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Home My WebLink About06-1383 , 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 NO. Ols:,- /2/3 eU'LL /SLhj JESSIE M BANGER 101 North Prince Street, Shippensburg P A 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 ALA WYER 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-1842 1111111111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, J.D. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) NA 70 I East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. JESSIE M BANGER 101 North Prince Street, Shippensburg PA 17257 Defendant : CIVIL ACTION - LAW Complaint 1. Plaintiff is Citibank (South Dakota) NA, with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Jessie M Banger, who resides at 101 North Prince Street, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged 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 5424180470681831 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $2,490.84 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $2,490.84, and the costs ofthis action. BURTON NtIL & ASSOCIATES, P.C. The law firm of Burton Neil & Associates, P.c. /~ By:_!.....' Burton eil, Esquire is a debt collector. ! 1 12/22/03 $517.66 f~~l~t ~~~~;:r:::~::~:~::~;g~ $2490.84 ~::~:;;~:;::::~::;.mL - SITE:KC-CL TM:CO-5000 02/22/05 ACID:KCB71S0 21:48:25: JESSIE M SANGER PO BOX 133 SHIPPENSBURG 17257-0133000 CITI CARDS P.O. BOX B119 S HACKENSACK, NJ 07606-8119 PA Citi" Driver's Edge" Card Options Rebates Account Numb.r S424 IB04 706B 1831 PAYWENT MUST IE RECEIVED IV 1:00 PM LOCAL TIME ON 12/22/2003 rDr~ortlll-...a"'DI'lI._1ttI t.thl.~ClillnlI"l !'IlJtpl"__,_r~ Statemlnt/CIC511l90~te 11/27/2003 AVi!lllMllecredltUne $0 AmountOfllr Cr~tLIM $290.84 .. Cil.5nAdtta~Ufl'llt $300 iQtll1 Credit LlrJoi' $2200 PastDua $168.60 .. Ss. Date Post Data Rer.,..n~ Number Ac:tlvtty Sine. last statem.n~ Standard Purch LATE FEE - OCT PAYMENT PAST OUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHASES'fINANCE CHARGE"PERI00IC RATE 84 0000 Standard AdY ADVANCES"fINANCE CHARGE"PERIODIC RATE B4 0000 11/27 11/27 11/21 11/21 , CIT! DRIVER'S EOGE CARD OPTIONS REBATES' Last Month's Balance Earned this Month Redeemed/Expired Current Balance For ClJstomer Servk::lI, ClllorwrU. I-BOO'961-B500 BOX 6500 SIOUX fALLS, SD 51111 "Vil!.\l~h(IICashLim\t $0 Purch/Adv M\nilT'AlmO~ $58.22 = twweZlllU\c. $2490.84 Minimum ....m<runt DU4 $517.66 Amount 35.00 ODDOOOOOOO 35.00 0000000000 4B.69 0000000000 4.53 0000000000 TOTAL 24.71 0.00 0.00 24.71 Your account is past due and your ba1ance is over the credit line. To ensure you continue to receive the many benefits of your cardmembersnip, please send the >>inimum Amount Due shown. If you have al ready sent us thi s payment, thank you. Account Summary puRCHASES ADVANCES TOTAL PrtNIOUs Balance $2.'66.13 .201. 49 $2,367.62 (-) Payments & Creodits jO.oo 0.00 0.00 (-t) purchaus & Advanc~s $70.00 $0.00 $10. DO Rate Summilry PURCHASES Standard purcn ADVANCES Standard Adv BaJanc@ Subject to Financ@ Charge PeriodiC Rate $2.189_55 $203.61 0.0166B,.(0) 0.01668%(D) EXHIBIT.-A- (+) F1NANC[ CHARGE $48.69 $4.53 $53.21 (=) New Balanc!' $2.284.82 .206.02 $2,490.84 Days ThIs Billing Pvrlod: 29 Nomrnal ANNUAL APR ~ERCENTAGE RATE 27. 990% 21.990% 27 ,990% 21.990% ,. 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 authorities. Date: (Q l ~ \ 05 Signature: fuMJ ci 0 ~ -(.C} I) tf\ rG. 1- ~ tn V( ,:~ ~ ..l ~ ~ ~ () ?- VJ t<' W \) t3 \) ~ .t SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-01383 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BANGER JESSIE 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 BANGER JESSIE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , BANGER JESSIE M 101 NORTH PRINCE STREET SHIPPENSBURG, PA 17257 PER OFFICE, DEFENDANT MOVED OUT YEARS AGO. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 18.48 5.00 10.00 .00 51. 48 ? so~ Sheriff of Cumberland County BURTON NEIL 03/15/2006 Sworn and subscribed to before me this rltAJ- day of ~ """ AD ~ protQ~:ff9 Burton Neil & Associates, p.e. By: Burton Nei , Esquire ill. NO. 11348 1060 Andrew D . ve, Suite 170 West Chester, P 19380 610-696-2120 Attorney for Pia ntiff CITIBANK (SO TH DAKOTA) N.A. 701 East 60th S eet N, Sioux Falls, SD 57117 Plaintiff v. I I I JESSIE M BAN~ER 121 Walnut Bott~m Road, Shippensburg PA 17257 I Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1383 Civil : CNIL ACTION - LAW Praecipe to Reinstate Please reinstate the Complaint. By: The law firm of Burton Neil & Associates is a debt collector. C-1842 11111111111110111111111111111111111111 1 1111111111111 1111 11111 11111 11111 1111111111 IIIIIMIIII III 11111111111111111111111111111111111111111111111111111I1111 ....... ", ,...", f";:~ C::::::'J f".::7'\. (~ ."1 :--~ c' :.::1 -",~- 1'0 r--.) a SHERIFF'S RETURN - NOT FOUND <II CASE NO: 2006-01383 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BANGER JESSIE 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 BANGER JESSIE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , BANGER JESSIE M 121 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 DEFENDANT IS BELIEVED TO BE LIVING IN CHAMBERSBURG. Sheriff's Costs: Docketing Service Not Found Surcharge Postage So answer . 18.00 17.60 5.00 10.00 .39 50.99 County BURTON NEIL /" ~ I~ /lq lo~ 12/12/2006 Sworn and Subscribed to before me this day of A.D. Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ill. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 06-1383 Civil JESSIE M BANGER Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: /;~~--- ~t J. SUllell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-1842 UlllIIl ~lllllllllllllmllllllllllllll 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111\11111111111\11111111 I....:l = = --J (... '2:: 4l:'-' o -n --I :1; '""lJ n,j"- -aGl .::~~~~ dt~~ '"\--.. N \.D -0 ~';'" - .. :r:- N :J~ ""'"'