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Home My WebLink About10-23881, T':r: C W Qy Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 Zvil f,.?" -9 Fro 4 i. A; -?? 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. NINA GABNER NO. /D 0?3 ?? 6 Plainview Road, Camp Hill PA 17011-7928 1 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 C-30200 Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 s 9,2 .0o I CL erg Wl.? ? k__+`--ag64Q 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 701 East 60th Street N A. IN THE COURT OF COMMON PLEAS Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NINA GARNER : NO. 6 Plainview Road, Camp Hill PA 17011-7928 Defendant CIVIL ACTION - LAW Complaint 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 Nina Gabner, who resides at 6 Plainview Road, Camp Hill, Cumberland , Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with number ending in 7252 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 nt attached hereto as Exhibit A. The monthly statements accurately stated the previous 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 of the billing statement or retained the statement without payment. 41 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $5,022.71 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 $5,022.71, and the costs of this action. eil 81,Asss(ciates, P.C. Yale D. VVe#ii-sfe-in, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 04/15/09 $5022.71 $652.31 SITE:KC-CL TM:GJ-5000 ACID:KCB0213 `_`i?aass€:: i=afire€: sati`t 10 / 2 9/ 0 9 2 2: 0 9: 3 6 CITI CARDS P.O. BOX 182564 NINA GABNER COLUMBUS, OH PLAINVIEW RD 43218-2564 AMP HILL PA 17011-7928000 / y / -- U /' L1 Citi Platinum Select Card tie 7252 1-800-9 BOX 650 SIOUX F 57117 50-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $4860 $0 $2600 $0 $5022.71 Statement/ Amount Over Pureh/Adv Minimum LLS, SD Closin Date Credit Line Past Duo l? Inimum Due mount Due 03/20/2x09 $162.71 + $285.22 + 1204.38 = 652.31 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 3/20 LATE FEE - FEB PAYMENT PAST DUE 39.00 66 0000 0000000000 3/20 OVER CREDIT LIMIT FEE 39.00 62 0000 0000000000 3/20 PURCHASES*FINANCE CHARGE*PERIODIC RATE 48.64 84 0000 0000000000 Balance Transfer - Charged To Offer 4 3/20 PURCHASES*FINANCE CHARGE*PERIODIC RATE 67.74 84 0000 0000000000 Extra Cash from Citi Summar extracash.citi.com Extra Cash Extra Cash Total Extra Cash Extra Cash Transferred To Your Earned This Period Adjustments This Period Earned This Period Extra Cash from Citf Account 0.00 0.00 0.00 0.00 No Extra Cash was transferred this month to your Extra Cash from Citi account. This may be because you made no eligible purchases or because a credit/adjustment/dispute exceeded the amount of eligible purchases. Extra Cash from Citi Member ID 8648-5139086 Your late fee was based on your account balance as of the payment due date (03/16/09), which was $4,828.33. Your account is two months past due and your credit privileges have been suspended. Please call the toll-free number shown above, Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. If you have already sent us this payment, thank you. Our records show home phone 717-737-4205 and business phone 000-000-0000. If incorrect, please update your account online at www.citicards.com or call us at 1-800-950-5114 to let us know. EXHIBIT----A- NINA GABNER Sale Date Post Date Reference Number Activity Since Last Statement Amount Account Summary Previous Balance (+) Purchases (-) Payments & Advances & Credits (+ FINANCE CHARGE (_) New Balance PURCHASE ADVANCE TOTAL S $4,828.33 $0.00 $4,828.33 $78.00 0.00 $0.00 0.00 $78.00 10.00 $116.38 $0.00 $116.38 $5,022.71 $0.00 $5,022.71 Days This Billing Period: 29 Rate Su mary Balance Subject to Periodic Finance Charge Rate Nominal APR PERCENTAGE RATE PURCHASE S Standar Offer ADVANCE d Purch 2,041.23 2,843.05 0.08216%(D) 0.08216%(D) 29.990% 29.990% 29.990% 29.990% Standar d Adv $0.00 0.08216%(D) 29.990% 29.990% ? ? Y Verification I, Leola Phenix , 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. Sig ure C-30200 Nina Gabner Account number ending in 7252 1000 rn4m ' =rn a r -cp can °7 --ao Zd S CE p C Qm 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 V. NINA GABNER Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-2388 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action The law firm of Burton Neil & Associates is a debt prey N P.C. 7Nale. Weinstein, Esquire Atto ev for Plaintiff C-30200 / 314