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Home My WebLink About09-0457Burton 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HEATHER A ENCK : NO. dQ NO ( (erm 148 Prowell Drive, Camp Hill PA 17011-1449 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 per 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-18036 4 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. Plaintiff v. HEATHER A ENCK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-457 CNIL TERM CNIL ACTION -LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton By: Yale P.C. Neinstein, Esquire for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-18036 2~~9 ul'~._ ~ J ~i`i ~' ~~ ,... ~, ~~ ~ , .> t. . -. w.,,_,,_._ ~ ,... ..,..,,:, i 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 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 9 - 1159 C-x? 7. 7c HEATHER A ENCK 148 Prowell Drive, Camp Hill PA 17011-1449 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 Heather A Enck, who resides at 148 Prowell Drive, Camp Hill, 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 0243 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 $1,838.60 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 $1,838.60, and the costs of this action. P.C. I By. ale D. Weinstein, Esquire /Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a deb collector. 07/08/08 $1838.60 $1838.60 SITE:KC-CL CITI CARDS PO BOX 183060 HEATHER A ENCK COLUMBUS, OH 148 PROWELL DR 43218-3060 CAMP HILL PA 17011-1449000 Citi" Dividend Platinum Select* Card Account Number oft JIM 0243 Customer Servke: 1-800-568-5000 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit $28220 $0 $17400 $0 BOX 6500 Statement/ Amount Over Parch/Adv SIOUX FALLS, SD Closln Data 2 redlt Line Past Due Mlgimum Due 57117 06/13/ 08 0.00 $348.35 197.96 TM:C0-5000 ACID:KCB0201 08/29/08 00:08:15: r. 1 ?U /I C tie New Balance $1838.60 Minimum Amount Due $1838.60 Standard Purch 6/13 LATE FEE - MAY PAYMENT PAST DUE 39.00 66 0000 0000000000 6/13 PURCHASES*FINANCE CHARGE*PERIODIC RATE 40.96 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 (06/09/08), which was $1,758.64. 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. Our records show home phone 717-557-9031 and business phone 305-653-3904. Please update coupon if incorrect. Account Summary Previous Balance Purchases & Advances Payments & Credits FINANCE CHARGE (c) New Balance PURCHASES $1,758.64 $39.00 0.00 $40.96 $1,838.60 ADVANCES 0.00 1 $0.00 0.00 1 $0.00 $0.00 TOTAL $1,7 8.64 $39.00 0.00 $40.96 $1,838.60 Day s This Billing Period: 29 Rate Summary Balance Subject to Periodic omina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $1,778.33 0.07942%(D) 28.990% 28.990% ADVANCES Standard Adv $0.00 0.07942%(D) 28.990% 28.990% vmmw oft Verification I, am an employee of Citicorp Credit Services, Inc., (USA) which i y contract the service provider for plaintiff CITMANK (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. - ?Iff Signature C-18036 Heather A Enck Account number ending in 0243 1000 (_ e:.:.J /^ .f3 V? v 1.. .e..w ? t7? _ ? b D ? - ^n ??. p w _ :?: a ?_. ?: '"C1 _ "_- { .?" , « Answer to Complaint - Heather Enck Name, address, and phone number for Respondent(s): Heather Enck 148 Prowell Drive Camp Hill PA 17011 Telephone: 717-557-9031 E-mail Address: ziggmar@yahoo.com Name, address, and phone number for Claimant(s): Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Telephone: 610-696-2120 RESPONSE FORM File Number: 09-457 Civil Respondent(s) states: I, Heather Enck, acknowledge receipt of a "Complaint Notice" from Burton Neil &Associates, P.C. This letter is in explanation the debt Burton Neil &Associates, P.C. are trying to collect. I am enrolled in a credit counseling program through "Credit Solutions". They do have power of attorney in my case and can be reached at 1-800-353-7630. 1 have been using "Credit Solutions" services since January 2008. They did mail a letter of hardship to Citibank when I first began the program with them. They do contact Citibank for me in efforts to settle the account. Currently, I am settling another account with Citibank via the assistance of Credit Solutions. I do plan to settle this account but need to negotiate payments in the future. Credit Solutions has been contacted about this matter and has assured me they are contacting Burton Neil & Associates today on my behalf. I would like to peacefully resolve this matter without going through the court system. However, I would like the opportunity to defend myself if this proposed action goes forward. Res ent's Affidavit of Authentici : I. assert, under penalty of perjury, that the facts supporting the (Print Respondent's Name) Response and the supp g o ents accurate and correct. Respondent's Signature: Date: 1? )09 P.O. Box 50191, Minneapolis, MN 55405-0191 • Tel: 800-474-2371 • Fax: 866-743-4517 • www.adrforum.com :112008 .x? ? d ? ? : ? ., „sn ?? ? "?, •-? SHERIFF'S RETURN - REGULAR CASE NO: 2009-00457 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS ENCK HEATHER A MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WNTrV NRATHFR A the DEFENDANT , at 1956:00 HOURS, on the 30th day of January , 2009 at 148 PROWELL DRIVE CAMP HILL, PA 17011 by handing to 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 12.60 Affidavit .00 Surcharge 10.00 .00 40.60 Sworn and Subscibed to before me this day of , So Answersf:' R. Thomas Kline 02/02/2009 BURTON NEIL & ASSOCIATES By: ?- Deput?k Sherif A. D. ,r.w. "lip :b? "^j