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Home My WebLink About05-0969 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester,PA 19380 (610) 696-2120 Attorney for Plaintiff BANK OF AMERICA, N.A., (USA) 4161 Piedmont Parkway, Greensboro, NC 27410 Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - q~9 Cw;L y~ RICHARD T CASTNER and JACQUELYN S CASTNER 32 Farm House Lane, Camp Hill PA 17011-8302 Defendant : CNIL 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, P A 17013 Telephone No, 7]7-249-3]66 or 800-990-9108 59251 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 IN THE COURT OF COMMON PLEAS BANK OF AMERICA, N.A., (USA) 4161 Piedmont Parkway, Greensboro, NC 27410 Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA NO. 0 S - Ou~L Ivz-~ RICHARD T CASTNER and JACQUELYN S CASTNER 32 Farm House Lane, Camp Hill P A ] 7011-8302 Defendant CIVIL ACTION - LAW Complaint 1. The plaintiff is Bank of America, NA (USA), a national banking association with place of business located at 4161 Piedmont Parkway, Greensboro, North Carolina. 2. The defendants are Richard T Castner and Jacquelyn S Castner, who reside at 32 Farm House Lane, Camp Hill, Cumberland County, Pennsylvania. 3, Plaintiff furnished consumer credit to the defendants by means of a credit card with account number 4336009010905246 hereinafter referred to as the credit card account. 4 The defendants accepted and used the credit card account by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendants each month by plaintiff which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due for the charges made by the defendants including any late or fmance charges is $8,071.87. 7, Defendants did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendants is in default on the credit card account. 8. Although demand has been made by plaintiff upon defendants to pay the sum of $8,071.87, the defendants failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against the defendants in the sum of $8,071,87 and the costs of this action. BURj NEIL& ASSOCIATES, P,C. i ~ . BY: <...,-.;:~. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector, Verification ~ \<iJ'I\a- ~-1{ ~ (Name of authorized representative) IS k~~-4, (Title or Position) for, Bank of America, 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 ofthe undersigned verifier's knowledge and belief, The undersigned Imderstands that the statements made herein are subject to the penalties of 18 Pa. C.S, Section 4904, relating to unsworn falsification to authorities, Date:~/o'\ ~o ~ Name Richard T Castner 4336009010905246 , . ~ (J -\Q \ en. .<11 -- Ire &- fA] C> ,~, 8 ..() ..t:. C) ''<:-' -.() ~ <" c'.'~ ~ (..1 ~ -'1 .'1 rr .. f",) 1 . . .. . I c.') ;J -- ~ ----- BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester, PA 19380 610-696.2120 ATTORNEY FOR: Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A. (USA) Plaintiff VS. : NO. 05-969 RICHARD T CASTNER JACQUELYN S CASTNER Defendant : CIVIL ACTION . LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice, BURTO~}EIL & ASSOCIATES, P,C. '-.BL-~ t .--J Burto;;-Neil, Esquire Attorney for Plaintiff The law finn of Burton Neil & Associates is a debt collector. 59251 u~ ,\ i"