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Home My WebLink About08-3219Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. R BRENT THOMPSON 550 Boxwood Ln, Carlisle PA 17015 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D$ - W19 3Vtt -[&h 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-14177 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. R BRENT THOMPSON 550 Boxwood Lane, Carlisle PA 17015 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. o F- 3 2 ) 7 Cu~:?l TZ., 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 R Brent Thompson, who resides at 550 Boxwood Lane, Carlisle, 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 5398570050962860 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 $1,753.04 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 $1,753.04, and the costs of this action. Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. at&t AT&T Universal Card R B THOMPSON Account 5398 5700 5096 2860 Calling Card + PIN November 12 - December 12, 2007 Quick Reference Minimum Payment Due ...................................... $1,753.04 Due Date• ................................................. January 7, 2008 "Payment must be received by 5:00 pm local time on the payment due data. Amount Past Due ..................................................:222.67 Credit Line ............................................................. $1,800.00 Available Credit ............................................................ 0.00 Cash Advance Limit ..................................................... 0.00 Available Cash Advance Limit .................................... 0.00 Account Summary Previous Ralance 1,709 12 moments and Adjustments 0 00 M4.02 A Activity 43.1 Total AT&T Services 0.00 New Balance $1,753.04 Note: Detailed activity starts on page 3. date paid amount paid check # atl' 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. Yaw 05398570050962860175304999995919 F53977Account85700 Number5096 2860 Please Enter Anwant of Payment Enclosed Payrnott Due Date Your Total Balance Miniature AMMM Due JAN 07 2008 1753.0411 $1753.04 $ 2135 MC 32 A I AR7052026 I„elll,r.lll?e?r,ell,lei,?Irrl„Il.ll,,,,,ell?l.lrll..,,.ll?l Irleelr,Il???lrl?relllrelr„lel?l.l??ll.,,l?elrlrl?l R B THOMPSON AT&T UNIVERSAL CARD 550 BOXWOOD LN P.O. BOX 18256 CARLISLE PA 17015-4301 COLUMBUS, OH 43218-2564 IIJeLJILtIIItItIIILIrLIJILJIIJ11JeIJrIIIJLIrelll AT&T Universal Card Page 1 of 3 How To Reach Us Visit: www.universaicard.com Customer Service: 1-800-423-4343 or write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. EXHIBIT_ /?- R THOMPS Account 5398 57000 0 5096 2860 AT&T Universal Card November 12 - December 12, 2007 Page 2of3 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. 'R B'THOMPSON Account 5398 5700 5096 2860 November 12 - December 12, 2007 AT&T Universal Card Page 3 of 3 AT&T UNIVERSAL MASTERCARD ACTIVITY Purchases .................................................................................................................................................................14.12 Cash Advances and Checks .................................................................................................................................... 0.00 Fees .......................................................................................................................................................................... 29.00 Total MasterCard Activity ................................................................................................................................... $43.12 PURCHASES Total MasterCard Purchases ................................................. $14.12 Standard Purch lL n L P R HAS S*FTNANIF CHARGF*PFR70 2-41 Total Standard Purch $2.41 Purch/CashAdv 12/12/2003 Trans Pogt D riotion Amount 12112 -;j P R-HA S*FTNeurr rueor_r*ornrn 11.71 Total Purch/CashAdv 12/12/2003 $11.71 CASH ADVANCES Cash Advance Limit ............................................... $0.00' `This represents a portion of your total credit line. FINANCE CHARGE INFORMATION Days In Balance Periodic Transaction ANNUAL Nominal Periodic x Billing x Subject to = )"NANCr + Fee/j?j; PERC E APR Rate Period Finance Charge CHAM CBfAM ads PURCHASES . Standard Purch 10.000% .02740%(D) x 30 x $292.73 = $2.41 + $0.00 10.000% Purch/CashAdv thru 12/12/03 10.000% .02740%(D) x 30 x $1,424.00 = $11.71 + $0.00 10.000°/ CASH ADVANCES Standard Adv 10.000% .02740%(D) x 30 x $0.00 = $0.00 + $0.00 10.000 % Total FINANCE CHARGE _ $14.12 FEES Standard Purch Trans Post Description Amo mt 12112 lAT F - NOV PAYM NT PAST DUE 29,00 Total Fees $29.00 AT&T SERVICES SUMMARY AT&T Universal Calling Card Calls ................................................................................................................... $0.00 Verification I Kris Dietz 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. i Signature R Brent Thompson 5398570050962860 7Q -6y, r? ^; c7 -711 i ? y r..r.r ?' Cr) ..L7 c SHERIFF'S RETURN - REGULAR CASE NO: 2008-03219 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS THOMPSON R BRENT WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THOMPSON R BRENT the DEFENDANT , at 0018:49 HOURS, on the 16th day of June 2008 at 550 BOXWOOD LANF CARLISLE, PA 17015 by handing to BRENT THOMPSON DEFENDANT 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 Service Affidavit Surcharge 4// So Answers: R. Thomas Kline 06/17/2008 BURTON NEIL & ASSOC By: _ Deputy Sheriff 18.00 5.00 .00 10.00 .00 33.00 Sworn and Subscibed to before me this day of , A. D. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. R BRENT THOMPSON 550 Boxwood Lane Carlisle PA 17015 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3219-CIVIL TERM CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $1,753.04 $1,753.04 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDE PA.R.CIV.P. 236 Pro rothonot Burton Neil & Associates, P.C. By t J. Suttell, Esquire Attorney for Plaintiff I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-14177 C-I4177 CI TIBANK (SOUTH DAKOTA), N.A. Plaintiff V. R BRENT THOMPSON Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3219-CIVIL TERM CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: R Brent Thompson 550 Boxwood Lane Carlisle PA 17015 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be, entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office 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 DATE OF NOTICE: July 9, 2008 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Z/ t 7 -- Brit J. Su , Esquire Attorney for Plaintiff Identification No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 rZ, -k S? Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. R BRENT THOMPSON Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3219-CIVIL TERM CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on rothonot By: Deputy If you have any questions concerning the above, please contact: Brit J. Suttell, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. Burton Neil & Associates, P.C. By Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. R BRENT THOMPSON Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3219-CIVIL TERM CIVIL ACTION - LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied on payment of your costs only. Burton Neil & Associates, P.C. By B t J. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-14177 cn cl