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Home My WebLink About09-3958Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 MICHAEL A KULCZYCKYJ : NO. OR -.R5$ a-via-terf-t 533 Lucinda Lane, Mechanicsburg Pa 17055 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-17117 Complaint 1. Plaintiff is Citibank (South Dakota), N.A., with place of business located at 701 East Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. 3 937 C ut l 71;:- MICHAEL A KULCZYCKYJ 533 Lucinda Lane, Mechanicsburg Pa 17055 Defendant CIVIL ACTION - LAW 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Michael A Kulczyckyj, who resides at 533 Lucinda Lane, 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 3001 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 $12,027.56 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 $12,027.56, and the costs of this action. P.C. By: ISerekT' Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 06/06/08 $12027.56 $12027.56 SITE:KC-CL TM:CO-5000 ACID:KCB0197 07/15/08 22:16:20: MICHAEL A KULCZYCKYJ CITI CARDS PO BOX 183057 COLUMBUS, OH 214 DOCK STREET 43218-3057 MIDDLETOWN PA 17057-1609000 " a t'' Card " Platinum Select Citi Account Number 3001 Customer Service: 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Avallable Cash Limit $0 $4200 $0 New Balance $12027.56 $10700 BOX 6500 SIOUX FALLS, SD Statement/ Amount Over Closin Date Credit Line Past Due 67 56 $1707 7 x Purch/Adv Minimum Duo $459.72 Minimum Amount Due $12027.56 57117 . . 08 $132 05/12/2 Sale Data Post Date Reference Number Activity Since Last Statement Amount 5/12 Standard Purch LATE FEE - APR PAYMENT PAST DUE 39.00 000 5/12 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 0000000 0000.24 84 0000 0000000 Balance Transfer - Charged To Offer 5 *FINANCE CHARGE*PERIODIC RATE RCH P 0.48 5/12 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (05/06/08), which was $11,687.84. Help is available! Please call the toll-free number shown above to learn about 8uamstoc5apm ayCentralpTime. Please gliveyus the opport nity to assistSyourday, EXHIBIT k Previous (+) urc ases (-) Payments (+) FINANCE =) ew Account Summary Balance & Advances & Credits CHARGE Balance PURCHASES $11,687.84 $39.00 $0 00 10.00 00 0 $300.72 $0.00 $12,027.56 $0.00 ADVANCES TOTAL $0.00 $11,687.84 . $39.00 . 0.00 $300.72 $12,027.56 Days This Billing Period: 32 Balance Subject to Periodic Nominal ANNUAL Rate Summary Finance Charg e Rate APR PERCENTAGE RATE PURCHASES Standard Purch 16,305.12 75 527 $5 0.07942%(D) 07942%(D) 0 28.990% 28.990% 28.990% 28.990% Offer 5 . , . ADVANCES Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Verification I, Shouna Houghton am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform, services on its behalf I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. r Signature C-17117 Michael A Kulczyckyj Account number ending in 3001 1000 0 F(EED41DPAC-f. OF THE PR0?(''4'?f',x^ TkRY 2009 JUN 12 PM 3-- 41 TIN so Po A C& 564108 P-T* a.alo [v?(o Sheriffs Office of Cumberland County R Thomas Kline Sheriff ?ir pC 4[?td?b?rr Ronny R Anderson t Chi D ?$?, a ? epu y ef Jody S Smith Civil Process Sergeant OFFICE 7"E aKER'rr Edward L Schorpp Solicitor Citibank (South Dakota) N.A. Case Number vs. 2009-3958 Michael A. Kulczyckyj SHERIFF'S RETURN OF SERVICE 06/30/2009 07/06/2009 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: Michael A. Kulczyckyj, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 09:14 AM - Dauphin County Return: And now July 6, 2009 at 0914 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint, upon the within named defendant, to wit: Michael A. Kulczyckyj by making known unto Nicole Kulczyckyj, wife of defendant at 605 Locust Street Hummelstown, PA 17036 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 08, 2009 ? rv O r? ? 'r 1 C., -0 T- CY) K ?'?fit.? oaf #[?eo'??exiff Mary Jane Snyder Real Estate Dep. William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy CITIBANK (SOUTH DAKOTA) NA VS County of Dauphin MICHAEL A KULCZYCKYJ Sheriff s Return No. 2009-T-1859 OTHER COUNTY NO. 20093958 And now: JULY 6, 2009 at 9:14:00 AM served the within COMPLAINT upon MICHAEL A KULCZYCKYJ by personally handing to NICOLE KULCZYCKYJ 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 605 LOCUST STREET HUMMELSTOWN PA 17036 WIFE Sworn and subscribed to before me this 6TH day of July, 2009 147? NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission Expires Sept 1 2010 So Answers, Sheriff of Da n Countv, Pa. By Deputy Sheriff Deputy: S SCHAEFFER Sheriffs Costs: $49.25 7/2/2009 l..?.L -LIB (?1?;t 13 2fl12 JAN 19 AM 10. 59 CUM NNSYLVAN'A S4 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. NO. 09 3958-CV MICHAEL A KULCZYCKYJ Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied. Burtok & Associates, P.C. By: The law firm of Burton Neil & Associates is a debt collector. C-17117 / 318 'YC. Blasker, Esquire Attorney for Plaintiff Ck 1131 9H O1 e al09913