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Home My WebLink About04-3834BURTON 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 V. SHELLEY A WHITCOMB 154 W Pomfret St Unit 2, Carlisle PA 17013-0000 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 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 C206 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. 70l East 60th Street North, Sioux Falls, SD Pla'mtiff SHELLEY A WHITCOMB 154 W Pomfret St Unit 2, Carlisle, PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. r.)~/- 3~' 39' Defendant CiVIL ACTION - LAW Complaint l. 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 Shelley A. Whitcomb, who resides at 154 W Pomfret St Unit 2, Carlisle, 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 of a credit card with account number 5491130312452998 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. 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 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 $12,492.43. Wherefore, plaintiff demands judgment against defendant for the sum of $12,492.43, and the costs of this action. BURTON .~EtlL & A~ OC IATES, P.C. By: ~.~~ ~'/ _..~..~---~urton NeiJ(, Esquire Attorney ~6r Plaintiff The law firm of Burton Nell & Associates, P.C. is a debt collector. Your.4T~~ Card Statement December 16 - January 15~ 2t]04 Page I of 3 ATaT SHELLEY A WHITCOMB Accouett ~ 1303 1245 2g~8 Calling Card + PiN No Annual Fee/Platinum Card How To Reach Us Account Online: www.universalcerd.com Customer Service: I 800 423-4343 et write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Minimum Payment Due .................................... $12,492.43 Due Oet~ ............................................... February 9, 2004 Amount Past Due ............................................... 31,400,40 Amount Over Limit ............................................ 01,342.43 Credit Line .......................................................... $11,150.00 Available Crsdil ............................................................ $0.00 Cash Advance Limit Available Cash Advance Lira t .................................... $0.00 Help is available~ Please cai) the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. J~w~3~zs Balnnce 12,492 43 ..~_s and Adjuntments 0 00 ~lasfer Card Acfivtty 0 00 ~T~taLAT&T Services O 00 New Balance ~ 2,492.43 Note: Detailed activity starts on page 3. Payment Record Amount Paid: Date Paid: Check Number:. Please follow pwmer~ JnslruclJons outlined ~ the "In Account Number Payment Due 5491 1303 12~; 2998 02109104 ( ) ( I.,.111...111 ...... I1,,11,1,,I,I SHELLEY A WHITCONB ATTNY ACCOUNT-C0DE=LB36 CARLISLE BRKS PA 17015 II1,,,I,,,I,I1,,11,,,,11,,I,,I,,,I,1,,,1111,,,11,,,I AT&T UNIVERSAL CA~k/U I D J"r PO BOX 8210 SOUTH HACKENSACK"RJ T]7606.-8210 II,l,l.llllll,,I.IIIIl,.ll,l,l,lll,l,lll,,lll,,l,l,tl.llll 54911303124529980012492430012492430 A WHITCOMB ~'age 2 of 3 A"F~T SHELLEY Account 5491 1303 1245 2998 December 16 - January 15, 2004 in the return envelope, please: F~tck~e ~m~ cbeck o~ mm~T ord~, lnclude your account number and name on the front of your check or money order. Please, no cash or foreign currency. E~lck]sc yolu'pay~ent colq3o~i. Do not staple or tape it to your payment, Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. SHELLEY a WHITC'OMB Account 5491 1303 1245 29g~ December 16 - January 15, 2004 Page 3 of 3 Total MasterCard Activity. ......................................................................................................................... $O.00 Total MasterCard Purchases ............................................. $O.00 Cash Advance Lim~ ............................. $2,000.00' *This represents a portion of your totaJ credit line. [ ;i~ancc Chat~ PURCHASES X $000 = $000 + $000 27990% X $000 = $0 O0 + $000 27990% X ~000 =; $0 O0 + $000 27990% Tolai FINANCE CHARGE $0.00 AT&T Universal Calling Card CAlls ......................................................................................................... VERIFICATION 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, relating to unsworn falsification to authorities. ~.~~ Date: .. SHELLEY A. Whitcomb 54911303 12452998 SHERIFF'S RETURN - REGULAR CASE NO: 2004-03834 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS WHITCOMB SHELLEY A SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon WHITCOMB SHELLEY A DEFENDANT , at 0931:00 HOURS, on the 12th day of August at CUMBERLAiqD CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to SHELLEY WHITCOMB 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 .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this /~ day of ~~_~ ~o~3~ A.D. ~othonotary '~ So Answers: R. Thomas Kline 08/12/200~ BURTON NEIL & ASSOC Deputy Sheriff 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. SHELLEY A WHITCOMB Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3834 : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTON~IL & ASSOCIATES, P.C. / BY: ~'a~h'~'e~, Esquire Attorney forXPlaintiff The law firm of Burton Neil & Associates is a debt collector. C206