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Home My WebLink About11-7387Burton 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. r? C? C ra r® -?3 CCU C.?7 ?.- C71, CD IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA LINDA A MARKLEY : NO. 11- 7387 Cjvi IerM 244 N 32nd Street, Camp Hill PA 17011-2810 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-53086 $Qa. oo P A ArN at 10114,7 e a & Sy q(1 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. LINDA A MARKLEY 244 N 32nd Street Camp Hill PA 170112810 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 Linda A Markley who resides at 244 N 32nd Street, 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. 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 5914. 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 $22,980.18 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 $22,980.18, and the costs of this action. Burton Neil & Associ e C. By: Neil Sarker, Esquire Attorney for Plaintiff In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. Z W Whir nnZo A O p n 0-0 40 ic W Z N in < N 0 0 u 5 10 ?°zr m $ 3 v?r N O _ o 13 ? s 0 ? fA e o a A 0 N m o o ;e civn Or0'1 cc) n 30n WxXP c_0 VrN N O O A W N Oa N o m in -3 0 a +^ °3 5 .q 3 e 2 r 2.7 Ba :o to .A L? rU fir .A 13. C3 r ru R1 .A M C3 r O O ru W 0. C3 C3 t-r r r W a: Y g n 'e n d CL M How To Reach Us www.citicards.co m 1-800-756-4000 Account Member LINDA A MARKLEY Customer Service Account Activity Account Number BOX 6500 SIOUX FALLS, SC Mar 16-Apr 15, 2011 5914 Member Since 2004 57117 Minimum Payment Due: New Balance: $22 980 18 $22 98 Summary of Account Activity , . , 0.18 Previous Balance $22,616.52 Fees Payment Due Date: Payments 7$0.00 Sale Post Descr?tion Amoun t Paym.ntmusteetecelvwaySOOPM 05/13/2011 OtherCredits -? 0 .00 _.._._._.,. __._ -. _ . .___ 04/15 LATE FEE MAR PAYMENT PAST DUE 35.00 bcal time on the paynwnsw data Purchases +$0.00 We Pa y If we do not receive your Cash Advances + 0.00 TOTAL FEES FOR THIS PERIOD 35.00 minimum payment nt by by the e date listed above, you may have to pay a late fee of up to $35 and your APRs may fees Charged ---- ?+$35.00 be increased up to the variable Penalty APR of 29.99%. Interest Charged {$32866 Interest Charged ' Mi New Balance 22.980.18 Post Description Amotmt nimum Payment Nfarntn If you make only the 04/75 INTEREST CHARGED TO STANDARD PORCH 328.66 8.56 minimum payment each period, you will pay more in Past Due Amount $2,995.64 Interest and It will take you longer to pay off your TOTAL INTEREST FOR THIS PERIOD 328.66 balance. For example: Amt. Over Credit Limit $0.00 If you make no You wilt pay off Ana you will end Credit Li it 2011 Totals Year-to-Date additional charges the balance shawl up pain an m _ $26,250 '? using this card and on this statement i estimated total Available Credit $0 Total fees charged In 2011 $140.00 x each month you pay. ! In about_ of. Cash Advance Limit $9 200 Onry the mml - mom I month(s) ( $22,960 0 -' " Available Cash Limit , " --0- Total Interest charged In 2011 $1,253.43 payment Statement Closing Cate 04 15 011 I Fx into maiian about aea l ccunsrunq sewices u,err aar-else. Days in Billing Cycle 31 Interest Charge Calculation Your Annual Percentage Rate (APR)rs the annual interest rate on your ac,a nt. Annual Percentage Balance Sub?'e" to ?- Interest Charge Type of Balance Rate (APR) Interest Rate Interest arg PURCHASES 3 Standard Purch 16.990% $22.775.15(D) $328.66 B ADVANCES Standard Adv 21.990% $0.00 'be 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 din 10 S pm, Central Time. Please give us the opportunity to assist you. • Iof2 How to Reach Us 1-800-756-4000 Customer Service BOX 6500 Account Number SIOUX FALLS, SD 571!7 '••"••• •,•' 5914 Access your account online: w_yw.clticards.com Please be sure to pay on time. It you submit your payment by [nail, we Suggest you mail it no later than 05/06/2017 to allow for enough time for regular mail to reach US. 2 ot2 Verification 1, Shmi M Rackhouse , 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 by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am 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. 4"__.-?_ Signature C-53086 Linda A Markley Account number ending 5914 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY,, Ronny R Anderson I Sheriffyr?tp o1?r?nbcr f n ^ , I ?. Jody S Smith° T 17i ` p Chief Deputy is' r'' r i? , Richard W Stewart Solicitor C?FF E -rE S"FR'FF Citibank, NA Case Number vs. 2011-7387 Linda A Markley SHERIFF'S RETURN OF SERVICE 10/11/2011 01:29 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2011 at 1329 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Linda A. Markley, by making known unto William Markley, Husband of Defendant at 244 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy f the sa e. MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $43.00 October 13, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ;oj CountyS'.ji(t', She nft. Te eosoft. Inc