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Home My WebLink About08-1585Burton 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTHER M SINGER : NO. p? - 15$5 aiVit (erm 1169 Three Square Hollow Road, Newburg PA 17240 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-14250 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTHER M SINGER 1169 Three Square Hollow Road, Newburg PA 17240 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 Esther M Singer, who resides at 1169 Three Square Hollow Road, Newburg, 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 5424180538120814 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 $11,131.67 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 $11,131.67, and the costs of this action. Burton Ndi1 & Abg4iates, P.C. YaYX(e?-Ior We' tein, Esquire Att Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt 01/08/08 $11131.67 $11131.67 SITE:KC-CL TM:CO-5000 ACID:KCB0201 r ? c3 02/02/08 23:01:20: , CITI CARDS PO BOX 183060 ESTHER M SINGER COLUMBUS, OH 1169 THREE SO HOLLOW NEWBURG RD PA 43218-3060 17240-9 17240-9 345000 Lb5o Citio Driver's Edge® C tie Platinum Select Card-Charter Rbts Account 5424 1805 3812 0814 Customer 5111"I m 1-800-756-4000 Total Credit Line Available Credit Line CaM Advance Limit Available Cash Limit $9200 $0 New Balance $5500 $0 BOX 6500 $11131.67 statement/ Amount Over Purch/Adv SIOUX FALLS, SO Closl Date Credit Line Past Due Ira U ou• 2 Minimum Amount Due 57117 12/14/ 07 $1931.67 $2235.53 431.08 $11131.67 sale Data Poat Date Relareace Num ber Activity Since Last statement Amount Standard Purch 12/14 LATE FEE - NOV PAYMENT PAST DUE 39.00 66 0000 12/14 PURCHASES?FINANCE CHARGE•PERIODIC RATE 0000000000 206.23 84 0000 0000000000 Balance Transfer - Charged To Offer 5 12/14 P R * * U CHASES FINANCE CHARGE PERIODIC RATE 74.85 84 0000 0000000000 Your 1 to fee was based on your account balance as of the payment due date (12/10/07), which was $10,81139. 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 an to 5 pm, Central Tine. Please give us the opportunity to assist you. Our records show home phone 717-423-5122 and business phone 717-532-4146. Please update coupon if incorrect. Account Summary Previous t Purchases - Payments (+) FINANCE (z) Now - Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $10,8 1.59 0.00 $39.00 0.00 $0.00 0 00 1 $281.08 j0 00 $11,1 1.67 1 TOTAL 510,811.59 . $39.00 0.00 . $291.08 0.00 $11,131.67 Da Vs This Baling Perky 30 Rate Summary Balance Subject to Finance Charge Periodic Rate om na ANNUAL PURCHASES APR PE RCENTAGE RATE Standard Purch Offer 5 18,031.67 52 915 18 0.08559%((D)) 0 08559% D 31.240% 31.240% ADVANCES , . . ( ) 31.240% 31.240% Standard Adv $0.00 0.08559%(D) 31.240% 31.240% E x W I -B IT- Verification Shauna Houghton 1, 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 1"aa Signature Shauna Houghton Esther M Singer 5424180538120814 J r cz? t? U 4;1e ? W Q - {T7 Ul SHERIFF'S RETURN - REGULAR CASE NO: 2008-01585 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SINGER ESTHER M WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SINGER ESTHER M was served upon the DEFENDANT , at 1218:00 HOURS, on the 12th day of March , 2008 at 1169 THREE SQUARE HOLLOW ROAD NEWBURG, PA 17240 by handing to BILL SINGER, HUSBAND 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 18.00 Service 19.20 Affidavit .00 Surcharge 10.00 .00 47.20 Sworn and Subscibed to before me this day So Answers: 14111 R. Thomas Kline 03/13/2008 BURTON NEIL By: Deputy S/ iff of A. D. i' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Citibank [South Dakota] N.A. : Civil Division vs. Esther M. Singer No. 2008-1585 SUGGESTION OF BANKRUPTCY To: Prothonotary Please note upon the record that Esther M. Singer, the defendant in the above- captioned action, filed a Voluntary Petition in Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on April 2, 2008, at 8:45o'clock P.M., which petition was docketed to 1-08-bk-01161-MDF. PURSUANT TO THE PROVISIONS OF 11 U.S.C. §362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT. CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, attorney for the above captioned defendant(s) in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or attorney's of record as follows: -If Yale D. Weinstein, Esquire Citibank [ Burton Neil & Associates, PC 701 East 1060 Andrew Drive, Sutie 170 Sioux F West Chester PA 17380 Date: April 21, 2008 R' rd Bu n7an, E quire 1 7 ath alley R d Box 51 ring Run, PA 17262-0051 [717] 349-7657 USBC PAM - LIVE - VERSION 3.1.7L - NoticeOfFiling United States Bankruptcy Court Middle District of Pennsylvania Notice of Bankruptcy Case Filing A bankruptcy case concerning the debtor(s) listed below was filed under Chapter 13 of the United States Bankruptcy Code, entered on 04/02/2008 at 8:45 PM and filed on 04/02/2008. William C Singer 1169 Three Square Hollow Road Newburg. PA 17240 SSN: xxx-xx-2776 aka Bill Singer Esther M Singer 1169 Three Square Hollow Road Newburg, PA 17240 SSN: xxx-xx-9633 The case was filed by the debtor's attorney: The bankruptcy trustee is: Richard L. Bushman Charles J. DeHart, III (Trustee) PO Box 51 16767 Path Valley Road 8125 Adams Drive, Suite A Spring Run, PA 17262-0051 Hummelstown, PA 17036 717 349-7657 717 566-6097 The case was assigned case number 1:08-bk-01161-MDF to Judge Mary D France. Page 1 of 2 In most instances, the filing of the bankruptcy case automatically stays certain collection and other actions against the debtor and the debtor's property. Under certain circumstances, the stay may be limited to 30 days or not exist at all, although the debtor can request the court to extend or impose a stay. If you attempt to collect a debt or take other action in violation of the Bankruptcy Code, you may be penalized. Consult a lawyer to determine your rights in this case. If you would like to view the bankruptcy petition and other documents filed by the debtor, they are available at our Internet home page http://www.pamb.uscourts.gov/ or at the Clerk's Office, U.S. Bankruptcy Court, Ronald Reagan Federal Building, PO Box 908, Harrisburg, PA 17108. You may be a creditor of the debtor. If so, you will receive an additional notice from the court setting forth important deadlines. Arlene E Righter Clerk, U.S. Bankruptcy Court https://eef.pamb.uscourts.gov/cgi-bin/NoticeOfFiling.pl?l 79551 4/2/2008 ra ??? ?'. ? <r? ?,? `??+ ??? _ S ?_ (? .; - ?- ?.x, j,,.' '.? ?:. , J ?,. 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. ESTHER M SINGER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1585 CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without eil & Yale The law firm of Burton Neil & Associates is a debt collector. P.C. ei ein, Esquire for Plaintiff C-14250 f? ` 4 _ c? ?F ; 3 ? .."C s'~ ??- C '; ? ? t- ?? ? ?' ?:. .I. ? . `? C_ ? ? C.J --t ? ?C