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Home My WebLink About07-4734Burton Neil & Associates, P.C. By: Derek C. Blacker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Q rf _ ~ 7,31 TIMOTHY J PEIRCE 7 West Main Street New Kingstown PA 17072-0294 G'~~~I T~ Defendant 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-12268 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire, I.D. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. TIMOTHY J PEIRCE 7 West Main Street New Kingstown PA 17072-0294 Defendant CIVIL ACTION -LAW Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Timothy J Peirce, who resides at 7 West Main Street, New Kingston, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180382218607 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $20,581.80 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $20,581.80, and the costs of this action. Buttat~il & A[ssoci~s,_P.Q. By: Derek~:"Blasker, Esq~i The law firm of Burton Neil & Associates, P.C. is a debt collector. 06/18/07 $20581.80 $20581.80 SITE:KC-CL CITI CARDS PO BOX 183066 TIMOTHY J PEIRCE COLl1MBUS, OH P.O. BOX 294 43218-3066 NEW KINGSTOWN PA 17072-0294000 Citi~ Dividend Platinum Select Card Account Number 5424 1803 8221 8607 c ti' Customer Servke• 1-800-568-5000 Total Credit Llne AvalWble Credit Llne Cash Advance limit Available Cash Limit New Balance BOX 6500 $17700 $0 $1700 $0 $20581.80 SIOUX FALLS, SD Statement/ Closing Date Amount Over Credit Llne Past Due Pureh/Adv Minimum Due Minimum Amount Due 57117 05/24/2007 $2881.80 $3348.38 $780.98 $20581.80 Sak Dete Post Date Reference Number Activity Since Last Statement Amount 5/24 5/24 5/24 5/24 Standard Purch LATE FEE - APR PAYMENT PAST DUE 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Standard Adv ADVANCES*FINANCE CHARGE*PERIODIC RATE 84 0000 Balance Transfer - Charged To Offer 6 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 Your late fee was based on your account balance as of the payment due date (05/18/07), which was $20,005.82. TM:CO-5000 ACID:KCB3104 07/04/07 17:59:59: C C'. I) ~ln~ 39.00 0000000000 398.92 0000000000 10.86 0000000000 127.20 0000000000 Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday. 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Account Summary Previous (+) Purc aces (-) Paymen s (+) FINANC (_) New Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $19 601.23 #404.59 $39.00 $0.00 $0 00 $0 00 $526.12 $10 86 $20,166.35 TOTAL 520,005.82 . . $39.00 $0.00 . $536.98 $415.45 $20,581.80 Da s This Blllfn Period: 30 Rate Summary Ba ante Su sec o Perio Ic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch Offer 6 $15,054.10 $4 800 26 0.08833%(D) 0 32.240% 32.240% ADVANCES , . .08833%(D) 32.240% 32.240% Standard Adv $409 81 . 0.08833%(D) 32.240% 32.240% EXHIBIT Verification I, ~~~ ~~ am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services on its behalf. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Signature Timothy J Peirce 5424180382218607 C~ -~ ~~ ~ ~~ ~ O 6' ~ v C'~ -v ~ ~ ~ _ - ~s t"i7 1 ~" t ,..,~ . ~ <~~ `7 - . l j ~ i 1~ f R ~ i '° SHERIFF'S RETURN - NOT FOUND CASE N0: 2007-04734 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PEIRCE TIMOTHY J 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 PEIRCE TIMOTHY J but was unable to locate Him in his bailiwick. !`~/ITRTT T TTTT f TT/1TTPT1"T He therefore returns the the within named DEFENDANT PEIRCE TIMOTHY J 7 WEST MAIN STREET NOT FOUND as to NEW KINGSTOWN, PA 17072-0294 DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge g~a~-/o ~ ~-~--. So answers .-~ ,,,,__---~.__:-v--~--„`_'" ~.- ~~,,/ 18.0 0 _- ~,- ~.... .-- 6 . 7 2 -=-= 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 39.72 BURTON NEIL 08/20/2007 Sworn and Subscribed to before me this day of A.D. Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.07-4734 CNIL TIMOTHY J PEIRCE Defendant CNIL ACTION -LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. The law firm of Burton Neil & Associates is a debt collector. C-12268 ~~i Ilil~l~l~ll~~l~~l N ~~I Attorney for Plaintiff C> ~ C. ~ ~ i ~ ~ ~~ ~ ~ _ Z ~~.~ "Q _ 1~T'S ~ Q ~ i' N t~'_ ~'..., ~ ~,.9 ty~+( ~ . ~ ~ ~ 1 . ~ ~y.~ v ~ V ~ ~ n ~ 1 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. TIMOTHY J PEIRCE 11 West Main Street Mechanicsburg PA 17055 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-4734 CIVIL CNII, ACTION -LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. B By: Derek C. Blasker, Est Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-12268 4 o ~, ~ ~ ~ ~: ~ ~ a ~ F ~ ~€~~ ~ y ,, ~ ~ ~ - ~ ~~ ~ w / , _ ~ t ~ """++~~ ~-'` r::.... ...j ` •• C.'1 Y =-~G . ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-04734 P •COMMONTWEALTH OF PENNSYLVANIA b COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PEIRCE _TIMOTHY J 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 unable to locate Him in his bailiwick !"~/'1TR TlT T TTTT C TT/1TTr'+L'~ but was He therefore returns the the within named DEFENDANT PEIRCE TIMOTHY J 7 WEST MAIN STREET NOT FOUND as to NEW KINGSTOWN, PA 17072-0294 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. CURRENT RESIDENT HAS BEEN THERE 15 YEARS. Sheriff's Costs: Docketing 18.00 Service 5.76 Not Found 5.00 Surcharge 10.00 lvlla/o 1 ~ 38.76 So answers: R . Thomas--~C~I i ne Sheriff of Cumberland County BURTON NEIL 10/09/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - NOT FOUND s CASE N0: 2007-04734 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PEIRCE TIMOTHY J 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 TT'~T Tf /11'~ TT11R /'1TVV T but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 11 WEST MAIN STREET MECHANICSBURG, PA 17055-0294 NOT FOUND as to GIVEN ADDRESS IS A BUSINESS AND NO ONE THERE HEARD OF DEFENDANT. Sheriff's Costs: Docketing 18.00 Service 9.60 Not Found 5.00 Surcharge 10.00 .00 i~/OyfG7~-, 42.60 PEIRCE TIMOTHY J So answers`. ~~ ---! _..-- ~'" ,~~ R. Thomas ine Sheriff of Cumb rland County BURTON NEIL 11/01/2007 Sworn and Subscribed to before me this day of A.D. Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. N0.202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4734 CIVIL TIMOTHY J PEIRCE Defendant Praecipe to Discontinue To the Prothonotary: CIVIL ACTION -LAW Kindly discontinue the above-captioned action without prejudice. Burto it Ass c' tes, P.C. By: Derek C. Blasker Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-12268 ~ ~ Q c~ -~ <~: ~! ~' a 7 -~, ~i r r r! ~ `~ ~ 1 : ~'~ ~ ~ t ° ~ '''> . ~ ~