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HomeMy WebLinkAbout09-4781Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 KELLY A MANSBARGER : NO. dq - y781 0'i"i I -T&-ra% 428 Prowell Drive, Camp Hill Pa 17011-1469 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-18407 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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. KELLY A MANSBARGER 428 Prowell Drive, Camp Hill Pa 17011-1469 Defendant : NO. D%- Y 7 Fj c u j 7a-01 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 Kelly A Mansbarger, who resides at 428 Prowell Drive, Camp Hill, 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 8597 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 $5,275.36 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 $5,275.36, and the costs of this action. Burto Neil & A ciates, P.C. By: w J 'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 08/05/08 $5275.36 $5275.36 SITE:KC-CL TM:CO-5000 ACID:KCB0197 essir## afiisrRat=ism:;:: 10/03/08 2 3: 08: 07 CITI CARDS PO BOX 183057 KELLY A MANSBARGER COLUMBUS, OH 428 PROWELL DR 43218-3057 CAMP HILL PA 17011-1469000 /1• Citi* Driver's Edge atl Platinum Select Card-Charter Rbts Account Number 8597 Customer Service. 1-800-568-5000 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New balance $4750 $0 $3000 $0 $5275.36 Box 6500 Statement/ Amount Over Purch/Adv Minimum SIOUX FALLS, SD Closin Date Credit Line Past Due Minimum Due Amount Due 57117 07111/2 08 $525.36 $673.53 $166.32 $5275.36 Sale Data Post Date Reference Number Activity Since Last Statement Amount Standard Purch 7/11 LATE FEE - JUN PAYMENT PAST DUE 39.00 66 0000 0000000000 7/11 PURCHASES*FINANCE CHARGE*PERIODIC RATE 73.14 84 0000 0000000000 Standard Adv 7/11 ADVANCES*FINANCE CHARGE*PERIODIC RATE 2.18 84 0000 0000000000 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 y, ou can pay these fees (and any other amounts owed on your account) at any time. Your late fee was based on your account balance as of the payment due date (07/07/08), which was $5,161.04. 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. Our records show home phone 717-731-9727 and business phone 717-737-8030. Please update coupon if incorrect. IXHIBI Account Summary Previous (+) Balance & Purchases (-) Payments Advances & Credits +) FINANCE CHARGE (_) New Balance PURCHASES $5 033.47 1 $39.00 0.00 $73.14 $5 145.61 ADVANCES 127.57 $0.00 0.00 1 $2.18 3129.75 TOTAL $5,161.04 $39.00 0.00 $75.32 $5,275.36 Days This Billing Period: 31 Rate Summary Balance Subject to Periodic _ omina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $5,068.77 0.04655%(D) 16.990% 16.990% ADVANCES Standard Adv $128.62 0.05477%(D) 19.990% 19.990% SEND PAYMENTS T0: 974 Verification I, Shmm peon 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. ZAIQ Signature C-18407 Kelly A Mansbarger Account number ending in 8597 1000 D PLED -0,7 OF j ,A ` 2 0 0 9 i'iL 17 P"1 12 ::; nalriguom srwaft 41'18.50 PQ ATr( (!ILA'' 5(08015 RTII o`Z s I al Sheriffs Office of Cumberland County R Thomas Kline .? rlC Sheri OF THE Fr-f7P N"OTARY ??„stir ai ?u+nbr?pdfi? Ronny R Anderson Chief Deputy 2009 JUL 22 PM 2: 28 -? r o Jody S Smith Civil Process Sergeant OFrieE `THE HERIrP UN" Edward L Schorpp Solicitor Citibank (South Dakota) N.A. Case Number vs. 2009-4781 Kelly A. Mansbarger SHERIFF'S RETURN OF SERVICE 07/2112009 06:43 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 21, 2009 at 1843 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kelly A. Mansbarger, by making known unto Ward Mansbarger, husband of defendant a- 428 Prowell Drive Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 July 22, 2009 SO ANSWERS, R AOM :K?LS KF Dep4ity W? CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. KELLY A MANSBARGER 428 Prowell Drive Camp Hill Pa 17011-1469 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-4781 : CIVIL ACTION - LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $5,275.36 $5,275.36 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 - . L4 /1 Z?& I e- Pro Prothonotary 1?w BuWrrdi P.C. By . , Esquire Attorney for Plaintiff I.D. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-18407 w CITIBANK (SOUTH DAKOTA), N.A Plaintiff V. KELLY A MANSBARGER Defendant : IN THE COURT OF COMMON PLEAS C-18407 : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-4781 CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Kelly A Mansbarger 428 Prowell Drive Camp Dill Pa 17011-1469 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office 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 DATE OF NOTICE: August 12, 2009 In making this communication, we advise our office is a. debt collector. Burt eil & Ass fates, P.C. By Edward .O'Brien, squire Attorney for Plaintiff Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 r FILED-0iCE OF THE PROT !IONOTARY 2009 AUG 28 Ph 1: 31 CUES s NTY F- v3 oo WA? -3 9- -ft Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 PENNSYLVANIA V. KELLY A MANSBARGER : CUMBERLAND COUNTY, : NO. 2009-4781 Defendant : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 9b-910 Prothonotary By: fl?r?fiG l Deputy If you have any questions concerning the above, please contact: Edward J. O'Brien, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.