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Home My WebLink About09-6254% 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA GALE M DERRICK : NO. C-1vi L Term 3425 Market St, Camp Hill PA 17011-4428 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-22272 . ra IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 9 - L .7 S"1 61"- 72. CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 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. GALE M DERRICK 3425 Market St, Camp Hill PA 17011-4428 Defendant 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Gale M Derrick, who resides at 3425 Market St, 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 1675 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. 4k 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $6,830.32 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 $6,830.32, and the costs of this action. Burton Neil & Associates, P.C. //L( By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Citi Professional" Card December 3 - January 5, 2009 GALE M DERRICK Account 1675 Page 1 of 2 Statement/Closing Date: 01/05/09 Quick Reference Minimum Payment Payment Due Date* 6830.32 January 29, 2009 +Payment must be received by 5:Gn pm local time on the payment due date. Amount Past Due 1,328.34 130 32 1 Amount Over Limit . , Amount Over Limit 00 700 5 Total Credit Line . , 0 00 Available Credit Line . 300 00 1 Cash Advance Limit Available Cash Advance Limit . , 0.00 Account Summary Previous Balance 6,615.71 0 00 Payments and Adjustments . 39 00 Purchases Cash Advances . 0.00 Fees & Finance Charges 175.61 32 830 $6 New Balance . , Purchase Categories Total Purchases $0.00 How to Reach Us www.citicards.com Citibank Customer Service Ctr BOX 6062 SIOUX FALLS, SD 57117 1-800-756-4000 Cardmember News Your late tee was based on your account balance as of the payment due date (12/29/08), which was $6,615.71. Help is available! Please call the toll-iree number 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. date paid amount paid check # Please follow payment Instructions outlined in the "important Instructions for Making Payments" section of the statement. Your Account Nuneer 05528150012601675683032999995217 1675 Please Eater Ainmmt of Payment Enclosed paYnent IWIM ee oe~ By 74 otal esls les =8 01/28/09 ,830.32 $6,32 69N PM 32 A 1 AR7322234 GALE M DERRICK 3425 MARKET ST CAMP HILL PA 11011-4428 CITI CARDS 2 EXHIBIT iq PO BOX 18305 COLUMBUS, OH 43218-3052 ?» ?? ww?iw/ F y . December 3 - January 5, 2009 GALE M DERRICK Accoun 675 Statement/Closing Date: 01/05/09 Page 2 of 2 Payments and Adjustments Sale Date Post Date Activity Amount Total Payments and Adjustments $0'00 Purchases Sale Date Post Data Activity Amount Total Purchases $0'00 Cash Advances Sale Data Post Date Activity Amount Total Cash Advances $0'00 Fees & Finance Charges _ Standard Purch Sale Date Post Date Activity Amount 01/05 LATE FEE - DEC PAYMENT PAST DUE $39.00 01/05 PURCHASES *FINANCE CHARGE*PERIODIC RATE $175.61 Total Fees & Finance Charges $214.61 Finance Charge Information Days in Balance Periodic Transaction Nominal Periodic x Billing x Subject to = FINANCE + Fee/FINANCE APR Rate Period Finance Charge CHARGE CHARGE - PURCHASES Standard Purch 28.990% .07942%(D) x 33 x $6,700.47 = $175.61 + $0.00 28.990% CASH ADVANCES Standard Adv 28.990% .0794Z%(D) x 33 x $0.00 = $0.00 + $0.00 28.990% Total FINANCE CHARGE = $175.61 t Verification I, Shame Hgto ton 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-22272 Gale M Derrick Account number ending in 1675 1023 0 OF Tl-il:- 2000 S E P { 1 PH 12: k $'78.50 PO A'rTI/ co )1 L06 PTA .130C A 4 Sheriffs Office of Cumberland County R Thomas Kline Sheri AFF;CE OF 7nE : ?<RIF€ F THE Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Citibank (South Dakota) N.A. vs. Gale M. Derrick 2rB IQ EP 22 € H 12: '--' 4 ':, T Case Number 2009-6254 SHERIFF'S RETURN OF SERVICE 09/22/2009 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: Gale M. Derrick, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Gale M. Derrick. Joyce Lanchrer, the receptionist at 3425 Market Street Camp Hill, PA 17011 stated the defendan- does not work here. An exact address is not available. SHERIFF COST: $46.50 September 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Citibank (South Dakota) N.A. vs. Gale M. Derrick ~t - ~''~'d Flt.~p-~~#-r;CE 110 JAN -8 At9 9~ 44 PF.~'iy$YLya~q Case Number 2009-6254 SHERIFF'S RETURN OF SERVICE 01/05/2010 08:04 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2010 at 2004 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gale M. Derrick, by making known unto herself personally, at 387 North 19th Street, 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: $41.50 January 06, 2010 SO A WE NY R ANDERSON, SHERIFF puty Sh¢riff CITIBANK (SOUTH DAKOTA), N.A.CARD 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff TN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. C~ o - ~i NO. 09-6254 CIVIL TERM ~ o GALE M DERRICK Z,~_, r ~~ -_ ; -~ ~ -,., 387 North 19th Street Lr , ~ _ -n M Camp Hill PA 17011-4428 va ::.. -:.~ v. ~~ ~ j~' Defendant :CIVIL ACTION -LAW 7 : ~_ ., ro `~ <. L-., ~~ ~~ Praecipe for Default Judgment ~ ~ ~ To the Prothonotary: ~, -< 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 $6,830.32 $6,830.32 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 Pro Prothonotary Burton Neil & Associate P.C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector C-22272 ~`i~4. vo ~~. ~~ G K~ 1~Q88 ~~ X37`.2? Ivo~~~~-ice .n.~~'C~~ CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. GALE M DERRICK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.09-b254 CIVIL TERM CIVIL ACTION -LAW Notice of Intention to File Praecipe for Default Judgment TO: Gale M Derrick 387 North 19th Street Camp Hill PA 17011-4428 IMPORTANT NOTICE C-22272 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 Sheet Carlisle, PA 17013 Telephone No.717-249-3166 or 800-990-9108 DATE OF NOTICE: January 29, 2010 in making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610}696-2120 n.,.. ,__...., .,~...~... _ .. _. .. ,.. ~_ 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. Plaintiff v. GALE M DERRICK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6254 CNIL TERM CIVIL ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ~~ _ i ~_ 20 / C~ Prothono By: If you have any questions concerning the above, please contact: Neil Sarker, 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.