The URL can be used to link to this page

Home My WebLink About10-1193 r ?r r I?t 1HE 2010 FEB 22 A 11 15 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. YOLANDA GARLINGER 237 N 2nd Street, Wormleysburg PA 170431102 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 1193 CWtiTr*. 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-31871 #ga.00 pa ATt`4 Q?t 7fl339 R-?` d3'T 851 Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 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. : NO. 16 -- 1113 -C iv?' 1 YOLANDA GARLINGER 237 N 2nd Street, Wormleysburg PA 170431102 Defendant CIVIL ACTION - LAW 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Yolanda Garlinger, who resides at 237 N 2nd Street, Wormleysburg, 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 3785 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 $1,469.96 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 $1,469.96, and the costs of this action. The law firm of Burton Neil & Associates, P.C. is a 09/16/09 $1469.96 $1469.96 SITE:KC-CL TM:CO-5000 ACID:IRB4980 12/24/09 19:27:01: CITI CARDS PO BOX 183051 YOLANDA GARLINGER COLUMBUS, OH 237 N 2ND 43218-3051 WORMLEYSBURG PA 17043-1102000 l 1 l .? t?0 C Citi Card 3785 Customer Servke• i i ble Cash Limit il A New Balance 1-800-568-5000 Total Credit Line m t Available Credit Line Cash Advance L $2500 va a $0 $1469.96 $4300 $0 BOX 6500 SIOUX FALLS, SD Statement/ Closin Date /2809 Amount Over 4redlt Line Past Due 62 00 $147 10 Purch/Adv MI imam Due 136.67 Minimum Amount Due $1469.96 57117 08/20 . . Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 39.00 8/20 L 66 0000 0 ATE FEE - JUL PAYMENT PAST DUE 70000000000 8/20 PURCHASES*FINANCE CHARGE*PERIODIC RATE 31.67 84 0000 0 70000000000 Your late fee was based on your account balance as of the payment due date (08/14/09), which was $1,399.29. Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Contact us today we can help! Go online at www.paymentsolutions.citicards.com to login or register. d Account Summary ew PURCHASES $1,399.29 $39.00 0.00 $J1.67 $1,469.96 ADVANCES $0.00 $0.00 0.00 0.00 $0.00 TOTAL $1,399.29 $39.00 10.00 $31.67 $1,469.96 Days This Billing Period: 30 iodic Nom i? ANNUAL Rate Summary Balance-Subject to er Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $1,414.54 0.07463%(D) 27.240% 27.240% ADVANCES Standard Adv $0.00 0.07463%(D) 27.240% 27.240% M X L LJ Verification I, Abbie Maday , 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. Vr ///A- Signa'tAe C-31871 Yolanda Garlinger Account number ending in 3785 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson {~~ ~~. Sheriff , of ~"Artn4r . ~ ~~~ ~~~ 1 r~~1 Body s smith ~t0 MAR Chief Deputy 3 AM g. 4 ~ Edward L Schorpp < ~, ,,, Solicitor ~~flt~y~„tr/~~~N~' Citibank (South Dakota) N.A. vs. Yolanda Garlinger Case Number 2010-1193 SHERIFF'S RETURN OF SERVICE 02/25/2010 06:50 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1850 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Yolanda Garlinger, by making known unto herself personally, at 237 N. Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. ^.,f SHERIFF COST: $42.40 SO ANS February 26, 2010 RON ANDERSON, SHERIFF, , gY Deputy Sheriff r,i ~.tlr':tYJWIF 5.^,81"i'T. TE;IPGS~`:l. 11`G. E FELED-CEFiC~ ~)F ?Nc P,~~T3-;C~?~OTARY 2010 ~~€~ -4 PH 3~ 00 cu~~4~ ~E~..~ : youavTY P~:~tti~l~'~V~~~v~~i Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (6I0~96-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 701 East 60`~ Street N Sioux Falls, SD 57117 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. YOLANDA GARLINGER : NO. 10-1193 Civil Term . 237 N 2"d Street, Wormleysburg PA 170431102 Defendant :CIVIL ACTION -LAW • Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (61096-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 701 East 60a' Street N Sioux Falls, SD 57117 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. YOLANDA GARLINGER : NO. 10-1193 Civil Term 237 N 2"~ Street, Wormleysburg PA 170431102 Defendant :CIVIL ACTION -LAW Defense 1. I, Yolanda Garlinger, the defendant is requesting that the Plaintiff, CTTIBANK (SOUTH DAKOTA), N.A. accept my letter requesting a payment schedule to pay off this bill. I have sent a copy of this letter to the Plaintiff requesting the same. I am unemployed at this time and on a limited income. I would like to pay off this debt but cannot make one lump sum payment of $1200.00 as requested. I have been unemployed for almost a year now and have been struggling financially for that time. While I know this is not the Plaintiff s problem I would appreciate their cooperation in this matter. I would too like for communication be made in written form as this way both parties are aware of what is being asked and have record of such. Yolanda Garlinger, Defendant ~P~,~d~ C~ ,z,; ~ ~~3I 2010 I have also included their latest letter for reference. ~~ . LAW OFFICES Burton Neil ' $URTON NEIL & ASSOCIATES, P.C. Edward J. O Brien Yale D. Weinstein 1060 ANDREW DRIVE, SUITE 170 Derek C. Blasker WEST CHESTER, PENNSYLVANIA 19380 Brit 7. Sutteil 610-696-2120 Neil Sacker Facsimile 610-696-4111 Email: Burton.neil@burt-law.com Refer to File # February 18, 2010 C-31871 Yolanda Gazlinger 237 N 2nd Street Wormleysburg PA 1 7043 1 1 02 RE: Citibank South Dakota, NA Account with Yolanda Gazlinger Account number 4128003627193785 Deaz Ms. Gazlinger: Legal action is being filed against you. My client will accept the sum of $1,200.00 to settle. If you accept the offer, payment is to be made lump sum within two weeks from the date of this letter. The settlement check, made payable to Citibank South Dakota, NA, is to be sent to my office. If you wish to pay by phone, call my office to speak with an account representative who will assist you in making payment with a check by phone. If you wish to discuss the offer, please contact our office to speak with an account representative. Our toll free number is 866-696-2120. „ yours, Y In making this communication, we advise that our firm is a debt collector. f PR NO TA, ,r` Pl, 2. I C"'IBERLAND BTU 4' T PENtis YL1/A iOU 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 Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. YOLANDA GARLINGER NO. 10-1193 CIVIL TERM Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burt n ell & oc'ates, P.C. By. a D. Weinstein, Esquire A o3-ney'for Plaintiff This is an attempt to collect a debt, and any information obtained ill be used for that purpose. This communication is from a debt collector. C-31871 /318 1