The URL can be used to link to this page

Home My WebLink About08-0814Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. TRACY A BAUMGARDNER 717 Market Street Ste 326 Lemoyne PA 17043-1581 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OER - Sl7 C?« L 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-13729 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. TRACY A BAUMGARDNER 717 Market Street Ste 326 Lemoyne PA 17043-1581 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. O k- P/9' &;Xd- -rel -• 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 Tracy A Baumgardner, who resides at 717 Market Street Ste 326, 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. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5187520049629463 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 $5,047.33 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 $5,047.33, and the costs of this action. Burton Neil & Associates, P.C. By: BriJ. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. .t , o. 12/21/07 $5047.33 $5047.33 SITE:KC-CL #pai?='ess?a?s:=:===: :asa?_>?t?;e€=?? =tsri??a?'s_??t= CITI CARDS TRACY A BAUMGARDNER PO BOX 183068 717 MARKET ST COLUMBUS, OH STE 326 43218-3068 LEMOYNE PA 17043-1581000 TM:CO-5000 ACID:KCB3104 12/27/07 22:41:48: '3i 71 Shell MasterCard from Citi* Cards Account Number 5187 5200 4962 9463 0 Customer Service: 1-800-925-8871 Total Credit Line Available Credit Line Cash Advance Limit Avail able Cash Limit New Balance BOX 6500 $4000 $0 $1200 $0 $5047.33 SIOUX FALLS, SD 57117 Statement/ Closing Date 11/27/2007 Amount Over Credit Line $1047.33 Past Due $1239.25 Purch/Adv Minimum Due $187.37 Minimum Amount Due $5047.33 Earn Rebates on Every Purchase Gasoline Rebate Summary Gasoline Rebates Gasoline Rebates Gasoline Rebates Gasoline Rebates Total Gasollne Rebates Gasoline Rebates Previously Earned Redeemed This Statement Earned This Statement Available Earned Since 12/05 ring Next Statement 10.00 0.00 .00 0.00 43.61 0.00 Sam Date resi vaw nenrence number Activity Since Last Statement Amount Standard Purch 11/27 PURCHASES*FINANCE CHARGE*PERIODIC RATE 101.94 84 0000 0000000000 Standard Adv 11/27 ADVANCES*FINANCE CHARGE*PERIODIC RATE 35.43 84 0000 0000000000 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. Account Summary Previous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Ad vances & Credits CHARGE Balance PURCHASE AADVANCESS 3643.52 1,266.44 1 0.00 0.00 0.00 0 00 1 1 $101.94 35 43 3,745.46 0 1 TOT TOTAL 4,909.96. . 0 .00 0.00 . $137.37 13 1.87 5,047.33 Days Th is Billing Period: 32 Rate Summary Balance subject to Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch ADVANCES $3,692.66 0.08627%(D) 31.490% 31.490% Standard Adv $1,283.52 0.08627%(D) 31.490% 31.490% . 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 unworn falsification to the authorities. f Signature Shauna Houghton Tracy A Baumgardner 5187520049629463 ? M 00 r7 o p I (Aj -n OV) mF SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-00814 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BAUMGARDNER TRACY A R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT 1: ZATWr-LT?nT\TRR TRArV A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 717 MARKET STREET SUITE 326 LEMOYNE, PA 17043 NOT FOUND , as to BAUMGARDNER TRACY A DEFENDANT ONLY HAS A MAILBOX AT GIVEN ADDRESS. SHE DOES NOT LIVE THERE. Sheriff's Costs: Docketing 18.00 Service 14.40 Not Found 5.00 Surcharge 10.00 00 2I 20'0 . 4 0 - -"' So answers: R. Thomas Kline Sheriff of Cumberland County BURTON NEIL 02/15/2008 Sworn and Subscribed to before me this day of A. D. Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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 Plaintiff V. TRACY A BAUMGARDNER 229 Susquehanna Avenue, Enola PA 17025 Defendant CUMBERLAND COUNTY, PENNSYLVANIA : NO, 08-814 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. Burton Neil & Associates, P.C. By. `f Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-13729 Pr 1?3 f/"1 ` L SHERIFF'S RETURN - REGULAR CASE NO: 2008-00814 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BAUMGARDNER TRACY A RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAUMGARDNER TRACY A the DEFENDANT , at 1809:00 HOURS, on the 5th day of March at 229 SUSQUEHANNA AVENUE ENOLA, PA 17025 by handing to TRACY BAUMGARDNER 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 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 shz Jai, 9, o 0 42.40 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 03/07/2008 BURTON NEIL By : ' Deputy S eriff A. D. , 2008 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. TRACY A BAUMGARDNER 229 Susquehanna Avenue Enola PA 17025 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-814 CIVIL TERM CIVIL ACTION - LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $5,047.33 $5,047.33 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTIC GIVEN ER PA.R.CIV.P. 236 gum" Pr roth Burton it MSuttell, s, P.C. By: B tquire Attorney for Plaintiff I.D. NO. 204140 51la108 The law firm of Burton Neil & Associates is a debt collector. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 C-13729 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. TRACY A BAUMGARDNER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-814 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Tracy A Baumgardner 229 Susquehanna Avenue Enola PA 17025 IMPORTANT NOTICE C-13729 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office 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 DATE OF NOTICE: March 27, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C By: C I 4,",u Brit . Suttei Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 F Q C a T 00 SL ? .x? ? c.s ? crr , Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. TRACY A BAUMGARDNER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-814 CIVIL TERM : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 5wi o8 P othonot By: Deputy If you have any questions concerning the above, please contact: Brit J. Suttell, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector