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Home My WebLink About03-5803BURTON 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 MELISSA A JACOBS 817 ANTHONY DRIVE MECHANICSBURG, 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 LAV~YER AT ONCE. IF YOU DO NOT HAVE A LAVCYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 Association 2 Liberty Avenue, Carlisle, PA 17013 717-249-3166 10007.034.5373 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 Pla/miff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MELISSA A JACOBS 817 ANTHONY DRIVE MECHANICSBURG, PENNSYLVANIA Defendant 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 MELISSA A JACOBS, who resides at 817 ANTHONY DRIVE MECHANICSBURG, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 5424180446807510 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 $10,109.09. 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 pla'tariff upon defendant to pay the sum of $10,109.09, 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 $1,920.73. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $10,109.09, attorneys fees in the sum of $1,920.73 and the costs of this action. BURTON/EIL & AS_SOCIATES, (By: ~ '~B"~ofi Neil, Esquire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. 0 0 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. MELISSA A JACOBS 5424180446807510 10007.034.5373 BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK sOUTH DAKOTA N.A. 701 East 60t~ Street North Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND coUNTY, PENNSYLVANIA VS. MELISSA A. JACOBS Defendant NO. 03-5803 CIVIL ACTION - LAW p~RAECI~E TO DISCONTINUE. TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. /~3Y: ~B/u~i~, Esquire - k~ ~A-~t~ey for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-05803 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLP~ND CITIBANK SOUTH DAKOTA NA VS JACOBS MELISSA A ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICB JACOBS MELISSA A DEFENDANT at 1900:00 HOURS, at 817 ANTHONY DRIVE MECHA_NICSBURG, PA 17050 PATRICIA JACOBS, MOTHER a true and attested copy of was served upon the on the 7th day of November , 2003 by handing to COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me this /F~- day of o ~ A.D. thonotary ' ' So Answers: R. Thomas Kline 1 /10/2003 BURTON NEIL By: ) Deputy Sheriff