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Home My WebLink About08-4182Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RONALD G VANART NO. 39 Stewart Place, Shippensburg PA 17257-1647 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-16212 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. T.cw- RONALD G VANART 39 Stewart Place, Shippensburg PA 17257-1647 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 Ronald G Vanart, who resides at 39 Stewart Place, Shippensburg, 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 Choice credit card with account number ending in 4414 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 $18,140.22 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 $18,140.22, and the costs of this action. Burton Neil & Associates, P.C. 1 By. war J. OBrien, , Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 05/12/08 $18140.22 $18140.22 SITE:KC-CL TM:CO-3000 ACI'D:KC60197 3*- +'arts> 05131f08 2014:28: CHOICE VISA RONALD G VANART PO BOX 183062 39 STEWART PL COLUMBUS, OH SHIPPENSBURG 43218-3062 PA 17257-1647000 Choice CHOICES Axourtt Numbet 4414 Omer Servke: 1-800-568-5000 'total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance BOX 6248 $17200 $0 $5800 $0 $18140.22 SIOUX FALLS, SO statement/ Amount Over Purch/Adv Mlnimurn Closi Date i Credit Line Past Out nimum Due Amount Out 57117 04/17/21 08 $940.22 $1856.07 434.84 Sale Date ;=Do, laslerence Number $18140.22 AstlrltY Since Last Statement Amount 4J17 Standard Purch LATE FEE - MAR PAYMENT PAST DUE 35.00 4J17 66 0000 O 70000000000 OVER CREDIT LIMIT FEE 35.00 62 0000 70000000000 4/17 PURCHASES*FINANCE CHARGE *PERIODIC RATE 429.84 84 0000 70000000040 Help is available! Please call the toll-free number shown above to learn about our special paygent 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. We will lower APRs from the default APR on all balances if you meet the terms of all Card Agreements you have with us for 12 billing periods in a row. We may lower these APRs sooner based on your record with us. Account Swnmary PURCHASES ADVANCES TOTAL Rate Summary 'URCHASES Standard Purch DVANCES Standard Adv EXHIBIT $17,640.38 $0.00 $70.00 00 0.00 $0 $429 84 Y910 $18,140.22 $17,640.38 . $70.00 0.00 10.00 $0.00 $429.84 $0.00 $18,140.22 Balance Subject to Brie is Da Nomina This Hint Period 30 Finance Charge Rate ANNUAL APR P E CEIYTAGE RATE $17,640.38 2.43667%(M) 29.240% 29.240% $0.00 0.08011%(F) 29.240% 29.240%, Verification Shauna Houghton 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 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 C-16212 Ronald G Vanart Account number ending in 4414 Q 71 N C.nJ \ y SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04182 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VANART RONALD R. Thomas Klin Sheriff or Deputy Sheriff, who being duly sworn acc rding to law, says, that he made a diligent search and inquiry for th within named DEFENDANT VANART RONALD but was unable to loca e Him in his bailiwick. He therefore returns the (,nMnT -ATATM f_ Mn T(V the within 39 STEWART PL] d DEFENDANT VANART RONALD G NOT FOUND , as to SHIPPENSBURG, PA 17257 GIVEN ADDRESS IS FRANKLIN COUNTY. Sheriff's Docketing Service Not Found Surcharge Sworn and me this s: So ans s: 18.00 .00 5.00 Thomas Kline 10.00 er' f of Cumberland County 33.00-- \P_URTON NEIL & ASSOCIATES 07/16/2008 'l23/06 t;C1 ribed to before day of , X. D. Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 : CUMBERLAND COUNTY, PENNSYLVANIA V. RONALD G VANART : NO. 08-4182 CIVIL Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton N94 s ciates, P.C. _V, % The law firm of Burton Neil & Associates is a debt collector. By: ?// ?'_n .1111 - w rie , Esquire Attorney for aintiff C-16212 C? 4? ;: "y c :. ? ? m°= w j... {l t,... ?. ?.. .. "..:. ?...:. G?"_ ""'"" Mf; i ..4,J t..? .?