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Home My WebLink About08-5102Burton 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. [?Pwi DELORES J HESS NO. 6$ 145 Willow Mill Park Road Mechanicsburg PA 17050-1760 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-15898 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. DELORES J HESS 145 Willow Mill Park Road Mechanicsburg PA 17050-1760 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 Delores J Hess, who resides at 145 Willow Mill Park Road, Mechanicsburg, 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 0952 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. Defendant : CIVIL ACTION - LAW 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 $4,055.20 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 $4,055.20, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. . Sears Gold MasterCard® DELORESJ HE Account Number. 952 Page 1 of 1 Your Account Summary Billing Cycle Closing Date 02/21108 Amount Over Credit Line $1,705.20 Amount Past Due $1,328.71 Current Minimum Due $99.00 Total Minimum Due $3,132.91 Previous Balance $6,555.20 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $0.00 FINANCE CHARGES $0.00 Account Balance $6,555.20 Your Credit Summa Total Credit Line $4,850.00 Available Credit Line $0.00 Cash Access Line $970.00 Available Cash $0.00 Payment Due Date 03/12/08 Wish you cads put yor past due W behind yea? Your tax rehmd can help mail; it happen. Many customers have resolved overdue amounts by using their tax refund money. It's simple and convenient. If you're not expecting a refund, we may have payment options available. Cali today, and together, we'1 cane up with a solution that is right for you. Did 1 1 So IYs Important foryou to call 1-8611-51&9049 today. 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 PE?TAGE RATE M=Month CHARGE SEARS REGULAR $342.89 $0.00 29.99%* .0822%(D)* $0.00 EXTERNAL REGULAR $6,212.31 $0.00 29.99%* .0822%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 29.99%* .0822%(D)* $0.00 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 29.99% Minimum FINANCE CHARGE: $0.00 Account Number. 952 Payment Total Account Balance _ Due Date Minimum Due Amount Enclosed -1 ( $6,555.20 03/12108 F$3,132.91 $ Sears Gold d° 0000000 EX 15 08052 1 7X8503 FVO 001 7 W IIIIIIIIIIIIIIII IIIIIIIIIIIIIII IIIIIIIIIIIII II IIIIIIIIIIIIIIII DELORES J HESS 145 WILLOW MILL PARK RD MECHANICSBURG PA 17050-1760 Please make address corrections above. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIII Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 EXHIBIT Call us at 1-800-669-8488 Go to www.searscard.com Write to us at PO Box 6922 The Lakes, NV 88901-6922 fr e Verification I, Tiena Reynolds 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 unswom falsification to the authorities. Signature C-15898 Delores J Hess Account number ending in 0952 1032 1? X. ?C p h F C? c ?s Z7. N C SV ui t7 C.3 W -n -i -r-f r'!l 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05102 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS HESS DELORES J 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 HESS DELORES J the DEFENDANT , at 1514:00 HOURS, on the 28th day of August 2008 at 145 WILLOW MILL PARK ROAD MECHANICSBURG, PA 17050 by handing to DELORES HESS 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 9.00 Affidavit .00 Surcharge 10.00 cijp4/ot ;?}` .00 `?'" 3 7 . 0 0 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 08/29/2008 BURTON NEIL & ASSOCIATES By: e ut r ff A.D. 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. Plaintiff V. DELORES J HESS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5102 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Associates, P.C. By: - :::?? - Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-15898 -n U) f> r N