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Home My WebLink About02-2567BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 7920 NW 110TH STREET KANSAS CITY, MO Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY S HEBERLIG 8002 WHITE CHURCH RD SHIPPENSBURG, PA Defendant NO. 0o~- ~'(~7 ~ 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 7920 NW 110TH STREET KANSAS CITY, MO Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ASHLEY S HEBERLIG 8002 WHITE CHURCH RD sI-m~PENSBURG, PA Defendant CiVIL ACTION - LAW Complaint 1. The plaintiff is Universal Bank N.A., with place of business located at 7920 NW 110TH STREET, KANSAS CITY, MO. 2. The defendant is ASHLEY S HEBERLIG, who resides at 8002 WHITE CHURCH RD, SHIPPENSBURG, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5491130017288168 for the defendant's use in making credit purchases and securing cash advances subject to the terms and conditions governing the use of the credit card. Attached hereto, made a part hereof and marked Exhibit A is a tree and correct copy of the terms and conditions. 4. The defendant accepted the credit card and the terms and conditions governing its use for the purchase of goods, merchandise and services and/or cash advances from vendors who accepted plaintiffs credit card. In using the credit card, the defendant agreed to comply with the terms and conditions governing its use which included the obligation to pay plaintiff for all the charges made in full upon receipt of the statement or in installments subject to monthly finance charges. 5. The defendant utilized the credit card by making/obtaining purchases of goods, merchandise and services and/or cash advances from vendors who accepted the credit card. Monthly statements were sent to the defendant which detailed the charges made to the account including finance charges, late and/or over limit charges. The balance due for the charges made by the defendant including any finance charges, late or over limit charges is $12,417.51. 6. Defendant did not pay the balance due in full upon receipt of the billing statements and failed to make the required minimum monthly payment set forth in the the billing statement. As such, defendant is in default of the terms and conditions governing the use of the credit card. 7. Although demand has been made by plaintiff upon defendant to pay the sum of $12,417.51, the defendant failed and refused to pay all or any part thereof. 8. Plaintiff alleges it is entitled to recovery of attorney's fees from defendant pursuant to the terms and conditions governing the account. Plaintiffs counsel is not a salaried employee of Universal Bank N.A.. Plaintiff seeks recovery of attorney fees in the sum of $2,359.33. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $12,417.51, attorneys fees in the sum of $2,359.33 and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. r~ i: Verification Linda Gonzales is a manager for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Citigroup, the w/thin Plaintiff in this action. She verifies that the statements of fact made in the foregoing Complaint are tree and correct to the best of her knowledge and belief. The Undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK SOUTH DAKOTA N.A. 701 East 60m Street North Sioux Falls, SD Plaintiff VS. ASHLEY S. HEBERLIG 8002 White Church Road Shippensburg, PA Defendant : IN THE COURT O : CUMBERLAND : NO. 02-2567 : CIVIL ACTION - PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudk BURTON NEIL & ~on Nel Attorney fc ?COMMON PLEAS )UNTY, PENNSYLVANIA AW kSSOCIATES, P.C. Plaintiff SHERIFF,s RETURN _ OUT OF COUNTy CASE ~0:2002-02567 p COMMONWEALTH OF COUNTy OF PENNSYLVANIA: CUMBERLAND CITIBANK SOUTH DAKOTA N A VS HEBERLIG ASHLEy S Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co R. Thomas Kline duly SWorn according to law, and inquiry for the within named DEFENDANT HEBERLIG ASHLEy S ~ , to wit: but was Unable to locate Hi_~m ~ deputized the sheriff of F___~___~KLiNin his bailiwick. He therefore Serve the within COMPLAINT & NOTICE County, Pennsylvania, to On Ju--~Y-~ 19~th , 20__q~02 , this officels . attached return from FRANKLIN mn receipt of the 18.00 9.00 10.00 37.80 .00 07/19/2002 OLIN NEIL HALTRECHT Sworn and subscribed to before me this 2~,,.( day Jm-~/~ A.D. of ~ Sheriff or Deputy Sheriff who being Says, that he made a diligent Search and So Sheriff of Cumberland County SHERIFF,s RETURN _ REGULAR CASE NO: 2002-00069 T COMMONWEALTH OF COUNTy OF PENNSYLVANIA: FRANKLIN CITIBANK SOUTH DAKOTA NA VS ASHLEy S HEBERLIG JASON M. BITNER -' ~ of FRANKLIN County, Pennsylvania, who being duly SWorn according to law, Says, the within COMPLAINT HEBERLiG ASHLEY S Was Served Upon DEFENDANT , at at 0015:00 Hour, on the7_~th day of June 8002 WHITE CHURCH ROAD ~, SHIpPENsBURG, PA 17257 ~ ASHLEy S. HERBERLiG by handing to a true and attested copy of COMpLAiNT the together with and at the Same time directing He____r attention to the COntents thereof. Sheriff's Costs: Docketing Service 9.00 Affidavit 9.00 Surcharge 4.00 Mileage 10.00 So Answers: 07/09/2002 CUMBERLAND COUNTy SHERIFF Sworn and Subscribed to before In The Court of Common Pleas of Cumberland County, Pennsylvania Citibank South Dakota VS. Ashley S. Heberlig SERVE: Ashley S. Heberlig No. 02 2567 civil Now, -May 30, 2002 _, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin _ County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.. SheriffofCumberland County, PA within Upon at Affidavit of Service _, 20 at ~ o clock ~ M. served the by handing to a and made known to _ copy of the original _ the contents thereof. So answers, Sworn and subscribed before me this ~ day of Sheriffof COSTS SERVICE MILEAGE~--~--~ $ AFFIDAVI~-----~ County, PA ,-- J