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Home My WebLink About03-1721 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 SEAN R MCMULLEN 31 QUEEN AVENUE ENOLA, PA Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · ?40. oa - 17..ll · 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 10007.034.484 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 SEAN R MCMULLEN 31 QUEEN AVENUE ENOLA, 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 SEAN R MCMULLEN, who resides at 31 QUEEN AVENUE, ENOLA, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5424180422507480 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 f'mance 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 $8,452.09. 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 $8,452.09, 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 $1,605.90. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $8,452.09, attorneys fees in the sum of $1,605.90 and the costs of this action. CIATES, P.C. ~Esq~ire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. goo~ or ~ue ~ .~e~ of ?tour ~ak i~ ~ =''~hle zo buy or le~e b~ for ~ ~-ou~ ~ o~;V be ~d for - ~ ~~= · _~ ,_~_~ _.- .... -_~ ,_ . nor ~ ~ ~o ~y ~' :~o,~ o~ ~ ~ ~d~- ~ ~r ~y ~v ~c~o~ we ~ you_ ~ 4 .... _ .. ~ m ~ ~ adv~uc~ b~c~ ~ w~ ~ec~a io hono~ a ozc~i ~% gyou def~% Jfyou ~d not co~oly w~ De.f~u!t p~v ~y ~o~Z yOU 0~ Te~e. phone ~- ;~ ~=~ or b5 ~I~hone ~d ~a~ you hotv so ~:~z z ~:e~ ef Ser~c~Caqle~ ~0. 8ox 4412~= J~d~ie, 3~I~;2T. I[ you nol~y us ~a~ you do r~( a~aof Ih~ pla~e rsrer to Your CJb%a~ Card A~ment by ah7 ~r ~q~nos in lecm~ a~. a~ng }~ur C~ro~:~ ~cd ~res~enf [o ~ubsglu~' ~ran~i~n ~a for b~hn~l~/~s, and fi~e ~r~me~. ~en app~bfe, Ih~a cha~ Y~ to read ~ no¢~ ~nd ~ve ~ for furze rs(er~nca. -the a"~qualpe.'c, enlac~e raia i'orpdr~ and c~' ad~n~ may ~ va~ i[ ~ del~u{{ onder anv ~Ubank Ca~Ag'~m~Jbe~ you ia~ Io make a o~menl Io ~ or any Of,Ser o~Ud~ w% n dOe .... ' ~ne, ~you ~ake a paym~ol ia ~ ~lal ~ noi ,h~ed pr~ ron. F rale) ~ · . a~ balings to a 'da/abd~ mf~ O/uo to 24,~%. ~c:or* considered h dalsrm~in9 Ih~ de/au4 rate ~y include I~ feng~ O[ lime he a~nl h~.been open, ~%e e~l~ x~iou~, and ~n~ of C~[ib~k Card A~m~l del~d s and olher h~o~ Os acc~( usage ~ ~ s:~you/~vs me[ lbe [e~ o[ a~ C~l~s~ ~rd belanc~ will remco ~b/e~ 1o Che dolaut] m(e m~ lhey are p~id In fuiL 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: Defendant: SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-01721 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAlqD CITIBANK SOUTH DAKOTA NA VS MCMULLEN SEAN R 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 MCMULLEN SEAN R unable to locate Him in his bailiwick. but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , MCMULLEN SEAN R 31 QUEEN AVENUE ENOLA, PA 17025 PER POST OFFICE, DEFENDANT IS DECEASED. , NOT FOUND , as to Sheriff's Costs: Docketing Service Not Found Surcharge 18 00 20 70 5 00 10 00 00 53 70 So answ ~ . ....... R. Thomas Kline Sheriff of Cumberland County BURTON NEIL 05/02/2003 Sworn and subscribed to before me this day of ~ ~900~ A.D. PrOthonotary ~ 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 IN TI~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 15863 SEAN R MCMULLEN 31 QUEEN AVENUE ENOLA, PA Defendant NO. 03-1721 CIVIL TERM CIVIL ACTION - LAW Praeeipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. BURTON NF~ & ASSOCIATES, P.C. / l~urtS~/Neil, Esquire Attorriey for Plaintiff 10007.034.484