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Home My WebLink About09-7361 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MICHELLE CARROLL :NO. Qq, 731o1 alvil exrt 115 3rd Street, New Cumberland PA 17070-2107 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-22749 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ? : NO. 0 9- 13 MICHELLE CARROLL 115 3rd Street, New Cumberland PA 17070-2107 Defendant : 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 Michelle Carroll, who resides at 115 3rd Street, New Cumberland, 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 0513 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 $3,050.55 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 $3,050.55, and the costs of this action. Burton Neill & Associates, P.C. By: De QC. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Gard' MICHELLE CARR Account Numbs . 13 Paps 1 of 2 Your Accowd Summs 61WV Cycle Clo*V Date 01IMMIXII Amount Over Credit Urle $505.20 Amount Pest Due 3773.87 Total MINmum Due $898.88 Previous Belarice $3,013.99 P"wisntr S Credits $0.00 Purdtasss B Defrite $0.00 &? Cha F $ 21 Total K AACE CHARGES 6. Account Balance $3,105.20 Your Cf"w awns nary Total Credit Line 52,800.00 Total Credit Available $0.00 You're in chwge. P at Due Dell 02/03109 We may haw the sakfa tt just for you, and you're In mdrW of how you do N. MwMe your 0000" OnUm OR by phons • )tu ann quldey go orb, or a a pet pneonl neWw" • So hhlhan a pqm i®rd Ie dl+? or poN?d • shat from asaddA pmt apuors b meet ycw needs that Nw. -Lowyxw><nl p?oar? and* LcowymmliM0. paynlwK Conb d w can Activity sob oeb poet Dab Dsew"ml Amowit 01101108 01101/08 LATE PAYMENT FEE 35,00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF =3,013.88, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE 0 SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment Inetructl me on reverse skis. Payment must 1116 Waived by 8:00 p.m. WW time on Payment Due Dots. Sears caw Acoounl Number.01313 TON 0 Aoeeant Belml0/ 111 pile ?Mb*n iim Due's $3.103.20 02!03/08 I 5880 88 ? t Baebeed ? . , 008WT az oa II 00M 1 TIIOOa I= 001 7 a III/1111111111111/11111111111111/1111111111111{11111111111111 1111111111111111111111111111111111111111111/111111111111111111 Make check payable to MICHELLE CARROLL SEARS CREDIT CARDS 115 3RD ST PO BOX 183081 NEW CUMBERLAND PA 17070-2107 COLUMBUS, OH 43218-0081 Plem make address cwnp a on reveal" aide. EXHIBIT call hu a11-M0A17-Trill) GO to VA" esa{saerd aan Write to us at PO Boot Sates 31ma FeM 8D 8711744 Sears Cards ul us at i-N&MT-TM Go to www.aaa OM&OW Write to Us at PO &a: OW SIOUX Pak SD ST1174W MICHELLE CARROLL Aocount Number: XXXX XXXX)D= 0513 P malt Dee Dab Paps 2 of 2 020M 30447 » Averepa Ow mom inY Periodic Rots Rafts -Roo Vanso adence Balance TAGE RATE U.Morm SEARS REGULAR $3,105.20 $3.047.47 20AW EXTERNAL .0539%(D)» :58.21 REGULAR $0.00 $0.00 20.40%• .0559%(D)• $0.00 CASH ACCESS REGULAR $0.00 $0.00 21.40%• OW7%(D)• $0.00 Days In Billing Period: 33 Ef conic ANNUAL PERCENTAGE RATE: 20.40% Mlnlmwn FINANCE CNARGE: $0.00 Cardiviefter News The *EfNotiw ANNUAL PERCENTAGE RATE" includes all transaction and periodic ?bans dnagss imposed this billing period on so balances on which finllnoe dwyes were imposed. If the 'E1Nclive ANNUAL PERCENTAGE RATE' Is WA, no fkmnos charges (after adjuelmeMs) vw o imposed this bNrq pwW. Fkwros dwgn may be acauing an promotional balanoss owl may be billed to your socoW under the terms of the promotional aft. Refer to tit oorreepondi ng APR for the APR that aMes to each balance. The Sells Date Is the Transaction Dais. V Verification Lisa BOW 1, 1 , 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. Signature C-22749 Michelle Carroll Account number ending in 0513 1031 Lo- oF4%Q;sm 2009 OCT 26 PM 2: 26 af, rIS • JO PD A7TY Cl('# to 14171 pl* a3asgq SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?4«?,tr of ?itthbrr???4 nr ,r ..i r X1.17.. r T -)TAgY 2069 ! - S PM 2: i 2 Culp" , Citibank (South Dakota) N.A. vs. Michelle Carroll Case Number 2009-7361 SHERIFF'S RETURN OF SERVICE 11/03/2009 08:24 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2009 at 2024 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michelle Carroll, by making known unto herself personally, at 115 3rd Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 November 04, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF LSherifCountySuite Sheriff. Teieosoft Inc.