HomeMy WebLinkAbout10-7074u
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.
KIM R CUFF
1907 Columbia Avenue
Camp Hill PA 17011-5421
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY', PENNSYLVANIA
NO.
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-40647
J
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
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.
KIM R CUFF
1907 Columbia Avenue
Camp Hill PA 17011-5421
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 Kim R Cuff, who resides at 1907 Columbia Avenue, 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(n) CITI
MASTERCARD credit card with account number ending in 4925 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.
1
1
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 $8,509.26 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 $8,509.26, and
the costs of this action. A
Burton ei & Associates, P.C.
By:
De k sker, Esquire
Attorney for laintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
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date pai.7 _ amaint F,?id __check n petach and follow paYment instructions on reverse
Makecheckpayableto:Cltl Cards
www.citicar ds.com
New Balance:
$8,504.26
Minimum Payment Due:
$8,509.26
Payment Due Date:
04/10/2070
000000 MC 32 A 0
KIM R CUFF
1907 COLUMBIA AVE
CAMP HILL PA17011-5421
Account Number:
4925
Amount Enclosed:
Payment must be received by 5:00 PM
local time on the payment due date.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH43218-2564
EX OIT - - A---
Verification
I Abbie Motley 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.
C-40647
Kim R Cuff
Account number ending in 4925
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson c? C=
C 'T1
`Ta
Sheriff -.4
Jody S Smith
Chief Deputy M
Richard W Stewart
r~?
--t
Solicitor
w w Q-) C")
Citibank (South Dakota) N.A. Case Number»
vs. 2010-7074
Kim R. Cuff
SHERIFF'S RETURN OF SERVICE
11/24/2010 10:15 AM - Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November
24, 2010 at 1015 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kim R. Cuff, by making known unto herself personally, at The Cumberland County
Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013
contents and at the same time handing to her personally the said true an rrect copy of th same
BRIAN BARRICK, DEPUTY
SHERIFF COST: $41.50
November 24, 2010
SO ANSWERS,
ROW R ANDERSON, SHERIFF
r7 Ctiun'ySult9 jhernf releoso`t. 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. 10-7074
KIM R CUFF r y r
1907 Columbia Avenue
Camp Hill PA 17011-5421 -q
Co
?
E Fn
Defendant
CIVIL ACTION - LAW ;, x
r-
s Z - rri
J
? C)
---a
Praecipe for Default Judgment
To the Prothonotary: C
-
Please enter judgment by default for want of an answer in the above case in favof of the
plaintiff and against the defendant, and assess damages as follows:
Principal:
TOTAL
$8,509.26
$8,509.26
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 L
received from the defendant and/or the Department of Defense
JUDGMENT BY DEFAULT ENTERED Bw
AND DAMAGES ASSESSED AS ABOVE.
NOTICE GIVEN UNDER PA.R.CIV.P. 236 By:
i
Pro othonotary
The law firm of Burton Neil & Associates is a debt collector.
C-40647
States based on information
& Associates, P.C.
lasker, Esquire
Attorney for Plaintiff
I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
?d. >G/
,??.?f X53 ys?
k A /-/ a / ? vloza
CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS
v. Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
KIM R CUFF NO. 10-7074
Defendant : CIVIL ACTION - LAW
TO: Kim R Cuff
1907 Columbia Avenue
Camp Hill PA 17011-5421
DATE OF NOTICE: December 17, 2010
IMPORTANT NOTICE
C-40647
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
In making this communication, we advise our office is a
debt collector.
BuZePayne, & Associates, C.
ByDa Esquire
Attorney for Plaintiff
Identification No. 202294
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
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.
Plaintiff
PENNSYLVANIA
V.
KIM R CUFF
Defendant
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: NO. 10-7074
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_/,?
Prothonotary
By:
If you have any questions concerning the above, please
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.