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Home My WebLink About05-0024 " BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. JAMES F P ARODA 9 Stephen Road, Camp Hill P A 17011-1156 Defendant NO. OS- - :J.l.f c/o; {IVL"\. : 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 TillS 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. TillS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO illRE 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-4373 BURTON NEn.. & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff : IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. OS -;(Lf C.ic..>~L'--r€rL~ JAMES F P ARODA 9 Stephen Road, Camp Hill, P A Defendant : crvn.. ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is James F Paroda, who resides at 9 Stephen Road, Camp Hill, Cumberland County, Pennsylvania. 3, Plaintiff, a national banking association, engages in various types of banking business including consumer lending through the issuance of credit cards. 4, Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180342147839 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7, Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection, 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $9,427.93. Wherefore, plaintiff demands judgment against defendant for the sum of $9,427,93, and the costs of this action, BuRTON IL & rcrTES, P.e. By: (d'" ~. .. .-.-..-BttrtoIlN ed, Esquue Attorney for Plaintiff The law firm of Burton Neil & Associates, P,C, is a debt collector, 09/20/04 $9427.93 $9999.99 SITE: KC-CL .-.......-............... ::::P.MOj::::ooi:::~;.tn::::;:;: ...,...,.-..','-.--.----. .....-.......".-.....-... ~~~~fii~~~itifi~~~~~~ ~~~~~ii~~~~~~~~i@~~~~~ C ITI CARDS P.O. BOX 8115 S HACKENSACK, NJ 07606 -8115 JAMES F PARODA 9 STEPHEN RD CAMP HILL 17011-1156000 PA Citi~ Platinum Select~ Card AC(ount NUIlIber 5424 1803 4214 7839 CUstomer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS, SD 57117 Total Credit Line $7700 Statemnt/ Closln9 Date 08/23/2004 II.valklble Credit Line $0 Amount Over Credit Line $1727.93 Cuh Advan~e Limit $3250 Available Cash Limit $0 Purch/Adv "Un/mum DUll ~229.28 Past DUll $982.17 Sail Date Post Date Relerence Number 8/23 8/23 8/23 8/23 8/23 Account SUmmary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 02/20/2004 ADVANCES Standard Adv Activit, SInce Lest Statement Standard Purc:h CREDIT PROTECTOR FEE - MONTHLY 74 0000 LATE FEE - JUL PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHASES.FINANCE CHARGE.PERIODIC RATE 84 0000 Purc:h/Adv Thru 02/20/2004 PURCHASES.FINANCE CHARGE.PERIODIC RATE 84 0000 Help is available! Please call the toll-free number shown above to learn about our special payment options, Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you, Previous Balance $9.069.52 $0.00 $9.069.52 (+) Purchases & Advances $134,13 $0,00 $134,13 (+) FINANCE CHARGE $224.28 $0,00 $224,28 (-) Payments & Credits 10,00 0,00 0,00 TM:CO-SOOO 11/12/04 cffr Hew 8alan~e $9427. 93 Minimum Amount Due $9427.93 Amount 64,13 0000000000 35,00 0000000000 35.00 0000000000 11. 64 0000000000 212,64 0000000000 (=) New Balance $9.427,93 $0,00 $9.427.93 Balance Subject to finance Charge Periodic Rate Days ThIs Billing Period: 32 Nominal ANNUAL APR PERCENTAGE RATE $664 .11 $8,513.58 $0.00 0.05477%( D) 0.07805%(0) 0.05477%(0) 19.990% 28,490% 19,990% 19,990% 28.490% 19.990% eXI HOlT ACID:KCB7150 18:21:29: A VERIFICATION Jennifer Sisson is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C,S. Section 4904, relating to unsworn falsification to authorities. Date: I a - 15- 0,-/ . .[~~6Y'v James F Paroda 5424180342147839 ~ ~ --€Q 7Ji ~ - , ~ U) () r--.:> ~ () r- c.= 0 ~ '--- = ~.- c.n " cg - J~~'~:' <- ~ t: p:! ):... L .- Z n,:n p .to"- ; (J.... ';0; I ;s~ ~:~ l_. w ~~ 1=: -~;'J' (".; -0 ~5 :;{ J;F~ ::l<.: c...) 5?~ :~ ~ --I ~ -' '" .!":;~ .... .D W --<: SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-00024 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PARODA JAMES F R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PARODA JAMES F but was unable to locate Him In his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , PARODA JAMES F 9 STEPHEN ROAD CAMP HILL, PA 17011 SERVICE WAS ATTEMPTED AT BOTH 9 STEPHEN ROAD CAMP HILL AND 196 ASHFORD DRIVE ENOLA. MOVED LEFT NO FORWARDING. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 22.20 5.00 10.00 .00 55.20 So answers.:...___";'C___ ____~_~,-7 ;.:::;:?/.~>2~ . I -R. Thomas Kline Sheriff of Cumberland County BURTON NEIL 01/10/2005 Sworn and subscribed to before ,J'J !'::. day of ,--,ldA<< 1'_ / 7 me this #Os A.D. Q ~A./Q ~ Pr t1{onotary .~ BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-24 JAMES F P ARODA Defendant : CIVIL ACTION - LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. BURTON NEIi & ASSOCIATES, P.c. ,~.l BY: t ~. '-- "- Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-4373 \ \11\11\ III \111\11\11111I11 111I1111I1111 11111111111111111111111 1111111I11111111111111I11111111111111111111111111111I11111I111111111I111IIIIIIIIIIIIIIIIIIIl --------- --------- ~ ~ c..- s:;;; \ \.D o -o~ r-:-;,jO r ~ 7:-" .~. ~:;\~ \~. ~\ ~ ~ -0 ~: ~ ::;:1 ~-n t t ~r=: -0 rr, -on C:) '1 ::-19 __r: -or'; C) ....;,:. =;." () 5rn -I ~~ :~~ c..:? c.,..' 0'" SHERIFF'S RETURN - REGULAR CASE NO: 2005-00024 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PARODA JAMES F ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PARODA JAMES F the DEFENDANT , at 1758:00 HOURS, on the 15th day of June 2005 at 217 W LOCUST STREET ENOLA, PA 17025 by handing to CATHY CLENDENIN, MOTHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 11.10 .37 10.00 .00 39.47 r~-~<~ R. Thomas Kline 06/16/2005 BURTON NEIL Sworn and Subscribed to before ~ ~ <./. . --=::> -b,"r ~ vi eputy Sheriff By: me this .<'<3.""'- day of <... ~~J'. 02(!v:5 A.D. ( J'l4' O. ~f(C., , ,# o honotary I CITIBANK (SOUTH DAKOTA) N.A. 701 J2ast 60th Street N, Sioux Falls, SD 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA VS. NO. 05-24 JAMES F PARODA 217 West Locust EnolaPA 17025 Defendant ; CNIL ACTfON - LAW 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; TOTAL $9,427.93 $.00 $9,427.93 Principal: Understanding that false statements herein made are subject to penalty under 18 Pa. e.S. 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 20 l(b)(1 )(A) ofthe Servicemembers Civil Relief Act of2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant andlor the Department of Defense website. BURTON ~ & ASSqcIA TES, P.e. L-- l. J'/\.. Burton Neil, Esquire- Attorney for Plaintiff !.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN VNDE A.R.eIV.p.236 ) BY: The law firm of Burton Neil & Associates is a debt collector. C-4373 11111111 III 111111 1111I 11m 111I1 1m I11I 1111111111111111111111111111I111111111111111111111111111111111I11I111111111I11111111111111 ClTIBANK (Soum DAKOTA) N.A. : IN TIIE COURT OF COMMON PLEAS Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-24 JAMES F PARODA Defendant : CIVIL ACTION - LAW Notice oflntention to File Praecipe for Default Judgment TO: James F Paroda 217 West Locust EnolaPA 17025 DATE OF NOTICE: July 7, 2005 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 obligations 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to [rod out where you can get legal help. This office can provide you with infonnation 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 BURTON NEIL & ASSOCIATES, P.C. BY: ~n~squire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 The flnn of Burton Neil & Associates, P .C. is attempting to collect a debt. C.4373 1l1111~11.lllllmlll III IUIII1IIIIIIIIIIIIIIIIIRllmlllm > c p ~ ..\0. \ ....() (J ~, tl = c:) '4- (~ . c-:\ ,,.1 8 0:.;/1 ~,: : .-, - h"l ~ r- -. ~~ r<) \I u" ~ \'" c3 -i'J ...:t - . 'lv E c-,) p: ---.L: .' r.:J ~. (:". --L. BURTON NEIL & ASSOCIATES, P.e. BY: . Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester,PA ]9380 610-696-2]20 ATTORNEY FOR: Plaintiff CITlBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-24 JAMES F PARODA 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 cJ L1 I" :J. f: c1.D~ <; I I Prothonotary ,,---By: ~()~O. {J, ~171l/:JGr------ Deputy If you have any questions concerning the above, please contact: Burton Nei], Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA ]9380 Phone: 6]0-696-2120 The law firm of Burton Neil & Associates is a debt collector.