The URL can be used to link to this page

Home My WebLink About05-3617BURTON 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 701 East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. ~~- / NO. d5- .30/7 L.lUcl.,~~~ SPEROS G NTONADOS 4174 Kittatinny Drive, Mechanicsburg PA 17050 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 aze 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 aze 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-5863 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. SPEROS G NTONADOS 4174 Kittatinny Drive, Mechanicsburg PA 17050 Defendant No. as -.~~7 CIVIL ACTION -LAW Complaint ~,v ~ C ! ~LY•-l 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 Speros G Ntonados, who resides at 4174 Kittatinny Drive, 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 4271382103429995 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 $26,250.34. Wherefore, plaintiff demands judgment against defendant for the sum of $26,250.34, and the costs of this action. BURTON N~L & ASSOCIATES, P.C. Burton Neil, E~quire Attorney for Filaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. _ 07/05/04 $26250.34 $9999.99 SITE:KC-CL TM:CO-5000 ACID:KCB7150 >Pei#<e~~:akts:>=> oa2w>t=nei~s>`:> E:Y31i3~>;sa#<`i~~ 0 6 / 17 / 0 5 18:5 0:48 CITI CARDS P.O. BOX 8107 SPEROS G NTONADOS 5 HACKENSACK, NJ 4174 KITTATINNY DR 07606-8107 MECHANICSBURG PA 17050-9138000 Citi~ Gold A"Advanta~e~ Card r\m till lkavantaa Account Number e Is a re9lsterea tr aaemark men can lr rl roes, roc. 4271 3821 0342 9995 Customer Service: 1-800-756-4000 Total Credit Line Available Credit Line Cash Advance Limit Avalla ble Cash Limit New Balance $23090 $0 $8000 $0 $26250 34 BOX 6062 SIOUX FALLS, SD Statement/ Amount Ovur Cloalnq Date Credll Lin• Past Dw Purch/Adv Inimum Du• . Minimum Amaunt Dua 57117 06/09/2004 $3160.34 + $2978.92 551.00 $26250.34 5eN Deto Post Date nebnnce Number Activity Since Lest Statement Amount Standard Purch 6/09 LATE FEE - MAY PAYMENT PAST DUE 35.00 66 0000 0 70000000000 6/09 OVER CREDIT LIMIT FEE 35.00 62 0000 0 70000000000 6/09 PURCHASES"FINANCE CHARGE'PERIODIC RATE 103.21 84 0000 0 70000000000 Pureh/Adv Thru 05/09/2003 6/09 PU RCXASES`FINANCE CHARGE•PERIODIC RATE 431.50 84 0000 0 70000000000 Help is available! Please call the toll-free number shown above to learn about our special payment opt ions. 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. Account Summary revlous (+) urc ases (-) Paymen s + NANO (_) ew Balance & Advances &Credits CHARGE Balance PURCHASES $25,645.63 $70.00 $0.00 $534.71 $26,250.34 ADVANCES $0.00 $0.00 $ 0.00 $0.00 $0.00 TOTAL $25,645.63 $70.00 $ 0.00 $534.71 $26,250.34 Da s Th is Blllin Perlotl: 29 Rake Summary a ante Su )ec o ergo is omina vu Nersc Finance Charge Rate APR ocor- oA~rr rd Purch $6,498.26 0.05477%(D) 19.990% 19.990% Adv u 05/09/2003 $19,404.57 0.07668%(D) 27.990% 27.990% S rd Adv $0.00 0.05477%(D) 19.990% 19.990% Verification I Courtney Gilbert am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff Citibank (South Dakota) N.A. retained to perform services including but not primarily limited 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: d ~ Signature: ~ ~ ~~ ~~ ~, 1 ~ yi ~ ~ ~__- .._ ~ ~~ -n 5 ( U _ ~ e 1 N Q ~1 ~ ~ ~ ~ U i rr 9 T _ 1 ~ G.J h3 ` 1 1 ~ ~ ' ti C„ SHERIFF'S RETURN - REGULAR CASE N0: 2005-03617 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS NTONADOS SPEROS G SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NTONADOS SPEROS G the DEFENDANT at 1930:00 HOURS, on the 19th day of July 2005 at 4174 KITTATINNY DRIVE MECHANICSBURG, PA 17055 by handing to NTONADOS WIFE OF DEFENDANT 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 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 .00 36.80 Sworn and Subscribed to before me this 2G ~ day of ~2OaS~ A.D. Prothonota -- So Answers: ~ ~,~ R. Thomas Kline 07/20/2005 BURTON NEIL By : // _ ~ De ty Sheriff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. SPEROS G NTONADOS 4174 Kittatinny Drive Mechanicsburg PA 17050-9138 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS-3617 Civil CNIL 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: $26,250.34 TOTAL $26,250.34 Understanding that false statements herein made are subject to penalty under 18 Pa. C.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 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the de ndant and/or the Department of Defense website. _ JUDGMENT BY DEFAULT ENTERED Burton AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA. CIV.P. 236 By:L ~/ Pro Prothon tart' The law firm of Burton Neil & Associates is a debt collector. P Yale emstein, Esquire Att v for Plaintiff 10'60 Andrew Drive, Suite 170 W. Chester, PA 19380 C-5863 A ~ ~ CITIBANK SOUTH DAKOTA N.A. Plaintiff v. SPEROS G NTONADOS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS-3617 Civil CIVIL ACTION -LAW Notice of Intention to File Praecipe for Default Judgment TO: Speros G Ntonados 4174 Kittatinny Drive Mechanicsburg PA 17050-9138 IMPORTANT NOTICE C-5863 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 County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: November 14, 2006 P.C. In making this communication, we advise our office is a debt collector. Yale emstein, Esquire Atto for Plaintiff Ide~~cation No. 89678 106"0 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 cc: Brian J. Tyler, Esquire 1719 N. Front Street Harrisburg, PA 17102 z /~/ M ~.."~... '~+ f 1 ~ ~: " N _ } j1 ~-•4 '"C7 ~~ ~``*~ " j '-{ , ~t =`r t`C1 ~{ ,~ . ~. Burton Neil & Associates, P.C. BY: Yale D. Weinstein, Esquire ID. NO. 89678 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 v. SPEROS G NTONADOS Defendant NO. OS-3617 Civil CNIL ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on .11~c, /~. a.Od~ Prothonotary By: ~~ If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. Burton Neil & Associates, P.C. By Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS-3617 Civil SPEROS G NTONADOS Defendant CIVII, ACTION -LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. By: Y The law firm of Burton Neil & Associates is a debt collector. & s sates, P.C. . Weinstein, Esquire nev for Plaintiff C-5863 C O o 'C3 ~ 3~ r'fi~_: ~ ~ T ~ ~ ±_ . ~ `"L_' ~ ~ ~ --~ N ~ -C