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Home My WebLink About10-7075 H? Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (61`0) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. DENNIS L UMBERGER 12 S Filbert Street, Apt A 1, Mechanicsburg PA 17055-6551 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. C-39553 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 Fi ?G q ?O Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th StreetN Sioux Falls, SD 57117 Plaintiff V. DENNIS L UMBERGER 12 S Filbert Street, Apt Al, Mechanicsburg PA 17055-6551 IN THE COURT OF COMMON PLEAS 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 Dennis L Umberger, who resides at 12 S Filbert Street, Apt Al, 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(n) CITI MASTERCARD credit card with account number ending in 8802 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 $6,694.37 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 $6,694.37, and the costs of this action. eil & Associates, P.C. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. s 03/08/10 $6694.37 $6694.37 SITE:KC-CL' TM:CO-5000 ACID:IRB9737 p=_i€-F€=;it=`ta€s€:;= #:=€=::; 06/25/10 2 2 48: 0 9 CITI CARDS DENNIS L UMBERGER PO BOX 183051 12 S FILBERT ST COLUMBUS, OH APT Al 43218-3051 MECHANICSBURG PA 17055-6551000 Citi' Driver's Edge'v Platinum Select Card-Charter Rbts Account Number: 8802 www.citicards.com Summary of Account Activity Previous Balance $6,542.19 Payments -10.00 Other Credits - 0.00 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0:00 Interest Charged +$152'.18 New Balance $6,694.37 Past Due Amount $1,571.93 Pmt. Over Credit Limit $0.00 Credit Limit $25,0 Available Credit $0 Cash Advance Limit $9,9 0 Available Cash Limit $0 Statement Closing Date 0211012010 Days in Billing Cycle 28 Customer Service: 1-800-925-8871 BOX 6500 SIOUX FALLS, SD 57117 c tl? Payment Information Payment must be receivedby5:00PM local time on the payment due date. New Balance $6,694.37 Minimum Payment Due $6,694.37 Payment Due Date 03/08/2010 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to payy u to a ;39 late fee and your APRs may be increased up to thep variable Penalty APR of 29.99%. Minimum Payment Warning:If you make only the minimum payment each period, you will pay more in interest and it well take vuu lnnnPr to nnu nff .... 1"1_.. If you make no additional charges You will pay off the balance And you will end up pa in an using this card shown on this y g estimated total and each month you statement in of... pay... about... Only the minimum payment 1 month(s) $6,694 u you wouia Me information about credit counseling services, call 1-877=337-8188. Sale Date Post Date Reference Number Activity Since Last Statement Amount Fees TOTAL FEES FOR THIS PERIOD 0.00 Interest Char ed 2110 P URCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 152.18 TOTAL INTEREST FOR THIS PERIOD 0000000000 152.18. 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.' Contact us today - we can help! Go online at www.paymentsolutions.citicards.com to login or register. EXHIBIT DENNIS L UMBERGER sale Date Post Date Reference Number Activity Since Last Statement Amount Rate Summary Balance Subject to Periodic Nominal ANNUAL Interest Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch ADVANCES $6,615.27 ..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 Ila. C.S. Section 4904, relating to unsworn falsification to authorities. 4- `' ?"- _a, Signature C-39553 Dennis L Umberger Account number ending in 8802 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY C, C Ronny R Anderson w'Ux M Z?; --- M Sheriff ?artitr ofI[I11Lr? r.n =M r +-- CfrT Jody S Smith 4 cor- > M Chief Deputy -; , < t,p C) ' Richard W Stewart C.)--n Solicitor cFFCEOF THE C `t°s --4 co Citibank (South Dakota) N.A. vs. Dennis L. Umberger Case Number 2010-7075 SHERIFF'S RETURN OF SERVICE 11/16/2010 07:54 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 1954 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dennis L. Umberger, by making known unto himself personally, at 12 S. Filbert Street, Apartment Al, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 17, 2010 RYAN BURGETT, D SO ANSWERS, RON R ANDERSON, SHERIFF (C) CountySutte Shenff. Teleosoft. Inc. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. DENNIS L UMBERGER IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7075 12 S Filbert Street, Apt Apt Al n 4 o 0 Mechanicsburg PA 170556551 Defendant : CIVIL ACTION -LAW ?? C rn? Praecipe for Default Judgment Z w O C2 To the Prothonotary: n o ss = o ?o ? z? Please enter judgment by default for want of an answer in the above case inf4or Rth vrl'y plaintiff and against the defendant, and assess damages as follows: -c Principal: TOTAL $6,694.37 $6,694.37 Understanding that false statements herein 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 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 Stites ased 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 r ono Burton N Associates, P.C. By: ei , Esquire Attorney for Plaintiff I.D. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-39553 a?J o 5-1 _8 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS V. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . DENNIS L UMBERGER NO. 10-7075 Defendant : CIVIL ACTION - LAW TO: Dennis L Umberger 12 S Filbert Street, Apt Al Mechanicsburg PA 17055-6551 DATE OF NOTICE: December 09, 2010 IMPORTANT NOTICE C-39553 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 ?16,ton Neil,& Associates, P.C. In making this communication, we advise our office is a debt collector. Burton Neil, Esquire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (61.0)696-2120 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DENNIS L UMBERGER NO. 10-7075 Defendant 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: eputy If you have any questions concerning the above, ple e contact: Burton Neil, 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. O TOF THE FILED-OFFICE 2013 APR I I PM 3: 32 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil &Associates, P.C. By: Burton Neil, Esquire ID.NO. 11348 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. 10-7075 DENNIS L UM 3ERGER Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . ,`Burt4NeA es, P.C. B Esquire Plaintiff The law firm of Burton Neil&Associates is a debt collector. C-39553 /318 f� 3b S� �� '� dLOg