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Home My WebLink About11-7322 T r E L. (`EG ()E; F 11,C LE 2011 SEP 22 PM 12: 40 ICUMBERLAPd J C;JJi i PENNSYLVANIA Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 2 2 / SASHA H EDELMAN NO. //- 73 v A / 1 141 W Louther Street, Carlisle PA 1 70 1 3-293 8 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 S 1 Telephone No. 717-249-3166 or 800-990-9108 ?z. 00 C-52589 c# /o7143 F#,"26,51030 . . BURTON NEIL & ASSOCIATES, P.C. By: Edward J. O'Brien, Esquire, Id. No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attornev for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. SASHA H EDELMAN 141 W Louther Street Carlisle PA 170132938 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complain 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Sasha H Edelman who resides at 141 W Louther Street, 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. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to Citibank (South Dakota), N.A., by means of a CITI MASTERCARD credit card account (hereafter the Account) with account number ending in 8897. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A., effective July 1, 2011, as approved by the Office of the Comptroller of the Currency. 6. Accurate records of all debits and credits to the Account were maintained by plaintiff. 7. Defendant was provided with monthly statements for the Account including the billing statement attached hereto as Exhibit A (redacted to remove confidential information). The monthly statements accurately stated the previous balance and the debits and credits to the Account for the prior billing period. 8. Defendant had for many months after receipt of a billing statement made payment on the Account or retained the statement without payment. 9. Defendant retained the Exhibit A statement without making payment by the stated due date. 10. Defendant's assent to the Account balance set forth in the Exhibit A statement is manifested through the prior conduct of defendant either making payment on the Account or retaining the statement without payment, after receipt of the monthly billing statements. 11. As a result of said assent, an account stated for the sum of $2,530.44 exists 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 $2,530.44, and the costs of this action. BurtonN eil & As ciates, P.C. By: d Q Esquire Attorney fo aintiff In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. M r 1 ? N D!'D O ?:E= 0 O U ea 3 N Z '0 2 0 N u 3 u E n b ? yl y yrl 0 0 >X" O r r" N "' 3 0 D -0 ON;N y • < W ii D N O e n 3 » 01 R nvn OQy mKA C_o 111 0) N N O9 X09 N m N On A ?3 g 3'g ?g m .c :o CP .a C3 rU Ln W C3 r C3 ru in W C3 r r C3 (3 C3 0" Ln O r C3 ff, 0 n !7 d M is a I 0 A 3 www.Citicards com Now To Reach Us Account Member 1-86C-756-4000 Account Activity SASHA H EDELMAN Customer Service Feb 24-Mar 23, 2011 Account Number Box 6500 Minimum Payment Due: New Balance: 8897 Member Since 2007 SIOUX FALLS, SD 57117 - $2,530.44 .130.44 $2 530 44 Summary of Account Activity , . Payment Due Date: Previous Balance ..._.?._.. - Payments $2,438.11 --° 00 --- 0 Fos 04/21/2011 PaYmentmustMreceWWtv&ooPM ocal tans an the Payment etweate. Lat P Other Credits `-?"'°' Purchases `"M? ' - ?0 w--------.. ° Sale Post_ ---_-?.. .. 03123 ?- Description ?LA TE FEE FEB PAYMENT PAS E --i mourrt e ayment by the If we do not receive your minimum Payment fee the date listed above, you may have to pay a late fee of u t $ Cash Advances -- F Ch '+$0 .00 0-0 _........ 0 ` --- T Du TOTAL FEES_F OR THIS PERIOD ' - 35.00 p o 35 and your APRs mayy be Increased up to the variable Penalty APR of 29.99%. ees arged +5 35 00 Interest C arged- Mo--- ` . Interest Char ad 35.00 YlnLnum Payment IMarnYtg It you make only the minimum payment e h Ne w Balance + 73 2,530.44 Post Descr tlon ac period, you will pay more in interest and It will take you longer to pay off your Past Due Amount $570.28 03/23 INTEREST CHARGED TG STANDARD PURCH " "" t ` --Am56-ous 7 balance. For example: Amt. Over Credit Limit $4 TOTAL INTEREST FOR THIS PERIOD . 3 If you make no i Y 30.44 56.73 ou will additional charges i paY off ! And you will end 1110 balance shown up paying an Credit L imit $2 10C) us ng this card and each month you pa ' on this statement estimated total I . SO _Available redB ?" -??_-- Y._ n abo ut_ _ CWi the minimum I oi-- _?- Cash AdvanCe Limit °'"?" 700 ? payment 1 month(si $2,530 Availabl a -Cash - -------?? F. im/wmanui .bout "edil i"s c d 1 e77 aiea. Statement C"516 9 03723]2011 . -337. Days In BllOn C l ' g yC e 28 2011 Totafs Year-to-Date Total fees charged ti 2011 - - - - _.? 5105.C0 Total inters:t chargN N 2011 ??_ ? - _?-" 5175 12 rest Charge Cakulatlon Annual Percentage Rata tAPRlis the annual interest rate m ytwr account. of Balance Annual Rate (APR) W Balance SUbw**ct to ` 'HASES ----- ,- Interest Rate ___ Interest Charge ASES --------___,_ 3 a° • loft Standard Purch 29.990% (V) $2,465.95 (D) ADVANCES $56.73 Standard Adv 29.990 46 (V) $C-.0"') (0" $O.i;G Help is available! Please call the tol!-fl e number shown above to learn al:out our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to pm, Central Time. Please give us the opportunity to assist you. Account Number ............ 8897 please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 04/14/2011 to allow for enough time for regular mail to reach us. How to Reacts Us 1-800-756-4000 Customer Service BOX 6500 SIOUX FALLS, SD 5;117 Access your account online. _www.citicaras co 2of2 Verification I, Shelb M. S- 4hp e , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. CCSI is a service provider for Citibank in that it services credit card accounts owned by Citibank This includes accounts previously owned b Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am y authorized to make this verification on behalf of Citibank. 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-52589 Sasha H Edelman Account number ending 8897 1000 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY c. _ 'HF "FRIFF i'C0 ?27 A 1 L. ?S , e t} 1 Citibank, NA Case Number vs. Sasha H. Edelman 2011-7322 SHERIFF'S RETURN OF SERVICE 10/21/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for'="he within named defendant to wit: Sasha H. Edleman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Sasha H. Edelman. Request for service at 141 W. Louther Street, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisle Postmaster has confirmed, Sasha H. Edelman's new address is 3515 E. Hearn Road, Phoenix, Arizona 85032. SHERIFF COST: $33.00 SO ANSWERS, October 21, 2011 RON R ANDERSON, SHERIFF ic1 GOUt1tVSU1tC Sher,tf Teieasuf't_ Iitc.