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Home My WebLink About05-3160BURTON 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. LORISSA D DELANEY 100 Hemlock Court, Mechanicsburg PA 17055 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. os - 21i? b CIVIL ACTION - LAW COMPLAINT NOTICE l2 I 'U Lt (?[??yv ' 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-6235 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. OS -3l(op LORISSA D DELANEY 100 Hemlock Court, Mechanicsburg PA 17055-5853 Defendant : CIVIL ACTION - LAW Complaint C-Uc???1L-' "Z 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 Lorissa D Delaney, who resides at 100 Hemlock Court, Mechanicsburg, 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 5424180131774116 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 he 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 $7,296.34. Wherefore, plaintiff demands judgment against defendant for the sum of $7,296.34, and the costs of this action. BURTON NEI;? & ASSOCIATES, P.C. By: ....-4;Urton5eil, Esquir Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. O2/0T/O5 $7296.34 $9999.99 SITE:KC-CL TM:CO-5000 ACID:KC87150 aIfAY::?Bkfli .... ..?G1£i 05/26/05 20:10:17: :3!IIL}E:SSft'8>F?<;: Y%dk'iJrbT;T;::::;i CITI CARDS P.O. 80X 8108 LORISSA D DELANEY S HACKENSACK, NJ 100 HEMLOCK CT 07606-8108 MECHANICSBURG PA 17055-5853000 Citia Platinum Select Card Clue Amount Number 5424 1801 3177 4116 Customer 5ervice 1-800-950-5114 Total Credit Unt AvoiMble Credit Line Cash Advance Limit Available Cash Limit New Balance $5800 $0 $2500 $0 $7296.34 BOX 6500 statement) Amount Over Purch/Adv Minimum SIOUX FALLS, SO Closin Date Credit Line Post Dw n?Ynimum Due Amount Due 57117 O1/12/2?05 $1496.34 + $1092._17 1177.36 $7296.34 Standard Porch 1112 OVER CREDIT LIMIT FEE 35.00 62 0000 0000000000 1/12 PURCHASES'FINANCE CHARGE-PERIODIC RATE 12.20 84 0000 0000000000 Purch/Adv Thru 04/11/2003 1112 PURCHASES•FINANCE CHARGE-PERIODIC RATE 160.16 84 0000 0000000000 Metp is available! Please call the toll-free number shown above to learn about our special payment opptions. Call Monday - Friday, 7 am to 9 pm, or Saturda , 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Our records show home phone 717-691-8079 and business phone 717-795-1313. Please update coupon if incorrect. Previous (+) Purchases (-) aymen s +) New 'Account Summary Balance & Advances & Credits CHARGE Balance JRCHASES $7,088.98 $35.00 #000 . $172.36 $7,296.34 CES 0 10 00 72 4 1TAL $7,088.98 $35.0 00 . 5 $1 .36 $7,296.3 Davs This 61111no Period. 30 ate Summary Finance Charce Rate APR PERCENTAGE RATE. Purch $507.83 0.08011%(D) 29.240% 29.240% X4/11/2003 $6,664.11 0.08011%(D) 29.240% 29.240% Adv $0.00 0.08011%(D) 29.240% 29.240% ,j? EXHIBIT_ -- Verification I,- ?, Ll7lJ? t l 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: 6W Signature Lorissa D Delaney 5424180131774116 O G ? r7 c? - ui ll m r r W `? CITIBANK SOUTH DAKOTA N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff vs. LORISSA D DELANEY 100 Hemlock Court Mechanicsburg PA 17055-5853 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3160 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 $7,296.34 $.00 $7,296.34 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)(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 A ABOVE. NOTICE GIVEI1UNDE$$Q.I?IV.P. 236 Pro The law firm of Burton Neil & Associates is a debt collector. BURTON NEId& ASSOCIATES, P.C. BY: Burton Neil, Es ire Attorney for Plaintiff I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 C-6235 CITIBANK SOUTH DAKOTA N.A. Plaintiff vs. LORISSA D DELANEY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3160 CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Lorissa D Delaney 100 Hemlock Court Mechanicsburg PA 17055-5853 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 800-990-91•Q8 BURTON NEli & ASSOCIATES, P.C. DATE OF NOTICE: July 14, 2005 BY: Burton eel, Esquire 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 gg??pp?????{{ryry?? pp N ?p? ppy?p?p p??q?(? ry?t ?p C-6235 ?fllgg111gIflM?N?? ?II?AM?IIgIllilg???110@II?NIIIQIItlp?Ngt?Nll O ?l n 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 CUMBERLAND COUNTY, PENNSYLVANIA vs. LORISSA D DELANEY NO. 05-3160 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 Prothonotary 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. 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. LORISSA D DELANEY Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3160 : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Burton By: Associates, P.C. Neil, Esquire ;v for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-6235 C- '? "C1 co ?? ?l.. .. i S./ ? j #