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Home My WebLink About07-7342A 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff No: t7- r13ya Civil?trm vs. COMPLAINT IN CIVIL ACTION ROBERT M HARKINS Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06213879 C J Pit SJS ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No ROBERT M HARKINS Defendant COMPLAINT AND NOTICE TO DEFEND 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 twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims 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. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I COMPLAINT 1. Plaintiff is CITIBANK (SOUTH DAKOTA) NA with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota, 57117. 2. Defendant is adult individual(s) residing at the address listed below: ROBERT M HARKINS 1716 MAIN ST LISBURN, PA 17055 3. Plaintiff is a national banking association, engaged in consumer lending through the issuance of credit cards. 4. Pursuant to Defendant's request, Plaintiff furnished to the Defendant a credit card account (hereinafter account) bearing account number 5424180486937896 . 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. a 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $1202.42 , which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , ROBERT M HARKINS , INDIVIDUALLY , in the amount of $1202.42 with continuing interest thereon at the rate of 6.000W per annum from date of judgment plus costs. James CFE rodt,42524 WELT ERG & REIS CO., L.P.A. 436 Sev enue, Suite 2718 Pi sbu 15219 (4 2) F 2-338-7130 0 21 79 C J Pit SJS -09/10/07 $1202.42 $1202.42 SITE:KC-CL TM:CO-5000 ACID:KCB3104 08/21/07 21:27:38: CITI CARDS ROBERT M HARKINS PO BOX 183061 ATTNY ACCOUNT-CODE=LE14 COLUMBUS, 1 LEWISBERRY 43218-3061 PA 17339-0318000 EXHIBIT Citi" Platinum Select" Card Account Number 5424 1804 8693 7896 Customer Service. 1-800-950-5114 Total Credit Line Available Credit Line BOX 6500 $1820 $ 0 SIOUX FALLS. SD Statement/ Closing Date Amount Over Credlt Line 57117 08/16/2007 X0.00 Sale Post Date Reference Number An yet 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 Balan (+) Purchases (-) Payments +) FINAWL (_) New PURCHASES ce $1 202 42 & Advances & Credits CHARGE Balance ADVANCES TOTAL , . $0.00 $1 202 42 0.00 0.00 1 0. 00 0.00 0 #1,202.42 0.00 00 , . 0.00 DO 0.00 . 0.00 $1,20202.42 Rate Summary Balance Subject t o Periodic Days This Billing Period: 29 Nominal PURCH S Finance Charge Rate ANNUAL APR DFOPCU tart n??? A ES Standard Purch ADVANCES Standard Adv Aeth,it. Ca.- I _f rc\ ' e citl Cash Advance Limit Available Cash Limit New Balance $310 $0 $1202.42 Past Due $402 60 Purch/Adv MI imum Due 1 Minimum Amount Due . 20.00 =1202.42 $0.00 0.08833%(D) 32.240% 32.240% $0.00 0.08833%(D) 32.240% 32.240% Verification Shaun* Hou On 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 including but not primarily limited to collecting delinquent debt. 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. S'houne MougWan ROBERT M HARKINS 5424180486937896 WWR#06213879 nottieu aH i: ,.si2 nompiJOH s-.eA8 l00 ? b l c) C7 ir`7 _-4 - _., r --t cr) -c a SHERIFF'S RETURN - REGULAR CASE NO: 2007-07342 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS HARKINS ROBERT M NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HARKINS ROBERT M the DEFENDANT , at 1420:00 HOURS, on the 27th day of December-, 2007 at 1716 MAIN STREET MECHANICSBURG, PA 17055 by handing to ROBERT M HARKINS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .oo 42.40 Sworn and Subscibed to before me this day So Answers: r R. Thomas Kline 12/28/2007 WELTMAN WEINBERG REIS By' Deputy Sheriff of A. D. w ,%b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) N.A. Plaintiff vs. No. 07-7342 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END ROBERT M HARKINS Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06213879 .0 ; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. Civil Action No. 07-7342 CIVIL TERM ROBERT M HARKINS Defendants PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End the above captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James . armbrodt, Esquire PA I. #42 24 WE MA , WEINBERG & REIS CO., L.P.A. 271 Kopp s Building 4 Seven Avenue ittsbur , PA 15219 (412) 4-7955 W #06213879 Sworn to and s i ed 1? Before me the Day of rch, 008 COMMONWEALTH OF PENN$YLVANIA N ARY PU C Notarial Seal Wayne A. Jones, Notary Public City Of Pittsburgh, Allegheny County My Commi w Expre ; June 29, 2010 Member, Penn: ylvania Asscc:ation of Notaries .? ?= ? ..-? '? ?- _.? 4 '?"' Y?: r y ?'? _ ? ?"3;? r ?? ?? .? ?.