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Home My WebLink About09-7352Burton 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 KIMBERLY A KENNERLY : NO. (? - 7 ?tVl? ???-rh 6307 Valleybrook Drive, Mechanicsburg PA 17050-7300 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-21263 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. KIMBERLY A KENNERLY 6307 Valleybrook Drive, Mechanicsburg PA 17050-7300 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o q- '7 ?Y 5 Z &"u 7 t,? 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 Kimberly A Kennerly, who resides at 6307 Valleybrook Drive, Mechanicsburg, 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 7570 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 $1,803.20 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 $1,803.20, and the costs of this action. Burton INdil Sikssociates. P.C. By: PlereT, C. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Card" Cali us at 1-X)0-917-7700 Go to www.soamcard.com Write to us at PO Box 8283 Sioux Falls, SD 57117-6283 KIMBERLY A KENNERLY Payment Due Data Account Number: ? 7570 Billing Cycle Closing Date 12/24108 You're in charge. Amount Over Credit Line $133.20 Amount Past Due $508.03 We may have the payment solution just for you, Total Minimum Due $609.94 and you're in control of how you do K. Previous Balance $2,224.29 Manage your account online OR by phone Payments & Credits $100.00 . You can quickly go online, or call to )et personal assWAnce Purchases & Debits $0.00 • See when a payment is due or posted Other Charges $35.00 • Select from affordable payment options to meet your needs that Total FINANCE CHARGES $43.91 may_ Lower your annual percentage rate Account Balance $2,203.20 - Lower your minimum payment Contact us today-we can help. \ Your Credit Summary Total Credit Line $2,070.00 / Total Credit Available $0.00 Activity Sale Data Post Date Description Amount 12/04/08 12/04/08 PAYMENT -THANK YOU -100.00 12/23/08 12/23/08 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,124.29, 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. Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Card" Account Number: 7570 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $2,203.20 01/21/09 $609.94 0091909 EX 17 A 08389 1 TR9009 FX8 001 7 N IIIIIIIIIIIIr IIIIIIIIIIIIIIIIIIIIIIIIIII III IIIIIII111III IIIIIIIIIIIIIIIIIII IIIII IIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 11 1111 Make check payable to KIMBERLY A KENNERLY SEARS CREDIT CARDS 6307 VALLEYBROOK DR PO BOX 183081 MECHANICSBURG PA 17050-7300 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 504994018683 0220320 0060994 0010000 1715 Your Account Summary Page 1 of 2 01 /21 /09 • Sears Carde KIMBERLY A KENNERLY Account Number: XXXX XXXX XXXX 7570 Page 2 of 2 81809 Average Daily Rates *Rate Varies Balance Balance Call us at 1-800-917-7700 Go to www.seeracerd.oom Write to us at PO Box 8283 Sioux Falls, SO 57117-8283 Payment Due Date 01 /21 /09 "riding Periodic Rate Periodic JAL D--Day FINANCE TENTAGE RATE M=Month CHARGE SEARS REGULAR $2,203.20 $2,175.58 25.40%* .0696%(D)* $43.91 EXTERNAL REGULAR $0.00 $0.00 25.40%* .0696%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 25.40%* .0696%(D)* $0.00 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 25.40% Minimum FINANCE CHARGE: $0.00 Cardmember News 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, Lisa BluM , 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. 'r Uap'-21'po&- Signature C-21263 Kimberly A Kennerly Account number ending in 7570 1031 0 OF THE %PP0MtAAY 2009 OCT 26 PM 2: 17 COUNTY PENNSYLVANIA *'78.50 PO Am/ GIGS & 1805 asa?(? Sheriffs Office of Cumberland County R Thomas Kline Cc?-LUF 714- Sheriff *ortr at `ujn6"rf4 . _ ',7ARY Ron Ronny R Anderson 4¢ 1° 2009 `? t NO V_ 4 A' I /1: 4 Q Chief Deputy C s Jody S Smith 4l Civil Process Sergeant OFFICE r" Eat ! Edward L Schorpp Solicitor Citibank (South Dakota) N.A. Case Number vs. 2009-7352 Kimberly A. Kennerly SHERIFF'S RETURN OF SERVICE 11/03/2009 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: Kimberly A. Kennerly, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kimberly A. Kennerly. Per resident of 6307 Valleybrook Drive Mechanicsburg, PA 17050 the defendant is currently residing at 21 N. Market Street Elizabethville, PA 17032. SHERIFF COST: $42.00 November 03, 2009 SO ANSWERS,.; R THOMAS K E, SHERIFF r '' F7 r~~ ~?~ p r~ ~Tq~y 20'10 FE8 -g At.1Q~ 4 ~Ci11I`vSY~ ~~~.:Jr`Vi)' Llfaa aye Burton Neil & Associates, P.C. By: Derek C. Blacker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. KIMBERLY A KENNERLY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.09-7352 CNIL 'TERM CNIL ACTION - LA W Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & es, P.C. By: Derek sk r, Esquire Attorney for Pl 'ntiff The law firm of Burton Neil & Associates is a debt collector C-21263