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Home My WebLink About10-4246FILED- 9 i'« '40TARY 2010 JUN 25 FM 1: J NTY pcNk,`SYl_vAMA 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ,i 1 (t°xCT SAMUEL R CALABRETTA NO. lo - qo?q( 1414 Walnut Bottom Road, Carlisle PA 17015-9156 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 O C-3331.4 #qa. oo Pa ATrY Of 77g70 Rit 4q(4308 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 V. SAMUEL R CALABRETTA 1414 Walnut Bottom Road Carlisle PA 17015-9156 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 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 Samuel R Calabretta, who resides at 1414 Walnut Bottom Road, Carlisle, 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 3935 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 $14,518.15 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 $14,518.15, and the costs of this action. Burton N4JV Associates, P.C. By: Blasker, Esquire for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 01/04/10 SAMUEL R CALABRETTA 1414 WALNUT BOTTOM RD CARLISLE 17015-9156000 $14518.15 $3041.59 SITE:KC-CL TM:CO-5000 ACID:IR85576 >:arai?a ae€:; rarRi_=_; 02/03/10 11:44:16: CITI CARDS PO BOX 183051 COLUMBUS, OH 43218-3051 PA Citi' Driver's Edges' Platinum Select Card-Charter Rbts Account Number 3935 Customer Service: 1-800-866-9900 BOX 6500 SIOUX FALLS, SO 57117 C tlm Minimum Payment Due Payment Due Date New Balance $3,041.59 I 01/04/2010 I $14,518.15 rate 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 29.99%. Credit Limit Available Credit $ash 5,900 Advance Limit Available Cash Limit Statement Closing Date Days In Billing Cycle $13,580 $0 12/08/2009 32 ?u¦um, y u1 Accuunt AcLlvlty Previous Balance Pa ments Other Credits Purchases Balance Transfers Cash Advances $14,065.60 $0.00 $0.00 $78.00 $0.00 $0.00 Amt Over Credit Line Past Due Amount New Balance $938.15 $1,545.89 $14,518.15 Sale Date Post Date Reference Number Activity Since Last Statement Amount 12/08 12/08 12/08 12/08 Standard Purch LATE FEE - NOV PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Balance Transfer - Charged To Offer 7 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned 0.00 NEW DRIVER'S EDGE REBATES 0.00 Purchase Rebates Earned Previous Balance PREVIOUS DRIVER'S EDGE REBATES 0.80 0.80 TOTAL REBATES AVAILABLE 0.80 39.00 0000000000 39.00 0000000000 165.07 0000000000 209.48 0000000000 Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Your late fee was based on your account balance as of the payment due date (12/03/09), which was $14,065.60. Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am 5 pm, Central Time. SAMUEL R CALABRETTA Sale Date Post Date Reference Number Activity Since Last Statement Amount Contact us today - we can help! Go online at www.paymentsolutions.citicaras.com to login or register. Account Summary Previous (+) Purchases {-) Pa s (+) FINANCE (_) New Balance & Advances & Cred is CHARGE Balance PURCHASES ADVANCES $14,065.60 $0.00 $78.0 0.0 0 $374.55 $14,518.15 TOTAL $14,065.60 0. 0 $78.00 10.00 $374.55 $14,518. 5 Rate Summary Balance Subject to Perio is Days This Billing Period: 32 Nominal PURCHASES Finance Charge Rate ANNUAL APR PERCENTAGE RATE Standard Purch Offer 7 $6,278.50 $7 967 70 0.08216%(D) 29.990% 29.990% ADVANCES , . 0.08216%(D) 29.990% 29.990% Standard Adv $0.00 0.08216%(D) 29.990% 29.990% 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. 0 f Signature C-33314 Samuel R Calabretta Account number ending in 3935 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FIL~.~~'~~'"'"~`~~~~ ,r ~~ Sheriff ' ` ~ ~ ~~'~qY ~yy«tt14 Ot ~MtlNbC~,~~~~ .)~ ~'tC. r Jody S Smith ~~ Chief Deputy `~ ~~ ~'x ~~~~ •~~~- ` ~ p~~ ~' ~ -,~1~; k Richard W Stewart ` Solicitor ~ ~ CtlP~~' :' -, ;,; t..':~~~ p~~i~~., r Citibank (South Dakota) N.A. vs. Case Number Samuel R. Calabretta 2010-4246 SHERIFF'S RETURN OF SERVICE 06/28/2010 08:00 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 1955 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Samuel R. Calabretta, by making known unto himself p sonall , at 1414 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents a d the a e time handing to hirn personally the said true and correct copy of the same. _ 1 SIjAWN HARR'I'~ON, D SHERIFF COST: $33.40 June 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF te? CouniySuite Snenft, Teleosoft, Inc. 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. C..~ ~ ~ -~ ~ NO. 10-4246 m ~ o o ~~ ~ _. SAMUEL R CALABRETTA ~ ~ ` a -°~~ ~~ 1414 Walnut Bottom Road "cn.;~ ~-- ~' Carlisle PA 17015-9156 , `"~ =-~ rv -`' - ~ ~„~ _ G_ n Defendant ~~ : CNIL ACTION -LAW :~ n -~ ~~= ~~~ Praecipe fo r Default Judgment '"' "= - - To the Prothonotary: `-~ r - 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 $14,518.15 $14,518.15 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 Bw AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 By: Pro Prot The law firm of Burton Neil & Associates is a debt collector. C-33314 & Associates, P.C. C. Blasker, Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 g`~Y.oo ~dL~ ~ gsy4/ ~ a~s~ CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ] 0-4246 SAMUEL R CALABRETTA Defendant :CIVIL ACTION -LAW TO: Samuel R Calabretta 1414 Walnut Bottom Road Carlisle PA 170]5-9156 DATE OF NOTICE: August 24, 2010 IMPORTANT NOTICE C-33314 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. 1f 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 tee 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 800990-9108 In making this communication, we advise our office is a debt collector. Burton Niei~ Associates, P.C. By: Derek C. B ,Esquire Attorney for Pla stiff Identifcation No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. SAMUEL R CALABRETTA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4246 CIVIL 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 /~ 2~1C~ T By: If you have any questions concerning the above, please contact: Derek C. Blasker, 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. . j {F S "! I 2 6 2: 14 CQU"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 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-4246 SAMUEL R CALABRETTA Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied. Burtq"(% & Associates, P.C. By: The law firm of Burton Neil & Associates is a debt collector. C-33314 / 318 C. Blasker, Esquire Attornfor Plaintiff -4 9. Ce.-?k ?ai s9? i ?a?s$sy