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Home My WebLink About06-3357LARIO & SALDUTTI By: Robert L. Saldutti, Esquire Identification No. PA - 63867 89 North Haddon Avenue Haddonfield, NJ 08033 (856) 795-4345 Attorney for Plaintiff BANK OF AMERICA, N.A. (USA) 1818 Market Street Philadelphia, PA 19103 Plaintiff V. JEFFREY D. DOYLE 635 Lerew Road Boiling Springs, PA 17007-9504 Defendant 200 Locust Street Unit 24E North Philadelphia, PA 19106 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW DOCKET NO. OL- 3391 `tui l?rcJL? NOTICE TO DEFEND 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 twenty (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 claims 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. Lawyer Referral Service 0 Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone: 717-240-6200 LARIO & SALDUTTI By: Robert L. Saldutti, Esquire Identification No. PA - 63867 89 North. Haddon Avenue Haddonfield, NJ 08033 (856) 795-4345 Attorney for Plaintiff BANK OF AMERICA, N.A. (USA) 1818 Market Street Philadelphia, PA 19103 Plaintiff V. JEFFREY D. DOYLE 635 Lerew Road Boiling Springs, PA 17007-9504 Defendant 200 Locust Street Unit 24E North Philadelphia, PA 19106 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW DocKETNo. 61? -3351 COMPLAINT - CIVIL ACTION CONTRACT 1. Plaintiff is a corporation with a place of business located at 1818 Market Street, Philadelphia, PA 19103 and at various other locations throughout the Commonwealth of Pennsylvania. 2. The defendant, Jeffrey D. Doyle, is an adult individual residing at 635 Lerew Road, Boiling Springs, PA 17007-9504. 3. Defendant entered into a Bank of America Visa Credit Card Account and Agreement under Account No. 4305500376566645 and made various credit purchases against this account. See Bank of America Visa Account Credit Card Statements attached hereto as Eadubit "A" 4. By the terns of said contract, defendant was obliged to make repayment of monies loaned in monthly payments and or pay the balance in full until the entire debt was repaid. Defendant has defaulted on his obligations under said contract by failing to pay monthly installments or repay the entire balance of the loan. 6. The credit card agreement provides that upon default in the payments of the agreed installments, defendant will pay to plaintiff reasonable attorney's fees and any costs incurred by plaintiff in the enforcement of this contact and agreement. Plaintiff has employed the undersigned attorneys to represent them in the filing of this suit and has agreed to pay them a reasonable fee for their services. 8. There is currently due and owing from the defendant to the plaintiff the sum of $7,437.88, together with attorney's fees in the amount of $1,859.47, interest and costs of suit. 9. Although plaintiff has demanded payment of the sum in question, defendant has refused to pay. WHEREFORE, plaintiff requests judgment as follows: Judgment be entered in favor of plaintiff, Bank of America, N.A. (USA) and against defendant, Jeffrey D. Doyle for $7,437.88; 2. Attorney's fees in a reasonable amount or 25% of the unpaid balance. In this particular litigation, $1,859.47; 3. Plaintiffs costs of the suit incurred in this action; and 4. Such other and further relief as the court may deem just and proper. LARIO & Robert L. Saldutt-Esquire 89 North Haddon Avenue Haddonfield, NJ 08033 Telephone: (856) 795-4345 Attorney for Plaintiff, Bank of America, N.A. (USA) Dated: May 22, 2006 VERIFICATION I hereby certify that I am authorized to make this verification on behalf of Bank of America, successor in interest to Fleet Bank and/or Summit Bank, plaintiff in the within action, and that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. EXHIBIT "A" Bankof America -q1W JEFFREY DOYLE Account Number: 4305 5003 7656 6645 Your Bank of America Visa® Account New Balance $7,437.88 Past Due Amount $7,267.77 Total Credit Line $0.00 Available Credit $0.00 Cash Limit $0.00 Available Cash $0.00 Overlimit Amount $1,037.88 Billing Date 0212806 Minimum Payment Due $7,437.88 Payment Due Date 03125/06 24-Hour Customer Service 1.800.492.2500 Pay online) Visit For Lost or Stolen Cards 1.800.848.6090 www.bankofamerica.com Transactions View recent transactions and pay your bill online at www.bankofamerica.com. POST. TRANS. REF. DESCRIPTION AM07 DATE DATE NO. CR=CREDIT Feb 28 Feb 28 PERIODIC FINANCE CHARGE $170.11 Account Summary Previous Balance $7,267.77 Purchases + $0,00 Cash Advances + $0.00 Other Debits + $0.00 Credits - $0.00 FINANCE CHARGE + $170.11 Payments - $0.D0 New Balance = $7,437.88 Past Due Amount = $7,267.77 Finance Charge Summary Corresponding Daily (D) / Monthly (M) Average Daily Minimum (M) / APR Periodic Rate Balance (ADS) Periodic (P) Charge Purchases 27.252% 0.07466%v D $7,349.73 $170.11 P Cash 27.252% 0.07466%v D $0.00 $0.00 P ANNUAL PERCENTAGE RATE 27.252% v=variable Please remit this Overlimit amount to us immediately or call: 1.800.236.6497. Bank of America -00- Customer Corner 0067563 0743788 0743788 4305500376566645 BANK OF AMERICA PO Box 1758 NEWARK NJ 07101-1758 IIIurloll lurllllnnnllud16u61Jdu1r,61du1dm11 L (y<<L Pavment Couoon Account Number 4305 5003 7656 6645 Payment Due Dale 03/25/06 Total Minimum Payment Due $7,437.88 New Balance: $7.437.88 '^ CJ -G G V, SHERIFF'S RETURN - REGULAR CASE NO: 2006-03357 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA NA VS DOYLE JEFFREY D SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE nOYLE JEFFREY D was served upon the DEFENDANT , at 1600:00 HOURS, on the 5th day of July , 2006 at 635 LEREW ROAD BOILING SPRINGS, PA 17007 JEFFREY DOYLE by handing to 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: So Answers: Docketing 18.00 Service 5.28 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 33.f8-,' 07/06/2006 7.1q-6(, LARIO & SALDUTTI Sworn and Subscibed to By: before me this day eputy Sher ff of A. D. Curtis R. Long Prothonotary office of the Protbonotarp Cumberfaub Couutp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 10?=,3„3 -q!7 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573