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Home My WebLink About09-8442Burton 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. SHARON MAGRUDER 2180 Canterbury Drive Mechanicsburg Pa 170555767 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. cA - 8g4a 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-28705 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 V. SHARON MAGRUDER 2180 Canterbury Drive Mechanicsburg Pa 170555767 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Defendant : CIVIL ACTION - LAW Complaint 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 Sharon Magruder, who resides at 2180 Canterbury 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 credit card with account number ending in 2660 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 $2,853.07 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 $2,853.07, and the costs of this action. Burton Neil & Associates, P.C. By: 4?z 1? z", Rob Ve Kane, Esquire Atto for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 06/26/09 $2853.07 $2853.07 ......................... ........................ ....................... SHARON MAGRUDER 2180 CANTERBURY DR MECHANICSBURG 17055-5767000 Choice* 4 CHOICE° 2660 Customer Servke: 1-800-568-5000 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $2280 $0 $1500 $0 $2853.07 BOX 6248 SIOUX FALLS, SD Statement/ Closin Date ( Amount Over Credit Line Past Duo Purch/Adv I? Inimum Due Minimum Amount Due 57117 06/03/2 09 $573.07 $511.41 1135.49 $2853.07 6/03 LATEdFEE - MAY PAYMENT PAST DUE 39.00 66 0000 0 70000000000 6/03 PURCHASES*FINANCE CHARGE*PERIODIC RATE 14.29 84 0000 0 70000000000 6/03 PURCHASES*FINANCE CHARGE*PERIODIC RATE 54.20 84 0000 0 70000000000 Your late fee was based on your account balance as of the payment due date (05/28/09), which was $2,745.58. 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 717-620-8952 and business phone 717-697-7295. If incorrect, please update your account online at www.citicards.com or call us at 1-800-568-5000 to let us know. Contact us today: we can help! Go online at www.paymentsolutions.citicaras.com to login or register. E X H I B I T A „_,,,. _... _. __ Account Summary Previous Balance +) Purchases - Payments & Advances & Credits (+) MNANCE CHARGE =) New Balance PURCHASES $2,745.58 $39.00 0.00 $68.49 $2,853.07 ADVANCES $0.00 $0.00 0.00 $0.00 $0.00 TOTAL $2,745.58 $39.00 50.00 $68.49 $2,853.07 Days This Billing Period: 30 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charg e Rate APR PE RCENTAGE RATE PURCHASES Standard Purch $579.73 0.08216%(D) 29.990% 29.990% Purch/Adv thru 07/03/2007 $2,198.81 0.08216%(D) 29.990% 29.990% ADVANCES Standard Adv $0.00 0.08216%(D) 29.990% 29.990% PA SITE:KC-CL TM:GJ-5000 ACID:KCB0219 08/27/09 22:52:07: CHOICE VISA PO BOX 183051 COLUMBUS, OH 43218-3051 Verification I Leda Phenix 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. d Signature C-28705 Sharon Magruder Account number ending in 2660 1000 0 Or THE THOWTAAY 9 DEC -1 PM 3-' 23 *78.50 Po AYTy Cr-`p tosssg W 013q (039' rna ) - ? r J - C ? (T x 3 : C-- 2t Burton Neil &Associates, P.C. --' N 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 Z r,. OF OC3? C:) J ) ??ry Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-8442 CIVIL TERM SHARON MAGRUDER Defendant : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Di Burton By: The law firm of Burton Neil & Associates is a debt collector. Associates, P.C. Blasker, Esquire for Plaintiff C-28705 / 318