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Home My WebLink About11-4008i? -{?FIFiCE II y -2 Ph i? 32 ?UMIBFERLAND COUNTY PENNSYLVANIA 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. p C (VI l JOHN C RIGGLEMAN NO. ' I • qM tA) 81 Kensington Drive, Camp Hill PA 170117911 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-49951 UA %aa.oo ?a M41 V_0093SGtlo 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. JOHN C RIGGLEMAN 81 Kensington Drive Camp Hill PA 170117911 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 John C Riggleman, who resides at 81 Kensington Drive, Camp Hill, 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 6968 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 $4,342.12 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 $4,342.12, and the costs of this action. eil &/Ms6ciates. P.C. D %Wel'nstein, Esquire nev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt ,1010 O • z _fl p It K ?• ¢ 3 3 m f o. Iu 17 V -i Gl D O r W N N n z m N O D ? ? n ° D z 0 v ID n n n V 0:0 0 Or O 3o> mx;o C v p a to N 0 0 =m A A N ro N O?+ A M X -? o c ?Y n 0 3g ?g 9 3 i n s 6 N 3 Y f') n 01 n N 03/11/11 23:33:05 How To Reach Us www.citicards.com 1-800-925-8871 Account Member JOHN C RIGGLEMAN Customer Service Account Activit bar BOXY SIOUX FALLS. SD Oct 20-Nov 17, 2010 6968 Member Since 1999 57117 p Minimum Payment Due: New Balance: Summary of Account Activity z $4,342.12 $4,342.12 u Previous Balance $4,245.74 Fees Payment Due Date: Payments 0.00 Sale Post Description Amount 12/1rJ/2010 Payment must be received by5AOPM Other redlfs -? $nT TOTAL FEES FORTHISPERIOD 0.00 local time an the payment due date. Purchases + 0.00 Late Paytwsat waraing:lf we do not receive your i i Cash Advances ? + 0.00 Interest Charged m n mum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may Fees Charged _ -_..-. + 0.00 _._ Post Description Amount = be increased up to the variable Penalty APR of 27.24%. Intere arged + 6.38 New Balance 4,342.12 11/17 INTEREST CHARGED TO STANDARD PURCH 8.18 Mi A*u Payment 1larning: if you make only the 4 00000000 84 0000 0000000000 minimum payment each period, you will pay more in I Past Due Amount $1,127.78 11/17 INTEREST CHARGED TO PURCH/ADV-04/06. 88.20 I interest and it will take you longer to pay off your -- balance. For example: balance. Over Credit Limit $142.12 00000000 84 0000 0000000000 H you make no You will pay oft I And you will end Credit Limit $4 200 TOTAL INTEREST FOR THIS PERIOD 96.38 _ additional charges the balance shown up payln an using this card and on this statement estimated total ' Available- Credit•° , -?0 > each month you pay-. In about... of... -- Ca9?Vance Imi - 2010 Totabt YeaFtrDato . Only the minimum I month(s) $4,342 payment Available Cash Limit 0 Total foos eba r7N in 2010 $284.95 Statement Closing Date 1 17 2010 - - - - rorlntormation about credit counseling servlces,call1-877-]37.8188. Days in Billing Cycle 29 Tata1 snterost "asyd in 2010 $786.16 0 3 E Y 3 3 + lot2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rat e on your account. Annual Percentage TM Balance Sublet to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 27.240% (V) $36024 (A) $8.18 Purch/Adv Thru 04/19/2006 27.240% (V) $3,685.50 (A) $88.20 ADVANCES Standard Adv 27.240% (V) $0.00 (A) $0.00 How to Reach Us 1.800-925-8871 Customer Service 80X 6500 Account Number SIOUX FALLS. SD 57117 -* -* .+.+ 6968 Access your account online: www.citicards.com 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. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 12/08/2010 to allow for enough time for regular mail to reach US. 2of2 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-49951 John C Riggleman Account number ending in 6968 1000 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JOHN C RIGGLEMAN 81 Kensington Drive Camp Hill PA 17011-7911 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : NO. 11-4008 Civil CIVIL ACTION - LAW Praecipe for Default Judgment Neil 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: TOTAL $4,342.12 $4,342.12 r? MT.- -urn ::O CD a-n =F3 am z? Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unworn 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 ' rma?ion received from the defendant and/or the Department of Defense website. ,// JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTIC I UN)PA.R.CIV 236 _2 Pr rib.-... '? ... c? c rnw C_ 2;0 x r ..?Z o cs 20 _ -? o Dz P.C. Y VL_ mstein, Esquire A rney for Plaintiff I . NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-49951 avv'? it (LI.co pd ° 1 ?d? b4U8y (24 abC) 7 100 CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-4008 Civil JOHN C RIGGLEMAN Defendant : CIVIL ACTION - LAW TO: John C. Riggleman 81 Kensington Drive Camp Hill PA 17011-7911 DATE OF NOTICE: June 01, 2011 IMPORTANT NOTICE C-49951 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 ssociates, P.C. In making this communication, we advise our office is a debt collector. By: Yale D einstein, Esquire Atto y for Plaintiff Ident ication No. 89678 106 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120