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Home My WebLink About01-2772 VALERIE ROSENBLUTH PARK, ESQUIP~E Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBEPJ~a/~D COUNTY COURT OF CO~4ON PLEAS CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. Defendant NO. O'- ~77~ ~O[~ ~--~ 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 twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims 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 other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TA/(E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C49 TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A~-ENI/E CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE HOSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT# :4128003355833784 ~u~BERLAND COUNTY COURT OF COMMON PLEA~ CITIBANK (SOUTH DAKOTA) N.A. 7920 NW ll0TH ST. KANSAS CITY, MO 64153 PLAINTIFF VS KATHY KEAN 111 FAIRVIEW DRIVE CAMP HILL, PA 17011-S312 DEFENDANT NO. ~ !- 2 7 7~ ~ ~/'~ CIVIL A ION-LAW 1. The Plaintiff is Citibank (South Dakota) N.A., ~ nationally charted banking institution with a place of busines located at 3940 Olympic Blvd. Erlanger, KY 41018 2. The Defendant is KATHy KEAN, with a place of residence located at 111 FAIRVIEW DRIVE CAMP HILL, PA 17011-8312 . CODI~T i - CONTI~ACT 3. At the request of the Defendant, Plaintiff issued to Defendant a credit card, account 4128003355833784; and at all times relevant THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAIIFED WILL BE USED FOR THAT PURPOSE. hereto, Defendant was. the holder of said card issued through the Plaintiff's credit facilities. 4. Defendant, upon acceptance and use of the Plaintiff,s credit card, agreed to be bound by the terms and conditions of Plaintiff's revolving credit plan. A true and correct copy of said Agreement is attached hereto, made a part hereof and marked Exhibit "A". 5. The Defendant subsequently used the said credit card. As of 09/21/2000, the Defendant had incurred charges in the sum of $3,462.46. Defendant may be entitled to payments made after 09/21/2000 which will be credited at the time of judgment. 6. In accordance with the terms of Exhibit "A", the Defendant agreed to pay the Plaintiff a finance/service charge on all sums due at an annual percentage rate of 22.40 and the Plaintiff is entitled to additional finance/service charges from 09/21/2000. 7. In accordance with the terms of Exhibit "A", Defendant agreed to pay Plaintiff a reasonable attorney,s fee if the account was referred to an attorney for collection and Plaintiff will incur an attorney,s fee in the amount of $865.00. WHEREFORE, Plaintiff demands judgment against the defendant in the sum of $3,462.46 plus attorney's fees of $865.00 plus interest from 09/21/2000'at the contract rate and cost of this action, less payments made, plus costs and any other such relief as this Court deems reasonable and just. THIS IS AN ATT~PT TO COLLECT A DEBT. ANY INFORMATION OETAINED WILL BE USED FOR THAT PURPOSE. COURT II UNJUST m~_!~M~m~T 8. Plaintiff hereby incorporates paragraphs i through 7 above as though set forth in full. 9. The Defendant received a monetary benefit, which was in fact appreciated bythe Defendant. 10. The Defendant accepted the benefits. 11. By virtue of the circumstances surrounding the request for funds made, the Defendant knowingly requested the funds at issue and/or knowingly and voluntarily accepted the benefits bestowed. 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands judgment against the defendant in the sum of $3,462.46 plus attorney's fees of $865.00 plus interest from 09/21/2000 at the contract rate and cost of this action, less payments made, plus costs and any other such relief as this Court deems reasonable and just. Respectfully submitted: PARK~' BY: VALERIE ROSENBLUTH PARK, ESQ. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. AFFIDAVIT STATE OF MISSOURI COUNTY OF PLATTE, TO-WIT: On this I ~-~ day of OCTOBER . 2000, came before me, a Notary Public in the jurisdiction aforementioned, JEANKTTE M. BROWN . who, after being duly sworn, deposes ns follows: I, JEANE'I'FE M. BROWN , hereby certify that I nm a Manager of Citicorp Credit Services. Inc.; that I am authorized to execute this Affidavit on behalfofCitibnnk (South Dukotu}, N.A.: that I make this affidavit of my own personal knowledge and am competent to testify to all matters contained herein; that I am personally familiar with Account No. 412800335S833784 ; that the defendunt signed nn Application for Credit which forms the basis for this uccount; that Kuthy Kean used or authorized use of said credit account for the purchase of goods and/or services sad cash advances; that the existing balance of the account is S 3~162.ZI6 ; that demnnd has been made upon Kathy Kean for puyment of this amount: that Kathy Keen was sent a copy of the Disclosure Statement with the credit enid; that payment has not been made pursuant fo the agreement between the parties and that said amount, plus continuing interest nnd attorney's fees is due and owing lo Citibank (South Dakote), N.A.; thor I have made diligent search and inquiry to determine whether the defendant, Kathy Kenn , is in the military service of the United States of America; sad, us u result of such search and inquiry, huve determined and ascertained that the said defendant is not in the military services of the United Sfutes nnd is not entitled to any of the rights nnd privileges as prescribed under the Soldiers and Sailors Civil Relief Act of 1940, ns amended. I certify the above to be true and correct to the best of my knowledge and belief. ,~CITICORP CREDIT SERVICES, INC. ~ MANAGER under limited power ofafforney for CITIBANK (SOUTH DAKOTA), N.A. STATE OF MISSOURI COUNTY OF PLATTE, TO-WIT: The foregoing Affidavit was acknowledged before me this / ~" day of OCTOBER 2000, by JEANETTE M. BROWN , whose title is MANAGER , on behalf of Citibank (South Dakota), N.A., a South Dakota corporation, on behalfofthe corporation. Given under my hand this /~- day of 00. My commission expires: ~20 ~ .... I NOT~RY PUBLIC EXHIBIT ili I ,--k!-iLr m .... il,'. l~,~ ..... Il · · :Il: :::: '. :..:l il! , . .. :'"''il i !' [ & I I ': l,_l]l,, ,!~,l]l I !iiir."lll i ~,'i ,:, i ! ' r r~lq ~'I "- , i , Il,, , , , i , i ,::: l:l: ill, IjlJ ,jililll, [[!:Il J l ljJllJ: - Il ' I I II ,, IlL , ,, , : ! , I I.:j l,, :!l- l: i: : ,IIJ ~' :,,,:,,, .-il, ;.'!~._ i ,.:,, ...... l il !l!![l! Il!'., I[i illli i!11 l!ll I-,'1 '.4 il'Il Il! Il I: ljj::l:j ii!~i!:;tliJi,l::l~!,::t ILl ,,,,,,~,!,.-,I,~I! ~:1 I I:l:l l,I I I J iii.ti !: : .i,: ! II Il_ I: ~j 111, jl~. !1,It, :! ~t. ,I,. ,:i:.t, ,,[ i: , j[., I,,[,l, .:.",,.,:.l, '-.--,,i:.J..'::,:' i it! ~, , ,,: .~ ,l , i ', [.,. ,I ,,, ,i,, :I ,,I, · II.l, Il I ., b,J, ,tib, t., . :: .. . t[,. ill , ,l l_,', ,I Ii, l'i ,,. :, ,. ., II i , tI,: r'..[ ! .i ,,1 ,;, t li ' I[' i :il ,.-ii ~. Ij I~J J ilJ. J J ~ J JJ ' '~iI l!lil Il I ji. ijjijj ,,1 ',, ,lIt , ii .I ,i li i " ""'"' '"" '"' , , l,· J, hr ItBj t t, [,. . , ~ ,. !,. ,,, ,,ill 1t 11.,,,..,Iff, ,,i~hl, ,i ,, .1 ,. ,l,.j ,.! i. ,. i,l,i i,,ll.J i.I, i. I,..1I .,,I ,, , .I ,.j, ii,iitljl ii Ig itl, J Jill !i rJ ""1 !1' ~,t l,,,., ,,1 ,1~, l[Jll} l J ll'li il[ !Jll ,,, ., ,. !~1,.. u~ .,i, SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-02772 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS KEAN KATHY R. Thomas Kline ,Sheriff or Deputy Sheriff, who bein9 duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT KEAN KATHY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , , NOT FOUND , as to the within named DEFENDANT , KEAN KATHY THIS ADDESS IS IN YORK COUNTY Sheriff's Costs: So answe~.~ .... ' Docketin9 18.00 ~" -~ ..-. Service .00 --'/~'~'~~-" Affidavit .00 R. ~homa.~ Kline Surcharge 10.00 Sheriff of Cumberland County .00 28.00 PARK LAW ASSOCIATES 05/14/2001 Sworn and subscribed to before me this ~ ~ ~- day of Profhdnot ary ! HEREBY CERTIFY THAT THE '~iTHIN~,/ lB ATRUE AND CORRECT COPY.,OF RE RD 25 East State Street ~ ~ ~ ~ ~ ~, ~. P.O. Box 1779 ~ Doylesto~, PA 18901 (215) 348-5200 A~O~Y ~R P~I~IFF ~~ CO~Y CO~T OF CO~N PL~ CITI~ (SO~ ~OTA) N.A. Plaintiff VS. ~Y ~ ~ NOTI~ You ~ve been sued ~n Court. If ~u wish to defe~ agai~t =he claims set forth in ~he foll~ng pages, ~u mus~ take action within twenty (20) ~ after this Complaint ~d Notice are se~ed, ~ entering a written apBear~ce perso~11y or ~ ~ atto~ey ~d filing in ~ting with the Cou~ ~r defenses or objections to the claims set for=h against ~. You are wa~ed t~t if ~u fail to do so, the case ~y proceed without ~ ~d a Ju~ent ~y ~ entered against you ~ the Court wit~t fur=her ~tice for ~y money claimed in the C~plaint or for o~her claims or relief re~ested ~ the Plaintiff. You ~y lose money or proper~y or other rights i~ort~t to ~u. YOU SHO~ T~ T;IS P~ ~ YO~ ~ AT ~. IF YOU DO ~T ~ A ~ OH ~T ~ 0~, ~ ~, OH T~EPHO~ ~E OFFI~ SET ~R~ B~W TO FI~ O~ ~ YOU ~ GET L~ ~LP. ~~ ~ ~ ~SOCIATION 2 LIB~ A~ ~IS~, PA 17013 (717) 249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OETAZNED NZLL BE USED FOR THAT PDI~POSE. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200) ATTORNEY FOR PLAINTIFF CUMBEP. LAND COURT OF C0~MON PLEAS CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. KATHY KEAN Defendant NO. 01-2772 PR~ECIPE TO DiSCOI~TIN0m WITHOUT PREJ1]DICE TO THE PROTHONOTARY: Kindly discontinue the above captioned matter, without prejudice. PARK LAW ASSOCIATES P.C. BY: ~ VALERIE ROSENBLUTH PARK, ESQ.