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HomeMy WebLinkAbout05-5762 ~ 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 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS' - S7W-.. C;u;l ~0L~ JEREMIAH W MAURICE 305 16 Street, New Cumberland PA 17070-1316 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-8051 1111111111111111111111111111111111111111 I ~~III mlllmllllllll~111111 ~1I11111111111111111 ~IIIIIIIMIIIIIIIM II 11111111 11111 II 11M BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, P A 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. NO. JEREMIAH W MAURICE 30516 Street, New Cumberland PA 17070-1316 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 Jeremiah W Maurice, who resides at 305 16 Street, New Cumberland, 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 5424180188055054 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. 1 9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $10,160.60. Wherefore, plaintiff demands judgment against defendant for the sum of $1 0, 160.60, and the costs of this action. BURTON N~ & ASSOCIATES, P.c. / .......>." By: .....c.,....:L L _ - Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 08/10/05 $10160.60 $1720.97 SITE:KC-CL ....................... n .......onno..on ;:::P.li.1:j::::fJ:ut:::Q~ffi:::::::: n.n.n.n.n........... u__..................... ..........-------------- ......................... :~:~~~:~:M~~~:~:~: :~:~:~~:~:~~:~:~~:~:~: CITI CARDS PO 8DX 183060 COLUMBUS, OH 43218-3060 JEREMIAH W MAURICE 305 16 STREET NEW CUMBERLAND 17070-1316000 PA Citi" Platinum Select" Card Account Number 5424 1801 8805 5054 Customer Service: 1-800-950-5114 80X 6500 SIOUX FALLS, 50 57117 Total Credit Line $9500 Statement! Cl051n9 Date 07/15/2005 Anllable Credit Line $0 Amount Over Credit Line $660.60 + Cast! Advance Limit $3000 Available Cash Limit $0 Purch/Adv Minimum On $291. 51 = TM:CO-5000 09/14/05 ~. Cltl New Balance $10160.60 Minimum Amount Due $1720.97 ACID:KCB71S0 20:40:37: Past Due $768.86 + Sale Dat& Post Date Reference Number 7/15 7/15 7/15 7/15 Activity Since Last Statement Standard Purch LATE FEE - JUN PAYMENT PAST DUE 66 0000 OVER CREOIT LIMIT FEE 62 0000 PURCHASES'FINANCE CHARGE'PERIOOIC RATE 84 0000 Balance Transfer - Charqed To Offer 6 PURCHASES'FINANCE CHARGE'PERIOOIC RATE 84 0000 Your late fee was based on your account balance as of the payment due date (07/11/05), which was $9,839.09. Your account is now 3 MONTHS PAST DUE and currently closed. 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. Our records show home phone 717-770-0863 and business phone 717-533-3311. Please update coupon if incorrect. Account Summary Amount 39.00 0000000000 35.00 0000000000 123.45 0000000000 124.06 0000000000 EXHIBIT PreVIOUS (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance $9,839.09 $74.00 r.OO $247.51 $10,160.60 $0.00 $0.00 0.00 $0.00 $0.00 $9,839.09 $74.00 0.00 $247.51 $10,160.60 PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Offer 6 ADVANCES Standard Adv Periodic Rate Davs This Billing Period: 30 Nominal ANNUAL APR PERCENTAGE RATE Balance Subject to Finance Charge $4,966.78 $4,991. 43 $0.00 0.08285%(0) 0.08285%(0) 0.0828S%(D) 30.240% 30.240% 30.240% 30.240% 30.240% 30.240% A Verification in ~ltAU'L ,) C . ../. ,/6cf)! I, Cristal Britt 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 th authoriti~s. - I Date: q D [D Signature: . "';',f' ;1, 'r ...., 0 -w.. (') C:-..> c.::> "'1' G ~,~ c.n #,:n 8 N Lf( ,;.." ::e ~ c::> t \f( "'" \:;:i I Jio .;::- (.:)0 CI\ , 4..1-,--" " "'0 ;>5:U - ~ C> ::;:: '''M +---, <=(1 ~ j; ~~~ U ~ 'f! .-~ C> r ;<> ::2 c:> .,j :< V) o.D -..0 ~ ?- -r- '-i.. SHERIFF'S RETURN - REGULAR CASE NO: 2005-05762 F COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA N VS MAURICE JEREMIAH W 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 MAURICE JEREMIAH W the DEFENDANT at 2040:00 HOURS, on the lOth day of November, 2005 at 305 16TH STREET NEW CUMBERLAND, FA 17070 by handing to JEREMIAH MAURICE 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 Aft idavi t Surcharge So Answers: 18.00 16.32 .00 10.00 .00 44.32 ,,?-:;::::- _'i'..'~,t::,~~~ R. Thomas Kline 11/14/2005 BURTON NEIL Sworn and Subscribed to !i me this ; ,f I'" day of before By: r. ;I I. / C./ 1--- , l~_ ~- ;;/2 ~puty Sheriff A.D. Frot ary l I. CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5762 civil JEREMIAH W MAURICE 305 16 Street New Cumberland PA 17070-1316 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: $10,160.60 TOTAL $10,160.60 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities, I verifY that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201 (b)(1 )(A) ofthe Servicemembers Civil Relief Act of2003 (SCRA), the defendant is not in the military service of the United States based on information received from)he defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE G N UNDER P . CIV.P.236 BURTON NEIL & .:$tS~OCIA TES, .p,c. BY: l....- t./l.-- '7 Burton Neil, Esqufe Attorney for Plaij!tiff LD. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-8051 111111111111111I111111111111111111111111 111111111111111111111111111111111111111111111111111111111111111111I11111111I11111111111111 , ,..... C-8051 CITlBANK SOUTH DAKOTA N.A. : IN THE COURT OF COMMON PLEAS Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-5762 civil JEREMIAH W MAURICE Defendant : CIVlL ACTION - LAW Notice ofIoteotion to File Praecipe for Default J udgmeDt TO: Jeremiah W Maurice 305 16 Street New Cumberland PA 17070-1316 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 ofthis notice, ajudgmentmay 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 fwd out where you can get legal help. This office can provide you with information abont 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 DA IE OF NOTICE: December 5, 2005 BURTON NBIL & ASSOCIATES, P.C. In making this communication, we advise ow office is a debt collector. .,.' By: .l y~"..... Burton Neil, E uire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 IIlIMWlIIIIIII I.IIIIIIIIIII.IIIIIIIIUII c }J p +;;. ~ ~ '1-- \\.. C> c. b - ....:l ~ ~ ~ ~ ~ C' ~ (') r-> W C~:.) ~ 1- (' c::) +: .;;rl ~ C [: ~ r-'-j n N ,--. c." ( -- - - -- r<) - ../' c;:;, ...0 -------- - .r :' 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. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, NO. 05-5762 civil JEREMIAH W MAURICE Defendant : CIVIL ACTION - LAW RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a mDGMENT in the above captioned matter has been entered against you on j)~c ,.2P J (')M f /p . Mthonotary By: If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, P A 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.