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Home My WebLink About03-4040BURTON 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 TRACEY L COVER 6204 PAXTON RUN ROAD SHiPPENSBURG, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~-~ -- ~/~)~t(.~ ~')~ 0 't 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 10007.034.5292 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. 70l EAST 60th STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TRACEY L COVER 6204 PAXTON RUN ROAD SHIPPENSBURG, PENNSYLVANIA 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, South Dakota. 2. The defendant is TRACEY L COVER, who resides at 6204 PAXTON RUN ROAD SHIPPENSBURG, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiffissued the defendant a credit card with account number 5424180442970759 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 $9,988.36. 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 $9,988.36, 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 $1,897.79. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $9,988.36, attorneys fees in the sum of $1,897.79 and the costs of this action. BI_ R31~N ~/EIL & ASSOCIATES, P.C. BY:Burton~ei s~uir 1, E e Attorney for Plai/~ff In making this communication, we advise our finn is a debt collector. c~ Notice of Change in Terms to Your Citibank Card Agreement § @ 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 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 unswom falsification to authorities. Date: Name TRACEY L COVER 5424180442970759 10007.034.5292 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 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 20509 TRACEY L COVER 6204 PAXTON RUN ROAD SHIPPENSBURG, PA Defendant NO. 03-4040 CIVIL CIVIL ACTION ~ LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. BI~RT6~f NEIL & ASSOCIATES, P.C. ~....~~ on Nell, Esquire Attorney for Plaintiff 10007.034.5292