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Home My WebLink About09-8193Burton Neil & Associates, P.C. By: Robert J. Kane, Esquire ID. NO. 209794 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. CATHY ANN MOTEN 104 South 27th Street, Camp Hill PA 17011-4502 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 6Q- st43 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-25133 Burton Neil & Associates, P.C. By: Robert J. Kane, Esquire ID. NO. 209794 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. O9 . ? 15 3 Ct tl-.e rl - CATHY ANN MOTEN 104 South 27th Street, Camp Hill PA 17011-4502 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 Ann Moten, who resides at 104 South 27th Street, Camp Hill, 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 4100 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 $3,580.65 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 $3,580.65, and the costs of this action. Burton Neil & Associates, P.C. By: Rob rt . Kane, Esquire Atto y for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Card' CATHY ANN MOT Account Number 4100 Page 1 of 2 Your Account Summary Billing Cycle Closing Date 03/20/09 Amount Over Credit Line $0.00 Amount Past Due $805.28 Total Minimum Due $977.51 Previous Balance $4,473.82 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $91.23 Account Balance $4,600.05 Your Credit Summary Total Credit Line $4,670.00 Total Credit Available $0.00 Call us at 1-800-917-7700 Go to www.seemeard.com Write to us at PO Box 6283 Sioux Falls, SD 67117-6283 Payment Due Date 04/17/09 Wish you could put your past due bill behind you? Your tax refund can help make it happen. Many customers have resolved overdue amounts by using their tax refund money. It's simple and convenient. If you're not expecting a refund, we may have payment options available. Call today, and together, we'll come up with a solution that is right for you. So it's important for you to visit us at www.searscard.com to login or register, or call 1-866-518-9050 today. Activity Sale Date Poet Date Description Amount 03/19/09 03/19/09 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $4,473.82, 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: - 4100 Payment Total Account Balance Due Date Minimum Due Amount Enclosed -] ( $4,600.05 04/17/09 $977.51 0019465 ED 14 A 09079 1 TRS006 FXG 001 7 N I IIIII IIIIIIIIII 111111 IIIII II IIIIIIIIII IIIIIIIIII IIIII IIIIIIII CATHY ANN MOTEN 104 S 27TH ST CAMP HILL PA 17011-4502 Please make address changes on reverse side. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 35.00 J? , Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 EXHIBIT, 200 4100 0460005 0097751 0000000 1414 " Sears Card CATHY ANN MOTEN Account Number: XXXX XXXX XXXX 4100 Page 2 of 2 19465 Call us at 1-800-917-7700 Go to www.searecard.com Write to us at PO Box 6283 Sian[ Fells, SD 57117-6283 Payment Due Date 04/17/09 Average Corresponding Pori odic Rate Pori odic Deily ANNUAL D--Day FINANCE Rates *Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $4,600.05 $4,520.09 25.40%* .0696%(D)* $91.23 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 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. ' or Signature C-25133 Cathy Ann Moten Account number ending in 4100 1031 p RLF" 117 ?RY ?~. . 2009 NOY 25 P!'112? 9 15 .. Li . $,I8. so Pts ATrj ei(-.* to 4 S7 03 PT's .754 140 ILED-OFFICE %I= THEI PROTHONOTARY 2911 MAR -4 AM 11: 11 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. CATHY ANN MOTEN Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8193 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Assoc'a , P.C. By: Neil Sarker, squire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-25133