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Home My WebLink About09-8819Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NORMA J MARDIS NO. 69 12 W Winding Hill Road 1 Mechanicsburg Pa 17055-5172 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-19491 Burton Neil & Associates, P. C. By: Burton Neil, Esquire ID. NO. 11348 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. NORMA J MARDIS 12 W Winding Hill Road Mechanicsburg Pa 17055-5172 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- ?-?/ q G N- ( --ecx 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 Norma J Mardis, who resides at 12 W Winding Hill Road, 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 6219 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 $9,860.50 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 $9,860.50, and the costs of this action. i Burton Neil & A ociates, P.C. 'By: B eil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Gold MasterCard' NORMA J MARDIS Account Number: ININFAIMMM 6219 Page 1 of 1 Your Account Summa Billing Cycle Closing Date 11/06/07 Amount Over Credit Line $1,800.50 Amount Past Due $2,125.12 Current Minimum Due $380.71 Total Minimum Due $4,306.33 Previous Balance $9,578.79 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $242.71 Account Balance $9,860.50 Your Credit Summa Total Credit Line $8,060.00 Available Credit Line $0.00 Cash Access Line $1,612.00 Available Cash $0.00 CI Ic'?q\ Activity Sale Date Post Date Description Amount 11/05/07 11/05/07 LATE PAYMENT FEE YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. 39.00 Average Corresponding Periodic Rate Periodic Rates 'Rate Varies Balance Daily Balance ANNUAL D=Day PERCENTAGE RATE M=Month FINANCE CHAR E SEARS REGULAR $460.27 $418.48 31.49%" .0863%(D)i $10.48 EXTERNAL REGULAR $7,480.79 $7,384.81 31.49%' .0863%(D)" $184.81 CASH ACCESS REGULAR $1,919.44 $1,894.81 31.49%" .0863%(D)" $47.42 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 31.49% Minimum FINANCE CHARGE: $0.00 Sears Gold MasterCard' Account Number: X6219 Payment Total Account Balance Due Date Minimum Due Amount Enclosed -1 ( $9,860.50 12/04/07 7( $4,306.33 $ 0008411 EX 04 A 07310 1 TX8803 FYO 001 7 N IIIIIIIIIIIIIIIIIIIIIIII VIII It IIIIII111IIIIIIIIIIIIIIIII VIII NORMA J MARDIS 12 W WINDING HILL RD MECHANICSBURG PA 17055-5172 Please make address corrections above. IIIIIIIIIIIIIIIIIIIIIIII ]IIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIIII Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 100 219 0986050 0430633 0000000 0414 EXHIBIT Call us at 1-800-669-8488 Go to www.searecard.com Write to us at PO Box 6922 The Lakes, NV 88901-6922 Payment Due Date 12/04/07 Verification I, Ln BIUMW , 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 unswom falsification to authorities. , -\' '3 V:?PL.' &" ".,a Signature C-19491 Norma J Mardis Account number ending in 6219 1032 09, fnu 09 CE:" C'3 PJ1 { 44 L I $ 4?.oa 7cL /?/ti(, CIX-41 `7/81 ?2?- aasy?? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Citibank (South Dakota) N.A. vs. Norma J. Mardis FILED-+YPCE ? ?ttr G( c: ra??f_?rr! F- rr,, 2010 JAIL i I AID 8: 10 =ze - CE.a1," t v-IJN 1 1 PEI,: N 3t LVA11 !,,A Case Number 2009-8819 SHERIFF'S RETURN OF SERVICE 01/04/2010 11:45 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on January 4, 2010 at 1145 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Norma J. Mardis, by making known unto herself personally, at 12 W. Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 06, 2010 SO ANSWERS, FY R ANDERSON, SHERIFF BYE°-""_'- ?? Depot Sheriff r #iE PRO 'HAO' AR 2013 SEP 16 PM 1: 12 t UMURLANQ cOUNTY PENNSYLVANIA 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-8819 NORMA J MARDIS Defendant : CIVIL ACTION - LAW Statement of Intention to Proceed To the Court: Plaintiff, CITIBANK(SOUTH DAKOTA),N.A., intends to proceed with the above captioned matter. BURT NE ASSOCIATES, P.C. Date: j �� By: Edward J. O'Brien, Esquire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. C-19491 C-19491 /314 c X w CZ Ci- 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-8819 NORMA J MARDIS Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burt on eil & Assoc' tes, P.C. By: E6X0011 e , Esquire Attorney f 1 ' tiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector.