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Home My WebLink About09-1787Burton 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. VONNIE ECKENRODE NO. ~4 ~ 78 ` ~w ~ 5 Travis Avenue, Shippensburg PA 17257-8112 ~ l 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-19420 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. VONNIE ECKENRODE 5 Travis Avenue, Shippensburg PA 17257-8112 Defendant CNIL 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 Vonnie Eckenrode, who resides at 5 Travis Avenue, 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. Count I 4. Plaintiff furnished consumer credit to the defendant by means of a(n) Sears credit card with account number ending in 2376 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 $3,852.07 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 $3,852.07, and the costs of this action. Count II 9. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number ending in 9428 hereinafter referred to as the credit card account. 10. Plaintiff kept accurate running records of all debits and credits to the account. 11. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit B. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 12. Before plaintiff mailed Exhibit B, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 13. Defendant's actions as set forth above constituted an account stated between parties for the sum of $12,865.18 which sum reflects the Exhibit B statement balance less credits, if any, which were applied subsequent to the date of Exhibit B. Wherefore, plaintiff demands judgment against defendant for the sum of $12,865.18, and the costs of this action. & A~sb~i~[tes, P.C. YID. emstein, Esquire Attorne for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. M y Sears Card® Previous Balance $3,729.98 Payments 8 Credits $0.00 Purchas & Debits e s $0.00 a~ h ~ Tot~aIrFINANCE CHARGES $87.09 Account Balance $3,852.07 cau ~s at 1-soo-ell-noo Go to www.warscard.com Write to us at PO Box 8283 Sioux Fads, SD 57117-6283 VONNIE ECKEN OI~ Account Number. ttt~2376 Pa ment Due Date Page 1 of 2 10/31/08 Your Account Summary Billing Cycle Closing Date 10/03/08 V Amount Over Credit Line $612.07 IDU'1"e In Chat'~e. Amount Past Due $762.44 We ~Y have ~ Pelt aok~Mon ~ ~ ~, Total Minimum Due $923.53 arld you're trt corrbnl dtlowyou do iL~ Your Credit Summary Total Credit Line $3,240.00 Total Credit Available $0.00 Manage your accauM online OR by phone - • You can qutcidy go orlarle, ar cei to get personal ewtstar7ce • See when a payment is due or posted • Select tram affadeble payment optbna to meet yore needs that - Lower your anrxlal peroerltage rate - Lower gar mhtmun payment Contact us todtsy-t+ve can help. Activity Sala Data Post Date Dasoriptlon Amount 09/30/08 09/30/08 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $3,729.98, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Card® Account Number. 2376 Payment Total Account BaNanu Due Data Minimum Due Amoulrt Enclosed $3,852.07 10/31!08 $923.53 VONNIE ECKENRODE 5 TRAVIS AVE SHIPPENSBURG PA 17257-8112 0079888 EX O1 A D8277 7 TR8008 FXO 007 7 N I11111111III II II IIIII 11111111111111111111111111111111111111111 Please make address changes on reverse side. Illtllllllllllllllllllll l1111111111111111111111111111111111111 Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 35.00 C-l9Ydb EXHIBIT- Sears Card® VONNIE ECKENRODE Account Number: XXXX XXXX XXXX 2376 Page 2 of 2 79988 o..°.... .., __ _ ... . Average Dsily Balance Balance Call us at 1-800.917-7700 Go to www.wsracard.com Write to us at PO Box 8283 Sioux Fells, SD 57117-6283 Pa meat Due Date 10/31/08 tpond"mp Periodic Rate Periodic JAL ~oay FINANCE ~NTAGERATE M=INonth CHI-~GE- SEARS REGULAR $3,852.07 $3,776.42 27.15°h' .0744%(D)' $87.09 EXTERNAL REGULAR $0.00 $0.00 27.15'/0' .0744%(D)' $0.00 CASH ACCESS REGULAR $0.00 $0.00 27.15%' .0744%(D)` $0.00 Days in Billing Period: 31 Effective ANNUAL PERCENTAGE RATE: 27.15% Minimum FlNANCE CHARGE: $0.00 Cardmember News The Sale Date is the Transaction Date. Your Total Minimum Payment on any Account Balance over $10 will no longer include the total amount of balance transfer and cash advance transaction fees or applicable insurance charges or credit protection fees assessed that billing period. Remember, you can pay these fees (and any other amounts owed on your aarount) at any time. 07/08/08 512865.18 512865.18 SITE:KC-CL T11~04/080 ACID•22g51944: YONNIE J ECKENRODE 5 TRAVIS AYE SNIPPENSBURG 17257-8112000 Cities Driver's Edge Card r Rebates 428 ~i rvieac 1_~O_7 6_~ TOtal Cntlit Unf Avtikbk Crfdn lpK box 6580 511530 50 SIOUX FALLS, SD Cf~taItfa~f~: A ~n~Ow~ tv,sv 06/13{Z008 (1335.1L8 Cfsh AdVtacf ~Imit AvaUtpk Cash t.imit 5310 50 Ptrch/Adv Past Ow ItlMwun Ow 51410.29 297.47 Nfw aslaace 512865.18 Standard Porch 6113 LATE FEE - MAY PAYMENT PAST OUE 00000000005 • 6/13 P~IIRCNAS~ES•FINANCE CNARGE•PERIODIC RATE 292.47 84 0000 0000000000 Your Minimum Amount Due on any New Balsnce over ;20 will no longer include the total aaqunt of your transactTOn fees. These fees include balance transfer, cash advance. and foreign purchase fees. Restember, ou can pay these tees (and any other amounts owed on your account) at any time. Nelp is available! Please tail 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. EXHIBIT ~ _, Account StNnntary ~ oua balrnce + urc eses 6 Advances - aymen s t & Credits CNAtl6E ^ tlw Balance PURCHASES NCES 612,5 T.71 ~ 5 5.00 ~ 0.00 :2 2.4T ~ ~ 512,85.18 T07A 512,5 ~.71 5.~ i 2.4 T 0.00 i2 512,865.8 Dave Thts Rab ~ Finance Gharge~ Rste APR PERCENTAGE RATE CITI CARDS PO BOX 183860 coc.uMSUS, ox 43218-3060 C \~`~~II PA CI~I~ ANCESd Porch 512,698.34 0.07942%{D) 28.99016 28.990% andard Adv 50.00 0.07942%(D) 28.99016 28.990% Veriffcation pam Cline 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. ~ L Signature C-19420\C-18967 Vonnie Eckenrode Account number ending in 2376 1031 n ~ ~ -`wi't <;° -~~ i=~ "~ ~ -i c~ r-n ~rl ~. N l C .s.7 ' .. ~~ ' ~ ^~ =! ~ i , ~. ._. _ ..1.+ ~.~ v, 1 , + . /~ ~.~,