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Home My WebLink About11-34231 1% Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. KATHRYN L RUNK 511 Rittenhouse Square Mechanicsburg PA 170501850 Defendant 1LE0-0FF'C ?-; . l nO HO oTa.,, , U QEt NSYL\1AN1Pk IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 11 3ya3 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-47818 S al?k s 4a. OD Ck 99 Lot)4 Ads? y3 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. KATHRYN L RUNK 511 Rittenhouse Square Mechanicsburg PA 170501850 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 Kathryn L Runk, who resides at 511 Rittenhouse Square, 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 AT&T UNIVERSAL MASTERCARD credit card with account number ending in 2782 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 $16,447.75 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 $16,447.75, and the costs of this action. Burton W & Vsykiates, P.C. Y94(). Wein , Esquire The law firm of Burton Neil & Associates, P.C. is a debt 3N7 n > O D A x O Z m -< AZz O to 2,n tn0A C C C W A n Z N 0m? a vN nn 0 I 0 0 0 r)vn 0b -I r . R+ C a -1 Moo taXZ ?m< N to ;u N p A > N n m n A N O N rn M A 2 N 3 N Z A O O F 3 ?s c A O ,??I 3 y m C° Lq<LAm ° m Q t ' =; 3 e? N ^3 i A d 0 3 D 1 1 C Z d n Ib d How To Reach Us www.unlversaicard.com 1-800-423-4343 Account Activity Account Member Sep 21-0Ct 20,2010 KATHRYN L RUNK Customer Service PO BOX 6500 er SIOUX FALLS, SD 2782 Member Since 1992 57117-6500 a Minimum Payment Due: New Balance: Summary of Account Act ivity s $16,447.75 $16,447.75 Previous Balance $16,026.47 Fees Payment Due Date: Paympntc' -$0.00 Sale Post Description Amount 11/16/2010 Payment must be received by 5:00 Other Credits $0.00 10120 LATE FEE - SEP PAYMENT PAST DUE 35.00 PM local time on the payment due L t P t W dit Purchases v s +$0.00 -- TOTAL FEES FOR THIS PERIOD 35.00 a e aymen arning e do not receive your minimum a ment b the date list d b Cash Ad ance +$0.00 p y y e a ove, you may o have to pay a late fee of up to $35 and your APRs may b i t h Fees Charged _ I t t Ch d +$35.00 $ 28 Interest Charged e ncreased t1p o t e variable Penalty APR of 28.99%. n eres arge + 386. v New Balance 16,447.75 post Description Amount a Minimum Payment Warning: If you make only the 10/20 INTEREST CHARGED TO STANDARD PURCH 31.14 minimum payment each period, you will pay more in Past Due Amount $2,154.46 10120 INTEREST CHARGED TO OFFFR-007 355.14 interest and it will take you longer to pay off your balance. For example: Amt. Over Credit Limit $0.00 TOTAL INTEREST FOR THIS PERIOD 386.28 If you make no You will pay off - And you will end Credit Limit $24 600 additional charges the balance shown up paying an -- , 2010 Totals Year-to-Date using this card and on this statementestimated total Availably Crpolt $0 x each month you pay... In about.. of... mash Advance LRnIL $8,100 Total fees charged In 2010 $177.00 " Only the minimum 1 month(s) $16,448 payment Available Cash Limit 0 'al - _._.Interest - _ '-goIIf ° In ' " ' 2010 ° To t t char ged $1 94 998 94 Statement Closing Date 10/20/2010 ,. For information about credit counseling services, call 1-877-337-8188. Days If) Billing Cycle 30 Categorized Purchase Activity Air Travel Auto Rental Entertainment Health Care Lodging Merchandise 0.00 0.00 0.00 0.00 0.00 0.00 " Miscellaneous Organizations Other Travel Restaurants Services Vehicle Services 0.00 0.00 0.00 0.00 0.00 0.00 q. S x x Iof2 Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual Interest rate on your account. Annual Percentage Balance Su%actto Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 28.990% (V) $1,306.82 (D) $31.14 Offer 7 28.990% (V) $14,905.59 (D) $355.14 !x2010 AT&T and the AT&T logo are trademarks of AT&T Intellectual Property, Ilcensed to Citigroup Inc. How to Reach Us 1-800-423-4343 Customer Service PO BOX 6500 Account Number SIOUX FALLS, SD 57117-6500 2782 Access your account online: www,universaicard.com Interest Charge Calculation (continued) Annual Percentage Balance Subject to Type of Balance Rate (APR) Interest Rate Interest Charge ADVANCES Standard Adv 28.990% (V) $0.00 (D) $0.00 Don't forget to use your AT&T Universal Platinum Card which offers you up to 30 free calling minutes good toward U.S. domestic and international calls, and 2 free directory assistance inquiries per month. Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. 2of2 Verification Abbie Motley 1, , 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. C-47818 Kathryn L Runk Account number ending in 2782 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Solicitor 01' u?86ri?k dFF) ?E . ? F+E . tFI:F FILED-OFF IC 0rF THE P R 0 ?'F???k0 2011 APR 21 An 10.- li4 C'UMBERLANU PENNSYLvpij v, Citibank (South Dakota) N.A. Case Number vs. Kathryn L. Runk 2011-3423 SHERIFF'S RETURN OF SERVICE 04/14/2011 07:5 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 010 at 1950 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathryn L. Runk, by making known unto herself personally, at 511 Rittenhouse Square, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. S EPHE14 BENDER, DEPUTY SHERIFF COST: $38.00 April 18, 2011 !c? r,ountySuite Shenfr_ Teeesoft. nc. SO ANSWERS, RON R ANDERSON, SHERIFF