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Home My WebLink About08-6344Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITI13ANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BETH E FOSTER : NO. d$ - (?y C?vit TrM+ 57 State Road, Mechanicsburg PA 1 7050-3 1 55 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-16137 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. O S- G 3 LI y et ;A eel BETH E FOSTER 57 State Road, Mechanicsburg PA 17050-3155 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 Beth E Foster, who resides at 57 State 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 1952 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 $3,480.05 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 $3,480.05, and the costs of this action. Burton Neil & Associates, P.C. By: B t I Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Card' Your Account Summary BETH E FOSTER Account NumbelijkliIIIIIIIIIIIIIIIIIIIII11195 2 Page 1 of 1 Billing Cycle Closing Date 01/11/08 Amount Over Credit Limit $1,910.05 Amount Past Due $497.10 Minimum Payment Due $641.30 Previous Balance $3,370.85 Payments & Credits $0.00 Purchases 81 Debits $0.00 Other Charges $29.00 Total FINANCE CHARGES $80.20 Total Account Balance $3,480.05 Your Credit Summary Total Credit Limit $1,570.00 Total Credit Available $0.00 Call us at 1-800-917-7700 Go to www.aearscard.com Write to us at PO Box e924 The Lek", NV 88901-6924 Minimum P nt Due Date 1 02108/08 Want an easy way to make a fresh start? Marry cardmembers have res*W Overdue balances by using #I* tax refund money. ICs simple and comronlent E1wn if you're not expecting a tax refund check, we have payment programe for all kkxffi of slhratiars, maybe even yours. Iles important that you call us tatty at 14168-6514488. We can help you make this new year the start of sDmetNr g good. Activity Sale Date Poet Date Description Amount 01/08/08 01/08/08 LATE PAYMENT FEE 29.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Daily Rates Rate Varies Balance Balance Periodic Rata Periodic D=Day FINANCE M=Month 7MTMW SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in Billing Period: 31 $3,480.05 $3,413.19 27.65%" .0758%(D)• $80.20 $0.00 $0.00 27.65%* .0758%(D)• $0.00 $0.00 $0.00 27.65%' .0758%(D)* $0.00 Effective ANNUAL PERCENTAGE RATE: 27.65% Minimum FINANCE CHARGE: $0.00 Sears Cae Account Number. X95 2 Total Account Minimum Payment Minimum Balance Due Dab Payment Des 05 02/08/08 $641.30 480 $3 Amount Enclosed . , 0001820 EX 07 A 08011 1 Ta8005 Ftla 001 7 N I... I I I I I I I I I I I I I I I I I I I I I I 111111 I I I I I I I I I I I I I I I I I I I I I I I I..11 II BETH E FOSTER 57 STATE RD MECHANICSBURG PA 17050-3155 Please make address changes on reverse side. III11111IIIII11111I1I11I111IIi IIIIIIII IIII1IIIIIIIIIIIIIIt Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 200 0348005 0064130 0000000 07 XHIBITk- ..__,_. Verification Tens Reynolds 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. 4- %LA.,4?? _ Signature C-16137 Beth E Foster Account number ending in 1952 1031 ? _? c? K cxs *,# w ? ? ' S J L? .. rv n ? + .,? ? ?.1 ?; .. .. D ? rn cn ? -,..r --c SHERIFF'S RETURN - REGULAR CASE NO: 2008-06344 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS FOSTER BETH E WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FOSTER BETH E DEFENDANT the at 0016:20 HOURS, on the 31st day of October , 2008 at 57 STATE ROAD MECHANICSBURG, PA 17050-3155 by handing to BETH FOSTER 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 18.00 Service 22.00 Affidavit .00 Surcharge 10.00 f -)/Of q. .00 50.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 11/06/2008 BURTON NEIL By: Deputy Sheriff of A. D. Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. BETH E FOSTER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6344 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. B on eil & As ci tes, P.C. Bye' - _ Brit . Suttell, Esquire Att rney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-16137 M ? ,? , r?; "C1 wca f. ._ °7'S . ? •?,=.: _. } ?. ?? , .; - .. _., >? ..?,.