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Home My WebLink About06-4740 > , , 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 ClTIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0(. - 47L/O ~,uitT~ KHRISTIE L LONG 317 Zion Road, Mount Holly Springs P A 17065 Defendant CIVIL ACTION - LAW COMPUAINT NOTICE You have been sued in court. If you wish to defend ~nst 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 wri1ling with the court your defenses or objections to the claim set forth against you. You are warned that iryou fail to do so, the case may proceed without you and a judgment may be entered against you by th<1 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 IlA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TP OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU ~AN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LA WYtR, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOU11 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REF$ENCE AND INFORMATION SERVICE Cumberland Couj1ty Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-9787 III~III m IIHllmllB IBIIIHIIIII III~IIIIIIII BIIII 1111 11111 IIBI 11111 Hili II 11111111 IBII II 1111 IIml II 11111 mill/liB . . , BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, LD. No. 11348 1060 Andrew Drive, Suite 170 WestChester,PA 19380 610-696-2120 Attorney for Plaintiff : IN THE COURT OF COMMON PLEAS CITmANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. OL.- (!:lCJ~L T~ v. KHRISTIE L LONG 317 Zion Road, Mount Holly Springs PA 170651418 Defendant : CIVIL ACTION - LAW Complaint 1. Plaintiff is CITmANK (SOUTH DAKOTA) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Khristie L Long, who resides at 317 Zioo Road, Mount Holly Springs, Cumberland Couoty, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including coosumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with accouot number 5424180545192517 hereinafter referred to as the credit card account. S. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statementll for the account including the billing statement attached hereto as Exhibit A. The monthly statements accutately 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 mooths 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 $6,019.32 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 defeodant for the sum of $6,019.3 2, and the costs of this It The law firm of Burton Neil & Associates, P.e. is a debt collector. SOCIATES, P.e. action. . . " 03/02/06 :iiw.%W%Wt $6029.32 ~~MI!f%~@ $6029.32 SITE:KC-CL TM:CO-5000 05/18/06 __.no ~'-im~'~~~~'hn_~ ---"_.-....,,..............~......_. ~~!!=.f.... ::::~1:~: CITI CARDS PO BOX 183055 COLUMBUS, OH 43218-3055 KHRISTIE L LONG 317 2ION RD M HOLLY SPGS 17065 -1418000 Citi~ Driver's Edpe~ Platinum Select Card-Charter Rbts Account Number 5424 1805 4519 2517 Customer Service: 1-800-925-8871 BOX 6500 SIOUX fALLS, SO 57117 Sail Dat. Post oate R.I.rence Numbu 2/06 2/07 2/07 2/07 PA car Total CredIt Line $3800 Statementl CloJln9 Date 02/07/2006 34534018 Available Credtt Line $0 Amount Ov.r Cr.dlt Line P..t Due $2229.32 $1129,22 AdiYlty Since La,t stawm.nt Payments. Credits & AdjustMents PAYMENT THANK YOU 70 0000 0000 -10.00 00000000000 Cash Adv.nce'lImlt $600 Av..Uable Cash Limit $0 Parch/Adv t.tlnfmum Due U53.27 New Balilnee $6029.32 Minimum Amount Du. $6029.32 Amount Standard Purch OVER CREDIT LIMIT fEE 62 0000 PURCHASES"fINANCE CHARGE"PERIODIC RATE 84 0000 Standard Adv ADVANCE5'fINANCE CHARGE' PERIODIC RATE 84 0000 35.00 0000000000 137.82 0000000000 10.45 0000000000 Help is available! Please call the toll-free number ~hown 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. AC:C:OU1t SUmmllrY PURCHASES ADVANCES TOTAL R.t. Summery PURCHASES Standard Purch ADVANCES Standard Adv Previous (+) Purchases (-) Plly~.nts (+) FlNANCE (=) New Balance & Advances & Creldits CHARGE Balance $5t443.04 $35.00 1~.72 $137.82 $5 ~ 609 .14 413.01 $0.00 3.28 $10.45 420.18 $5,856.05 $35.00 $10.00 $148.27 $6.029.32 Balance SUbject to finance Charge $5,508.83 $417 .81 Days This BllllnQ P.rlod: 29 Nominal ANNUAL APR PERCENTAGE RATE Penodlc R.t. 0.08627%(0) 0.08627%(0) 31. 490% 31. 490" 31.490% 31.490% ACID:ROB0554 00:39:02: ~ ~ ~ 4) . " ,. Verification I, Jlllme PIyne 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. 1 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. 1 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. ~~ Khristie L Long 5424180545192517 e~8"1 ernilll.. f:) ~ ~ ~ ("') = t t U'l. c: "" ~ rc0 Crt ~ l:: -Or",' rt'~ ,,'['- c> -o~ '--y.. , '"~lr;t Crt ~; - :n ~ ..) 'j: (it -I '~ ~ \)' .. 4". - =< H -n 1~~ .." C)B ""'Q .c::: -U ~~f2,; ;:J: ;?-:rn - ! w 9 ~ r :Y'C: .' -". Z - ~ ~ :;: N ~ 1- SHERIFF'S RETURN - REGULAR CASE NO: 2006-04740 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS LONG KHRISTIE L BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon LONG KHRISTIE L the DEFENDANT , at 0017:37 HOURS, on the 13th day of September, 2006 at 317 ZION ROAD MOUNT HOLLY SPRINGS, PA 17065 by handing to JANICE LONG (MOTHER) a true and attested copy of NOTICE together with COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.16 .00 10.00 .00 34.16./ tf/;2(o{, ~ Sworn and Subscibed to So An?~_~~ R. Thomas Kline 09/14/2006 BURTON NEIL day Deputy Sheriff By: jJhfij) ftl. before me this of A.D. Bu.'1on Neil & Associates, P.C. t By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA C1TIBANK (Soum DAKOTA) N.A. v. : NO. 06-4740 KHRISTIE L LONG Defendant : CIVIL ACTION -LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. The law firm of Burton Neil &. Associates is a debt collector. C-9787 11111111111 1111111111111111111111II11111 1::J ~~;; r-:> = S.~ o C). ----j: ~...) '--l ~ ..-! :r-;.--n rnc: 4"""1 '~"l",: -?,{;\ .,-);::'':::'::.j ~,i;,> }i"', .~ .'b ~ --0 --'.-'" --<,.:',:M c