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Home My WebLink About07-69334 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MARGARET MUSTIN NO. CYA7 863 Acri Road, Mechanicsburg PA 17050-2231 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, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-12302 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorne for Plaintiff CITIBANK DAKOTA) N.A. 701 East ( 60th S Street OUTH N = THE COURT OF COMMON PLEAS Sioux Falls, SD 57117 V. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA MARGARET MUSTIN : NO. 863 Acri Road, Mechanicsburg PA 17050 Defendant CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with lace o 701 East 60th Street North, Sioux Falls South Dakota. 2. Defendant is Margaret Mustin, who resides at 863 Acri Road M Cumberland County, Pennsylvania. Mechanicsburg, 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(n) AT&T Universal credit card with account number 5491130372400242 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 i statement attached hereto as Exhibit A. The monthly including 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 $16,048.02 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 $16,048-02, and the costs of this action. Burton N ' & A socia .C. Bf: Yale . We' tei Atto ey for Plaintiff 7 The law firm of Burton Neil & Associates, P.C. is a debt collector. 08W AT&T Universal Rewards Card Charter Member MARGARET MUSTIN Account 5491 9303 7240 0242 Calling Card + PIN April 3 - May 3, 2007 Quick Reference Minimum Payment Due .......................... Due Date"......... ... $486207 "P ment must May A, 2007 Amount ?' be Past received Due by 5:00 pm lopl time on the payment due date. ..t...,., Amount Over Limi ............................................ $2682.36 Credit Line i 9.75 .. Available Credit ................."""""" $17,360.00 Cash Advance Limit ................... .................. $0.00 Available Cash Advance..Limit .............................$1'0.00 . $0.00 Account Summary Prt?VIO s B^I"nna i S 70 1ldastert^ard Arn vity 56,51 AR New Balance S7 B,629.75 Note: Detailed activity starts on page 3. AO% Citl* AT&T Universal Card Page 1 of 3 How To Reach Us Visit: www.universalcard.oom Customer Service: 1-800-423-4343 or write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Your late fee was based on your account balance as of the payment due date (04/27/07), which was $18,065.79. Your account balance is over the credit line. In order to continue earning ThankYou Points with your card, you must bring your account balance under the credit line now. If you have not already done so, please pay the Minimum Payment Due. date paid amount paid check # AT&T and the AT&T globe design are trademarks of Please follow payment Instructions outlined In the "Important Instructions for Making Payments- section of thestatemen , Ikensed to Citlgroup b1C 05491130372400242999999999995915 Yaw Account Muniber E5491 1303 7240 0242 Payrneet pue paKe Yow Total Balance Please Enter Amoent of Payment Enclosed MAY 2 8 2007 N?nMan Amount Due X18629.75 $4662.07 5935 MC 20 A I AR7051805 't1 MARGARET tRET MUSTUST'I'1 I?IIIt1111?11'l'ilt/Ir11111'?1111'II'?111' ?1 ?III11"IIIII'It1'?IIII111'll I'Itl t'1I111'1I11'/I' IN 863 ACRI RD AT&T UNIVERSAL CARD MECHANICSBURG PA 17050-2277 PO BOX 183052 COLUMBUS, OH 43218-3052 nlrtrtlunntlrtlurtrfrllnnnllrlntlrnlrtulltnrtnrlr Cid 3 6 2- EXHIBIT_z4 MARGARET MUSTIN Account 5491 1303 7240 0242 April 3 - May 3, 2007 AT&T Universal Gard Page 2 of 3 In the return envelope, please; I Make your check payable to AT&T Universal Card. 2 Enclose your check or money order. Include your account number and name on the front of your check or money order. Please, no cash or foreign currency. 3 Enclose your payment coupon. Do not staple or tape it to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. Verification I, Kris. Dietz Inc., (USA) which is by contract the service provider for an employee of Citicorp Credit Services, DAKOTA), N.A. retained to perform services on its plaintiff CITIBANK (SOUTH verification as attorney-in-fact for plaintiff under powers of attorney from plain rp tiff to Citico Credit Services, Inc. (USA) and to me. The foregoing averment are true and correct to the best of my knowledge, information s of fact in the within pleading and belief. made herein are subject to the penalties of 18 pa I understand that the unsworn falsification to the authorities. C.S. Section 4904, relating to Li:; - I -'4-0 Signature Margaret Mustin 5491130372400242 ?a. s CD d ? Pn c 'r m A s-: Urn k Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6933-Civil Term MARGARET MUSTIN Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action wi By: Neil Y P.C. koifistein, Esquire for Plaintiff The law firm of Burton Neil & Associates is a debt collector. V C-12302 IIIU111111111111ININININ1111I IN 111111111 IN IN 1111111hI1111111111IN 111111111IN 111111111111 IN 1111111111111111111111111111IIIRIIIII IN tP, C-7 Vic. SHERIFF'S RETURN - REGULAR CASE NO: 2007-06933 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MUSTIN MARGARET KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MUSTIN MARGARET the DEFENDANT , at 1815:00 HOURS, on the 6th day of December , 2007 at 863 ACRI RnAn EMCAHNICSBURG, PA 17050-2231 by handing to ROBERT MUSTIN 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 Affidavit Surcharge %. /i 76.7 -, So Answers: 18.00 14.40 ???%?•,?,? ??? .00 10.00 R. Thomas Kline 00 42.40 12/07/2007 BURTON NEIL Sworn and Subscibed to before me this day By: of A. D. 4(-?A She ff