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Home My WebLink About12-7861Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. N0.204140 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. m ~~-. , r-.~ L. ~ r v J ~ 4:... t C.n~ : •..e4 r.~' , ~ ~.. - --i , t :.. : "T7 C~ :.;: ~~.. I1V THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDWARD L GAMBLE NO. ~~ ~Jg(p/ Cj Vi I T rM 1060 Greenspring Road Newville PA 17241-9691 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 HIItING A LAWYER. IF YOU CANNOT AFFORD TO HIItE 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 x/03.75' Po /~~ C-52370 / 304 ~~ la 8ioy BURTON NEIL, & ASSOCIATES, P.C. Edward J. O'Brien, Esquire, Id. No. 32985 Brit J. Suttell, Esquire, Id. No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attornev for Plaintiff CITIBANK, N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. EDWARD L GAMBLE 1060 Greenspring Road Newville PA 17241-9691 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 Edward L Gamble who resides at 1060 Greenspring Road, Newville, 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 4318. 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. CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant :CIVIL ACTION -LAW 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 $2,015.26 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 $2,015.26, and the costs of this action. o eil ocia es, P.C. d d J. O'Bnen, Esquire By: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-52370 / 205 rn ~~ ~~ z-'m m~v~ O S+ p O~ O O W N 3: y 2 .N m ~ ~ N ~ ~mv p ^ . 0 0 3 O~ a U c r mr 3 ~Zp r> ~ ~ VI N N 3 N 01 n~ q w O v p~ ~ P~ ~Zmn o 3 a m O ,.r 0 ~o ~ av m o m ri~n ~O~ won wx~ c~v ~ N N O N 2 A A m A ~m ~3 g '^ .~. a~ m ~m ~ ~yyyOD~~~ i` 6 A 5 W e) ~o ;~ r W r O fU 0 to rL lT' 0 ru !-' In IU Q' O 0 O W O O O .~ r Iii g 3 n n a n u, 3 4. R 0 R Q i 3 2 S www.cltlcard;com Account Member EDWARD L GAMBLE Account Activity er~niint Number Mar 12-Apr 13, 2011 4318 Member Since 2008 Minimum Payment Due: New Balance: Summary of Account Act ivity $2,015.26 $2,015.26 Previous Balance $1,99A.A2 Fees Payment Due Date: Payments -$0.00 Sale a' 05/09/2011 aaitim onina a mantcu eo pM its h ° p y :d i. a P i cttases +S0.00 Late Payment Warninq: If we do not receive your minlmum payment by the date listed above you may Cash Advances +$0.00 Interest , have to pay a late fee of up to $35 and Your APRs mayy Fees Charged +$0.00 be Increased up to the vanable Penalty APR of 2A.999b. Interest Charged +$16.44 Minimum Payment Warninq: II you make only the New Balance 2,015.26 minlmum payment each period, you will pay more In Past Due Amount $384.64 Interest and it will take you longer to pay otf your balance. For example: Amt. Over Credit L.Imlt $0.00 If you make no ( You will pay oft And you will end additional charges ;the balance shown, up paying an Credit Llmlt $9,000 using this card and Ion this statement = estimated total Available Credit $0 each month you pay...!; in about... oL.. CashAdvance LImII $2,700 Only tiieminimum 1 month(s) 52 015 Available Cash Llmlt $0 , payment Statement Closing Date 04JI-i~2011 roc o,ro~maila~ abo~i ~~eali roan:eihy :e vice:, eau r-en-aai-eies. Days iii Billing Cycle 33 tofl How To Reech Us 1-A00-925-8A71 Customer Service BOX 6500 sloux FnLLS, sD 57117 Past. Description TOTALFEES FOR THIS PERIOD Amount 0.00 Post Description Amount 04/13 INTEREST CHARGED TO STANDARD PURCH q,9;~ 04/13 INTEREST CHARGED TO PUR PR-11/03/10. 11.49 TOTAL INTEREST FOR THIS PERIOD 16.44 2011 Totals Year-to-Date Total tees charged In 2011 $105.00 Total interest charged to 2011 $47.08 Interest Charge Calculation Your Annual Percentage Rata (APR)is the annual Interest rMe on your account. Annual Percentage Balance Sub ectto Type of Balance Rata (APR) Interest ate Interest Charge Standard Purch 28.990% (V) S18A.A7(D) $4.95 Purch Prior fl/03/10 6.990% (V) $1,817.40 (D) S11.49 ApVANCES Standard Adv 2A.9904k, (V) S0.00(D) $0.00 Our records show hollte phone 717-776-6515 and business phone I17-795-5520. If incorrect, please update your account online at www.citicards.com orcall us at 1-800-925-8871 to let us know. Verification I, Niidd L. Koch , 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. d Signature C-52370 Edward L Gamble Account number ending 4318 1008 C-52370/221 CITIBANK,N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. r•, NO. 12-7861 CIVIL TERM, E EDWARD L GAMBLE A 1060 Greenspring Road Newville PA 17241-9691 r-- ..- Defendant : CIVIL ACTION-LAW —:C C-) =9: =C) C Praecipe for Default Judgment ;r_ --.j C ) 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: $2,015.26 TOTAL $2,015.26 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 Burto it Associates, P.C. AND DAMAGES ASSESSED AS ABOVE. NOTICE G N ER CIV.P. By: d O'Brien, Esquire Att mey for Plaintiff Pro Protkono I.D.NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil &Associates is a debt collector. O_R� Ilk';)�.- d •Y�1 C-523 70/265 CITIBANK, N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-7861 CIVIL TERM EDWARD L GAMBLE Defendant : CIVIL ACTION -LAW TO: Edward L Gamble 1060 Greenspring Road Newville PA 1 724 1-969 1 DATE OF NOTICE: February 19,2013 IMPORTANT NOTICE 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 •�N Burt Neil ssociates, P.C. By: Edward J.O'Brien, Esquire Attorney for Plaintiff Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 In making this communication, we advise our office is a (610)696-2120 debt collector. r Burton Neil &Associates,P.C. By: Edward J.O'Brien,Esquire ID.NO. 32985 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. EDWARD L GAMBLE NO. 12-7861 CIVIL TERM Defendant CIVIL ACTION-LAW Rule of Civil Procedure NO.236 (Revised) Notice is give that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary By: ri Oft'. If you have any questions concerning the above,please contact: Edward J. O'Brien, 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. 06 Or 0 Tj_y�a 2013 P!1 t 'Jt1QERL P dS YrV,4 FOUNT y Burton Neil &Associates, P.C. By: Neil Sarker, Esquire ID.NO. 203465 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. NO. 12-7861 CIVIL TERM EDWARD L GAMBLE Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton Neil &Associates, P. . By: Neil Sarker, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-52370/318 �q.soPd a� 10# a93ooS