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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.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
HELGA T WALKER : NO. 1 l - `'1 5 A C{ h `
17 Pine Hill Avenue, Mechanicsburg PA 17050
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-49684 a%)A %.Ok?,OC 1'd Q1?
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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.
HELGA T WALKER
17 Pine Hill Avenue
Mechanicsburg PA 17050-1642
Defendant CIVIL ACTION - LAW
Complaint
I. 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 Helga T Walker, who resides at 17 Pine Hill Avenue, 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) RADIO
SHACK credit card with account number ending in 6039 hereinafter referred to as the credit card
account.
5. Plaintiff kept accurate running records of all debits and credits to the account.
6. Plaintiff provided 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 provided 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 $1,948.58 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 $1,948.58, and
the costs of this action.
Burton Neil & Associates, P.C.
_
By: c2f 477?-?
Trenton A. Farmer, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
Customer Service:
radioshack acoountonlinecom
Account Statement
Send Notice of Billing Errors and Customer Service Inquiries to:
RADIOSHACK CREDIT PLAN
PO BOX 653054, DALLAS TX 75265-3054
Ra01OWiacKe ® Account Inquiries:
l4M8-316-8480 3l?-
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Mailed payments must be received by 5:00 PM at the
information address for payments by the payment due date.
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Credit Limit 0.00
Available Credit 0.00
Statement Closing Date 01/10/2011
Next Statement Closing Date 02/07/2011
Days in Billing Cycle
31
TRANSACTIONS
Minimum Payment Due $586.90
Payment Due Date February 06, 2011
Late Payment Warning: If we do not receive your minimum payment by the
date listed above, you may have to pay a late fee up to $35.00.
Minimum Payment Warning: 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:
) W `YY'
Only the minimum payment 16 years $4,634
$82 3 years $2,934
(Savings=$1,700)
If you would like information about credit counseling services, call 1-877-337-8188.
Trans Date Description Reference # Amount
FEES
01/06 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD $ 35.00
INTEREST CHARGED
7/10 Interest Charge on Purchases $ 46.36
TOTAL INTEREST FOR THIS PERIOD $ 46.36
Access current and past statements -Set up email alerts
-Pay your bill online 24/7 with same day post ing* -View recent activit
y
Register now at radioshack.accountonline.com
' If payment is received by 5pm ET.
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4
-------------------------------------------------------------------- This Account Is Issued by Citibank (South Dakota), N.A.
-
-----------------
Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records- +
RadioShack Make Checks Payable to:
® RADIOSHACK CREDIT PLAN
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P
t Past Due Amount is included in the Minimum Payment Due.
,.
ayment Due Date New Balance Past
,s
Due Amountt Minimum Payment Due Amount Enclosed
r February 6, 2011 $1,948.58 $485.90 $586.80 $
SAVE STAMPS, TIME... AND TREES! Visit Account C)rline and register now for Online Bill Pay,
Paperless Statements and More.
KBAVRS 1 2 1110/11 28441 8
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A HELGA T WALKER PROC
ESSING CEN
TER
17 PINE HILL AVE
MECHANICSBURG, PA 17050-1642 DES MOINES IA 50364-0001
III Il111r111I1111111111111I111111IIIIlIIl1IIIl111111111IIt IIIII Ii
Print address
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Information About Your Account.
How to Avoid Paying Interest on Purchases. Your payment due date is at least 25 days after
the close of each billing cycle. We will not charge you any interest on purchases if you pay your
New Balance by the payment due date each month. This is called a grace period on purchases. If
you do not pay the New Balance in full by the payment due date, you will not get a grace period
on purchases until you pay the New Balance in full for two billing cycles in a row. We will begin
charging interest on cash advances (if available on your account) on the transaction date.
It you have a balance subject to a deferred interest or 0% APR promotion and that promotion
does not expire before the payment due date, that balance (the "excluded promotional balance")
is excluded from the amount you must pay in full to get a grace period. However, you must still
pay any separately required payment on the excluded promotional balance. In billing cycles in
which payments are allocated to deferred interest balances first, the deferred interest balance
will be reduced before any other balance on the account. However, you will continue to get a
grace period on purchases so long as you pay the New Balance less any excluded promotional
balances in full by the payment due date each billing cycle. We may refer to deferred interest
promotions as No Interest or No Monthly Interest promotions.
In addition, certain promotional offers may take away the grace period on purchases. Other
promotional offers not described above may also allow you to have a grace period on purchases
without having to pay all or a portion of the promotional balance by the payment due date. If
either is the case, the promotional offer will describe what happens.
How We Calculate Your Balance Subject to Interest Rate. For each balance, the letter
following the Annual Percentage Rate in the Interest Charge Calculation section on the front of
the statement indicates the method we use to calculate interest charges. For Methods B and E.
we use an average daily balance method (including current transactions) to calculate interest
charges. For Methods C, D and M, we use a daily balance method (including current transactions)
to calculate interest charges. To find out more information about the balance computation
method that applies to your account and how the resulting interest charges were determined,
contact us at the Account Inquiries number on the front.
Credit Reporting Disputes. If you think we reported inaccurate information to a credit bureau
write us at the Customer Service address shown on the front.
Report a Lost or Stolen Card Immediately. Call the Account Inquiries number shown on the
front.
What To Do if You Think You Find a Mistake on Your Statement
If you think there is an error on yoc r statement, write to us at the Billing Errors address shown
on the front.
In your letter, give us the following information:
Account information: Your name and account number.
Dollar amount: The dollar amount of the suspected error.
Description of Problem: If you think there is an error on your bill, describe what you believe is
wrong and why you believe it is a mistake.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing, You may call us, but if you do we are not
required to investigate any potential errors and you may have to pay the amount in question.
While we investigate whether or not there has been an error, the following are true:
We cannot try to collect the amount in question, or report you as delinquent on that amount.
The charge in question may remain on your statement, and we may continue to charge you
interest on that amount. But, if we determine that we made a mistake, you will not have to pay
the amount in question or any interest or other fees related to that amount.
While you do not have to pay the amount in question, you are responsible for the remainder of
your balance.
We can apply any unpaid amount against your credit limit.
Your Rights If You Are Dissatisfied with Your Credit Card Purchases
If you are dissatisfied with the goads or services that you have purchased with your credit card,
and you have tried in good faith to correct the problem with the merchant, you may have the
right not to pay the remaining amount due on the purchase. ,
To use this right, all of the following must be true:
1. The purchase must have been made in your home state or within 100 miles of your current
mailing address, and the purchase price must have been more than $50. (Note: Neither of
these are necessary if your purchase was based on an advertisement we mailed to you, or if
we own the company that sold you the goods or services.)
2. You must have used your credit card for the purchase. Purchases made with cash advances
from an ATM or with a check that accesses your credit card account do not qualify.
3. You must not yet have fully paid for the purchase.
It all of the criteria above are met and you are still dissatisfied with the purchase, contact us in
writing at the Billing Errors address shown on the front.
While we investigate, the same rules apply to the disputed amount as discussed above. After we
finish our investigation, we will tell you our decision, At that point, if we think you owe an
amount and you do not pay we may report you as delinquent
Important Payment Instructions.
Crediting Payments. If we receive your payment in proper form at our processing facility by 5 p.m.
local time there, it will be credited as of that day. A payment received there in proper form after that
time will be credited as of the next day. Allow 5 to 7 days for payments by regular mail to reach us.
There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form or
is not sent to the correct address. The correct address for regular mail is the address on the front of
the payment coupon. A payment made in-store is not sent to the correct address. The correct
address for courier or express mail is the Express Payments Address shown below.
Proper Form. For a payment sent by mail or courier to be in proper form, you must:
Enclose a valid check or money order. No cash, gift cards, or foreign currency please.
Include your name and account number on the front of your check or money order.
If you send an eligible check with this payment coupon, you authorize us to complete your
payment by electronic debit. If we do, the checking account will be debited in the amount
on the check. We may do this as soon as the day we receive the check. Also, the check
will be destroyed.
Copy Fee. We charge $5 for each copy of a billing statement that dates back 3 months or more.
We add the fee to the regular purchase balance. We waive the fee if your request for the copy
relates to a billing error or disputed purchase.
Payment Options Other Than Regular Mail.
Online Payments. Visit the web address on the front and sign up for online payments.
Enrollment may take a few days. If we receive your request to make an online payment by 5 p.m.
Eastern time, we will credit your payment as of that day. It we receive your request to make an
online payment after that time, we will credit your payment as of the next day. For security
reasons, you may be unable to pay your entire New Balance with your first online payment.
Pay by Phone Service. You may use this service any time to make a payment by phone. You
will be charged S14.95 if a representative of ours helps expedite your payment. Call by 5 p.m.
Eastern time to have your payment credited as of that day. If you call after that time, your
payment will be credited as of the next day. We may process your payment electronically after
we verify your identity.
Express Payments. You can send payment by courier or express mail to the Express Payments
Address. This address is Customer Service Center, Dept. CCS 911, 4740121st Street, Urbandale, IA
50323. Payment must be received in proper form at the proper address by 5 p.m. Central time
to be credited as of that day. All payments received in proper form at the proper address after
that time will be credited as of the next day.
RPLG 10110
T00508 X E 05/01/02 89 34 RSUP 04/30/10 P 7 0 9194 0685 0005
Page 2 of 4 RPLG 10110
Account: **** **** **** 6039
s .=?'M``
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Total Fees Charged in 2011 $35.00
Total Interest Charged in 2011 $46.36
INTEREST CHARGE CALCULATION Your Annual Percents a Rate (APR is the annual interest rate on our account.
PURCHASES
Standard 28.85% M 18.65 .46
Standard Prior 06/11/10 28.85% M $1,873.51 5.90
CASH ADVANCES
Standard 28.85% M
.00 .00
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Page 3 of 4
Account: **** **** **** 6039
Page 4 of 4
Verification
Mena Reynolds
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 unworn falsification to authorities.
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Signature
C-49684
Helga T Walker
Account number ending in 6039
1027
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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!all JUN 14 AM 10,'
`'E-'NS Y1.VAt1(A 27
Citibank (South Dakota) N.A.
vs.
Helga T Walker
SHERIFF'S RETURN OF SERVICE
Case Number
2011-4542
06/02/2011 05:43 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on June 2,
2011 at 1743 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Helga T. Walker, by making known unto Ilonka Weaver, Daughter of Defendant at 17
Pine Hill Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same
time handing to her personally the said true and correct copy of the same.
RONALD HOOVER, DEPUTY
SHERIFF COST: $38.00
June 03, 2011
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
SO ANSWERS,
4NR?
ANDERS
ON, SHERIFF
(r) {.;nu,<*yS;?ite Sherd. Tereosolt. In;
F BLED OFFICE
fh PROTHONOTAR'`s
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.
Plaintiff
V.
HELGA T WALKER
Defendant
2011 JUL 1 I AM 11: 27
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11-4542-civil
CIVIL ACTION - LAW
Praecipe to Settle, End, & Discontinue
To the Prothonotary:
Mark the above matter Settled, Ended and Discontinued.
Burton Neil & Associates, P.C.
By:
Trenton Farmer, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-49684