The URL can be used to link to this page

Home My WebLink About08-7231Burton 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 Plaintiff V. NATHANIEL H HERBERT JR 395 Crossroad School Road Newville PA 17241-9572 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Q$ ` ?a3 I 1 V t ( -Term 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-14414 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. NATHANIEL H HERBERT JR 395 Crossroad School Road Newville PA 17241-9572 : NO. 0 t- 72 3 / aiq 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 Nathaniel H Herbert Jr, who resides at 395 Crossroad School Road, Newville, 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) Sears credit card with account number ending in 6082 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 $5,914.48 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 $5,914.48, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Gold MasterCarde call us at 1-M009-8488 Go to www.ssarsomd.com Write to us at PO Box 8922 The Lakes, NV 88601-0822 NATHANIEL H HERBERT JR Account Number.djffp?6082 Payment Due Date Page 1 of 1 02108!08 Your Account Summary your 8eus Choice Rewards Summary Billing Cycle Closing Date 01/11/08 Previous Reward Points Balance 0 Amount Over Credit Line $1,414.48 Reward Points Earned This Period 0 Amount Past Due $1,362.57 Adjustments to Reward Points 0 Current Mirtimunn Due $252.92 Reward Points Redeemed This Period 0 Total Minimum Due $3,029,97 Ending Reward Points Balance 0 Previous Balance vious a $5 721 58 56 Don't Forget! Your Sears Gold MasterCard card is accepted Pa Credits , $0 at millions of locations. You can earn points on your Purchases 8 Debits 00 0 6110ibls purchases everywhere MasterCard credit cards OtIrw Charges FINANCE CH R 9.0 0 $3 are accepted. A GES Account Balance $153,92 $5,914.48 Your Credit Summary Total Credit Line A il 4,500.00 ` ? I 1 1 r 1? 1 va able Credit Line $0.00 Cash Acess Line $900.00 Available Cash $0.00 Acthrity Sale Date Post Deb Description Amount 011011108 01/08/08 LATE PAYMENT FEE YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Averse Daily Rates 'Rats Varies Belswe Bal ance 39-OD Periodic Rate Peliodio 01,01110, FFINANCE U-Maft SEARS REGULAR EXTERNAL $924.86 $878.73 31.24%• .0&%%(D)• $23.32 REGULAR CASH ACCESS $4,989.62 $4.921.92 31.24X• .0856%(D)• $130.60 REGULAR $0.00 $0.00 31.24X.` .0856%(D)• $0.00 Days In Billing Period: 31 EKectlve ANNUAL PERCENTAGE RATE: 31.24% Minimum FINANCE CHARGE: $0.00 Sears Gold terCaw Account Number. 62 Ac csurlt Balance Dus Date Mini murem Due Arlroart Enaloasd F $5,914.48 02/08/08 63,029.97 000"" EX 07 A coal 1 1 Tx"M PYa 001 7 N I,UIIIII1111111111118111111181111111101111111loll@I loll 111111 NATHANIEL H HERBERT JR 395 CROSSROAD SCHOOL RD NEWVILLE PA 17241-9572 Plasse malts address corrections above. II11111II11111I1{IIIIIIIII[II1IIIIIIIIIIIII[I111IIIIIII11I11 Malts 0" payabb to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3062 100 52121071824306082 0591448 0302997 0000000 0714 EXHIBIT A- www"MAR Verification Pam Cline 1, 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 C-14414 Nathaniel H Herbert Jr Account number ending in 6082 1032 00 N c= 0 0 ETC. C -- III F= C(A 00 ,; t t' SHERIFF'S RETURN - REGULAR CASE NO: 2008-07231 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK -SOUTH DAKOTA NA VS HERBERT NATHANIEL H JR TIMOTHY R BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HERBERT NATHANIEL H JR the DEFENDANT , at 0014:29 HOURS, on the 22nd day of December-, 2008 at 395 CROSSROAD SCHOOL ROAD NEWVILLE, PA 17241-9572 NATHANIEL HERBERT JR DEFENDANT by handing to 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 yo So Answers: 18.00 8.10 00 10.00 .Thomas Kline ?0 0 36.10 12/23/2008 BURTON NEIL & ASSOCIATES Sworn and Subscibed to before me this By day D puty Sheriff of A. D. ~~ Tfi~~ ~T~~OTA~'r' 1010 OCT _& P1=~ 3~ 17 rE.1~3~E~LA~~~ COUNT;, ,~'~.~~~'zSY~ ~~A~'~°~~, Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. N0.203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. NATHANIEL H HERBERT JR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.08-7231 CIVIL TERM CIVIL ACTION -LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Assoc' t .C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-14414