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Home My WebLink About04-4402BURTON NElL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 1N THE COURT OF COMMON PLEAS 701 East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA LYNDA K I4:ETRICK 306 Sandbank Road, Mount Holly Springs PA 17065 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 800-990-9 108 c-2066 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neff, Esquire Identification No. 11348 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 70I East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. LYNDA K HETRICK 306 Sandbanl~ Road, Mt Holly Spring, PA Defendant CWIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Lynda K Hetrick, who resides at 306 Sandbank Road, Mt Holly Spring, Cumberland County, Pennsylvania. 3. Plaintiff, a national banking association, engages 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 credit card with account number 5491130009273947 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the accom~t stated, less credits, if any issued subsequent to the Exhibit A statemem, is $33,286.09. Wherefore, plaintiff demands judgment against defendant for the sum of $33,286.09, and the costs of this action. BURTOb?'~NEIL & AS~/SOCIATES, P.C. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. A'r T YourAT~TUn/vec~a/(~rd Statemmt ~age ~ or 3 April 15 - May 17, 2004 How To Reach Us A~ceunt Online: www.unlversalcard.com LYNDA K HETRICK Customer Service: 1 800 423-4343 or write Cardmember Services PO Box 44167 Accm..nt M91 13~0 ~927 3~47 Jacksonville, FL 3223t-4167 Calling Card + PIN No Annual Fee/Platinum Card Help is available! Please call the toll-free number shown above to learn about our Minimum Payment Due .................................... $33,288.09 speciaJ payment options. PJease give us Due Date~ ..................................................... June 11, 2004 the opportunity to assist you. Amount Past Due ............................................... ~114,38.82 Amount Over Limit ............................................ ~8,288.09 Please note that payments must bo Credit Line .......................................................... $25,000.00 received by 1:00 p.m., local time, on a Available C~edit ............................................................ $0.00 bank business day at the payment Cash Advance Limit ............................................. $5,700.00 processing facilib/that handles your Available Cash Advance Limit .................................... $0.00 payments, in order to be credited to your account as of that day, and payments must conform to the payment instructions set forth on the reverse side. All conforming Previou~ Ralance 33,286 ~3.q payments received at the payment 09 Payments a~d Adjustmenls O OD MasterCard Ach~ty 0.00 processing facility after that time will be ]:otar AT&T Services 0.00 credited as of the following bank business #ew Balance $33,288.09 day. Note: DetaiJed activity starts on page 3. Payment Record Amount Paid: Date Paid: Che~k Number: 05491130009273947999999999995911 I 549! 1300 0927 3947 II JUN 3.1 2004 $33286.09 $33~'06,09][$ h,,llh,,llh,,,ll,,,M,lh,,lh,,h,l,,,,llh,h,,,lh,lhl IIh,,h,,hlh,lh,,,lf. h,h,,,Ih.lh,,lllh,,I LYNDA K Hi[TRICK AT&T UNIVERSAL CARD ATTNY ACCOUNT- COD£=LB34 P.O. 8OX 6111 aT HOLLY SPGS PA 17065-008! S HACKENSACK, NJ 07606-8111 Ihhl.lllllM.hlhlM,Ihhllh hh hllh,llhll,IMI EXHIBIT LYNbA I~ HETRICK Accounl~ 5491 1300 April 15 - May 17, 2004 In the return envelope, please: F~cio~e }'om'cbeckot tomtit order'. IncJude your account number and name on the front of your check or money order. Please, no cash or foreign currency. F~tck~e]/ola'13a~rme~t co[llx~. Do not staple or tape it to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. LYNDA K, HETRJCK , Page 3 of 3 ~r~l"r Account 54~1 1300 092? 3~47 April 15 - May 17, 2004 Toial MasierCard Ac[ivi[y ........................................................................................................................... ~0.00 PURCHASES CASH AOVANCES Total F~N~NCE C~RGE AT&T Universal Calling Card Calls ......................................................................................................... $0.00 VERIFICATION Plaintiffin this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Lynda K. Hetrick 5491130009273947 SHERIFF'S RETURN - REGULAR CASE NO: 2004-04402 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS HETRICK LYNDA K RONALD KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HETRICK LYNDA K the DEFENDANT , at 1414:00 HOURS, on the 7th day of September, 2004 at 306 SANDBANK ROAD MT HOLLY SPRINGS, PA 17065 by handing to MARLIN HETRICK a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Service 5.18 . Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 33.1809/08/2004 NEIL ASSOO Sworn and Subscribed to before By: me this /~ day of Deputy Sheriff / 'Prothonotary ' ' CITIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Sl~eet N, Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-4402-CV LYNDA K HETRICK 306 Sandbank Road Mount Holly Springs PA 17065 Defendant : CIVIL ACTION - LAW Praeeipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above ease in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $33,286.09 $.00 TOTAL $33,286.09 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, I verier that: I. The above are the precise last-known addresses ofthejudgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom j udgtnent is to be entered and to their record attorneys, if any, al~er the default occurred, and at least ten days prior to thc date of thc filing of this praecipc. 3. Pursuant to Section 201(b)(I)(A) ofthe Servicemembers Civil ReliefAct 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. JUDGMENT BY DEFAULT ENTERED BURTON,~ & bSSOCIATES, P.C. AND DAMAGES ASSESSED AS ABOVE., " N~ICE GIVEN UNDER PA.IL~IV.P. 236 ~--0' "-~ ~ ........ Burton Neil, Esquire Pro Prothonotary ~ - ' -(~ Attorney for Plaintiff I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Nell & Associates is a debt collector. c-2066 ~i~mANK (SOUTH DAKOTA) N.A. : IN TH]8 COURT Olm COMMON PLN, AS Plaintiff : CUMBERI,AND COUNTY, P]~INSYLVANIA : NO. 0~-4402-CV LYNDA K HE~ D~flmdaut : CIVIL ACTION - LAW Notfee of/ntmtio~ ~o File Praecipe for D~ault J~dgment TO: Lynda E Hetri~k 306 5mdlmnk Road Mount Holly $1nin~ PA 17065 DATI~ O~ I~TIC~: September 29. 2004 IMI~ORTANT NOTICE file in writing with the eou~ your defemos or obli~iom to the claims set t'mth against yo~ Ualem you within ten (10) day~ from the a,~- of this noli~e, s judgment may be enmed against you you may lose your property m other impmm~ fights. You shouldt~ this no~oe to your lawyer at ~. Ityou do not have a lawyer ~r c, mnot afford ~me~ go ~o m telephoto the following ol~lloe m find ~ ~ ~ z~ ~t legal help. This otilc~ can provide you with int~...~iim ~bout hiring a I&wyer. If you ~armot Ltf~rd to hire a lawyer, this o~ize may be able ~o ~-ovide you wi~ int~'~,~ a,,n about age,les that way offer 1¢~1 services ~o eli~ie ~ ~t a miuzed ~ee ~r no ~OI~M. ATION SERVICE S2 South B~d~o~d Sm~'t C~rlislc, PA 1701S T~]~pho~ No. 717.249-S 166 ~ BU~TON ~ &~SSOCIAT~S, P.C. BY: ~ Id~ificaliou No. 11~48 10~0 Andrew Drive, S~ii~ 170 W~t C~,,s~', PA 19380 610.-69~-2120 Th~ firm ot' Buriou Nell & Asso~{ates, P.C. is attmui~mg ~o collec't ~ debt. ~-2066