HomeMy WebLinkAbout08-4827Burton 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
IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEBRA BOLTON
464 West Main Street
Walnut Bottom PA 172669762
NO. 61@ -,qg.Z/
Defendant : CIVIL ACTION -LAW
Complaint - Notice
61 u t- LQ7ieev1
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-16275
C-16217
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.
DEBRA BOLTON
464 West Main Street
Walnut Bottom PA 172669762
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
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 Debra Bolton, who resides at 464 West Main Street, Walnut Bottom,
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 incorporates herein paragraphs 1 through 3.
5. Plaintiff furnished consumer credit to the defendant by means of a credit card with
account number ending in 3498 hereinafter referred to as the credit card account.
6. Plaintiff kept accurate running records of all debits and credits to the account.
7. 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.
0
8. Before plaintiff mailed Exhibit A, defendant had for many months made payments on
account of the billing statement or retained the statement without payment.
9. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $3,900.71 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 for Count I against defendant for the sum of
$3,900.71, and the costs of this action.
Count II
10. Plaintiff incorporates herein paragraphs 1 through 3.
11. Plaintiff furnished consumer credit to the defendant by means of a(n) AT&T
Universal credit card with account number ending in 4632 hereinafter referred to as the credit
card account.
12. Plaintiff kept accurate running records of all debits and credits to the account.
13. 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.
14. Before plaintiff mailed Exhibit B, defendant had for many months made payments on
account of the billing statement or retained the statement without payment.
15. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $13,750.69 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 for Count II against defendant for the sum of
$13,750.69, and the costs of this action.
Wherefore, plaintiff demands judgment in the entirety against defendant for the sum of
$17,651.40, and the costs of this action.
Burton Neil & Associates, P.C.
By:
Brit . Suttell, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
05/06/08 $3900.71 $3900.71 SITE:KC-CL TM:CO-5000 ACID:KC00201
06/03/08 22:02:34:
CITI CARDS
DEBRA BOLTON PO BOX 183057
COLUMBUS, OH
464 W MAIN ST 43218-3057
WALNUT BOTTOM PA
17266-9762000
I
Citi' Platinum Select' Card
MJ? 3498
t
1-800-950-5114 TOM Credit Line AVallaale Crtdk Line Cash Advam m Limit AVaiNalt Case Unit
BOx 6500 $3250 $0 $2500 $0
SIOUX FALLS, SO C Dati A r.024 Lin Post Due Mldauw ?ii
57117 04/10 208 $650.71 $886.36 5169_6b
4/10
4/10
4/10
Standard Purch
LATE FEE - MAR PAYMENT PAST DUE
66 0000
PURCHASES•FINANCE CHARGE•PERIODIC RATE
84 0000
Purch/Adv Thru 07/12/2006
PURCHASES«FINANCE CHARGE•PERIODIC RATE
84 0000
Your 1 to fee was base on your account balance as of the payment due date
(04/07108), which was 3,770.05.
atle
Nary eabnee
$390g0??.71
A.euati
$3900.71
Ampurd
39.00
0000000000
000000000704.95
16.71
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.
We will lower APRs from the default APR on all balances if you meet
the terms of all Card Agreements you have with us for 12 billing periods
in a row. We may lower these APRs sooner based on your record with us.
Aeeotnt Summary Previous + rc aaea - aym : + ew
Balance & Advances A Credits CHARGE Balance
PURCHASES
ADVANCES
TOTAL $3,770.050
s
1 $ 0.00 0.00
1 $91.66 $3,9 .71
?p
$3,7
0.05 $ 9.00
0.00 $ 1.66 ;3.900.71
Da s This 811 Period. 30
ROW Summary Balance ec to
Finance Charge er c
R
t orn ne ANNUAL
PURCHASES a
e APR PE RCENTAGE RATE
Standard Purch
Purch/Adv $3,118.72 0.08011%(D) 29.240% 29.240%
thru 07/12/2006
ADVANCES $695.45 0.08011%(D) 29.240% 29.240%
Standard Adv $0.00 0.08011%(D) 29.240% 29?_ M IBIT
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Detach and follow payment imtrudlem on reverse
Make check payable te:AT&T Universal Card
Total New Balance: Account Number
$13,750.69 632
Minimum Amount Due:
Amount Enclosed: ///yyy
•
/
Payment t Due
Payment Date:
/
05/12/2008 I
Payment must be maived by 5:00 PM
aal time on the payment due date.
000000 PM 32 A 0
DEBRA L BOLTON
464 W MAIN ST AT&T UNIVERSAL CARD
WALNUT BOTTOM PA 17266-9762 P.O. BOX 182564
COLUMBUS, OH43218-2564
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Verification
I Shauna Houpht4n
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.
'r i 91 1 1'h' A? A --f-
Signature
Shsuru?l?ught ,;
C-16275
Debra Bolton
Account number ending in 3498
1000
noJryQoOH Sllu6le,
vOH snustlE
25.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04827 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK (SOUTH DAKOTA) N A
VS
BOLTON DEBRA
MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BOLTON DEBRA the
DEFENDANT , at 0017:23 HOURS, on the 14th day of August 2008
at 464 WEST MAIN STREET
WALNUT BOTTOM, PA 17266-9762 by handing to
DEBRA BOLTON DEFENDANT
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 flog
Affidavit 9I 0?
Surcharge
Sworn and Subscibed to
before me this
of
18.00
20.00
.00
10.00
day
So Answers:
R. Thomas Kline
08/15/2008
/// , ?
By: '7
BURTON NEIL & ASSOCIATES
A. D.
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
DEBRA BOLTON
464 West Main Street
Walnut Bottom PA 17266-9762
Defendant
To the Prothonotary:
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 084827 CIVIL TERM
CIVIL ACTION - LAW
Praecipe for Default Judgment
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: $3,900.71
Principal Count II: $13,750.69
TOTAL $17,651.40
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
AND DAMAGES ASSESSED AS ABOVE.
NOTICE GIVEN UNDER PA.R.CIV.P. 236
/s/ 1 l /, d'# 4 P '/?N b
Pro Prothonotary O c"
B on Neil As ciates, P.C.
B _
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-16275
CiTIBANK (SOUTH DAKOTA), N.A.
Plaintiff
V.
DEBRA BOLTON
Defendant
IN THE COURT OF COMMON PLEAS
C-16275
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4827 CIVIL TERM
: CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Debra Bolton
464 West Main Street
Walnut Bottom PA 17266-9762
IlvI'PORTANT 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 8, 2008
In making this communication, we advise our office is a
debt collector.
Burton Neil & Associates, P.C.
By?
Brit J. Su ll, Esquire
Attorney for Plaintiff
Identification No. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
"C7
FT;
to _7
{
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. IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEBRA BOLTON
NO. 08-4827 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 I kk
Prothonotary
By: S C.
Deputy DrCI,s
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.
I it O t 11LIt:Uul ...
f143NOV 18 11: 5E.
CUMBERLAND COUNT?
PENNSYLVANIA
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. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
v.
: NO. 08-4827 CIVIL TERM
DEBRA L BOLTON
Defendant : CIVIL ACTION-LAW
Praecipe to Satisfy Judgment
To the Prothonotary:
Mark the judgment Satisfied .
Burton Neil &Associates, P.C.
By: /1�ii '
rit J. Su 111, squire
Attorney for laintiff
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
C-16217/318
SO/Dd
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