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Home My WebLink About08-4828Burton 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. CAROLYN KREUTZER : NO. 414 Arlington Road, Camp Hill PA 17011-2106 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-16203 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CAROLYN KREUTZER 414 Arlington Road, Camp Hill PA 17011-2106 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 Carolyn Kreutzer, who resides at 414 Arlington 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 9448 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 $3,706.18 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 $3,706.18, and the costs of this action. & A&ociates, P.C. By: Derek`C^-BlasUr, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 04/07/08 CAROLYN KREUTZER 414 ARLINGTON RD CAMP HILL 17011-2106000 $3706.18 PA $3706.18 SITE:KC-CL TM:CO-5000 ACID:KCB0197 05/31/08 20:01:32: ==f6fR=:=i4ai3:`?Sfi,IE=:;:= CITI CARDS PO BOX 183058 COLUMBUS, OH 43218-3058 Citi' Driver's Edge& Card Ctie Charter Rebates Account Number 9448 Customer Service. 1-800-568-5000 Total Credit Line Available Credit Line Cash Advance Limit $3500 $0 Available Cash Limit New aalance BOX 6500 $3500 $0 $3706.18 Statement/ SIOUX FALLS, SD Closing Date 57117 03/12/2008 Amount Over Credit Line Past Due $ Purch/Adv MI imum Due Minimum Amount Due 206.18 $315.00 76.00 $3706.18 Sale Date Post Date Reference Number Activity Since Last Statement Amount 3/12 3/12 3/12 3/12 Standard Purch LATE FEE - FEB PAYMENT PAST DUE 66 00 OVER CREDIT LIMIT FEE 0 PURCHASES*FINANCE CHARGE *PERIODIC RATE 84 0000 0 Purch/Adv Thru 06/13/2007 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 0 29.00 70000000000 29.00 70000000000 6.85 70000000000 53.48 70000000000 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. Account Summary Previous (+) Purchases ( ) Payments (+) FINANCE (=) New Balance & Advances rv rrarlifit CHARGF 0-1 ---- PURCHASES $3,587.85 $58.00 0.00 $60.33 $3,706.18 ADVANCES $0.00 $0.00 0.00 $0.00 $0.00 TOTAL $3,587.85 $58.00 10.00 $60.33 $3,706.18 Da ys This Billing Period: 29 Rate Summary Balance Subject to Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch Purch/Adv $410.47 0.05751%(D) 20.990% 20.990% thru 06/13/2007 ADVANCES $3,206.42 0.05751%(D) 20.990% 20.990% Standard Adv $0.00 0.05751%(D) 20.990% 20.990% EXHIBIT A *1 , " 4 -4? sw? $ Verification I Kris Dietz 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. C-16203 Carolyn Kreutzer Account number ending in 9448 1000 zo o - n 6 Lo SHERIFF'S RETURN - REGULAR CASE NO: 2008-04828 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS KREUTZER CAROLYN KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KREUTZER CAROLYN the DEFENDANT at 0016:12 HOURS, on the 21st day of August , 2008 at 414 ARLINGTON ROAD CAMP HILL, PA 17011-2106 by handing to CAROLYN KREUTZER 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 4 01 Service 1 1 t j Affidavit Surcharge Sworn and Subscibed to before me this of 18.00 15.00 .00 10.00 .00 43.00 day So Answers: 01 oo, R. homas Kline 08/22/2008 BURTON NETT. & ASSOCIATES By: A. D. 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. CAROLYN KREUTZER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-4828 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton it ociates, P.C. By: erek lasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-16203 C b m n -- csl cn