HomeMy WebLinkAbout10-2159ALED--ti: F= '!E
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20{0 PEAR 29 FIM 2: L0
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.
Cti?r<I-_ _ w,4 r
1 ii'4?kJli'y?Ill?L ?r?1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTINE KHOURI NO. 10-(R157 C?V t ( l
?t'm
19 Fieldstone Drive, Mechanicsburg PA 170501726
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
C-28866
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
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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.
NO.
CHRISTINE KHOURI
19 Fieldstone Drive, Mechanicsburg PA 170501726
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 Christine Khouri, who resides at 19 Fieldstone Drive, Mechanicsburg,
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 1655 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 $5,717.84 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 $5,717.84, and
the costs of this action.
Burton NeadlMAssociates. P.C.
By:
DerC. Blasker, Esquire
Atto ey for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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Total New Balance:
$5.717.84
Minimum Amount Due:
$5.717.84
Payment Due Date:
07/31/2007
000000 MC 32 A 0
CHRISTINE KHOURI
19 FIELDSTONE DR
MECHANICSBURGPA 17050-1726
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MaFe eMeF WYatW te:C?t? Cards
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Account Number
655
Amoun nclosed:
Payment m t b. re aw" by 5:00 PM
laal tine on tae Payment due We.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH 43218-2564
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Verification
I, Mark Molinario , 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.
Signature
C-28866
Christine Khouri
Account number ending in 1655
1000
T E'ILED-OFFICE
1" T E PROTIH 0 NO 11 -A F.; y'
2,310 DEC 27 PM 3: 25
CUMBERLAND C1)ljvf°
PENNSYLVANIA,
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.
Plaintiff
V.
CHRISTINE KHOURI
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-2159 CIVIL TERM
CIVIL ACTION - LAW
Praecipe to Settle, End, & Discontinue
To the Prothonotary:
Mark the above matter Settled, Ended and
Burton NQ(\)aAssociates, P.C.
By:
Der
Attorney
The law firm of Burton Neil & Associates is a debt collector.
Lsker, Esquire
Plaintiff
C-28866