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Home My WebLink About10-7087Burton Neil & Associates, P.C. B.y: Neil Sacker, Esquire ID. N0.203465 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ((~ LORIE A FOOR : NO. / " _ ~ ~ ~~ 87 Hummel Avenue, Lemoyne PA 17043-1945 Defendant :CIVIL, ACTION -LAW Complaint -Notice .g ou 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 fiirther 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 ar 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 FO~TH 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 HIl2E A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PE',RSONS 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-39477 ~ '~ 4~ ~~~~~ ~~ E4urton Neil & Associates, P.C. Ety: Neil Sark~;r, Esquire ID. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (+510) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. L,ORIE A FOOR 87 Hummel Avenue, Lemoyne PA 17043 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. jU ~. 7~ ~ ~ G,`,,'l CIVIL ACTION-LAW Complaint 1. Plaintiff is CITIBA.NK (SOUTH DAKOTA), N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Lorie A Foor, who resides at 87 Hummel Avenue, Lemoyne, 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 0308 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 fox the sum of $6,966.09 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 $6,966.09, and tl':~e 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. 05/13/10 $69b6.09 $6966..09 SITE:KC-CL TM:CO-5000 AGID:IRB1175 ' ------------------- --- -----__-_--___------ ------------ -- 06/24/10 21:49:11: izax~as~i<-rizi~=:= =i~€~i~:-viii:#ii~ir' ~-~i~`=~ii~-? CiTI CARDS PO BOX 183051 UDRIE A POOR COLUMBUS, OH 87 HUMMEL AVE 43218-3(151 L.IEMOYNE PA ].7043-1945000. ~~ ~' ~'~ ,~ " f ~~y Citi~' C~river's Edge' Card Charter Rebates Account Wumber:~~~ 0308 Customer Service: 1-800-925-8871 www.citicards.com BOX 6500 SIOUX FALLS, SD 57117 Summary of Account Activity Previous IBalance $6,817.08 Payyments - 0.00 Other Credits - 0.00 Purchases + 0.00 Balance Tiransfers + 0.00 Cash Advances + 0.00 Fees Chart~ ed + 0.00 Interest Charged +$149.01 New Balamce $6,966.09 Pas# Due Amount $1,583.29 Amt. Over Credit Limit $1,246.09 Credit Limit $5,720 Availab a Credit $0 Cash Advance Limit $4,A00 'Available Cash limit .Statement Closinqq.Date 04/15/2010 Days in Billing Cycle 30 Sale Date Past Date ReFerence Nwmber Activity Since Last Statement Amount --r-- __ 4,/15 4/15 Fees TOTAL FEES FOR THIS PERIOD Interest Chargged PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 TOTAL INTEREST FOR THIS PERIOD 0.00 13.82 0000000000 135.19 0000000000 144.01 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 helpp! Go online at ~rwriN.paymentsolutions.citicards.com to login or register. f EX~i1BIT C tl® Pa ment Information Payment must berece'rvedby5:00PM y local time on the payment due date. New Balance $6,966.09 Minimum Payment Due $6,966.09 Paymeht Due Date 05/13/2010 Late Payment Warningi:If we do not receive your minimum payment by the date listed above, you may have to pay vp to a 39 late fee and yyour APRs may be increased up to the variable Penalty APR of 29.99°~. Minimum Payment Warn'ing:If you make only .the minimum payment each period,; you will pay more in Ynterest and it will take you longer o nav off vour balance- Fnr PYamnia• If you make. no You will pay And you will end additional charges off the balance up payng an using this card shown on this , estimated tota l .and each month you statemenf in of... pay.: about... Only the minimum payment 3 month(s) $6,966 If you would 4ike information about credit counseling services, call 1:-877-337.-.8188.. E I_O~RIE A FOOR Sale Date Pa~stbate Referenee Number l4ctivity Since Last Statement Amount Balance Subject to Periodic Nominal ANNUAL Rate Summary _ Interest Charge Rate APR PERCENTAGE RATE PURCHASES Standard'Purch $560.75 0.08216%(D) 29.990% 29.990% PLrch/Adv ThYu 02/15/2008 $6,328.08 0.07121°k(D) 25.990% 25.990% ADVANCES Standard Adv $0.00 0.08216%{D) 29.990% 29.990°~ Verification Lisa Blamer 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. (~.5. Section 4904, relating to unsworn falsification to authorities. Signature ~C-39477 Lorie A Foor .Account number ending in 0308 1000 Lorie A. Foor 87 Hummel Ave Lemoyne, Pa. 17043 Defendant in Pro Per Court of Common Pleas Cumberland County, Pennsylvania Civil Action-Law Citibank Plaintiff vs. Lorie A. Foor Defendant No. 10-7087 Civil Term OF TNEI'P O7OFFICE HONOTA 2010 DEC 10 PM 1: 12 CUMBERLAND COU14Ty PENNSYLVANIA Lorie A. Foor ("Defendant'), hereby answers the complaint of Citibank ("Plaintiff') for it's self alone as follows and generally denies the allegations due to the complaint based on lack of information and belief. Due to a seroius financial crisis, defendant does not have sufficient funds to pay the full amount of disputed debt, if any. I cannot pay this amount because of a serious financial issue. I am making an effort to get some money and will let you know when I can pay. I am confident this matter will get resolved. Wherefore, Defendant requests that: 1. Defendant takes nothing by way of his complaint; and 2. For Defendant's cost of suit December 8, 2010 ! v., i) r l--Z H _ ?v ? Defendant in Pro Per ?, uj., SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff O THE PROTHONOTARY Jody S Smith y 2010 DEC _g PM y: 20 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Citibank (South Dakota) N.A. Case Number vs. 2010-7087 Lorie A. Foor SHERIFF'S RETURN OF SERVICE 12/02/2010 07:40 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1940 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lorie A. Foor, by making known unto herself personally, at 87 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $56.80 December 03, 2010 RYAN BURG TT, SO ANSWERS, RONW R ANDERSON, SHERIFF F iL O-OF F !Ct FOTHONOTAR? 2011 JUL 13 AM 10: 5 3 CUMBERLAND COUNTY PENNSYLVANIA 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 V. LORIE A FOOR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7087 CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Di & Associates, P.C. By: Derek 'aster, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-39477