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Home My WebLink About08-2991Burton 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 MONICA J ALLEN : NO. 0$ aqa l? W ?- 206 Hemlock Road, New Cumberland PA 17070 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-14294 Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 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 NO. dJP- 9 9/ ?Cu? f o,?"' MONICA J ALLEN 206 Hemlock Road, New Cumberland PA 17070 Defendant CIVIL ACTION - LAW 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Monica J Allen, who resides at 206 Hemlock Road, New Cumberland, 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 5424180691022898 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 $22,499.04 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 $22,499.04, and the costs of this action. Associates, P.C. By: ale-D7-Weinstein, Esquire ttornev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt , i 10/30/07 $22599.02 $5146.31 SITE:KC-CL TM:CO-5000 ACID:KCB3104 W-ROW 5-1 -NNNOW11 qWO 02/06/08 23:33:56: CITI CARDS PO BOX 183053 MONICA J ALLEN COLUMBUS, OH 206 HEMLOCK RD 43218-3053 NEW CUMBERLAND PA 17070-2819000 L Citr Platinum Select` Card a b0, AOCount Nanber 5424 1806 9102 2898 cuseomer servkm 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance BOX 6500 $21060 s0 $3800 s0 $22599.02 SIOUX FALLS, SD Cio ItnsgDati 4 A Credit Over Past Due nlmum Du 1 Amount Dw 57117 10/0 2007 (1539.02 + :2887.47 + 719.82 = $5146.31 Standard Purch 10104 LATE FEE - SEP PAYMENT PAST DUE 39.00 66 0000 0000000000 10/04 OVER CREDIT LIMIT FEE 35.00 62 0000 0000000000 10/04 PURCHASES+FINANCE CHARGE•PERIODIC RATE 455.82 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (10/01/07), which was $22,069.20. Your account is seriously past duand your credit privileges have been suspended. Please call the toll-7r ee number shown above to learn about our special payment options. Call Monday - Friday, T am - 9 pm, or Saturday, 8 am - 5 pm, Central Time. Our records show hoax phone 717-774-9469 and business phone 717-790-0400. Please update coupon if incorrect. Account Summary Previous + Purchases - Payments (+1 FIKAKCE : New' Balance & Advances b Credits CHARGE Balanee PURCHASES ADVANCES $22,069.20 $0.00 $14.00 0.00 10.00 0.00 $455.82 0.00 $22,5 9.02 $0 00 TOTAL $22,069.20 S 4.00 0.00 1 $4 5.82 . $22,599.02 Rata Summary Purch $22,288.47 0.07052%(D) 25.740% 25.740% Adv $0.00 0.07052%(D) 25.740% 25,740% XHIST Al 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 unworn falsification to the authorities. Monica J Allen 5424180691022898 b .:- _ lTl --- 0 Q ?' ?3 N ' R1 ; C:i N C 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. V. Plaintiff MONICA J ALLEN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2991 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. , P.C. Ya We' stein, Esquire A ey or Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-14294 , ?v b ? ? ? t _ , f7't r.. ? . t ? +.,..