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HomeMy WebLinkAbout11-1210L 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 v'L 13 T 11'0' IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA E SULLIVAN : NO. Ci mTe r m 24 Gale Road Camp Hill PA 170112619 Defendant 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-46876 Qvv?®q D.06 Pa 00!J C? 94W vi*26y535 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. LAURA E SULLIVAN 24 Gale Road Camp Hill PA 170112619 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 Laura E Sullivan, who resides at 24 Gale 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 VISA credit card with account number ending in 3623 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 $6,156.96 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 $6,156.96, and the costs of this action. Neilt4 Ass ' s, P.C. Y D. Weinstein, Esquire rney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt M X DAD 0 X D C O n O- N r w Z ° ' = r 00 -• E a Account Activity A N< 0C- N a a co 3 - - Aug 18-Sep 16, 2010 ? b a O W a w < D O ° a Minimum Payment Due: New Balance: 0 Z 0 0 3 Summary of Account Activity N d !? 3 - $6,156.96 $6,156.96 Previous Balance $5.9x2173 ° Payment Due Date: Payments -$0.00 by 5:00 PM 10/14/2010 ay i Other Credits l date. me on the payment due Pu rchases +$000 Late Payment warning: If we do not receive your Cash Advances +$0.00 minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs mayy Fees Charged ' +$25.00 be increased up to the variable Penalty APR of 29.99%. Interest Charged +$149.23 C3 Ir g Minimum Payment Warning: If you make only the New Balance 6,156.96 minimum payment each period, you will pay more in Past Due Amount $1,370.23 Cr interest and it will take you longer to pay off your ..L balance. For example: Amt. Over Credit Limit $1,056.96 D' E If you make no You will pay off And you will end additional charges the balance shown up paying an Credit Limit $5,100 k- using this card and on this statement estimated total Available Credit $0 t.+ F each month you pay... In about... of... Cash Advance Limit $600 P 0 r 0 Q' (r Only the minimum 1 month(s) $6,157 Available Cash Limit $0 . _ i o n payment Statement Closing Dale 09/16/2010 CD x ;o C -O For information about credit counseling services, call 1-877-337-8188. Days In BIIIIng Cycle 30 N C3 im A C3 r o w N Cr C3 z N v °' 3 C3 i Z a ?3 ' ?? r C3 e ru e n? m o 2 m ? i ? r 6, n tn x Iof2 www.citlcl rds.com How to Reach Us Account Member 1-800-756-4000 LAURA E SULLIVAN Customer Service Account Number BOX 6500 3623 SIOUX FALLS, SD 57117 Important Changes to Your Account: We changed our fee structure. This change does not result in an increase in fees and in many cases will reduce the fees you currently pay for late and returned payments. Below, we summarize the new fee structure that began on 08/22/2010. Late Payment Fee For the first late payment: Up to $15 on balances up to $100.00 Up to $25 on balances of $100.00 and over For each additional late payment during the next six billing cycles: Up to $15 on balances up to $100.00 Up to $29 on balances of $100.00 Lip to $250.00 - Up to $35 on balances of $250.00 and over Return Payment Fee Up to $25 for the first returned payment Up to $35 for each additional returned payment during the next six billing cycles If you have any questions about the impact to your account, please call 1-800-756-4000. Sale Post Description Amount 09/16 1 ATF FFF - AI Ir, P A V MF n1T PACT nl it oc n TOTAL FEES FOR THIS PERIOD 25,00 Interest Charged Post Description Amount 09/16 INTEREST CHARGED TO STANDARD PURCH 149.23 TOTAL INTEREST FOR THIS PERIOD 149.23 2010 Totals Year-to-Date Total Fees charged in 2010 $337.00 Total Interest charged in 2010 $1,195.86 How to Reach Us 1-800-756-4000 Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 **** **** **** 3623 Access your account online: www.citicards.com Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual Interest rate on your account. Annual Percentage Balance Subtect to Type of Balance _ Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 29.990% (V) $6,054.55 (D) $149.23 ADVANCES Standard Adv 29.990% (V) $0.00 (D) $0.00 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 pin, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 1010712010 to allow for enough time for regular mail to reach us. 2of2 Verification 1, Abbie Motley , 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 unworn falsification to authorities. C-46876 Laura E Sullivan Account number ending in 3623 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??of euni?rr? FILED FFI 2911 FEB I I Pik 1* I S CUMBERLANI Citibank (South Dakota) N.A. I 201Case1-1210 Number vs. Laura E. Sullivan SHERIFF'S RETURN OF SERVICE 02/09/2011 10:38 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 9, 2011 at 1038 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laura E. Sullivan, by making known unto Donald Bender, Husband of defendant at 24 Gale Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. L %, MICHELE SH LL, DEPUTY SHERIFF COST: $41.50 February 10, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF J 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. 11-1210-CT LAURA E SULLIVAN 177, 24 Gale Road Camp Hill PA 170112619 cv ?+ Defendant : CIVIL ACTION - LAW _rn ? r' a r-g-t ? cry ru -? ? Praecipe for Default Judgment r- To the Prothonotary: C:) Yi -: . F , c , Please enter judgment by default for want of an answer in the above case in fa a ofi& y' plaintiff and against the defendant, and assess damages as follows: - Principal: $6,156.96 Less Credits: $300.00 TOTAL $5,856.96 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. ICE GIVEN UNDER PA.R.CIV.P. 236 rothono Burton Meil &/AA(ciates, P.C. By: The law firm of Burton Neil & Associates is a debt collector. C-46876 Ya1fD1/ Wein,, eein, Esquire I. NO. 89678 11660 Andrew Drive, Suite 170 West Chester, PA 19380 0?? ?V't 00 3 at? C? as ? 5?7 ",A' Ce ow W'6 r CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. LAURA E SULLIVAN Defendant TO: Laura E Sullivan 24 Gale Road Camp Hill PA 170112619 DATE OF NOTICE: March 04, 2011 IN THE COURT OF COMMON PLEAS C-46876 : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-1210-CT CIVIL ACTION - LAW IMPORTANT NOTICE 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 P.C. Andrew Drive, Suite 170 West Chester, PA 19380 In making this communication, we advise our office is a (610) 696-2120 debt collector. By: Yale eins in, Atto y for Pl t Id fication No. 89678 1 0 a 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. 11-1210-CT LAURA E SULLIVAN 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 ?\r C.?l? ?-\ , ?p1 By: Deputy If you have any questions concerning the above, please Yale D. Weinstein, 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.