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Home My WebLink About06-5278 ....... .4, 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. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 010 - 5,),."11>' CI~~L/~ KENNETH B KULLMAN 769 Hamilton Court, Carlisle PA 17013-1519 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 TillS 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 IllRING A LAWYER. IF YOU CANNOT AFFORD TO IllRE A LAWYER, TillS 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-I0129 11111111111111111111111111111 I111I11111111 mil 1111 11111 11111 111111111111 IIIIHIIIII II 111111 11111 IllIImll 11111111111 ,. ~ .~. I 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) N.A. 70 I East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. Cl. - Q/1r (?lu~L ~~ KENNETH B KULLMAN 769 Hamilton Court, Carlisle PA 17013-1519 Defendant : CIVIL ACTION - LAW Complaint 1. 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 Kenneth B Kullman, who resides at 769 Hamilton Court, Carlisle, 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 5410654361236513 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 $26,876.45 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 of$26,876.45, and the costs of this action. By: l - Burto The law firm of Burton Neil & Associates, P.C. is a debt collector. '-._" , 10/14/03 IjJij$ir:':::::M~ $28131.07 $2529.75 ~~~:~:t15 ~~~l@:~!@m 5 ITE: KC-CL TM:CO-5000 07/12/06 ACID:KCB3104 22:28:21: KENNETH B KULLMAN 8 DIVER DUCK DR LONG NECK 19966-9622000 CITI CARDS PO BOX 183063 COLUMBUS, OH 43218-3063 .0LCA \ ~\ V \;\ DE C It I" G ~.t~...~~~ty.~.!:lJ!l,a!:," ~~t~,. Account Number 5410 6543 6123 6513 PAYMENT MUST BE RECEIVED BY 1:00 PM LOCAL TIM[ ON 10/14/2003 Statement/Closll19 Date 09/19/2003 tor Customer S.rvke, ClU or write 1-888-766-CITI (2484) T.r-..... iiI..._........ ... ..... ...... aIInlJ ... Mtpr_r-""" 80X6062 SIOUX FALLS, SO 57117 Total Credit Line $28000 Available CredIt Line Cash Advance Limit $0 $1300 ~~:dWl.?:r Past Du. $131.07 + $1754.98 + ActlYlty SInce LBlt statem.nt Standard Purch LATE FEE- AUG PAYMENT PAST DUE 66 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 'THE FOLLOWING DISPUTE IS NOW CONSIDERED RESOLVEO ' 'NSS'R690P6'GQ MAG 5/12 SALE DATE ' , $10.00 + $.30 FIN CHG PREVIOUSLY CREDITED' A....nable Cash LImIt $0 PlJrch/.4clv MlnlmJm Du. $643.70 = New Balance $28131. 07 5.. O.t. Post DeW R.lerence Number MlnllTl.1m Amount Due $2529.75 Amount 9/19 9/19 35.00 0000000000 638.70 0000000000 '" CITI AADVANTAGE MILES UPDATE .., Earned Miles: 0 Too much debt and looking for a solution? If you are a homeowner~ call Citifinancial Mortgage at 1-888-722-9<36 to apply for a home egulty debt consolidation loan. Your preferred status number is 81212. EXHIBIT If- Prevlou.s {+} Purchases (-} Payments (+) FINANCE {=} New Balanct & Advancts & Credits CHARGE Ba lanct $27,457.37 $35.00 (0.00 $638.70 $28,131. 07 $0.00 $0.00 0.00 $0.00 $0.00 $27.457.37 $35.00 0.00 $638.70 $28,131. 07 AccOWIt SUmm.-y PURCHASES ADVANCES TOTAL R.t. Summary PURCHASES Standard Purch ADYANCES Standard Adv Bel.nct Subject to F'lnence Chan~e $27,764.85 $0.00 PeriodiC Ri!lte Days This Billing Period: 30 Nommi!ll APR ANNUAL PERCENTAGE RATE 0.07668%(0) 0.07668%(0) 27.990% ' 27.990% 27.990% 27.990% .. . -- I Verification I, J8Ime PIlYM am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITlBANK (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. ~tl~ '\ Kenneth B Kullman 5410654361236513 . Br1'(SQ emlsL n 'be.. G "'. i'V 'R 1I1 ,....., #'- CI1 (") c;, 0 c- = -n ~""" .;;J"'t. ~" ," <:I? "" ~ P"! rnr ....... -'J -''rfTI Cb Vl () \ :.:~? CO ':~::i (..) "l -c.J "~'lf t -0 ;:'')=t} ..... :l: ""."" 11: F , '7.... ~ (",) x:- es ::;::; -; "'~~ jJ ----t ~ -:I c:> -< "-, N -- Burr~n 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 VS. : NO. 06-5278 KENNETH B KULLMAN Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudiJe. Burton Neil & Associates, P.C. BY: The law firm of Burton Neil & Associates is a debt collector. C-10129 1111111111I111111111111111111 111111111111 11111111111111111111111111111111111111111111I11111I1111111/11111111111111/1111 I111 11111111I11111111111111I1111 11111111I1111 (') r-,:> 0 -c:::::;: C'~ c:::> Ii ooS-' " (':) (') -' ..... -V -.~ N C- \..O SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-05278 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS KULLMAN KENNETH B 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 KULLMAN KENNETH B but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT , NOT FOUND , as to the within named DEFENDANT , KULLMAN KENNETH B 769 HAMILTON COURT CARLISLE, PA 17013-1519 DEFENDANT DOES NOT RESIDE AT ADDRESS PROVIDED, PER CURRENT RESIDENT AND SON KYLE KULLMAN, DEFT RESIDES IN LONG NECK DELAWARE. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 4.40 5.00 10.00 .00_1 37.40,/ 16/0";0' 9- Subscribed to before County & ASSOC Sworn and me this day of A.D.