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Home My WebLink About04-3839BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attomey for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff LEE WOODALL 21 West Mulberry Hill Road, Carlisle PA 17013-8410 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 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-1497 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 LEE WOODALL 21 West Mulberry Hill Road, Carlisle, PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0t1'3~3q 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 Falls, South Dakota. 2. The defendant is Lee Woodall, who resides at 21 West Mulberry Hill Road, Carlisle, Cumberland County, Pcrmsylvania. 3. Plaintiff, a national banking association, engages in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff fumished consumer credit to the defendant by means of a credit card with account number 5466160173415231 hereinafter referred to as the credit card account. 5. Plaintiff maintained 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 statcmaent 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 amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $22,528.20. Wherefore, plaintiff demands judgment against defendant for the sum of $22,528.20, and the costs of this action. By:. ~ 3Y:' B~squire Attorney for Plaintiff The law finn of Burton Neil & Associates, P.C. is a debt collector. 05/i7/04 $22528.Z0 $9999.99 SITE:KC-CL LEE WOODALL ATTNY ACCOUNT-CODE=LB34 CARLISLE 17013-8410000 PA CIT! CARDS P.O. BOX 8116 S RACKENSACK, NJ 07606-8116 TM:CO-5000 os/o5/o4 AC[D:KCB7150 19:49:25 5466 1601 7341 5231 CuatomorServige: 1-800'9~5-8871 BOX 606~ SZOUX FALLS, SD 57117 04/22/2004 sob Date ~Date Nal~enceNumber $o $10000 $0 $3208.20 $3778.49 $474.00 Help is available! Please call the toll-free number shown above to learn about our special ~ayment oEtfons. Call ¥onday - Friday, 7 am to y pm, or baturday, 8 am to $ pm, Central Time. Please give us the opportunity to assist you. $22528.20 $22528.20 Previous (+) Purchases (-) Payments A¢count Summarf BaJance & Advances & Credits PURCHASES $22,528,20 $0.00 $0.00 ADVANCES $0,00 ~0.00 $0.00 TOTAL $Z2,528.20 $0.00 $0.00 Rate Summary Bo{anco Subjec~to Periodic Finance Charge Rate PURCHASES Standard Purch $0.00 0.07668%(D) ADVANCES Standard Adv $0.00 0.07668%(0) (+) FINANCE (~ New CHARGE Bo[anco 0,00 $22,528.20 0.00 $0.00 0.00 $22,528.20 DaysThlsB~lfngPerlod: 30 Nominal ANNUAL APR PERCENTAGE RATE 7.o,EXHIBIt 7.,,o 27.990% 27.990~ VERIHCATION Tara Cr'o is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiffin this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned vefifier'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. Lee Woodall 5466160173415231 SHERIFF'S RETURN - REGULAR CASE NO: 2004-03839 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS WOODALL LEE GERALD WORTHINGTON , Cumberland County,Pennsylvania, says, the within NOTICE WOODALL LEE DEFENDANT , at 0015:33 HOURS, at 21 WEST MULBERRY HILL ROAD CARLISLE, PA 17013 LEE WOODALL a true and attested copy of NOTICE COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 13th day of August , 2004 by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.70 Affidavit .00 Surcharge 10.00 .00 31.70 Sworn and Subscribed to before me this J~,~ day of otho .2o~¥ A.D. notary So Answers: Thomas Klin~- 08/13/2004 BURTON NEIL & ASSOCIATES Deputy sb~Fiff CITIBANK (SOUTH DAKOTA) N,A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff VS. LEE WOODALL 21 West Mulberry Hill Road Carlisle PA 17013-8410 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3839 : 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 thc plaintiffand against the defendant, and assess damages as follows: Principal: $22,528.20 TOTAL $22,528.20 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: 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)(l)(A) of the Servicementhers Civil Relief Act of 2003 (SCKA), 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. 1 BURTON NEll,/& ASSOCIATES, P.C. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER~CIV. P. 236 Pro Prothonotary . ~x~,~ Attorney for PI'a, hltiff I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neff & Associates is a debt collector. C-1497 C£t'I~ANK (SOUTH DAKOTA) ' Plaintiff VS. LEEWOODALL D~fendant IN THE COURT OF COMMON PLEAS CUlVlBBKLAND COUNTY, PENNSYLVANIA NO. 04-3839 CIVIL ACTION - LAW Notice of Intention to File Praeeipe for Default Sudgment TO: Lee Woodall 21 West Muibert~ Hill Road Carlisle PA 17013-8410 DATE OF NOTICE: September 7, 2004 1MI~ORTANT NOTICE You are in defauk because you have failed to enter a written appearance personally or by attorney and file in writin~ with the court your defenses or obligations to the claims set foffit against you. Unless you act within ten (10) day~ fi.om the date of this notice, a judgment may be entered .~i.~t you without a hearing and you may lose your property or other importam fights. You should take this notice to your lawyer at once. If you do not have a lawyer or ea~not afford one, go to or t*lephene the following office to find om where you can gM legal help. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, fffis office may be able to provide you with information about agencies that may offer legal services to digible persons at a reduced fee or no fee. LAWYER REFERENCE AND INFORMATION SERVICE Cumborlmd County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-99~108 ! BURTON N]SI~ ASSOCIATES, P.C. ~n Neil, Esq~ Attorney for Plalhtiff Identification Nc~ 11348 1060 Andrew DriNk, Suite 170 West Chester, PA 19380 $10-696-2 t20 Th* firm of Burton Nvit & Associates, ?.C. is attempting to collect a debt. C-1497