The URL can be used to link to this page

Home My WebLink About10-3615.Hr-1? C5D- :47 20th J'?t? -2 ?M 12 sw. Y-'Y N? ?iJ J1?14 1 r?IIS?LV 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. CYNDEE KAY 6809 Salem Park Circle Mechanicsburg PA 170502847 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IJ-30S- 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-33896 /2 0- ?3 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. CYNDEE KAY 6809 Salem Park Circle Mechanicsburg PA 170502847 NO. 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 Cyndee Kay, who resides at 6809 Salem Park Circle, 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 6861 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 $1,927.67 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 $1,927.67, and the costs of this action. Burton Nell 44 Associates, P.C. By: C. Blasker, Esquire ?v for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 12/15/09 ;:<i?a??i==tip=? CYNDEE KAY 6809 SALEM PARK CIR MECHANICSBURG 17050-2847000 $1927.67 $1927.67 SITE:KC-CL TM:CO-5000 ACID:IRB8994 02/25/10 01:09:54: CITI CARDS PO BOX 183051 COLUMBUS, OH 43218-3051 PA Citi CashReturns'm MasterCard` c A4 '.'*& Citi and OR! with Arc Design are registered service marks, and Citi CashReturns and CitiDollers are service marks, of Citigroup Inc. 6861 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS, SO 57117 Minimum Payment Due Payment Due Date New Balance $1,927.67 I 12/15/2009 I $1,927.67 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a $39 late fee and your APRs may be increased up to the Penalty APR of 28.99%. Credit Limit Available Credit Cash Advance Limit Available Cash Limit Statement Closing Date Days in Billing Cycle $1,200 $0 $400 $0 11/18/2009 29 Summary of Account Activity Previous Balance Payments Other Credits Purchases Balance Transfers Cash Advances $1,883.80 $0.00 $0.00 $0.00 $0.00 $0.00 Amt Over Credit Line Past Due Amount New Balance $727.67 $636.52 $1,927.67 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard r 11/18 I I S4RCHOOOOPFINANCE CHARGE*PERIODIC RATE I 00000000002.13 Standard Adv 11/18 ADVANCES*FINANCE CHARGE*PERIODIC RATE 1.74 84 0000 0000000000 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.citicaras.com to login or register. EXHIBIT 14 __ Account Summary Previous {+) Purchases {-) Payments Balance & Advances & Credits (+) FINANCE CHARGE (_) New Balance PURCHASES $1,809.04 0.00 0.00 $42.13 $1,851.17 ADVANCES $74.76 0.00 0.00 1 1 $1.74 $76.50 TOTAL $1,883.80 0.00 0.00 $43.87 $1,927.67 Days This Billing Period: 29 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $1,829.30 0.07942%(D) 28.990% 28.990% ADVANCES Standard Adv $75.60 0.07942%(D) 28.990% 28.990% Verification Abbie Motley I, , 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. f , Signature C-33896 Cyndee Kay Account number ending in 6861 1000 nl'21m 12 `C?1?'SYt V?Lt?I 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. CYNDEE KAY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3615-CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action with' t prejudice. Burton Associates, P.C. By: Derek sker, Esquire Attorney fo laintiff The law finrri of Burton Neil & Associates is a debt collector. C-33896 / 3 14