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HomeMy WebLinkAbout11-3930i 1',r r 0TNOt?OTAR i' 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 2011 APR 2l AM 11: 2" CUI IBERLAIrO COUNT`" pEt,'NSYLYANIA IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. KOOLA MENSAH NO. \V3Q 50 712 Stanwix Circle, Apt 4 Carlisle PA 17013-2152 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-49576 s avA va00 PC, 1e a58q 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 : NO. KOOLA MENSAH 712 Stanwix Circle, Apt 4 Carlisle PA 17013-2152 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 Koola Mensah, who resides at 712 Stanwix Circle, Apt 4, 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 1760 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 $1,717.84 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 $1,717.84, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarke Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. SITE:KCCL TM:GJ-5000 ACID:KCB3075 02/25/11 19:24:16 nn:?! A >-or o 0 MAaD 0 0 0 r '• f M . 3 0 N e .?1 c m MK 3 D x W W s O A• n o_ n = N O ^ .? n a o 3 o N n ? to 0 N O t X 3 www.citicards.com Account Member KOOLA MENSAH How To Reach Us 1-800-568-5000 Customer Service BOX 6500 SIOUX FALLS, SO 57117 Account Activity ber Oct 07-Nov 04, 2010 760 Member Since 2009 Minimum Payment Due: New Balance: Summary of Account Activity $1,717.84 $1.717.84 Previous Balance $1,658.68 Fees Payment Due Date: Payments $0.00 Sale Post Description Amount 12/02/2010 Payment must be received by 5,00 PM Other Credits $tr - It/04 LATE FEE - 0CT PAYMENT PAST DUE 35.00 _- 66 local time on the payment due date. Purchases .,.,....,.....,.m.... w + 0.00 00000000 66 0000 Late Payment 1larnia? If we do not receive your Cash Advances ----- + 0.00 - - - - °° °° ° - - minimum payment by the date listed above, you may Fees Charged - + 35.00 TOTAL FEES FOR THIS PERIOD 35.00 have to pay a late fee of up to $35 and your APRs ma ..,__ be increased up to the variable Penalty APR of 29.99 A. interest Charged +24.16 New Balance 1,717.84 Interest Charged nvn 0b? i00> mx71 c?0 to rn rn O_ N A N_ m N a A M X :sue RP ?a S$ i 1 01 a ? 0 n n ar a N S 4 1i A 3 Z Minimum Payment WaraloW If you make only the minimum payment each period, you will pay more in Past Due Amount $318.00 interest and it will take you longer to pay off your Amt. Over Credit Limit $217.84 balance. For example: If you make no i You will pay off And you will end additional charges the balance shown up paying an Credit Limit . . . , -v... _ . $1,500 using this card and on this statement estimated total . . „. _„ _ .._ „. ?_.. . . Available Credit ....,_..-..,..,. .„,. 0 each month you pay.. in about ... i of - ?-w`-"- Cash Advance Llmlt -- ?- S00 Only the minimum 1 month(s) $1,718 - Available Cash Limit payment Statement Closing Date 104 2010 ror lMonation about credit counseling services, call 1-877-337-8188. Days in Billing Cycle 29 tof2 Post Description Amount 11/04 - INTEREST CHARGED TO STANDARD ADV 1.57 00000000 _ 84 0000 Y0000000000 11/04 INTEREST CHARGED TO STANDARD PURCH - 22.59 00000000 84 0000 - 0000000000 wr..,. TOTAL INTEREST FOR THIS PERIOD 24.16 2010 Totals Yoar-te-Date, Total fees c6arpl in 2010 $329.00 - - ----------- --- ------- ----- Total interest c6a1rN in 2010 $261.62 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. - _ Annual Percentage Balance Surt to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 17.990% (V) $1,580.36 (D) $22.59 ADVANCES Standard Adv 21.990% $89.94(D) $1.57 Account Number ..........*.11760 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. 4+ Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 11/25/2010 to allow for enough time for regular mail to reach US. 2of2 How to Reach Us 1-800-568-5000 Customer Service BOX 6500 SIOUX FALLS, SD 57117 Access your account online: www.citicards.com Verification I,bb+e McrleY , 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.:[ 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 unswom falsification to authorities. Signature C-49576 Koola Mensah Account number ending in 1760 1000 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. KOOLA MENSAH 712 Stanwix Circle, Apt 4 Carlisle PA 17013-2152 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-3930- CTVIL : CIVIL ACTION - LAW Praecipe for Default Judgment c e } r-- _._ c? . CD --s q - Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $1,717.84 Less Credits: $100.00 TOTAL $1,617.84 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN U DER PA.R.CIV.P. 236 onotary Burton Neil & As tes, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 1V f?l'Y C-49576 ?lir • # 1?'06 ??' 7 ?,r?f deha lw?? CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-3930- CIVIL KOOLA MENSAH Defendant : CIVIL ACTION - LAW TO: Koola Mensah 712 Stanwix Circle, Apt 4 Carlisle PA 17013-2152 DATE OF NOTICE: May 24, 2011 IMPORTANT NOTICE C-49576 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office below. 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 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C By: Neil Sarker, Esquires Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-3930- CIVIL KOOLA MENSAH Defendant : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ?YZA / L5,aA' I Prothonotary By: puty If you have any questions concerning the above, please contact: Neil Sarker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.