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HomeMy WebLinkAbout10-4142THE H? OF -TRY 2010 JUN 21 PM 04 4 CLWWQ.h4o COLMY 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HONORA R SANTEL : NO. 10 _ I- ,qA 0'1\14Tem 442 Crestview Court, Camp Hill PA 17011-2117 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 Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-34551 - ggjoo PA Ate'`/ Vt 77304 & dyYogq 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. HONORA R SANTEL 442 Crestview Court, Camp Hill PA 17011-2117 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 Honora R Santel, who resides at 442 Crestview Court, Camp Hill, 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 1899 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 $5,026.03 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 $5,026.03, 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. 01/18/10 HONORA R SANTEL 442 CRESTVIEW CT CAMP HILL 17011-2117000 $5026.03 $5026.03 SITE:KC-CL TM:CO-5000 ACID:IRB0021 1. 03/10/10 22:49:03: CITI CARDS PO BOX 183051 COLUMBUS, OH 43218-3051 PA Citi" Advantage' World MasterCard* a ti e i AAdvantage is a registered trademark of American Airlines, Inc. Customer Service: 1-800-756-4000 1899 BOX 6062 SIOUX FALLS, SD 57117 Minimum Payment Due Payment Due Date I New Balance $5,026.03 01/18/2010 $5,026.03 Late Payment Warnippqq• If we do not receive your minimum payment by the date listed above, you may have to pay a i39 late fee and your APRs may be increased up to the Penalty APR of 29.99%. Revolving Available Cash Advance Limit Available Cash Limit Statement Closing Date Days In Billing Cycle 4tl090 Limit Revolving Credit V 52,600 $0 12/21/2009 32 Summary of Account Activity Previous Balance Payments Other Credits Purchases Balance Transfers ash Advances $4,857.68 $0.00 $0.00 $39.00 $0.00 0.00 Amt Over Revolving Past Due Amount New Balance Credit Line $936.03 $1,152.21 $5,026.03 Sale Date Post Date Reference Number Activity Since Last Statement Amount standard Purch 12121 LATE FEE - NOV PAYMENT PAST DUE 39.00 66 0000 0000000000 12121 PURCHASES*FINANCE CHARGE*PERIODIC RATE 55.54 84 0000 0000000000 12121 ADVANCES*FINANCE CHARGE*PERIODIC RATE 73.81 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (12/16/09), which was $4,857.68. The minimum amount due displayed on this statement includes your past due, the Purch/adv minimum due, and transactions that exceed your revolving credit line. 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. Credit Protector Your account protection eligibility has been cancelled on your account effective 11/19/2009. Contact us today - we can help! Go online at EA www.paymentsolutions.citicaras.com to login or register. I 'H I HONORA R SANTEL S8k Date Post Date Reference Number Activity Since Last Statement Amount Previous + Purchases PI NANCE () Account Summary -) Payments + = ew Balance f Arlv.nr.e ruanr_r PURCHASES CES TA 21085.80 - --•-- $39.00 0.00 -• °'-- valance 55.54 2,180.34 1 TO L q;g57.68 ;39.00 0.00 10.00 73.81 2,845.69 $129.35 15,026.03 Days This Billing Period: 32 Rate Summary Balance Subject to Finance Charge Periodic Rate omina ANNUAL ADO nnaca ndard Purch $2,112.58 0.08216%(D) 29.990% 29.990% NCES ndard Adv $2,807.47 0.08216%(D) 29.990% 29.990% 4, V •', . Verification I, Mary E. Crum 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-34551 Honora R Santel Account number ending in 1899 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~ ~1'~ Sheriff ~.1~~,~ ;~ e ~..~~tt`,"~~Y Jody S Smith ~~`~~ rrr'~4 E~~ ~~' Chief Deputy 4 ~~~ ~' ~~~ 2Q10 .~t~~~ 25 ~~~ g: t 2 Richard W Stewart .~,~ Solicitor ~F~t~~ c~F ~ ~ >~~~~~ ,,, }`.,~~ Citibank (South Dakota) N.A. vs. Case Number Honora R. Santel 2010-4142 SHERIFF'S RETURN OF SERVICE 06/23/2010 07:56 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2010 at 1956 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Honora R. Santel, by making known unto himself personally, at 442 Crestview Court, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. ~P ~zl~~ ~ NOAH CLINE, DEPUTY SHERIFF COST: $41.50 June 24, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (o) GouniySuile Shenif. TelecsOft, Inr. R. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. HONORA R SANTEL 442 Crestview Court Camp Hill PA 17011-2117 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4142 CNIL ACTION -LAW Praecipe for Default Judgment To the- Prothonotary: C') c-~ - =~T a ~ i - ---. nt ,- ~.. - ~ n - ~r_ :° . W ._ c Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $5,026.03 $5,026.03 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOT GIVEN UNDER PA.R.CIV.P. 236 / ~~. A Pro Prothonotary Burton Neil & Associat .C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-34551 $I'~. 00 P~ A T'N C~ ~~ p,~` ~ rasa ~oke.~, CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-4142 HONORA R SANTEL Defendant :CIVIL ACTION -LAW TO: Honora R Santei 442 Crestview Court Camp Hill PA 17011-2117 DATE OF NOTICE: July l 6, 20l 0 IMPORTANT NOTICE C-34551 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten {10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office below. 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 I7013 Telephone No. 717-249-3166 or 800-990-9108 In making this communication, we advise our office is a debt collector. Bu n Neil & Associ es, P.C. ~ ~ , By: Da ei A. Payne, Esquire Attorney for Plaintiff Identification No. 242294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610)696-2120 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. Plaintiff v. HONORA R SANTEL Defendant TN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4142 CIVII., ACTION -LAW Rule of Civil Procedure N0.236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ~ ~ld Prothon By: ~ Deputy If you have any questions concerning the above, please contact: Neil Sarker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. Burton Neil &, Associates, P.C. F 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-4142 HONORA R SANTEL Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied. Burton Neil & Associates, P.C. By: _ Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-34551 oj?+ ??, ? aSp?ilSL?