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Home My WebLink About03-3170BURTON 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 DENISE VASSIL 439 NORTH 2ND STREET LEMOYNE, PA Defendant NO. 0 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 judgrnent 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 10018.034.3794 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, SOUTH DAKOTA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DENISE VASSIL 439 NORTH 2ND STREET LEMOYNE, PENNSYLVANIA Defendant NO. 0~.$/?~ : 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 Fails, South Dakota. 2. The defendant is DENISE VASSIL, who resides at 439 NORTH 2ND STREET LEMOYNE, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiffissued the defendant a credit card with account number 5398430023511130 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 goveming 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 ail 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 baiance due for the charges made by the defendant including any finance charges, late or over limit charges is $3,420.44. 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 $3,420.44, the defendant failed and refused to pay all or any part thereof. 8. Plaintiffalleges 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 $649.88. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $3,420.44, attorneys fees in the sum of $649.88 and the costs of this action. BUI~...T~"lX/IEIL & ASSOCIATES, P.C. In making this communication, we advise our firm is a debt collector. Late Fee: Notice of Change in Terms to Your Citibank Card Agreement g 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 Compl~nt 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: DENISE VASSIL 5398430023511130 10018.034.3794 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-03170 P COMMONTWEALTH OF PENNSYLVAiqIA COUNTY OF CUMBERLAND CITIBANK(SOUTH DAKOTA) NA VS VASSIL DENISE Thomas Kline ,Sheriff or Deputy Sheriff, who being a diligent search and duly sworn according to law, says, that he made inquiry for the within named DEFENDAiqT VASSIL DENISE unable to locate Her COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT 439 NORTH 2ND STREET WORMLEYSBURG, PA 17043 DEFENDANT'S CURRENT ADDRESS IS 6589 WATERLEVEL HWY CLEVELAND, Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 Sworn and , VASSIL DENISE , NOT FOb-ND , as to TN 37323 R. Thomas Kline Sheriff of Cumberland County BURTON NEIL 07/10/2003 subscribed to before me this JL~ day of ~ ~33 A.D. tary 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-IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 15410 DENISE VASSIL 439 NORTH 2ND STREET LEMOYNE, PA Defendant NO. 03-3170 CIVIL TERM CIVIL ACTION ~ LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. BUR~IL & ASSOCIATES, P.C. 10018.034.3794