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Home My WebLink About08-7331Burton 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JAYME S BINDER :NO. (? _ ? 0,iVit erm 3 Lance Court, Newville PA 17241-9207 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-18416 416 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 V. Plaintiff JAYME S BINDER 3 Lance Court, Newville PA 17241-9207 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. : 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 Jayme S Binder, who resides at 3 Lance Court, Newville, 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 0744 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 $3,041.57 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 $3,041.57, and the costs of this action. Burton Neil & Associates, P.C. By: Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 01/29/08 $3941.57 13941.57 SITE:KC-CL CITI CARDS JAYME S BINDER PO BOX 183053 3 LANCE CT COLUMBUS, OH NEWVILLE 43218-3053 17241-9207000 PA Citio Dividend Platinum Select" Card Aocou t Number 0744 ustonner Service: 1-800468-5000 Total Credit Line BOX 6500 $3230 SIOUX FALLS, SD statement/ 57117 01104720080 1/04 1/04 1/04 Available Credit Line Amount Over O Credit Line $711.57 Activity Since Last Cash Advance Limit Available Cash Limit $1500 10 Past Due Purch/Adv Inimum Due $580.66 176.89 Standard Purch LATE FEE - DEC PAYMENT PAST DUE 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 39.00 0000000000 00000000004 89 PURCHASES*FINANCE CHARGqqE*PERIODICORATE I 84 0000 00000000004'00 Your late fee was based on your account balance as of the payment due date (12/31/07), which was $3,803.68. Help is available! Please call the toll-free number shown above to learn about our stoc5al payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am pm, Central Time. Please give us the opportunity to assist you. EXHIBIT A- Account Scimmary reviou3 (+ urc 0303 (- Payments t PURCHASES Balance $3 803 68 & Adva C & Cr- its ew CHARGE (z) N Balance ADVANCES TOTAL , . $0.00 ;390.00 .00 3 0.00 $98.89 $3,941.57 $3,803.68 9.00 $ 0.00 $0.00 $0.00 $98.89 $3,941.57 Rata Summary Balance fee to Periodic Days This Billing Period: 30 N PURCHASES Finance Charg e Rate ominal ANNUAL APR Standard Purch Offer 6 ADVANCES Standard Adv $3 306.03 0.08559%(D) 1545.24 0.08559%(D) $0.00 0.08559%(D) C tl? New Balance $3941.57 Minimum Amount Due $3941.57 Amount 31.240% 31.240% 31.240% 31.240% 31.240% 31.240% TM:CO-5000 ACID:KCB0201 10/02/08 23:48:03: v SEND PAYMENTS T0: Verification I, am an employee of Citicorp Credit Services, Inc., (USA) which i 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- 4K6,tL FL4r'?"' Signature C-18416 Jayme S Binder Account number ending in 0744 1000 ? r n FT; o ' ?"1 { o O 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07331 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS BINDER JAYME S NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BINDER JAYME S the DEFENDANT , at 0020:15 HOURS, on the 19th day of December-, 2008 at 3 LANCE COURT NEWVILLE, PA 17241-9207 T lIT T T)TTTT1Tn97 by handing to WIFE OF 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: So Answers: Docketing 18.00 Service 9.90 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 ??UD?( ? 37.90 12/23/2008 BURTON NEIL & ASSOCIATES i Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JAYME S BINDER 3 Lance Court Nevwille PA 17241-9207 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7331 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: TOTAL $3,041.57 $3,041.57 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 based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NaC E GI N ER R.CIV.P. 236 o Prothon B on Neil & Associates, P.C. B• B t J. Suttell, Esquire Attorney for Plaintiff I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-18416 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JAY NE S BINDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7331 CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Jayme S Binder 3 Lance Court Newville PA 17241-9207 1MPORTANT NOTICE C-18416 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 objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office 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 DATE OF NOTICE: January 14, 2009 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Brill. Suttel uire Attorney fo Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 O th p n-y YYN? CIO 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. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JAYME S BINDER : NO. 08-7331 CIVIL TERM 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 Prothono I'll ?r N A-. ? By: If you have any questions concerning the above, please contact: Brit J. Suttell, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CHAPTER 13 JAYME SCOTT BINDER fdba JB Photography CASE NO. 1:13-bk-01545 JODY ANN BINDER, Debtors JAYIVIE SCOTT BINDER fdba JB Photography ar r xz JODY ANN BINDER, Z -� Movants . V. --� CITIBANK SOUTH DAKOTA NA, . .c4 Respondent ORDER UPON consideration of the foregoing Motion to Avoid Judgment of Respondent under Section 522(#)of the Bankruptcy Code ,it is hereby ORDERED AND DECREED that the relief prayed for in the Motion be,and hereby is granted,to wit,the judgment of CITIBANK SOUTI=1 DAKOTA NA in the approximate amount of$3,041.57 entered in Cumberland County at docket number#2005 CV 7331 be and hereby is avoided; it is further ORDERED AND DECREED that a certified copy of this Order may be filed with the Prothonotary of Cumberland County and the Prothonotary is directed to terminate the judgment in the judgment indices. - Dated: April 23, 2013 050489 21509450539010