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Home My WebLink About07-1072Burton 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. GREGG WELLS 1516 Terrace Avenue, Carlisle PA 17013-9369 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (}'0'1 - / O Afo-? (21U !. 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, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-11159 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 CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. a-Lu GREGG WELLS 1516 Terrace Avenue, Carlisle PA 17013-9369 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 Gregg Wells, who resides at 1516 Terrace Avenue, 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 5424180459611197 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 $4,645.54 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 the sum of $4,645.54, and the costs of this action. Burton Neil & Associates, P.C. Burton Neil, Esquire The law firm of Burton Neil & Associates, P.C. is a debt collector. 11/06/06 $4647.91 $4647.91 SITE:KC-CL = s E=# ==aitav =ice `sssi =aasf = CITI CARDS PO BOX 183058 GREGG WELLS COLUMBUS, OH 1516 TERRACE AVE 43218-3058 CARLISLE PA 17013-9369000 Citio Card Account Number 5424 1804 5961 1197 Customer Service: C ti? 1-800-866-9900 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $4100 $0 $3300 $0 $4647.91 BOX 6500 Statement/ Amount Over Purch/Adv Minimum SIOUX FALLS, SD Closing Date Credit Line Past Due Minimum Due Amount Due 57117 10/12/2006 $547.91 $565.80 $200.62 $4647.91 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 10112 LATE FEE - SEP PAYMENT PAST DUE 66 0000 10112 OVER CREDIT LIMIT FEE 62 0000 10/12 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Standard Adv 10112 ADVANCES*FINANCE CHARGE*PERIODIC RATE 84 0000 Your late fee was based on your account balance as of the payment due date (10/06/06), which was $4,458.29. TM:CO-5000 ACID:ROB0554 12/27/06 21:22:38: 39.00 0000000000 35.00 0000000000 93.81 0000000000 21.81 0000000000 Help is available! Please call the toll-free number shown 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. EXHIBIT ' I Account Summar Previous (t) Purchases (-) Payments (+) FINANCE (=) New y Balance & Advances & Credits CHARGE Balance PURCHASES $3 617.24 $74.00 0.00 693.81 $3 785.05 ADVANCES $841.05 $0.00 1 0.00 521.81 4862.86 TOTAL $4,458.29 $74.00 0.00 $115.62 $4,647.91 Days This Billing Period: 29 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $3,662.33 0.08833%(D) 32.240% 32.240% ADVANCES Standard Adv $851.53 0.08833%(D) 32.240% 32.240% Verification I, Kris D,atz 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. 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. Gregg Wells 5424180459611197 V N Q r7 co N O Ti -?P rrI 4T, `l? 1 Z7 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1072 CIVIL TERM GREGG WELLS Defendant CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & A The law firm of Burton Neil & Associates is a debt collector. P.C. , Esquire Plaintiff C-11159 c-n SHERIFF'S RETURN - REGULAR CASE NO: 2007-01072 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS WELLS GREGG MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WELLS GREGG the DEFENDANT at 1946:00 HOURS, on the 9th day of March , 2007 at 1516 TERRACE AVENUE CARLISLE, PA 17014-9369 GREGG WELLS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 3lJc??b? t/ 32.80 Sworn and Subscibed to before me this day of , So Answers: -11 ?,Ae? R. Thomas Kline 03/12/2007 BURTON NEIL & A O IATES By: Deputy Sherff A. D.