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Home My WebLink About08-7229Burton 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. AMY L RICKENBACH 336 E Garfield Street Apt 2, Shippensburg PA 17257-2004 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. M - gaa9 Civit lerpK 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-18472 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. AMY L RICKENBACH NO. D F- 7 2-29' 336 E Garfield Street Apt 2, Shippensburg PA 17257-2004 Defendant : CIVIL ACTION - LAW Complaint I . 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 Amy L Rickenbach, who resides at 336 E Garfield Street Apt 2, Shippensburg, 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 9624 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. ft 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $3,921.09 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 $3,921.09, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, E quire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. . , 09/22/08 $3921.09 $3921.09 SITE:KC-CL TM:CO-5000 ACID:KCB0197 ::??5{ erkiE:: : ataiaEti€<`= issia##isii 10/03/08 23:08:07: CITI CARDS PO BOX 183068 AMY L RICKENBACH COLUMBUS, OH 336 E GARFIELD ST APT 2 43218-3068 SHIPPENSBURG PA 17257-2004000 Citi' Dividend Platinum Select Card C t e i Account Number ?PNWW 9624 Customer Service. 1-800-925-8871 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit $2900 New Balance BOX 6500 $0 $300 $0 $3921.09 SIOUX FALLS Statement/ Amount Over Pureh/DAdv , SO Closln Date Credit Line Past Duo Minimum u• Minimum Amount Due 57117 0 8/27/2 08 $1021.09 $1036.34 $128.24 $3921.09 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 8/27 PURCHASES*FINANCE CHARGE*PERIODIC RATE 89 24 . 84 0000 0000000000 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 ive us the o t it , . g ppor un y to assist you. Account Summary Previous (+) Purchases (-) Payments + FINANCE {) ew Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $3,831.85 $0 00 0.00 0 0 1 0.00 $89.24 $3,921.09 TOTAL . $3,831.85 . 0 0.00 0.00 110.00 50.00 $0.00 $89.24 $3,921.09 Days This Billing Period: 29 Rate Summary Balance Subject to Periodic Nomina ANNUAL - Finance Charge Rate APR PERCENTAGE RATF DVA ZCE Purch $3,874.76 0.07942%(D) 28.990% 28.990% Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Exhibit SEND PAYMENTS T0: Verification I, am an employee of Citicorp Credit Services, Inc., (USA) which Jby 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. 4- J&Jaz Signature C-18472 Amy L Rickenbach Account number ending in 9624 1000 Cl ^? 00 o 9' W J o o iZ 25 r •. 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07229 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS RICKENBACH AMY L 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 RICKENBACH AMY L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT 336 E GARFIELD STREET APT 2 RICKENBACH AMY L SHIPPPENSBURG, PA 17257-2004 OCCUPANT AT THIS ADDRESS NEVER HEARD OF DEFENDANT PER POST OFFICE, DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS. Sheriff's Costs: So answers- Docketing 18.00 ""- Service 18.00 Not Found 5.00 R. Th mas Kline Surcharge 10.00 Sheriff of Cumberland County .00 51.00 BURTON NEIL & ASSOCIATES 12/30/2008 Sworn and Subscribed to before me this day of A. D. ?.? r--:a - s'3 ;: ---t -- ._. , .a.,. ?rt fa.°1 s? __ C t '? ": - 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7229-CIVIL TERM AMY L RICKENBACH Defendant : 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-18472 ?- ? `? ,?-?? ?, - ?_? `?= ??? R? „-.? ?'"° ? ? 3 :? ?? ?,-. -..