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Home My WebLink About12-1003FILED-OFFICE OF THE PROTHONOTARY 2012 FEB 16 AM 11: 29 CUMBERLAND COUNT`` PENNSYLVANIA 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ILANA C BOYUM ; NO. (a ?1- VI) 8 Dogwood Circle Shippensburg PA 17257-9446 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-56371 / 304 6D a? 81n?.?s? °? ?.? a?1137 BURTON NEIL & ASSOCIATES, P.C. Trenton A. Farmer, Esquire, Id. No. 209422 Brit J. Suttell, Esquire, Id. No. 9- UIV Y0 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. ILANA C BOYUM 8 Dogwood Circle Shippensburg PA 172579446 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 Ilana C Boyum who resides 8 Dogwood Circle, Shippensburg, 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 7642. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011. 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 $2,488.07 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 $2,488.07, and the costs of this action. Burton Neil & Associates, P.C. By: Tr nton A. Farmer, Esquire By: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-56371 / 205 8 0 ? Y p H •+y OVI J..{{ ?on v.`. 4 ? X X i,- um°Hi 8 lu u ? J 0 M S C Err L? g? all 3 ll ll a $ 888800o On 8 ? ($ a8 Y r 0 N r r ? + ? + ? N N 41/1 I? 'C y j O < t ? uu a _¢EEg'i ?.? ? m ? < u Eu't'AUc ? u qu A `m m > ci m ?su g 2 q Y A N y r. = 1 E C>?N > q O?ui.- < u<u<vip 20 CY -Z L ?? yg>° „`$> 1`? m cm- a tt,? E r• ao'??a ??ggi?a ?° agog p! " ltl Ea g, fr'?t 1.9 E M a 7 M OEr$ E.5 z f N N O N N O p L N V/ E f N 0 ?o E t ? a ?n d Ln m Id E C 0 dy O $ N O > O ° N Gam. C O?•N 9 N E2 r-,4 Ei?7 c:2o ?i W a CL yo d $ c? N i?41 d mU`I c dy d a: E m i- d yyyy?? u 2ma N "P? 6"mf P" drat M 001" IMLIMUC&AND M•••wrmy-b.Chl Cards 7642 0253807 0253807 0007800 1313 New Balance: $2.530.07 Mlnlmum P aymnt Dur. 764 $2.530.07 Mapmt Enebmat Payment Due Data: 07/15/2011 P?? ? e..««wa ey io0 Pw local Hm? a H» pglnw?t 01» 44. 000000 MC 32 A 0 ILANA C BOYUM B DOGWOOD CIR SNIPPENSBURGPA 17257-9446 CITI CARDS P.O. BOX 182564 COLUMBUS, ON 43218-2564 EXHIBIT ?_ I O O u Y V C N M • O^ y O V > to Ym A N ? m YI J RN EgQ > a0 ..T a?? y~M? O x • 00 ZX= _ I UmN < EE N 7 10 d 7 ? > 2• N p O 0 N u` a E < 3M Ea > L ao cE EE N L 0.O L 7 ? O O C >a E° a; y O 7 ?p ?y y0 EN =; co o? >o o• c m of a? H? v0 ac a .. m= M Wm LE E= Verification I Tiene Reynolds , am employed by Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. 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 unworn falsification to authorities. Signature C-56371 Ilana C Boyum Account number ending 7642 1000 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, N.A. Plaintiff V. ILANA C BOYUM Defendant PLMSYLVA i rT Z"ll R 2F PH 2: 2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012-1003 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: C? Trenton A. Farmer, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-56371 / 318