HomeMy WebLinkAbout10-4141F1tFFICE
OF THE P.90THMOTARY
2010 JUN 21 PM 1: 23
C UMBERL W c OLM
P "M"
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.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
STEPHANIE SPOTTS
1110 Ridge Drive,
Mechanicsburg PA 17055-4483
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1lb - 4141
a-ty ItTem
: 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
Trl
a N
Telephone No. 717-249-3166 or 800-990-9108 ?ga.C33.
C-33325 Ct `7g300,1
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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
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.
STEPHANIE SPOTTS
1110 Ridge Drive,
Mechanicsburg PA 17055-4483
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 Stephanie Spotts, who resides at 1110 Ridge 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 9100 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 $12,098.34 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 $12,098.34, and
the costs of this action.
Burton Neil & Associates, P.C.
By:
Neil Sarker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
09/06/07
STEPHANIE SPOTTS
1110 RIDGE DR
MECHANICSBURG
17055-4483000
$12098.34
PA
$12098.34 SITE:KC-CL TM:CO-5000 ACID:IRB0021
02/03/10 11:44:08:
CITI CARDS
PO BOX 183051
COLUMBUS, OH
43218-3051
C??332
®
"
"
0 C tl•
Citi
A
Advantage
World MasterCard
AAdvantage is a registered trademark of American Airlines, Inc.
Account Number
9100
Customer Service: Revolving Available Revolving
1-800-925-8871 Credit Line Credit Line Cash Advance Limit Available Cash Limit New Balance
$10000 $0 $7400 $0 $12098.34
BOX 6062
Statement/ Amount Over Purch(Adv Minimum
SIOUX FALLS, SD Closing Data Revolving Credit Line Past Due Minimum Due Amount Due
57117 08/13/2007 $2098.34 $2785.09 $457.03 $12098.34
Sale Date Post Date Reference Number Activity Since Lest Statement Amount
Standard Purch
8/13 PURCHASES*FINANCE CHARGE*PERIODIC RATE 176.37
84 0000 0000000000
8/13 PURCHASES*FINANCE CHARGE q*PERIODIOffer 5
C RATE 160.66
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.
Our records show home phone 717-691-9514 and business phone 717-691-9514.
Please update coupon if incorrect.
IXHIBITL4
Account Summary Previous
Balance +) Purchases (-) Payments
& Advances & Credits (7) FINANCE
CHARGE (_) New
Balance
PURCHASES $11,761.31 0.00
0.00 $337.03 $12,098.34
ADVANCES $0.00 0.00 0.00
1
1 $0.00 $0.00
TOTAL $11,761.31 0.00
0.00 $337.03 $12,098.34
Days This Billing Period: 32
Rate Summary Balance Subject t o Periodic Nominal ANNUAL
Finance Charge Rate APR PERCENTAGE RATE
PURCHASES
Standard Purch 6,239.88 0.08833%(D) 32.240% 32.240%
Offer 5 5,683.89 0.08833%(D) 32.240% 32.240%
ADVANCES
Standard Adv $0.00 0.08833%(D) 32.240% 32.240%
Verification
I, Lisa Blumer , 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.
Signature
C-33325
Stephanie Spotts
Account number ending in 9100
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
~tjtit k~ +~.~Ilifll~Cj.
Jody S Smith °~°~ Jr,~~ ~'~~~ ~~" ~~
Chief Deputy ~ ~~~ ~~~ ~~'- ~ ~~ '~;~~~~RY
Richard W Stewart ~ `° Z~ ~ ~ ~~~~ ~ S ~ ~; ~
Solicitor ~;c~=" "~==~aai~r
Citibank (South Dakota) N.A.
vs.
Stephanie K. Spotts
Case Number
2010-4141
SHERIFF'S RETURN OF SERVICE
06!24/2010 08:24 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 24,
2010 at 2022 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Stephanie K. Spotts, by making known unto herself personally, at 1110 Ridge Drive, Unit
A, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to
her personally the said true and correct copy of the same.
SHERIFF COST: $37.00
June 25, 2010
.-~
RYAN BURGE ,
SO ANSWERS,
RON r R ANDERSON, SHERIFF
(c) CeuntySuita 5henff, i'elecseft, Iqe.
CITIBANK (SOUTH DAKOTA), N.A.,
Plaintiff
vs.
STEPHANIE SPOTTS,
Defendant
IN THE COURT OF COMMON
of CUMBERLAND COUNTY,
PENNSYLVANIA c~
No. 10.~~Civi1 Term ~~'~ ~°.
--
Civil Action -Law ,~`_ ; ~`'
~c
_ ~.
ENTRY OF APPEARANCE .=~ `= c.~
TO THE PROTHONOTARY:
-~ r..
c._.-
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~, -,-~
-!_'1 ~Y;
`'~,-
_~.:
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Kindly enter the appearance of Keith E. Kendall, Esq. and Scaringi & Scaringi,
P.C. on behalf of the above-captioned Defendant.
Date: ~ C~
r
Keith E. Kendall, Esq.
Attorney ID No. 42910
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 657-7770
(717) 657 7797 (FAX)
CERTIFICATE OF SERVICE
I, Keith E. Kendall, Attorney for the Defendant, hereby certify that I have this
date served a true and correct copy of Defendant's Entry of Appearance upon the
Plaintiffs attorney, by First Class U.S. Mail, postage prepaid, addressed as follows:
Neil Sarker, Esq.
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Date: ~ -~ ~
eith E. Kendall, Esq.
Attorney for Defendant
tir
CITIBANK (SOUTH DAKOTA), N.A.,
Plaintiff
VS.
STEPHANIE SPOTTS,
Defendant
IN THE COURT OF COMN~ :- ;
of CUMBERLAND COU `~ "
PENNSYII ~~1NIA ~?"' .. ~ ;; -r+
r.
r - r,
No. 10--i~4#~~ivil Term ~ ~ ~ ~"'
_~. -;
Civil Action -Law x ~~- ~.~
r`~
----- -------- ~ --~ ._~ ~ ~ _.. _ _ ..c_ .-c.
FOR INSUFFICIENT SPECIFICITY OF PLAINTIFF'S COMPLAINT AND
FAILURE TO CONFORM TO RULE OF COURT
The Defendant, Stephanie Spotts ("Defendant"), by and through her counsel,
Keith E. Kendall and Scaringi & Scaringi, P.C., files these Preliminary Objections to
Plaintiffs Complaint pursuant to Rule 1028 of the Pa. Rules of Civil Procedure
("Pa.R.C.P."), and in support thereof avers the following:
I. Insufficient Specificity of a Pleading
1. Plaintiff initiated this action by filing a Complaint on or about June 21,
2010. A true and correct copy of the Complaint is attached hereto as Exhibit "A."
2. Plaintiffs Complaint appears to allege a cause of action for breach of a
charge card agreement between Plaintiff and Defendant.
3. The alleged breach is supported by an averment in Paragraph 4 of the
Complaint that "Plaintiff furnished consumer credit to the defendant by means of a credit
card with account number ending in 9100 hereinafter referred to as the credit card
account."
4. Paragraph 5 of the Plaintiffs Complaint further alleges that "Plaintiff kept
accurate running records of all debits and credits to the account."
5. Paragraph 6 of the Plaintiffs Complaint further alleges that "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."
6. Paragraph 7 of the Plaintiffs Complaint further alleges that "Before
plaintiff mailed Exhibit A, defendant had for many months made payments on account of
the billing statement or retained the statement without payment."
7. Paragraph 8 of the Plaintiffs Complaint further alleges that "Defendant's
actions as set forth above constituted an account stated between the parties for the sum of
$12, 098.34 which sum reflects the Exhibit A statement balance less credits, if any, which
were applied subsequent to the date of Exhibit A."
8. Pa.R.C.P. 1019(a) requires that "the material facts on which a cause of
action is based shall be stated in a concise and summary form."
9. Pa.R.C.P. 1019(f) further requires that "averments of time, place and items
of special damage shall be specifically stated."
10. None of the averments of Plaintiffs Complaint set forth with sufficient
specificity any acts or omissions by the Defendant that caused Plaintiffs alleged
damages, in violation of Pa.R.C.P. 1028(a)(3), which permits a preliminary objection to a
pleading for lack of specificity. Defendant is therefore unable to ascertain from the
Complaint the specific conduct of the Defendant that allegedly caused Plaintiff s
damages.
11. Paragraph 5 of Plaintiffs Complaint alleges that "Plaintiff kept accurate
running records of all debits and credits to the account," but fails to attach a writing on
which such debits and credits are recorded, in violation of Pa.R.C.P. Rule 1019(1), which
requires that "When any claim or defense is based upon a writing, the pleader shall attach
2
a copy of the writing, or the material part thereof." In that regard, Defendant believes, and
therefore avers that any such credit card account described by Plaintiff must be based
upon a writing, which is also absent from the Complaint, in violation of Pa.R.C.P.
1019(1).
12. Paragraph 6 of Plaintiffs Complaint references "monthly statements"
mailed to Defendant, of which Plaintiff attaches only one to its Complaint, in further
violation of Pa.R.C.P. 1019(1).
13. Paragraph 7 of Plaintiffs Complaint is unintelligible to Defendant, and is
therefore in violation of Plaintiff s duty to state its claim in "concise and summary form,"
in violation of Pa.R.C.P. 1019(a).
14. Paragraph 8 of Plaintiffs Complaint makes the conclusory allegation that
"Defendant's actions set forth above constituted an account stated between parties," in
further violation of Plaintiffs duty to state its claim in "concise and summary form"
pursuant to Pa.R.C.P. 1019(a). Further, Plaintiff alleges that "Defendant's actions" have
somehow harmed Plaintiff, yet Plaintiff has not stated any act or omission on the part of
Defendant in any allegation in its Complaint.
15. Plaintiffs Complaint lacks sufficient specificity to apprise Defendant of
the issues to be litigated, to allow her to adequately prepare and assert defenses to
Plaintiff s allegations.
3
WHEREFORE, pursuant to Pa.R.C.P. 1028(a)(3), Defendant respectfully requests
that this Court require Plaintiff to plead more specifically the averments of its Complaint
relating to the nature and facts of Plaintiff s cause of action.
Date: c~- I ~
Respectfully submitted,
Keith E. Kendall, Esq.
Attorney ID No. 42910
Scaringi & Scaringi, P.C.
Attorneys for Defendant
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 657-7770
(717) 657 -7797 (FAX)
4
CERTIFICATE OF SERVICE
I, Keith E. Kendall, Attorney for the Defendant, hereby certify that I have this
date served a true and correct copy of Defendant's Preliminary Objections upon the
Plaintiffs attorney, by First Class U.S. Mail, postage prepaid, addressed as follows:
Neil Sarker, Esq.
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Date: J- / 1~
Keith E. Kenda 1, Esq.
Attorney for Defendant
~ ,.
1, '` ~ _
BURTON NEIL & ASSOCIATES, P.C. :'~ ' E
BY: Yale D. Weinstein, Esquire h ;,,, __; ~ r'~ v;
Identification No. 89678 ~~ ~ ~ ~. ~ `b
~;r
1060 Andrew Drive, Suite 170 ~~ W ~ ~ 3 ~ ~~
West Chester, PA 19380 C:"J't ~ ~~~~; t
610-696-2120 ` _ ~ ~ .
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A
Plaintiff
VS..
STEPHANIE SPOTTS
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 10-~~4'i' ~~ N
CIVIL ACTION -LAW
PLAINTIFF'S ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS
1. Admitted.
2. Denied. To the contrary, plaintiff s cause of action is based on an account stated.
3. Admitted in part, denied in part. It is admitted that the averment recites paragraph 4 to
plaintiff s complaint. It is denied that is where the alleged breach is supported.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. There are no facts alleged in the averment to which a responsive pleading is required.
9. There are no facts alleged in the averment to which a responsive pleading is required.
10. Denied as a conclusion of law in which no further response is required.
11. Denied. To the contrary, plaintiffls cause of action is based on an account stated and
attaches a copy of the last monthly billing statement sent to defendant. This is the only document
required to be attached when pleading an account stated cause of action. See Citibank ,South
Dakota, N.A. v. King, 2 Pa. D. & C.Sth 60, 63 (2007); Rush's Service Center, Inc. v. Genareo, 10
Pa. D. & C.4th 445, 447 (1991);Citibank (South Dakota) N.A. v. Cassie O. Kapusta. 2007-SU-
3005-YO1 (York Cty., 2007); Citibank (South Dakota) N.A. v. Alicia M. Cusanelli, # 5-1516 -
2008 (Schuylkill Cty., 2008); Citibank (South Dakotal N.A. v.Paula Zuder, # 7286 of 2008
(Luzerne Cty., 2008); Citibank (South Dakota) N.A. v. Sobel, # 2005 CV 4855 CV (Dauphin Cty
2008); Citibank (South Dakota) N.A. v. Elvin L. Weaver, # 2006 - 01614, (Lebanon Cty., 2008);
Citibank (South Dakota) N.A. v. Deb Krasle~ CI-08-09523 (Lancaster Cty.,2008) Citibank l,South
Dakotal N.A. v.Mark Heverly, #13215 of 2008 (Westmoreland County; 2008); Citiban c~(South
Dakota) N.A. v. Nicola A. Lamont, # 2007 GN 6062 (Blair Cty., 2008; Citibank .(South. Dakota)
N.A. v. Robert Kutz, # 08 - S -1576 (Adams Cty., 2009); Citibank (South Dakota) N.A. v. Chad
Beatty, Sr. # 3161 of 2008 GD (Fayette Cty., 2009).
12. Denied as a conclusion of law in which no further response is required.
13. Denied. There are no facts alleged in the averment to which a responsive pleading is
required. The allegation is denied pursuant to Pa R.C.P. 1029(d).
14. Denied. There are no facts alleged in the averment to which a responsive pleading is
required. The allegation is denied pursuant to Pa R.C.P. 1029(d).
15. Denied as a conclusion of law in which no further response is required
WHEREFORE plaintiff moves the Court overrule defendant's Preliminary Objections as per
the attached proposed Order.
BURT{~N NEI~/~i ASSOCIATES, P.C.
By:
Yal D. Weinstein, Esquire
A rnev for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
t ~l F ;_~ -
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~[' ~ ~ . ,' 1 i i~r
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. :CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-4141
STEPHANIE SPOTTS
Defendant :CIVIL ACTION -LAW
Certificate of Service
I, Yale D. Weinstein, Esquire do hereby certify that I served a true and correct copy of the
within Response to Preliminary Objections on defendant's counsel, Keith E Kendall, Esquire at
his address of record via first class mail, postage prepaid on the date set forth below.
Burton N~ii"&~Ass~iates, P.C.
Date:
By:
Yale . VV~i~fein, Esquire
Att ev for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-33325
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Praecipe for Listing Case for Argument
(Must be typewritten and submitted in duplicate) `
L-
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: -ow �--
rn. -W,
Please list the within matter for the next Argument Court.
---------------------------------------------------------------------------------------------------- --- ---
CITIBANK(SOUTH DAKOTA),N.A.
Plaintiff
V.
STEPHANIE SPOTTS
Defendant NO. 10-4141
1. State matter to be argued(i.e., plaintiff s motion for new trial, defendant's demurrer to
complaint, etc.):
Defendant's Preliminary Objections
2. Identify counsel who will argue case:
(a) for plaintiff: Yale D. Weinstein, Esquire c/o Burton Neil &Associates,
P.C.
address: 1060 Andrew Drive, Suite 170, West Chester, PA 19380
b) for defendant: Keith E Kendall, Esquire
address: 2000 Linglestown Road Ste 106 Harrisburg PA 17110
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: August 9, 2013
JAM Weinstein, Esquire
for the Plaintiff This is an attempt to collect a debt, and any informined will be used for that purpose.
This communication is from a debt collector.
CP
CIP
# a
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. CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-4141
STEPHANIE SPOTTS
Defendant : CIVIL ACTION - LAW
Certificate of Service
I, Yale D. Weinstein, Esquire do hereby certify that I served a true and correct copy of the
within Praecipe for Argument on defendant's counsel, Keith E Kendall, Esquire at his address of
record via first class mail,postage prepaid on the date set forth below.
Burton Neil sociates, P.C.
Date: By:
Yale . Weinstein, Esquire
Atto ey for Plaintiff
This is an attempt to collect a debt, and any information obtai ed will be used for that purpose.
This communication is from a debt collector.
C-33325
23 OCT -2 Phi 1: 12
CUMBERLAND COUNTY
PENNSYLVANIA
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.
NO. 10-4141
STEPHANIE SPOTTS
Defendant : CIVIL ACTION-LAW
Praecipe to Settle,End, & Discontinue
To the Prothonotary:
Mark the above matter Settled, Ended and Discontinued.
Burton Nei ► •c es, P.C.
By: .1
Yale ! ;-instein, Esquire
Atto - for ' ai tiff
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. /324