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Home My WebLink About11-3775t >° THE P ? THONOT?RY Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 M I APR 18 Pty 2. 39 1060 Andrew Drive, Suite 170 West Chester, PA 19380 CUMBERLAND COUNTY (610) 696-2120 PENNSYLVANIA 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. KENDALL S LEHMAN NO. II - 3- 775 2171 Newville Road Carlisle PA 170157747 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 HERE 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-49343 ?`? ,? /77* Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. KENDALL S LEHMAN 2171 Newville Road Carlisle PA 170157747 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 Kendall S Lehman, who resides at 2171 Newville Road, Carlisle, 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 0726 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. r 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 $2,407.69 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 $2,407.69, and the costs of this action. Associates, P.C. By: , Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. rl N A ),::! z ° D ° Z n ? N N v r i 1 0 r °1 r r 3 A 3 - ?rt-13 -+d 17 D m ? r ? ° ? n ? ^ r r ?DD ° n Ut A ? n C n r»n ion mx? c ? p 0 U xm W A N OD N A X X Mme a) isaaaaaall - ? -Z ao a? c t? m 3$ o = p 0 ?a a 6 3 F 0 lu i 3 a n m n N ^v 3 d S E 3 3 S SITE:KC-CL TM:GJ-5000 ACID:KC83075 02/26/11 23:22:33 www.citicards.com Account Member KENDALL S LEHMAN Account Activity Oct 06-Nov 03, 2010 mbar 0726 Member Since 2007 How To Reach Us 1.800-846-8444 Customer Service BOX 6500 SIOUX FALLS, SD 57117 Minimum Payment Due: New Balance: Summary of Account Activity $2.407.69 $2.407.69 Previous Balance $2,352.89 Fees Payment Due Date: Payments _....,.._...,...-._.._.,...__. - 0.00 Sale Post ._..,.......?_............w._ ......_....._._....._...-...-.,_........_ Description Amount ,...,_,._.._.._............._......_...-_.-_._.- 12/01/2010 Payment must be neeNed by 8:00 PM Other Credits 0.0_0_ TOTAL FEES FOR THIS PERIOD 0.00 local time on the payment due date. Purchases + 0.00 L ? If receive ate Paywrent xarw a we do not your Cash Advances- + 0.00 interest Charged minim payment by the um date listed above, you may have to pay a late fee of up to $35 and your APR Fees Charged +0.00 Post Description Amount be increased up to the variable Penalty APR of 28.99 /o. Interest Charged 11/03 ?._- .____ _...___.-..__.. --_...-.,_,.__.._ INTEREST CHARGED TO STANDARD PORCH 54.80 New Balance 2,407.69 Mining m Payment WarwiW If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no You will pay off - And you will end additional charges Ithe balance shown up paying an using this card and on this statement estimated total each month you pay In about-. of.. - -- - -- Onlytheminlmum i month(s) $2,408 paymen t For Information about credit counseling services, call 1-877-337-8188. Past Due Amount Amt. Over Credit Limit 00000000 84 0000 0000000000 $1.316.65 ___..____ ................._..__..__ _.._.__ _?..___..._._..._...._._?__.__.. ....-.-.--_.._._..._._..._, ._. ._-°-- TOTAL INTEREST FOR THIS PERIOD 54.80 2010 Totals Year-te-Date Total fees charged in 2010 $0.00 .............. _ Total interest chary" in 2010 $378.21 $1,01224 Credit Limit $1,000 Available Credit - Cash Advance Limit" '- $0 -'-'-" $300 Available Cash Limit Statement Closing Date so 11/03/2010 - Days in Billing Cycle 29 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Percentage Balance SuVoct to Type of Balance Rate (APR) Interest Date Interest Charge PURCHASES Standard Purch 28.990% (V) $2.379.24(D) $54.80 ADVANCES Standard Adv 28.990% (V) $0.00 (D) $0.00 Minimum Payment Due includes past due amounts. Your account may be with a collection vendor and when you call our number, you may be referred to the vendor. Please call the toll-free number shown above Monday-Thursday 8am to 6 pm or Friday 8 am to 5 pm, Central time. 1-800-846-8444 1of1 Verification Abbie Motley I, , 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-49343 Kendall S Lehman Account number ending in 0726 1000 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CUMBERLAND COUNTY, PENNSYLVANIA KENDALL S LEHMAN 2171 Newville Road, Carlisle PA 17015-7747 Defendant(s) NO. 11-3775 CIVIL ACNB 39 Carlisle Road, Newville, PA 17241x,-' T7 : Garnishee(s) : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER r? 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2.. against KENDALL S LEHMAN , Defendant(s) 3. and against ACNB , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) a2Q. 00 ft A"1?y 34. OD CBr NO LEVY - GARNISHMENT ONLY ga.00 C8F Serve interrogatories on garnishee at: 39 Carlisle Road, Newville, PA 17241 W. 00 1, Sol. 409 d so 5. Amount Due $x-69 50 - PO ATrJ Interest from 6/6/2011 $168.10 Credit 9999:60 Total $1,675.79* 4s, as 806io *Plus writ costs 50 LL Dated: December 12, 2012 Derek C. Blask , Esquire C*0797 Attorney for Plai iff 2#a8q3(0 y ,?&?g,tj%uud NOTE': tinder paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. C-49343 € HE pKOT"t1€)40 fit 2913 MAR 15 PM 2: 29 PE YL VCOUNTY I Burton Neil&Associates,P.C. By: Derek C.Blasker,Esquire ID.NO.202150 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. CUMBERLAND COUNTY,PENNSYLVANIA KENDALL S LEHMAN Defendant NO. 11-3775 CIVIL and ACNB Garnishee : CIVIL ACTION-LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against ACNB, garnishee. Burton jej Associates, P.C. By: D tt e Blasker, Esquire A or Plaintiff The law firm of Burton Neil&Associates is a debt collector. C-49343 a� U�. A f f v4 i 'E pf"Offlo'4 li'�Aat 2013 MAR 16 PM 2: 49 'WWRLAND COUNTY P�°I tS`tLVA'RiA Burton Neil &Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 11-3775 CIVIL KENDALL S LEHMAN Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton Associates, P.C. By: Wr k C. Blasker, Esquire Atto key for Plaintiff The law firm of Burton Neil &Associates is a debt collector. C-49343 /318