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Home My WebLink About04-3823BURTON 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 CITFBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DENISE STARNER 405 CASCADE ROAD MECHANIC SBURG, PA Defendant NO. O 5t- S~,23 ~ '7-~ 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 wittfin (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 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 Association 32 S. Bedford Street, Carlisle, PA 17013 800-990-9108 10007.034.6411 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) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff IN* THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DENISE STARNER 405 CASCADE ROAD MECHANICSBURG, PENNSYLVANIA Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Siot~x Falls, South Dakota. 2. The defendant is DENISE STARNER, who resides at 405 CASCADE ROAD MECHANICSBURG, CUMBERLAND County, Pennsylvania. 3. Plaintiff, a national bm~ing 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 ora credit card with an account number 5424180782299165 hereinafter referred to as the credit card account. 5. Plaintiffmaintained an accurate and running record of all 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 plaintifffor 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 assemed and agreed to the correctness of the balance due on the credit card account so as to constitute an accotmt stated. 9. The amount due plaintiffon the account stated less credits, if any issued subsequent to the Exhibit A statement, is $9290.79 Wherefore, plaintiff demands judgment against the defandant for the sum of $9290.79 and the costs of this action. Burton Neil, Efquire Attorney for gqaintiff In making this communication, we advise our firm is a debt collector. 07/19/04 $9290.79 $9999.99 SITE:KC-CL DENISE STARNER ATTNY ACCOUNT-COD£=FN34 MECHANICSBURO 17055-5520000 Pa. ClTI CARDS P.O. BOX 8117 S HACKENSACK, NJ TM:CO-5000 o7/1~/o4 AC[D:KCB7150 19:38:ZZ: 07/19/04 $9?90.79 $9999.99 SITE:KC-CL DENISE STARN£R ATTNY ACCOUNT-CODE=FN34 MECHANICSBURG 17055-5520000 PA CZT! CARDS P.O. BOX 8117 S HACKENSACK, 07606-8117 NJ TM:CO-5000 07/13/04 ACID:KCB7150 19:38:22: Citi* Platinum Select* Card 5424 1807 8229 9165 Customer Ser~k=e:. :t- 800o950-5114 Total Credit Line $8000 I~OX 6SO0 Statement/ SIOUX FALLS, SD Closin Date 57117 06/Z4/2~04 $0 $2400 $0 $1290.79 $2938.75 $198.00 Help Js available! Please call the toll-free number shown above to learn about our special ~ayment o~tion$. Call Monday - Friday, 7 am to ~ pm, or ~aturday, 8 am to 5 pm, Central Time, Pleaae give us the opportunity to assist you. $9290,79 $9290.79 Previous (+) Purchases (-) Payments Account Summary Balance & Advances & Credits PURCHASES $7,245.53 $0.00 $0.00 ~OVANCES ~2,045.26 $0.00 tOTAL $9,290.79 $0.00 $0.00 Rata Summary ~URCHASES Standard Purch DVANCES Standard Adv Balance Su~ectto Finance Charge $0.00 $2.068.16 Periodic Rate 0.07668%(D) 0.07660%(0) (+) FINANCE (=) New CHARGE I~alance I O.O0 $7,245.53 0.00 $2,045.26 O, O0 $9,290.79 Days This Billing Per/od: 30 Nominal ANNUAL APR PERCENTAGERATE 27.990% 27.990% 27.990% 27.990% I::XHIBIT Verification SIJ,SAN 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. Account number: 5424180782299165 Defendant: DENISE STARNER SHERIFF'S RETURN - CASE NO: 2004-03823 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUNBERLAND CITIBANK SOUTH DAKOTA NA VS STARNER DENISE REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according says, the within COMPLAINT & NOTICE was served upon STARNER DENISE DEFENDANT , at 0942:00 HOURS, on the llth day of August at 405 CASCADE ROkO MECFIANICSBURG, PA 17055 by handing to DENISE STARNER a true and attested copy of COMPLAINT & NOTICE to law, the , 2004 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.14 Affidavit .00 Surcharge 10.00 .00 36.14 Sworn and Subscribed to before me this /~ day of So Answers: R. Thomas Kline 08/12/2004 URTON EIL & ASSOC Deput CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD 57117 : ]N THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-3823 DENISE STARNER 405 CASCADE ROAD MECHANICSBURG, PA 17055~5520 CIVIL ACTION - LAW Defendant Praeeipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the pla'tariff and against the defendant, and assess damages as follows: Principal: $9,290.79 Credit: $0.00 Attorney's Fees: $0.00 Total: $9,290.79 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 Sdrvicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the nfilitary service of the United States based on information received flora the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. ? BURTON*~EIL & ASSOCIATES, P.C. Burton ~el!r, E~tuire Attorney for P{aintiff Attorney I.D. 1~o. 11348 1060 Andrew EMve, Suite 170 West Chester, PA 19380 10007.034.6411 Burton Neil & Associates, P.C. is a debt collector CITIBANK (SOUTH DAKOTA) N,A. Plaintiff VS. DENISE STARNER Defendm~t : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3823 : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: DENISE STARNER 405 CASCADE ROAD MECHANICSBURG, PA 17055-5520 DATE OF NOTICE: September 09, 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 find out where you can get legal help. This office canprovide 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 Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 800-990-9108 ? BUP~,~t~DN NElL & ASSOCIATES, P.C. ......... B'~:~on Nell, Esquire Attorney [or Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 In making this communication, we advise that this off'me is a debt collector. BURTON NElL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 6I 0-696~2120 Attorney for Pla/nti£f CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD 57117 Plaintiff VS. DENISE STARNER 405 CASCADE ROAD MECHAN/CSBURG, pA 17055-5520 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3823 BURTON NElL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA ~9380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60th STREET NORTH SIOUX FALLS, SD 57117 Plaintiff VS. DENISE STARNER 405 CASCADE ROAD MECHANICSBURG, PA 17055-5520 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3823 : 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 ~2-e~<~ ~qg!w[~L.~l~' o~ ~O0 ¢ Prothonotars' 6C.--lt-L- D~uty If you have any questions concerning the above, please contact: Burton Nell, Esquire ,Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 In making this communication, we advise that our firm is a debt collector.