HomeMy WebLinkAbout12-2371I.
C F C F v C
,2 16
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 CUMBERLAND COUNTY, PENNSYLVANIA
V. /n
JANE WAGNER NO. /V 3 ???? ??
202 Gull Court
Mechanicsburg PA 170502056
Defendant 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
C-55728 / 304
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
05.
0qj'//9o37
/0#7a 7 3a7y
IN THE COURT OF COMMON PLEAS
BURTON NEIL & ASSOCIATES, P.C.
Trenton A. Farmer, Esquire, Id. No. 209422
Brit J. Suttell, Esquire, Id. No. 240140
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.
JANE WAGNER
202 Gull Court
Mechanicsburg PA 170502056
Defendant
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
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 Jane Wagner who resides 202 Gull Court, 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(n) AT&T credit card account (hereafter the
Account) with account number ending in 5579.
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 $15,951.72 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 $15,951.72, and
the costs of this action.
jBon 1 Associates, P.C.
T nton A. Farmer, Esquire
/By: Brit J. Suttell, Esquire
In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector.
C-55728 / 205
c j O
o v M1
17
a'
N •
N u
7 j0 VO1
?In (4
vV ?JO
.v ?D m
E a ° off
a'
C .? N n
O N `J = O
O N ? i
O ? >
N N
N
c° ? y o
$ 0 0
8 0 ? c
J N
•
-n Eo<?
'r•
? n --
oo
?
o
L.
s
_
ro
S Ua?u) ¢ D
C] D C S W
t IL b e V O
!2
a " • M
W a _ • _
r a
L N vri W0 Y
s1
O.O 12
rip
o
p
14
E
(a l
. 0
tj
CA Q K Q O /M O i o f
Q_ S S W tV s ?, C C
W
tJ ••F=
d:W
W ±J V
•
p T
?'
1e N ?"' .
N W.W !? 1
.
N M
E z:z i j to o .7 9
u at j ° o o
a
Q
44 ,?
° .N N • is
Y Y
O
r'4
W
3
?? t da
a a O~ O= O
O W
uz E s 2 `w "y! M
<a 2
c
at ,
=
u
p
O O O'S 84
0110
r 00 O
O
O 0 0 0
O to 0 0 M
,,po uI(??
pN
?
O
12 ^ IO O rn. In' ?.
.
u
sNM
,? ? ? N I 111 - ,O. Q; '.Ni
N
4'{
.u 1Ai l?
N N
'T
O,
T u
a
d.
?
r
Cc, a! v U E E'c'>
V
d C V PJ J ,U
V N 7
< z p
a ?? d _d <O
NI
O
- ? O >
E¢ ` C,y.r'O gip.
tJ C
_ C L
m?
mi a
{,J
> N H > 2 C
,U N v tJ U
C d> d Cm
ca a 1.5
u a u
u u >:E E d `.c.N
it
E or N a..
rrp m
;>
<Q < o ?^ 0 m y
HCL 0CLut.._° 0 m
z a a y
v> >.
?.atja.c,, o
or - Eao, c _°eo m
61 >°EaN >oo s5Y ! a
N °>3 i>a`6 o E?
ti p o; "=qt
v>o>a
a %p ?>
a •
U
o
0 u°
: E 021g?
7
o0
m In ? ..lnyy
'. a u,Na b >' Orn
31
°
a u w p? S
3 02
p CO
a ? M
_
«
71 E
ei
gi?A o t}
Z
°°"c
s
4,
y CD OI t,,, Y N ,b
;"?
°
_0
....
`
r
-0 -E iE r= oo.415
E x
'v
I"
Iva
11(m
E A g°? Boa Jr=NOj
6 0z
c
ifEyc ?iEa
E Ifl E?
-oe'
O
? t
U
U
U
U ?
r
C
« ? o
u .• ' ? p
D ?
N N ? ? ti
•V N N
ut! T T
T rn
+? - ^ a'
• c o
a CC
n N O
?" h6l\?
S N Il e-
5-5 , Eta "H
W. P+td amwht Paid truck It Delilah end follow payment Instructiewo an reverse,
WKWA tleenaWAULeatt MeteahowtPeyeweltp:AT&T UnIV9rsal Card
5579 1595172 1595172 0023200 0818
New Balance:
415.951.72
minimum Payment Due:
$15,951.72
Payment Due Date:
10/00/2011
000000 PW 32 A 0
JANE WAGNER
202 GULL CT
MECHANICSBURG PA 17050-2056
3579
Amount Enclosed:
>aymeht mast be I-egVed by 5:00 PM
-` time W the Payment due date.
AT&T UNIVERSAL CARD
P.O. BOX 182564
COLUMBUS, OH 43218-2564
V1 7'
a ...r 4 7i
-Y'Irj'_
9
0
a
N
Y
C
J
3
3
3
D
in
•
?N Y ? Y
CO ! h
? co O O "f
q ?fl NOJ
it r 0 Q >
+N OOX N
;
Z mo NOO Y
0 co :3
:E U G of <
d ?
a?
N
E?
V
r? 0
0
N
wi
e
o
u.. S O
mac
N N ? w
Cr
q C
m
ia' O
5 i?l
dM ', N
-441
0
9
u
U
d ?
o ?
L a
u w'?a
m w a
U
m O < a
T
O
Z _
O T
1 C 7 a
a
-0
M 1 7 .0
O
n
° n v
'a n 3 c 3
O
o N o
' V
c?
off
2
m
a ? N
?Q E z
.
C+ Oz O O
n °a Q ?Q MZ
.O O Z to =++Y O
c W Z vP 0
p Y mNE°
a
VI
i 7
V
? ? -_. N !"
x Y d (j C,
?
'may V 7?0?0 .-
y'o a
0 n:.a v >
v =o v cvMy a
yL„
Y p U
a., a
' Y N
a
ma
V ? ? ?o via
UC
TC
CO a u
0,v
i
d o
4
v'' w U C
ry=v E
a 0 V _ ? lu W
Z Z .= 3Q ca n
E
F- >
7 p 7
QC?.0
r6
Z Z ?'yo,t
u C? CZ
p
,p 4 ? ? 1 .
Y
cx
N d
d
' d
?
V 0 -0
C
`w 0
u>ap?' au
0
N
Verification
I, Lisa Blunw , am employed by Citibank, N.A. (hereafter Citibank), which
is successor in interest to Citibank (South Dakota), N.A. 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.
??
Signature
C-55728
Jane Wagner
Account number ending 5579
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
t
C?FF,CE --_ *- :"-. RIFF
' 1LE 0-sl lCr-
2012 MAY --8 AM 9: 55
CUIr° RLAND COUNTY
PE" YLVANIA
Citibank, NA
Case Number
vs. 2012-2371
Jane Wagner
SHERIFF'S RETURN OF SERVICE
04/23/2012 08:22 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 23,
2012 at 2022 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jane Wagner, by making known unto Ron Brown, adult in charge at 202 Gull Court,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
April 26, 2012
DENNI RY, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) icuntySuite Sheriff, Teleoso`t_ Inc-
•? a
CITIBANK, N.A.
701 East 60th Street N,
Sioux Falls, SD 57117
Plaintiff
V.
JANE WAGNER
202 Gull Court
Mechanicsburg PA 17050-2056
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 12-2371 civil term -:.71 +
rr C=
77-5
CIVIL ACTION - LAW = -? -
Praecipe for Default Judgment r
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
$15,951.72
$15,951.72
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unswom 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 GIVEN UNDER PA.R.CIV.P.23i
Pro
Burton Neil & Associates, P.C.
By: -?
Trento 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-55728 / 221
sig. sa ?E4t
/
CITIBANK, N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 12-2371 civil term
JANE WAGNER
Defendant : CIVIL ACTION - LAW
TO: Jane Wagner
202 Gull Court
Mechanicsburg PA 17050-2056
DATE OF NOTICE: May 16, 2012
IMPORTANT NOTICE
C-55728 / 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.
By:
Tr on 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. IN THE COURT OF COMMON PLEAS
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
JANE WAGNER
NO. 12-2371 civil term
Defendant : 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 r
1
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.