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HomeMy WebLinkAbout08-1081Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. PAMELA L PALMER 10 W Pomfret Street #2, Carlisle PA 17013-3216 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1081 Oivl( -?--M 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-13760 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 8 - 16S/ U'd w-- PAMELA L PALMER 10 W Pomfret Street #2, Carlisle PA 17013-3216 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 Pamela L Palmer, who resides at 10 W Pomfret Street #2, Carlisle, 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 5424180190592961 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 $1,996.25 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 $1,996.25, and the costs of this action. P.C. By: Derek C. Blask'ef, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 11/03/04 $5029.16 $482.11 SITE:KC-CL TM:CO-5000 ACID:KCB3104 Pa ........ = aii vii:= s?tri = 3 == u>R = ?s# ? ?= 01/03/08 23:38:31: CITI CARDS PO BOX 183057 PAMELA L PALMER COLUMBUS, OH 4 TRINE AVE 43218-3057 MOUNT HOLLY SPRINGS PA 17065-1143000 CitioUpromise- Ctm Platinum Select MasterCard Account Number 5424 1801 9059 2961 Customer Service. 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $6300 $1270 $1500 $1270 $5029.16 BOX 6500 Statement/ Amount Over SIOUX FALLS, SO Closing Date Credit line Past Due Purch/Adv Minimum nimum Due Amount Due I? I 57117 10112/2004 $0.00 + $352.89 + 1129.22 = $482.11 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 10112 LATE FEE - SEP PAYMENT PAST DUE 35.00 66 0000 0000000000 10112 PURCHASES*FINANCE CHARGE*PERIODIC RATE 124.22 84 0000 0000000000 ***Upromise Service for Citi Cardmembers*** Previous Statement's Dollars Earned Dollars Earned This Billing Period Bonus Dollars Earned This Period Total Dollars Earned This Period Dollars To be Transferred to Upromise Dollars Earned Since Enrollment 53.63 0.00 0.00 0.00 0.00 53.63 Bonus Cash Back may take one to two billingg cylles to appear on your statement. Please refer to the specific term$ and conditions pertaining to the promotion for further details. You must contact Upromise to complete your enrollment. Any accumulation indicated above will not be eligible until this has occurred. Your account is past due. Please pay the Minimum Amount Due shown. If you have already sent us this payment, thank you. EXHIBIT N- Accourtt Summary Previous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance PURCHASES $4,869.94 $35.00 $0.00 $124.22 $5,029.16 ADVANCES $0.00 $0.00 $0.00 $0.00 $0.00 TOTAL $4,869.94 $35.00 $0.00 $124.22 $5,029.16 Days This Billing Period: 32 Rate Summary Balance Subject to Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $4,929.85 0.07874%(D) 28.740% 28.740% ADVANCES Standard Adv $0.00 0.07874%(D) 28.740% 28.740% 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 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. r f ' Signature Shauna Houghton Pamela L Palmer 5424180190592961 A6 V ? ((y!fin? i ?., V V tJ 4S-f q SHERIFF'S RETURN - REGULAR CASE NO: 2008-01081 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PALMER PAMELA L STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DAT,MRR UAMRT,A T, the DEFENDANT , at 0950:00 HOURS, on the 21st day of February-, 2008 at 10 W POMFRET STREET #2 CARLISLE, PA 17013-3216 by handing to PAMELA PALMER 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 3J63/0k , So Answers: 18.00 4.80 .00 10.00 R. Thomas Kline .00 32.80 02/21/2008 BURTON NEIL Sworn and Subscibed to before me this of By .A?_ez_ day eputy Sheriff A. D. r 1" CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. PAMELA L PALMER 10 W Pomfret Street #2 Carlisle PA 17013-3216 Defendant Praecipe for Default Judgment To the Prothonotary: 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 : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1081 CIVIL TERM : CIVIL ACTION - LAW $1,996.25 $1,996.25 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. NOTICE GIVEN UNDER PA.R.CIV.P. 236 Pro Prothonj 41,/08 B aDeWrek_S&r, iates, P.C. B Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-13760 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. PAMELA L PALMER Defendant : IN THE COURT OF COMMON PLEAS C-13760 : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1081 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Pamela L Palmer 10 W Pomfret Street #2 Carlisle PA 17013-3216 IMPORTANT NOTICE 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 18, 2008 In making this communication, we advise our office is a debt collector. By: Attorney P.C. BuU1aser,.s"cqqu?iirSA'- Derfor Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 ?, na -a Ar? D _, W , 1 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 : CUMBERLAND COUNTY, PENNSYLVANIA I Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against v. : NO. 08-1081 CIVIL TERM PAMELA L PALMER Defendant CIVIL ACTION -LAW you on 'q1/1/ 02 Prothonotary By: If you have any questions concerning the above, please contact: Derek C. Blasker, 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.