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Home My WebLink About09-2551Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LID #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. KWAN CHENG 4125 NANTUCKET DR MECHANICSBURG PA 17050-7605 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. O9 - cQ-XZ CiVi? 1F1?'I?? NOTICE TO DEFEND 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 twenty (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 claims 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 2136815 PPTCHDFI L , Blatt, Hasenmiiler, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. ##92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA), N.A. CITIBANK (SOUTH DAKOTA), N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, VS. KWAN CHENG 4125 NANTUCKET DR MECHANICSBURG PA 17050-7605 Defendant(s), IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 4 9. 2 5 5( Ctur l TL COMPLAINT Plaintiff, CITIBANK (SOUTH DAKOTA), N.A. claims as follows: 1. The Defendant(s), KWAN CHENG , is a resident of Cumberland County, Pennsylvania. 2. In the usual course of business, the Defendant requested that Plaintiff open, and Plaintiff did open a credit account. Defendant was the cardholder under the account. 3. The Defendant(s) did use the account to make purchases of goods and/or services and/or to receive cash advances. There is a balance due and owing of $13295.04. 4. Plaintiff properly billed Defendant for payment of the charges on the account. Defendant has failed to pay the amounts due and owing. Thus, Plaintiff declard Defendant(s) to be in default and demands payment of the balance. 2136815 PPTCCITI WHEREFORE, the Plaintiff, CITIBANK (SOUTH DAKOTA), N.A., prays for judgment in its favor and against Defendant(s), KWAN CHENG in the amount of $13295.04, plus costs. Respectfully s miffed, CITIBANK ( TH DAKOTA), By: One of its Attorneys Daniel Santucci, Attorney No. 92800 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: March 25, 2009 VERIFICATION is 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 including but not primarily limited to collecting delinquent debt. 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). The foregoing averments of fact in the within COMPLAINT are true to my 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. Date: V ig ature 2136815 PPTXCITI Exhibit "A" PPTXEXAI 07/07/08 $13295.04 $13295.04 SITE:KC-CL TM:CO-5000 ACID:KCB0197 appm 07/11/08 23:00:42: CITI CARDS PO BOX 183059 " KWAN CHENG COLUMBUS, OH ATTNY ACCOUNT-CODE=LTO3 43218-3059 MECHANICSBURG PA 17050-7605000 E7 Cfti' Platinum Select' Card CTI, a Pccount Number 5410.6584 3853 9270 Customer Service: 1-800-950-5114 Total Credit Line $12820 Available Credit Line $0 Cash Advance Limit Available Cash Limit New Balance BOX 6062 $10900 $0 $13295.04 SIOUX FALLS, SD sstatement/ Cloal Date 2 Amount Over Credit Line Past Out porch/Adv Inimum Dae Minimum Amount but 57117 06/12/ 08 $475.04 $1898.91 199.00 $13295.04 SaN Date Post Date Reference Number Activity Since Last statement Amount 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. 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. Account Summary Previous + Balance & A urc aces - Payments dvances & Credits (+) FINANCE CHARGE ¦ Now Balance PURCHASES ADVANCES TOTAL $13,295.04 ¢0.00 0.00 0.00 1 1 0.00 0.00 0.00 0.00 1 ;13,2 5.04 0 00 2 $13,295.04 0.00 0.00 0.00 . $13, 5.04 Days This Billing Period: 29 Rate Summary Balance Subject to Finance Charge er o le Rate Nominal ANNUAL PURCHASES APR pE RCENTAGE oAT Standard Purch Offer 4 0.00 0 00 0.07942%(D) 28.990% 28.990% Offer 5 Offer 7 . 0.00 1 0.07942%(D) 0.07942%(D) 28.990% 28.990% 28.990% 28.990% 4DVANCES 0.00 0.07942%(D) 28.990% 28.990% Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Q r E OF 7 11 TARY 10091 Pd' \ ( '13 A lo: J 9 Cum, Os . So Pn PATTq dwo OUT a JA4155 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. KWAN CHENG 4125 NANTUCKET DR MECHANICSBURG PA 17050-7605 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION ???? No. bq -d-, 51 0""' 1Teerw PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-800-850-1079 ext. 4151 Dated: March 25, 2009 2136815 PPTXPEAI I MIMI IN 111 1111111111 Hill 1111111111111111111111111111111111111111111111111 1111 BLATT, HA & MOORE, By: Daniel Santucci Gregory R. Dye LEIBSKER L` FF1LE1-"-F;? fi E CF THE ; 2009 APR 23 AM 10: 59 Z.ilf1?' i'' Y ?a ?1n ,V? Sheriffs Office of Cumberland County R Thomas Kline r of cumbtr4t Edward L Schorpp Sheri ' A# Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFF IGE,";c T4E s-ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/12/2009 05:35 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kwan Cheng, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kwan Cheng. Kanyuk Cheng the defendants stepdaughter states that the defendant has not resided at 4125 Nantucket Drive Mechanicsburg, Cumberland County Pennsylvania 17050 in ten years, and he is currently residing in a nursing home in Maryland. The Mechanicsburg Postmaster has advised that the defendants mail is still delivered to address. An exact address is not available. SHERIFF COST: $42.00 May 12, 2009 2009-2551 Citibank VS Kwan Cheng SO ANSWERS, R THOMAS KLINE, SHERIFF FILE C-,,-? OF THE F' 'C7!`- TM 2009 MAY 14 ril ?: 24, -ly