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Home My WebLink About08-3664Burton 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 KIMBERLY S BANZHOFF : NO. D8 ' au..q CNtt -Fexm 301 N 21st Street, Camp Hill PA 170113702 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-14368 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. p?' :3 lv( o7 Ci ) ; ( Tel KIMBERLY S BANZHOFF 301 N 21st Street, Camp Hill PA 170113702 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 Kimberly S Banzhoff, who resides at 301 N 21st 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. Count I 4. Plaintiff furnished consumer credit to the defendant by means of a(n) AT&T Universal credit card with account number ending in 4262 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 $19,200.55 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 on Count I for the sum of $19,200.55, and the costs of this action. Count II 9. Plaintiff incorporates herein by reference above paragraphs one through three. 10. Plaintiff furnished consumer credit to the defendant by means of a(n) AT&T Universal credit card with account number ending in 8529 hereinafter referred to as the credit card account. 11. Plaintiff kept accurate running records of all debits and credits to the account. 12. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit B. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 13. Before plaintiff mailed Exhibit B, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 14. Defendant's actions as set forth above constituted an account stated between parties for the sum of $6,344.72 which sum reflects the Exhibit B statement balance less credits, if any, which were applied subsequent to the date of Exhibit B. Wherefore, plaintiff demands judgment against defendant on Count II for the sum of $6,344.72, and the costs of this action. WHEREFORE, plaintiff demands judgment against defendant in the total sum of $25,545.27, and the costs of this action. Burton Neil & Associates, P.C. By: ill - Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. aW AT&T Universal Rewards Card Charter Member KIMBERLY S BANZHOFF Account M251 CaDing Card + PIN July 13 - August 14, 2007 Quick Reference Minkri m Payment Dtte ...................... ............. 53 -M Was Datea................................... Septataber , 2007 "Payment must d naivd sr S:OD Pm local time on the payment due dab. Amount Past Due ............................... Amount Over Limit ............................ ................ 81 78a.57 ................... f9/O.bS Credit Line ....... ................................. ............. $18,260.00 Available Credit ..................................... 0.00 .....................4 Cash Advance Limit .............................. ............... .00 0 Available Cash Advance Limit ............. ....................... $0.00 Account Summary AT&T Universal Card Page 1 of 4 How To Reach Us Visit: www.universaleard.com Customer Service: 1-800-423-4343 or vwhe Cardmember Services PO Box 44167 Jacksonville, FL 3223-4167 Your late fee was based on your account balance as of the payment due date (08107107), which was $18,588.71. Your account balance is over the credit line. In order to continue earning ThankYou Points with your card, you must bring your account balance under the credit line now. If you have not already done so, please pay the Minimum Payment Due. era%inus Ralancq 19,588.71 Our records show home phone 717-975-1920 EA ^ ` 6t 1 M and business phone 717-975-1920. Please Total AT&T Servicas O.OQ update remittance coupon if incorrect. New Balance 119,200 55 Note: Detailed activity starts on page 3. date paid amount paid check If atl0 AT&T and the AT&T globe design are trademarks or AT&T Knowledge Ventures. tlaased to CRigroup Inc Pleese follow Payment lastructim vAfir&d In the "Importent MainKtlone. ter t WAV PaymerrW sectim of the statement. 05491130346084262999999999995217 Yew AOOOwiRReleYol 4262 Nsa. KNOW Awwet of P89-" ambled SEP 07 2007 $19204.35 3492.96 4" PC 211 A 1 AR71151765 Neill 1161111111111111118611111811111911011 KIMBERLY S BANZNOFf AT&T UNIyy??R AL CARD 632 DEVON RD P.O. BOX 1$2 CAMP HILL PA 17011-1620 COLUMBU55, 0 43218-2564 IItLGIIIINIrrt.t{Illrr{Ir.{{Ifr{{{ter{{LtIIILIIIi.rlllyd EXHIBIT KIMBERLY 5 OFF Account July 13 - August 14, 2007 AT&T Universal Card Page 2 of 4 i,ti In the return envelope, plsese: I Make your check payable to AT&T Universal Card. Z Enclose yow 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 pslyment 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. 'KIMBEFtLY S BANZHOFF Account July 13 - August 14, 2007 AT&T Universal Card Page 3 of 4 AT&T UNIVERSAL MASTERCARD ACTIVITY Purchases ............................................................................................................................................................... 533.84 Cash Advances and Checks .................................................................................................................................. 0.00 Fees ....................................................................................................................................................................... 78.00 Toted Mastercard Activity ................................................................................................................................. 5811.84 PURCHASES Total MasterCard Purchases ................................................ $533.84 Standard Punch Trap Post nescription Amount 08114 PURCNASES+F1NANCE rNABGFaPER100 493.04 Total Standard Purch $443.04 Balance Transfer - charged To Offer 8 Tam% Post Desariotton Amount 08/4 PURCNAcrS*FINANCE CNAgCr*PERIOn 40.80 Total Balance Transfer - Charged To Offer 6 $40.80 CASH ADVANCES Cash Advance Limit ....................................... $1,000.00' 'This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Days in Betenca Periodic Transaction DIAL Nominal Periodic x 81111ng x Subject to FmAm C + FedlitlAm MdteE APR Rate Period Firwnre Charge smam PURCHASES Standard Purch 32.310% .08052%(D) x 32 x $17.405.62 = $493.04 + $0.00 32.810% Offer 4 32.310% .0e652S6(D) x 32 x $1.440.41 $ $40.80 + $0.00 32.310% CASH ADVANCES Standard Adv 32.310% .008b2%(D) x 32 x $0.00 = $000 + $0.00 32.310% Total FINANCE CHARGE - $533.84 FEES Standard Purch Trans Post Description Amount _ OR114 YFYRERSHiP FEE AUG 07-JUF OR 50.00 _ 08114 IAT FFF - J1U PAYMENT PAST OUE 39.00 68/14 OVER CREDIT LIMIT FEE 39.00 Total Fees $78.00 ATAT SERVICES SUMMARY AT&T Universal Calling Card Calls ................................................................................................................... $0.00 KIMBERLY S BANZHOFF Account July 13 . August 14, 2007 AT&T Universal Card Page 4of4 REWARDS 16TMnkYOugO -AT&T Universal Card ThankYou Points Summary"" Activity This Period Base Points Earned ............................................................................................................ .......................... 0 Total ThankYou(sm) Points Earned This Period ........................................................................................................ 0 Points Transferred to Your ThankYou Network Member Account ............................................................................ 0 Total ThankYou Points Earned .................................................................................................. Year to Date Activity .................. 0 Go to thankyounetwork.com to review your ThankYou Point balance and redeem! Bonus Points may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. CitlBusiness' Platinum Select' Card Account Summary Statement KIMBERLY S BANZHOFF Business Accottn 8528 Total Cardmem December 12 - January 11, 2008 QUICK REFERENCE Minkvmm Payment $6,344.72 New Imams $6,344.72 Dus DAW 02MMO PsynwK mtwt be roealved by 110 pm I" time as the Payment Due Dow Past Due $1,45924 Amount Over Limit $1,344.72 Business Credit Line $5,000 Available Credit Cash Advance Line $2,500 Available Cash Advance $0 Page 1 of 2 How To Reach Us Visit nesscreditcards.com Customer Service: 1-800-750-7453 or mite to CitlBusiness Card, P.O. Box 44180 Jacksonville, FL 32231-4180 NEWS FROM CITI 'I Your account has been permanently closed. Remit the past due amount of $1,459.24 immediately, i ACCOUNT SUMMARY Previous Balance.... .. ... ........ $6,189.68 Payments, Credits and Adjustments........... 0.00 Purchases. 10.00 Cash Advances.. . 0.00 Finance Charges ...........................$1 5.04 Fees .... $0.00 New Balance ............................ 56,344.72 MONTHLY ACTIVITY BY CATEGORY miscellaneous ............................. $155.04 Detach and felow payment instrvctleas an reverse side. Wake" Account Mewaw 05082290056628529634472999995219 8529 sPhase [Mar Amelwt of Payment LncWW PNVWMA DW--] N&W &WSWA ifiniMAMP I . A 1 02105108 56,344.72 $6 344.72 T 443M aM 72 A I CROS01461 KIMBERLY S BANZHOFF CITIBUSINESS CARD 301 N 21ST ST PO BOX 183058 CAMP HILL PA 17011-3702 COLUMBUS, OH 43218-30581 (ui?Ils?rinll?r,I?Irillr?tlt?Iiiurltllllt?rl?rtlnll?IuII) ( 1 ) -Ilyonenrldran W1 addr"o W4Mvr Us* Nt° cwWCr youoba.tt YM r account. tr° MY Woo w Your o-ol addtara to nand Yw Inrarn,atH about praNucto and awvlcaa yw n.IgM n.tl uaaN. Pam ZEN" BY "a M 0F." NMSR °r?^a EXHIBIT 1 KIMBERLY S BANZHOFF Page 2 of 2 Business 9529 December 12 - January 11, 2008 BUSINESS ACCOUNT SUMMARY Business Activity t Purchases f Standard Purch Trans Post Description Amount 01111 PURCHASES'FINANCE CHARGE'PERIODIC RATE 518.01 Total Standat?d Punch $18.01 Balance Transfer - Char ged To Offer 4 Trans Post Description Amount 01/11 PURCHASES* FINANCE CHARGE`PERIODIC RATE $59.58 Total Balance Transfer - Charged To Offer 4 $59.58 Cash Advances Standard Adv Trans Post Description Amount 01/11 ADVANCES'FINANCE CHARGE'PERIODIC RATE $77.45 Total Standard Adr $77AS Finance Charge Summary Periodic Transaction Nominal FINANCE FaE - PURCHASES APR ,?g¢E OWN Standard Purch 31.240% $18.01 S0.00 Offer 4 31.240% $59.59 $0.00 CASH ADVANCES Standard Adv 31.240% WAS $o.00 Total FINANCE CHARGE $155.04 Verification I, Shauna Houghton am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services on its behalf. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to the authorities. Signature Shauna Houghton Kimberly S Banzhoff 5082290056628529 ?t1£st1? M ? -n h ? r o o 'd i-, cm c? SHERIFF'S RETURN - REGULAR CASE NO: 2008-03664 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS BANZHOFF KIMBERLY S RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsy;lvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BANZHOFF KIMBERLY S DEFENDANT the at 1929:00 HOURS, on the 27th day of June 2008 at 632 DEVON ROAD CAMP HILL, PA 17011-3702 -..-- .: n ? XTr7Trn T71" by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time ditecting Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 r Service 15.00 i -040? Postage .59 Surcharge X0.00 R. Thomas Kline .00 7I??+(?$ 4 9 06/30/2008 BURTON NEIL & ASSOCIATES Sworn and Subscibed to By: before me this ;day Deputy eriff of A.D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. KIMBERLY S BANZHOFF 301 N 21st Street Camp Hill PA 17011-3702 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3664 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: Count I $19,200.55 Count II $6,344.72 TOTAL $25,545.27 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 A/L.Ll.l.1'GX )C.. PPiokrothonotary d om B n Neil & Associates, P.C. By ?` B t 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-14368 • CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. KIMBERLY S BANZHOFF Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3664 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Kimberly S Banzhoff 301 N 21st Street Camp Hill PA 17011-3702 IMPORTANT NOTICE C-14368 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 22, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. )Zl/ Bri J. Suttel , Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 -6? t'?r1 r CIO ?a? C ON - G ?3 yam. Ln 0 . . .% 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 : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KIMBERLY S BANZHOFF Defendant NO. 08-3664 CIVIL TERM 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 In.Q Prothonotary By: 11 A JA a v rg 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.