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HomeMy WebLinkAbout11-7841FROTT)NOTNI 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. DEBORAH SCHREFFLER 3085 Spring Road Carlisle PA 17013-8713 `.,T 1 P f io ?? Ur7 aCRL,J CQU?3T KNISYLVANIA IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. cim 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-53712 oo? '?ot a m tad °b`I Ck?ross?{ VLL ab???D 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 Attornev for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff V. CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH SCHREFFLER 3085 Spring Road Carlisle PA 17013-8713 Defendant : NO. CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Deborah Schreffler who resides 3085 Spring Road, 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 credit card account (hereafter the Account) with account number ending in 1167. 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 $12,399.83 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 $12,399.83, and the costs of this action. Burton,Xeil & 49$6ciates, P By: Yal?. ?VVeinin, Esquire In making this communication, we advise Burton Neil & Ass?/iates, P.C. is a debt collector. 0 O 0 Mtmnp 2 U1y"L r e < ?1z 3 nX3; r a2. K n $ sir it to M 3 5 tl It 5 O ? M W s 3 '-,b' D 0 O O r" D O ] W 0 Y iii S ? A n-0 ri Or-b-4 ?Sa m X W 0 C ¦ 1 I1 Ol U . ` 0 in _ A _N N C 3 e 3y R S Rap1?h 0 j r L? Cr v r fU W .A De W r ru W .A .A 0e W O O r r W O O O .A r Ln S I www.clticards.com Account Member How To Reach Us 1-800-THANKYOU Cust DEBORAH SCHREFFLER Service Account Activity Account Number OX 6500 B Apr 14-May 12, 2011 1167 Member Since 2003 SIOUX FALLS, SD 57117 Minimum Payment Due: New Balance: $12 399 83 $12 39 Summary of Account Activity , . , 9.83 Previous Balance $12,245.20 Fees Payment Due Date: Payments •0.00 Sale Post Description A ount m 06/09/2011 Paynwttmu"asra0a?ataysooPM Other Credits - - 0.00 05/12 _ ____ _ _ LATE FEE APR PAYMENT PAST DUE _ _ ' 3500 bW time anthepayment duNate. Purchases + 0.00 _.__...,_.._..._..?.?_.___.._.__.. TOTAL FEES FOR THIS PERIOD _. __ . - Late Payfsent wwnk* If we do not receive your Cash Advances + •00 33.00 minimum payment by the date fisted above, you may have to pay a late fee of u to 85 a d APR Fees rged + n Y v our s ma be increased up to the va able Penalty APR of 29.99%. _. In-terest ChargeC _ __ ? +?p9;63 Interest Charged 1111111101111111111111 Payfwent tiantllt? If you make only the New Balance 12,399.83 --- Post 05/12 Deseriptlon INTEREST CHARGED TO S ? - TANDARD PURCH Amount minimum payment each period, you will pay more in I t Past Due Amount $1,752.47 ? - --- ----- TOTAL INTEREST FOR THIS PERI __ .. 119,E n erest and it will take you longer to pay off your OD 1?9. balance. For example: Amt. Over Credit Limit $529.83 If you make no additional charges You will pay off And you will and he balance shown up paying an Credit Limit $11,870 U! 9 this card and on this statement' estimated total Available Credit 88t1tnonM You pay_ N about Of- _ Cash Advance Limit $6,600 Onty the rniNmun I moat mantMs) j $12 400 Available Cash Limit -----`'0 ` . WYment ---------------- -- --_--? ;...._ ____, For Inf-lion a tt ."t mnseanq rMtts tali 1-877 337 8188 ?__- Statement Closing Date 05/12/2011_. . . Days In Billing Cycle 29 n n 3 r n M iof2 2011 Totals Year-to-Date TOW tees cisarged in 2011 $175.00 Total ktterost t:ltr0ad In 2011 $602.95 rest Charge Calculation And" Percentage Rate Willis the annual Interest rate on your account. .......... . Annual PeRentege Balance eCt to of Balance Rata t Interest Raq Interest Charge Standard PUrch 12240% (V) $12,302.86 (D) $119.631 Standard Adv 21.990% $0.00 (D) $0 00 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. How to Reach Us 1-800-THANKYOU Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 •••• •••• •••• 1167 Access your account online: www.cltlcrds.com Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 06/02/2011 to allow for enough time for regular mail to reach us. 2of2 Verification I, Sheili M. Stackhouse , 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. ,,6 rn S?tu??? Signature C-53712 Deborah Schreffler Account number ending 1167 1000 C-53712 /324 rE PROTHONOTAIR 1' 2013MAY IQ AH11, 114 CUMBERLAND 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,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 11-7841 CIVIL DEBORAH SCHREFFLER Defendant : CIVIL ACTION-LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton eil &'As ociates, P.C. By Yalerb. Weinstein, Esquire A orney 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.