HomeMy WebLinkAbout12-0830FILED-OFFICE
L"r THE PROTNCNO IARY
Burton Neil & Associates, P.C.
By: Trenton A. Farmer, Esquire ID. NO. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
CITIBANK, N.A.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
STEPHEN WENGER
916 Williams Grove Road
Mechanicsburg PA 170558000
Defendant
2017 FEE -9 Ali 10: 5 E
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. a C- S2>0 ? ? V L I
CIVIL ACTION - LAW
Complaint - Notice
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to
the claim set forth against you. You are warned that if you fail to do so, the case may proceed without
you and a judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERENCE AND INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
C-55732 / 304
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BURTON NEIL & ASSOCIATES, P.C.
By: Trenton A. Farmer, Esquire, Id. No. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
STEPHEN WENGER
916 Williams Grove Road
Mechanicsburg PA 170558000
Defendant CIVIL ACTION -LAW
Complaint
1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street
North, Sioux Falls, South Dakota.
2. Defendant is Stephen Wenger who resides 916 Williams Grove Road,
Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff is a national banking association, engaged in various types of banking
business including consumer lending through the issuance of credit cards.
4. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to
Citibank (South Dakota), N.A., by means of a credit card account (hereafter the Account) with
account number ending in 4813.
5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011.
6. Accurate records of all debits and credits to the Account were maintained by plaintiff.
7. Defendant was provided with monthly statements for the Account including the billing
statement attached hereto as Exhibit A (redacted to remove confidential information). The
monthly statements accurately stated the previous balance and the debits and credits to the
Account for the prior billing period.
8. Defendant had for many months after receipt of a billing statement made payment on
the Account or retained the statement without payment.
9. Defendant retained the Exhibit A statement without making payment by the stated due
date.
10. Defendant's assent to the Account balance set forth in the Exhibit A statement is
manifested through the prior conduct of defendant either making payment on the Account or
retaining the statement without payment, after receipt of the monthly billing statements.
11. As a result of said assent, an account stated for the sum of $5,588.94 exists which
sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent
to the date of Exhibit A.
Wherefore, plaintiff demands judgment against defendant for the sum of $5,588.94, and
the costs of this action.
Burton Neil & Associates, P.C.
By:
Tre n A. Farmer, Esquire
Attorney for Plaintiff
In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector.
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•tatr Pad amount Pad enact it
DateM ee/ IeNae1 PeYnltttt Ibetwathae an revaew
Www.t:ItleMA&GIN Maaecbeetee"abetoCM Cards
4813 0558894 0558894 0041600 1018
4ew Balance:
s3.3et11.94
minimum Payment Due: 4813
Amount Encfoa4mk
$3,317113.94
?ayment Due Date:
10/10/20M - lymmt mutt be recNred by S:00 PM
local time m tM Payment due date.
000000 PM 32 A 0
STEPHEN WENGER
916 WILLIAMS GROVE RD
MECHANICSBURGPA 17055.8000 CITI CARDS
P.O. BOX 182564
COLUMBUS,OH43218-2564 EXHIBIT
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Verification
Tena Reynolds
I am employed by Citicorp Credit Services, Inc. (USA)
(hereafter CCSI), a subsidiary of Citibank, N.A. (hereafter Citibank), which is successor in
interest to Citibank (South Dakota), N.A. CCSI is a service provider for Citibank in that it
services credit card accounts owned by Citibank This includes accounts previously owned by
Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am
authorized to make this verification on behalf of Citibank. The statements of facts set forth in the
complaint are true and correct upon my information and belief and are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
0
Signature
C-55732
Stephen Wenger
Account number ending 4813
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
etc.
Ronny RAnderson EO-OV F .? ..
PP^T????;?1? i
Sheriff -
4?t14'4t E.44t1ltxt?.?4nb
Jody S Smith ZM2 FEB 23 AM $; 46
Chief Deputy
N 1 y'
Richard W Stewart CUMBERLAND C
s1f
Solicitor PENN-
Citibank, NA
vs.
Stephen Wenger
Case Number
2012-830
SHERIFF'S RETURN OF SERVICE
02/14/2012 03:22 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
14, 2012 at 1522 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Stephen Wenger, by making known unto Cindi Wenger, Wife of Defendant at 916
Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $38.00
February 15, 2012
TIM K, DEPUTY
SO ANSWERS,
RON ~ R ANDERSON, SHERIFF
CITIBANK, N.A. : IN THE COURT OF COMMON PLEAS
701 East 60th Street N, Sioux Fal ls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANI A
r . Gm;1
V. i
00
NO. 2012-830 CIVIL M c?3 - k
STEPHEN WENGER 'r 7J -" r
916 Williams Grove Road - ? N
E
Mechanicsburg PA 17055-8000
Defendant : CIVIL ACTION - LAW = o r°
.. °r',
Praecipe for Default Judgment ,
To the Prothonotary:
Please enter judgment by default for want of an answer in the above case in favor of the
plaintiff and against the defendant, and assess damages as follows:
Principal:
TOTAL
$5,588.94
$5,588.94
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment debtor and creditor.
2. The annexed notice of intention to file this praecipe was mailed to all parties against whom
judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least
ten days prior to the date of the filing of this praecipe.
3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA),
the defendant is not in the military service of the United States based on information received from
the defendant and/or the Department of Defense website.
JUDGMENT BY DEFAULT ENTERED
AND DAMAGES ASSESSED AS ABOVE.
NOTICE (1?VEN kNDE?t PA.R.CIV.P. 6
Y , J
Pro Prothonotary-
Burton Neil & Associates, P.C.
By:
Trenton A. Farmer, Esquire
Attorney for Plaintiff
I.D. NO. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
The law firm of Burton Neil & Associates is a debt collector.
C-55732 / 22.1
.so0 d_ l
fZ#?73ataa
MAU' mdilgdi
CITIBANK, N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2012-830 CIVIL
STEPHEN WENGER
Defendant : CIVIL ACTION - LAW
TO: Stephen Wenger
916 Williams Grove Road
Mechanicsburg PA 17055-8000
DATE OF NOTICE: March 13, 2012
IMPORTANT NOTICE
C-55732 / 265
You are in default because you have failed to enter a written appearance personally or by attorney and file in
writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10)
days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your
property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer,
go to or telephone the office below. This office can provide you with information about hiring a lawyer.
If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that
may offer legal services to eligible persons at a reduced fee or no fee.
LAWYER REFERENCE AND
INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
In making this communication, we advise our office is a
debt collector.
Burton Neil & Associates, P.C.
B V.
Trenton-A'Farmer, Esquire
Attorney for Plaintiff
Identification No. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Burton Neil & Associates, P.C.
By: Trenton A. Farmer, Esquire ID. NO. 209422
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK, N.A.
Plaintiff
V.
STEPHEN WENGER
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2012-830 CIVIL
CIVIL ACTION - LAW
Rule of Civil Procedure NO. 236 (Revised)
Notice is given that a JUDGMENT in the above captioned matter has been entered
against you on y la l/ a
Prothonotary
By:
Deputy
If you have any questions concerning the above, please contact:
Trenton A. Farmer, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
The law firm of'Burton Neil & Associates is a debt collector.