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Home My WebLink About10-73740~' THE PROT~O~d01'ARY 2oro Gov z9 PM z: ss Burton Neil & Associates, P.C. By: Neil Sarker, 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 v. KARA M MNICK 519 Colony Road, Camp Hill PA 17011-2011 Defendant EUMBERLAND COUNTY PFNNSYLVA~!!A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ (7 ~.'.'~ 3~ 1'I 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, 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-41651 ~ ~,PD Q~ oak ~ ~~ Burton Neil & Associates, P.C. By: Neil Sarker, 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. KARA M MNICK j ~ - ~ 3 7 ~ CN,,' 519 Colony Road Camp Hill PA 17011-2011 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 Kara M Mnick, who resides at 519 Colony Road, 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 7546 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 $8,797.83 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 $8,797.83, and the costs of this action. Burton Neil & Associates, P By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ,a ,~ - 04/16/08 $8797.83 s8797.83 SITE:KC-CL TM:CO-5000 ACID:IRB8606 ~3ka~=` =?a~av~_~~t ~ 3~i~~~k#_ 10 / 0 7 / 10 2 2 : 3 6 : 3 9 CITI CARDS P.O. BOX 182564 KARA M MNICK COLUMBUS, OH 7872 MANADA CRT 43218-2564 HARRISBURG pA 17112-8711000 Citi~ Platinum SelectsCard Amount Number ~~ 7546 Ctistomar Servka: 1-800-950-5114 Total Credit line AvsiWble Credit Line s6900 so BOX 6500 SIOUX FALLS, SD 57117 c ots e o io 2 A cr°:uleii~: 03/27/ 08 s1897.83 SeM Dab Post Date Retereau Num ber Activity Sinee Last Stet ~i~51 ~~• Cash Advance Limit Avallabie Cash Limit New Balance s3400 s0 s8797.83 Past Oue s2029 36 Inimum~Dui Amount Dui . 288.96 s8797.83 3/27 PURCHASESPFYNANCE CHARGE*PERIODIC RATE 84 0000 3/27 ADVANCES*FINANCE CHARGE*PERIODIC RATE 84 0000 106.38 0000000000 95.58 0000000000 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. Account Summary revious + urc ases - eymen s + ew Balance & Advances & Credits CHARGE Balance ADVANCESS 4 068 05 TOTAL ; . 8 595.87 0.00 0.00 501.96 8,797.83 Rate Summary e once a ec Finance Char e o Brio is omine ANNUAL PuKCrtasES g Rate APR PERCENTAGE ATE Standard Purch ADVANCES s4,578.97 0.08011%(D) 29.240% 29.240% Standard Adv 54,114.01 0.08011%(D) 29.240% 29.240% t Verification I, 'r'A~~-~.~T~~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. G~ Signature C-41651 Kara M Mnick Account number ending in 7546 1008 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy FILED-OFFICE. OF THE PROTHONOTARY 2010 DEC -9 Pty 4: 20 Richard W Stewart Solicitor Y;S?R - _ cu?F I.,UMBERLAND LOE F e°s PENNSYI.VANI , Citibank (South Dakota) N.A. vs. Kara M. Mnick Case Number 2010-7374 SHERIFF'S RETURN OF SERVICE 12/02/2010 04:50 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1650 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kara M. Mnick, by making known unto herself personally, at 519A Colony Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 December 03, 2010 RYAN BURGETT, DEPUTY SO ANSWERS, 6 Z RON R ANDERSON, SHERIFF 17 GouMySuite ShkNi f. Tele05of4. 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. 10-7374 KARA M MNICK 519 Colony Road Camp Hill PA 17011-2011 C o Defendant : CIVIL ACTION - LAW . 03 = mm -a Praecipe for Default Judgment 77 m To the Prothonotary: = > ° ' Please enter judgment by default for want of an answer in the above case in fi7v C of the o-q c :)c") plaintiff and against the defendant, and assess damages as follows: v c-n Principal: $8,797.83 TOTAL $8,797.83 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED Burton Neil & Associ C. AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 By:_ Neil Sacker, Esquire Attorney for Plaintiff Pro Prothonotary I.D. NO. 203465 J 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-41651 ILLa ?' a1? Cj, Cj, T, 253g7$o poJeJ CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-7374 KARA M MNICK Defendant : CIVIL ACTION - LAW TO: Kara M Mnick 519 Colony Road Camp Hill PA 17011-2011 DATE OF NOTICE: December 29, 2010 IMPORTANT NOTICE C41651 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. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 C-41651 / 232 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. KARA M MNICK 2295 Lambs Gap Rd, Enola PA 17025-1124 Defendant(s) MEMBERS FIRST F.C.U. 3867 Union Deposit Road, Harrisburg, PA 17109 Garnishee(s) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-7374 : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against KARA M MNICK , Defendant(s) 3. and against MEMBERS FIRST F.C.U. , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 3867 Union Deposit Road, Harrisburg, PA 17109 5. Amount Due Interest from 01/18/2011 Total *Plus writ costs Dated: August 6, 2014 $ 8,797.83 1,905.72 $10,703.55* //(7 Neil Sarker, Esquire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. auk c. L//5G . a d --25Th " #/3/ A309'1145 1- df& THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net CITIBANK (SOUTH DAKOTA), N.A. Vs. KARA M. MNICK WRIT OF EXECUTION (Pa R.C.P. 3252) NO 10-7374 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KARA M. MNICK, 2295 LAMBS GAP ROAD, ENOLA, PA 17025-1124 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS FIRST F.C.U.GARNISHEE(S), as garnishee, 3867 UNION DEPOSIT ROAD, HARRISBURG, PA 17109 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with.a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the 'defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $8,797.83 Interest FROM 1/18/2011- $1,905.72 Attorney's Comm. % Attorney Paid $171,50 Date: 8/13/14 (Seal) Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs -4514AL .-gt.dt, David D. Buell, Prothonotary REQUESTING PARTY: Name : NEIL SARKER, ESQUIRE Address: LAW OFFICES BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLANTIFF Telephone: 610-696-2120 Supreme Court ID No. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY (:r f H` PRO -1110'1'40 of .ir 4,°"'k" �� 2O R AUG 26 NI IG t 9 CUMBERLAND COUNTY PENNSYLVANIA MICE OF THE si<.ERIFF Citibank (South Dakota) N.A. vs. Kara M. Mnick Case Number 2010-7374 SHERIFF'S RETURN OF SERVICE 08/22/2014 10:58 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Laruie Shultz, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 25, 2014 to K- - M. Mnick at 2295 Lambs Gap Road, Enola, PA 17025-1124. August 25, 2014 (c) CountySuite Shoritt, Teleosoft, Inc. LLIA LIN , DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Burton Neil&Associates, P.C. By: Neil Sarker,Esquire ID.NO. 203465 0"i J 1060 Andrew Drive, Suite 170 IRECEIVED West Chester, PA 19380 610-696-2120 AUG 2 5 2014 Attorney for Plaintiff CITIBANK(SOUTH DAKOTA),N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. CUMBERLAND COUNTY,PENNSYLVANIA KARA M MNICK 2295 Lambs Gap Rd,Enola PA 17025-1124 NO. 10-7374 Defendant(s) MEMBERS FIRST F.C.U. Garnishee CIVIL ACTION-LAW To: MEMBERS FIRST F.C.U. 3 867 Union Deposit Road, Harrisburg, PA 17109 S Interrogatories to Garnishee You are required to file answers to the following interrogatories within twenty(20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant or any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owed solely or in part by the defendant? r� 3. If the answer to I and/or 2 is yes, please specify the nature of the property and, if money, the amount? 4. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? �n 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? r RECEIVED AUG 2S aw, 6. At any time before you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? 1V` C:) 7. At any time after you were served did you pay,transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? �c 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law?If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 1\�0 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. IV� Burton Neil &Associate , P.C. By: Neil Sarker, Esquire This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. 2CA SEP1 I1 CUMBERLA YL COUNTY PE NS Burton Neil & Associates, P.C. By: Neil Sarker, Esquire M. NO. 203465 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 v. : CUMBERLAND COUNTY, PENNSYLVANIA KARA M MNICK Defendant : NO. 10-7374 and MEMBERS FIRST F.C.U. Garnishee : CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against MEMBERS FIRST F.C.U., garnishee. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-41651 ci CL,/38qthI �# 31096110