Loading...
HomeMy WebLinkAbout08-6307I Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. SANDRA A SHEPHERD : NO. O$ - ?D 3p'r l..N Z t T?r'w? 206 York Street, Enola PA 17025-2436 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-17346 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. SANDRA A SHEPHERD 206 York Street, Enola PA 17025-2436 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. Or- 4367 CIVIL ACTION - LAW Complaint G 1 ?'; I +C fA, 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 Sandra A Shepherd, who resides at 206 York Street, 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 credit card with account number ending in 9148 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 $1,509.30 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 $1,509.30, and the costs of this action. Burton Neil & AAAciates. P.C. D. We' ein, Esquire nev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt OT/14/08 $1509.30 $1509.30 SITE:KC-CL TM:C0-5000 07/24/08 CITI CARDS PO BOX 183062 SANDRA A SHEPHERD COLUMBUS, OH 206 YORK ST 43218-3062 ENOLA PA 17025-2436000 ACID:KC80197 19:39:35: ® " tl? Card Platinum Select Citi *00 Irm 148 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $1000 $0 $1000 $0 $1509.30 BOX 6500 SIOUX FALLS, SD Statement/ Amount Over Cloel Date Credit Line Post Due 2 Purch/Adv Minimum Mlgimum Due Amount Due 57117 08 $509.30 $491.12 06/17/_ j8T.47 $1509.30 saM Date Post Date Refereace Number Activity Since Last Statement Amount Standard Purch 6/17 LATE FEE - MAY PAYMENT PAST DUE 39.00 66 0000 0000000000 6/17 PURCHASES*FINANCE CHARGE*PERIODIC RATE 5.80 84 0000 0000000000 Purch/Adv Thru 02/16/2007 6/17 PURCHASES*FINANCE CHARGE*PERIODIC RATE 27.67 84 0000 0000000000 Your Minimum Amount Due on any New Balance over $20 will no longer include the total amount of your transaction fees. These fees include balance transfer, cash advance, and foreign purchase fees. Remember, you can pay these fees (and any other amounts owed on your account) at any time. Your late fee was based on your account balance as of the payment due date (06/13/08), which was $1,436.83. 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. EXHIBIT f? Account Summary Previous Balance (+) Purchases -) Payments & Advances & Credits (+) FINANCE CHARGE (= ew Balance PURCHASES $1,436.83 $39.00 #0.00 $33.47 $1,509.30 ADVANCES $0.00 $0.00 1 0.00 $0.00 $0.00 TOTAL $1,436.83 $39.00 0.00 1 $33.47 $1,509.30 Days This Billing Period: 29 Rate Summary Balance Subject Finance Charg _ Periodic e Rate Nominal ANNUAL APR PERCENTAGE RATE PURCHASES Standard Purch $251.61 0.07942%(D) 28.990% 28.990% Purch/Adv thru 02/16/2007 $1,201.31 0.07942%(D) 28.990% 28.990% ADVANCES Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Verification I, ShwmMaGhlon am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITI13ANK (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. Signs e C-17346 Sandra A Shepherd Account number ending in 9148 1000 noRlCuoH snuseZ C co 3C: r? Q :27 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS SHEPHERD SANDRA A JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHEPHERD SANDRA A the DEFENDANT , at 0019:19 HOURS, on the 29th day of October , 2008 at 206 YORK STREET ENOLA, PA 17025-2436 by handing to HENRY SHEPHERD HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 . fJ1/ 7/f1 P` 00 43.00 Sworn and Subscibed to before me this day of , So Answers: oe e2,000" R. homas Kline 10/30/2008 BURTON NEIL By. A. D. ?_._. . ?r*. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. SANDRA A SHEPHERD 206 York Street Enola PA 17025-2436 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6307-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: $1,509.30 Less Credits: $149.60 TOTAL $1,359.70 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 base n information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTER-ED Burto 1 leil soci s, P.C. AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN U ER PA.R.CIV.P. 236 D. Weinstein, Esquire ttorney for Plaintiff Pr rothono I.D. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-17346 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. SANDRA A SHEPHERD Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6307-CIVIL-TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Sandra A Shepherd 206 York Street Enola PA 17025-2436 IMPORTANT NOTICE C-17346 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 objet 'ons to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment Imay be entered against you without a hearing and you may lose your property or other important rights. You shod take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the llowing office to find out where you can get legal help. This office can provide you with information about hirinjg 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: November 24, 2008 In making this communication, we advise our office is a debt collector. & Alsvegfes, P.C. Yale D ej std1, Esquire Atto for Plaintiff Id cation No. 89678 1 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 ? ? O G C7 ?? ? ? ? ? .? ? ?_ ? ?, CA ? ? ? ?`?"? ? ?;n , ? ? O c'? -r: fir ,,, ? ? „- ? , ?j '- P"t r -•}??n d. ` ? • " 1 ? ?? ? S ? f ? RAJ Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. 0 8-63 07 -CIV U.-TERM SANDRA A SHEPHERD 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 /a1$ Prot By: Deputy If you have any questions concerning the above, please contact: Yale I). Weinstein, Esquire Attorney for Party Filing 1060 A drew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.