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Home My WebLink About06-3107e 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 RANDY M RICKERT CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. 410 N Walnut Street Reaz, Mount Holly Springs PA 17065-1504 Defendant IN THE COURT CUMBERLAND NO. 17~-3la7 CIVIL ACTION - COMMON PLEAS ,PENNSYLVANIA / a.~--. COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set you must take action within (20) days after this complaint and notice aze appearance personally or by attorney and filing in writing with the court the claim set forth against you. You aze warned that if you fail to do so, f you and a judgment may be entered against you by the court without furti claimed in the complaint or for any other claim or relief requested by the or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ON A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHO FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFI< PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TE SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Baz Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-440-41 C-9489 rth in the following pages, ved, by entering a written u defenses or objections to case may proceed without notice for any money untiff. You may lose money IF YOU DO NOT HAVE THE OFFICE SET ELP. THIS OFFICE WYER. MAY BE ABLE TO C MAY OFFER LEGAL )FEE. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, I.D. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITffiANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND C UNTY, PENNSYLVANIA v. ~ ~ " No. 0~• 3 ~ b ~.,~:t.Q 1 ~,.~ RANDY M RICKERT 410 N Walnut Street Rear Mount Holly Springs PA 17065-1504 Defendant CNIL ACTION - L W Complaint 1. Plaintiff is Citibank (South Dakota) N.A., with place of busin ss located at 701 East 60th Street North, Sioux Fa11s, South Dakota. 2, Defendant is Randy M Rickert, who resides at 410 N Walnut treet Reaz, Mount Holly Spr, Cumberland County, Pennsylvania. 3, Plaintiff is a national banking association, engaged in various es of banking business including consumer lending through the issuance of credit cazds. 4. Plaintiff furnished consumer credit to the defendant by means f a credit card with account number 5424180107277318 hereinafter referred to as the credit card acco t. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the acco t including the billing statement attached hereto as Exhibit A. The monthly statements accuratel 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 mon s 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 s ted between parties for the sum of $8,836.04 which sum reflects the Exhibit A statement balance less if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for th~ sum of $8,836.04, and the costs of this action. BURTON NF,kL & (ASSOCIATES, P.C. Burton The law firm of Burton Neil & Associates, P.C. is a debt collector. a t 03/20/06 58636.04 58836.04 SITE:KC- CITI CARDS PO BOX 183067 RANDY M RICKERT COLUMBUS, OM 410 N WALNUT ST REAR 43218-3067 MOUNT HOLLY SPR PA 17065-1504000 TM:CO-5000 ACID:KCB3104 04/24/06 16:26:56: ® ~ t~~ Citi Card Aaoum Nuntaer 5424 1801 0727 7318 Customer Sarvke: 1-800-866-9900 Total Crealt Llne AraiNble Cretlk Line Cash Advance Ll mit Aralla ble Cash Llmi New aalance 59750 50 5200 S 36836.04 BOX 6500 SIOUX FALLS, SD statement) Closing Data 2/23/2 06 Amount Ovar 4malt Llne 0 00 Past Dua 5777 75 Purch/Ad l~Inimum Du 2 Mlnlmum Amount Dua 8 57117 0 0 5 . . 5 22.3 36.04 58 Standard Purch 2/23 LATE FEE - JAN PAYMENT PAST DUE 35.00 66 0000 0000000000 2/23 PURCHASES•FINANCE CHARGE*PERIODIC RATE 217.36 84 0000 0000000000 Help is available! Please calf the toll-free number shown above to 1~ our special payment options. Call Monday - Friday, 7 am to 9 pm, or 8 am to 5 pm, Central Time. Please give us the opportunity to assist BIT 1~ Account Summary Balance & Advances firCredit afCNARGE ~ Balance PURCHASES 58,583.68 535.00 ¢0.00 5217.36 58,835.04 ADVANCES 50.00 50.00 0.00 50.00 50.00 TOTAL 58,583.58 535.00 0.00 5217.36 58,836.04 Da s hls Blllln Period: 29 Rate Summary a once u iec o en m omma ANNUAL Finance Char a Rate APR p RC NTA R TE PURCHASES Standard Purch 58,688.16 0.08627%(D) 31.490% 31.490% ADVANCES Standard Adv 50.00 0.08527%(D) 31.490% 31.490% Verification Shauna Houghton 1, am an employee Services, Inc., (USA) which is by contract the service I Citibank (South Dakota) N.A. retained to perform servi primarily limited to collecting delinquent debt. 1 am au verification as attorney-in-fact for plaintiff under powe plaintiff to Citicorp Credit Services, Inc. (USA) and to r averments of fact in the within pleading are true and c my knowledge, information and belief. I understand th made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the a~ Date: ~ ~ Signatuq of Citicorp Credit rovider for plaintiff :es including but not horized to make this s of attorney from ie. The foregoing ~rrect to the best of it the statements UZtp~yU~J~ ~fe~tfif{iG N c"a ~' - V ~ -n r ~ m I ~ n~ r ~ ~:~~ 7 W ~~ ~ ~~:~ A, ST' ~C7 is ' J .a •• I : :-a b ~ R ri ~. w .~ CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff VS. RANDY M RICKERT 410 North Walnut Street Rear Mount Holly Springs PA 17065-1504 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 063107 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 $8,836.04 $8,836.04 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) ofthe 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 P~IR.CIV.P. 236 & ASSOCIATES, P.C. Eil, Esquire for Plaintiff Pro The law firm of Burton Neil & Associates is a debt collector. LD.#1);348 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 C-9489 Illinl II I IIIIN IIIII hin IIIII Iill it ll I I I IIII I II III IIIII NIII II 111111111 I II II II 1111111 II I II IIIII NNI null IIII 111111 IIIII II IIN f CITIBANK (SOUTH DAKOTA) N.A. Plaintiff vs. RANDY M RICKERT Defendant AI THE COURT OF COMMON PLEAS G9489 CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3107 Civil CIVII. ACTION -LAW Notice of Iutentiou to File Praecipe for Default Judgment TO: Randy M Rickert 410 N Walnut Street Rear Mount Holly Springs PA 17065-1504 IlvIPORTANT NOTICE You aze 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 heazing 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 fmd 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 Cazlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: 7uty 7, 2006 In making [his communication, we advise our office is a debt collector. BURTON NEII, & ASSOCIATES, P.C. Yale D. Weinstein, Esquire Attorney for Plaintiff Identification No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610)696-2120 INNNINNI~~NINNI~I~NII II~I~INII~IIN~N~NII~IINNIIIhIINIII~NINIINNIIN ICJ -~r~ c-~ 6`' ,d ~V 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 V S. RANDY M RICKERT N0.06-3107 Civil Defendant : CP/IL ACTION -LAW RULE OF CIVIL PROCEDURE N0.236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary sy: If you have any questions concerning the above, please contagt. 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. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03107 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS RICKERT RANDY M VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland Courity,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RICKERT RANDY M the DEFENDANT at 1351:00 HOURS, on the 13th day of June 2006 at 410 N WALNUT STREET REAR MT HOLLY SPRINGS, PA 17065 by handing to BILLIE RICKERT SPOUSE 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 Affidavit Surcharge ~ ~,,,,, Sworn and Subscibed to before me this of So Answers: 18.00 5 . 2 8 .,,~. . 0 0 ~~ 10.00 R. Thomas Kline .00 33.284 00/00/0000 ~-/7-a~ By C~ '~ day De uty Sheriff :.r .~. A . D . ~-- 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. RANDY M RICKERT Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.06-3107 Civil CNIL ACTION -LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Neil & As ciates, P.C. Burton Neil, E uire Attorney for P aintiff The law firm of Burton Neil & Associates is a debt collector. C-9489 r-~ ~) ~ -n n " ~.. s..~ --' ..~ e [ ~ , ; ~ rt ; ,.. ,,..3 , . Z Y~i ' ~ ,...3 ~ I R - ~` Y J ~"~ : ~ i ,. ~ f ~ IAA!' {W.J