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Home My WebLink About03-3168BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 26 South Church Street West Chester, PA 19382 610o696-2120 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 REBEKAH L MACEYKO 500 WALNUT STREET APT C-1 LEMOYNE, PA Defendant : NO. 03- 3lGf' ~ '-'/"-~...~ : 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 717-249-3166 10020.034.3995 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CIT1BANK (SOUTH DAKOTA) N.A. 701 EAST 60TH STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA REBEKAH L MACEYKO 500 WALNUT STREET APT C-1 LEMOYNE, PENNSYLVANIA Defendant NO. (9S- 3/~- g~ : CIVIL ACTION - LAW Complaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is REBEKAH L MACEYKO, who resides at 500 WALNUT STREET APT C-1 LEMOYNE, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5491130393899646 for the defendant's use in making credit purchases and securing cash advances subject to the terms and conditions governing the use of the credit card. Attached hereto, made a part hereof and marked Exhibit A is a true and correct copy of the terms and conditions. 4. The defendant accepted the credit card and the terms and conditions governing its use for the purchase of goods, merchandise and services and/or cash advances from vendors who accepted plaintiffs credit card. In using the credit card, the defendant agreed to comply with the terms and conditions governing its use which included the obligation to pay plaintiff for all the charges made in full upon receipt of the statement or in installments subject to monthly fmance charges. 5. The defendant utilized the credit card by making/obtaining purchases of goods, merchandise and services and/or cash advances from vendors who accepted the credit card. Monthly statements were sent to the defendant which detailed the charges made to the account including finance charges, late and/or over limit charges. The balance due for the charges made by the defendant including any finance charges, late or over limit charges is $1,763.52. 6. Defendant did not pay' the balance due in full upon receipt of the billing statements and failed to make the required minimum monthly payment set forth in the the billing statement. As such, defendant is in default of the terms and conditions governing the use of the credit card. 7. Although demand has been made by plaintiffupon defendant to pay the sum of $1,763.52, the defendant failed and refused to pay all or any part thereof. 8. Plaintiff alleges it is entitled to recovery of attorney's fees from defendant pursuant to the terms and conditions governing the account. Plaintiffs counsel is not a salaried employee of Citibank (South Dakota) N.A. Plaintiff seeks recovery of attorney fees in the sum of $335.07. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $1,763.52, attorneys fees in the sum of $335.07 and the costs of this action. Q~BURTON~IL & ASSOCIATES, P.C. B~6'n Neil, Esquire Attorney for Plaint~f In making this communication, we advise our firm is a debt collector. ~] Verification Jennifer Sisson is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Citigroup, the within Plaintiff in this action. She verifies that the statements of fact made in the foregoing Complaint are true and correct to the best of her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: REBEKAH L MACEYKO 5491130393899646 10020.034.3995 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-03168 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS MACEYKO REBEtQAH L R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT MACEYKO REBEKAH L unable to locate Her COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being search and in his bailiwick. but was He therefore returns the the within named DEFENDANT , NOT FOUND , as to , MACEYKO REBEKAH L 500 WALNUT STREET APT C-1 LEMOYNE, PA 17043 DEFENDANT'S CURRENT ADDRESS 12406 IS PLANTATION PINE LANE APT 104 TAMPA, FL 33635-1811. Sheriff's Costs: Docketing 18.00 Service 11.04 Not Found 5.00 Surcharge 10.00 .00 44.04 So answers: ~ ~z~..~._~ /_~__.~ // R. Thomas ~t~ne Sheriff of Cumb6rland County BURTON NEIL 07/10/2003 Sworn and subscribed to before me this /4 ~ day of C~ tary ' BURTON N-EEL 8: ASSOCIATES, P.C. By: Burton Nell, Esquire Identification number: 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 701 EAST 60TH STREET NORTH KANSAS CITY, MO Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 15407 REBEKAH L MACEYKO 500 WALNUT STREET APT C-1 LEMOYNE, PA Defendant NO. 03-3168 CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. BURTONS/IL & ASSOCIATES, P.C. Attorney for Plaintiff 10020.034.3995