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Home My WebLink About11-1209i ILL Lf- l.:f TJI? iY.. { 1 - ? r i?`IY? t 2091 Fr-? -2 :.F' 10: Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. JEANNE A SHEARER 416 N Front Street, Lemoyne PA 170431114 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. -Tif rm : 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-47136 q 2.00 ?d a ?Ryay? R ?' ?S?{53 y Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. JEANNE A SHEARER 416 N Front Street, Lemoyne PA 170431114 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 Jeanne A Shearer, who resides at 416 N Front Street, 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 5166 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 $14,801.92 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 $14,801.92, and the costs of this action. Burton 161 466sOciates, P.C. By: We stein, Esquire or Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt Q z vv f A M O 00 p Z Z '? y N 3 N E 3Tz p &< A ?. A F 3 E M A o 0) 3 0 w o > v{,zy 3 C ?. 3 n C 0 m y 0 cO N to N o N rs n D N m a m O D to m 3 E - A =t 0 A m v ? Z. r) n -U r7 Oa-4 Cm r1 3 O D W X A c-?o (/r m N N O N xrn A N CD N 01 A n m3 0 3 n o 3 A 6 VI P R (7 rt n a CL N 3 u 0 t 3 www.cltlcards.com Account Member JEANNE A SHEARER How To Reach Us 1800-866-9900 Customer Service BOX 6500 SIOUX FALLS, SD 57117 Account Activity umber Sep 24-Oct 25, 2010 5166 Member Since 1981 Minimum Payment Due: New Balance: Summary of Account Activity $14,801.92 $14,801.92 Previous Balance $14,620.58 Fees Payment Due Date: Payments -$0.00 Sale Post Description Amount 11/21/2010 payment must be received by &,00 Other Credits -S0.00 10/25 LATE FEE SEP PAYMENT PAST DUE 35.00 PM local time on the payment due Late Pa ment Warnin fi d t i Purchases Cash Advance +$0.00 +$0 00 TOTAL FEES FOR THIS PERIOD 35.00 y g e o no rece ve your minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may s Fees Charged . - +$35-00 Interest Charged be increased up to the variable Penalty APR of 28.99%. Interest Charged +$146.34 New Balance 14,801.92 Post Description Amount Minimum Payment Warning: If you make only the 10/25 INTEREST CHARGED TO STANDARD PORCH 2.60 minimum payment each period, you will pay more in Past Due Amount $1,244.14 10/25 INTEREST CHARGED TO PUR PR-07/14/10. 143.74 interest and it will take you longer to pay off your b l f l Amt. Over Credit Limit $491.92 TOTAL INTEREST FOR THIS PERIOD 146.34 a ance. or examp e: If you make no You will pay off And you will and Credit Limit $14 310 additional charges the balance shown up paying an , using this card and on this statement estimated total Available Credit SO each month you pay... In about._ of... Cash Advance Limit 510,300 Only the minimum 1 month(s) $14802 Available Cash Limit $0 payment Statement Closing Date 10/25/2010 For information about credit counseling services, call 1-877-337-8180. Days In Billing Cycle 32 1 012 2010 Totals Year-to-Date Total fees charged In 2010 $173.00 Total Interest charged In 2010 $1,538.71 Interest Charge Calculation ::: Your Annual Percentage Rate (A PR)ls the annual interest rate on your account. 9 Annual Percentage lance Subject to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 28.990% (V) $102.19 (D) $2.60 Purch Prior 07/14/10 11.240% (V) $14,589.15 (D) $143.74 ADVANCES Standard Adv 28.990% (V) $0.00 (D) $0.00 ers avai special Account labie! Plees call the pm, cent'Ylment options toll-free Nu+nber Time. Ptea Call Monda numbers ' «' ''•• 5166 - Fria how re se give us the opportunity top 0? PM, Of, S t 0 about our Please be su afear mail it no later to 11 on time. You. Y 6 urd am to S than 71/14/ZO10 to a?low for r@ ouch atime y fo?be mail, we suggest 9ular mail to reach us. 0 to Reach 1- s p-866-acq 0 Cust S1 56 6 ? 3ervlce S10UX FgLLS, Sp 57,17 Access Your account online: www.citlcards,corn 2 of 2 Verification Leda Phenix 1, , 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. Si e C-47136 Jeanne A Shearer Account number ending in 5166 1008 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c Sheriff d` Jody S Smith Loll, Chief Deputy 2,311 FEB -8 A 9: 1 t Richard W Stewart CUMBEPZLAt?J' +,OiJ -w Solicitor PENNS`i'LVAI'''1 =. Citibank (South Dakota) N.A. Case Number vs. Jeanne A. Shearer 2011-1209 SHERIFF'S RETURN OF SERVICE 02/04/2011 07:18 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2011 at 1918 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeanne A. Shearer, by making known unto herself personally, at 416 N. Front Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the sa444PUTY SHERIFF COST: $42.40 February 07, 2011 SO ANSWERS, l RON R ANDERSON, SHERIFF CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JEANNE A SHEARER 416 N Front Street Lemoyne PA 170431114 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-1209-CT CIVIL ACTION - LAW Praecipe for Default Judgment ':7 N ray w a c n r--:;= ,cam C- -? -mac' CD ) C? ;C 77 C r ? -o rs . 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 $14,801.92 $14,801.92 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 7e d on information received from the defendant and/or the Department of Defense websit? JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. GIVEN UNDER PA.R.CIV.P. 236 Pr Pr onotary The law firm of Burton Neil & Associates is a debt collector. C-47136 Associates, P.C. Y D einstein, Esquire orney for Plaintiff I NO. 89678 060 Andrew Drive, Suite 170 West Chester, PA 19380 OLwk? X14: eu t?d at a R°11g1O eZ57 i49 ?pWcx M4 te'8 CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-1209-CT JEANNE A SHEARER Defendant : CIVIL ACTION - LAW TO: Jeanne A Shearer 416 N Front Street Lemoyne PA 170431114 DATE OF NOTICE: March 11, 2011 IMPORTANT NOTICE C47136 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 Burtony it & ANWates, P.C. Yali' D. '% ation No-89678 106 Andrew Drive, suite 170 W st Chester, PA 19.380 In making this communication, we advise our office is a (610) 696-2120 debt collector. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. JEANNE A SHEARER Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 1 I Prothono By: If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-1209-CT Defendant : CIVIL ACTION -LAW The law firm of Burton Neil & Associates is a debt collector. y 2G13 MAY 23 PM 3: 22 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil &Associates,P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. 11-1209-CT JEANNE A SHEARER Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Bur o Neil & sso fates, P.C. By: e D. Wei tein, Esquire A orne r 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-47136 /318 1� l a