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Home My WebLink About09-8135w 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. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OR - !B13.5 0,tv i Clirm : 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. CATHY L BARTOO 6025 Hummingbird Drive Mechanicsburg PA 17050-2048 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-21577 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 9_ ? 3 S? vJ • ? ? tvw. CATHY L BARTOO No. 6 6025 Hummingbird Drive Mechanicsburg PA 17050-2048 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 Cathy L Bartoo, who resides at 6025 Hummingbird 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 6562 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 $5,343.07 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 $5,343.07, and the costs of this action. Burton Neil & ates, P.C. By: E ward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Cards' Call us at 14800-917-7700 Go to www.seameard.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 CATHY L BARTOO Account Number: 40011IW56 2 Payment Due Date Page 1 of 2 02/09/09 Your Account Summa Billing Cycle Closing Date 01/12/09 Amount Over Credit Line $3,823.07 Amount Past Due $1,182.65 Total Minimum Due $1,392.27 Previous Balance $5,187.45 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $120.62 Account Balance $5,343.07 Your Credit Summary Total Credit Line $1,520.00 Total Credit Available $0.00 Activity Sale Date Post Date Description Amount 01/07/09 01/07/09 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $5,187.45, 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. C Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Cards' Account Number: 41001@W 2 Payment Total Account Balance Due Date Minimum Due L $5,343.07 02/09/09 $1,392.27 0000000 EX 07 09012 1 TIVION FXO 001 7 tt IIIIIIIIIIIII111 111111111111111 IIIII 11111111111 1 CATHY L BARTOO 6025 HUMMINGBIRD DR MECHANICSBURG PA 17050-2048 Please make address changes on reverse side. Amount Enclosed IIIIIIII 1111111 IIIIIIIIIIIIIII IIIIIIIII1111II IIIIIIIIII111 Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 EXHIBIT 200 5049941110817480 0534307 0139227 0000000 0716 Sears Card' Call us at 1-800-917-7700 Go to www.seemeard.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 CATHY L BARTOO Account Number: XX XX7?(X 6562 Payment Due Date Page 2 of 2 02/09/09 a Average Corresponding Periodic Rate Periodic Deity ANNUAL D=Day FINANCE Rates 'Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $5,343.07 $5,252.00 25.40%* .0696%(D)* $120.62 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: 33 Effective ANNUAL PERCENTAGE RATE: 25.40% Minimum FINANCE CHARGE: $0.01] Cardmember News Please see the enclosed privacy notice for important information. 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. V # Verification h USa Blumer , 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 Signature C-21577 Cathy L Bartoo Account number ending in 6562 1031 p RLED-01FrRCE OF THE PPP r uC,, 0TAPY 2009 NOY 23 PH 1: 51 C L) 4 rM. 5o PA ATM GL? lo3l?S $34oco ~~tw.~.~-~l~Fl~~ 1.01 QrT -~ Pik 3~ 1 ~~~}~BERZ~1~~ C~UP~T~ Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. CATHY L BARTOO Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.09-8135 CNIL TERM CNIL ACTION -LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without & A~~okiates. P.C. . Vl~sf in, Esquire w for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-21577