The URL can be used to link to this page

Home My WebLink About08-2989Burton 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. JANIS TECHNOLOGIES INC. 2157 Market Street, Camp Hill PA 17001-1556 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. bB - dgg9 Civil Pro% : 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-14930 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. v -F - 2 4,F 9 &u-tj -7 u, JANIS TECHNOLOGIES INC. 2157 Market Street, Camp Hill PA 17001-1556 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 Janis Technologies Inc., with place of business located at 2157 Market Street, Camp Hill, 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) CitiBusiness credit card with account number 5082290053746720 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 $8,971.96 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 $8,971.96, and the costs of this action. Burton Neil & Associates, P.C. ,f' By: / Br' ' J. ASuttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. CRIBusinesse Platinum Select" Card Account Summary Statement WAYNE JANIS JANIS TECHNOLOGIES INC Business Account 5082 2900 5374 6720 Total Cardmembers: 1 November 28 - December 28, 2007 QUICK REFERENCE MMdnaan Paynw" !;".971.86 Balance V5 New Daaw 01MM 'p"ld mast be re"I"d by 5:00 pm lecsl Past ?tsePymsnl Due OMs Aunw over Lbnit M 183AS f071.OB Business Credit Line $8,0 0 CashlAdvanceeliae 0 Available Cash Advance ;4.O$0 ACCOUNT SUMMARY Previous Balance.. $8, 712.87 Payments, Credits and•Adfustments::::•" Purchases. 0.00 Cash Advances. 0.00 Finance Charges:.: " " " " " 0.00 Fees ...................... $2 4.09 New Balance ::..:.......................?•S83435.00 MONTHLY ACTIVITY BY CATEGORY Miscellaneous......... .................... $259.09 Dstseh and 161" "m"t InstrsctteM sn rsvsns side. 05082290053746720897196999995116 ewlssaAs66sst11Mbw 5082 2900 5374 8720 NssM9sdr AnnwM PM ?y11U1,t [Tdsssl 58,871.98 i8 971.98 $ !1111 1111 tf A / CROSeIfit JrANIS TECHNOLOGIES INC CAMPOHILLSPA 17001-1556 ? t "UK Ci f 1: I " /}(J CITIBUSINESS CARD .,., PO BOX 183069 COLUMBUS, OH 43218-3069 InII11?I?InIIII, INtllfII,IIIHitlellIIII we f"y all* w Page 1 of 2 How To Reach Us visit citibusinesscreditcards.com Customer Service; 1-800.750-7453 or who to ChiBusiness Card, P.O. Box 44180 Jacksonville, FL 32231-4180 NEwS FROM CITI Your late fee was based on your account balance as of the payment due date (12/24/07), which was $ 8,712.87 I WAYNE JANIS JANIS TECHNOLOGIES INC Business Account SOei2 2900 5374 6720 November 2e - December 28, 2007 Purchases Standard Purer Trans Post Description Total Starwdarp°?I, LATE FEE - NOV PAYMENT PAST DUE Amount 135.00 00 PURCHASES h Nominal Parma c APR ? ' Fa Terans?actlon CA SH ADVANES 31.240% $224 09 Standard Adv . $0.00 31.240° $0.00 $0.00 Toted FINANCE CHANGE CARDHOL R SUMMARY 5224.09 Cardholder Activit Cardholder W IS Account a umber Amount Transaction Activit $0.00 Employee Credit Une Employee Cash Advance Umlt 18,000 Account Number 55M 3700 OOti4 W75 - Subtotal of Aethdty for Account Number Page 2 of 2 Amount 224.09 OP rr?r7?i Trans post Description Total stand rd2p?h pURCHASE3'FINANCE CHARGE-PERIODIC RATE Verification 1, 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. Signatur Janis Technologies Inc. 5082290053746720 q (-Z 0- _ °° C=3 q to -?,,r mr F rn .0 ? W -3 M 0 0 t.a lei SHERIFF'S RETURN - REGULAR CASE NO: 2008-02989 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS JAMIS TECHNOLOGIES INC MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the JANIS TECHNOLOGIES INC was served upon DEFENDANT at 2105:00 HOURS, on the 3rd day of June , 2008 at 2157 MARKET STREET CAMP HILL, PA 17011-1556 by handing to WAYNE JANIS, OWNER ADULT IN CHARGE 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 11.00 Postage .59 Surcharge 10.00 L/01.10 0 0 39.59 Sworn and Subscibed to before me this day So Answers: f R. Thomas Kline 06/04/2008 BURTON NEIL & ASSOCIATES By: eputy Sh iff of A.D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JANIS TECHNOLOGIES, INC. PO Box 1556 Camp Hill PA 17001-1556 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2989 CIVIL TERM CIVIL ACTION - LAW 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 $8,971.96 $8,971.96 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn 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. NOT E GIVEN UN ER PA.R.CIV.P. 236 Pr Prothonot B on it s ociates, P.C. By• t Br' J. Suttell, Esquire Attorney for Plaintiff I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-14930 w CITIBANK (SOUTH DAKOTA), N.A. Plaintiff' V. JANIS TECHNOLOGIES INC. Defendant : IN THE COURT OF COMMON PLEAS C-14930 : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2989 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Janis Technologies Inc. P O Box 1556 Camp Hill PA 17001-1556 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: July 10, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By -- - ' 1340. Sutte , Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 W C? t1 44. V y 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 CUMBERLAND COUNTY, PENNSYLVANIA Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered v. : NO. 08-2989 CIVIL TERM JANIS TECHNOLOGIES INC. Defendant CIVIL ACTION -LAW against you on Arothonot 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.