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Home My WebLink About08-4310Burton 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. '_- CONNIE M SHEPARD NO. d F - L' 3 ) b 37 Ridge Avenue, Carlisle PA 17013 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-16282 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 3, `f 3 10 ?? T? CONNIE M SHEPARD 37 Ridge Avenue, Carlisle PA 17013 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 Connie M Shepard, who resides at 37 Ridge Avenue, Carlisle, 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 ending in 9442 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 $6,219.81 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 $6,219.81, and the costs of this action. Burton NeR& AssbciaWVP.C. Yale /W ' in, Esquire Attev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt 02/19/08 $6219.81 $6219.81 SITE:KC-CL TM:CO-5000 ACID:KCB0201 05/31/08 20:01:32: `r?a aid#tittiaiRrs?sssiar: CITI CARDS PO BOX 183068 CONNIE M SHEPARD COLUMBUS, OH RR 1 BOX 1222 43218-3068 / SHINGLEHOUSE PA 16748-9729000 Citi® Dividend Platinum Select® Card C tl0 aount Number ?? 9442 Customer Servke• • i i New Balance 1-800-756-4000 Total Credit Line Available Credit Line Cash Advance Limit m t Available Cash L $0 81 $6219 $4800 $0 $1100 . BOX 6500 SIOUX FALLS, SD Statement/ Closln Date Amount Over Credit Line Past Due Purch/Adv Minimum Due Minimum Amount Due 57117 01/25/2x08 $1419.81 $1371.39 $248.86 $6219.81 Sak Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 1/25 LATE FEE - DEC PAYMENT PAST DUE 39.00 66 0000 0000000000 1/25 PURCHASES*FINANCE CHARGE*PERIODIC RATE 00000000006.18 84 0000 I Purch/Adv Thru 03/28/2006 1/25 PURCHASES*FINANCE CHARGE*PERIODIC RATE 00000000001.68 84 0000 Your late fee was based on your account balance as of the payment due date (01/21/08), which was $6,032.95. 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. EXHIBIT4W ------- ul? Previous Payments Purchases (- (+) (+ Account Summary Balance Advances & Credits & CHARGE Balance PURCHASES $6,032.95 $39.00 #0.00 0 00 $147.86 00 $0 $6,219.81 00 $0 ADVANCES TOTAL $0.00 $6,032.95 . $0.00 1 $39.00 50.00 . $147.86 . $6,219.81 Days This Billing Perlod: 29 Rate Summary Balance Su lec Finance Charg to Periodic e Rate Nominal ANNUAL APR PERCENTAGE RATE PURCHASES Standard Purch $1,080.65 0.08353%(D) 30.490% 30.490% Purch/Adv thru 03/28/2006 $5,023.38 0.08353%(D) 30.490% 30.490% ADVANCES Standard Adv $0.00 0.08353%(D) 30.490% 30.490% 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 unswom falsification to the authorities. ILIJ I JL Signature C-16282 Connie M Shepard Account number ending in 9442 1000 Z r v Yq ? J b ? ra 0 m 2t i'J r t f C_.. C; - --1 -c f T`f ? - [a r°n ?. 7 . a 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. Plaintiff V. CONNIE M SHEPARD Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.08-4310 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burt Neil & A oc' es, P.C. By: Y D e' ein, Esquire 0 or Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-16282 6.3 two a r*Q SHERIFF'S RETURN - REGULAR CASE NO: 2008-04310 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SHEPARD CONNIE M RONALD E HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHEPARD CONNIE M the DEFENDANT , at 0011:04 HOURS, on the 28th day of July , 2008 at 37 RIDGE AVENUE CARLISLE, PA 17013 CONNIE M SHEPARD DEFENDANT 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 Service Affidavit Surcharge P/0116 18.00 5.00 .00 10.00 .00 33.00 Sworn and Subscibed to before me this day So Answers: • R. Thomas Kline 07/29/2008 BURTON NEIL & ASSOCIATES Deputy Sheriff of A. D.