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Home My WebLink About05-5129 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 CITlBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANN M BUKEVICZ 2203a Cedar Run Dr Ext Camp Hill PA 17011-7400 Defendant NO. 05" - Sf.J... 9 c/o, L T~ : 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. LA WYER 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-3157 C-3437 \\11\11\\1\ \\111111111111111111111111111 1111111111111111111 111111111111111111111111I1111111I1111111111111111111111111111111111111111111 . 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, PENNSYLVANIA NO. OS"" - ~J/~' ClL>~LlE'R-~ ANN M BUKEVICZ 2203a Cedar Run Dr Ext Camp Hill PA 17011-7400 Defendant : CIVIL ACTION - LA W 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 Ann M Bukevicz, who resides at 2203a Cedar Run Dr Ext, 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. Count I 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180477678863 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 $5,735.30. Wherefore, plaintiff demands judgment against defendant on Count I for the sum of $5,735.30, and the costs of this action. Count II 10. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180249866267 hereinafter referred to as the credit card account. 11. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 12. 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. 13. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit B statement without protest, dispute or objection. 14. Defendant in not protesting, disputing or objecting to the statements including the Exhibit B statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 14. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit B statement, is $6,230.09. Wherefore, plaintiff demands judgment against defendant on Count II for the sum of$6,230.09, and the costs of this action. ) BURT04EIL & SSOCIATES, P.C. /",Ji' ,tI' .,' By: l,.../~. Burton Neil, s Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. , 03/18/04 $5735.30 $9999.99 SITE:KC-CL .__.."h",,_,'__'_.h.h. ::::p.ii1Oj::::OOf::'9~fi:::::::: ..-..-.~.. ........ ....... ......................... ._.._.h...........h... ._....._.._..-.h.h... ~~~~~~~~~~MMf~~{ ~~~~~~~~(~~f~~~~!~{~~ CITI CARDS P.O. BOX 8117 S HACKENSACK, NJ 07606-8117 ANN M BUKEVICZ 2203A CEDAR RUN DR EXT CAMP HILL 17011-7458000 Citi~ Driver's Ed5le~ Platinum Select Card-Charter Rbts Account Number 5424 1804 7767 8863 Customer Service: 1-800-756-4000 BOX 6500 SIOUX FALLS. SD 57117 PA Total Credit LIne $8700 Statement! Closing Date 02/24/2004 Anllable Credit Line $0 Amount Over Credit Line $0.00 Cash Advance Limit $1500 Available Cash Limit $0 PurchjAdv Minimum Dult $126.04 Sa'" Datlt Post Date Reference Number Past OUlt $747.84 2/24 2/24 2/24 2/24 Activity Since Last Statement Standard Purch lATE FEE - JAN PAYMENT PAST DUE 66 0000 PURCHASES*FINANCE CHARGE*PERIOOIC RATE 84 0000 Standard Adv ADVANCES*FINANCE CHARGE*PERIOOIC RATE 84 0000 Purch/Adv Thru 01/25/1993 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. TM:CO-5000 02/09/05 ~... Cltl Hew Balance $5735.30 Minimum Amount Due $5735.30 Amount 35.00 0000000000 85.93 0000000000 25.16 0000000000 9.95 0000000000 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 01/25/1993 ADVANCES Standard Mv PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance r,419.64 $35.00 $0.00 $95.88 $4,550.52 1,159.62 $0.00 10.00 $25.16 11,184.78 5,579.26 $35.00 0.00 $121. 04 5,735.30 Balance Subject to Finance Charge PeriodiC Rate Days This Billing Period: 26 Nominal ANNUAL APR PERCENTAGE RATE $4,002.20 $463.50 $1.171. 70 27.990% 27.990% 27 .990% 27.990% 27.990% 27.990% 0.07668%(0) 0.07668%(0) 0.07668%(0) ACID:KCB7150 01:48:24: EI)),lJiLA ! , 03/10/04 $6230.09 $9999.99 f~~f&~~~i~~~~~~~~~ ~~I~~~~~~M~M~~~t: l~~ijji'f~@W.t~ SITE:KC-CL TM:CO-5000 02/09/05 CITI CARDS P.O. BOX 8111 S HACKENSACK, NJ 07606-8111 ANN M BUKEVICZ 2203A CEDAR RUN DR EXT CAMP HILL 17011-7458000 PA Citi~ Driver's Edge~ Platinum Select Card-Charter Rbts Account Nu mber To report billing enDrS, write 5424 1802 4986 6267 ::':h1'':=:;,~''::=:u PAYMENT MUST BE RECEIVED BY 1:00 PM LOCAL TIME ON 03/10/2004 ~ Y statement/Closing Date 02/16/2004 tor Customer Service, call or write 1-800-568-5000 BOX 6500 SIOUX FALLS. SO 57117 Total Credit Line $9600 Available Credit Line $0 Amount Over Credit Line $0.00 Cash Advance Limit $7000 New Balance $6230.09 A vailable Cash Limit $0 purch/ Adv MlnilOOm Due $150.47 Minimum Amount Due $6230.09 Amount Sale Date Post Date Reference Number Past Due $625.93 2/16 2/16 2/16 2/16 Activity Since Last Statement Standard Purch LATE fEE - JAN PAYMENT PAST DUE 66 0000 PURCHASES*fINANCE CHARGE*PERIODIC RATE 84 0000 Standard Adv AOVANCES*fINANCE CHARGE*PERIOOIC RATE 84 0000 Purch/Adv Thru 01/15/1993 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 35.00 0000000000 64.65 0000000000 40.56 0000000000 40.26 0000000000 ACID:KCB7150 01:48:18: Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 01/15/1993 ADVANCES Standard Adv When you pay your bill by check. you authorize us to electronlcally process your payment. If your check is processed electronically. your checking account may be debited on the same day we receive the check and it will not be returned with your checking account statement. If someone other than you or a bill paying service pays your bill, you must give a copy of this notice to them before the payment is sent to us. 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. PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance r.362.95 $35.00 r.OO $104.91 14,502.86 1,686.67 $0.00 0.00 $40.56 1,727.23 6,049.62 $35.00 0.00 $145.47 $6,230.09 Balance Subject to Finance Charge Periodic Rate Days This Billing Period: 31 Nominal ANNUAL APR PERCENTAGE RATE $2.719.84 $1,693.67 $1,706.21 27.990% 27 .990% 27 .990% 27.990% 27.990% 27.990% 0.07668%(0) 0.07668%(0) 0.07668%(0) ~;~A,b!L b L- j4~{ 1 Verification I, Courtney Gilbert 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 autho . ies. J elL \ 05 Signature Date: -r'1 ~ 1- (~ -- -l:::. ,- -l:: t b f:t ...(,Q.. Ul. Ul {ft D ~ D } I - o 't-~;: 1-) c.:':':' c::;.o c..tl en C~~ ~ cO ~~ 8 o -(} ~-;)'-l\ t'') C';) ~~ ...0 ---------- SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05129 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BUKEVICZ ANN M 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 BUKEVICZ ANN M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , BUKEVICZ ANN M 2203A CEDAR RUN DRIVE EXT CAMP HILL, PA 17011-7400 DEFENDANT RECENTLY HAD A STROKE AND IS CURRENTLY IN A HOSPITAL. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.40 5.00 10.00 .00 47.40 So answel;'S :,/-- ./ ,,'.7~/ / ,;~~~:" Sheriff of Cumberland County ..,~ BURTON NEIL 10/06/2005 Sworn and subscribed to before me this "" "" - ..( C day of (jJ~ dW~~ 1 . pr~onotar ,/. 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANN M BUKEVICZ 2203a Cedar Run Dr Ext Camp Hill PA 17011-7400 Defendant NO. 65 - S/~9 C-lu~L~&~ : 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 rr~UE COP"( FROM REcel'::::, ~..! T\"~\);~),~(mv ' i ~1fo;1 j~ntu ,~)/ fnr \'~tHl ,:~~~,~ t(~lf.) ~/~~,; .'A :;;:l~~t COH , !~t ,..,JH:'.ia, Pa, fill C-3157 C-3437 1111111111111111111111111111111111111111 111111111111111111111111111111111111111111111111111I11111111111I11111111111111I1111111I11111111 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. ANN M BUKEVICZ 2203a Cedar Run Dr Ext Camp Hill PA 17011-7400 Defendant : CIVIL 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 Ann M Bukevicz, who resides at 2203a Cedar Run Dr Ext, 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. Count I 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180477678863 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 plaintifffor 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 $5,735.30. Wherefore, plaintiff demands judgment against defendant on Count I for the sum of $5,735.30, and the costs of this action. Count II 10. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180249866267 hereinafter referred to as the credit card account. 11. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 12. 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. 13. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit B statement without protest, dispute or objection. 14. Defendant in not protesting, disputing or objecting to the statements including the Exhibit B statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 14. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit B statement, is $6,230.09, Wherefore, plaintiff demands judgment against defendant on Count II for the sum of $6,230.09, and the costs of this action. BURTO ElL & #~OCIATES, P.c. /0 I />/ By: ~UrtO~~:q:ire Attomey for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. THESGNI\I\llEABOVE CER1IAESlHATlIUSIS A lRUEANO CORH!:CT COI'Y Of THE ORIGINALFlLf INniS CAlISE. 03/18/04 $5735.30 $9999.99 5ITE:KC-CL __...nn................ :;::P.M:t:::OOE:::u:I.:~::::::: ......................... ....h....h....___....._ U~~~~!i~~@t~@~~ ~~~~~~m~~~~~~~~~@~~~~~ CITI CARD5 P.O. BOX 8117 5 HACKENSACK, NJ 07606 -8117 ANN M 8UKEVICZ 2203A CEDAR RUN DR EXT CAMP HILL 17011-7458000 Citi"' Driver's Ed5le"' Platinum Select Card-Charter Rbts Account Number 5424 1804 7767 8863 Customer Service: 1-800-756-4000 80X 6500 SIOUX FAllS, SO 57117 PA Total Credit Line $8700 Statementl Closlnq Date 02/24/2004 Available Credit Line $0 Cash Advance limit $1500 Available Cash Limit $0 Purch/Adv Minimum DlJlt $126.04 TM:CO-5000 02/09/05 _. eltl New 5illlance $5735.30 Minimum Amount Due $5735.30 Amc>unt Over Crl~dlt Line $0.00 Past Due $747. 84 Sale Date Post Date Relerence Number 2/24 2/24 2/24 2/24 Activity Since Last Statement Standard Purch lATE FEE - JAN PAYMENT PAST DUE 66 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Standard Adv ADVANCES'FINANCE CHARGE'PERIODIC RATE 84 0000 Purch/Adv Thru 01/25/1993 PURCHASES'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. Amount 35.00 0000000000 85.93 0000000000 25.16 0000000000 9.95 0000000000 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 01/25/1993 ADVANCES Standard Adv PrevIous Balance 14.419.64 1,159.62 5,579.26 (+) Purchases & Advances $35.00 $0.00 $35.00 (+) FINANCE CHARGE $95.88 $25.16 $121.04 (=) New Balance $4,550.52 $1.184.78 $5,735.30 Ba lance Subject to Finance Charge Periodic Rate Davs ThIs BillIng PerIod: 28 Nominal APR ANNUAL PERCENTAGE RATE 27.990% 27 . 990% 27.990% (-) Payments & Credits $0.00 $0.00 $0.00 $4,002.20 $463.S0 $1,171. 70 0.07668%(0) 0.07668%(0) 0.07668%(0) 27. 990% 27 . 990% 27.990% ACID:KCB7150 01:48:24: Elh 10 d.. A 03/10/04 $6230.09 $9999.99 SITE:KC-CL TM:CO'5000 02/09/05 ........n....."_......._ u.n.._n.............. ....................... ~~~~~~~;~~~~~~~;~;;~~; ;;~~~~;~~~~~~;~;~ ~;~;~~~~~~;~;~~@~~;;; ANN M BUKEVICZ 2203A CEDAR RUN DR EXT CAMP HILL 17011-745BOOO CITI CARDS P.O. BOX B111 S HACKENSACK, NJ 07606-B111 PA Citi~ Driver's Edge~ Platinum Select Card-Charter Rbts Account Number To report billinq errws, ",lte 5424 1802 4986 6267 ::h1s=:~~~nq.....r PAYMENT MUST BE RECEIVED BY 1:00 PM LOCAL TIME ON 03/10/2004 pi" y gilts For Customer ServIce, call or write 1-800-568-5000 BOX 6500 SIOUX FALLS. SO 57117 Statemerlt/ClosingDate 02/16/2004 Total Credit Line $9600 Available Credit Llrle $0 AmourltOver CredltLlne $0.00 Cash Advance Limit $7000 Available Cash limit $0 Purch/Adv MInimum Due $150.47 Past Due $625.93 Sale Date Post Dale Reference Number Activity Since Last Statement Standard Purch LATE FEE - JAN PAYMENT PAST DUE 66 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Standard Adv ADVANCES'FINANCE CHARGE'PERIODIC RATE 84 0000 Purch/Ado Thru 01/15/1993 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 2/16 2/16 2/16 2/16 When you pay your bill by check, you authorize us to electronlcally process your payment. If your check is processed electronically, your checking account may be debited on the same day we receive the check and it will not be returned with your checking account statement. If someone other than you or a bill paying service pays your bill. you must give a copy of this notice to them before the payment is sent to us. 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. New Balance $6230.09 Mlnimum Amount Due $6230.09 A.mou nt 35.00 0000000000 64.65 0000000000 40.56 0000000000 40.26 0000000000 Account Summary PURCHASES ADVANCES TOTAL PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance 14,362.95 $35.00 iO'OO $104.91 14,502.86 1,686.67 $0.00 0.00 $40.56 1,727.23 6,049.62 $35.00 0.00 $145.47 $6,230.09 Rate Summary Balance Subject to Finance Charge Periodic Rate Days ThIs BIlling PerIod: 31 Nominal ANNUAL APR PERCENTAGE RATE PURCHASES Standard Purch Purch/Adv thru 01/15/1993 ADVANCES Standard Adv $2,719.84 $1,693.67 $1.706.21 0.07668%(0) 0.07668%(0) 0.07668%(0) 27 . 990% 27.990% 27.990% 27 .990% 27 . 990% 27.990% ACID:KCB7150 01:48:18: 6',/)1/17It.. b Verification L- '3<--t~( I, Courtney Gilbert 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 autho . ies. oJ i&iJ Date: gjL\CU Signature ", ,It/ifg,t OV' rP:; SOul II :f: d c. ,,~, ;, ',,' ,; ~,~ . _:..J, ....~. ._.1 ',;;.d.:'; " ,~ '00 ~- !~-= J U U d2J ~ If1R1 . 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 N, Sioux Falls SD 57117 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS, : NO, 05-5129 civil ANN M BUKEVICZ 2203 Cedar Run Drive Ext Apt A, Camp Hill P A J 70 11 Defendant : CIVIL ACTION - LA W Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. ) BURTON NEIL & ASS9CIATES, P,C. II "v/ BY: Burton Nei , Esquire Attorney 1) r Plaintiff The Jaw firm of Burton Neil & Associates is a debt collector. C-3157 \ 111111\ \\1 \\11111111\ \\1111111111111111 111111111111111111111111111111I11111111111111I11111111111111111111111111111I111111111111111111111111111111111111111 2_~; 0 <,;:;::1 -n 0'" --------- -'1 pI. C'] , _..J (2 o - , 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 CmBANK (SOUTH DAKOTA) NA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS, : NO, 05-5129 civil ANN M BUKEVICZ Defendant : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice, \ BY: Ie D Weinstein, Esquire ttorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-3157 1\1111111111111I11111111111111\111111111 11111111111111111111111111111111111111I1111111111111111111111111111111111111111111111111111111111111111 111111 1111111I11111111 -.,"" () -;-'"1 ...., -'C ;'jl r~i c;;; c,J .) C,j SHERIFF'S RETURN - REGULAR CASE NO: 2005-05129 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BUKEVICZ ANN M ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BUKEVICZ ANN M the DEFENDANT , at 1456:00 HOURS, on the 1st day of March , 2006 at 920 S HUMER STREET ENOLA, PA 17025-7400 by handing to NANCY HERTZLER, DAUGHTER 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 26.40 .39 10.00 .00 54.79 1'~~"'~~ R. Thomas Kline 03/02/2006 BURTON NEIL Sworn and Subscribed to Ie> me this ~D ~ day of before BY~~J eputy erif1 ~ M~~ }? . pro'o~tar "