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Home My WebLink About09-5367Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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 LINDA K SPRIGGLE : NO. oq - sa07 l V 1 ? le m 4191 Gettysburg Road Lot 7 Camp Hill PA 17011-6700 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-14443 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. LINDA K SPRIGGLE 4191 Gettysburg Road Lot 7 Camp Hill PA 17011-6700 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o'? -5-367 c", 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 Linda K Spriggle, who resides at 4191 Gettysburg Road Lot 7, 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(n) Sears credit card with account number ending in 0839 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 Defendant 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 $10,273.11 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 $10,273.11, and the costs of this action. By: eil &I Associates, P.C. Yalp-Weinstein, Esquire Attdrney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt ld MasterCard Cain us at 1.800.6ee-8488 G S o ears Go to www.omrward.com Write to us at PO Box 0022 The Lakes, NV 88901-6922 LINDA K SPRIGGLE ;6 Payment Due Date 0839 Account Number 6910 4 Page 1 of 2 02/12/08 Your Account Summar y Billing Cycle Closing Date 01115108 Amount Over Credit tine $0.00 Amount Past Due $1,820.42 Current Minimum Due $427.12 Total Minimum Due $2.247.54 Want an easy tray to make a fresh start? r ! s 8 P $9,94 Many cardmembata here re *W wardue aalwm by vaing their lax rehnd yme Credits Paayme nts i1 & , Cre $00.0 .00 00 $0 ?? 11 money. Ire ample and celMv*t Evan It you're not expecting a tax refund Purchases S Debits . $39 00 chocK wehwepaymentpragramstaallkindsofstatlrns,maybewenyours. O Cha Other rges S . 12 $285 FINANCECHARGE . 11 273 $10 Ws Important you callus Coda at 1-866-651 0186 k Account Balance . , new year the scan of something good. We can help you melee th Your Credit Summary Total Credit Line $13,450.00 Available Credit Line $0.00 Cash Access Line $2,690.00 Available Cash $0.00 Activity Sale Dab Poet Data Dvwription Amount 01110108 01110108 LATE PAYMENT FEE 39.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. BINed Aoawd Prwiow Paymarrta Pumheaee FINANCE Promo. FINANCE Exp. Promotional Balances sawn*" rR credits a Debit CAAi1M Beare MARM Date BALANCE TRANSFER $4,589.18 $0.00 50.00 $131.43 $4.720.61 $0.00 Until PD B,AIANCETRANSFER $4.637.14 $0.00 $0.00 $132.80 $4,769.94 $0.00 Until PD CONVENIENCE CHECK $193.40 $0.00 $0.00 $5.54 $198.94 $0.00 Until PD Sears Gold MasterCard' Account Number 39 Tohl Account Balance Duo Onto Mhilnum Dw Amoumt Encioeed $10,273.11 02112108 $2,247.54 $ 027a11115 110 09 A. 000/5 1 TXNN "s 001 7 X LJII...III...... Il..rllrllrrlrrnlllaaallarrllrrrlrrrlllarrl LINDA K SPRIGGLE 4191 GETTYSBURG RD LOT 7 CAMP HILL PA 17011-6700 Plasm make aWress corrections above. rlnlnllnrlnlnull!nlnrllrllurlulrrnlnllnlualnllrlrr Make check payable to SEARS CREDIT CARDS PO BOX 183062 COLUMBUS, OH 43218-3082 639 P, X1BIT ?' Sears Gold MasterCard* LINDA K SPRIGGLE Account Number. XXXX XXXX XXXX 0839 Page 2 of 2 273195 Call us at 1-800-869-8488 Go to www,searscard.com Write to us at PO Box 6922 The Lakes, NV 88901-6922 Payment Due Date 02/12108 Rates 'Rate Varies Belence AveMe Delly Baknw Corresponding Periodic Rate ANNUAL D=Dsy pTAGE RATE M=Momh Periodic FINANCE C RG SEARS 41 $269 $233.99 31.24%* .0856%(D)' $6.61 REGULAR . EXTERNAL 21 $314 $309.68 31.240/9 .0856%(D)' $8.74 REGULAR BALANCETRANSFER . $4,720.61 $4.652.59 31.2496' .0856%(D)' $131.43 BALANCETRANSFER $4,769.94 $4,701.21 31.24%' ' 6 .0856%(D)' ' $132.80 54 $5 CONVENIENCE CHECK $198.94 $196.06 /0 31.24 .0856%(0) . CASH ACCESS 00 $0 $0.00 31.24%' .0856%(0)` $0.00 REGULAR . ANNUAL PERCENTAGE RATE: 31.246/6 ti Eff Minimum FINANCE CHARGE: $0.00 Days in Billing Period: 33 ec ve Verification "?iena r?eynoids 1, 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 C-14443 Linda K Spriggle Account number ending in 0839 1032 Q r ti " Tt???l THE": 2009 Jx lL 31 P 3: 2 3 C } F F .$78.50 PA ATTy Crif ta3y a eaa8 7o Sheriffs Office of Cumberland County R Thomas Kline ; . Sheriff OF TI PE w _ ;° F; t M Y Ronny R Anderson Chief Deputy - F` • 2009 PtUlIG "6 P1:1 3: 3 ! Jody S Smith Civil Process Sergeant OUICE OF: Tt, E?ERiPF G?.IIL'`IE- ;T Y Edward L Schorpp Solicitor Citibank (South Dakota) N.A. vs. Linda K. Spriggle Case Number 2009-5367 SHERIFF'S RETURN OF SERVICE 08/04/2009 07:32 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 4, 2009 at 1932 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Linda K. Spriggle, by making known unto herself personally, defendant at 4191 Gettysburg Road Lot 7 Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $39.70 August 05, 2009 SO ANSWERS, -00 R THOMAS KLINE, SHERIFF 01 TZ eputy Sheriff U Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5367 CIVIL TERM LINDA K SPRIGGLE Defendant : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Ndr& By: Y The law firm of Burton Neil & Associates is a debt collector. P.C. Nan, Esquire for Plaintiff C-14443 OF THE `7 `.I)'74PY 20,39 SE 2' 1 PIN 2: 0