The URL can be used to link to this page

Home My WebLink About05-3149 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 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ot;; - 3/49 Cio,L~~ BARBARA D PROCTOR 19a W Glenwood Drive, Camp Hill P A 170 II 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-6115 . 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 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. BARBARA D PROCTOR 19a W Glenwood Drive, Camp Hill P A 170 II Defendant NO. OS- - J Nf{ Cicil ~~ : CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank South Dakota N.A., with place of business located at 70 I East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Barbara D Proctor, who resides at 19a W GJenwood Drive, 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 5424180421880565 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 $11,475.75. Wherefore, plaintiff demands judgment against defendant for the sum of$ll ,475.75, and the costs of this action. BURIeJ1fNElL &,ASSOCIATES, P.C. By: ,_. Burton Neil, Esquir Attorney for Plainti The law firm of Burton Neil & Associates, P.C, is a debt collector. 01/31/05 $11475.75 $9999.99 ~~I~@I~~W~~lliffi~I~~~ ~~~i~~I~mJMii~~I~I~ ~l~~~ijji~~l@~~i@l~ SITE:KC-CL TM:CO-5000 05/13/05 ACID:KCB7150 20:25:16: BARBARA D PROCTOR 19A W GLENWOOD DR CAMP HILL 17011-1139000 CITI CARDS P.O. BOX 8102 S HACKENSACK. NJ 07606-8102 PA Citl~ Platinum Select~ Card cffr Account Number 5424 1804 2188 0565 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FAllS. SO 57117 Total Credit LIne $10850 statem.ntl Clo'ln9 Date 01/04/2005 AvaJJabJe Credit Line $0 Amount O..,.r Credit L1n. $625.75 . Cuh Advance limIt $2900 Past Du. $791. 26 . A",.lIable C.lI5h Limit $0 PlIrch/Adv Minimum DIJe $293.45 = Hew Balance $11475.75 Minimum Amount Du. $1710.46 Sa. Oat. P<1$t Dat. R.'e,tnce Number 1/04 AdM!, Since Last Statement Standard Purch LATE FEE - DEC PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Standard Adv ADVANCES'FINANCE CHARGE'PERIODIC RATE 84 0000 Balance Transfer. CharQed To Offer 5 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Amount 1/04 1/04 1/04 39.00 0000000000 35.00 0000000000 171.59 0000000000 2.68 0000000000 1/04 114.18 0000000000 Your late fee was based on your account balance as of the payment due date (12/29/04), which was $11.113.30. Your account is past due and your balance is over the credit line. To ensure you continue to receive the many benefits of your cardmembership, please send the Minimum Amount Due shown. If you have already sent us this payment. thank you. Account Summary PrevIous (t) Purchases (-) Payments (of) FINANCE (=) New Balance &. Advances & Credits CHARGE Bali!lnce PURCHASES $11~010.03 $74.00 (O.OO $285.77 $11~369.80 ADVANCES 103.27 $0.00 0.00 $2.68 105.95 TOTAL $11.113.30 $74.00 0.00 $288.45 $11.475.75 Balance Subject to PeriodIC Days This Billing PerlQd: 32 Rate Summary Nominal ANNUAL Finance Charge Rate APR PERCENTAGE RATE k PURCHASES 29.240%EXH J BJ~.240% Standard Purch 16.693.62 0.08011 %(0) Offer 5 4.454.22 0.08011%(0) 29.240% 9.e19U ADVANCES Standard Adv $104.56 0.08011%(0) 29.240% 29.240% Verification I, Avu f'- ')(1 o~ am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiffCITIBANK 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 offact 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:~ , QltfJi{fJ(jtidc , , SIgnature Barbara D Proctor 5424180421880565 1 - 6'- ~ ~ ~ -GQ. o lit \- ~ V< -- 0 ~~ ~~ '----'-- o (:;; j~-~ .-> 0 8 c:;:, .on = <.J1 ~'1'] <-: fn F:: c,. '-;j ;;;::: ::2'0 if) .-' -I - C~(J --1 ::;:... ":;,1. -;:) ;~~, -;'f\ -:1:: "') ',~4. W .- ~~ N v:> SHERIFF'S RETURN - REGULAR CASE NO: 2005-03149 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PROCTOR BARBARA D KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PROCTOR BARBARA D the DEFENDANT , at 2005:00 HOURS, on the 29th day of June 2005 at 19A W GLENWOOD DRIVE CAMP HILL, PA 17011 by handing to BARBARA PROCTOR 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 Postage Surcharge So Answers: 18.00 11.10 .37 10.00 .00 39.47 ?'-}:f~#:.,r ~ '.'f~~ R. Thomas Kline 06/30/2005 BURTON NEIL Sworn and Subscribed to before By: me this /;)!!o- day of ().;7 <:2;.05 A.D. ~<.<..- Q Y/";PO,, , A{J.G: P othonotary '11' -, 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 C1TlBANK SOUTH DAKOTA N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO, 05-3149 BARBARA D PROCTOR Defendant : CIVIL ACTION - LAW PRAECIPE TO SETTLE, END & DISCONTINUE TO THE PROTHONOTARY: Mark the above matter Settled, Ended and Discontinued. ~'SSOCIA~ES, P.C. ---- ' ~,--- ::::.. --,,- Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-6115 11I1I11I~I~nlllllllllllllllllllllllll 111111111111111111111111111111111111111111111I11111I111111111111111111111111I11111111 ,,;:.i:' i.11 t~ ~.( (/.1- C1 S; ~ $ ~ G> - U) -<J -",c' "'" Q. :1.." rn~ pC? ',";,0 ~:.~3J ".7~ C'21" -;."- ~ ~ c.J1 &' -