HomeMy WebLinkAbout10-1191I/
2C 10 FEB 22 AN 11: 52
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.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JAMIE L KREISER : NO. 10 - l lq i 1 Term
10 W Scenic Drive, Carlisle PA 170159523
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
C-31225 Telephone No. 717-249-3166 or 800-990-9108 0
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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. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAMIE L KREISER
10 W Scenic Drive, Carlisle PA 170159523
Defendant
NO. 'D - )I cI I
: CIVIL ACTION - LAW
Complaint
C ?u .
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 Jamie L Kreiser, who resides at 10 W Scenic Drive, 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 7624 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.
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8. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $4,377.73 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 $4,377.73, and
the costs of this action.
P.C.
By:
Blasker, Esquire
for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Total New Balance:
$4,377.73
Minimum Amount Due:
$4.377.73
Payment Due Date:
10/19/2009
000000 VI 32 A 0
JAMIE L KREISER
10 W SCENIC DR
CARLISLE PA 17015-9523
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-- OVUM and follow Payment uMtructlNN en.....
Make check Nvdk te:CEtl Cards
Act: t Number.
7624
Amount Enclosed:
PaYmeat mutt be fecelved kY 5:00 PM
local law on tM PaYmeM due doe.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH43218-2564
EXHIBIT A
Verification
Leola Phei iix
1, , 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.
AX
Si ture
C-31225
Jamie L Kreiser
Account number ending in 7624
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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OFFICE C?'F Tt S-ERIFF
EiLED-C=':EwE
??? THE P?tuTP-Cl! MARS
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
2010 MAR -E PM 12*. 5, 4
Cain j N l y
Citibank (South Dakota) N.A. I
vs.
Jamie L. Kreiser
Case Number
2010-1191
SHERIFF'S RETURN OF SERVICE
02/23/2010 08:56 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 23
2010 at 2056 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jamie L. Kreiser, by making known unto herself personally, at 10 W. Scenic Drive,
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 SO ANSWE
February 25, 2010 RONN ANDERSON, SHERIFF
BY ?
Depu Sheri
;c; C.CwitySUle Sheoff_ Teieosof't h,-.