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Home My WebLink About04-3827- 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. 701 East 60th Street North, Sioux Falls, SD Plaintiff TRACEY E GLESSNER 14 South Broad Street, Mecharficsburg PA 17055-3705 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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 wamed 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-990 BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell, Esquire 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 TKACEY E GLESSNER 14 South Broad Street, Mechanicsburg, PA 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 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 Tracey E Glessner, who resides at 14 South Broad Street, 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 account number 5183900040308347 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. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the baiance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiffon the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $3,882.76. Wherefore, plaintiff demands judgment against defendant for the sum of $3,882.76, and the costs of this action. BURTON) ~E~$OCIATES,, P.C. By: B~o~eil, Esquire A~omey for Plaintiff The law firm of Burton Nell & Associates, P.C. is a debt collector. 04/12/04 TRACEY E GLESSNER ATTNY ACCOUNT-CODE=DMCD MECHANICSBURG 17055-3705000 $3882.76 $9999.99 SITE:KC-CL PA SUNOCO MASTERCARD P.O. BOX 8112 S HACKENSACK, NJ 07606-8112 TM:CO-5000 04/15/04 ACID:KCB7150 17:39:14 5183 9000 4030 8347 Customer service.' 1-877-645-2017 Total Crealt Line IRVING, TX CIo~ln Date 75014-2319 03 / 17/2 ~04 3/17 3/17 $o $3000 $882.76 $1012.29 Standard Parch PURCHASES*F[NANCE CHARGE*PERiODiC RATE 84 0000 0 Standard Adv ADVANCES*F[NANCE CHARGE*PERiODIC RATE 84 0000 0 Available Cash Limit to Purch/Adv Inlmum Due ~116.00 Help fs available! Please call the toll-free number shown above to learn about our special ~ayment oEtions. Call Nonday - Friday, 7 am to ~ pm, or ~aturday, 8 am to 5 pm, Central Time. Please qJve us the opportunity to assist you. $3882.76 $3882.76 Amount 5.25 70000000000 43.76 70000000000 Previous (+) Purchases (-) Payments Account Summ~y Balance & Advances & Credits PURCHASES $410.59 $0.00 $0.00 ADVANCES $3,423.16 $0.00 ~0.00 TOTAL $3,833.75 $0.00 $0.00 Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Balance Su~ectto Finance Charge $413.12 $3,444.24 Periodic Rate 0.04381%(D) 0.04381%(D) (+)FINANCE (=)New CHARGE Balance $5.25 $415.84 $43.76 $3,466.92 $49.01 $3,882.76 Days This Billing Perl~: 29 Nominal ANNUAL APRx~,,~CENTAGERATE 15.990~ IBiT5.990~ 15.990% 15.990% VERIFICATION 'l'~ra ¢co$$ is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are tree and correct to the best of the undersigned verifier's 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. TRACEY E Glessner 5 ! 83900040308347 SHERIFF'S RETURN - CASE NO: 2004-03827 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS GLESSNER TRACEY E REGULAR GERALD WORTHINGTON Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon GLESSNER TRACEY E DEFENDANT , at 1440:00 HOURS, on the 20th day of August at SCOTTIE'S LOUNGE MECPIANICSBURG, PA 17055 TRACEY E GLESSNER Sheriff or Deputy Sheriff of who being duly sworn according to law, 710 W MAIN STREET by handing to a true and attested copy of COMPLAINT & NOTICE the , 2004 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 /~z~- day of 4× ~on~t~ ~ So Answers: R. Thomas Kline o8/23/2o04 BURTON NEIL & ASSOC Deputy She~t~ff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff VS. TRACEY E GLESSNER 14 South Broad Street Mechanicsburg PA 17055-3705 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3827 CIVIL ACTION - LAW 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 plaintiffand against the defendant, and assess damages as follows: Principal: $3,882.76 TOTAL $3,882.76 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. ~ 4904 relating to unswom falsification to authorities, I verify that: l. 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 ReliefAct of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UND~.CIV.P. 236 Pro Prothonotary BURTON ~L & ASSOCiATES, P.C. ',~.~ BY: ~Esquire Attorney for Plaintiff I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Nell & Associates is a debt collector. C-990 C/TIBANK (SOUTH DAKOTA) Plaintiff VS. TRACEY E Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3827 : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Tracey E Gles~ner lz~ S. Broad Street Mechanicsburg PA ] 7055-3705 DAT~ OF NOTICE: S~tember 13, 2004 ~ORTANT NOTICE You ar~ in defauk because you have failed to ~ntor a written appeamuce pemonally or by attorney and ~e in wri~ng with the couri yo~ defenses or obligaiious to the claims set forth against you. Unless you a~ within ten ( 1 O) days from the d~e of this notice, a judgment may be enlered against you without a hearing znd you may lose your propc~oy or other important fight~. You should take th~s notice to your lawyer at once. If you do not have a lawyer or caunot zfford one, go to or t~lephone the following office to find out wher~ you can g~t legal help. This office can provide you with information abeut hiring a lawyer. ffyou cannot afford to hire a lawyer, tl~ office may be able to provide you with informhtion about agencies fl~t may offer legal services to ehg4ble persous at a reduced f~ or no fee. LAWhrER RF_,FER~CE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlizle, PA 17013 Telephone No. 717-249-3166 or BURTON NELL/ASSOCIATES, P.C. / Identification No. 11348 1060 Andrew Drive, Su/te 170 West Chester, PA 19380 6! 0.696-2120 Thc ~ of Burton Ne[[ & Associates, P.C. is afl. erupting to collect a debt. C-990