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Home My WebLink About05-1195 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 CITffiANK (SOUTH DAKOTA) NA 701 East 60th Street North, Sioux Falls, SD Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()~ - / f9S C/(.>~l~Q~ N G BRUNO AKA NANCY G BRUNO 915 Country Club Road, Camp Hill P A 17011 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-814 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 ClTIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. N G BRUNO AKA NANCY G BRUNO 915 Country Club Road, Camp Hill, P A Defendant : CIVIL 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 N G Bruno aka Nancy G Bruno, who resides at 915 Country Club 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 4271382108119765 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 $13,844.31. Wherefore, plaintiff demands judgment against defendant for the sum of $13,844.31, and the costs of this action. J BURTON NEIL & A~CIATES, P.C. By: c.....-) t-1 Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 02/09/04 ~~:~*~:~t;m:i~~:~:~:~: .......................-- ._...n.................. $13844.31 $9999.99 SITE: KC-CL TM:CO-5000 12/31/04 ACID:KCB5314 18:41:34: ~j~~Wj~~jii~~~j~j~ HiM~~mtj~mm~~;j~ N G BRUNO PO BOX 862 CAMP HILL 17001-0B62000 CHI CARDS P.O. BOX 8110 S HACKENSACK, NJ 07606 -8110 PA Citr Gold Card For Customer Servklil, call or wrltoi 1-800-756-4000 Account Number 4271 3821 0811 9765 PAYMENT MUST BE RECEIVED BY 1:00 PM LOCAL TIME ON 02/09/2004 TorepOJtbllllnqenors,tiI'lte to IhI,. addre-:ealllnq 11III1 I'olltpl'eserveyo~rlghta. BOX 6062 SIOUX FALLS, SO 57117 statement/Closing Date Total Credit Line Available Credit line Cash Advance limit Available Cash Limit New Balarlce 01/15/2004 $15700 $0 $10000 $0 $13844.31 Amount Over PastDua Purch/Adv Minimum Amount Due CredltLinll MlnlmumDu8 $0.00 $1627.85 $288.00 $13844.31 Sale Date Post oat. Rel.rence Number Activity Since Last statement Amount Standard Purch 1/15 LATE FEE - DEC PAYMENT PAST DUE 29.00 66 0000 0 70000000000 1/15 PURCHA5ES'FINANCE CHARGE'PERIODIC RATE 3.02 84 0000 0 70000000000 1/15 Purch/Ad. Thru 02/14/2003 PURCHASES'FINANCE CHARGE'PERIODIC RATE 222.07 84 0000 0 70000000000 Help ;s 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. Our records show home phone 717-737-9630 and business phone 717-652-7376. Please update above coupon if incorrect. Account Summary PURCHASES ADVANCES TOTAL PrevIous Balance $13,590.22 $0.00 $13.590.22 (t) Purchases & Advances $29.00 $0.00 $29.00 (-) Payments & Credits 10.00 0.00 0.00 (+) FINANCE CHARGE $225.09 $0.00 $22S.09 (=) New Balance $13,844.31 $0.00 $13,844.31 Rate Summary PURCHASES Standard Purch Purch/Adv thru 02/14/2003 ADVANCES Standard Adv Balance Subject to FIMnce Charge PeriodiC Rate Days ThIs Billing Period: 30 Nominal ANNUAL APR PERCENTAGE RATE 19.990% 19.990i\-- 19.99J;'J $183.51 $13,515.19 $0.00 0.05477%(0) 0.OS477%(D) 0.05477%(D) 19J!l)EHIBIT 19.990% 19.990% VERIFICATION Nick Petsche 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 ofthe 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: '~liG( ~ / // / - ,f ~~/ " N G Bruno 4271382108119765 .-' 8 {,Q. 1- V) 8 11- III -..J VI ....' <.:,) c~-:) C> C.~ '''',1 - u' -' " '\) -0 ::n:: '"":l-1"'\ """'" l';1f~ V'> -:t ~J ~t1r-n ~ I :b't ~ _l :~?{(:.:".)- J .:,~.~, :~:i -0 " ) I'~') :;1; ::~:-;"n :",) ~ ..\ ~<- '.~& ,J;.~' ClTIBANK (SOUTH DAKOTA) N.A., Plaintiff v. N G BRUNO alkla NANCY G. BRUNO Defendant IN THE COURT OF COMMON PLE S OF CUMBERLAND COUNTY, PENNS1 LV ANIA I I I I I NO. 05.1195 CIVIL ACTION - LAW NOTICE TO PLEAD TO: Citibank (South Dakota) N.A. c/o Burton Neil, Esquire Burton Neil & Associates, P.c. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 YOU ARE HEREBY NOTIFIED to file a written response to the enclos d New Malter within twenty (20) days from service hereof or a judgment may be entered ag inst you. BUTLER LAW FIRM By: /ullk:J Ronald D. Butler, Esquire Attorney for Defendant !.D. #09826 500 North Third Street P.O. Box 1004 Harrisburg, PA 17108 (717) 236-1485 v. IN THE COURT OF COMMON PLEi'\S OF CUMBERLAND COUNTY, PENNSI LV ANIA I I I I I NO. 05-1195 ClTlBANK (SOUTH DAKOTA) N.A., Plaintiff N G BRUNO a/k/a NANCY G. BRUNO Defendant CIVIL ACTION. LAW DEFENDANT'S ANSWER AND NEW MATTER AND NOW, comes the Defendant, N G Bruno a/k/a Nancy G. Bruno, band through her attorneys, Butler Law Firm, and files this Answer and New Matter, and i support thereof avers the following: ANSWER I. Admitted upon information and belief. 2. Admitted. 3. Admitted upon information and belief. 4. Denied. Defendant is without sufficient information and knowle e to form a belief as to the truth of the allegations made in this paragraph. As such, said allegati ns are specifically denied and strict proof thereof is demanded at trial. 5. Denied. Defendant is without sufficient information and knowle e to form a belief as to the truth of the allegations made in this paragraph. As such, said allegati ns are specifically denied and strict proof thereof is demanded at trial. ~ . , . 6. Denied. Defendant is without sufficient iuformation and knowledj e to fonn a i! belief as to the truth of the allegations made in this paragraph. As such, said allegati1!lS are 11 specifically denied and strict proof thereof is demanded at trial. I! 'I !! 7. Denied. Defendant did not receive monthly statements from Plain iff for the credit card account as alleged. Moreover, Defendant did protest, dispute and object t said charges. Receipt of Defendant's objection was acknowledged by Plaintiffs attorney y letter daled January 14,2005, a true and correct copy of which is attached hereto and mad a part hcreof as Exhibit "A". Defendant also requested a complete historical account of all harges and payments alleged by Plaintiff, which Plaintiff has failed and refused to provide to De endant. 8. Denied. Defendant has and does protest, dispute and object to the harges and statements including the statement aUached to Plaintiffs Complaint as Exhibit "A". eceipt of Defendant's objection was acknowledged by Plaintiffs attomey by letter dated Janu ry 14,2005 (Exhibit "A" to Defendant's Answer and New MaUer). Defcndanl also requested a mplcte historical account of all charges and payments alleged by Plaintiff, which Plaintiffh' failed and refused to provide to Defendant. 9. Denied. Defcndant specifically denies that she owes the amount ated or any amount whatsoever to Plainti ff. Strict proof thereof is demanded at trial. WHEREFORE, Defendant respectfully requests this Honorable Court t dismiss PlaintilTs Complaint with prejudice and grant all such other relief as is reasonable adjust. NEW MATTER 'I , o. Dof",d,,,,,., Arow",' <0 p.mgmph, , <hro"~, 9 of P','o<,ff, C"'1r'p",,,,, incorporatcd herein by referencc as though fully set forth. II 11. Defendant previously protested, disputed and objected to the char< s alleged by Plaintiff. Plaintiffs attorney acknowledged receipt of Defendant's protesl, disput and objection by letler dated January 14,2005 (attached hereto as Exhibit "A"). 12. Defendant requesled a complete historical account of all charges' d payments alleged by Plaintift~ which Plaintiff has failed and refused to provide to Dc endant. 13. Plaintiffs claims are barred by the statute oflimitation. 14. Plainti ff s claims are barred by the statutc of frauds. WHEREFORE, Defendant respectfully requests this Honorable Court t dismiss . . Plaintiff's Complaint with prejudice and grant all such other relief as is proper and jLI~1. Respeclfully submitted, BUTLER LA W FIRM Attorneys for Defendant By: Ronald D. Butler, Esquire J.D. #09826 .1ana Butler Toole, Esquire J.D. #80574 500 North Third Street P.O. Box 1004 Harrisburg, PAl 71 08 (717) 236.1485 Burton Neil Edward J. O'Brien Jay H. Pressman Yale D. Weinstein LAW OFFICES BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUllE 170 WEST CHESlER, PENNSYL V AN1A 19380 610-696-2120 Facsimile 610-696-4111 Email: Burton.neil@burt-Iaw.com January 14, 2005 N G Bruno aka Nancy G Bruno 915 Country Club Road Camp Hill P A 17011 RE: Citibank(South Dakota) NA Account with: N G Bruno aka Nancy G Bruno Dear Ms. Bruno: You previously advised that you disputed the balance owed to my client, Citib Dakota) NA. Enclosed is verification. v@ry:'truly yours, j I ,~ I B~on Neil Enclosure In making this communication, we advise our firm is a debt collector. Refer to File # C-814 (South XHIBIT RA" 01/10/05 $14306.69 $9999.99 :JmHlIIJI!lIl1illllll I ill!! i Ill! !lllIIl lliill! lIIililllli SITE:KC-CL TM:CL-SOOO 12/16/04 N G BRUNO ArtNY ACCOUNT-CODE=lB34 CA~P HILL PA 17001-0862000 CHI CARDS P.O. BOX 8110 S HACKENSACK. NJ 07606-8110 cltr Gold Card em" 4271 3821[0811 9765 1-1Ot-'25rll71 lOX 1062 , SIOUX FAW. 5D 57117 ' $15700 $0 $0 $298.00 $14306.69 $14306.69 $10000 $4890.85 12/15/2004 $0.00 Nelp I. aYall.~lel Plaale call tbe toll-'ree >>ullber 11\0"" Hove to learn about our 5Mcia' pay_t optl...... Call _d"" - 'rldaY,'7.. to 9 p.. .r Saturd.y, . aM to 5~. tefttral T\.e. Ple".olye .. the opportunity to ...I.t you. IIIJlORTAIIT INrOWAnOll AIOU7 CREDIT REPOING: 1ft: IlAY, RlPORT IIlf000nOll AIOU7 YOUR ACC T TO CRElIIT; _ UTE PAMIITS IUSSED PA NTS OR OmR ~ 011 YOUR ACCOUNt IlAY IE IE LEcn:6 III YOUR cliEiiiTLitPORT. ~ r... + u. ... . .,. :ll~~s $14.3ro.69 U,OO U.OO '14'~E: 0.00 0.00 0.00 TOTAL '14.306.69 .00 .00 $14.3 . Do TlIIs Pttlod: ... a CI I 0 Ie om I AHIlIlAL Fin..... CII.- Rite API PUIICIIAS stong, $0.00 0.05477"(0) 19.990" 19._ Purc t ftr OUlI/ZOO3 '0.00 0.05477,.(0) 19.99D'4 19.9 ADvANCE St..d.rld Adv $0.00 0.05477"(0) 19.990" 19.99 ID:IIC85318 19:02:07: VERIFICATION l, Nancy G. Bruno, Defendant herein, hereby certify that the fac set forth in the foregoing Answer and New Matter are true and correct according to the hest of my knowledge. infonnation and belief. I underst,md that any false statements herein are made subject to pc Ities of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date 3111/65 . . . '. . elTlBANK (SOUTH DAKOTA) N.A., Plaintiff v. N G BRUNO a/k/a NANCY G. BRUNO Defendant IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY, PENN, i~'L VANIA NO. 05-1195 CIVIL ACTION - LA W CERTIFICATE OF SERVICE I, Jana Butler Toole, Esquire, hereby certify that on the 22nd day of arch, 2005, I scrved a true and correct copy of the foregoing Answer and New Matter by depos' ing same in the United States Mail, postage prepaid in Harrisburg, Pennsylvania, addressed as follows: Burton Neil, Esquire Burton Neil & Associates, P.c. 1060 Andrew Drive, Suite 170 West Chester, P A 19380 500 North Third Street P.O. Box 1004 HalTisburg, P A 17108 (717) 236-1485 ....... ';~ ", ,";'-;' o -n ...... ~-\- ffi ~1J " ~ __lrr1 ~;:,? j (~) :1) c) ',(Tl .'::1 ,J> .oJ ,< ", f',,') (.-.1 f'.' Ul (J,J SHERIFF'S RETURN - REGULAR CASE NO: 2005-01195 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BRUNO N G AKA NANCY G BRUNO JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according t law, says, the within COMPLAINT & NOTICE was served upon BRUNO N G AKA NANCY G BRUNO DEFENDANT , at 1846:00 HOURS, on the lOth day of March at 915 COUNTRY CLUB ROAD CAMP HILL, PA 17011 JERRY COHEN, HUSBAND by handing to th , 2005 a true and attested copy of COMPLAINT & NOTICE together ith and at the same time directing His attention to the contents th reof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.10 .00 10.00 .00 39.10 So Answers: , ' 7"~/~?j?',~ /~. .,.'."" ..-,,':"'7;"'::1'-';7i><?r.::L:::'A.-( ../~-*" ,: ... -...,,,. .'?' R. Thomas Kline 03/11/2005 BURTON NEIL Sworn and Subscribed to before By: me this ~ day of fl \ cla (),c{ ~1" BURTON NEIL & ASSOCIATES, P.C. Burton Neil, Esquire, Id. no. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attornev for Plaintiff CITIBANK (SOUTH DAKOTA) NA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1195 N G BRUNO AKA NANCY G. BRUNO Defendant: CIVIL ACTION - LAW PlaintifPs Reply to New Matter 10. (1)-(6) Denied. No facts are set forth in these incorporated by reference averments of defendant's answer. In accordance with Pa R.C.P. 1029(d) the averments are deemed denied. 10. (7) Denied. The alleged notice of dispute referenced in the exhibit to defendant's answer was not a dispute to any of the statements sent to her by plaintiff. To the contrary, the exhibit A letter was sent in response to a request by defendant for copies of monthly statements of the account. At no time did defendant communicate to plaintiff or plaintiff s counsel that any of the statements were disputed. It is denied that plaintiff did not provide defendant with a record of the account detail. To the contrary, monthly statements were sent to defendant on a regular basis which said statements accurately reflected the account activity for the prior month. 10. (8) Denied. Plaintiff incorporates by reference its response to paragraph 10 (7). 10. (9) Denied. To the contrary, defendant is indebted to plaintiff in the sum of $13,844.31. 11. Denied. To the contrary, at no time did defendant dispute any ofthe charges. In a contact with plaintiffs counsel, defendant requested copies ofthe monthly statements which were sent to her with a cover letter which is defendant's Exhibit A. Although the letter references the same was sent in response to a dispute, there was in reality no such dispute. By way of further reply, defendant at no time within 60 days after her receipt of any of the monthly statements ever sent to plaintiff a written billing error notice as required by the Fair Credit Billing Act. 4 12. Denied as stated. Plaintiff sent monthly billing statements to defendant on a regular basis. Plaintiff is without knowledge or information sufficient to form a belief as to defendant's disposition of the monthly statements. However, defendant's course of payments made would reflect that they were made after her receipt of the statements. It is denied that plaintiff did not accommodate a later request by defendant to send her copies of the monthly statements. To the contrary, statements were sent to her. 13. Denied. Plaintiffs records reflect defendant's last payment was made on August I, 2003. As such, the defense of the statute oflimitations is not applicable. 14. Denied. No facts are averred in support of this affirmative defense. The allegation is denied in accordance with Pa R. c.P. I 029( d). _-~ ~---- ~Burton Ne' & Associat.~s, P.C. <------lC-:f.) By Burton Neil, Esquire In making this communication, we advise our firm is a debt collector. VERIFICATION Burton Neil, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, Citibank (South Dakota) N.A., in the foregoing matter, that he is authorized to take this verification on its behalf; and that the facts set forth in the foregoing Plaintiffs Reply to New Matter are true and correct to the best of his knowledge, infonnation and belief subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ) Date: 41-1., ~/ ./ L.. \ __,./" Burton Neil'1;squire NG Bruno 4271382108119765 C-814 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 CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-1195 Civil N G BRUNO AKA NANCY G BRUNO Defendant : CIVIL ACTION. LAW Certificate of Service I, Burton Neil, Esquire do hereby certify that a I served a true and correct copy of the within Reply to New Matter on defendant's counsel, Ron Butler, Esquire at his/her address of record via first class mail, postage prepaid on the date set forth below. Date: u./t~( ., BURTON NEIL & ASSOCIATES, P.C. ) ,.'^ BY: <---<~l - /' Burton Neil," Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-814 .-.' S?, ("....i1 ~~::. -t'" c.J -" ~ c' --i,1 -, -(. ""T1 i 1"1 ~"-. ,\',"\ -C"le; '~~(~ N -- C~) ..".. " "'.. 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, PENNSYL Y ANIA YS. ; NO. 05-1195 Civil N G BRUNO AKA NANCY G BRUNO Defendant ; CNIL ACTION - LAW PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification for the attorney verification filed with plaintiffs Reply to New Matter. BURTON NEIL & ASSOCIATES, P.C. c , :1 BY: ,ff:,. C. t Burton Neil, E'Squire Attorney for Plaintiff Veritication .Sherri Smith is a litigation assistant for Citicorp Credit Services, lt~~ provider under ((1I1Irilct with Citibank (South Dakota) N.A. both of whieh arc wholly owned subsidiaries of ('iligrnLlp USA. tbe within PlaintitTin this action. She verifies that the statcmcnts offaet made in thL' t;"egoing Reply to New Malter! Affirmative Dcfenses are true and correct to the best of her k "",,,ledg" ilnd belief The undersigned understands that the statcmcnts made herein are sLlbjcct to th,' 1',:1l:1I1 lc', of IS l'iI. ('.S Scdion 4904, relating to unsworn falsification to the authorities. . j .j ():II,'. l\-_\l= 0 c:::::;, r- \" \"'. I', ~~O~~ Signature N(i lhuno 1:'7J,,~210SI19765 (',,,:11 ,,---- ,~^-.J -n :::;1 i-it ~-'. c'-.::;- ,._1 - BURTON NEIL & ASSOCIATES, P.C. By Yale D. Weinstein, Esquire Identification No. 89678 1060 Andrew Drive, Suite 170 West Chester, P A 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. : JN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-1195 Civil N G BRUNO AKA NANCY G BRUNO Defendant : CIVIL ACTION. LA W PRAECIPE TO SETTLE, END & DISCONTINUE TO THE PROTHONOTARY: Mark the above matter Settled, Ended and Discontinued. ASSOCIATES, P.c. ( By: /' The law firm of Burton Neil & Associates is a debt collector. C-814 111111111111111I1111111111111111111 111111111111111111111111111111111111111111I111111111111111111111111111111111111111111