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Home My WebLink About08-0710Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. MARK E ALLEN NO. 3955 Sullivan Street Mechanicsburg PA 17050-2175 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-13258 A Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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 Plaintiff V. MARK E ALLEN 3955 Sullivan Street Mechanicsburg PA 17050-2175 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OF- 710 Ctc 7`.? : 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 Mark E Allen, who resides at 3955 Sullivan Street, Mechanicsburg, 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 5424180154874157 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 Defendant 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 $15,667.33 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 $15,667.33, and the costs of this action. eil 4 A06ciates, P.C. Y e stein, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt 11/06/07 $15667.33 $15667.33 SITE:KC-CL : ?8t :=:8ff€:?tlF?E=: 1£Yf :9lEt 123 € =r = f6iii i411f_= SfES6= CITI CARDS PO BOX 183059 MARK E ALLEN COLUMBUS, OH 3955 SULLIVAN STREET 43218-3059 MECHANICSBURG PA 17050-2175000 TM:CO-5000 ACID:KCB3104 12/06/07 00:27:48: ??,ISZti?d Citi Simplicity- Rewards Card Account Number 5424 1801 5487 4157 Customer Servke. 1-866-696-5673. BOX 6500 SIOUX FALLS, SD Total Credit Line Available Credit Line $14340 $0 Statement/ Amount Over Closin Date Credit Line 0/12/207 $1327.33 C tla Cash Advance Limit Available Cash Limit New Balance $9100 $0 $15667.33 Purch/Adv Minimum SaM Dab Poet Dab Cabgav Actift Sbrce Last staMneM - Amount - Standard Purch 10112 LATE FEE WAIVED - $ 39.00 0.00 66 0000 0000000000 10/12 OVER CREDIT LIMIT FEE 39.00 62 0000 0000000000 10112 PURCHASES*FINANCE CHARGE*PERIODIC RATE 389.03 84 0000 0000000000 We are glad to inform you that your late fee has been waived. We'll waive late fees as Iong as you've made a purchase or cash advance in the same billing period that the payment is due. Please understand that balance transfers do not qualify. While we know that things may get in the way of paying on time, we recognize your desire to maintain a good credit history. Your APRs may increase if your payment is late. A late payment may negatively affect both your account terms and your credit report. Thank you for choosing the Citi Simplicity(SM) Card. 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 (+) Purchases (-) Payments (+) NA (=) New Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $15,239.30 00 $0 $39.00 $0 00 0.00 1 $389.03 $15,667.33 TOTAL . $15,239.30 . $39.00 0.00 0.00 $0.00 $389.03 $0.00 $15,667.33 Days This Billing Period: 29 Rate Summary Balance Subject to Periodic Nomina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $15,426.29 0.08696%(D) EXHIBIT, 31 740% 31 740% ADVANCES . . Standard Adv $0.00 0.08696%(D) 31.740% 31.740% 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 unsworn falsification to the authorities. Signature Shauna Houghton Mark E Allen 5424180154874157 X-n D C, t-0 J ? rv SHERIFF'S RETURN - REGULAR CASE NO: 2008-00710 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS ALLEN MARK E 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 ALLEN MARK E the DEFENDANT at 2040:00 HOURS, on the 6th day of Februarys , 2008 at 3955 SULLIVAN STREET MECHANICSBURG, PA 17050-2175 by handing to MARK ALLEN 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 13.44 Affidavit .00 Surcharge 10.00 .00 l?°?/ a Y 41 . 4 4 Sworn and Subscibed to before me this day So Answers: ,? R. Thomas Kline 02/07/2008 BURTON NEIL & ASSOCIATES By: I Deputy Sheriff of A. D. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A Plaintiff V. MARK E ALLEN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-710 Civil Team CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without ppjigdi Burton Neil & By: Yale P.C. Weinstein, Esquire for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-13258 ?....? f -'? ??., ?-°s ?_.-? ? k?-' i ;? ?=" ? .. ;• ?? ° ,Y , r . ?,N.'