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Home My WebLink About11-3553Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 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. DANIELA TUBBS 100 Shirley Lane Boiling Springs PA 17007-9592 Defendant a" 0 1 ff?y7p? NO 1AR?a Y '(11! J 1 J A 11: 07 'UMBE21AND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11- 355f Ci"I 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-47839 S as ¢?mpd ot W99%91 ¢*a57MO . Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 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. DANIELA TUBBS 100 Shirley Lane Boiling Springs PA 17007-9592 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 Daniela Tubbs, who resides at 100 Shirley Lane, Boiling Springs, 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 8287 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 $26,492.59 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 $26,492.59, and the costs of this action. Burton Neil & Associates, P.C. By. Trenton A. Farmer, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. www.citicards.com 1r 6i• 287 1/17/10 26492.59 $5061.76 DANIELA TUBBS 100 SHIRLEY LN BOILING SPRINGS 17007-9592000 PA Citi® Driver's Edgea Platinum Select Card-Charter Rbts Account Number: 8287 www.citicards.c Summary of Account Activity Previous Balance $26,026.00 Payments - 0.00 Other Credits - 0.00 Purchases + 0.00 1 Cash Advances + 0.00 Fees Charged +$35.00 Interest Charged +$431.59 New Balance Past Due Amount Amt. Over Credit Limit Credit Limit Available Credit Cash Advance Limit Available Cash Limit Statement Closing Date Days in Billing Cycle 20 V1 0695 1 MC 4 CITI CARDS PO BOX 183051 COLUMBUS, OH 43218-3051 Customer Service: 1-800-866-9900 BOX 6500 SIOUX FALLS, SD 57117 Payment Information i«ait,onnbep ymentduedate. New Balance $26,492.59 Minimum Payment Due $5,061.76 Payment Due Date 11/17/2010 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may a increased up to the variable Penalty APR of 29.99%. $26,492.59 Minimum Payment Warning: If you make only the minimum $2,788.58 pa ment each period, yyou ll will pay more in interest and it wi take you longer to pay off your balan ce. For example: $1,542.59 If you make no You will pay And you will end additional charges off the balance up pa inq an $24,950 using this card shown on this estimated total $0 and each month you statement in of... $2,6$0 pay... about... 0 1012112010 Only the minimum payment 33 year(s) $62,261 30 $881 3 year(s) $34,516 (Savings= $27,745) If you would like information about credit counseling services, call 1-877-337-8188. Sale Date Post Date Reference Number Activity Since Last Statement Amount Fees 10121 LATE FEE - SEP PAYMENT PAST DUE 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Charged 10121 INTEREST CHARGED TO STANDARD PURCH 10121 INTEREST CHARGED TO PUR PR-08/11/10. TOTAL INTEREST FOR THIS PERIOD 2010 Totals Year-to-Date Total Fees charged in 2010 149.73 Total Interest charged in 2010 4,052.01 1.61 429.98 431.59 EXHIBIT 6 SEND PAYMENTS TO: PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. 135 www.citicards..com 20 V1 0695 1 MC 4 DANIELA TUBBS C fir' Sale Date Post Date Reference Number Acthrity Since Last Statement Amount DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned 0.00 Ad'ustments / Expired -8.07 NE DRIVER'S EDGE REBATES -8.07 Previous Balance Purchase Rebates Earned 361.30 PREVIOUS DRIVER'S EDGE REBATES 361.30 TOTAL REBATES AVAILABLE 353.23 Bonus Rebates ma 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. Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 8.07 rebates expired on OCTOBER 21, 2010 35.09 rebates will expire on NOVEMBER 19, 2010 Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am - 5 pm, Central Time. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 11/10/2010 to allow for enough time for regular mail to reach us. Interest Charge Calculation Type of Balance PURCHASES Standard Purch Purch Prior 08/11/10 ADVANCES Standard Adv Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Percentage Balance Subject to Rate (APR) Interest Rate Interest Charge 29.990%(V) $65.47(D) $1.61 19.990% $26,168.54(D) $429.98 29.990%(V) M ON D) $0.00 ..NU YATNtNIS IU: 135 PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. Verification 1, Abbie Motley 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 unworn falsification to authorities. f Signature C-47839 Daniela Tubbs Account number ending in 8287 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart) Solicitor ?001111r of ulnbrrt QrFICE T,. c• RIFF F 1LE?U-GFFiCL H! PPOTHOP40TARY 2011 APR 20 PM 2: 0 CUMBERLAND COUNT' PENNSYLVANIA Citibank (South akota) N.A. vs. Daniela Tubbs Case Number 2011-3553 SHERIFF'S RETURN OF SERVICE 04/14/2011 09:0 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2011 at 21109 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Daniela Tubbs, by making known unto herself personally, at 100 Shirley Lane, Boiling Spri gs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. --a RYAN BURGETT, DEPU SHERIFF COST: April 18, 2011 00 SO ANSWERS, RON R ANDERSON, SHERIFF (q Count Suite Shenff. Teleosuft, Inc FILED-OFFICE t = , E FROTHONOTAR't, 2011 JUL 1 i AN 11: 29 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 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 Plaintiff V. DANIELA T'UBBS Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3553-CIVIL : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: Trenton . Farmer, squire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-47839