HomeMy WebLinkAbout11-3143• e
v i I9r P RO i HONOTA- i
2011 HAP, 21 PM 1: G E
`CUMBERLAND COUNTY
PEN14SYLVANIA
Burton Neil & Associates, P.C.
By: Neil Sarker, Esquire ID. NO. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN C DANGLO : NO. \? ?314 3 Civil
318 Brandy Lane, Mechanicsburg PA 170552807
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 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-49071
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14a5 847
Burton Neil & Associates, P.C.
By: Neil Sarker, Esquire ID. NO. 203465
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.
KATHLEEN C DANGLO
318 Brandy Lane
Mechanicsburg PA 170552807
Defendant CIVIL ACTION - LAW
Complaint
1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at
701 East 60th Street North, Sioux Falls, South Dakota.
2. Defendant is Kathleen C Danglo, who resides at 318 Brandy Lane, Mechanicsburg,
Cumberland County, Pennsylvania.
3. Plaintiff is a national banking association, engaged 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(n) CITI
MASTERCARD credit card with account number ending in 8389 hereinafter referred to as the
credit card account.
5. Plaintiff kept accurate running records of all debits and credits to the account.
6. Plaintiff mailed to defendant monthly statements for the account including the billing
statement attached hereto as Exhibit A. The monthly statements accurately stated the previous
balance, the debits and credits to the account for the prior billing period.
7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on
account of the billing statement or retained the statement without payment.
8. Defendant's actions as set forth above constituted an account stated between parties
for the sum of $28,868.38 which sum reflects the Exhibit A statement balance less credits, if any,
which were applied subsequent to the date of Exhibit A.
Wherefore, plaintiff demands judgment against defendant for the sum of $28,868.38, and
the costs of this action.
Neil Sarker, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
Burton Neil & Associates . .
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www.citicardscom
Account Member
KATHLEEN C DANGLO
Account Activity Account Number
Nov 04-Dec 03, 2010 18389 Member Since 1989
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Minimum Payment Due: New Balance:
Summary of Account Activity
$28,868.38 $28,868.38 Previous Balance $28,456.99
Payment Due Date: Payments -$0.00
01/01/2011
o
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p
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PM Other Credits
l
e on tt
e
a
ment due date.
ti
ca Purchases +$0.00..
Late Payment Warning: If we do not receive your Cash Advances +$0.00
minimum payment by the date listed above, you may
to pay a late fee of up to $35 and your APRs maV
b
P Fees Charged +$35.00
e increasetl up to
e
the varia
ble
Penalty
APR of
29
.99%. Interest Charged +$376.39
Minimum
Payment
Warning:
if you
make
only
the New Balance 28,868.38
minimum payment each period, you will pay more in Past Due Amount $2,670.34
interest and it will take you longer to pay off your
balance. For example: Amt. Over Credit Limit $1,138.38
If you make no You will pay off And you will and
additional charges the balance shown- up paying an Credit Limit $27,730
using this card and on this statement estimated total Available Credit $0
each month you pay... In about... of... Cash Advance Limit $18,800
Only the minimum i month(s) - $28,868 Available Cash Limit - $0
payment statement Closing Date 1210312010
For information about credit counseling services, call 1-877-337-8188. Days in Billing Cycle 30
3
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How To Reach Us
1-800-866-9900
Customer Service
BOX 6500
SIOUX FALLS, SD
57117
Total ThankYou Member Available
Point Balance As Of 12/01/10: 0
Log on to www.tt)ankyou.com today to check your latest point balance, redeem for great
rewards, and earn more points.
Fees
Sale Post Description Amount
12/03 LATE FEE - NOV PAYMENT PAST DUE 35.00
TOTAL FEES FOR THIS PERIOD 35.00
Interest Charged
Post Description Amount
12/03 INTEREST CHARGED TO STANDARD PURCH 0.46
12103 INTEREST CHARGED TO PUR PR-10/26/10. 375.93
TOTAL INTEREST FOR THIS PERIOD 376.39
2010 Totals Year-to-Date
Total fees charged in 2010 $130.00
Total Interest charged In 2010 $4,308.73
Interest Charge Calculation
Your Annual Parcentage Rata (APR)ls the annual Interest rate on your account.
Annual Percentage Balance subiectto
e
Type of Balance Rate (APR) Interest hate Interest Charg
PURCHASES
Standard Purch 15.990% (V) $35.22 (D) $0.46
Purch Prior 10126110 15.990% (V) $28,603.28 (D) $375.93
Account Number
**** **** **** 8389
a
Interest Charge Calculation (continued)
Annual Percentage Balance Subject to
Type of Balance Rate (APR) Interest state Interest Charge
ADVANCES
Standard Adv 25.240% (V) $0.00 (D) $0.00
ThankYou Points Summary Member ID: 8910234849674327
ThankYou Points Earned This Period
Category Merchant Card Member Payment
Base Bonus Bonus Bonus Rewards Bonus Adjusted
0 0 0 0 0 0
Total ThankYou Points Earned This Period: 0
ThankYou Points Earned Year to Date
Total Total Total Total
Base Bonus Adjusted Earned
2,432 0 0 2,432
Go to www.thankyou.com to review your ThankYou Point balance and redeem!
Bonus Points may take one to two billing cycles to appear on your statement. Please refer to
the specific terms and conditions pertaining to the promotion for further details.
Due to your late payrnent status you did not earn any points this month. To view
your scheduled payments and payment history, sign on to Account Online using the
URL on the back of your card. To view available ThankYou Points, visit
www.ThankYou.com
Help is available! Please call the toll-free number shown above to learn about our
special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5
pm, Central Time. Please give us the opportunity to assist you.
How to Reach Us
1-800-866-9900
Customer Service
BOX 6500
SIOUX FALLS, SD 57117
Access your account online: www.clticards.com
Please be sure to pay on time. If you submit your payment by mail, we suggest you
mail it no later than 1212512010 to allow for enough time for regular mail to reach
US.
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Verification
I, Lisa Blumel , am employed by Citicorp Credit Services, Inc. (USA)
(hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service
provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to
make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are
true and correct upon my information and belief and are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to authorities.
t
Signature
C-49071
Kathleen C Danglo
Account number ending in 8389
1000
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Sheriff R Anderson Wrr ?'?? RD? ??? !C?
Jody S Smith ?4?,l?tt, of 4m+uLca,,rr??? 20"MA N?'' '¢'?R??
Chief Deputy 3Q Ply 3:24
Richard W Stewart C"BERLAP Q COUNTY
Solicitor - - - PE'NNS }?LYq M Citibank (South Dakota) N.A.
vs. Case Number
Kathleen C. Danglo 2011-3143
SHERIFF'S RETURN OF SERVICE
03/28/2011 05:44 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
March 28, 2011 at 1744 hours, she served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Kathleen C. Danglo, by making known unto Marianne Manion, adult in charge at
318 Brandy Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $38.00
March 29, 2011
"(Akuw. Pd'jL'jL
AMANDA COBAUG , DEPLIV
SO ANSWERS,
RON R ANDERSON, SHERIFF