HomeMy WebLinkAbout09-4005
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.
PEGGY S RAILING
14 East Green Street, Shiremanstown Pa 17011
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Cwt' ( C* *1
: 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-20596
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. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. V q- 9005 Cwt -Z
PEGGY S RAILING
14 East Green Street, Shiremanstown Pa 17011
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 Peggy S Railing, who resides at 14 East Green Street, Shiremanstown,
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 7550 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 $1,722.54 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 $1,722.54, 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.
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Total New Balance:
82,322.54
Minimum Amount Due:
$2,3122.54
Payment Due Date:
12AS12000
000000 MC 32 A 0
PEGGY S RAILING
14 E GREEN ST
SHIREMANSTOWN PA 17 011-65 5 2
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Chec k a Detach and INlow
wymtllL IIHiNCENM eh tWafee
ktaaechecapeyMlete:C1t1 Cards
Account Number.
7550
Amount Enclosed:
v f
Payment must be recetred by 5:oo PM
Incal tMne " the payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH43218-2564
r(HIBR
Verification
Sham Mq phton
I,
C-20596
Peggy S Railing
Account number ending in 7550
1000
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.
Signature
FIL F
OF THEE
2309 JUN 15 PM 1: 4 5
a iopuom wtgfi?,
$178.50 PA AT"
(;?,?t S55'16
o1?lt?'14 CP
Sheriff s Office of Cumberland County
R Thomas Kline ~~;~,titr at : ~~ ~nGrrr~'r Edward L SChorpp
Sheriff ~' '~ Solicitor
C _ .,
=t .~_.
Ronny R Anderson Jody S Smith
Chief Deputy '"~~wE'= "-"= s"`~'~~ civil Process Sergeant
Citibank (South Dakota) N.A. Ca a Number
vs. 009-4005
Peggy S. Railing
SHERIFF'S RETURN OF SERVICE
06/22/2009 05:00 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states t at on June
22, 2009 at 1700 hours, he served a true copy of the within Complaint and Notice, upon the ithin named
defendant, to wit: Peggy S. Railing, by making known unto herself personally, defendant at 4 E. Green
Street Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the sa a time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $41.50 SO ANSWERS,
7~ ~,I'~~
June 23, 2009 R THOMAS KLINE, SH IFF
ut Sherif
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