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Home My WebLink About10-4076 c~;Q.l~~ 1~ r~~` .3~ 44 I b,'i~ _ ~ i ~1 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. N0.203465 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. DEBRA A NORMAN 6328 Pennsboro Drive Mechanicsburg PA 17050-2322 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~b - ~~7~p CIVI ~ 1~(`n~t 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. ~ga.00 Pp Ail`/ 32 South Bedford Street C~~7~3~1~ Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 ~#a'~ 3885 C-31527 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. N0.203465 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. DEBRA A HORMAN 6328 Pennsboro Drive Mechanicsburg PA 17050-2322 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CNIL 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 Debra A Horman, who resides at 6328 Pennsboro 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(n) Sears credit card with account number ending in 1389 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 $2,575.88 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 $2,575.88, and the costs of this action. Burton Neil & Associates By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Card® Call us at 1-800-917-7700 Go to www.eaaracard.com Write to us at PO Box 8283 Sioux Fella, SD 57117-8283 DEBRAAHORMAN Account Number: ~ 1389 Payment Due Date Page 1 of 2 10/21!09 Your Account Summa Billing Cycle Closing Date 09/2M09 Amount Over Credit Line $225.88 Amount Past Due $664.80 Total Minimum Due $791.69 Previous Balance $2,474.99 Payments 8 Credits $0.00 Purchases 8~ Debits $0.00 Other Charges $39.00 Total FINANCE CHARGES $61.89 Account Balance $2,575.88 Your Credit Summary Total Credit Line $2,350.00 Total Credit Available $0.00 Your past due amount may be a number. But you're definitely not. Call 1-866-518-9054 today. And we'll help you with a payment solution. You're our customer. We value our relationship with you. So let us help you take care of your past due amount and avoid future late fees. We'll look at your account on an individual basis and work with you to come up with a payment solution for your unique situation. Call us and you'll flnd someone who's ready to Ilsten and who can help you qet back on your feet. ACtiVity Selo Dete Poat Date Description Amount 09/21/09 09/21/09 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,474.99, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Card® Account Number. ~ 1389 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $2,575.88 10/21/09 $791.69 0064339 EX 17 A 09267 1 TRS006 FXG 001 7 N IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII DEBRA A NORMAN 6328 PENNSBORO DR MECHANICSBURG PA 17050-2322 Please make address changes on reverse side. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII111III Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 39.00 2D0 389 0257588 0079b69 OOD0000 b710 EXHIBIT • Sears Card® DEBRA A HORMAN Account Number: XXXX XXXX XXXX 1389 Page 2 of 2 64339 Average wily Rates 'Rate Varies Balance Balance Call us at 1-80x917-7700 Go to www.seerecard.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 Payment Due Date 10/21/09 sponding Periodic Rate Periodic 1AL D=Day FINANCE TENTAGE RATE M=Month CHARGE SEARS REGULAR $2,575.88 $2,509.91 29.99%' .0822%(D)* $61.89 EXTERNAL REGULAR $0.00 $0.00 29.99%' .0822%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 29.99%* .0822%(D)' $0.00 Days in Billing Period: 30 Effective ANNUAL PERCENTAGE RATE: 29.99% Minimum FINANCE CHARGE: $0.00 Cardmember News The "Effective ANNUAL PERCENTAGE RATE" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "Effective ANNUAL PERCENTAGE RATE" is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. The Sale Date is the Transaction Date. Verification Ai~bie Mogey 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. C-31527 Debra A Horman Account number ending in 1389 1031 7-73 TV i'0,:nigac vric. = 201411PR -7 NI 33 CUMBERLAND COUNTY PENSYLVANIA Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 v. DEBRA A HORMAN To the Prothonotary: Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-4076 Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment Mark the judgment Satisfied . Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-31527 / 318 ak sopolag Y.4 /35i%) LJ Zit 2.bc-(Os