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Home My WebLink About07-5424 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. N0.203465 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. ANN G RUTHERFORD 32 William Penn Drive Camp Hill PA 1 70 1 1-6667 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. t7`] _ 6~a~ Civr I ~CrM 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 Baz Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-12338 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire, I.D. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 _Attomey for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. ANN G RUTHERFORD 32 William Penn Drive Camp Hill PA 17011-6667 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Ann G Rutherford, who resides at 32 William Penn Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged 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 5410658426257810 hereinafter referred to as the credit card account. 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. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $10,934.81 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 against defendant for the sum of $10,934.81, and the costs of this action. Burton Neil & Associates, P By: Neil Sarker, Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. r 06/04/07 510934.81 =10934.81 SITE:KC-CL TM:CO-5000 ACID:KCB3104 •• ._ •58• •.•::• :z-•:-,>_~ ~::n ~•~.'= ~~sii~:.`..,.~:_ 07/24/07 20 . . 14. CITI CARDS PO BOX 183055 ANN G RUTHERFORD COLUMBUS. OH 32 WILLIAM PENN DR 43218-3055 CAMP HILL PA ~ ` 17011-6667000 l ~~ ~ ~ t~~ Card iti® Platinum Seiect C Account Number 5410 6584 2625 7810 Gustomar Sarvlc~ 1-800-950-5114 Total Credit Llne Available Credit line 50 Gash Advance Umit 510000 Available Cash Limit 50 New aalance 510934.81 511000 BOX 6062 Statement/ Amount Over SIOUX FALLS, SD Cioeln Date 4redit Llne 57117 05/08/2x07 10.00 Past Dua :1689.12 PurcA/Adv Inimum Due ~ 451.53. Minimum Amount Dua 510934.81 Standard Purch 5/08 LATE FEE - APR PAYMENT PAST DUE 00000000009'00 66 0000 5/08 PURCHASES*FINANCE CHARGE*PERIODIC RATE 00000000004.65 84 0000 Standard Adv 5/08 ADVANCES*FINANCE CHARGE*PERIODIC RATE 298.88 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (05/02/07), which was 510,592.28. Help is available! Please call the toll-free number shown above to learn about our special pa ment options. 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. EXHIBIT revlous (t) urc ases - aymen s t) ew Acctxnt Summary Balance & Advances & Credits CHARGE Balance PURCHASES NCES 5162.21 539.00 3 0.00 00 s 54.65 5205.86 3 81 53 ~10 30 TOTA 10,592.28 9.00 5 0. , 4. . S Da s Thls Blllin Period: 32 a once ec o eno is om na ANNUAL Rate Summary Finance Charqe Rate APR PERCENTAGE RATE rd Purch 5164.45 0.08833%(D) 32.240% 32.240% rd Adv 510,574.14 0.08833%(D) 32.240% 32.240% Y Verification Shauna Houghton I, 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 on its behalf. I azn authorized to make this verification asattorney-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 aze true and correct to the best of my knowledge, information and belief. I understand that the statements made herein aze subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Signature Sharma Houghton Ann G Rutherford 5410658426257810 ~i~:~~~.JUM C,{'iV6if~ nclcipuoM enus~l2 "~ ~ ~ 00 ~ ._. .p ~j ~ ~"' ' ~*1 J ~ 0o D ,,~" ~ ~ ~ G"i - SHERIFF'S RETURN - NOT FOUND M CASE NO: 2007-05424 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS RUTHERFORD ANN G R. Thomas Kline ,Sheriff or Deputy Sheriff, who be:Lng duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT RUTHERFORD ANN G but was unable to locate Her in his bailiwick. He therefore returns the l'Y/1T rtTlT n TTTT r TT/1TT/~1"~ NOT FOUND as to the within named DEFENDANT RUTHERFORD ANN G 32 WILLIAM PENN DRIE CAMP HILL, PA 17011-6667 PER POST OFFICE, DEFENDANT LIVES IN NORTH CAROLINA. Sheriff's Costs: Docketing Service Not Found 907 ' Surcharge ~D -'Ia /._-.~ ~- 18 0 0 So answe~ ..~. ~ ti... ,... ...~ _. s 14.4 0 ~~ ~ i~ ~~ 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 47.40 BURTON NEIL & ASSOCIATES 10/02/2007 Sworn and Subscribed to before me this day of A.D.