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Home My WebLink About04-3824BURTON NElL & 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, SD Pla'mtiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DILIP R ABAYASEKARA 17 ROUND HILL ROAD CAMP HILL, 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 OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROV/DE 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 10007.034.6872 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 $3851.59 Wherefore, plaintiff demands judgrnent against the defendant for the sttrn of $3851.59 and the costs of this action. BU~RT~t~ AS S OCIATES, Bv?'~ Burton Neil, Esquire Attorney £or Plaintiff In making this communication, we advise our finn is a debt collector. 12/08/03 $4021o98 $9999.99 SITE;KC-CL TM:CO-5000 ACID:KCB3074 ~::'-:,:-=-:-:-:-'<-:<-':~:'-z:-:-":-;:::;::: <-":-'-:-:':-:-:-:-'-=':-:-:-:-:'~-':-":':-~ 01/26/04 16:31:36' DILIP R ABAYASEKARA ATTNY ACCOUNT-CODE=FN34 CAMP HILL 17011-2636000 PA P.O. BOX 8105 5 HACKENSACK, NJ 07606-$108 CitF Driver's Edcje Card Charter Rebates 54Z4 1800 3654 0836 3.1/1,2/2003 $6800 $0 Credit Llae $o.oo 1-800- 568-5000 Ter e~'t ~1~atrial- ~Ite BOX 6500 tet~.a~e~.~l SIOUX FALLS, SD $6800 $0 $4021.98 $399.00 $83.00 $4021.98 Help is available} Please call the toll-free number shown above to learn about our special payment o~tions. Call ~onday - Friday, 7 am to y pm or ~aturday, 8 am to S pm, Central Time. P ease qive us the opportunity to assist you. Previous (+) Purchases (-)Payments :ountSummarv Balance & Advances & Credits CHASES $4,021.98 $0.00 $0,00 0.00 ~NCES $0.00 $ $o.o0 ~0.00 ~L $4,021,98 $0.00 ~alance Subject to Periodic ~ Summary Finance Charge Rate ~ASES ~dard Purch $0.00 0.05425%(0) iCES ~dard Adv $0.00 0.0S42B%(0) (+) FINANCE (=) Hew CHARGE Oa[ance 0.00 $0.00 ~0.00 $4,021,98 $0.00 $4,021.98 OaysThls Billing Perlocl: 29 Nominal ANNUAL APR PERCENTAGE RATE 19.800% 19.800% 19.800% 19.800% EXHIBIT Verification Tara Cross is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Cifigroup, 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 unswom falsification to authorities. Account number: 5424180036540836 Defendant: DILIP R ABAYASEKARA SHERIFF'S RETURN - CASE NO: 2004-03824 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS ABAYASEKARA DILIP R REGUI2tR DAVID MCKIN-NEY , Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE ABAYASEKARA DILIP R DEFENDANT , at 1403:00 HOURS, at 17 ROUND HILL ROAD CAMP HILL, PA 17011 SHARON ABAYASEKARA, WIFE a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 26th day of August , 2004 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.36 Affidavit .00 Surcharge 10.00 .00 38.36 Sworn and Subscribed to before me this /~ day of rot ~~ ~2~, '/' A.D. honotary -- So Answers: R. Thomas 08/27/2004 BURTON NEIL By: Kline & ASSOC BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19382 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (sOUTH DAKOTA), N.A. Plaintiff VS. DILIP R ABAYASEKARA Defendant IN THE cOURT OF COMMON PLEAS cuMBERLAND COUNTY, PENNSYLVANIA NO. 04-3824 : CIVIL ACTION - LAW PRAECIPE TO SETTLE, END & DISCONTINUE TO THE PROTHONOTARY: Mark the above matter Settled, Ended and Discontinued. BURTOI~'~IL & ASSOCIATES, P.C. / Burton Nell, Esq._e_ Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. 7.6872