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Burton Neil & Associates, P.C.
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.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
DONNA M HANNALLAH
448 Brook Circle, Mechanicsburg PA 170504617
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Io -'1'78 (2-lvi l (arm
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 O
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
C-31327 $ga.op p4 Arn/
ft-# 6935q
P--T# a37 05?
Burton Neil & Associates, P.C.
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.
701 East 60th Street N
Sioux Falls, SD 57117
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
DONNA M HANNALLAH NO.
448 Brook Circle,
Mechanicsburg PA 170504617
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 Donna M Hannallah, who resides at 448 Brook Circle, 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 5818 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 $1,797.98 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 $1,797.98, and
the costs of this action.
Burton
By:
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Total New Balance:
$+.79a.99
M1n4num Amount Due:
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$1.797.99 «
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Payment Due Date:
10/0912009 ?wrape nr,pt r. nc.pne w sm PM
000000 MC 32 A 0 ix.i ern. en (hp rprn.M aw erp
DONNA M HANNALLAH
448 BROOK CIR
MECHANICSBURGPA 1 7 050-4 617 CITI CARDS
P.O. BOX 182564
COLUMBUS, OH 43218-2564
EXHIBIT A
Verification
I, Mary E. Crum
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.
C-31327
Donna M Hannallah
Account number ending in 5818
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
?y%vIV of 4unttyc
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OFF c Tr
F LEA J,-" riU
2010 FEB 16 PH 2: ; 2
Citibank (South Dakota) N.A.
vs. Case Number
Donna M. Hannallah 2010-778
SHERIFF'S RETURN OF SERVICE
02/05/2010 02:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February
5, 2010 at 1420 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Donna M. Hannallah, by making known unto herself personally, at 448 Brook Circle,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
her personally the said true and correct copy of the same.
SHERIFF COST: $37.00
February 09, 2010
SO ANSWERS,
O Y R ANDERSON, SHERIFF
Bh ;;Ci Coun*S?.?ite S.^:.F;rr:. t. TEat?-so`t. In.r.