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Home My WebLink About07-1117IN THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) N.A., Plaintiff vs. AMY S TAYLOR , Defendant No. 01 -- //17 0,-,, L l,, ?L. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05666368 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) N.A., Plaintiff vs. AMY S TAYLOR, Defendant Civil Action No. COMPLAINT IN CIVIL ACTION AND 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 an 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 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 50'" Street North, Sioux Falls, South Dakota, 57117. 2. Defendant is an adult individual residing at 277 REDWOOD LN CARLISLE,PA 17013. 3. Plaintiff is a national banking association, engaged in consumer lending through the issuance of credit cards. 4. Pursuant to Defendant's request, Plaintiff furnished to the Defendant a credit card account (hereinafter account) bearing account number 5424180597018313 . 5. Plaintiff kept accurate running records of all debits and credits to the Account. 6. Plaintiff mailed to Defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $3,013.28, which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, AMY S TAYLOR , individually, in the amount of $3,013.28 with interest at the statutory interest rate of 6% per annum from date of judgment plus costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. M 61W n, Esquire PA. I.D.44743 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh. Avenue Pittsburgh, PA 15219 (412) 434-7955 FEB-13-2007 14:27 WELTMAN WEINBERG & REIS P.03i21 11/20106 $3013.Z8 $3013.28 SITE:KC-CL TM:CO-5000 ACID:ROB0554 V 11121106 19:38:33: A-KINOW 16-ad-WO CITI CARDS PO BOX 183066 AMY S TAYLOR COLUMBUS. OH ATTNY ACCOUNT-CODE=PCZ9 43218-3066 CARLISLE PA 17013-7818000 i k: Citr Platinum Select` Card at1e Accourg Mwgw 5424 1805 9701 8313 Carlnmer Service: 1-800-950-5114 Total Crean Llne $2300 Awlla4a Credit Une Cash Advance Limit $0 3700 Avallable Cash L101N New Balance ?X ?? f0 $3013.28 SIOUX FALLS, SO ftalw it GI i Data % " Ameunt Over train Llno Nast Due Parey?av In wwa Due Yin hors A.. Due 57117 10/25 2 06 (713.28 la.b1 86.99 $3013.28 Sob Date Peat Date RafwaaceNumber AcWkr Slap Led Stalamard Amount Standard Pureh 10/25 PURCHASES•FINANCE CHARGE-PERIODIC RATE 48.21 84 0000 0000000000 Standard Adv 10/25 ADVANCESeFINANCE CHAR,GEaPERIODIC RATE 8,76 84 0000 0000000000 Help is available: Please call the toll-tree number shown above to learn about our special payment options. Call Monday - Friday. T am to 9 pm. gr Saturday. 8 am t0 5 pm, Central Time. Please give us the opportunity to assist you. Account Suanoilary + revBalancecul 6 urAdvances aS V) Pa S C yments redits (+) FINANCE CHARGE I..) S Now atan"' PURCHASES ADVANCES $2 500.69 4455 60 O.OD 0.00 $14.21 $2 548.90 TOTAL . $2,956.29 0.00 0 .00 1 0.00 0.00 1 58,78 $56.99 4464.38 $3,013.28 Do" This Bel Perfad. 30 Rate Summary ante u ec Finance Char4e era a Rat Nominal ANNUAL PURCHASES e APR P ERCENTAGE merE Standard Purch ADVANCES $2,523.91 0.06367%(D) 23.240% 23.240% Standard Adv $459.83 0.06367%(D) 23.240% 23.240% k 4: l 1 M. Y: Y'.. C: r. 1FFB-13-2007 14:26 WELTMAN WEINBERG & REIS P.02i21 4 { Verification I, Shauns Boughton am an employee of Citicorp Credit f Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA) N.A. retained to perform serviceg including but not primarily limited to collecting delinquent debt. I am , authorized to make this verification as attorney-in-fact for plaintiff under t powers of attorney from plaintiff to Citicorp Credit Service Inc., P (USA) t 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. ;i S t10t Defendant's name-.AMY S TAYLOR Client's acct number 5424180597018313 WW'R#05666368 i. z s 6_ noldQUGH rinusri2 040 w ? -? C'S w _ 0 fTl .a? rte} OV) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. No. 07-1117-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE AMY S. TAYLOR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I. D.#47437 WELTMAN,WEINBERG &REIS,CO. L.P.A. 436 SEVENTH AVENUE, SUITE 2718 PITTSBURGH,PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#05666368 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-1117-CIVIL AMY S. TAYLOR Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05666368 t E SWORN TO AND SCRIBED before me this day ?_? C) ?:? ,-'? ..? _ ?.? ? _ - -t` -? :- .? _-?. ;i??- c.? -n -_,.J _:1 ?.? - -- ?; SHERIFF'S RETURN - REGULAR CASE NO: 2007-01117 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS TAYLOR AMY S ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TAYLOR AMY S the DEFENDANT , at 2055:00 HOURS, on the 22nd day of March , 2007 at 277 REDWOOD LANE CARLISLE, PA 17013 AMY TAYLOR by handing to 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: So Answers: Docketing 18.00 Service 13.44 Affidavit .00 dowp? Surcharge 10.00 R. Tho as Kline .00 31d-4/6'? 41.44 00/00/0000 Sworn and Subscibed to B before me this day eputy Sheriff of A. D.