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HomeMy WebLinkAbout08-3662Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. JILL I KUHNS 467 Oak Flat Road, Newville PA 17241-9462 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0% - 361oQ : CIVIL ACTION -LAW Civi l l errs 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-15873 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JELL I KUHNS 467 Oak Flat Road, Newville PA 17241-9462 Defendant : No. 68' -3? 61 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 Jill I Kuhns, who resides at 467 Oak Flat Road, Newville, 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 ending in 7978 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 $9,269.85 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 $9,269.85, and the costs of this action. P.C. By: Attorney B*ker, Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. ,0, at&t AT&T Universal Rewards Card Charter Member JILL I KUHNS Accountf1010?7978 Calling Card + PIN October 19 - November 19, 2007 Quick Reference Minimum Payment Due ...................................... $9,289.85 Due Date" ........................................... December 13, 2007 "Payment mutt be received by 5:00 pm local time on the payment due data. Amount Past Due ............................................... $1731.83 Amount Over Limit. .............................................. (999.85 Credit Line.. ...................... .................................... $8,270.00 Available Credit ............................................................ $0.00 Cash Advance Limit .................... ................... $6,000.00 Available Cash Advance Limit .................................... $0.00 Account Summary Previous Balance 8,983.30 Payments and A 'usiments 0.00 MasterCa iki 286-55 Total AT&T Services 0-00 New Balance $9,269.85 Note: Detailed activity starts on page 3. AT&T Universal Cara Page 1 of 3 How To Reach Us Visit: www.universaleard.oom Customer Service: 1-800-423-4343 or write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Your late fee was based on your account balance as of the payment due date (11/13107), which was $8,983.30. Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. I ( J, 1 date paid amount paid check # Citl® AT&T and the AT&T globe design are trademarks of AT&T Knowledge ventures, licensed to Cltigroup hit. Please follow payment Instructions outlined In the "Important Instructions for Making Payments" section of the statement. D Yaw Account Member law 7978 Please Enter Amount of Payment Enlaced PaymeM Due Data Yaw Totel eslance MFNman Arn101a1t Due DEC 13 2007 59269.85 59269.85 2755 MC 32 A I AR7052043 irrrllt,..trrl.1,I.e1.r.I11.i.r.i..l.ll....lei.tleel,e.l.eelii ini..I.,ttrr.l.i..e111.ete.,l.iri.lrrile.rl,el,lriti JILL I KUHNS AT&T UNIVERSAL CARD 467 OAK FLAT ROAD P.O. BOX 18256 NEwvILLE PA 17241-9462 COLUMBUS, OH 43218-2564 ILLLtlililrirlllerirtlliltltLJIIL.IlireillllltlleliLltl EXHIBIT A moomm JILL 1 KUHNS Accoun 7978 October 19 - November 19, 2007 AT&T Universw t dl U Page 2 of 3 in the return envelope, please: 1 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 payment 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. JILL I KUHNS Account 978 October 19 - November 19, 2007 ;??`?&7 IJI?IVeI say L.u? u Page 3 of 3 AT&T UNIVERSAL MASTERCARD ACTIVITY Purchases ............................................................................................................................................................... 247.55 Cash Advances and Checks .................................................................................................................................... 0.00 Fees .......................................................................................................................................................................... 39.00 Total MasterCard Activity ................................................................................................................................. $286.55 PURCHASES Total MasterCard Purchases ................................................ $247.55 Standard Purch Trans Post Description Amount 11/19 PURCHACES*FINANCE CHARGE*PERIOD 247.55 Total Standard Purch $247.55 CASH ADVANCES Cash Advance Limit ....................................... $6,000.00` 'This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Days In Balance Periodic Transaction ANNUAL Nominal Periodic x Wiling x Subject to = F7NAel + Fee/QdA= P[ACEMTACt* APR Rate Period Finance Charge CHAM9 PBAM ffm PURCHASES Standard Purch 32.020% .08773%(D) x 31 x $9,102.52 = $247.55 + $0.00 32.020% CASH ADVANCES Standard Adv 32.020% .08773%(D) x 31 x $0.00 = $0.00 + $0.00 32.020% Total FINANCE CHARGE _ $247.55 FEES Standard Purch Trans Pest Description Amount 11/19 LATE FEE - OCT PAYMENT PAST DUE 39.00 Total Fees $39.00 AT&T SERVICES SUMMARY AT&T Universal Calling Card Calls ................................................................................................................... $0.00 Verification Shauna 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. d ?l(1 r i,n ?? Signature Shauna Houghton Jill I Kuhns 7978 . ) ?7 CASE NO: 2008-03662 P KUHNS JILL I COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS DENNIS FRY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon uTTLINC .TTT.T. T the DEFENDANT , at 1100:00 HOURS, on the 21st day of June , 2008 at 467 OAK FLAT ROAD NEWVILLE, PA 17241-9462 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 RETURN - REGULAR Sheriff's Costs: Docketing Service Affidavit Surcharge 41 G1b? So Answers: 1 8.00 _f 11 .00 .00 10.00 R. Thomas Kline .00 39.00 06/23/2008 BURTON NEIL & ASSOCIATES Sworn and Subscibed to before me this of By day puty Sh r f A. D. w CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JILL I KUHNS 467 Oak Flat Road Newville PA 17241-9462 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3662 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 $9,269.85 $9,269.85 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unworn 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. NOTICE GIVEN UNDER PA.R.CIV.P. 236 5 O KA Wo Prothonotary Burt eil klac-sker, iates, P.C. By: re Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-15873 C-15873 ' CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JILL I KUUNS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3662 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to Fite F'raecipe for Default Judgment TO: Jill I Kuhns 467 Oak Flat Road Newville PA 17241-9462 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 15, 2008 In making this communication, we advise our office is a debt collector. P.C. By: Derek . Blaske , Esq ire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 .. F.. -W 00 ? Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 V. JILL I KUHNS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3662 CIVIL TERM Defendant : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on R/ &01 /S/"- P. Prothonotary By: Deputy If you have any questions concerning the above, please contact: Derek C. Blasker, 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. ESE! T?a PM E-'E NNSYLVANIA Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 V. JILL I KUHNS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3662 CIVIL TERM Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . By: The law firm of Burton Neil & Associates is a debt collector. C-15873 / 318 Associates, P.C. U. Masker, Esquire ?v for Plaintiff Oln'? s &). dbI'd `?