HomeMy WebLinkAbout10-11920?/
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2M FEB 22 rk "11'`52
v
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. : IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NICKI SIMMONS : NO. Vi
(
125 Herman Avenue, Lemoyne PA 170431936
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-31476
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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. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NICKI SIMMONS . NO G d `l oZ G N 'f o f
125 Herman Avenue, Lemoyne PA 1 7043 1 93 6
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 Nicki Simmons, who resides at 125 Herman Avenue, Lemoyne,
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) AT&T
Universal credit card with account number ending in 4896 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 $3,833.94 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 $3,833.94, and
the costs of this action.
B
B
The law firm of Burton Neil & Associates, P.C. is a de
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Total New Balance:
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Minimum Amount Duo:
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Payment Duo Date.
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NICKI SIMMONS
125 HERMAN AVE AT&T UNIVERSAL CARD
LEMOYNE PA 17043-1936 P.O. BOX 182564
COLUMBUS, OH 4321a-2564
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Verification
I Abbie Motley
,
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-31476
Nicki Simmons
Account number ending in 4896
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff f~ ~,.f~~~~~-
4vti~~t+~ oC' ~ uia b,~~,~~~~~
Jody S Smith
Chief Deputy ZO t ~ MAR -3 AM 9i b 3
Edward L Schorpp
Solicitor ~ ,~ ~ -. ~ ;~=~~~~ ~~~;~ -N~Y
I'~ilv'3YI„VAMi~
Citibank (South Dakota) N.A.
vs.
Nicki Simmons
Case Number
2010-1192
SHERIFF'S RETURN OF SERVICE
02/25/2010 06:00 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February
25, 2010 at 1800 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Nicki Simmons, by making known unto herself personally, at 125 Herman Avenue,
Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $42.40 SO ANSW S,
n+-`.~
February 26, 2010 RON Y ANDERSON, SHERIFF
Deputy Shariff
!c Countyg,~it~; Sh¢:rrt, ie~e~=efi. inc.
rF THE P"~1': ~nN~ iARY
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
Plaintiff
v.
NICKI SIMMONS
Defendant
ZOIO~if°f~ -5 ~~i !~ ~~
CU'~~:~ ~ ~ ~~aEd;l'
r'cl`~~ ~ a ~`L~t. `~ ~'~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-1192 CNIL TERM
CIVIL, ACTION -LAW
Praecipe to Discontinue
To the Prothonotary:
Kindly discontinue the above-captioned action
s, P.C.
By:
D. Weinstein, Esquire
nev for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-31476