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Home My WebLink About09-7797 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 SARAH NAVARRO : NO. ( - T14? CIV i l (ef"A4 645 W 1st Street, Boiling Springs PA 17007-9554 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-29425 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01- '7797 etL J T? SARAH NAVARRO 645 W 1 st Street, Boiling Springs PA 17007-9554 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 Sarah Navarro, who resides at 645 W 1st Street, Boiling Springs, 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 5924 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. L 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $2,198.29 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 $2,198.29, and the costs of this action. Burton Neil & Associ es, P.C. By: Edward J. O' en, squire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Premier Card® SARAH NAVARRO Account Number: 41§illliM? 5924 Page 1 of 2 Your Account Summa Billing Cycle Closing Date 07/29109 Amount Over Credit Line $0.00 Amount Past Due $186.00 Total Minimum Due $289.58 Previous Balance $2,116.71 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $46.58 Account Balance $2,198.29 Your Credit Summary Total Credit Line $2,750.00 Total Credit Available $0.00 Call us at 1-800-917-7700 Go to www.meameard.com Write to us at PO Box 8283 Sioux Fells, SD 57117-6283 Payment Due Date 08/26/09 Your past due amount may be a number. But you're definitely not. Call 1-866-518-9054 today. And we'll help you with a payment solution. You're our customer. We value our relationship with you. So let us help you take care of your past due amount and avoid future late fees. We'll look at your account on an individual basis and work with you to come up with a payment solution for your unique situation. Call us and you'll find someone who's ready to listen and who can help you got back on your feet. Activity Sale Date Poet Date Description Amount 07/24/09 07/24/09 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,116.71, 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 Premier Card® Account Number: 924 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $2,198.29 08/26/09 $289.58 0066649 ED 19 A 09210 1 TRS006 FXG 001 7 N IIIIIIIIIIIIllll111111111I111111I111111111I I11111111IIIIIIIIII IIIIIIIIIIIIIIII IIIIIIIIIII III11111111111111111111111111111111 Make check payable to SARAH NAVARRO SEARS CREDIT CARDS 645 W 1ST ST PO BOX 183081 BOILING SPRINGS PA 17007-9554 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. EXHIBITN A. Rates *Rate Varies Sears Premier Card° SARAH NAVARRO Account Number: XXXX XXXX XXXX 5924 Page 2 of 2 66649 Call us at 1400-917-7700 Go to www.seamoard.com Write to us at PO Box 6283 Sioux Falls, SD 57117-6283 Payment Due Date 08!26!09 Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $2,198.29 $2,145.51 23.99%* 0658%(D)* $46• EXTERNAL REGULAR $0.00 $0.00 23.99°k* 0658%(D)* $0.00 CASH ACCESS $0.00 REGULAR $0.00 $0.00 24.99°k* 0685%(D)* Days in Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 23.99% Minimum FINANCE CHARGE: $0.00 d?-..l.r. har Wawa 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 1, Mena Reynolds , 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-29425 Sarah Navarro Account number ending in 5924 1031 RLED-,?-;` -IE 07 TH!7 20,09 NOV 10 hil-I 0: 3 5 i ?;a .*I%.So At ArT CL:'* lpaoc? Q- TI, a s-usg 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 ALED-OF !CE OF THE MOTH.C' NOTARY Citibank (South Dakota) N.A. vs. Sarah Navarro 2009 NOV 19 PH 12: 59 PENNSYLVANIA Case Number 2009-7797 SHERIFF'S RETURN OF SERVICE 11/17/2009 04:10 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Novembei 17, 2009 at 1610 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sarah Navarro, by making known unto herself personally, at 645 W. First Street Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 November 18, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 7 Deputy Sheriff !ci Coun`ySuite Sheriff. ieieosoft. Ina