HomeMy WebLinkAbout10-0832
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2010 FEB -2 r;' 1:5
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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.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
BETH A SHENK : NO. 10 - 8301 IV; 1 1em
1856 Walnut Bottom Road, Carlisle PA 170157672
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 4qa,oc> pp ATr/
Carlisle, PA 17013 CO (A a 103
TelepholleNo. 717-249-3166 or 800-990-9108 p..-I' a3708G
C-31685
Burton Neil & Associates, P.C.
B • Yale D Weinstein Esquire ID. NO. 89678
.7 ,
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.
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1p . $ 3 O- c Y
BETH A SHENK
1856 Walnut Bottom Road, Carlisle PA 17015
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 Beth A Shenk, who resides at 1856 Walnut Bottom Road, Carlisle,
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 6564 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.
I -
8. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $26,213.51 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 $26,213.51, and
the costs of this action.
Burton No" ociates, P.C.
'dale D. Weinstein, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a d6bt collector.
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Total Now Balance:
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Minimum Amount Due: d
Payment Due Data.
10iADVA100f ?n?.?iwi?n ewwa 0.PM
000000 PW 32 A 0
BETH A SHENK
1856 WALNUT BOTTOM RD CITI CARDS
CARLISLE PA 17 015-7 67 2 P.O. BOX 162564
COLUMBUS, OH43218-2564
EXHIBIT A--
Verification
I JENNIFER SHEPHERD , 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 unworn falsification to authorities.
Si e
C-31685
Beth A Shenk
Account number ending in 6564
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff FILED r"iCE
Ot 441jr1tJ(y??TJtT!-?,?. "":"fltil":i
Jody S Smith o
Chief Deputy P10 FFQ 16 PM 2: 14
Edward L Schorpp
Solicitor
' i "N531'
E
Citibank (South Dakota) N.A.
vs.
Beth A. Shenk
Case Number
2010-832
SHERIFF'S RETURN OF SERVICE
02/08/2010 05:30 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on February
8, 2010 at 1730 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Beth A. Shenk, by making known unto herself personally, at 1856 Walnut Bottom Road,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $33.40
February 09, 2010
SO A E
N Y R ANDERSON, SHERIFF
By ?..
Deputy Sheri
C1,10" . _..If T c ;f.lrc.