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HomeMy WebLinkAbout05-2901 BURTON NEIL & ASSOClA TES, p,c. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITlBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SO Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA JOAN E MURRAY 4655 Creekview Road, Mechanicsburg P A 17050 Defendant : CNIL ACTION _ LA W NO, 6!;" - dl9DI {};u~L~~ 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 ALA WYER 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LA WYER 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-2964 ... BURTON NElL & ASSOCIATES, P,C, By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2]20 Attorney for Plaintiff ClTIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYL VANIA NO, OS'- ~9DI {lic;;.L Ly-82..nt JOAN E MURRAY 4655 Creekview Road, Mechanicsburg P A 17050-2109 Defendant CIVIL ACTION - LA W Complaint I. 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 Joan E Murray, who resides at 4655 Creekview Road, Mechanicsburg, 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 5424180516036933 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 $17,612.65. Wherefore, plaintiff demands judgment against defendant for the sum of $17,612.65, and the costs of this action. ,I BURT{)N NEiL & ASSOCIATES, P.C. By: L i / Burto~ ~], E(~uire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. . . . l 06/07/04 ~~~~j!!i~IW~~jlim~j~j~I~ $17612.65 $9999.99 5ITE:KC-Cl TM:CO-5000 02/09/05 AClD:KCB7150 01:4B:27: n_......_....n_....... n..........._.._.._... i~~~~~~i~~~~~~~~~ ~~~~~~~i~~~~~~~~~~~i~~ JOAN E MURRAY 4655 CREEKVlEW RD MECHANlCSBURG 17050-2109000 PA CITl CARDS P.O. BOX B107 S HACKENSACK. NJ 07606-B107 Citt Platinum Select"' Card em" Account Number 5424 1805 1603 6933 Customer Service: 1-800-950-5114 80X 6500 SIOUX FALLS. SO 57117 Sale Oat. Post Oat. Reference Number fotal CredIt LInt' $15220 St.-t.m.of! CI05109 Oat. 05/11/2004 Available Credit Line $0 Amount Over Cr.dlt line $2392.65 Cash Advance limit $S500 5/11 5/11 Activit., Since Last Statement Standard Purch OVER CREDIT lIMIT FEE 62 0000 PURCHASES-FINANCE CHARGE-PERIODIC RATE 84 0000 Past Due $2560.77 Available Cash Limit $0 Purch/Adv ~Inlmum Due J430.90 NeW!lalance $17612.65 Minimum A.mount Du. $17612.65 Amount 35.00 0000000000 425.90 0000000000 Please note that payments must be received by 1:00 p.m., local time, on a bank business day at the payment processing facility that handles your payments, in order to be credited to your account as of that day, and payments must conform to the payment instructions set forth on the reverse side. All conforming payments received at the payment frocessing faclllty after that time will be credi ed as of the fOllowing bank business day. 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. $17,357.18 $0.00 0.07668%(0) 0.07668%(0) 27.990% 27.990% EXHIBt:;~ Account Summary PURCHASES ADVANCES TOTAL reVIOUS Balance $17,151.75 $0.00 $17,151. 75 (+) Purc ases &. Advances $35.00 $0.00 $35.00 (-) aymen s & Credits fO.oo 0.00 0.00 =) New Balance $17,612.65 $0.00 $17,612.65 Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Ba l.'Ince Su Jee 0 finance Charge erlo IC Rate Oa s ThIs BJltln PerIOd: 32 Nomina ANNUAL APR PERCENTAGE RATE -- _ .l Verification I,~^rhOlR:kK_ Inc., (USA) which is by contract the service provider for plaintiffCITIBANK (SOUTH am an employee of Citicorp Credit Services, DAKOTA) N.A. retained to perform services including but not primarily Iimited to collecting delinquent debt. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: 0SllQ1 O~ [j#JnJ&~1C SIgnature Joan E Murray 5424180516036933 C-2964 --- - - ~ (.:) 'ig. ~ 0 - ...0 tI) 8 """ ~ D (") ...., ~ = 0 ...c: = ...... ~ u(J:: <.r> -n ""Q ~ mr'il <- =r! --Cl ~?-.: <= z m:D t: (f) )_,~ I }J~ ~ ~::; 0'\ 0 :-<0 "<7 ..+==r-; Zc :J:; >' J:- c:C ' )..- 200 Z w 6rn :;? .t'" ;;;! Ul .n -< SHERIFF'S RETURN - REGULAR CASE NO; 2005-02901 P COMMONWEALTH OF PENNSYLVANIA; COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MURRAY JOAN E SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MURRAY JOAN E the DEFENDANT , at 1123;00 HOURS, on the 13th day of June 2005 at 4655 CREEKVIEW ROAD MECHANICSBURG, PA 17050 by handing to ROBERT ECKERD, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 8.88 .37 10.00 .00 37.25 r~~"<:~ R. Thomas Kline 06/14/2005 BURTON NEIL Sworn and Subscribed to before By: me this ;2v e day of l ;L~ 2OV! A.D. '-;'1;~{}on~"a1~'-', ~ CITIBANK (SOUTH DAKOTA) N,A. 701 East 60th Street N, Sioux Falls, SD 571 17 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.05-2901-Civil JOAN E MURRAY 4655 Creekview Road Mechanicsburg P A 17050-2109 Defendant : CIVIL ACTION - 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: Principal: $] 7,612.65 TOTAL $17,6] 2.65 Understanding that false statements herein made are subject to penalty under] 8 Pa. C.S. S 4904 relating to unsworn falsification to authorities, I verify that: I. 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. Pursuantto Section 20](b)(I)(A) of the 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 and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER P .ClV.P.236 BURTON NElL & ASSOCIATES, p,c. BY: 'L--, f Burton Neil, Esq~ire Attorney for Plaintiff J.D. #] 1348 1060 Andrew Drive, Suite ] 70 W. Chester, PA ]9380 The law firm of Burton Neil & Associates is a debt collector. C-2964 1111111111111111111111111111111111111111 1111111111111111111111111111111111111111111111I111111I11111111111I111111111111111111111111 CITIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-2901-Civil Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Jndgment TO: Joan E Murray 4655 Creekview Road Mechanicsburg PA 17050-2109 DATE OF NOTICE: July 5, 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 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 COWlty Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-9.90-9108 BURTON bmIL & ASSOCIATES, P.C. ,. BY: ,. L t.. ( BurtOn 'FIe!], Esquire Attomejfor Plaintiff ldentifitation No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-6%-2120 The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. C-2964 IlIIImlllllll 1I1111.111.IIIIIIMI .' ~ N 0 -lQ ~ t ....(::) Q F --- '- () --- \\'- ..../;;, ~ ~ ~ 0 ....' ~ (- c::;:) 0 .= 6"- :',;; c.r> -n L. --1 IU' ti 1- (~'- :;:C-'J - 1';:;;; p1r=- ~ "" ?312\ 1'0 , , :__i(~/, -"'J .~,~ Z~; 0) : -'~I ;-;:1 -. ;;~ =<: ::0 c:::> .-< .' . BURTON NElL & 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. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.05-2901-Civil JOAN E MURRAY 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 , ilL .L ( .J ..:? ..J6f.,l r . I Prothonotary "By: ~a~ f) P7f!-/?/?-"y~ Deputy If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing I 060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.