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Home My WebLink About08-3593 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JESSICA L TALALAI : NO. 0$ - 35g3 Civi erM 513 Lamp Post Lane, Camp Hill PA 17011-1430 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-15711 C] 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. OF - 3543 CZ,-d -t'.-- JESSICA L TALALAI 513 Lamp Post Lane, Camp Hill PA 17011-1430 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 Jessica L Talalai, who resides at 513 Lamp Post Lane, 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) Choice credit card with account number ending in 5989 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 $5,890.03 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 $5,890.03, and the costs of this action. Burton Neil & Associates, P.C. By: Brit. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 03/14/08 $5890.03 $5890.03 SITE:KC-CL CHOICE MASTERCARD PO BOX 183064 JESSICA L TALALAI COLUMBUS, OH 513 LAMP POST LANE 43218-3064 CAMP HILL PA 17011-1430000 Choice, Account Number 5989 Customer Service- 1-800-568-5000 Total Credit Line Available Credit Line 4840 $ $0 BOX 6248 ta Amount f L SIOUX FALLS, SO Closing Da ine 57117 02/20/2008 $1050.03 Sale Date Post Date Reference TM:CO-5000 ACID:KCB0197 04/23/08 23:54:08: CHOSE` Cash Advance Limit Available Cash Limit New Balance $2900 $0 $5890.03 Purch/Adv Minimum Past Due Minimum Due Amount Due $1123.97 $239.40 $5890.03 e Last Statement Amount Standard Purch 2120 LATE FEE - JAN PAYMENT PAST DUE 39.00 66 0000 0 70000000000 2/20 PURCHASES*FINANCE CHARGE*PERIODIC RATE 142.40 84 0000 0 70000000000 Your late fee was based on your account balance as of the payment due date (02/14/08), which was $5,708.63. 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. EXHIBIT Account Summary Previous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance PURCHASES $5,708.63 $39.00 0.00 $142.40 $5,890.03 ADVANCES $0.00 $0.00 0.00 1 $0.00 $0.00 TOTAL $5,708.63 $39.00 0.00 $142.40 $5,890.03 Days This Billing Period: 30 Rate Summary Balance Subject to Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $5,777.16 0.08216%(D) 29.990% 29.990% ADVANCES Standard Adv $0.00 0.08216%(D) 29.990% 29.990% Verification I, Shauna Houghton 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 µstatements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Signature Shauna Houghton Jessica L Talalai 6989 1011'puorl, +?nut +::: rl()ItlpuoH snuss+P- n ?p 00 00 N C-17 00 ' F= f 7 rt * v' iJ C1 ---4 CO "` W 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03593 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS TALALAI JESSICA L STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TALALAI JESSICA L the DEFENDANT , at 0845:00 HOURS, on the 21st day of June 2008 at 513 LAMPPOST LANE CAMP HILL, PA 17011-1430 JESSICA TALALAI 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 18.00 Service 14.00 Affidavit .00 Surcharge 10.00 00 J oL? ?D S ?i 42. 00 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 06/23/2008 BURTON NEIL & ASSOCIATES By: Deput Sheriff A. D. 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. Plaintiff V. JESSICA L TALALAI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3593 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Bu 1 & o , P.C. By: Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-15711 C3 F'