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Home My WebLink About08-7340 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE A HALTER : NO. p$ - 7'3? Q V ( (tf M• 471 Waterleaf Court, Mechanicsburg PA 17050-2489 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-18437 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 V. MICHELLE A HALTER 471 Waterleaf Court Mechanicsburg PA 17050-2489 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . NO. Defendant : CIVIL ACTION - LAW Complaint 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 Michelle A Halter, who resides at 471 Waterleaf Court, 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 credit card with account number ending in 2773 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 $8,863.53 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 $8,863.53, 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. 05/05/08 $8863.53 ;8863.53 SITE:KC-CL TM:CO-5000 ACID:KCB0201 :::?1::: = <Kfik3y 10/01/08 23:59:21: MICHELLE A HALTER 471 WATERLEAF CT MECHANICSBURG 17050-2489000 PA Citl' Platinum Select' Card Account Number CITI CARDS PO BOX 183056 COLUMBUS, OH 43218-3056 2773 Customer Sarvkr. 1-800-950-5114 Total Credit Line ;8000 Available Credit Line Cash Advance Limit BOX 6500 ;0 ;2400 SIOUX FALLS, SD 57117 Statement/ Closln Date 0 x Amount over Credit Line Past Due 4/09/2 08 $863.53 ;856.11 4/09 4/09 4/09 4/09 C tip Available Cash Limit New Balance $0 $8863.53 Pereh/Adv inimum Due Minimum Amount Due 227.32 $8863.53 Standard Purch CREDIT PROTECTOR FEE MNTHLY 8009505114 74 0000 LATE FEE - MAR PAYMENT PAST DUE 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Standard Adv ADVANCES*FINANCE CHARGE*PERIODIC RATE 84 0000 00000000000.00 39.00 0000000000 86.26 0000000000 14.06 0000000000 Your late fee was based on your account balance as of the payment due date (04/07/08), which was ;8,724.21. 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 t0 5 pm, Central Time. Please give us the opportunity to assist you. EXHIBIT 5',., rd Adv if,927.30 ;845.30 0.03627%(D) 0.05545%(D) 13.240% 20.240% 13.240% 20.240% Account Summary Previous (+ urc ases Payments (+) rtHANCE Balance & Advances Credits CHARGE ew PURCHASES Balance ADVANCES ;7 885.69 ;39.00 0.00 TOTAL 038.52 ;0.00 0.00 86.26 ;8 010.95 $8,724.21 ;39.00 10.00 14.06 }852.58 ;100.32 ;8,863.53 Days This 81111n Period: 30 Rate Summary Balance ec o _, _. erio is Verification I, Shauna Houghton unsworn falsification to the authorities. 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 Signature C-18437 Michelle A Halter Account number ending in 2773 1000 % 10 R' :' 00 W 6 s 406 t) CTJ Ul - ..- 71 „J fV cn ' { C ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-07340 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS HALTER MICHELLE A SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HALTER MICHELLE A the DEFENDANT , at 0918:00 HOURS, on the 3rd day of January , 2009 at 1320 CONCORD ROAD MECHANICSBURG, PA 17050-2489 by handing to MICHELLE HALTER 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 19.80 Affidavit .00 Surcharge 10.00 .00 47.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/05/2009 BURTON NEIL &ASS By. A. D. c 3 Co - 01 40 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. MICHELLE A HALTER Defendant r,7 to ?r- - -. CD w ? rv . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7340 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Assoc' , P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-18437 / 318