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Home My WebLink About04-6379 .. BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 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, PENNSYLVANIA v. BERTHA R MILLER 49 Garden Parkway, Carlisle PA 17013-9221 Defendant NO. Oli - 10379 C,u~L~8LVV\ : 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. TillS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO IDRE 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-4245 BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 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, PENNSYLVANIA v. NO. BERTHA R :MILLER 49 Garden Parkway, Carlisle, P A 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 Bertha R Miller, who resides at 49 Garden Parkway, Carlisle, 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 5424180661654464 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 $3,596.81. Wherefore, plaintiff demands judgment against defendant for the sum of $3,596.81, and the costs of this action. IL & ASSOCIATES, P.C. " By: Burto~ui: Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 10/08/04 ~~~~~!~~~~~~li#~~@ $9999.99 SITE:KC-CL $3596.81 t~j~ji!~~M~j~ ~~~~~i!it~H~~g~j~j~ CITI CARDS P.O. BOX 8109 S HACKENSACK. NJ 07606-8109 BERTHA R MILLER 49 GARDEN PKWY CARLISLE 17013-9221000 Citi~ Br.!?n~~5~:l~~r~Yk~~e!~gr~:. ~.ard Account NIJIIIbef 5424 1806 6165 4464 Customer Service: 1-800-866-9900 BOX 6500 SIOUX FALLS, SD 57117 PA Total Credit Line $3000 Statement/ Cl051n9 Date 09/14/2004 ",yall4ble Credit Line $0 Amount Over Credit Line $596.81 Past Due $314.13 Cash Advance Limit $900 Ayallable Cash Limit $0 Purch(Adv Minimum Due $91.21 Sale Date Post Date Reterence Number 9/14 9/14 9/14 9/14 Account Summary PURCHASES ADVANCES TOTAL Rate Summery PURCHASES Standard Purch ADVANCES Standard Adv Activity Since Last Statement Standard Purch LATE FEE - AUG PAYMENT PAST DUE 66 0000 OVER CREDIT lIMIT FEE 62 0000 PURCHASES*FINANCE CHARGE*PERIOOIC RATE 84 0000 Standard Adv AOVANCES*FINANCE CHARGE*PERIOOIC RATE 84 0000 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. IMPORTANT INFORMATION ABOUT CREDIT REPORTING: WE MAY REPORT INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS, MISSED PAYMENTS, OR OTHER DEFAULTS ON YOUR ACCOUNT MAY BE REFLECTED IN YOUR CREDIT REPORT. Previous Balance $2,l489.98 :,950.62 $3,440.60 (+) Purchases & Advances $70.00 $0.00 $70.00 (-) Payments & Credits to.oo 0.00 0.00 (+) FINANCE CHARGE $62.39 $23.82 $86.21 TM:CO-5000 11/06/04 ~. Cltl New Balance $3596.81 MInImum Amount Due $3596.81 Amount 35.00 0000000000 35.00 0000000000 62.39 0000000000 23.82 0000000000 (=) New Balance $2,1622.37 :,974.44 $3,596.81 Balance Subject to Finance Charge Periodic Rate Days This Billing Period: 32 Nominal ANNUAL APR PERCENTAGE RATE $2,520.07 $962.11 0.07737%(0) 0.07737%(0) 28.240% 28.240% 28.240% 28.240% EXHIBIT ACID:KCB7150 16:39:05: A . VERIFICATION j.h <-of fed-Q~e 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: J (~ - I 0'- 0'-) ~ ~.-:::..~../.~ /F':?~~# Bertha R Miller 5424180661654464 ~ ~ ~ !l U( .vt ;: ~ ) !",.~, '- .. - > (J -l::. r --' ~ "J:;- -,-, ..() (g C:-,l ::~j 8 I ~ U) '- ') f, i i^~ f) fi} 1'-,' :" J'C I C) " .,,' 1 ~ , -I 1 :rJ I ;'1 - , 1 --ft ) " C.) i ( "\ ' - "-~> .J . '. 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. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-6379 BERTHA R MILLER Defendant : ClVIL ACTION ' LAW PRAECIPE TO DISCONTThiUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without pn:judice. .~::t~-~ ^,SOC~TES, PC Burton~uire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-4245 n ~::r1 --. '""Tl +~r: C'~',] ~n ",,':" \ CJ (':.) SHERIFF'S RETURN - REGULAR CASE NO: 2004-06379 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MILLER BERTHA R DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER BERTHA R the DEFENDANT , at 1630:00 HOURS, on the 5th day of January ,2005 at 49 GARDEN PARKWAY CARLISLE, PA 17013 by handing to BERTHA R MILLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff1s Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31.70 9' -~fG:.~:'~P:~", R. Thomas Kline /'~ ,:'_l<<t;,"-.~~::"w~"'7.~' 01/06/2005 BURTON NEIL Sworn and Subscribed to before By: t/-~/~ . Deputy ~ me this ,')'t.f~ day of ll~.../ a{h)~ A.D. / ..} ~ .U-, (2~ ~prothonotary ~