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Home My WebLink About04-5963 BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, P A 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANlA v. PAMELA A TERRY 66 Old Stonehouse Road S., Carlisle P A 17013 Defendant NO. d-I-~W c'u~L ~'"'I : 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 TillS 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. TIDS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TillS 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-468 BURTON NEIL & ASSOCIATES, P.e. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITmANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff : IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO D4- S'9t.J C/~;L ~~ PAMELA A TERRY 66 Old Stonehouse Road S., Duncannon, PA Defendant : CNIL 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 Pamela A Terry, who resides at 66 Old Stonehouse Road S., Duncannon, 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 5424180504473866 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 account stated, less credits, if any issued subsequent to the Exhibit A statement, is $4,678.22. Wherefore, plaintiff demands judgment against defendant for the sum of $4,678.22, and the costs of this action. .---. BUR.TO~.& ASS~TES, P.C. \;By: ~ \- 1./ Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 12/22/03 ~~~~~t~i~~ii~~~~~~~ $4678.22 $419.09 ~~~fi~~~fii~~~~~~~ ~f!ifi~~mi~W~~~~~~ SITE:KC-CL PAMELA A TERRY PO BOX 242 DUNCAN NON 17020-0242000 CITI CARDS P.O. BOX 8118 S HACKENSACK, NJ 07606 -8118 PA Citi~ Driverls Edge~ Card Charter Rebates Account Number 5424 1805 0447 3866 PAYMENT MUST BE RECEIVED BY 1:00 PM LOCAL TIME ON 12/22/2003 T. report bill.... err...... wrIte to this ad*ess; call1nq wltl not preserve yo.. rl9fts.- statement/Closing Date 11/26/2003 Total Credit Line $8100 Available Credit Line $3421 Amount Over Credit Line $0.00 + Cash Advance Limit Available Cash Limit New Balance $400 $400 $4678.22 Past Due M~f~~~~e Minimum Amount Due $312.66 + $106.43 = $419.09 Sale Date Post Date Re'erence Number Activity Since Last Statement Standard Purch CREOITSHIElO PREMIUM 74 0000 lATE FEE - OCT PAYMENT PAST DUE 66 0000 PROPl1002200252712112 800-338-3815 WY 61 N5969USA 2019 PURCHASES*FINANCE CHARGE*PERIOOIC RATE 84 0000 Purch/Adv Thru 08/28/2000 PURCHASES*FINANCE CHARGE*PERIOOIC RATE 84 0000 Balance Transfer - CharQed To Offer 4 PURCHASES*FINANCE CHARGE*PERIOOIC RATE 84 0000 11/26 11/26 11/13 11/13 YXYNMQOO 11/26 11/26 11/26 * CITI ORIYER'S EDGE CHARTER MEMBER REBATES last Month's Balance Earned this Month Redeemed/Expired Current Balance TM:CO-5000 10/16/04 For Customer Servk:e, call or write 1-800-866-9900 BOX 6500 SIOUX FAllS, SO 57117 *TOTAl 94.98 1.00 0.00 95.98 Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am - 5 pm, Central Tlme. Our records show home phone 717-805-1644 and business phone 717-561-9915. Please update above coupon if incorrect. Account Summary PURCHASES AOYANCES TOTAL Previous Balance $4,488.95 $0.00 $4,488.95 (-) Payments & Credits $0.00 $0.00 $0.00 (+) Purchases & Advances $87.84 $0.00 $87.84 Rate Summary PURCHASES Standard Purch Purch/Adv thru 08/28/2000 Offer 4 AOYANCES Standard Adv Balance Subject to Finance Charge Periodic Rate $1,493.12 $993.47 $2,075.11 $0.00 0.07668%(0) 0.07668%(0) 0.07668%(0) 0.07668%(0) (+) FINANCE CHARGE $101.43 $0.00 $101. 43 Amount 2.89 0000000000 35.00 0000000000 49.95 75414913317 33.20 0000000000 22.09 0000000000 46.14 0000000000 (=) New Balance $4,678.22 $0.00 $4,678.22 Days This Billing Period: 29 Nominal ANNUAL APR PERCENTAGE RATE 27.990% 27.990% 27.990% 27.990% 27.990% 27.990% 27.990% 27.990% EXHIBIT ACID:KCB7150 16:38:17: A VERIFICATION Leola Phenix is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in 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. Date: \ ~ \ \ . o~ ~~.~ ~ Pamela A Terry 5424180504473866 1~~ <0 ~ ~ C> ~~iP (;; ! -- j? "t-. .. (") ,..." ~ = ~ r; c;::) ~'.. ..... r\ 'I % :r::o 0 ...;: 1'11, ", -Of? '-D is ::..\'-) :2 ':1': =ii _.!~-J.o. ~-'~(~ {.:-t (...) ~) ;:,:~ ~;O \.0 .< CIT.lBANK (SOUTH DAKOTA) NA 70 I East 60th Street N, Sioux Falls, SO 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA YS. : NO. 04-5963 Civil PAMELA A TERRY 66 Old Stonehouse Road S. Carlisle PAl 70 13 Defendant : CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $4,678.22 $.00 $4,678.22 TOTAL Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities, I verifY that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(I)(A) of the Servicemembers Civil Relief Actof2003 (SCRA), the defendant is not in the military service of the United States based on information receiv om the defendant and/or the Department of Defense website.... i JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER P A. CIV.P.236 BY: Burton Neil, Esquire Attorney for Plaintiff 1.0. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-468 ClTIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLV ANJA : NO. 04-5963 Civil PAMELA A TERRY Defendant : CIVIL ACTION - LAW Notice orIntentioD to File Praecipe for Default Jadllmeat TO: Pamela A Terry 66 Old Stonehouse Road S. Carlisle PA 17013 DATE OF NOTICE: December 30, 2004 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or obligations to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to [md out where you can get legal belp. This office can provide you with infonnation about hiring a lawyer. If yon 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 8(){}1-9I08 BURTON ~ & ASSOCIATES, P.C. BY IJd!- '--___........ N..,..'.. . Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 The firm of Burton Neil & Associates, P .C. is attempting to collect a debt. C468 BU~TON NEIL & ASSOCIATES, P.c. BY: Burton Neil, Esquire Identification No. ] ]348 ] 060 Andrew Drive, Suite ] 70 West Chester, P A ] 93 80 6]0-696-2]20 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) NA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-5963 Civil PAMELA A TERRY Defendant : CIVIL ACTION - LAW RULE OF CML PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on ..J~) 'lLf ~~\ I Prothonotary ~4~p P7t/?///tJ Deputy " If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing ] 060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 6] 0-696-2120 The law firm of Burton Neil & Associates is a debt collector. ~ );' ~ :';) ~ tt- 8 (f'I '- ~ J ~ ~ C> F -~~t? !f- J:- f""~ ,- ~":l {',:::) '-)"" (,.... 1",) , (,,) o -n ..~ -"\- {-;1?J t"n o (J.) "";1 (:''S ..,In " L"',) (~~'") ',.-" '1J SHERIFF'S RETURN - REGULAR CASE NO: 2004-05963 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS TERRY PAMELA A DAVID MCKINNEY I Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TERRY PAMELA A the DEFENDANT I at 1110:00 HOURS I on the 8th day of December, 2004 at 66 OLD STONEHOUSE ROAD CARLISLE, PA 17013 by handing to PAMELA TERRY a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.44 .00 10.00 .00 32.44 .~~?l;:~~~tu;: ,?~ R. Thomas Kline 12/09/2004 BURTON NEIL Sworn and Subscribed to before By: a~ Deputy heriff t:t-- me this '7 ~. /""..', day of ( i ~ '---~ QZQ'D!J A.D. ~ c/. ~~C.~ ~, P othonotary I