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HomeMy WebLinkAbout10-6634OF Tf Er R`C PROTHONOTARY 2010CUCT 19 AN 10: 28 CUMBERLAND COUNTY PENNS YLVANIA 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. MICHAEL J ARDOLINE 13 Larch Lane, Enola PA 17025-3401 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. ) O - &U9(/ iv i I -]?,rwl 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 HERING 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 OS C-42807 # qa .00 P o Air/ of $(.P603 e a?4l9 980 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 NO. MICHAEL J ARDOLINE 13 Larch Lane, Enola PA 17025-3401 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 Michael J Ardoline, who resides at 13 Larch Lane, Enola, 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) CITI MASTERCARD credit card with account number ending in 5136 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 $24,801.32 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 $24,801.32, 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. 07/08/10 $24801.32 $24801.32 SITE:KC-CL CITI CARDS PO BOX 183051 MICHAEL J ARDOLINE COLUMBUS, OH 13 LARCH LN 43218-3051 ENOLA PA 17025-3401000 Citi' Driver's Edge" Platinum Select Card-Charter Rbts Account Number: 5136 www.citicards.com Summary of Account Activity Previous Balance $24,647.51 Payments - 0.00 Other Credits - 0.00 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances +10.00 Fees Charged +$39.00 Interest Charged +$114.81 New Balance $24,801.32 Past Due Amount $1,593.701 Amt. Over Credit Limit $0.00 Credit Limit $25,000 Available Credit $0 Cash Advance Limit $11,790 Available Cash Limit S0 Statement Closing Date 06/10/2010 Days in Billing cycle 29 Customer Service: 1-800-866-9900 Rny Asnn CTnny CAIiC cn c7ii7 C tl? t Information New Balance 24,801.32 Minimum Payment Due 24,891.32 Payment Due Date 07/08/2010 Late Payment Warning:.If we do not receive your minimum pa ment by the date listed above, you may have to pay up to a39 late fee and your APRs may be increased up to the variable Penalty APR of 29.99%. Minimum Payment Warning: If you make only the minimum payment each period, you will fay more in interest and it will take you longer to Pav off Your balance. For examDle: If you make no You will pay And you will end additional charges off the balance up paying an using this card shown on this _ estimated total and each month you statement in of... pay... about... Only the minimum payment 1 month(s) $24,801 If you would like information about credit counseling services, call 1-877-337-8188. 1 mF Gh e4-w.-wF 6/10 LATE FEE - MAY PAYMENT PAST DUE 66 0000 TOTAL FEES FOR THIS PERIOD 6/10 PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 6/10 PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 TOTAL INTEREST FOR THIS PERIOD Your late fee was based on your account balance as of the payment due date (06/08/10), which was $24,647.51. TM:CO-5000 ACID:IRB8606 08/27/10 21:48:44: C y?? 0'1 39.00 0000000000 39.00 83.38 0000000000 31.43 0000000000 114.81 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. EXHIBIT - MICHAEL J ARDOLINE Sala Data Post Data Reference Number Activity Since Last Statement Amount Our records show home phone 717-732-0172 and business phone 717-732-7708. If incorrect; please update your account online at www.citicards.com or call us at 1-800-866-9900 to let us know. Contact us today - we can help! Go online at www.paymentsolutions.citicaras.com to login or register. Rate Summary Balance Subject to Periodic Nominal ANNUAL Interest Charae Rate APR PERCENTAGE RATE PURCHASES Standard Purch 11,467.94 0.02507%(D) 9.150% 9.150% Offer 4 13,234.94 0.00819%(D) 2.990% 2.990% ADVANCES Standard Adv $0.00 0.06915%(D) 25.240% 25.240% Verification Abbie Motley 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-42807 Michael J Ardoline Account number ending in 5136 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R; Anderson Sheriff Jody S Smith Chief Deiouty Richard 'W Stewart Solicitor Citibank (South Dakota) N.A. vs. Michael J. Ardoline Case Number 2010-6634 SHERIFF'S RETURN OF SERVICE 11/01/2010 06:12 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 1, 2010 at 1812 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael J. Ardoline, by making known unto Joe Ardoline, Son of defendant at 13 Larch Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. rr?; ? P ? 1S i Fr ?/ ? ?Aa NIDA COBAUGH, DE?Y)TY SHERIFF COST: $41.50 November 05, 2010 SO ANSWERS, r'W RON ? R ANDERSON, SHERIFF f rr roif?^< Suite ne,-?°f, 7'e.'eosoft CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD Plaintiff V. MICHAEL J ARDOLINE 13 Larch Lane Enola PA 170253401 Defendant IN THE COURT OF COMMON PLEAS 57117 CUMBERLAND COUNTY, PENNSYLVANIA C "ti ? NO. 10-6634 CIVIL TERM rnCo rat ca C) - --r s- U)rte" C-r n -) nr- Z' -* X co r t o CIVIL ACTION - LAW C ? co Praecipe Ifor Default Judgment Please enter judgment by default for w t of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as fellows: To the Prothonotary: Principal: $24,801.32 TOTAL $24,801.32 Understanding that false statements hereibn made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom 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 Ns praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if a4y, 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 GIV N UNDER PA.R.CIV.P. 236 Pro Pro Wary Burton Neil & Associ , P.C. By: Neil ker, Esquire Attorney for Plaintiff I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-42807 am .a Iq.Db 11> at J C?`?5?5s1 e CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 042807 V. Plaintiff MICHAEL J ARDOLINE Defendant TO: Michael J Ardoline 13 Larch Lane Enola PA 170253401 DATE OF NOTICE: November 25, 2010 : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-6634 CIVIL TERM CIVIL ACTION - LAW IMPORTANT NOTICE You are in default because you have failed to enter a written appearance wring with the court your defenses or objections to the clOims set forth against yo 0 1 y or by attorney and file in los days from the date of this notice, a judgment may be ent Paper to Unless yd you ou a within ten (10) property or other important rights. You should take this against your lawyt at oncea hearing yoando not have a e your go to or telephone the office below. This office can provide you with information about hiring a la lawyer, wyer. 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 INFORMATIO SERVICE Cumberland County Bar Assoc. 32 South Bed?ord Street Carlisle, PA 17013 Telephone No. 717-2494166 or 800-990-9108 Burton Neil & Associates, P.C In making this communication, we advise our office is a debt collector. By:- / y? Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 .' 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. Plaintiff V. MICHAEL J ARDOLINE Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-6634 CIVIL TERM CIVIL ACTION - LAW Rule of Civil Procedlure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on_?P.t! PYV1 Y ?{ 10 ?,pVSp D, gvtGL Pro By: thonDepu If you have any questions concerning the above, please contact: Neil Sarker, Esquire Attorney for Party 'i,Filing 1060 Andrew Drivle, Suite 170 West Chester, PA 19380 Phone: 610-696-2 t 20 The law firm of Burton Neil & Associates is a debt collector.