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HomeMy WebLinkAbout12-2487Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. DAVID R STEIGELMAN 8 Robin Drive Shippensburg PA 172579484 Defendant C-) C r .? Z? <> r:)c,• X c} s n IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. /a - 0?g8J <nivi l Term 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 LJ Telephone No. 717-249-3166 or 800-990-9108 *103. n5 PD ATM C-56191 / 304 e* a74/W BURTON NEEL & ASSOCIATES, P.C. Yale D. Weinstein, Esquire, Id. No. 89678 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. DAVID R STEIGELMAN 8 Robin Drive Shippensburg PA 172579484 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 David R Steigelman who resides 8 Robin Drive, Shippensburg, 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 8217. 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 $14,029.01 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 $14,029.01, and the costs of this action. e' &Associates, P.C. TBO ale Dinstein, Esquire Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-56191 / 205 =m> 1/00 _ Z2. (A 0 U1 T Ln n n N r j O N Z A 2 r M ; M Z c ? ? ss O n:0 n r40-_+ WX z $A N Gu a, A W N tD y 9 pW i ? A a 4 ?q €y e? r? a It kr v le+ r O ru 31 O h+ k+ r O ru _o O 6+ t? O ru ..B O O O B- r De I if n n CL m l a a i ww.citlcards.com Account Member DAVID R STEIGELMAN Account Activity Account Number Sep 09-Oct 10, 2011 8217 Member Since 1995 Wellman Payment Due. New Balanc r $14,029.01 $14,029.01 Summary of Account Activity Previous Balance $13,80533 Payment Due Dab- Payments .00 11/06/2011 ~ its r ? loaltlmantlaepagm tddandells. Purc hases + . Late Payneert ¦arnh* If we do not receive your Cash Advances + Op p I givto m payment by theuudate 5?3st5ed aboo?veyou maayaY too your APR up to oo a ty 5 Fees Charged-- - - -+ 5-pp he be Increased t variable Pen l APR of 29 9996. va Interest Cliaryad +$iB9 (,g MlitYnstni Paytaaut ¦rnllW If you make only the New Balance 4,029.01 minimum payment each period, you will pay more In Past Due Amount $1,976.90 Interest and it will take you longer to pay off your balance. For example: Amt. Over Credit Limit $769.01 If you make no ' You will pay off And you Will and additional threes the balance shown up paying an Credit Limit ,. $13,260 us" this card and ' on this statement ealmated total Available CreGlt $p aaM month you pay In atwut_ of_ Cash Advance Limit $8.50'0 , Only the mhlmum 1 month(s) $14.029 Available Cash Limit --??-?s0 Payment _? _ Statement dosing Date 10/10/2011 F. into mNlan adoul cwt cowu?png errvlus ai i-en-mot-ales Days In Bliling Cycle 32 loft Now To Reach Us 1-800-THANKYOU Customer Service BOX 6500 SIOUX FALLS. SD 57117 Fees Sail Post Description Amount 10/10 LATE FEE - SEP PAYMENT PAST DUE 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Cher _ Post Description Amount 10/10 INTEREST CHARGED TO STANDARD PURCH 5055 10110 INTEREST CHARGED TO OFFER-004 7,97 10/10 INTEREST CHARGED TO PUR PR-05/31/10. - 130.56 TOTAL INTEREST FOR THIS PERIOD iBf16B 2011 Totals Yenta-Dab Total tees cM r"d In 2011 $200.00 ___._.__ .... _.... _ Total [merest cber"d in 2011 $1,690.61 Interest Charge Calculation Your ANWAN Percaatage pate (APR)Is the annual Interest rate an your accent. Type of Balance Annual Pereenlpe Rau (APR) Balance Beet to Interest Rate Interest Charge PURCHASES Standard Purch 18.990% (V) S3.012.30 (D) $50.15 Offer: 2.990% $3,04233(D) $7.97 Purch Prior 05/31/10 18.990% $7,841.84 (D) $130.56 ADVANCES Standard Adv 25.240% (V) SO.00(D) $0.00 How to Reach Us 1.800-THANKYOU Customer sorvk:e Box 6500 Accamt HumbM SIOUX FALLS. SO 57117 ............ 8217 Access ymr See*" onllnw IMPORTANT NOTICE ABOUT YOUR ACCOUNT Effective July 1, 2011, Citibank (South Dakota), NA., is merged into Citibank, N A. Ci b account. A Iich is i ce 4to in Sioux falls, Citibank (South D* ta , KA., in the account of ref ere and in documentation, including the Card Agreement, communications about your account should be deemed to refer to Citibank, NA Any optional program provided by Citibank (South Dakota), N A•, is now provided by Citibank, N.A. Help is available) Please tail the toll-tree number shown above to learn about our 7 am to 9 pm. or Saturday, 8 am to 5 special payment options. Call Monday Friday, Opportunity to assist you. pm, Central Time. Please give us the 2012 Verification I Tiene Reynolds , 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. V Signature C-56191 David R Steigelman Account number ending 8217 1000 SHERIFF'S OFFICE OF CUMBERLAND-COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 2012 MAY -3 PM 1: 54 cUMBEKAND GOUNT NNSYLVAN A 'J Citibank NA vs. David Richard Steigelman, Sr Case Number 2012-2487 SHERIFF'S RETURN OF SERVICE 04/26/2012 06:05 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 26, 2012 at 1805 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David Richard Steigelman, Sr., by making known unto Gertrud Steigelman, Wife of Defendant at 8 Robin Drive, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. i!az STEPHEN BENDER, DEPUTY SHERIFF COST: $48.00 April 27, 2012 SO ANSWERS, RbNI`V R ANDERSON, SHERIFF CITIBANK, N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. DAVID R STEIGELMAN 8 Robin Drive Shippensburg PA 172579484 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-2487 CIVIL TERM C:- Fri T.-I CIVIL ACTION - LAW ` C-D Praeci a for Default Judgment 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 $14,029.01 $14,029.01 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. ? JUDGMENT BY DEFAULT ENTERED AND AMAGES ASSESSED AS ABOVE. NOTI G PA.P.; . .236 Pila.,Pr o'h The law firm of Burton Neil & Associates is a debt collector. C-56191 / 221 & Associates, P.C. Yhk,'D. Weinstein, Esquire Attorney for Plaintiff I.D. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 #I(o.So PA ATTy dt laaaq ed71o78i( 2, ,& W led CITI$ANK, N.A. Plaintiff V. DAVID R STEIGELMAN Defendant TO: David R Steigelman 8 Robin Drive Shippensburg PA 172579484 DATE OF NOTICE: May 22, 2012 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-2487 CIVIL TERM : CIVIL ACTION - LAW IMPORTANT NOTICE C-56191 / 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 800-990-91 P.C. In making this communication, we advise our office is a debt collector. Yale D einstein, Esquire Atto for Plaintiff ldent' tion No. 89678 106 ndrew Drive, Suite 170 We Chester, PA 19380 (610) 696-2120 C . Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. Plaintiff V. DAVID R STEIGELMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 12-2487 CIVIL TERM : 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 La Prothono By w Deputy If you have any questions concerning the above, please contact: Yale D. Weinstein, 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.