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Home My WebLink About10-7749~~ r~~f P~~~7~0~'~~~r~~•., z~ ~ o o~c ~ 7~ a~ ~: ~ ~ ~f)~3SEnLAf'~f) CGUrd``.'~3 pf_fVNSYl.~~;~Pdit~ 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. MARK MCCLEEREY 1169 Cross Creek Drive Mechanicsburg PA 170502019 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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 ~ ~~ Q~ C-42369 Asa s~~ e 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. MARK MCCLEEREY 1169 Cross Creek Drive Mechanicsburg PA 170502019 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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 Mark McCleerey, who resides at 1169 Cross Creek Drive, 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 8518 hereinafter referred to as the credit card account. ~. 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 $26,685.34 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 $26,685.34, 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. °o~ P w °u O ~ ~ > ~n q ~ M N J ~~ OOlaa. w O O ~ X 30 aX~~^ O m 7 0 ~~ S^ Vmv7N W JO QF W ZW< . Q~tY W d c~ ' Ea ' o< Z v d c ~ ', Y~ a 0 a ', v `m ~U H ~ ', d ~' m:: me ~o a o~ O a In O N O N ~ O ~ U ~ f O r0 V IJ MARK MCCLEEREY 1169 CROSS CREEK DR CITI CARDS MECHANICSBURGPA 17050-2019 P.O. BOX 182564 to O ~ ? o E ~ N H + tp ~ ~~ U ~ T ~ X ca ~ - o o, ° ns ~ a .. °` U a o v7 ? N N O j ~ > O a ° E >. ~ y ~ nN •L-. c Q` X O N X ~ .o O O .o N L G Q N n7 ~ 10 o u ar-~ ~ o m E~~ ~ ~~" a c'~ o via c a n .n .o ~ ~ ,~ > o o _ ~ a o ~ ova c ~ ~ d O N TQ~ - r0 > c ,D ~ V a O N d N N N ~ ~ O d ~ ~0 a) .- - a3 aaa r'^o u ai ~ °/ u ~ > 3 t a y v3 mEr V) 0. '~~. Ip T ` ~ W IA ~ ,p _ ~ o rh ,n - a~ O Q V V 0 ~ a 7 ~ ¢ O > S n ~ n Datatlf and fe11eM Myma,d Irotruttbm en ravana MakacMek payatla to:C~t~ Cer'd5 New Balance: r $26,685.34 8518 Minimum Payment Due: Amount Enclosed: $26,685.34 Payment Due Date: Payn,.,,~,,,,,s~kar«ati.aeys:oorM 07/03/2010 ` ~ laal tkne on tka paYmant tlua date. 000000 PM 32 A 0 O~N a K O W E > V Y~ `~ M O ` = M 0 O a Ew E d° o ~ ~ w, a° o o wr ~ O ~ r ~ O E ~ Cf C 'u ~Y ~ O a ~ ~ O O O N 3~ S o ~ O . 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Date (.'ei~7 _ ertwant Pin] __cYiecF a www.okkards.eom C OLU M BU 5, OH 43218-2564 ,.{,rj.~ EXH's"~3tT ~ {1 Verification I, Tien Reynolds , 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 cazd accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint aze true and correct upon my information and belief and aze made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~ ~~~~ Signature C-42369 Mark McCleerey Account number ending in 8518 1400 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Citibank (South Dakota) N.A. vs. Mark McCleerey 5 yt" .. FILED-OFFICE ?,_, i Idly PROTHO fl A 2u 10 DEC 30 PM 1 1 C191'BEREAh CU1..,_. OENNSYLYWA Case Number 2010-7749 SHERIFF'S RETURN OF SERVICE 12/27/2010 03:20 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on December 27, 2010 at 1520 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark McCleerey, by making known unto himself personally, at 1169 Cross Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. / r DENNIS FRY, DEPU SHERIFF COST: $37.00 December 28, 2010 SO ANSWERS, RONN` R ANDERSON, SHERIFF CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C") C ? V. NO. 10-7749 m? "M MARK MCCLEEREY 1169 Cross Creek Drive Mechanicsburg PA 17050-2019 rL?.y G a =-n C:5-n Defendant : CIVIL ACTION -LAW Zo oc7 te` -a Praecipe fo r Default Judgment rv S To the Prothonotary: _.e Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $26,685.34 $26,685.34 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 AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.R.CIV.P. 236 Pro Burton Neil & Associ C. By:_ Neil Sarker, 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-42369 OjK} fly. P0 td al? ?1??953b7 ?asv?84 C:ITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-7749 MARK MCCLEEREY Defendant : CIVIL ACTION - LAW TO: Mark McCleerey 1169 Cross Creek Drive Mechanicsburg PA 170502019 DATE OF NOTICE: January 19, 2011 IMPORTANT NOTICE C-42369 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. By: Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 i EC41.. 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. IN THE COURT OF COMMON PLEAS V. MARK MCCLEEREY Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7749 Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton Neil & Associates, P.C By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-42369 r2??zs?8.2?