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HomeMy WebLinkAbout07-7670Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JEREMY A HARING NO.? 627 Brisbain Lane, Enola PA 17025-1557 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-13041 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JEREMY A HARING NO. 627 Brisbain Lane, Enola PA 17025-1557 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 Jeremy A Haring, who resides at 627 Brisbain Lane, Enola, 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(n) AT&T Universal credit card with account number 5491130304434228 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 $9,295.82 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 $9,295.82, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquir Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. aw AT&T Universal Rewards Card Charter Member JEREMY A HARING Account 6491 1303 0443 4228 Calling Card + PIN June 14 - July 13, 2007 Quick Reference Minimum Payment Due .............................. 936 $1 46 , . Due Date* ................................................... August 7 2007 " Payment must be received by 5:00 Pm local time on the , Payment due date. Amount Past Due .......................................... Amount Over Limit ..... $107612 f ....................................... ........ 496.82 Credit Line .............. --....... ........................ ........ Available Credit .... $8,800.00 ................................................ Cash Advance Limit ......................................... ......... $0.00 $2 000 00 Available Cash Advance Limit ......................... .... , . ........... $0.00 Account Summary Previous Ralan e P 8 gad Rn avmentc and A ustmenic MasterCard 0 00 Total AT&T Services 0 nn New Balance $9,295.82 Note: Detailed activity starts on page 3. AT&T Universal Card Page 1 of 4 How To Reach Us Visit: www.universalcard.com Customer Service: 1-800-423-4343 or write Cardmember Services, PO Box 44167 I Jacksonville, FL 32231-4167 }} Your late fee was based on your account 1 balance as of the payment due date (07/09/07), which was $8,984.30. Your account balance is over the credit line. In order to continue earning ThankYou Points with your card, you must bring your account balance under the credit line now. If you have not already done so, please pay the Minimum Payment Due. Please see enclosed privacy notice for Important information, date paid amount paid check # Cltl' AT&T and the AT&T globe design are trademarks of AT&T Knowledge Ventures, licensed to citigroup Inc. Please follow Payment Instructions outlined In the -Important Instructions for Making Payments" section of the statement. 05491130304434228929582999995817 Vow Account Number 5491 1303 0443 4228 Please Enter Armant of Payment Enclosed Payment Dw D-M Yaw Total Helena Minimum i'o- $9295.8211 5.82 $1936.46 SOIS MC 20 I 2 AR7051860 II IIII ?1/elllllll llll llllllllll llellll,III/I, I11'IIII //IIIIIII I1?,/'III'II III II IIIIIIe It IIIII IIIIIIIIII III,IIIIIII JEREMY A HARING AT&T UNIVERSAL CARD 627 BRISBAIN LN. PO BOX 183059 ENOLA PA 17025-1557 COLUMBUS, OH 43218-3059 'II?IIfI'?IIIIn'nli?'?nlt'ell ilia 'IfII1lI1IlIeIIII'IIIIeII EXHIBIT A ' JEREMY A,HARING Account 5491 1303 0443 4228 June 14 - July 13, 2007 AT&T Universal Card Page 2 of 4 In the return envelope, please: I Make your check payable to AT&T Universal Card. 2 Enclose your check or money order. Include your account number and name on the front of your check or money order. Please, no cash or foreign currency. 3 Enclose your payment coupon. Do not staple or tape It to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. j JEREMY A HARING Account 5491 1303 0443 4228 June 14 - July 13, 2007 AT&T Universal Card Page 3 of 4 AT&T UNIVERSAL MASTERCARD ACTIVITY Purchases ............................................................................................................................................................ Cash Advances and Checks ................................................................................................................................233.52 . 0.00 Fees ................................... 78.00 Total MasterCard Activi ........' .............................................. ty ..................................................................................................................................5311.52 PURCHASES Total MasterCard Purchases ................................................ $233.52 Standard Purch 07/1 p Itir ueSFC*EINANCE CHARGE PERl0 i Total Standard Purch 233 S? $233.52 CASH ADVANCES Cash Advance Limit ....................................... $2,000.00' 'This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Nominal Periodic Days in x Oiling Balance Periodic Transaction ANNUAL x Subject to e EWA APR Rate Period + Fe% Finance Charge FT"ENTAQF CHA PURCHASES M RM Standard Purch 32.310% CASH ADVANCES .08852%(D) x 29 x $9,096.53 = $233.52 + $0.00 32.310% Standard Adv 32.310% .08852%(D) x 29 x $0.00 = $0.00 + in nn Total FINANCE CHARGE = $233.52 FEES Standard Purch Trans post na<r.c.d;.... 07/1 ATF FFF O°'°""} 0711' U PAYMENT PACT DUE DV R racnTT LIMIT Frr ?Q nn Total Fees -?.00 $78.00 AT&T SERVICES SUMMARY AT&T Universal Calling Card Calls ................................................................................................................... $0.00 REWARDS ""AT&T Universal Card ThankYou Points Summary°"' CiThankYou90 Base Points Earned ................... Activity This Period ....................................................................... Total ThankYou(sm) Points Earned This Period ................ "..."".."""""""""""" 0 Points Transferred to Your ThankYou Network Member Account ............................................................................ 0 Total Base Points Earned ........................... Year to Date Activity ......................................................................................................... 8,402 Total ThankYou Points Earned ...................... ....................................................................................................... 8,402 Go to thankyounetwork.com to review your ThankYou Point balance and redeem! Bonus Points may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. ` JEREMY A HARING Account 5491 1303 0443 4228 AT&T Universal Card June 14 - July 13, 2007 Page 4 of 4 Don't forget to use your AT&T Universal Rewards Card which gives you five ThankYou Points for every dollar spent on certain AT&T consumer products and/or services as well as purchases made at supermarkets, drugstores, and gas stations. i Verification I, Shauna Houghton 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 unswom falsification to the authorities. Signature Shauna Houghton Jeremy A Haring 5491130304434228 L. tAi r C.) f?x ws 4 ti I V 1J !y+ T© 7o ir> (Y9 --G SHERIFF'S RETURN - REGULAR CASE NO: 2007-07670 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS HARING JEREMY A VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HARING JEREMY A the DEFENDANT , at 1705:00 HOURS, on the 31st day of December-, 2007 at 627 BRISBAIN LANE ENOLA, PA 17025-1557 by handing to KELLY SMELTZ, SISTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 .00 41.44 Sworn and Subscibed to before me this day of , So Answers: t R. Thomas Kline 01/02/2008 BURTON NEIL By: Deputy Sherif A. D. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JEREMY A HARING Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-7670 Civil Term CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-13041