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Home My WebLink About08-4664Burton 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL A YONTA NO. i °m 352 Cortland Circle, Shippensburg PA 17257-8528 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-14717 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. MICHAEL A YONTA 352 Cortland Circle, Shippensburg PA 17257-8528 Defendant : CIVIL ACTION - LAW Complaint 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 Michael A Yonta, who resides at 352 Cortland Circle, Shippensburg, 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) Sears credit card with account number ending in 4415 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 $3,377.97 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 $3,377.97, and the costs of this action. P.C. By: Derek C. Bla*er, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Gold MasterCard® Call us at 1-800.669-8488 Go to www.seemeard.com Write to us at PO Box 6922 The Lakes, NV 88901-6922 MICHAEL A YON Account Number. ?t415 Payment Due Date Page 1 of 1 02/18/06 Your Account Summary Billing Cycle Closing Date 01/21/08 Amount Over Credit Line $577.97 Amount Past Due $657.69 Current Minimum Due $165.18 Total Minimum Due $1,400.84 Ward an easy trey to make a fresh start? Previous Balance Payments & Credits $3,211.79 $0.00 Many cardmembers have resolved overdue balances by using their tax refund Purchases & Debits $0.00 money. Its simple and convenient Even if you're not expecting a tax refund Other Charges $74.00 check we have payment programs for all kinds of situations, maybe awn yours, FINANCE CHARGES $92.18 Account Balance $3,377.97 It's important that you call us today at 14866-651-0486. We can help you make this new year the start of something good. Your Credit Summa Total Credit Line $2,800.00 Available Credit Line $0.00 Cash Access Line $280.00 Available Cash $0.00 Activity Sale Date Post Date Description Amount 01121/08 01/21/08 OVERLIMIT FEE 35.00 01/16/08 01/16/08 LATE PAYMENT FEE 39.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Rates *Rate Varies Balance Balance P R TAGE RATE M=Month CHARGE SEARS REGULAR $295.91 $225.60 31.240/o* .0856%(D)* $6.38 EXTERNAL REGULAR $3,082.06 $3,037.65 31.24%* .0856%(D)* $85.80 CASH ACCESS REGULAR $0.00 $0.00 31.24%* .0856%(D)* $0.00 Days in Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 31.24% Minimum FINANCE CHARGE: $0.00 Sears Gold Card® Account Number: 4415 Payment Tote Account Balance Due Date Minimum -1 ? $3,377.97 02/18/08 $1,400 0070358 EX 13 A 08021 1 TXS503 FVG 001 7 N IIIII'?111IIIIIII?I It IIIIIIIIIIIIIIIIIIIII ItII llilllll l'IIIII' I Due Amount Enclosed .84 ? ?$ MICHAEL A YONTA 352 CORTLAND CIR SHIPPENSBURG PA 17257-8528 Please make address corrections above. 1111 I'IIIfl/ll lI III VIII VIII II III II I11 I111'II I11 ?11IIII?II111 Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 EXHIBIT 74 r Verification I, Pam Clue 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 Pant Me C-14717 Michael A Yonta Account number ending in 4415 1032 gnomsq writ,) mi99 OO ' T p? 0 00 ? _- 0 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. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4464 CIVIL TERM MICHAEL A YONTA Defendant CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burtoates, P.C. By: k lasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-14717 C?