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HomeMy WebLinkAbout01-4566OLIN, NEIL & HALTRECHT By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff CITIBANK (sOUTH DAKOTA) N.A. 701 East 60~ Street North Sioux Falls, SD 57117 Plaintiff ROBERT REED 1053 W King Street, Shippensburg, PA 17257-7900 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 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 Assoc. 2 Liberty Avenue Carlisle, PA 17013 Telephone No. 717-249-3166--800-990-9108 OLIN, NEIL & HALTRECHT By: Burton Nell, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60t' Street North Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT REED 1053 W King Street, Shippensburg, PA 17257-7900 Defendant NO. CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A. with place of business located at 701 East 60~ Street North, Sioux Falls, South Dakota. 2. The defendant is Robert Reed, who resides at 1053 W King Street, Shippensburg, Cumberland County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card 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. 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 for cash advances from vendors who accepted plaintiff's credit cards. 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 charges made in full upon receipt of the statement or in installments subject to monthly finance charges. 5. The defendant utilized the credit cards 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 late and/or finance charges. The balance due for the charges made by the defendant including any late or dalinquency charges is $7,752.15. 6. Defendant did not pay the balance due upon receipt of the billing statements and 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 $7,752.15, the defendant failed and refused to pay all or any part thereof. 8. Pursuant the terms and conditions of the account, Defendant is liable for attorneys fees in the sm of $1,550.43, which Plaintiff has calculated at 20 per annum. A true and correct copy of the terms and conditions of the account is attached hereto, marked Exhibit A. Wherefore, plaintiff demands judgment against the defendam in the sum of $7,752.15, attorneys fees in the sum of $1,550.43 and the costs of this action. Burton Neil, Esquire Attorney for Plaintiff VERIFICATION Jeanette M. Brown is a Manager for Citicorp Credit Services, Inc. The within plaintiff Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc. are both wholly owned subsidiaries of Citigroup and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. APR ~ 8 Z001 ~ ~. ~ Date:. Name OLIN, NEIL & HALTRECHT BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. VS. ROBERTREED Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 014566 Civil Term CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. OLIN, NEIL & HALTRECHT BUrton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that we are a debt collector. OLIN, NEIL & HALTRECHT BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. VS. ROBERT REED Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4566 Civil Term : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. OLIN, NEIL & HALTRECHT Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that we are a debt collector.