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Home My WebLink About05-3060BURTON 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 V. DANIEL R BAKER 1613 Chatham Road, Camp Hill PA 170116009 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- 1?64.6 61i0f1C-T if-11 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-5993 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 V. DANIEL R BAKER 1613 Chatham Road, Camp Hill PA 170116009 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O E - ,36L O CIVIL ACTION - LAW Complaint l v ?-1 ??lL.v?-1 C', _ 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 Daniel R Baker, who resides at 1613 Chatham 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 5424180496030211 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 $3,462.20. Wherefore, plaintiff demands judgment against defendant for the sum of $3,462.20, and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. By: L Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. w 02/25/05 $3462.20 $9999.99 SITE:KC-CL TM:CO-5000 ACID:KCB7150 05/13/05 19:47:57: CITI CARDS P.O. BOX 8102 DANIEL R BAKER S HACKENSACK, NJ 1613 CHATHAM RD 07606-8102 CAMP HILL PA 17011-6009000 " ll, Y ti+ Adv Citi A antacge Card AAdvantase is it resister tradenArh of Acwrican Airlines. Inc. Account Number 5424 1804 9603 0211 Customer Servke: 1-800-866-9900 Total Credit Une Available Credit Une Cash Advance Limit Available Cash Limit New Balance $3000 $0 $600 $0 $3462.20 BOX 6500 Statement/ Amount Over PurcnjAdv Minimum SIOUX FALLS, SD Closln Data Credit Llna Past Due Minimum Duo Amount Due 57117 02/02/2805 $462.20 + $298.60 $82.87 $3462.20 Standard Purch 2/02 LATE FEE - JAN PAYMENT PAST DUE 35.00 66 0000 0000000000 2/02 OVER CREDIT LIMIT FEE 35.00 62 0000 0000000000 2/02 PURCHASESsFINANCE CHARGE*PERIODIC RATE 77.75 84 0000 0000000000 Purch/Adv Thru 03/03/2004 2/02 PURCHASES-FINANCE CHARGEePERIODIC RATE .12 84 0000 0000000000 Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 8 5 C t l Ti t pm, en ra me. 9 pm, or Saturday, am o Please give us the opportunity to assist you. EXHIBIT Account Summary revlous Balance (+ Purchases & Advances {-) Payments & Credits (+ FINANCE CHARGE _) New Balance PURCHASES $3,314.33 $70.00 $0.00 $77.87 $3,462.20 ADVANCES 50.00 50.00 50.00 $0.00 $0.00 TOTAL $3,314.33 570.00 $0.00 $77.87 $3,462.20 Rate Summary ndard Purch $3,346.75 0.08011%(D) 29.240% 29.240% ch/Adv thru 03/03/2004 $5.02 0.08011%(D) 29.240% 29.240% NCES ndard Adv $0.00 0.08011%(D) 29.240% 29.240% Verification 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 unworn falsification to the authorities. Date: cju J?& - /? -?' Signature Daniel R Baker 5424180496030211 Lr) ?o -o ? ? n xr- a n ;{ u. SHERIFF'S RETURN - REGULAR CASE NO: 2005-03060 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS DANIEL R CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAKER DANIEL R the DEFENDANT at 1918:00 HOURS, on the 27th day of June 2005 at 1613 CHATHAM ROAD CAMP HILL, PA 17011 by handing to KAREN BAKER, WIFE 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 18.00 Service 10.36 Affidavit .00 Surcharge 10.00 .00 38.36 So Answers: R. Thomas Kline 06/28/2005 BURTON NETT' Sworn and Subscribed to before By: me this 3 day of A. D. Prothonotary CITIBANK SOUTH DAKOTA N.A. 70-1 East 60th Street N, Sioux Falls, SO 571 17 Plaintiff vs. DANIEL R BAKER 1613 Chatham Road Camp Hill PA 170116009 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3060 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: TOTAL $3,462.20 $.00 $3,462.20 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 20 1 (b)(1)(A) of the Servicemembers Civil Relief Act 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 AND DAMAGES ASSESSED AS ABOVE. NOTIC IVEN UNDE A.R.CIV.P. 236 Pro othonotary The law firm of Burton Neil & Associates is a debt collector. BURTON NEIL & ASSOCIATES, P.C. BY: a Button Neil, Esquire Attorney for Plaintiff I.D.#11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 C-5993 CITIBANK SOUTH DAKOTA N.A. Plaintiff VS. DANIEL R BAKER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3060 CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Daniel R Baker 1613 Chatham Road Camp Hill PA 170116009 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 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 800-990-910&' DATE OF NOTICE: July 19, 2005 BURTON NEIL & ASSOCIATES, P.C BY: .ter Burtoll'Nei , Esquire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 The firm of Burton Neil Bc Associates, P.C. is attempting to collect a debt. C-5993 ?????11???1811gItlIU?IYI,W?IIfIH 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. IN THE COURT OF COMMON PLEAS Plaintiff vs. DANIEL R BAKER CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3060 Defendant : CIVIL ACTION - LAW RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on P thonotary By: Deputy If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. ? ? =, ? _ _ _ ?: ? ? ?, ? fi ? ? - , ? ? c ?v ?`4,\ '1 Z° c7 0 vt G w Burton Neil & Associates, P.C. By Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. Plaintiff V. DANIEL R BAKER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3060 CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Burton Neil & By:. P.C. Burttlh- l4il, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-5993 r - C--.; C7 r-- rv ''--