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Home My WebLink About05-2831 BURTON NEIL & ASSOCIATES, P.c. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite] 70 West Chester, PA ]9380 (610) 696-2]20 Attorney for Plaintiff CITlBANK (SOUTH DAKOTA) NA 70] East 60th Street North, Sioux Falls, SO IN THE COURT OF COMMON PLEAS Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA CONSTANCE H HOLLEY 1050 Country Club Road, Camp Hill PAl 70 I ] NO. DS - .;ij>.3 { (]Lo~L ~~ 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 ALA WYER 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 MAYBE 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 ] 70 13 Telephone No. 717-249-3]66 or 800-990-9 lOb c- 3602 T 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 v. CUMBERLAND COUNTY, PENNSYL VANIA NO. D5- .;LP.31 r2iu~L ~~ CONSTANCE H HOLLEY 1050 Country Club Road, Camp Hill, PA Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiff is ClTlBANK (SOUTH DAKOTA) N.A., with place of business located at 70 I East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Constance H Holley, who resides at 1050 Country Club Road, Camp Hill, 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 5424180507878954 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 $3,829.84. Wherefore, plaintiff demands judgment against defendant for the sum of $3,829.84, and the costs of this action. BURTON NEIL & AS By: crATES, P.C. The law firm of Burton Neil & Associates, P.C. is a debt collector. . ~ II' 08/20/04 j~~~f:~!~~j~@~m~j~j~!~ $3829.84 $9999.99 SITE: KC-CL ~j~j*ij~!~@~fir ~lim~~~!~j~i~.M~!~ CONSTANCE H HOLLEY 307 MOUNTAIN RO DILLS8URG 17019-1517000 PA CITI CARDS P.O. BOX 8118 S HACKENSACK, NJ 07606 -8118 Citi~ Card Account ~1.II'llber 5424 1805 0787 8954 Customer Service: 1-800-866-9900 80X 6500 SIOUX FALLS. SO 57117 Sale Date Post Date 7/27 7/27 7/27 7/27 Accot.rlt Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 10/26/2001 ADVANCES Standard Adv Total Credit line $3300 St-ltement/ C1051n.9 Date 07/27/2004 Available Credit line $0 AmGunt Over Credit line $529.84 Ca$h Advilnce limit $600 Avallilble Cash Limit $0 Purch/Adv Minimum 0". $96.91 TM:CO-5000 02/09/05 ~. eltl New Salanee $3829.84 Minimum Amount Due $3829.84 Amount 35.00 0000000000 35.00 0000000000 56.66 0000000000 35.25 0000000000 (=) Now Bellanee- $3,829.84 $0.00 $3,829.84 Bel anee Su Jee 0 Finance Charge Perle Ie Rate Da s ThIs 81111n Period: 32 omrna ANNUAL APR PERCENTAGE RATE 28.240% 28.240% 28.240% 28.240% 28.240% 28.240% EXHIBIT B Past Due $315.14 Ref.rence Number Acttvlty Since Last statement Standard Purch LATE FEE - JUN PAYMENT PAST DUE 66 0000 OVER CREDIT liMIT FEE 62 0000 PURCHASES-FINANCE CHARGE-PERIOOIC RATE 84 0000 Purch/Adv Thru 10/26/2001 PURCHASES-FINANCE CHARGE-PERIODIC 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. revlous Balance $3,667.93 $0.00 $3,667.93 (+) urc ases & Advances $70.00 $0.00 $70.00 (-) aymen s & Credits fO.oo 0.00 0.00 $2,288.57 $1,423.69 $0.00 0.07737%(0) 0.07737%(0) 0.07737%(0) ACID:KCB7150 01:48:27: Verification I, Jaime Payne am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA) N.A. retained to perform services including but not primarily limited to collecting delinquent debt. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: Sllw/{J) ~yne Constance H Holley 5424180507878954 C-3602 $n\((..", ,r'" '('_';'\, l ~ B 0<> 0 () .:-::;;;> !GJ 1Ii t; c:-~ -n ~, .-j '- :c., ~ ,- rnE ~ .. ,.. C> I CJ - ~ - () ",', "- -0 -",'. :lJ ...c:: c; r:- r'o ~ C:? ~ -...1 ~ =< </) CJ ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-02831 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS HOLLEY CONSTANCE H R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOLLEY CONSTANCE H but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HOLLEY CONSTANCE H 1050 COUNTRY CLUB ROAD CAMP HILL, PA 17011 PER POST OFFICE, DEFENDANT'S ADDRESS IS 307 MOUNTAIN ROAD DILLSBURG, PA 17019 - YORK COUNTY. sheriff's Costs: Docketing Service Not Found Surcharge Postage 18.00 10.36 5.00 10.00 .37 43.73 S~,...~" ~ ,..' ~.- .... .,....- ---~~...-,.--".- '..-~' -.,.- , - R. Thomas Kline Sheriff of Cumberland County ~ BURTON NEIL 06/13/2005 Sworn and subscribed to before me this .lo e.. day of ~ .-' ;)00:;, A.D. ~Q~~ Pr th notary . .... 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 ClTIBANK (SOUTH DAKOTA) NA : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-2831 CONSTANCE H HOLLEY Defendant : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTON N~L & ASSOCIATES, P.C. BY: VI Burton N , Esquire Attorney or Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-3602 1111111111111111I11111111111111111111111 111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111I1111 lBF' ?~i" t'7~; ::~~. '..-- '~ ~~, (') S; =-~ .~ ...., e') = cJ" o ~ ~ o "T1 -l :.J:-n rnp"" 'Or.. l:'V UeS --i":;"i :L- -f-~ C')(") 2m ~~ "l> or.) --<;, "" '"'" ::;0: ~ C) N