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Home My WebLink About11-3144 FILED- C"EFICE 2311 MAR 21 PM 1: s0 rUMBERLANID COUNTY PENNSYLVANIA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA M .1 NO.11.3tyL4 U"A CIVIL ACTION - LAW Complaint - Notice 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. VANESSA L DOLAN 723 N River Street APT 4 Wormleysburg PA 170431006 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-49068 6i:? aCkW? e? 7d aid J iz#- t 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. VANESSA L DOLAN 723 N River Street APT 4 Wormleysburg PA 170431006 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 Vanessa L Dolan, who resides at 723 N River Street APT 4, Wormleysburg, 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 7891 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 $22,285.75 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 $22,285.75, and the costs of this action. Burton Neil & Associates By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 0OON> ° A -4 W Z 0 O-0 A K N Z IE 3 .PzM 0 4t < N N < ° <D ~ m O c N W ur m r? N ,?. to 3? v n t 0 c, A a o < N z D a m ° D ° m 0 A W o ¦ 0 m nvn °r0? KOD M C: X 2 ' N 0 on A A W W m Ra C ; on m Aa 0, o3 7 ? Ag n 3 m ? r + . _ 10 do a N u 0 s x www.clticards.com Account Member VANESSA L DOLAN How To Reach Us 1-800-866-9900 Customer Service BOX 6500 Account Activity Account Number SIOUX FALLS, SD Nov 10-Dec 09, 2010 ? 7891 Member Since 1997 57117 Minimum Payment Due: New Balance: Summary of Account Activity $1,160.54 $22,285.75 Previous Balance $21,988.21 Fees Payment Due Date: Payments -$0.00 Sale Post Description Amount 01/07/2011 Payment must be received by 5:00 PM Other Credits -$0.00 12/09 LATE FEE - NOV PAYMENT PAST DUF 25.00 local timeonthe payment due date. Purchases +$000 TOTAL FEES FOR THIS PERIOD 25.00 Late Payment Warning: If we do not receive your Cash Advances +SO.oG minimum payment by the date listed above, you may Fees Charged +$25.00 have to pay a late fee of up to $35 and your APRs may be Increased up to the variable Penalty APR of 29 9946 Interest Charged +$272.54 Interest Charged t . . Minimum Payment Warning: If you make only the New Balance 22,285.75 Post 12/09 Description INTEREST CHARGED TO STANDARD PURCH Amoun 272.54 minimum payment each period, you will pay more in Past Due Amount $641.00 TOTAL INTEREST FOR THIS PERIOD 272.54 Interest and it will take you longer to pay off your Amt. Over Credit Limit $0.00 balance. For example: It you make no '. You will pay off And you will end Credit Limit $25,000 additional charges - the balance shown ' up paying an -- - - Available Credit - $0 using this card and : ea on this statement . estimated total 0nlythe m minimum 32 yea(s) $48,237 0 payment Statement Closing Date 12/09/201 $750 3 year(s) $27,648 Lays in Billing Cycle 30 (Savings-520,589) For information about credit counseling services, call 1-877-337-8188. C 1of2 2010 Totals Year-to-Date Total fees charged In 2010 $25.00 Total Interest charged In 2010 $272.54 Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual Interest rate on your account. Annual Percentage Balance Subfectto Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 14.990% (V) $22,119.66(D) $272.54 ADVANCES Standard Adv 21.990% (V) $0.00 (D) $0.00 Your account is now 3 MONTHS PAST DUE and currently closed. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pin, or Saturday, 8 am to 5 pm, Central Time. How to Reach Us 1-800-866-9900 Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 **** **** **** 7891 Access your account online: www.citicards.com 0 Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 12/31/2010 to allow for enough time for regular mail to reach us. 2of2 Verification L, Lisa Blamer ; 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. Signature C-49068 Vanessa L Dolan Account number ending in 7891 1008