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HomeMy WebLinkAbout03-4045BURTON NElL & ASSOCIATES, P.C. By: Burton Neff 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 ROBERT C HARR 68 TIFFANY DRIVE SHIPPENSBURG, 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 10010.034.5175 BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell 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 ROBERT C HARR 68 TIFFANY DRIVE SHIPPENSBURG, PENNSYLVANIA Defendant :NO. 03 : CIVIL ACTION - LAW Complaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is ROBERT C HARR, who resides at 68 TIFFANY DRIVE SHIPPENSBURG, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 4428135130187925 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 fi.om 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 $20,519.80. 6. Defendant did not pay the balance due in full upon receipt of the billing statements and failed to make the required minimm 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 $20,519.80, 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. Pla'mtiffs counsel is not a salaried employee of Citibank (South Dakota) N.A. Plaintiffseeks recovery of attorney fees in the sum of $3,898.76. WHEREFORE, plaintiffdemands judgment against the defendant in the sum of $20,519.80, attorneys fees in the sum of $3,898.76 and the costs of this action. BU~T~L~L & ASSOCIATES, P.C. Burton I~Teil, E~quire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. 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. Tbe 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: ROBERT C HARR 4428135130187925 10010.034.5175 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 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 20546 ROBERT C HARR 68 TIFFANY DRIVE SHIPPENSBURG, PA Defendant To the Prothonotary: Please reinstate the Complaint. NO. 03-4045 CIVIL CML ACTION - LAW Praecipe to Reinstate BU~~OCIATES, P.C. BY"~ff~on Neil, Esquire Attorney for Plaintiff 10010.034,5175 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 23369 ROBERT C HARR 68 TIFFANY DRIVE SHIPPENSBURG, PA Defendant NO. 03-4045 CIVIL CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above captioned action without prejudice. B.jN ,NEIL & ASSOCIATES, P.C. 10010.034.5175