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Home My WebLink About05-6115BURTON 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. RUSSEL RINEER 104 South 17th Street Camp Hill PA 17011-5531 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 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-5572 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. RUSSEL RINEER 104 South 17th Street Camp Hill PA 17011-5531 Defendant NO. 0S - L //sue 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 Russel Rineer, who resides at 104 South 17th Street, 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 5410654785382513 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 $10,492.83. Wherefore, plaintiff demands judgment against defendant for the sum of $10,492.83, and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire v., Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 0 10/11/04 $11292.83 $1618.20 SITE:KC-CL TM:CO-5000 ACID:KCB7150 i -- ----?€:;rs-r4<_:;:: 10/21/05 19:12:39: ms:iiE 5000W goo~ CITI CARDS P.O. BOX 8110 RUSSEL RINEER 5 HACKENSACK, NJ 104 S 17TH ST 07606-8110 CAMP HILL PA 17011-5531000 i Cities Platinum Select Card Account NumW 5410 6547 8538 2513 Customer Service: 1-000-950-5114 Total credit Line AvalMbie Credit Line $10600 $0 BOX 6062 Statement/ Amount Over SIOUX FALLS, SO Cloeln Data Credit Line s-nr7 09/15/204 $692.83 + Cash Advance Limit Available Cash Limit New Balance $1500 $0 $11292.83 Purch/Adv Minimum Past Due Minimum Do* Amount Due 1659.93 + $265.44 = $1618.20 Standard Purch 9/15 LATE FEE - AUG PAYMENT PAST DUE 66 0000 9/15 PURCHASES-FINANCE CHARGE•PERIODIC RATE 84 0000 IMPORTANT INFORMATION ABOUT CREDIT REPORTING: WE MAY REPORT INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS MISSED PAYMENTS, OR OTHER DEFAULTS ON YOUR ACCOUNT MAY BE REFLECTED IN YOUR CREDIT REPORT. 35.00 0000000000 260.44 0000000000 EXHIBIT, Previous (+) Purchases (-) Payments (+) FINANCE (_) ew Account Summary Balance &Advances &Credits CHARGE Balance PURCHASES $10,997.39 $35.00 0.00 $260.44 $11,292.83 ADVANCES $0.00 $0.00 0.00 $0.00 $0.00 TOTAL $10,997.39 $35.00 0.00 $260.44 $11,292.83 Davs This Billina Period: 30 Rate Summary Finance [Marne Rate APR PFRCENTAGE RATE Purch $11,122.76 0.07805%(D) 28.490% 28.490% Adv $0.00 0.07805%(D) 26.490% 28.490% Verification 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 falsific; Date: ?? G G Sig n moo. ?' ? ?- ? ? C `? ^p `? ? c --,? SHERIFF'S RETURN - REGULAR CASE NO: 2005-06115 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS RINEER RUSSEL 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 RINEER RUSSEL the DEFENDANT at 1954:00 HOURS, on the 21st day of December-, 2005 at 104 SOUTH 17H STREET CAMP HILL, PA 17011-5531 RUSSEL RINSER by handing to 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 18.00 Service 28.80 Affidavit .00 Surcharge 10.00 1? Sworn and Subscribed to before me this j day of „2o A.D. U Prod ota IF So Answers: R. Thomas Kline 12/27/2005 BURTON NEIL By: eputy She ff CITIBANK SOUTH DAKOTA N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff VS. RUSSEL RINSER 104 South 17th Street Camp Hill PA 17011-5531 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6115 civil 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 $10,492.83 $.00 $10,492.83 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 thejudgment 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 AS ABOVE. NOTICE GIVEN UNDER PA.R.C .236 ro rothonotary The law firm of Burton Neil & Associates is a debt collector. BURTON 'AIL & ASSOCIATES, P.C Burton Ne , Esquire Attorney or Plaintiff I.D. #11348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 C-5572 C-5572 CIT113ANK SOUTH DAKOTA N.A. : IN THE COURT OF COMMON PLEAS Plaintiff VS. RUSSEL RINEER Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6115 civil CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Russel Rineer 104 South 17th Street Camp Hill PA 17011-5531 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 800-990-9108 DATE OF NOTICE: January 12, 2006 In making this communication, we advise our off-ice is a debt collector. BURTON II & ASSOCIATES, P.C. By Burton Neil, Esquire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 I(Ilnll!lI?Illullllllllll(IIIIIIII 110111111111?II1?N(ilfif II(lliilli?il(1lullnllllll!(Illlllllllllll(I ? * CST fi °Q W r> "1111', m r .: 41- tD S t? w N 4.7 CA 77G _ti 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. RUSSEL RINEER NO. 05-6115 civil Defendant : CIVIL ACTION - LAW RULE OF CIVII, PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary J By: 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. RUSSEL RINEER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-6115 civil : CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Burton Neil-&-j ssociates, P.C. B Burton N 1, Esquire Attorney r Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-5572 m tea ?`? co