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Home My WebLink About08-2953Burton 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 KIMBERLEY COPEMAN : NO. b$ - 0Jg53 Civtl TG(n. 10 Front Street Apt K, Shiremanstown PA 17011 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-11370 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. Of - 195,3 a!4 TZa, KIMBERLEY COPEMAN 10 Front Street Apt K Shiremanstown PA 17011-5384 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 Kimberley Copeman, who resides at 10 Front Street Apt K, 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(n) AT&T Universal credit card with account number 5491130142816214 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 $2,986.33 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 $2,986.33, and the costs of this action. Burton Neil &„-)ssociates, P.C. B : J eil, Esquire for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt your AWUnim? +Card Statement January 20 - February 20, 2006 KIMBERLEY COPEMAN Account 6491 1301 4281 8214 Calling Card t PIN No Annual Fee/Platinum Card Quick Reference Minimum Payment Due ........................................... $62.00 Due Date ........................ -..................... ... Marfit 17, 2006 •paym•nt must be received by 5:00 pm local time on the payment duo d•ls. Credit Line ............................................................. $91000.00 Available Credit ............................................................ 00 Cash Advance Limit ................................................ $5 0.00 Available Cash Advance Limit .................................... $0.00 Account Summary 3.126.02 ?? r[`ar ACII{ 't 20:QQ T I AT T i ° ??? New Balanee Note: Detailed activity starts on page 3. lT Universal Card Page 1 of 3 r? I How To Reach Us visit: wvfrv.unlversalcard.com CCardmember ServiCOS PO Box444167n?e Jacksonville, FL 32231-4167 The minimum amount due below may not reflect your payment arrangement. Please continue to pay your agreed-upon minimum payment. Your account is currently on a debt management program (DMP). The minimum due on your statement is not the DMP payment Failure to make the DMP payment for two months terminates the DMP and reinstates your previous terms. date paid amount paid check # please follow payment Instructions outlkied In tin "Important instructions for Making payments" section of the statement. Yew Account Nwnfer 054911301428]16214298633062000012 5491 1301 4281 6214 Please Cater Arseeot of f40mwd EM106011 gylaeet out f!•t• YolrT" • =$62.00 MAR 17 $2986.33 7775 HC 44 A I AR7051587 'til{I'l//'{I1e111/?'IIt'11'lel'llll lt"IIIIt{11{tl lit{I{Il1I{ KIMBERLEY COPEMAN 104 S LOCUST ST APT 2A CAMP HILL PA 17011-6734 'Ilelfll?'111'tI111'I'I/'U1?'i'?1IIII{IIIIUI{111' AT&T UNIVERSAL CARD PO BOX 183064 COLUMBUS, OH 43218-3064 {L11{li{I111IJ.{tll11llli{1{I11l11 ltllllltlL{.{1{{11.111 EXHIBIT ? KIIABERLEY COPEMAN Account 5491 1301 4291 6214 January 20 - February 20, 2006 a AT Universal Card Page 2 of 3 In the return envelope, pl"se: I Make your check payable to AT&T Universal Card. 2 Enclose your check or money order. Include your account number and name on the front of your check or money order. Please, no cash or foreign currency. 3 Enclose your paynertt coupon. Do not staple or tape it to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. KIMBERLE$ COPEMAN ?AM Universal Card Account 5491 1301 42B1 8214 January 20 - February 20, 2008 Page 3 of 3 PAYMENTS AND ADJUSTMENTS Amnunt True Post DaseripUan 01/28 ELECTRONTr PAYMENT-THANK YOU -C1159715 165 QDCR Total Payments and Adjustments $165.000R AT&T UNIVERSAL MASTERCARD ACTIVITY ........................-............................................... 25.31 Purchases ................................................................................... ........................................................-......-................. 0.00 Cash Advances and Checks ................................................ Total MasterCard Activity ..................................................... ........... ......... .................. .----------- .----- ------ .............. $25.31 PURCHASES Total MasterCard Purchases ................................................. $25.31 Standard Purch + a 02120 Total Standard Purch $25.31 CASH ADVANCES Cash Advance Limit .......................................... $500.00' 'This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Days In aeranee Periodic Transaction Nominal Periodic x Billing x Subject to FMANCE • reelfINAW -._____ ---- user esraxec PURCHASES Standard Purch 910056 .02712%(D) x 31 x $3,010.63 CASH ADVANCES Standard Adv 9.90056 .02712%ID) x 31 x $0.00 AT&T SERVICES SUMMARY AT&T Universal Calling Card Calls ....................................................... = $26.31 + $0.00 9.90056 = $0.00 + $0.00 9.90056 Total FINANCE CHARGE $25.31 ....................................................... $0.00 Verification M%Una Houghton I am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services on its behalf. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. V 9)?4? Signature Sh$Ws Min Kimberley Copeman 5491130142816214 nohlQuoH iinusQ J C'f +v 00 - 0 p ? J '0 00 0 _0 m e co C.n CUI) SHERIFF'S RETURN - REGULAR CASE NO: 2008-02953 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS COPEMAN KIMBERLEY SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon mpF:MAm KTMRF'RTRRY the DEFENDANT , at 1228:00 HOURS, on the 31st day of May 2008 at 10 FRONT STREET APT K SHIREMANSTOWN, PA 17011 KIMBERLEY COPEMAN 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 6/64/0, 4 v,,**' Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 06/02/2008 BURTON N 18.00 26.00 .00 10.00 .00 54.00 day By: A. D. A 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. KIMBERLEY COPEMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2953 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Di :Burton N ' & Associates, P.C. Burton a 1, Esquire Attorney f r Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-11370 ??; ry G7 :77-x' _)i f p? 0.ryj