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Home My WebLink About09-7884 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINA L RITTEL NO. ()q - r1$$ 4 a-wa-Tern 9 Pamela Place, Mechanicsburg PA 17050-1773 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-23833 Complaint 1. Plaintiff is Citibank (South Dakota), N.A., with place of business located at 701 East 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 NO. 0q- '1 PPY CHRISTINA L RITTEL 9 Pamela Place, Mechanicsburg PA 17050-1773 Defendant CIVIL ACTION - LAW 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Christina L Rittel, who resides at 9 Pamela Place, 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 credit card with account number ending in 3557 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 $3,937.07 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 $3,937.07, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. t ? 12/05/08 $3937.07 $3937.07 SITE:KC-CL TM:CO-5000 ACID:KCB3104 =?t '•:=3 =:#k#3 05/15/09 21:55:28: CITI CARDS PO BOX 183051 CHRISTINA L RITTEL COLUMBUS, OH 9 PAMELA PL 43218-3051 MECHANICSBURG PA 17050-1773000 Citi' Dividend Platinum Select" Card t?* Account Number 3557 Customer Servkc 1-800-756-4000 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $3260 $0 $1000 $0 $3937.07 BOX 6500 Statement/ Amount Over Purch/Adv Minimum SIOUX FALLS, SO Closln Data 2 Credit Line $ Past Due $ t?Inimum Due 66 7 Amount Due $3937 OT 08 57117 11/12/ w,w.wwww Y .\w. 67T. OT w-u c,www 1 ooh 826.1T Ch w,w ?wwi . 2 11 . •.ww.. wh .Y1 J Standard Purch 11112 LATE FEE - OCT PAYMENT PAST DUE 39.00 66 0000 0000000000 11112 PURCHASES*FINANCE CHARGE*PERIODIC RATE 88.72 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (11/06/08), which was $3,809.35. Help is available! Please call the toll-free number shown above 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. Our records show home phone 717-691-0155 and business phone 000-000-0000. Please update coupon if incorrect. EXHIBIT A- Account Summary Previous Balance +) Purchases (- Payments & Advances & Credits + FINANCE CHARGE (z) Now Balance PURCHASES $3,809.35 $39.00 0.00 $ 8.72 $3,9 7.07 CES 0.00 0 0.00 0.00 3 1 1 0.0 3 TOTAL $3,8 9 .35 $ 9.00 0.00 $88.72 $3,9 7.07 Days This Billing Period: 29 Rate Summary Balance Subject t o Periodic Nominal ANNUAL Finance Charge Rate APR PER CENTAGE RATE PURCHASES Standard Purch $3,852.01 0.07942%(D) 28.990% 28.990% ADVANCES Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Verification 1, Mark Molinari , 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-23833 Christina L Rittel Account number ending in 3557 1000 (aN k?zv WILEL-ov c JF THE -? , , J?,;qY 2009 NOV 12 Phi 3: 03 VLrt f ? . ,.ij`v ? ?. 419.50 pu AIW elf` 4030(P? M*x.33431 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 0 0'? J' o1 4?utifir?????? OFFI,` , t Ts -uvRIFF FILED- OFFiCE OF THE FR3T!-'0N0TARy 2009 NOV 19 PM 12*. 58 CUIf6 =i,NTY PEN INSYLVAMA Citibank (South Dakota) N.A. I Case Number vs. 2009-7884 Christina L. Rittel SHERIFF'S RETURN OF SERVICE 11/18/2009 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: Christina L. Rittel, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Christina L. Rittel. Barry Rittel advised Deputies Christina L. Rittel is currently residing in Pittsburgh, PA and her mail is still received at 9 Pamela Place Mechanicsburg, PA 17050. SHERIFF COST: $42.00 November 18, 2009 SO ANSWERS, P e r R THOMAS KLINE, SHERIFF (.r. noun?ySuac SN,01, 1 eioosoPt. ii`. 0F THE PROTHONOTARY zof 1 APR -8 Are 11: 00 CUMBERLAND COUNTY PENNSYLVANIA 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. CHRISTINA L RITTEL Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-7884 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associat By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-23833