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Home My WebLink About09-7292w , a 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH W BETTINGER : NO. ?q -'jaQa ?IV{? (?rWt 67 Walnut Dale Road, Shippensburg PA 17257-9667 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 . _ND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-21216 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. p 9- ? ? 9 z C(La 7curas JOSEPH W BETTINGER 67 Walnut Dale Road, Shippensburg PA 17257-9667 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 Joseph W Bettinger, who resides at 67 Walnut Dale Road, Shippensburg, 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 0078 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 $2,199.41 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 $2,199.41, and the costs of this action. Burton Neil & Ass iates, P.C. By: Ed d 6>16rien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. SearsCharge PLUS` Call us at 1-800-917-7700 Go to www.seamcard.com Write to us at PO Box 8283 Sioux Falls, SD 57117-6283 Your Account Summa JOSEPH W BETTINGER Account Number 078 Page 1 of 2 Billing Cycle Closing Date 12/23/08 Amount Over Credit Line $0.00 Amount Past Due $508.72 Total Minimum Due $600.55 Previous Balance $2,129.58 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $34.83 Account Balance $2,199.41 Your Credit Summary Total Credit Line $5,200.00 Total Credit Available $0.00 Payment Due Date 01120/09 Activity Sale Date Post Date Description Amount 12/22/08 12/22/08 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,129.58, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Rates 'Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $2,199.41 $2,148.74 20.40%' .0559%(D)' $34.83 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 20.40% Minimum FINANCE CHARGE: $0.00 Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. SearsCharge PLUS' Account Number 078 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $2,199.41 01120/09 $600.55 JOSEPH W BETTINGER 67 WALNUT DALE RD SHIPPENSBURG PA 17257-9667 0000000 ED 16 08356 1 THS001 F10 001 7 W II II VIII III IIII IIIIII II III II II IIIIIIIIIII II II III IIIIIIIIII III IIIIIIIIIIIIII II IIIIIIIIIIIIIIIIIIIIIII IIIIIII III III II IIIII III Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 078 0219941 0060055 0000000 1613r"'g'T SearsCharge PLUS Call us at 1-NO-917-7700 ` Go to www.eearseerd.oom Write to us at PO Box 8283 Sioux Fells, SD 57117-8283 JOSEPH W BETTINGER Account Number: XXXX XXXX XXXX 0078 Page 2 of 2 0 Cardmember News Payment Due Date 01/20/09 The Sale Date is the Transaction Date. The "Effective ANNUAL PERCENTAGE RATE" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "Effective ANNUAL PERCENTAGE RATE" is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. Verification I, Pam Cline , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. :1? ? Q. - Signature C-21216 Joseph W Bettinger Account number ending in 0078 1031 O ILt ^A!??1 2??30c-j -Z N-1 22:414 41J.5o PD ATI%f (oil 41 R awwo0 Sheriffs Office of Cumberland County R Thomas Kline Sheri OFF iCE 'GP ' IE $,"ERIFF . FILED-OFFICE OF THE POTH?f,'OTARY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2009 OCT 29 AM 10: 11 CUN Citibank (South Dakota) N.A. vs. Joseph W. Bettinger Case Number 2009-7292 SHERIFF'S RETURN OF SERVICE 10/27/2009 08:44 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 27, 2009 at 2044 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joseph W. Bettinger, by making known unto himself personally, at 67 Walnut Dale Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hire personally the said true and correct copy of the same. SHERIFF COST: $46.00 October 28, 2009 SO ANSWERS, roool-Ac"O' ? vo? R THOMAS KLINE, SHERIFF Deputy Sheriff