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Home My WebLink About05-5176 , . 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 IN THE COURT OF COMMON PLEAS CITIBANK (SOUTH DAKOTA) N .A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA NO.6!; - S/11o C'-v; L 't-Efl-.~ EDWARD KRONSBEIN 88R Autumn Lane, Enola PA 17025-2105 Defendant : CIVIL ACTION - LA W 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 MAYBE 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- 7710 \ 111\11\ III 111111111\\ \11I\ 111\\ 11\\ 111\ \ \11\11\ mil 111111 1111 11111 11111 11111111111 II 11111111 1111111 1111111 111111 111111111111111 II 1111 -~ 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 - 5/1{, C;uJ.. 'iEfl-\ EDWARD KRONSBEIN 88R Autumn Lane, Enola PA 17025-2105 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 Edward Kronsbein, who resides at 88R Autumn Lane, Enola, 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 4621201165928693 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 $1,321.84. Wherefore, plaintiff demands judgment against defendant for the sum of$1,321.84, and the costs of this action. BURTON NE~Y& ASSOCIATES, P.C. By: The law firm of Burton Neil & Associates, P.C. is a debt collector. .- . .' ~ 08/08/05 $1321.84 $1321.84 SITE:KC-CL TM:CO-5000 ACID:KCB7150 08/25/05 19:24:19: .............__...-...... ...._-.-..........._-... ..--.--.......---.----- ~~~~~~~~~@~~~~~~~~~~~~~ ~~~~~f~~~~~~~~: ~~J~~~~~~~W~~~~f~~ EDWARD KRONSBEIN 88R AUTUMN LN ENOLA 17025-2105000 CITI CARDS PO BOX 183059 COLUMBUS, OH 43218-3059 PA Citr Card cffr Account Number 4621 2011 6592 8693 Customer Service: 1-800-950-5114 PO BOX 142319 IRVING, TX 75014-2319 Total Credit Line $1050 Statementl Closlnq Date 07/14/2005 Available Credit Line $0 Amount Over Credit Line $271.84 + Cash Advance limit $740 Past Due $320.55 Available Cash limit $0 Pu rc h/Adv Minimum DUll $81. 62 New Balance $1321.84 Minimum Amount DUll $1321.84 Sale Date Post Date RlIfllrllnce Number 7/14 7/14 7/14 Activity Slncll Last Statllmllnt Standard Purch LATE FEE - JUN PAYMENT PAST DUE 66 0000 0 OVER CREDIT LIMIT FEE 62 0000 0 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 0 Amount 39.00 70000000000 35.00 70000000000 30.62 70000000000 Your late fee was based on your account balance as of the payment due date (07/08/05), which was $1,217.22. 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. EXHIBIT A PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance $1,217 .22 $74.00 r.OO $30.62 $1,321. 84 $0.00 $0.00 0.00 $0.00 $0.00 $1,217.22 $74.00 0.00 $30.62 $1,321.84 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Balance Subject to Finance Charge PeriodiC Rate Days This BfIIlng Period: 30 Nominal ANNUAL APR PERCENTAGE RATE $1,231.96 $0.00 0.08285%(0) 0.08285%(0) 30.240% 30.240% 30.240% 30.240% Verification c - 77/0 iJ ~ '1~ /\ l A/-t {) C t', .. ) I, Crystal Britt 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. Section 4904, relating to unsworn falsification to e authoriti Date: B !?!iILD rt' '\8 \61Z'\"'~ () -<q. ~ -p -r:::- U1 t \:\- lf1 Vt c'> .-' 0 - (...~ ..t: Dr ~:~; ,::;:::;::? -n - ;;:J"1 \T""- o :.? v ~ c-) --C" --n ~ ~ I'lli'''''' t>.J ~ I ::~;18 V( c.....> ":!::~ .....! [..~'C) ___..J ~::r, ~ "D -n ~.~~~ t.~ -:'-1,,: -(- <:? 6rn .--\ --I 'CC,. :;:-- :'D c..r. .< .----------- ------- ....----- SHERIFF'S RETURN - REGULAR CASE NO: 2005-05176 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS KRONSBEIN EDWARD CPL TREVOR KENT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KRONSBEIN EDWARD the DEFENDANT , at 1949:00 HOURS, on the 4th day of October ,2005 at 88R AUTUMN LANE ENOLA, PA 17025 by handing to EDWARD KRONSBEIN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 14.40 .37 10.00 .00 42.77 yr ~ ~.~),.('" . ':.,~<~::...-ry~','r::r.f::. __~ .~~~_.. ~. ." R. Thomas Kline 10/05/2005 BURTON NEIL me this Jo ""'- day of BY:~~ i:J ( Deputy Sheriff Sworn and Subscribed to before (fJr.I:"-L d.1J1)~' A.D. 1~~ ' ~ I CITlBANK SOUTH DAKOTA N.A. 701 East 60th StreetN, Sioux Falls, SD 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5176 Civil EDWARD KRONSBEIN 88R Autumn Lane Enola P A 17025-2105 Defendant : 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: $1,321.84 TOTAL $1,321.84 Understanding that false statements herein made are subject to penalty under 18 Pa. e.S. S 4904 relating to unsworn falsification to authorities, I verify that: I. 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 of2003 (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 BURTON.. iIL & ASS..O.. CIATES, P.C. AND DAMAGES ASSESSED AS ABOVE. !Jl-J _-. NOTICEG VENUNDERP .R.CIV.P.236 B~ -JL~/ Burton ~Esquire Attorney for Plaintiff !.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-7710 111111111111111111111111111111111111111I IIIIIIIIIIIIIIIIIIIIIIIIIIII~IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII111111111111111I1111111111111 , C-7710 elTlBANK SOUTH DAKOTA N.A. IN THE COURT OF COMMON PLEAS Plaintiff vs. CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5176 Civil EDWARD KRONSBEIN Defendant : CIVIL ACTION - LAW Notice of Intenuon to File Praecipe for Default Judgment TO: Edward Kronsbein 88R Autumn Lane Enola PA 17025-2105 IMPORTANT NOTICE You are in defaultbecause 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. LA WYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 .'- DATE OF NOTICE: November 7, 2005 BURTON ~.~ ASSOCIATES, P.C. /' I L In making this communication, we advise our office is a debt collector. ~: Burton Neil, s ui Attorney for Plain ff Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester,PA 19380 (610) 696-2120 cc: James Gallagher, Esquire 1010 Franklin Avenue, Ste 400 Garden City, NY 11530 IlmUI~lllllUlnlllll~lm IftllllllmlmMm~~llIlllllmIl1lIIHlIII~DI~I"11 C 70 0 .{,q 7' --0 () \t tt \) () ,-" t- C> t:;:.) ,. ('-~",-, ... c.r\ F ---- -- ~ ~ 0- "'0 r',..., ~ ---- '-'" -J:: C> IlJ , W n ff -l- (,) (:1 0 r --------- , 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. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-5176 Civil EDWARD KRONSBEIN 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 /1')('\0 - ;) 9 ;:) ()(')$ I ::ili?:~ If you have any questions concerning the above, please contact: ~ Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, P A 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.