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Home My WebLink About08-5101Burton 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. KURT JHENDLEY dba FOLTZ APPLIANCE SERVICE 27 S West Avenue, Camp Hill PA 17011-6544 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. b8 , .5101 CDefendant : 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-16589 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 NO. KURT J HENDLEY dba FOLTZ APPLIANCE SERVICE 27 S West Avenue, Camp Hill PA 17011-6544 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 Kurt J Hendley dba Foltz Appliance Service, who resides at 27 S West Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including lending through the issuance of credit cards. 4. Plaintiff furnished commercial credit to the defendant by means of a(n) CitiBusiness credit card with account number ending in 2452 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. N 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $22,048.05 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 $22,048.05, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, E uire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. CitiBusiness' Platinum Select' Card Account Summary Statement KURT J HENDLEY FOLTZ APPLIANC Business Account 2452 Total Cardmembers: 0 December 3 - January 2, 2008 QUICK REFERENCE Minimum Payment $22,018.06 New lWance $22,048.05 Due Date* OIPAM •Pryteant MW be recdvdd by 6.0 pm lout t1aw on the Payment Due Dab P o t Am un Over Lhwt $2,040.06 Business Credit Line $20,000 Available Credit 0 Cash Advance Line $10,0800 Available Cash Advance ACCOUNT SUMMARY Previous Balance......................... $21.451.35 Payments, Credits andustmen...... 60.00 Purchases .. .................. 10.00 Cash Advances .. ............................ 550.00 Finance charges ............................ $5 7.70 Fees .... $39.00 New Balance ........................... $39.00 MONTHLY ACTIVITY BY CATEGORY Miscellaneous ............................. $596.70 Page 1 of 2 How To Reach Us Visit nesscreditcards.com Customer Service: r r 1-800-750-7453 or write to ? vt CitiBusiness Card, P.O. Box 44180 Jacksonville, FL 32231-4180 HEtttS FROM CITI Your account has been permanently closed. Remit the past due amount of $2,648.88 immediately. Your late fee was based on your account balance as of the payment due date (12/27/07), which was $ 21,451.35 Detach and Wow Payment instracthtns on reverse if". Nueb"B Aedetw, nwdbp 04122510030222452999999999995912 . 52 at Paytaelt Mddaod "M 1 01128108 [$22,043.05 $22,048.0S 232t aV 32 A 1 MUMS ...11.11...1.1..11,1.!.11„1.11...I.rl.11 KURT J HENDLEY FOLTZ APPLIANCE SERVICE 27 S WEST AVE SHIREMANSTOWN PA 17011-6544 raw rnW4 1,1,11.,!l.r,l,l.,rill..Ir.1lI.l1....1/11..1t1111f11 CITIBUSINESS CARD PO BOX 183051 COLUMBUS, OH 43218-3051 l,lrlllrlti,111111,r,lr11111..11rl,r,rIDl,DlrrtltDNrrril?A1-rrBIT • Ir rev presla an ewlall ado ew wo maywo It le caned V" a6" re.w accoNd. We may alas W yew 9w 41 adores to send you IdY,manan aaeut Preduda a11dW V n V.Uffdplt 8W ueeAA. • „.7TUM. i OWN • KURT J HENDLEY FOLTZ APPLIANC Business Account December 3 3 - - January 2, 2 Page 2 of ;! BUSINESS ACCOUNT SUMMARY Business Activity Purchaps Standard Purch Trans Post 01/02 Description PURCHASES'FINANCE CHARGE-PERIODIC RATE Amount Total Standard Purch . Business Fees W 0 Purchases Standard Pinch Trans Post 01/02 Description LATE FEE - DEC PAYMENT PAST DUE Amount 539 0 Total Standard Pureh 0 : ?Y 00 1rhu e ChaM Summa PURCHASES Periodic Nominal APR CHA Transaction FeC?j Standard Purch CASH ADVANCES 31.240% 1557.70 50.00 Standard) Adv 31.240% $0.00 $0.00 Total FINANCE CHAROE Sss7 70 , 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. d Signature C-16589 Kurt J Hendley Account number ending in 2452 1023 ;ri C prz!? N ca C.7 N CS1 c,a c.? r Tl ,s 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05101 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS HENDLEY KURT J DBA FOLTZ APPLI ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HENDLEY KURT J DBA FOLTZ APPLIANCE SERVICE the DEFENDANT , at 1600:00 HOURS, on the 3rd day of September, 2008 at 27 S WEST AVENUE SHIREMANSTOWN, PA 17011 by handing to BETSY HENDLEY, WIFE 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 13.00 Postage .59 Surcharge 10.00 110416 Yq„, 00 41*59 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline ' 09/04/2008 BURTON NEIL & ASSOCIATES By-?? Deputy Sheri f A.D.