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Home My WebLink About08-4582J` J Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 VICTORIA K ROSWOG : NO. 4?" ZJ5?a2 CI V1 µr 7 Gale Road, Camp Hill PA 17011-2620 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-15252 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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. VICTORIA K ROSWOG 7 Gale Road, Camp Hill PA 17011-2620 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 6 ?- - G.w, 1 ?GrM : 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 Victoria K Roswog, who resides at 7 Gale Road, 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 credit card with account number ending in 3954 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 $5,323.42 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 $5,323.42, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esq ire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ' 02/18/08 $5323.42 $5323.42 SITE:KC-CL TM:CO-5000 ACID:KCB0197 aiE3 aii'##=` 1133 = 03/28/08 01:18:49: CITI CARDS PO BOX 183065 VICTORIA K ROSWOG COLUMBUS, OH 7 GALE RD 43218-3065 CAMP HILL PA 17011-2620000 y "' Ct ? i Platinum Select Card Citi Account Number 3954 Customer Servke• 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $4990 $0 $3700 $0 $5323.42 BOX 6500 SIOUX FALLS, Statement/ Amount Over SD Closing Data Credit Line Past Due Purch/Adv Minimum Due Minimum Amount Due 57117 01/22/2008 $333.42 $972.46 $232.65 $5323.42 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 1/22 LATE FEE - DEC PAYMENT PAST DUE 66 0000 1122 OVER CREDIT LIMIT FEE 62 0000 1/22 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Purch/Adv Thru 08/23/2007 1/22 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Your late fee was based on your account balance as of the payment due date (01/16/08), which was $5,103.77. 39.00 0000000000 39.00 0000000000 5.57 0000000000 136.08 0000000000 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. Previous (+) Purchases (-) Payments (+) FINANCE (=) New Account Summary Balance & Advances & Credits CHARGE Balance PURCHASES $5,103.77 $78.00 0.00 $141.65 $5,323.42 ADVANCES $0.00 $0.00 0.00 $0.00 $0.00 TOTAL $5,103.77 $78.00 3353350.00 $141.65 $5,323.42 Days This Billing Period: 32 Rate Summary Balance Subject t o Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $203.44 0.08559%(D) 31.240% 31.240% Purch/Adv thru 08/23/2007 $4,968.63 0.08559%(D) 31.240% 31.240% ADVANCES Standard Adv $0.00 0.08559%(D) 31.240% 31.240% , .,,oI 1 F? 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. TS?,, Signature Shauna Houghton Victoria K Roswog 954 Y J tJ?J ry f "' 1 tir III)d Cry SHERIFF'S RETURN - REGULAR CASE NO: 2008-04582 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS ROSWOG VICTORIA K RONALD HOOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT Sc NOTICE was served upon DnCT.7n(' 17T('rVOVTA u the DEFENDANT , at 1905:00 HOURS, on the 22nd day of August , 2008 at 7 GALE ROAD CAMP HILL, PA 17011-2620 VICTORIA K ROSWOG 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 15.00 Affidavit .00 Surcharge 10.00 1 n .00 g1U3f H? `'?"' r/ 43.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/25/2008 BURTON NEIL & ASSOCIATES By : Deputy Sheriff of A. D. CTTIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. VICTORIA K ROSWOG 7 Gale Road Camp Hill PA 17011-2620 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-4582 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 $5,323.42 $5,323.42 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn 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 Burton Neil & Associates, P.C. AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UND R PA.R.CIV.P. 236 By: Neil Sarker, Esquire I/M J- Attorney for Plaintiff Pr rothono I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-15252 ,? C-15252 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. VICTORIA K ROSWOG Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4582 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Victoria K Roswog 7 Gale Road Camp Hill PA 17011-2620 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: September 15, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: - C.- / Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 r s ilia, ? rah t?'3 ?' . CrJ t 7 Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-4582 CIVIL TERM VICTORIA K ROSWOG Defendant CIVIL ACTION -LAW against you on _6/ 03108 rothon By: Deputy If you have any questions concerning the above, please contact: Neil Sarker, 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. a