HomeMy WebLinkAbout13-2257 Supreme Court of Pennsylvania otProtl
ion
ntary UseOnl
Court of Common Pleas o.. E "
Civil Cover Sheet
CUMBERLAND County
The in formation collected on this form is used solely for court administration purposes. This form does not
supplement or replace the . filing and service of leadin s and other papers re quired by law or rules of the court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from Another Jurisdiction 11 Declaration of Taking
E Lead Plaintiffs Name: Lead Defendant's Name:
C CITIBANK, N.A. LAURIE C RUDOLPH
T
I
O Any money damages requested ?: ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
Name of Plaintiff/Appellant's Attorney: Brit J. Suttell, Esquire
❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant)
E
nature of the Case Place end "W';'` to the 1`afk oftle, ONE case categorythat must accuratlyE clescnbe your ..
t'ItIMA RY CASE. If ou are #0 than one type z6fclairb c eclC the pne that
s 'yop coil i er mast txnportan �� Y,
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Possession ® Debt Collection: Credit Card ❑ Board of Assessment
S ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
E ❑ Nuisance ❑ Depart. of Transportation
C ❑ Premises Liability ❑ Statutory Appeal: Other
T ❑ Product Liability (does not ❑ Employment Dispute:
I include mass tort) Discrimination
O ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
N ❑ Other: ❑ Other:
B ❑ Other:
MASS TORT
❑ Asbestos
❑ Tobacco
• Toxic Tort - DES
• Toxic Tort - Implant
❑ Toxic Waste
❑ Other:
REAL PROPERTY MISCELLANEOUS
❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
• Dental ❑ Partition ❑ Replevin
• Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
E HO, Cr
O TA p r'
2013 APR 2S AH 10: 08
CUMBERLAND COUNTY
PENNNSYLVANIA
Burton 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. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
V. Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
LAURIE C RUDOLPH NO. I J' ��S? .I I
27 Hamilton Road
Boiling Springs PA 17007 -9761
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
Carlisle, PA 17013
Telephone No. 717- 249 -3166 or 800 - 990 -9108
C -60564 / 304 n,,A
y
BURTON NEIL & ASSOCIATES, P.C.
Yale D. Weinstein, Esquire, Id. No. 89678
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. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.
LAURIE C RUDOLPH
27 Hamilton Road
Boiling Springs PA 17007 -9761
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 Laurie C Rudolph who resides at 27 Hamilton Road, Boiling Springs,
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 The Home Depot credit card account (hereafter the
Account) with account number ending in 7974.
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 $3,590.58 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 $3,590.58, and
the costs of this action.
I,,-yvy: tes, P.C.
n, Esquire
. quire
In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector.
C -60564 / 205
Account Statement
Send Notice of Billing Errors and Customer Service Inquiries to:
�►■ Customer Service: HOME DEPOT CREDIT SERVICES
{�}
myhomedepotaccount. corn PO Box 790328, St. Louis, MO 63179
Account Inquiries:
��• ® 1 - 866 - Accot nf`3Vt rFiE
58 -7683 -
Summary of Account Activity Payment Information
Previous Balance $3,477.87 New Balance $3
Payments -$0.00 Minimum Pa ment Due $674.00
Other Credits -$0.00 Payment Due Date January 20, 2013
Purchases _+$0.00 Late Payment Warning: If we do not receive your minimum payment by the
Fees Charged +$35.00 date listed above, you may have to pay a late fee up to $35.
Interest Charged +$77.71 Minimum Payment Warning: If you make only the minimum payment each
New Balance $3,590.58 period, you will pay more in interest and it will take you longer to pay off your
Past Due Amount $525.00 balance. For example: _ -
s I1�ak FaTdtfkriat SW Matf
� �ftaigr��9sir�fH{& �al`d�� " si�s�vn tsrl tkns, ��h�r.�P pa�il?g�r
" 2frle each rt)t�nztr�toupa�ie f `'statsm�rtt Iii ab_6u_ . " t� e ii _ at$cY tdta+ 41
Credit Limit $0.00 s - ff1 _
Available Credit $0.00 Only the minimum payment 22 years $9,302
Statement Closing Date 12/24/2012 $145 3 years $5,207
Next Statement Closing Date 01/24/2013 1 1 1 1 (Savings = $4,095)
Days in Billing Cy 31 If you would like information about credit counseling services, call 1- 877 - 337 -8188.
Your minimum payment due is $674.00. To avoid interest charges on your non - promotional (revolving) balance and any expiring promotions, pay $3,590.58 by January 20,
2013. If you pay your non - promotional balance in full every month, no additional billed interest charges will apply. Interest accrues daily from your statement closing date until
we receive your payment, so please check your next statement for any additional interest you may have incurred.
TRANSACTIONS
Trans Date Description Reference # Amount
FEES
12/20 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD $ 35.00
8HD15
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, N.A.
---------------------------------------------------------------------------------------------------------- -- ------------ - - - - --
I' Please detach this portion and return with your payment to insure proper credit Retain upper portion for your records. +
IM tPast Due Amount is included in the Minimum Payment Due.
-_'nu AccoriitNkttitie >>" Payment Due Date New Balance I Past Due Amountt Minimum Payment Due Amount Enclosed
?94k' JANUARY 20, 2013 $3,590.58 $525.00 $674.00 $
7974035905800146000067400101
Make Checks Payable to:
HOME DEPOT CREDIT'SERVICES
PO BOX 182676
LAURIE C RUDOLPH COLUMBUS, OH 43218 -2676
27 HAMILTON RD
BOILING SPRINGS, PA 17007 -9761
FXI-IIBIT A
Print address changes above in blue or black ink.
frifornr&#fan Aa�e€it'Your Arcaui+t.
How to Avoid Paying interest an Purchases.Your payment due date€sat least 25 days after the Not Will iiapFeh der ft's ig�cef�$Ytitir Lefton
close of eactu billing:pole.We Ductl not chargeyouu any imlerest on purchases if you pay your New When we receive your letter,we must do two things:
Balance by the payment due date each month.This is rolled a grace period on purchasm if you do f Within 30 days of receiving yawn iettef we narsttel€you that we received your 1Bttec €e wilt also
not pay the New Balm in full try the paymerrzdue date,you will not get a grace period an purchases loll you n 30 have already corner your the error.
until you pay the New Balance in full for two billing cycles in a four.
tf you have a lag€arr�subject to a def6rred i,r crest ar 0 APf#promotion and that promotion lass not believe the belays=�wing your ,leGes vie rrnist either corrnz t fi?e error or explain to you why we
expire be ore the pap neat due date,that bafarce{6aB`excluded baler e°) is e rJuded from the While we investigate whether or not there has been an error:
amount ecru must pay in#u!1 to get a grate period.However,ecru must still pay any se�rately rreeqquired
payment an the excluded balance.!n boiling cyc 6s€n uu itch payments are al€oratad to deferred °6Me cannot u f to collect khe amaunt in auestia r,or rrortyou as delinquent on that amount
interest bat?znces fret,the defer eel intermit ba€ance writ fro reduced before erne ether balariee on the *The charge in question may remain on your statement,and we fray coottrim to charge you interest
Scoot nt HoweiBr,you wits continue fo get a gta 2 period on purchases so tong as you ay the New on that amount
Balance tee any B;,cfuded balances in full by the paymer t dice data each hitting cycle. e may refer a Vilille you do net have to pay the amount in question,you are responsible for the remainder of
to de€rx eel interest pramatiorus as No€derest premofions. your balance.
In addition, certain promotional offers may take affray the grace period on purchases. Other *We mn apply any unpaid amount agalnst your credit limit
promotional offers eat described above may also allow you to have a grace period on purchases After we finish our investigafon,one of two things will happen
without having to pay all or a pumice of the promotional balance by the payment due date if either is a It ive made a mistake:You will not have to pay the amount in question or : interest or other tees
Me case,due promotT�€offer vr1l dB,�crtbe what happens. ar`l
related to that amount
Now We Caicmfafe Your Balance Subject to Interest Rate. For each bmlarueB,the fetter a it w.
,do notbelrwve then?Baas ainistake:You will have to pay the amount in question,along with.
following the Annual Percentage Rate in the Interest Charge Calculation section on the front of the applicable interest and fees.We wit send you a statemarit of the amount you owe and the date
statement indicates the method we use to calculate interest charges.For Methods C.H and M,we use payment is due.We may then report you as delinquent if you do not pay the armours we think you owe.
a daily balance method(including current transactions)to calculate interest charges.For Methods I y
and L,we use an average daily balance method(including current transactions)to calculate interest If I cu receive our explanaation but stilt believe your bill is wrong,you must write to us mthin Ill dM
charges.For Method K,we ire an average daily ba�nce r (excluding current transactions)to to ling us that you still refuse to pay.If you do so,we cannot report you as delinquent withoii also
calculate interest charges.To find out more information about the balance computation method that reporting that you are questioning your bill.We must tell you the name of anyone to whom we reported
applies to your account and Prow the resulting Interest charges were determined,contact us at �as delinquent, and we must let those organizations know YiNri the matter has been settled
Customer Servic?,number on the front. veen us.
Cmdf#Reporting disputes.#f you lhinkwe reported inaccurate information to aciedif bureau write If we do sot faifow all of the rules above,you do not have to pay the first$50 of the amount you
us at the Customer Service address shown on the tronL question even it your bill is correct.
Report a Lost or Stolen Card immediately.Call the Account inquiries number shown on YearN'rrghls ff Yon Are Dissadsf od Ylfth Your Credit Card ftrfiases
the front If you are dissatisfied with the goads or services that you have purchased with your credit card,and
tit ke To go It Yeir Find A N.1,41vke On Yuan•Stalvment you have tried in good faith to correct the problem with the merchant,you may have the right not to
if you think there is an error on your statement,write to us at the address for billing inquiries and pay the remaining amount due an the purchase.
correspondence sham on the front of your statemerd. To use this right,al of the following must be Ir
In your letter,give us the following information: 1.The purchase must have been made in your home state or within 100 miles of your current
a rr nnf inforaraflon:Your frame and mount number. mailing address,and t4 purchase price must have been more than$50.(Note,Neither of these
+,Dollars-,so=nata The dollar amount of the suspected error. are necessary if your purchase wro based an an advertisement we Trailed to you,or if via own the
Dascr:Atirn nfproblam:(f you think there€s an error on yadr bill,describe wtiatyou believe is wrong company that sold you the goods or services.)
and why you believe it is a mistake. 2.You must have used your credit card for the purchase.Purchases made with cash advances from
You must contact us: an ATM or with a check that accesses your credit card account do not quality.
v Within 60 days after the error appeared on your sialement 3.You n1ust not yet have fully paid tar the purchase.
*AU least 3 business days before an automated payment is scheduled,It you want to stop payment an
the amount you think is wrong. if all of the criteria above are met and you are still dissatisfied with the purchase,contact us in tw tJng
You must notify us of any potential errors in ivrft.You may call us,but if you do we are not required at the address for blllf ng€nqufries and correspondence shown on the front at your statement
to investigate any patentrai errors and you may have to pay the asnoourd in question. While we Investigate,the same rules apply to the disputed amount as discussed above.After tar;finish
our investigatican,vie will fait you our decision.At that point if we think you owe an amount and you
do not pay,we may report you as delinquent.
KAY CREDfT TERMS—NO MTEREST IF PAID IN FULL WITHIN 6 MONTHS*.$299 minimum panchase required.Minimum payments required.linterest will be charged to your
account from the parch.ifate it the purchase h2lama(Including premiums tar optional credit Insurance)Is not paid in full within 6 months or ft your make a Iota payment.
'With credit approval for qualifying purchases Trade on The Home Depot or EXPO Design Center Consumer Credit Card,17.99%-26.99%APR.Minimum interest charge:$2.See card agreement for
details including APR applicable to you.Offer is only valid for consumer accounts and is subject to change without natice.
Important P2ymerst Instructions- Payment Options Other Than Regular Mail.
Right to Prepay Your Account.You ma pay+all or part of your amount balance at any time. a tlnlins Payments. Visft myhomedspolaccountcom and sign 4 for free online payments
Hoviever,you must pay.by fife payment due date,at least the minimum payment due. Enrollment may take a few days.If we receive your request to make an online payment by 5 Jr pp
t edl" Paymaots-tf we receive your malted pa in proper form aI our processing facility by Eastern time,vie will edit your payment as of that day grid it will post within three business uiay:
5 p.m.towel time lhcre,d will be cued tad as of tfiaY r yA part newt received there in proper fora t after €f we receive your request to make an onl ine payment attar that tirr ,we will credit your payment a
final time will he credited as of the next d.-y.Allow 5 to 7 days for payments try regular maul to reach of the newt day and It will t within three business days.For security reasons,you may be unab€
us.There ray a delay of up to 5 days€n erBdrfng a pay�nentvre receive that is not In proper form to pay your entire New Balance vi€ih your first online payment
or is net sent to the correct address Tire eatrectaddress for regular r fait€s tfiB address an itre front of *Aulofty Service.It you are enrolled€n this service,your payment amount will be deducle
the paynent cm;ton.The corm t ac#drBSS far onurler or express mal I is tfaB Fxpress Payme'is address automatically each month on your due date from the bank account you select.
shown be€ovr.
Proper Form.',:or a payment sent by mail or courier to be in proper form,you must: o Pay by Phone Service.You may use this service a%time to make a payment by phone,if you
account is eligible.You will be charged$14.95 to use this service P a representative of ours help
• Enclose a valid check or money order made payable to Home Depot Credit Services.No rash, expedite your payment.Call by 5 p.m.Eastern time to have your payment credited as of that day an
gift cards,or foreign currency please. posted within three business days.It you call after that time,your payment will be credited as of th
• Include your name and account number on the#rent of your check or money order next day and posted within three business days.We may process your payment electronically at
It you send an eligible check with this payment coupon°you authorize us to complete we verify your identity.
your payment by electronic debit°It we do,the checking account will he debited in the *dress Payments.You can send payment by courier or wgmss mail to the Express Paymm
amount an tie check.We may do this as scan as the day vie receive the check.Alga, Address. This address is: Customer Service Cents Attention: Payment Mail opening, 15c`
the check will be desl€oyW. Bofionfield St,Calurnbus,OH 432211 Payment must be received in proper form at the prop
Copy Fee,We chame$5 for each copy of a billing statement that dates back 3 months or snore.We address by 5 pm.Eastern time to be credited as at fiat*All payments rived in proper form
add the fee to a glance of our choosing.We reserve flue fiat to add this fee to balances subject to a the Proper dress after that time will be credited as of the next day.
higher annual percentage rate.We waive the fee if your request for the copy relates to a bil ling error or a in-Store Payments.For your added convenience,payments can be made at The Home Depo
disputed purchase. stores,with no service fee.Arry payment in proper farm accepted In-store will be credited as of tt
day.Howevu,credit avellability may be subject to ver€ficabon of hinds.
T02364-9196-0400-0002-E-34-X–Oa=01/07-76-113-P--O-Y-4-M-NOPrAY--06/22/12-W17B-Nnvember23,2012-0A N— HD/U UL12
Page 2 of 4
Account` 7974
_TRANSACTIONS(cont.)
Trans Date Description Reference# Amount
INTEREST CHARGED
12/24 INTEREST CHARGE ON PURCHASES $ 7711
TOTAL_INTEREST FOR THIS PERIOD $ 77.71
Total Fees Charged in 2012 $280.00
Tatai interest Charged in 2012 $948.46
INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account.
__ .. .-�-�..-__..:�.,,_--,..,_-rt.:._:..s...o -�..r,.,;:---•_-�;.._ _ ••-:�;-:�. - _ =ors `;�'. :�-rs
-
.. .� -.. .. -
' :rf:s..e..
�Fy�e:,otBaianee-a�,:�_;
PURCHASES
Revolving Balance 25.99% M $3,520.92 $77.71
Page 3 of 4
v., s
Account: 7974
Page 4of4
e.
p • J, - _
Verification
I, KATHY RIZOR , 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 unworn falsification to authorities.
JSignae
C-60564
Laurie C Rudolph
Account number ending 7974
1025
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FlED-OFFICL'
Sheriff OF TPFPROTHIP40TAR)
Jody S Smith
Chief Deputy cil , 2013 MAY 13 AM 10: '-37
Richard W Stewart CUMBERLAND COUNTY
Solicitor CW-FICE OF THE 544ERWP PENNSYLV-ANIA
Citibank, N.A. Case Number
vs.
Laurie C Rudolph 2013-2257 I
SHERIFF'S RETURN OF SERVICE
05/03/2013 06:20 PM-Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint&
Notice by"personally"handing a true copy to a person representing themselves to be the Defendant, to
wit: Laurie C Rudolph at 27 Hamilton Road, South Middleton Township, Boili S ngs, PA 17007.
IUL
S:;0 boill SHALL,-1b;EPMV--
SHERIFF COST: $41.56 SO ANSWERS,
May 06, 2013 RbNW FANDERSON, SHERIFF
(c)CountySuRe Shedtl,Teleosoft.Inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson LED-0FFICE
Sheriff OF THP_ Prr',OTVIMOTA.,�)
Jody S Smith
Chief Deputy 2013 MAY 13 AM 10' 37
'4s
Richard W Stewart CUMBERLAND COB TY
Solicitor CP PENNSYLV.ANIA
Citibank, N.A. Case Number
vs.
Laurie C Rudolph 2013-2257
SHERIFF'S RETURN OF SERVICE
05/03/2013 06:20 PM- Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Laurie C Rudolph at 27 Hamilton Road, South Middleton Township, Bloili,. S 'ngs, PA 177007.
S A SHALL, 6EPUTY-
SHERIFF COST: $41.56 SO ANSWERS,
May 06, 2013 RbNW R ANDERSON, SHERIFF
(c;)CcuntySuite Sheriff, oleosoft,Inc.
C-60564/221
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. 13-2257 CIVIL ==
LAURIE C RUDOLPH "le;
27 Hamilton Road
r�� c r
Boiling Springs PA 17007-9761
Defendant : CIVIL ACTION-LAW
C c —o c71
Praecipe for Default Judgment = r%) ±'
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: $3,590.58
TOTAL $3,590.58
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 eil & 4 soc'=tes, P.C.
AND DA -- ES SE • 1 AS ABOV
NOTICE G N U► `ER .R.CIV. ' By.
.4re D. einstei Esquire
ttorne, ' aintiff
Pro Prot onotary I.D. NO. 89678
1060 Andrew Drive, Suite 170
West Chester, PA 19380
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.
Ok* Sc)/6116
� •Y�ti
140k1Lt Aoci1eitt taaPiSD
C-60564/265
CITIBANK, N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 13-2257 CIVIL
LAURIE C RUDOLPH
Defendant : CIVIL ACTION - LAW
TO: Laurie C Rudolph
27 Hamilton Road
Boiling Springs PA 17007-9761
DATE OF NOTICE: June 04, 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 thee 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 800-99! Ili
Burt. Neil . s ociates, P.C.
•
o-1 1' • B):
Ya e D. We stein, Esquire
Attorney fe.r Plaintiff
This is an attempt to collect a debt, and any information Identi c. ion No. 89678
obtained will be used for that purpose. This 1060 ►drew Drive, Suite 170
communication is from a debt collector. West hester, PA 19380
(610) 696-2120
cc: William P Harrington Jr., Esquire
1400 Oaks Street
Coatsville PA 19320
•
, .
Burton Neil&Associates, P.C.
By: Yale D. Weinstein,Esquire D.NO. 89678
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. 13-2257 CIVIL
LAURIE C RUDOLPH
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 )\-)Y\e
Prothonotary £r,
4 b
By:c.
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
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.
;11'7: PrWitr
Z714 JUiV -2 Pt:
CUNBERL. A ND COUNT
PENNSYLVANIA
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. : IN THE COURT OF COMMON PLEAS
V.
LAURIE C RUDOLPH
To the Prothonotary:
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 13-2257 CIVIL
Defendant CIVIL ACTION - LAW
Praecipe to Satisfy Judgment
Mark the judgment Satisfied .
Burton Neil es, P.C.
By:
ale D. Weinstein, 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-60564 / 318