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Home My WebLink About08-2742Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. EDITH RILAND : NO. O$ - ol'14a 0,;vit, [ tfOxVW, 115 Humer Street, Enola PA 17025-0000 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-13107 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. EDITH RILAND 115 Humer Street, Enola PA 17025-0000 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O.F. -? 7V2 C'u T.,- : 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 Edith Riland, who resides at 115 Humer Street, Enola, 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 5424180023206714 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 $13,122.58 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 $13,122.58, and the costs of this action. Sarker, Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. Attorney for Plaintiff 11/30/06 $19822.58 $19822.58 SITE:KC-CL CITI CARDS PO BOX 183054 EDITH RILAND COLUMBUS, OH 115 HUMER ST 43218-3054 ENOLA PA 17025 Citi® Card Account Number 5424 1800 2320 6714 Customer Service. . 1-800-866-9900 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit BOX 6500 $20440 $0 $6800 $0 Statement/ Amount Over Purch/Adv SIOUX FALLS, SO Closi Date Credit Line Past out nimum Due 57117 11/06/206 $0.00 $2885.57 1771.14 Sale Date Post Data TM:CO-5000 ACID:KC63104 11/15/07 21:38:43: f C tie New Balance $19822.58 Minimum Amount Due $19822.58 Standard Purch LATE FEE - OCT PAYMENT PAST DUE 39.00 0000000000 2.35 0000000000 66 0000 PURCHASES*FINANCE 84 0000 CHARGE*PERIODIC RATE 11/06 11/06 11/06 Purch/Adv Thru 11/04/2004 PURCHASES*FINANCE CHARGE*PERIODIC RATE 531.79 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (10/31/06), which was $19,249.44. 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 (+) Balance & Purchases (-) Payments Advances &Credits (+) FINANCE CHARGE (=) New" Balance PURCHASES $19,249.44 $39.00 $0.00 $534.14 $19,822.58 ADVANCES $0.00 $0.00 $0.00 $0.00 $0.00 TOTAL $19,249.44 $39.00 $0.00 $534.14 $19,822.58 Days This Billing Period: 31 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $85.72 0.08833%(D) 32.240% 32.240% Purch/Adv thru 11/04/2004 $19,420.96 0.08833%(D) 32.240% 32.240% ADVANCES Standard Adv $0.00 0.08833%(D) 32.240% 32.240% EXHIBIT_ A Verification I, Kris Dietz 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 Edith Riland 5424180023206714 M-4 vl n F W Ln o -o - SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02742 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS RILAND EDITH 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 RILAND EDITH but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT RILAND EDITH 115 HUMER STREET ENOLA, PA 17025 DEFENDANT IS DECEASED. Sheriff's Costs: Docketing 18.00 Service 30.00 Not Found 5.00 Surcharge 10.00 .00 63.00 So answers: 1-. R. Thomas Nj ine Sheriff of Cumberland County BURTON NEIL & ASSOCIATES 05/21/2008 Sworn and Subscribed to before me this day of A. D. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorne for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 V. Plaintiff M COPY FROM RECORD n Testi ,y weersot, $ hefa unto set my ham 10 of said Coun at Getl , Pa, I" . 4 C-02 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EDITH RILAND : NO. O$ - ajg2 115 Humer Street, Enola PA 17025-0000 l?iVi ( T°?-rlha 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-13107 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 V. EDITH RILAND 115 Humer Street, Enola PA 17025-0000 Defendant Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 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 Edith Riland, who resides at 115 Humer Street, Enola, 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 5424180023206714 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 $13,122.58 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 $13,122.58, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. THE SIGNATURE ABOVE CERTIFIES THAT THIS IS A TRUE AND CORRECT COPY OF THE ORIGINAL FILE IN THIS CAUSE. 11/30/06 $19822,58 v EDITH RILAND 115 HUMER ST ENOLA PA 17025 $19822.58 SITE:KC-CL TM:CO-5000 ACID:KCB3104 f6sRYssS€`: 11/15/07 21:38:43: CITI CARDS PO BOX 183054 COLUMBUS, OH 43218-3054 V v3 Cities Card Account Number 5424 1800 2320 6714 Customer Service: 1-800-866-9900 Total Credit Line Available Credit II BOX 6500 $20440 ne $0 Cash Advance Limit $6800 Available Cash Limit SIOUX FALLS, SD Statement/ Closing Date Amount Over $0 57117 11/06/2006 Credit Line $0.00 Past Due $2885 57 Purch/Adv Minimum Due Sale Date Post Date Relerenca Number Acti it SI . $ 771 _ 14 11/06 11/06 11/06 v Y nce Last Statement Standard Purch LATE FEE - OCT PAYMENT PAST DUE 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Purch/Adv Thru 11/04/2004 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Your late fee was based on your account balance as of the payment due date (10/31/06), which was $19,249.44. C tla New Balance $19822.58 Minimum Amount Due $19822.58 Amount 39.00 0000000000 0000000000 2.35 531.79 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 Summa Previous Balance (+) pure aces (-) paymen s (+) FINANCE PURCHASES $19 249 44 & Advances & Credits CHARGE (_) New Balance ADVANCES TOTAL , . $0.00 $19 249 44 $39.00 $0.00 $0'00 $0.00 $534.14 $0 00 $19,822.58 , . $39.00 $0.00 . $534.14 $0.00 $19,822.58 Rate Summary Ba ance Su )ec o Perio is Da s This Billin Period: 31 PURCHASES Finance Charge Rate Nomina ANNUAL APR Standard Purch PER CENTAGE RATE Purch/Adv $85.72 0.08833%(D) 32.240% thru 11/04/2004 ADVANCES CES $19,420.96 0.08833%(D) 32.240% Standard Adv $0 00 32.240% 32.240% . 0.08833%(D) 32.240% 32.240% EXHIBIT Verification I Kris Dietz 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 ' Edith Riland 5424180023206714 > T/ ?f L fi Z d b Z tidy 8001 ??l?It'yS 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. EDITH RELAND Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2742 CIVIL. TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil &,Associates, P.C. By. Neil, Esquire Atto ey for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 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