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Home My WebLink About04-3825BURTON 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 COUNTY, PENNSYLVANI/ CHRISTINE M MARTIN 913 SCOTISH COURT MECHANICSBURG, 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 PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU V~ITH 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 10007.034.3862 BURTON NElL & 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 CHRISTINE M MARTIN 913 SCOTISH COURT MECHANICSBURG, 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 Fails, South Dakota. 2. The defendant is CHRISTINE M MARTIN, who resides at 913 SCOTISH COURT MECHANICSBURG, 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 ora credit card with an account number 5424180162500810 hereinafter referred to as the credit card account. 5. Plaintiffmaintained an accurate and running record of ail 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 $2803.30 Wherefore, plaintiff demands judgment against the defendant for the sum of $2803.30 and the costs of this action. ms 674 N, ZIL-- ) & ASSOCIATES, P.C. Burton Neil, Esquir~ Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. 07/27/04 $28,03.30 $9999.99 SIT£:KC-CL CHRJSTIN£ M MART2N RTTNY ACCOUNT-CODE=FN34 HIGHSPIRE 17034-0160000 PA CITI CARDS P.O. BOX 8,102 S HACKENSACK, 07606-8,&02 NJ TM:CO-5000 07/13/04 AC[D:KCB7150 19:38:Z~ Citi* Platinum Select* Card 54Z4 1801 6~'50 0810 Cuatemer Servi~e= 1-800-P50-5114 Total Credit Line BOX 6500 $5200 S~OUX FALLS, SD Cio/In Date S?Zl? 07/02/2~04 So $39oo $o ~0 Past Due MI ~mum Due $1364,77 ~58.00 00 Help is available! Please call the toll-free number shown above to learn about our special Eayment oEtfons. Call Monday - Friday, 7 am to ~ pm or ~aturday, 0 am to 5 pm, Central Time. P ease qive us the opportunity to assist you. Please see the enclosed privacy notice for important information. $2803.30 $2803.30 Previous (+) Purchases (-) Payments Account Summary Balance & Advances & Credits PURCHASES $2,803.30 $0.00 $0.00 ADVANCES $0.00 $0.00 $0.00 TOTAL $2,803.30 $0.00 $0.00 Rate Summary 8,alance Su~ec~to Periodic Finance Charge Rate PURCHASES Standard Purch $0,00 0.06847%(0) ADVANCES Standard Adv $0,00 0.06847%(0) (+) FINANCE (=) New CHARGE Balance 0,00 $2,803.30 0.00 $0.00 O.00 $2,803.30 Days This Bil~lng Period: 30 Nominal ANNUAL APR PER(;ENTAGF~ RATE 24.990% 24.990% 24.990% 24.990% EXHIBIT rQ Verification SUSAN CAREY. ~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 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: Account number: 5424180162500810 Defendant: CHRISTINE M MARTIN SHERIFFIS RETURN - REGUI~AR CASE NO: 2004-03825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MARTIN CHRSTINE M CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE MARTIN CHRISTINE M DEFENDANT , at 0020:56 HOURS, at 912 SCOTISH COURT MECHANICSBURG, PA 17050 CHRISTINE M. MARTIN a true and attested copy of NOTICE COMPLAINT was served upon on the 18th day of August the , 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 7.40 Affidavit .00 Surcharge 10.00 .00 35.40 Sworn and Subscribed to before me this /'~.~ day of ~, , ~7/ A.D, ~z~othonot ary ' So Answers' R. Thomas Kline 08/19/2004 BURTON NEIL & ASSOC. CITIBANK (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. 04-3825 CHRISTINE M MARTIN 913 SCOTISH COURT MECHANICSBURG, PA 17050 : 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: $2,803.30 Credit: $0.00 Attorney's Fees: $0.00 Total: $2,803.30 Understanding that false statemems 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 Servicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defeadaht~d/or the Department of Defense website. / JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER ~E~.R. CIV.P.236 Pro Prothonotary ~7 / BURTON NEIL/~?ASSOCIATES, P.C. ---~ofi~N~eil, F/squire Attorney for Plaintiff Attorney I.D. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 10007.034.3862 Burton Neil & Associates, P.C. is a debt collector CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. CHRISTINE M MARTIN : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3825 Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: CHRISTINE M MARTIN 913 SCOTISH COURT MECHANICSBURG, PA 17050 DATE OF NOTICE: November 01, 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 BY: ~u~;~eil, Esq '~' uire 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. C)