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Home My WebLink About04-3819 BURTON NEIL & ASSOCIATES, P.c. By: Burton Neil Identification No, 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff eITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 0'1. 33/1 ~ "-p.. MICHAEL D TRiTT 1 FORESTRY ROAD SHlPPENSBURG, PA : CIVIL ACTION - LAW Defendant 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 f1ling 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 LAW1 OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,- OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Association 32 S. Bedford Street, Carlisle, P A 17013 800-990-9108 10007.034.5994 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) NA 701 EAST 60th STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 0'1- 3? ,q G;J. lLo-" MICHAEL D TRITT 1 FORESTRY ROAD SillPPENSBURG, PENNSYLVANIA Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N A, with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is MlCHAEL D TRlTT, who resides at 1 FORESTRY ROAD SHIPPENSBURG, CUMBERLAND County, Pennsylvania. 3. Plaintiff, a national banking association, engages 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 credit card with an account number 5424180547742475 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing cycle. 7. Defendant received the monthly statements from plaintiff for the credit card account, including the statement attached as Exhibit A, without protest, dispute or objection. 8. Defendant, by not protesting, disputing, or objecting to the statements including the Exhibit A statement, thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated less credits, if any issued subsequent to the Exhibit A statement, is $6096.27 Wherefore, plaintiff demands judgment against the defendant for the sum of $6096.27 and the costs of this action. \ ........ BURT NEIL & ASSO By: ~/.. Burton Nei~qU1 Attorney for Plain ff In making this communication, we advise our firm is a debt collector. 08/03/04 iWi.~'m@ $6096.27 $9999.99 ~~:~~fmn#t~~ ~t'~~~~~l SITE: KC-CL TM:CO-5000 07/13/04 ACID:KC87150 19:38:22: MICHAEL D TRITT ATTNY ACCOUNT-CODE=FN34 SHIPPENS8URG 17257.9683000 CITI CARDS P.O. BOX 8106 S HACKENSACK, NJ 07606-8106 PA Citl"' Platinum Select"' Card _. Cltl AccoUl"lt Number 5424 1805 4774 2475 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS, SD 57117 Sa. Dllte Post Date R.'.rene& Numb., Tot.' Credit line $9300 St..ttmentl Closln9 Date 07/09/2004 "nl~blt Credit line t..sh Advante limit $0 $3300 Amount O.".r ~redlt Line Past Due JO.OO $1795.14 Activity Since lest Statement A....allable Cash LImit $0 Purcl\/AdV h1.1nlmum Due un.oo Me..., hlance $6096.21 Minimum Amount Due $6096.21 ....."' 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. Please see the enclosed privacy notice for important ; nformati on. Account SUmmary PURCHASES ADVANCES TOTAL ~r.vious B~lanc. $6,096.27 $0.00 $6,096.27 (ot) Purchases & Advances 10.00 0.00 0.00 (-) Poymonts & Crodlts 10.00 0.00 0.00 (+) FINANCE CHARGE 10.00 0.00 0.00 (0) Now B!llance $6,096.27 $0.00 $6,096.27 Rate Summery PURCHASES Standard Purch ADVANCES Standard Adv Balanct Subject to FInance Charge Periodic Rete Days This Bllllf'lQ P.rlod: 31 Nomin.1 ANNUAL APR PERCENTAGE RATE $0.00 $0.00 0.82500%(M) 0.02712%( F) 9.900% 9.900% 9.900% 9.900% EXHiBiT -A Verification SUSAN CAREY is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Citigroup, the within Plaintiff in this action. She/he verifies that the statements of fact made in the foregoing Complaint are true and correct to the best of her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: J JdB 10--1 k Account number: 5424180547742475 Defendant: MICHAEL D TRITT ,- r.,...) C::,} (: p ~ ~ C:..) -h ~- -i"',", ::;1 \\-j 8' Jf ,., 1;: ~ , ""' ..f; .. -<) '"" V-" '-... V\. ., ~ 1">.'"} ,..\ r<} D c,..:; SHERIFF'S RETURN - REGULAR CASE NO: 2004-03819 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS TRITT MICHAEL D DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsy1vania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE TRITT MICHAEL D was served upon the DEFENDANT , at 1953:00 HOURS, on the 1st day of September, 2004 at 1 FORESTRY ROAD SHIPPENSBURG, PA 17257 MICHAEL D. TRITT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.84 .00 10.00 .00 39.84 Sworn and Subscribed to before me this 'J e day of ~.k.....- .,,2(1"0'1 A.D. Q t2 ~ ~- r6thonotary , So Answers: .~f2~~~<~ R. Thomas Kline 09/02/2004 BURTON NEIL & ASSOC By: p-,~?t ' Deputy She~ CITmANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD 57117 : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04.3819 MICHAEL D TRITT I FORESTRY ROAD SHIPPENSBURG, PA 17257-9683 : CIVIL ACTION - LAW Defendant Praecipe for Default Judgment To the Prothonotary: 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: Credit: Attorney's Fees: Total: $6,096.27 $0.00 $0.00 $6,096.27 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: I. 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 of2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defen t and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UND~R P~CIV.P.236 ChA~~ K .0~_ Pro Prothonotary {T"- B Tor... '.' & ASSOCIATES, P.C. BY:'\ Burton N ii, Esquire Attorney for Plaintiff Attorney I.D. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 10007.034.5994 Burton Neil & Associates, P.C. is a debt collector CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. Defendant : NO. 04-3819 : CIVIL ACTION - LAW MICHAEL D TRITT Notice of Intention to File Praecipe for Default Judgment TO: MICHAEL D TRITT I FORESTRY ROAD SIDPPENSBURG, PA 17257-9683 DATE OF NOTICE: September 28,2004 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 obligations 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to [md out where you can get legal help. This office canprovide you with infonnation about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with infonnation about agencies that may offer legal services to eligible persons at a reduced fee or no fee. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 800-990-9108 '----.. NNEIL & ASSOCIATES, P.C. BY: / __ 0 ~SqUire . Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 In making this communication, we advise that this office is a debt collector. r~ii; B" --- '-> D- r' ~ ::: 3 CI) ~ ac) Ill" CI) ~~ ~ ~ i: ~ ~ BURTON NEIL & ASSOCIATES, P.C. By Burton Neil, Esquire Identification No. 11348 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 VS. : NO. 04-3819 MICHAEL D TRITT Defendant : CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Mark the judgment Satisfied On payment of your costs only. L & ASSOCIATES, P.C. --~.--_.-. By: Burton Neil, Esqu're Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. T -3067 1111111111111111111111111111111111111111 111111111111111111111111111111111111111111111111111I11111111111111111111111111111111111111111111111111111 ,...., = = """ <./l rn -0 -, ~- -""' 0-'''-- I'.:> ...s::> ~ ~.." rt"'\r=- :gEJ ~~,~7_ -~':'",\ C}(') cC-rTI 9 -; :'0 -< -:::' :;:- <.,.)