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Home My WebLink About06-4010 . 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 SARAH M BOSWELL 503 Grant Drive, Camp Hill P A 17011 Defendant NO. 010 - '-/DIO C,~~L T0L~ : 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 C-9622 ; ~ BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, LD. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CmBANK (SOUTH DAKOTA) NA 70 I East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. Ot. ~ i(tJlO ~iu~CT~ SARAH M BOSWELL 503 Grant Drive, Camp Hill PA 17011 Defendant : CIVIL ACTION - LAW Complaint L Plaintiff is CITIBANK (SOUTH DAKOTA) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Sarah M Boswell, who resides at 503 Grant Drive, Camp Hill, 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 5424180 I 02981997 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 $4,492.68 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. sum of$4,492.68, and the costs of this action. SSOCIATES, P.c. "--- B' Burton The law firm of Burton Neil & Associates, P.C. is a debt collector. , .. 05/02/06 $4492.68 $4492 . 68 SITE,KC-C( 1M,CO-SOOO ACID,ROBOS54 Hilllllllllln Ilillin 1111:1I111I1111I11I11 1IIIIIIIIIIIIHlllllIiI 04/25/06 20,41:26: cln CAR S PD 80X 1 3055 SARAH M BOSWELL COLUMBUS OH PO BOX 141 43218-30 5 CAMP HILL PA 17001-0141000 C~qbbV I ~.E!emond Preferred'" Entert.lnment ca~ 5424 1801 0298 1991 I ClIItIlIM~ i 1-_-9~&-8 1 _C.-LlM. .....A......UnoIl ~wol..ble~bL..ft lOX 6lilH1 $0 $1200 I $0 SIOUX FALLS. SD A'r.:."It'lr: ! _. _ '=-"'= 85 2.65 --- .....- St_,~ ,cli 4/01 PURCIIASES. IRAllCE CHARGE.PER OOlC RATE 84 ??OO' cffr New ..I.Ke $4492.68 A..:l-r.: <l49Z .. - 68.65 ??oo??oo00 CHAMGIRG YOUR ADDRESS? LET US KRO....I~. aln your QOOd cr It ratlnQ. Keep us tnfor~ of your new .deSre.s. WIten' you . pleas. correc your aditress on the pay..nt coupon or call custo..r seryl e. Kelp. II ayallablel Pleale call the toll-tree nu~r lhown boye to learn about our 1"""lal pay..nt options. Call _daY.' - Frida. y. .1 a. to 9 p.. or Saturday, 8 a. to 5 p., Central TI... Pleale Qlye .1 the ~rtunlty to assist you. --...rv rovlOUS + ur aym . . IW CIlARGI: PURCHASES $4'~f.03 (i' 00 fO.DO $68.65 $4,492.68 ADVANCES . 0.00 0.00. 0.00 $0.00 $0.00 TOTAL $4.4 4.03 0.00 0.00 $68.65 $4,492.68 01 TIlll8.. _30 Rate -1IrY ..nQ I 0 C omna ANNUAL Fln.,c" Char . Ratl APR PURCIIASES EXHIBIT Standard Purch $4,451.12 0.0513411(0) 18.74011 18.74011 ADVAIltES Stondard Ady $0.00 0.0623011(D) 22.14011 22 .7<1011 , . Verification I, Sandy Arenas am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiffCITIBANK (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. -----------~ ,f <". Sarah M Boswell 5424180102981997 '. 26n91A I{Oru,€ i (J .(q \ ~ "-> ~ c.., ...... -,-, -T-) E tv D ::;j G ~ ., ~ r .-.-" tr' --. ;',) ,"1-., ~ c....) ( SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04010 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BOSWELL SARAH 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 BOSWELL SARAH M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , BOSWELL SARAH M 503 GRANT DRIVE CAMP HILL, PA 17011 503 GRANT DRIVE IS VACANT. NO FORWARDING ADDRESS ON FILE AT POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 26.40 5.00 10.00 .00 59.40 Y i :10/0 ~ q-. Subscribed to before ~ R. Thomas Kline Sheriff of Cumberland County BURTON NEIL 07/31/2006 Sworn and me this day of A.D. Burton Neil & Associates, P.C. By: BUrton Neil, Esquire ill. 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. : NO. 06-40 1 O-civil SARAH M BOSWELL Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without pr. c /"" Burt6n Neil & Burton N 1, Esquire Attorney r Plaintiff By: The law firm of Burton Neil & Associates is a debt collector. C-9622 1111111111I 11111111111111I11111111111111 111111111111111111111111111111111111111111111I11111I11111111111111/1111111111111111 11111111I111111111111111111111111111111111 (") ~ ~~: ~r' ~J:: ~(.::. k-'. ~C; =0 J:>c: z: ~ f'-oJ' g t::r" !5 ..c. N CD ~ ~~ :Bo Ob -4-,-. :C-d ~B .><--rn ~ ~ -0 :J: N .. s:- O