HomeMy WebLinkAbout11-41854
?j?A??? r
'it'iBEFIAND COUNTY
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. ``? p
SANDRA LUTZ NO. I ,- " 1 l 0 S b\i1
918 Loring Lane, Mechanicsburg PA 17055-4000
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-50247
ate Ct.) L Qd °
&W 10145y
lz4. a5 49 1 2;'-
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.
SANDRA LUTZ
918 Loring Lane
Mechanicsburg PA 17055-4000
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 Sandra Lutz, who resides at 918 Loring Lane, 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
MASTERCARD credit card with account number ending in 6544 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 $7,603.49 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 defer)lant for the sum of $7,603.49, and
the costs of this action.
Burto *Attomev ates, P.C.
By :
ker, Esquire
laintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
(M
w
0
On
m
u
Y (A
u ^'
dQ
0 0
0 N
to
u?
0
?o
J
U
r
CIO C
O
Ej El
a a
• V
t r > V)
4 W M o J
J
SU) i,°?a
30 «x?r
om oo?r
S .-. V m to rn
°u
v° E
•~
• a
°o
3 uZ
3 4 vdi
a
0 3 1
0 0
L 4
V C6 O M
N U) N N
y N
Y
i
C ?
0 0 O O
« m ?
• 1
O
0 a C (D In O O?
a c
O •
m
?
'
C 0 0 0 0
0 O o 0 0
<
`r
? 0. • N N N N
'
C 6
< C
<
ti
4 «
•
? K
°
j •
P O
0
? e
C
r O
U
n u
a >
u < 0
WE o n a 0
U
3
m°
W
N
` a
k
d
u
Z
c a`
v c
• U
¢
>
Cr
°
° G M
V
° v) a
a in a
r a
O N
N 01
N r
N ?
w ?
? I
O
L
r
Y
? 10
O
H O , N
O N .i
N .! =
G
i M
i ( In n
o a P a l L
c
N V
O
0 o
00
• w ?00 O O
? ?
la•. N O 00 1 O
aua) N O 0 0 V N 7 00 0 0 0 0 o'
E°
' r 0 ' 0 0 0 0 0 Ln o r V> 0 vi O
+ + } v D• N m
>N + r N N N
a _ N
c E .. :' o y
0 J E J C >
u u
a m
r
. j
° J
u
t - U
. u m m E c
W (D
Eo w
E L a v
N a, m o o .J.. ? a
t ? E G
E> > 4, u t 3 y m
>
m E
> >
W a ! a a' U z n a u d a Iw o
>o
ay. O o >'0P
?m-off
J' E -6
y c ? a
• c• o
ui a >oaN > ° °
<N
« > as >a0
Ot :
d??a E?
ao 02L n in
=
v
=
? x ?
r
a.
u 0o co E a>
Z r o
C= E= n
U r4 a
"
a a: 3
0 I
»
6
0 *
02u) c. 1
3 -
E
0
.'C?a
n 3 a
It
o ff E, 3°:0?
...>v
C o
•'*-"
t
MSl o IS
-
Q
2
Fa - _
Is
°
?
?
E.
S,o ?O> A
> o°..
i-
yL? !'2
o dx
? u
;
Y
>a
- .22
E A G Q a as q
¦ w'; m $ as $!= 18
-
.Q
to C) M
0 Eq..«aEi >j$
$I
N dJ°d
7 Jai, V T« PEI>
CL N Erg i E i0 LL
date Ce"7 _ ert?ouril (aid ctiPCA P
www.citicards.com
New Balance:
$1.603.49
Minimum Payment Due:
$7.603.49
Payment Due Date:
12/23/2010
000000 MC 32 A 0
SANDRA LUTZ
918 LORING LN
MECHANICSBURGPA 17055-4000
N
O
Detach and follow Payment inatructione on reverse
make, check payawt te:Citi Cards
5 O ? 6544
moan ad:
Paymant must be MaWed by 5:00 PM
iocal time on the payment due data.
CITI CARDS
P.O. BOX 182564
COLUMBUS, OH4 3 21 8-2 564
EXHIBIT q
E
0
V
N
T
°
u
V
3
3
3
e
c
? o
e
a ° ? u
Ln i N Vq
y IL ° to
aW N ? j
CN
0 n
b 6 E 'Dx a
r oj r
boo o00 u
S- VmN 4
Ln
T
E O
Z ° E Y
`c o ao d
o,', s> o`O
Q } C'?p ?•ip
d
a?i Y 3 E
a `O E o
?°ET
rp fl-+•
a. O
G ?'? C w
- EE
m
z0
y
E mT
dt
d 1? r j J
O
>
E ro >
E o
4, L
via
-w TO y=j 0
vw
$ c:E
o -
o?
To
v
n
g? .
Y
-d 0
-m?
QUO °io
EN
N
c M
m 0-
w 22
] N
a as a 1
y ° ai
cE O i
m° d.-
-E~ d
•ip T rp N?
` O
.nVv N.-
n d •ip ?
2 n a E
Verification
Abbie Mosley
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-50247
Sandra Lutz
Account number ending in 6544
1000
CITIBANK (SOUTH DAKOTA), N.A.
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff
V.
SANDRA LUTZ
918 Loring Lane
Mechanicsburg PA 17055-4000
Defendant
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11-4185- CIVIL
CIVIL ACTION - LAW
Praecipe for Default Judgment
To the Prothonotary:
C-3
C n
--4
Z7J Z MM
Wr' tv
° MM
o0
ac -*?
n-n
"
Z,C E5 fi
J?t
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
$7,603.49
$7,603.49
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 information received from
the defendant and/or the Department of Defense website. N
JUDGMENT BY DEFAULT ENTERED
AND DAMAGES ASSESSED AS ABOVE.
NOTICE%VE D A.R.CIV.P 6
47 - U '44~ 1
Pro,,. o
By:
& Associates, P.C.
Blasker, Esquire
Attorne or Plaintiff
I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
The law firm of Burton Neil & Associates is a debt collector.
C-50247
QI zlq 4
Nc?i>c?- Moab
CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 11-4185- CIVIL
SANDRA LUTZ
Defendant : CIVIL ACTION - LAW
TO: Sandra Lutz
918 Loring Lane
Mechanicsburg PA 17055--4000
DATE OF NOTICE: June 01, 2011
IMPORTANT NOTICE
C-50247
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 claans 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. 717-249-3I E
800-990-9108
& Associates, P.C.
In making this communication, we advise our office is a
debt collector.
By:
Derek C. r, squire
Attorney for inti f
Identification No. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
OCT 28 1='
PE Ns YLVAi IA
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. 11-4185-CIVIL
SANDRA LUTZ
Defendant : CIVIL ACTION-LAW
Praecipe to Satisfy Judgment
To the Prothonotary:
Mark the judgment Satisfied .
Burton - : Associates, P.C.
By: \,•\
►-rek . Blasker, Esquire
Attorney for Plaintiff
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
C-50247/318
9. 5-0 17
Ce /.3.7/27--g
ge.29W/5