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Home My WebLink About10-4824 -{^~ t 'h +~... ,7' 1 -t-'~ ,N Burton Neil & Associates, P.C. By: Edward J. OBrien, Esquire ID. NO. 32985 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. KERI K JOHNSON 26 Cumberland Drive Mechanicsburg PA 17050-1717 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. I~ , t'I'Sa~ ~i v~ tlerr+n 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 HIItING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, TffiS 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 $4o'l•Op P~ ATh/ Telephone No. 717-249-3166 or 800-990-9108 C-37324 e ~ 7ggro Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. KERI K JOHNSON ~ NO ~ O - '~ ~~/ C N~'sl 26 Cumberland Drive Mechanicsburg PA 17050-1717 Defendant C1VIL 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 Keri K Johnson, who resides at 26 Cumberland 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 5598 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 $10,875.25 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 $10,875.25, and the costs of this action. Burton Neil & AssaeRates. P.C. By: rdV~arcl~-l. O' n, Esquire Attorney fo laintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Qp.. ar1 o ~O~ e1pJ Y ~ V ~ J e ~ E .'^o'a` #~ Six~~ oto vo?~ S~ Vmvt ut W Q J lp P E'~^ ~ m '• . z S ~o -~ r q; Y 8& Y < ~O s~ s '-° e '0 ~~ u ~ V < ~ 1 1 n u~ t- W W W b 2Wt <~~ d C~ E °~ z°< ~~ a •Y a N r d '~, ,~ c m a d 7 a c d n d 0 d v c q m a C 7 O V V q ~ 7 0 O ~ Tr C f` O ~ 'd N N N ~ ; ~ L N 3 L d ; d O -° o 7 ~ rs ~~ ~~ E ~ ~ ~ ~ ~ ~$ ~ O pp O S pp O N ~ nNi, G O 0 0 N V O O C VI M ~ N o V N "' ti >° + ~ + ; + o o ~ i a ~ d q ~ ~ E ~ E E c d > u a= w d o d d d -~ « A ° g N _ N ` C 01 Q V U q q .~ ~, m » ' ,n -- ~ ~ ~ r q O d d ' E y d d y E 00 c E, o E y d > ` R R t~ ~ A a H ~ ~& m 3 o o d g > L a g > '° m ~'na q a m u i n°. a v a cu a o ps~ ~E~a~c E0 ° :PS ~ ~ 111 .3 ;>b~ n E ~~' ~%a N'r o~e5 ~,BE ~ u^, ~ GS u .~ a ~r 'd d Q O d g 0 a y~oaaaa C a w < • --...... .... ...__ J °° e h ~gq>aE';$ " c c ~ ~ E v 3 c _ r p ,~. ~ b r ~ Y i m O p .O ~ q q >j.y + iC d C V• q> a~ ~ v N Y y E ;d ~ Bo ~ - r C ~ q q ~' > = .n C~ -'D r d y J ~ O ~ ~ a S ~t„ C N M Y yy ~yy L q~GV N CC ~'c 0 Y N Y r p • O 1RC pL C- E O d.." d'; q ppSOS c ~ E N • O ~-~~ ~-= d =~ ~ '~ w • d ~ ~ 7 4 ~~ S~~`$c~ e Eia~ c€ E c t7 E ~ E :: d ~,,~ ~ ~ -- $ q ' i ~ -$+e ~ 5 t/1 1 s ;cw ~ c n O ~~Et ~ Ewa ~a ~]a[e (u47 _ _____ eroouni paio _____ __cnecti p ______ www.ekkarda.com New Balance: 510,875.25 Minimum Payment Due: 51.26825 Payment Due Date: 04/13/2010 000000 MC 32 A 0 KERIKJOHNSON 26 CUMBERLAND DR MECHANICSBURGPA 17050-1717 CITI CARDS P.0. BOX 182564 COLUMBUS, OH 43218-2564 EXHIBIT 0 D•L1N1 •1/ I•IOIr MY~M M•huctlNr M1 rwws• MaR•cMeM MYabN b:Clt~ Car'd5 ,~~~f~2~ r 5598 Amount Enclosed: Payment must N raNr•I EY S:oo PM bcal rim. on tM Payment dtw date. E i v `s ~~ ~~~ w c ~ ~ •~ ~ J .~ x Opp pJ O `~ O V r0~ O~DX M O _~ Vmin v t - .. ip = V m V yj C d o°E _d n~ °' ° - R a~idc o > °' ~ U u >°'E yin `VIA ~- n„o, N u~E .o ~ 'o 0 ~?~ w > o ,~ o m9 F- c ,~„ NSA Q N~ N O O =a+E ~->n Q~°rn ~o f ~.. f°3E ;ono oLr C ~ N N N a c E9 » ~ mac, ~O ~ v ~_ c 0 >«°.~ Verification Mary E. Crum 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. Signature C-37324 Keri K Johnson Account number ending in 5598 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , I I=l -~: - Sheriff r Tr_ ,,- ,, s ,, ~,~r e~ ~at~n~,,~r~~,~ _ ;~; ; Jody S Smith ; ~- . Chief Deputy ~ ~,~ `~ ~ ~ ~ ~ ~..." ".~ - ~; f' k. k ~ ~ . i ~~ Richard W Stewart ~ ~``~~'`'~ ~~~ `~ PN~ ! ~o'ZI Solicitor i~E v- rr~ st+s~,F~ ~~.~,, ~_ _ .:~:~ ~% Citibank (South Dakota) N.A. Case Number vs. 2010-4824 Keri K. Johnson SHERIFF'S RETURN OF SERVICE 07/30/2010 09:17 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 30, 2010 at 2117 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Keri K. Johnson, by making known unto herself personally, at 26 Cumberland Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. AMANDA COBAUGH, DEPUTY SHERIFF COST: $37.00 August 03, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-4824 v n KERI K JOHNSON 26 Cumberland Drive ; Mechanicsburg PA 17050-1717 rn Defendant : CIVIL ACTION - LAW :. ? Praecipe for Default Judgment w "' D To the Prothonotary: -. cn 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 $10,875.25 $10,875.25 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unworn 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. NOTICE GIVEN UNDER PA.R.CIV.P. 236 Pro Pr ary B VNNe' sso ciates, P.C. By. O'Brien, Esquire Attorney for Plaintiff I.D. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector C-37324 c ? 83f3q`j CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS C-37324 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-4824 KERI K JOHNSON Defendant : CIVIL ACTION - LAW TO: Keri K Johnson 26 Cumberland Drive Mechanicsburg PA 17050-1717 DATE OF NOTICE: August 25, 2010 IMPORTANT NOTICE 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 17013 Telephone No. 717-249-3166 or 800-990-9108 & Assies, P.C. / "'e ? In making this communication, we advise our office is a debt collector. By: Edward J. ' s u' Attorney for Pla' tiff Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff PENNSYLVANIA V. KERI K JOHNSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 10-4824 : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on J Pss-?- (? ?Q!(? Prothonot By: epu If you have any questions concerning the above, please contact: Edward J. O'Brien, 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.