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Home My WebLink About04-3833BURTON 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 SHERI L BEERE 6030 Wertzville Road, Enola PA 170251159 Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 6¢ 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 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-g86 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 Fails, SD Plaintiff SHERI L BEERE 6030 Wertzville Road, Enola, PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant CIVIL ACTION - LAW CompLaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Sheri L Beere, who resides at 6030 Wertzville Road, Enola, Cumberland County, Pennsylvania. 3. Plaintiff, a natiunal 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 5424180725283052 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 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 balance due on the credit card account so as to constitute an account stated. 9. The mount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $9,446.04. Wherefore, plaintiff demands judgment against defendant for the sum of $9,446.04, and the costs of this action. //p BURTO~~ SOCIATES, P.C. By: ~L~n ~eil, Esquire ,A, tt~_mel f°r Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 05/04/04 $9446.04 $9999.99 SZTE:KC-CL SHER! L BEERE ATTNY ACCOUNT-CODE=LB34 £NOLA 17025-1159000 PA CZT! CARDS P.O. BOX 8107 S HACKENSACK, NJ 07606-8107 TM:CO-5000 04/15/04 ACZD:KCB7150 17:39t15: Citi' Dividend Platinum Select' Card 5424 1807 2528 3052 Custemer Service= 1-000-066-9g00 Total Credit Line $9700 BOX 6500 Statement/ SIOUX FALLS, SD Cio in Date s7'r17 o4/o97~o4 $0 $2400 $0 $825.82 ~:~01.00 Help is avaitablel Please call the toll-free number shown above to learn about our special payment oEtions. Call ¥onday - Friday, 7 am to y pm, or ~aturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. $9446.04 $9448.04 Previous (+)Purchases (-) Payments :count Summa~/ Balance & Advance~ & Credits RCHASES $9,446.04 $0.00 $0.00 VANCES $0.00 $0.00 $0.00 TAL $9,446.04 $0.00 $0.00 Balance Subject~o Periodic La Summery Finance Charge Rste 'CHASES andard Purch $0.00 0.07668%CD) far 4 $0.00 0.07668%CD) ANCES andard Adv $0,00 0.07668~(0) (+)FINANCE (~ New CHARGE Balance $0.00 $9,446.04 $o.oo So.oo $0.00 $9,446.04 Day$TnlsBIrlfngPerfo~: 30 Nominal ANNUAL APR PERCENTAGE RATE ,.99o EXHIEt I 27.990% 27.990~ 27.990% VERIFICATION T~t~ 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 true 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, relat'mg to unsworn falsification to authorities. Date: Sheri L Beere 5424180725283052 August 16, 2004 l) True - The Piaintiffis C/v//Action #04 3833 60· Citibank (S. Dakota) N.A., with ~e p/ace Street North, Sio~ Fa/Is, South Dakota. of business located at 701 East 2) True ~ttm ~/sSlier/:L. Beere, res~g at6030:~Rged' Enoia, PA 17025. 3) True - C/tibank is a National Bank/rig Association, bus/nessiaohat/ngeoasamer l~ding-~ . . whicih engages in various types of bunking 4) mroug~ ~ssuance of credit cards. True - My Citibank Credit Card Account is $424180?252,83052. above. account mention~mamta~a~ ~ recur4 oCa~deb/~r ~edits made to my card "-~ ement each month. 7) True - I agree that I owe what is shown on the attached statement copy. 8} True----t amnotpmtes~ what I owe Citibank. 9) True - I agree that the amount I owe Citibank is $9,446 04 displayed _ which amoa~ there is no excuse I am the - - raP°t°g~'~the~----' ..... n~inegand:~l~ damagewi~- ' one that must live ..~,L .~ 7_',* .'~asl°°RY that I have however, I do be-liat~to-teve~.. ,,t~u me choices I make - my credit is not have the funds to pay you ill ~.~t~-e to~t~-egZl~res~unsibility for tiffs debt; c~ borrow ~om at a meo/13 75% -,~:-,- .... '~-~,~r, amme r~ ..... set~ff~isto~mat~,.~ ~ · - -~n ~s much hi~her,~- _ . ' .~..,~,e a une-of-credit th acs. ~ am rid ot-~;,~"~7,, ~a- ..a!ys~. r ao~'~ rm, e-~,,,~t___ _ - ~ uouar credit c ~J to ua, out 1 wou/d like to thing a~ won't make l~roliase~unless t/u~ve t~ - u .... ~'. ~ am acing the right doe~'t seem to work for me. ,~o~ey. T~ thoa~t~ ofpayi~ the bill whe~ it arrives ~e~ap_monov~.~P~ Yments to me to cover *~- -- ~ tba~velg~l~s th,, ~ ~_,~. _ ='" "~- oc'e~ms~ t tm,e ~t ~, .t_- ~ "'~ on me vehicles TI,;o~. .... "~'. 'Y ~ paid me did,', '~.~.-,;" ,,,,~.. -~ -,,mu nave done the ..... ~ we-wer~tlt fr/en~, rt, _ .omy trying to heln --"'~Y --morew/ser, lr ~a~t ~,~_~f°r .me. It's safe to say .-~mm t ac R; r ~ °uuse~mg my I ask you to be merciful, which is not easy for me... I tend to pride myselfwith my integrity, but this is the t/me when- I must admit defeat. I appreciate anything that you can do to help me. (TI 7-732-t264} SHERIFF'S RETURN CASE NO: 2004-03833 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BEERE SHERI L - REGULAR SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BEERE SHERI L DEFENDANT , at 1805:00 HOURS, at 6030 WERTZVILLE ROAD ENOLA, PA 17025 LLOYD BEERE, HUSBAND a true and attested copy of on the was served upon 9th day of August the , 2004 by handing to COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.88 Affidavit .00 Surcharge 10.00 .00 36.88 Sworn and Subscribed to before me this I~- day of ~ ~2~ A.D. rothonotary ' So Answers: R. Thomas Kline 0s/10/2004 By: BURTON NEIL & ASSOCIATES, P.C. Burton Neil, Esquire, ID#11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CIT1BANK (SOUTH DAKOTA) N.A. Plaintiff SHERI BEERE Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3833 CIVIL ACTION - LAW Praecipe for Judgment Upon Admissions Pursuant to Pa R.C.P. 1037(b) To the Prothonotary: Pursuant to Pa.R.C.P. 1037(b) enter judgment upon the admissions to the complaint in defendant's answer, a copy of which is attached hereto, wherein defendant admitted all of the allegations of the complaint. Defendant admitted the principal amount due of $9,446.04. Assess damages for plaintiff and against defendant as follows: Principal & Total Judgment: $9,446.04 B~ao~rNen, Esquire ~ Attorney for Plaintiff And now, this, ~ D-'}-- day of ]~_'~ , 2004, judgment is entered for the plaintiff Citibank (South Dakota) N.A. and against ~he defendant Sheri Beere per PA R.C.P. 1037(b) and damages are assessed in a sum certain against said defendant pursuant to the admissions in her answer to the complaint as follows: in the total sum of $9,446.04. Prothonotary ~ In making this communication, we advise our firm is a debt collector. August 16, 2004 Cititm~ vs Shea'i C~,,A1 A~tion #04 3833 1) Tree - The Plaintiffis Cit~ank (S. Dakota) N.A., with the place of business located at 701 East 60~ Stree~ North, Siosax Falls, South Dakota. 2) True --The- defem~nt is St~4 L. Bee~, ~em'~ng a~ 6g3~We~t-zvil~R~ga~ ~oh, PA 17025. 3) 4) Tree - Cit~ank is a National Banking Association,. which engages in various types of banking tm~zss4aeI~Vmg ee, n~-ame~ tendiag through-~ssmmce of credit cards. True - My Citibank Credit Card Account is 5424180725283052 T-nee-C'm'ba~ did ma/rash-a~aeeurate record of ~-debi~s an5 ~:redits made to my card accotm~ men!io~e.d .a. bove_~ 6) True.--~Tm%ank n~ii:r~d me~m-aeea~at¢15 ~ statement each month. 7) True - I agree that I owe what is shown on the attached statemem copy. 8) True [am,~-,v .... sfng_what I owe Citibank. 9) True - I agree that the amount I owe Citibank is $9,446.04. I a~¢z ~at ][ c,w¢ C~m~le theameo~,nt of $9-,446:.04: [ apa!%~ ~c ~sib~ ~at I have ~layed - ~ch ~ere is no excuse. I m ~e one ~at mu~ ~e ~h ~e choices 1 ~e - my ~e~ is ~ , ..... ra t~e ~~ for ~s debt; how~, I do not have ~e ~ds m pay you ~ ]~ ask~fo~ yo~r consideration i~roa~hing some ~*~~t ~S&~ ~ye a ~e-of-~e~ ~at 1 c~ bo~ow ~om at a rate of 13.75% - whch is much ~ ~ mo~ ~ 6~ds, but I wo~d ~e to thig, I m fid of~ doRar ~e~ c~ds ~d ~ose t~t I ke~ ~ mx out at $1000. I m do~g ~e ~t doe~'t ~em to work for me. Iix ..... I~malm Ie.. ~=a-I-pm- ~ T~ ~s- ...... ~ I~s that I ~Id to ~ds ~d ' ' ~ · ey were ~g pa~ents to me to cov~ ~e pa~ents ~at I owe~ m ~, ~s was ~pposed to ~cc ~m~cy ~ erc~ e~d payments, ~ K~t ~, ~ ~ paid me ~'t a~a~ cov~ ~e ~H pa~t ofw~t I owed un ~e veMcles. ~s pm me behMd. I Was oMy ~g to he~ ~-~ ~..~ ....... s ~- ~ ~ ~ [~W ~at ff~e tables w~e ~e~ ~ey wo~d have done ~e ~e for me. Iffs sffe to ~y~at I wa~'f prop~ly budgetMg my 1 ask you to be mer¢ifal, which is not easy for me... I tend to pride myself with my integrity, but this is ~ fim~ arhen, t must admit defeat. I appreciate anything that you can do to help me. S'm rely, Sh&i L. Beere BURTON NEIL & ASSOCIATES, P.C. Burton Nell, Esquire, ID#11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff SHERI BEERE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3833 CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Service members Civil Relief Act 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. BURTON ~EIL & ASSOCIATES, P.C. Butt~en Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. 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. VS. SHERI L BEERE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3833 : CIVIL ACTION - LAW PRAECIPE TO VACATE TO THE PROTHONOTARY: Kindly VACATE the judgment entered in the above-captioned action. BURTO~/~IL 8t~ASSOCIATES, Attorney for Plaintiff 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. Plaintiff VS. SHERI L BEERE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3833 : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTOI~fiL & ASSOCIATES, P.C. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-886