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Home My WebLink About10-1155 2010 FEB 18 PH 2: 29 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. SUSAN STICKELL 4106 Caissons Court, Enola PA 17025-1481 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 1155 0,-%V; leV"'M : 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-31687 iJ $ga.00 p6 A-%T^lt &-* (o8(olV5 04 a3'717M as 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. SUSAN STICKELL 4106 Caissons Court, Enola PA 17025-1481 Defendant NO. /0r/ / S-? ev l +C"- 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 Susan Stickell, who resides at 4106 Caissons Court, Enola, 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 4211 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 $9,187.73 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plair-demands judgment against defendant for the sum of $9,187.73, and the costs of this action. Burton Neil & Associates, P.C. By: Z/7? Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ?* M a IG 1A J O ? L ? O E?oxJ N u `^ 1? X C ?1 1 ? Vm?1li 0. N M A, N WYWYJ 1?q H P N N L N • t 0 g c u M I ON IL U g 0 ` J y o to .0 CO I 40 OZ / -- Z N o 4 ?4ft A,te FaW amount Pii] Total New Balance: $%W7.73 Minimum Amount Due: $96UT.73 Payment Due Date: 000000 PW 32 A 0 SUSAN STICXELL 4106 CAISSONS COURT ENOLA PA 17025-1481 A A M o r . O _ ; ., d C W ? O O O M O < i M N M N i< r c o o y O O O yo c o o .?. o p O P O P C M M w7 a o° ? P P N p 4 C ut A ? C O Oy j02; q CLL. N O E a0 d P M C?O at ? G toy s °Z^" ? N r!! ,Ua u N yNN N C R dsd a na O YY C E '-° E l . y3O V # O O O ~ 0 0 ~ N GD H V VI >> ? du '"u° ct ..K cn o„ y$ 0? d ?a+N C O\ u4° e r c o a v ?W O`N ar U .5'To °oc e E ? s a? c ???? , ar dmri E"Ea ' . ' 4 ? g O ' d' Q Iwo U 3 Q q q ON y a. ?C?tt ? F u?i•C :tw k • eatwe MW hlbw gaWAW erlnal m on aearo MMaaeww"suCHI Cards ?? (? S 1 211 ,erwnMwaW ko PM eul fr,M m h» nvmaee ew "a. CITI CARDS P.O. BOX 182564 COLUMBUS, ON43218-2564 EXHIBIT/ '? Verification Mary E. Crum I, , 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. I \'? Signature C-31687 Susan Stickell Account number ending in 4211 1000 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. Susan Stickell ~c TcFl1 c[~ ~{~ •~ ~t,,, of ~itirr6rrf ~.1T" tf{~L1'I~~~vll 2~ 10 MAR -3 AM 9s 4 ~ y , i'. ANtA Case Number 2010-1155 SHERIFF'S RETURN OF SERVICE 02/25/2010 08:10 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 2010 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Susan Stickell, by making known unto herself personally, at 4106 Caissons Court, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, - February 26, 2010 RO ~ ANDERSON, SHERIFF r Deputy S ariff c; Cetir.~Suite S.rer,K. ie~rsofl. lix;.