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Home My WebLink About04-3822BURTON 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) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COLrNTY, PENNSYLVANIA KAREN C MYER 410B NORTH ENOLA DRIVE ENOLA, PA 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H/RING 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 Association 32 S. Bedford Street, Carlisle, PA 17013 800-990-9108 10007.034.7071 BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff : IN' THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA KAREN C MYER 410B NORTH ENOLA DRIVE ENOLA, PENNSYLVANIA Defendant : NO. 0 '-3Va 'F'o.- : 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 Fails, South Dakota. 2. The defendant is KAREN C MYER, who resides at 410B NORTH ENOLA DRIVE ENOLA, 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 5424180158694841 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of ail debits and credits to the credit card account in its books of account. 6. Plaintiffmailed 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 correchaess 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 $10612.00 Wherefore, plaintiff demands judgment against the defendant for the sum of $10612.00 and the costs of this action. In making this communication, we advise our firm is a debt collector. Verification Tara ¢~'055 . ~s 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 s~atements of fact made in the foregoing Complaint arc tmc and correct to thc best of her knowledge and belief. The undersigned understands that the statements made herein arc subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: Account number: 5424180158694841 Defendant: KAREN C MYER SHERIFF' S RETURN CASE NO: 2004-03822 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MYER KAREN C - REGULAR SHANNON K. SHERTZER , Cumberland County, Pennsylvania, says, the within NOTICE MYER KAREN C DEFENDANT , at 0020:00 HOURS, at 30 LANCASTER AVE ENOLA, PA 17025 KAREN MYER a true and attested copy of NOTICE COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to was served upon the on the 16th day of August by handing to together with law, , 2004 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.10 Affidavit .00 Surcharge 10.00 .00 39.10 Sworn and Subscribed to before me this /~.~ day of ~_~_.. ~_~D ~ A.D. , P~rotHonotary ' So Answers: 08/17/2004 BURTON NEIL & ASSOCIATES By: ~De~puty~ S er~zff BURTON NElL & AS. SOCIATES, P.C. BY: BurtonNeil, Esquire identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (soUTH DAKOTA), N.A. Plaintiff IN THE cOURT OF coMMON PLEAS cUMBERLAND coUNTY, pENNSYLVANIA VS. NO. 04-3822 KAREN C MYER Defendant CIVIL ACTION - LAW pRAECIPE TO DISCONTINUE- TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTO~~SSOCiATES, P.C. Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector 7.7071