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Home My WebLink About09-4568 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA GUIANA R POFF : NO. CA- qs"8 ClVi l-Fermi 657 Lewisberry Road New Cumberland PA 17070-2709 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-17014 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. 09- q3 (4a - GUIANA R POFF 657 Lewisberry Road New Cumberland PA 17070-2709 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 Guiana R Poff, who resides at 657 Lewisberry Road, New Cumberland, 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(n) Sears credit card with account number ending in 5205 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 $1,745.98 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 $1,745.98, and the costs of this action. Burton Neil & .Assbciates. P.C. By: Derek C. X31 er, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Premier Gold MasterCard' Call us at 1-800-669-8488 Go to www.seemeard.com Write to us at PO Box 6922 The Lakes, NV 88901-6922 GUIANA R POFF Account Number: 5205 Page 1 of 1 Your Account Summary Billing Cycle Closing Date 12/26/07 Amount Over Credit Line $645.98 Amount Past Due $546.09 Current Minimum Due $27.00 Total Minimum Due $1,219.07 Previous Balance $1,745.98 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $0.00 FINANCE CHARGES $0.00 Account Balance $1,745.98 Your Credit Summary Total Credit Line $1,100.00 Available Credit Line $0.00 Cash Access Line $110.00 Available Cash $0.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Payment Due Date 01/15/08 Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Rates `Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $600.94 $0.00 31.24%* .0856%(D)* $0.00 EXTERNAL REGULAR $1,145.04 $0.00 31.24%* .0856%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 31.24%* .0856%(D)* $0.00 Days in Billing Period: 30 Effective ANNUAL PERCENTAGE RATE: 31.24% Minimum FINANCE CHARGE: $0.00 Sears Premier Gold MasterCard' Account Number: X5205 Payment Total Account Balance Due Date Minimum Due Amount Enclosed -1 [ $1,745.98 01/15/08 $1,219.07 0000000 EX 17 07360 1 TXS503 FVG 001 7 W I111ili11111 I111111IIIII III II II IIIIIIII II III IIIIIIIIII IIIII III GUIANA R POFF 657 LEWISBERRY RD NEW CUMBERLAND PA 17070-2709 Please make address corrections above. III IIIIIIIIIIII111III11IIIIIIIIII IIIII IIIII II IIIIIIII II 11111 Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 100 5121075042315205 0174598 0121907 0000000 1714 IXHIBIT - L Verification I Tiena Reynolds 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. I VAA,,,- LAZR& Signature C-17014 Guiana R Poff Account number ending in 5205 1032 0 FIND .: 2R9M -0 FA JJ I iii.'rv' o PD' A-!7 ( co 504016 RT* lad-151 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. Plaintiff V. GUIANA R POFF Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4568 CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Ne ociates, P.C. By: Derek . Bl ker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-17014 FILED--?) iD: OF THE PL=O iHC NKYARY 2009 JUL 20 Ph 1= 09 PENNSYLVANIA