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Home My WebLink About08-5227It , 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. ADRIANNE ROWLEY 219 Wyoming Avenue, Enola PA 17025-2433 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4? : 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-16415 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. ADRIANNE ROWLEY 219 Wyoming Avenue, Enola PA 17025-2433 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA `??h. NO. ?-7 G Nr1 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 Adrianne Rowley, who resides at 219 Wyoming Avenue, Enola, 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 2243 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 $3,706.43 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 $3,706.43, 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 Calm ADRIANNE ROWLEY Account Number: 2243 Page 1 of 1 Your Account Summary Billing Cycle Closing Date 01/15/08 Amount Over Credit Line $906.43 Amount Past Due $680.88 Total Minimum Due $736.88 Previous Balance $3,706.43 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $0.00 Total FINANCE CHARGES $0.00 Account Balance $3,706.43 Your Credit Summary Total Credit Line $2,800.00 Total Credit Available $0.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Call us at 1-800-917-7700 Go to www.s"recard.com Write to us at PO Box 6924 The Lakes, N1/ 88901-6924 Payment Due Date 02/04/08 Ward an easy way to make a trash start? Many cardmembers have resolved overdue balances by using their tax refund money. ICs simple and convenient Even if you're not expecting a tax refund check we have payment proms for all kinds of situations, maybe even yours. 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. Average Corresponding Periodic Rate Periodic Daily ANNUAL D-Day FINANCE Rates *Rate Varies Balance Balance PEM-NTAGE RATE M=-Month CHARGE SEARS REGULAR $3,706.43 $0.00 29.40%* .0806%(D)* $0.00 EXTERNAL REGULAR $0.00 $0.00 29.40%* .0806%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 29.40%* .0806%(D)* $0.00 Days in Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 29.40% Minimum FINANCE CHARGE: $0.00 Sears Card* Account Number 43 Account Balance Due Date Mindmurn Due $3,706.43 02/04/08 $736.88 0000000 Ex 08 08015 1 Ta8006 FXa 001 7 IF ADRIANNE ROWLEY 219 WYOMING AVE ENOLA PA 17025-2433 Amount Enebsed 1 J Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 2243 0370643 0073688 0000000 0917 ExHIB Y 7 I -...A ?, Verification I Mena 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 unworn falsification to the authorities. I aEyco?- G'4-? Signature C-16415 Adrianne Rowley Account number ending in 2243 1039 0 d w v CIL w n I,- ?-, Q C- C 'z -Y) 1"Z 1 r? -n N it -7 CD `a"'1, 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. ADRIANNE ROWLEY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5227 CIVIL : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-16415 ra G ? r -- ?? 0 z - :te t3'+ C , SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05227 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS ROWLEY ADRIANNE R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ROWLEY ADRIANNE but was unable to locate Her in his bailiwick. He therefore returns the P9^T,NT1T T TTTT f ATnrr7 T t" V , NOT FOUND , as to the within named DEFENDANT , ROWLEY ADRIANNE 219 WYOMING AVENUE ENOLA, PA 17025-2433 PER POST OFFICE, DEFENDANT MOVED TO NORTH CAROLINA. Sheriff's Costs: Docketing Service Not Found Surcharge IV, /o 308 ?i-• So answers: 18.00 15.00 °-` 5.00 R. Thom Kline 10.00 Sheriff of Cumberland County .00 48.00 BURTON NEIL & ASSOCIATES 09/15/2008 Sworn and Subscribed to before me this day of A. D.