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Home My WebLink About03-1719BURTON NElL & 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. 701 EAST 60TH STREET NORTH SIOUX FALLS, SD Plaintiff Vo CARL E SNYDER 201 YORK ROAD NEW CUhdBERLAND, PA Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · 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 10014.034.3528 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. 701 EAST 60TH STREET NORTH SIOUX FALLS, SD Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA Vo CARL E SNYDER 201 YORK ROAD NEW CUMBERLAND, PA 'NO. Defendant · CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 EAST 60TH STREET NORTH, SIOUX FALLS, SD. 2. The defendant is CARL E SNYDER, who resides at 201 YORK ROAD, NEW CUMBERLAND, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5466160193334925 for the defendant's use in making credit purchases and securing cash advances subject to the terms and conditions govemlng the use of the credit'card. Attached hereto, made a part hereof and marked Exhibit A is a true 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 $12,772.77. 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 $12,772.77, 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 Citibank (South Dakota) N.A. Plaintiff seeks recovery of attorney fees in the sum of $2,426.83. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $12,772.77, attorneys fees in the sum of $2,426.83 and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. ( Burt°fi'~eix~_~torn_ey fol?pElSmq, fin}~f In making this communication, we advise our firm is a debt collector. i ~ o~ ~u~ b'ff;~ .... ~- '---~ .... - · .. - ~oN~e~ by yo~ ~d ~ w~h qou ~v~d no De~u!t you ~ ~ d~a~ ~v~ m~v ~a yom- ~t ~d p~r of ~ ~ ~uo& 2-you ~w ~n ~ p~v ~y ~o~ you 0~ ~_ Bu~ offcome, you ~:~ C~I ~ ~ a~fi f~ ~- ~ h~o yom ~- ~x- ~- fe~ rf~e ~e ~o coiiez: ~d ve-- ~o~ you or vo~ ~o~.~ 5~a ~ ~ p~ ~eL- ~&cz c-: m~u~ yo~ u~e. ~s= -~d ~ n~. ~e sx~ ~d you ~ Telephone ~io~m H~ <- {m ~ ~ b5 ~h~e ~d ~zz you ho~v ~ ~ z ~ C]os~g Ref~s~ of ~a ~.a ~ hoc z~o~bie ~-s~ do nor ~ a ~e or c~ ~v&7~ Om :- · ~ ' ~" - ~ ~e ~ m~um . ~ ~.n~ 3~l~1. t[~ nobTy us ~t You do noi a~a~/!h~e · 'Y°U~nc~iioue{oe~e~c~d(sl,,~' , or ~o e~i~iion date on Il. i Imray ~r ~c~nt ~tt be c[O~' ~d you w~ll ~e pay or( ~r ple~ r~t lo y~r Cil~a~ C-r<~ ~ ) COgent le~s, by any ~r ~anos ~ng, our ~Jo~ ,,. ~d ~reem~ Io subsglu~' . Y~ {o (sad ~ no~ ~qd ~e ~{ fac [uiure rs [¢~nce. Va~i~i~ ~nnuM ~ircan~a~ Raie~ far ~e ~"~ua! percen~e rai~ ior pdr~ ~nd c~h' afl~nc~ ~y ~ va~ i[ ~ de[aull undez any Ca~'~be~ you ~) 'o mak~ s p~men/ o ~ or any Ol,Se~ ~'~6r wi)eh d~, Y~.ex~d war ~ne, ~you make a Caym~l D ~ ~al ~ no( h~ed 24 ~ ~oc~ ~d~rad ~n Oel~rmb~g th~ dei~lt ~%a ~ s~ou~, ~nd E~n~ o[ Cffib~k Card Agr~m~l de/~ ¢~, and olher ~l~cns O! acc~/usage a~d pedo~ncm ~e %~eaaa % ~e ~dabl8 parentage ~le be~me'e~glble /ac a ~r ~ ~ al~ yO~ ~vs mel Ihs le~ O( aU Cib%a~ ~rd ~a~n~ W~I remco ~bje~ lo Lhe deia~il ~[e ~f~ ihe7 are pdd In full Verification Jennifer Sisson is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Citigroup, the within Plaintiff in this action. She verifies that the statements of fact made in the foregoing Complaint are true 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 unsworn falsification to authorities. Date: Account number: ~ CoG I~ 0 ~ ct ~ '~:~"'-t' c~-~- Defendant: ~.-c., v' ~ ~ r~ ,~.3~ v- SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-01719 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SNYDER CARL E 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 SNYDER CARL E unable to locate Him COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT , SNYDER CARL E 201 YORK ROAD NEW CUMBERLAND, PA 17070 ADDRESS INDICATED IS ACTUALLY LOCATED IN YORK COUNTY. RETURNED NOT FOUND PER ATTORNEY'S OFFICE. , NOT FOUND , as to Sheriff's Costs: Docketing Service Not Found Surcharge 18 00 00 5 00 10 00 00 33 00 / R. Thom~"K1 ine Sheriff of Cumberland County BURTON NEIL & ASSOCIATES 04/16/2003 Sworn and subscribed to before me this ~ ~L day of~ ~o~a3 A.D. Prot~dnot ary ~ 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. 701 EAST 60TH STREET NORTH SIOUX FALLS, SD Plaintiff Vo CARL E SNYDER 201 YORK ROAD NEW CUMBERLAND, PA 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 ifyoa 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 WItERE YOU CAN GET LEGAL HELP. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 717-249-3166 ~ECO~14.034.3528 't'RUE COPY FROM BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2 ! 20 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 CARL E SNYDER 201 YORK ROAD NEW CUMBERLAND, PA · NO. Defendant · CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 EAST 60TH STREET NORTH, SIOUX FALLS, SD. 2. The defendant is CARL E SNYDER, who resides at 201 YORK ROAD, NEW CUMBERLAND, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5466160193334925 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 true 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 $12,772.77· 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 $12,772.77, 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. Plaintiff's counsel is not a salaried employee of Citibank (South Dakota) N.A. Plaintiff seeks recovery of attorney fees in the sum of $2,426.83. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $12,772.77, attorneys fees in the sum of $2,426.83 and the costs of this action. BUR~ & ASSOCIATES, P.C. ~sqtiire Attorney for Plaintiff The signature above certifies that this is a tree and correct copy of the original file in this cause. In making this communication, we advise our finn is a debt collector. p%v ~y ~o~ you ot~ - -- ~*~'~=~-~}'~-fe~ rf~e~a~ocoiie=i~dvo.- co~. ~ ~o% ho,zm~_ ,~ ~- ~o~ c:~ com~ . - o~ ~ ~ !-~on~ --=~ f ..... L . , '7~' ~ ~i .~d you Teiephone ~ ~ ~ ~ ~ q~y; of ~r s~ ~ ~-~ yom- r n~ ~,on ~ I0, bo,~n~ l~nsf~s, and Enel~ Ihs cor~po~ng ~ in ~r Y~ ~o [sad ahis no~ ~d ~w ~ for future ~a/er&nce - . ~a~ Ag~b~: z~ ~etsuK Unae~ any- Cigbank ~i~:Y~:~t~k~a~aYm~( ,o ~ ~a, ~ no[ h~ed Pr~l[ona~ rala) ~ a~ balAn~s Io a de[aut{ ~[g o[ UO 2~,~%. ~x ~nslderad in d~le~m~9 ~h~ deFau~l ~he &~len~ s~ou~ and .... ' pe~c~ntsge ~e ~ ~ ~' ~e~e e~g~o~e [o~ ~ ~ are paid In fuji ule~ Jo Lhe osiad~ ~[e ~ii I~ey Verification Jennifer Sisson is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subs/d/aries of Cifigroup, the w/thin Pla/ntiffin 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 unsworn falsification to authorities. Date: Account number: Defendant: BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification number: 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 701 EAST 60TH STREET NORTH KANSAS CITY, MO Plaintiff V. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 12651 CARL E SNYDER 201 YORK ROAD NEW CUMBERLAND, PA Defendant · NO. 03-1719 CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. NEIL & ASSOCIATES, P.C. 10014.034.3528