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Home My WebLink About07-6953Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. MARYBETH WILLIAMS 341 Herman Avenue, Lemoyne PA 17043-1940 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. pq - (oq 53 C w l t l erm 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-12581 I1111111III111111IIIIIIIIIIIIIIIIIIIIIIIIIIII I1111111IIIII111111IIIIIIIIIIIIII111111IIIIIIIIIIIIIII??f11IINIiINliu11N?111111111IIIIII Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 2.- G fS 3 C, ,`J 7?,n MARYBETH WILLIAMS 341 Herman Avenue, Lemoyne PA 17043-1940 Defendant 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 Marybeth Williams, who resides at 341 Herman Avenue, Lemoyne, 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. Count I 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180715122039 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 $2,082.54 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 $2,082.54, and the costs of this action. Count II 9. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180777966547 hereinafter referred to as the credit card account. 10. Plaintiff kept accurate running records of all debits and credits to the account. 11. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit B. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 12. Before plaintiff mailed Exhibit B, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 13. Defendant's actions as set forth above constituted an account stated between parties for the sum of $1,512.04 which sum reflects the Exhibit B statement balance less credits, if any, which were applied subsequent to the date of Exhibit B. Wherefore, plaintiff demands judgment against defendant for the sum of $1,512.04, and the costs of this action. Burton NeX& Associates, P.C. Neil, Esquire v for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt 12/01/06 $2082.54 $2082.54 SITE:KC-CL TM:CO-5000 ACID:KCB3104 `:ki >s aasi 09/11/07 2 3: 3 0: 05 CITI CARDS PO BOX 183055 MARYBETH WILLIAMS COLUMBUS, OH 341 HERMAN AVE 43218-3055 LEMOYNE PA 17043-1940000 Citi' Upromise' Platinum Select MasterCard" Account Number 5424 1807 1512 2039 Customer Servke. 1-800-568-5000 Total Credit Line Available Credit Line BOX 6500 $1610 $ 0 Statement/ Amount Over SIOUX FALLS, SD closln Date Credit Line 57117 11/07/206 $472.54 Cash Advance Limit Available Cash Limit $800 $0 Past Due Minimum Dui $503.90 $110.66 C t'• New Balance $2082.54 Minimum Amount Due $2082.54 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 11/07 LATE FEE - OCT PAYMENT PAST DUE 39.00 66 0000 0000000000 11/07 PURCHASES*FINANCE CHARGE*PERIODIC RATE 51.66 84 0000 0000000000 REMINDER: You may be assessed an over-the-credit-line fee if your account balance exceeds your credit line at any time during the billing period. Your late fee was based on your account balance as of the payment due date (11/01/06), which was $1,991.88. Help is available! Please call the toll-free number shown above to learn about our special payment 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?- Account Summary Previous + Purchases (-) Payments (+) FINANCE (= New Balance & Advances & Credits CHARGE Balance PURCHASES $1,991.88 $39.00 0.00 $51.66 $2 082.54 ADVANCES $0.00 $0.00 0.00 1 $0.00 , $0.00 TOTAL $1,991.88 $39.00 0.00 $51.66 $2,082.54 Days This Billin Period: 29 Rate Summary Balance Subject to Periodic Nominal Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $2,016.71 0.08833%(D) 32.240% 32.240% ADVANCES Standard Adv $0.00 0.08833%(D) 32.240% 32.240% r¦r?rr 12/12/06 $1512.04 $1512.04 SITE:KC-CL TM:C0-5000 ACID:KCB3104 "M '000 1y LA ._01 '61, 1 09/07/07 23:42:42: CITI CARDS P.O. BOX 6413 MARYBETH WILLIAMS THE LAKES, NV 11911 HE 142ND PL 88901-6413 98034-14 KIRKLAND WA 98034-1454000 ? '/?_? V ? ` ' C tip Citi Dividen d Platinu m Select Card Account Number 5424 1807 7796 6547 Customer Servke• 1-800-568-5000 Total Credit Lint Available Credit Line Cash Advance Limit Available Cash Limit New 04140ce BOX 6000 $1000 $0 6300 $0 $1512.04 THE LAKES, NY Statement/ Ciosing Data Amount Over Credit Line Pest Due Porch/Adv MI mum Due Min u AmountmDum e 89163-6000 11/1 7/2006 6512.04 $371.49 89.97 $1512.04 Sole Date Post Date Refereaa Num ber Activity Since Lest Statement Amount Standard Purch 11/17 CREDIT PROTECTOR FEE MNTHLY 8009505114 0.00 74 0000 0000000000 11/17 LATE FEE - OCT PAYMENT PAST DUE 39.00 66 0000 0000000000 11/17 PURCHASES*FINANCE CHARGE*PERIODIC RATE 35.97 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (11/13/06), which was $1,437.07. Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am t0 5 pm, Central Time. Please give us the opportunity to assist you. EXHIBIT 6 Account Summary Previous + Purchases - Payments (+) FINANCE (z) N ew Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $1,47.07 0 00 $39.00 0.00 $0 00 1 $15.97 $1,512.04 . . 0.00 0.00 $0.00 TOTAL $1,437.07 $39.00 0.00 $35.97 $1,512.04 Days This Billing Period 28 Rata Summary Balance Subject to Per-16411 s omina ENTA Finance Charge Rate APR PERC GE RATE PURCHASES Standard Purch $1,454.34 0.08833%(D) 32.240% 32 240% ADVANCES . Standard Adv $0.00 0.08833%(D) 32.240% 32.240% .._..11 -- ............. . a Verification I, Shauna Houghton 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 am authorized to make this verification as attorney-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 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. Signature Shauna Houghton Marybeth Williams 5424180715122039 3 r r.? 00 8 ?, SHERIFF'S RETURN - REGULAR CASE NO: 2007-06953 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS WILLIAMS MARYBETH 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 WILLIAMS MARYBETH the DEFENDANT , at 1412:00 HOURS, on the 30th day of November-, 2007 at 341 HERMAN AVENUE LEMOYNE, PA 17043-1940 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: Docketing Service Affidavit Surcharge A, /4D Sworn and Subscibed to before me this So Answers: 18.00 15.36 .00 10.00 R. Thomas Kline .00 43.36 12/04/2007 BURTON NEIL By: day Deputy Sheriff of A. D. Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. MARYBETH WILLIAMS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6953 Civl Term : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil Ass iftes, P.C. ELI Burton eil, Esquire Attorrrne for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-12587 CC) rn f= Ul rO