HomeMy WebLinkAbout05-2271
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
DIRECT MERCHANTS CREDIT CARD BANK N.A.
Kierland 1, Suite 300, 16430 N. Scottsdale Road
Scottsdale, Arizona
IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLV NIA
v.
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JIMMY D RICHARDSON
405 Fairmont Avenue, New Cumberland PA 17070-0265
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 appearan e
personally or by attorney and filing in writing with the court your defenses or objections to the claim t forth
against you. You are warned that if you fail to do so, the case may proceed without you and ajudgme t may be
entered against you by the court without further notice for any money claimed in the complaint or for ny other
claim or relief requested by the plaintiff. You may lose money or property or other rights important to ou.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR H
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PRO DE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PRO IDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES 0
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERENCE AND
INFORMA nON SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
04-408
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
DIRECT MERCHANTS CREDIT CARD BANK, N.A. IN THE COURT OF COMMON PLE S
Kierland 1, Suite 300,16430 N. Scottsdale Road
Scottsdale, Arizona
Plaintiff
CUMBERLAND COUNTY, PENNS
NO. DS - d,,;Z"T1 C'ucL
v.
JIMMY D RICHARDSON
405 Fairmont Avenue, New Cumberland, PA
Defendant
: CIVIL ACTION.. LAW
Complaint
I. The plaintiff is Direct Merchants Credit Card Bank, N.A., a national banking as ociation
with place of business located at Kierland 1, Suite 300, 16430 N. Scottsdale Road, Scottsd e,
Arizona.
2. The defendant is Jimmy 0 Richardson, who resides at 405 Fairmont Avenue, N w
Cumberland, Cumberland County, Pennsylvania.
3. Plaintiff furnished consumer credit to defendant by means of a credit card with ccount
number 4730680141105559 hereinafter referred to as the credit card account.
4. The defendant accepted and used the credit card account by making purchases, alance
transfers and/or cash advances.
5. Monthly statements were sent to defendant each month by plaintiff which detai ed the
charges and credits made to the credit card account for the prior month.
6. The balance due on the credit card account is $14,282.64.
7. Defendant did not pay the balance due on the credit card account in full upon re eipt of the
monthly billing statements and also did not make the required minimm monthly payment et forth in
the monthly billing statement. As such, defendant is in default on the credit card account.
8. Although demand has been made by plaintiff upon defendant to pay the sm of $ 4,282.64,
the defendant failed and refused to pay all or any part thereof.
Wherefore, plaintiff demands judgment against the defendant in the sum of $14,28 .64 and
the costs of this action.
BURTON)4EIL & ASSOCIATES, P.
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Burton Neil, Esquire
Attorney for Plaintiff
By:
The law firm of Burton Neil & Associates, P.C. is a debt collector.
VERIFICA nON
Ruth A. Kenny is Agency Assistant for Direct Merchants Credit Card Bank N.A. the within PI intiff in
this action, and that the statements of fact made in the foregoing Complaint are true and correc to the
best of the undersigned verifier's knowledge and belief. The undersigned understands that the tatements
made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsi cation to
authorities.
Date: ;f- jii j~
Jimmy D Richardson
4730680141105559
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BURTON NEIL & ASSOCIATES, P.e.
BY: Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
ATTORNEY FOR: Plaintiff
DIRECT MERCHANTS CREDIT CARD
BANK, N.A
: IN THE COURT OF COMMON PLEAS
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 05-2271
TIMMY D RICHARDSON
Defendant
: CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Kindly discontinue the above-captioned action without prejudice.
BURTON,L & ASSOCI~TES, P.C.
BY: ..~ "' \. L./
Burton Neil, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
04-408
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