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Home My WebLink About09-1066Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 7930 N.W. 110th Street Kansas City MO 64153 Plaintiff V. SAMUEL J CHAMBERS 105 Brook Meadow Drive Mechanicsburg PA 17050-3135 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. di - 10(P& &""AT*J'M 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-19404 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 7930 N.W. 110th Street Kansas City MO 64153 Plaintiff V. SAMUEL J CHAMBERS 105 Brook Meadow Drive Mechanicsburg PA 17050-3135 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 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 Samuel J Chambers, who resides at 105 Brook Meadow Drive, 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(n) Sears credit card with account number ending in 6656 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 $1,707.61 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 $1,707.61, and the costs of this action. 'Derek C. Busker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Cardo Call us at 1-800-917-7700 Go to www.seemeard.com Write to us at PO Box 6283 Sioux Falls, SD 57117-6283 SAMUEL J CHAMBERS Payment Due Date Account Number: lANIONOW656 Page 1 of 2 10/31/08 Your Account Summary Billing Cycle Closing Date 10/03/08 Amount Over Credit Line $307.61 You're in charge. Amount Past Due $463.87 We may have the payment solution just for you, Total Minimum Due $555.09 and you're in control of how you do R. Previous Balance $1,634.39 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $38.22 Account Balance $1,707.61 Your Credit Summary Total Credit Line $1,400.00 Total Credit Available $0.00 Manage your account online OR by phone • You can quiddy go online, or cat to get personal assistance • See when a payment is due or posted • Select from affordable payment options to most your needs that may: - Lower your annuel percentage rate - Lower your minimum payment Contact us today-we can help. Activity Sale Date Post Date Description Amount 09/30/08 09/30108 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $1,634.39, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE iMMEDIATELY. Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Card" Account Number: 6656 Payment Total Account Balance Due Date Minimum Due Amount Enclosed -1 [ $1,707.61 10/31!08 $555.09 0079034 EX 01 A 08277 1 TRS006 FXG 001 7 N IIIIIII II III IIIIIIIII II1111II II III IIIIIIIIIIIIIII IIIIIIIIII III IIII IIIIIIIIIIII III III Itillllllllllllll 111 1111/// l1111IIIIIIII Make check payable to SAMUEL J CHAMBERS SEARS CREDIT CARDS 105 BROOK MEADOW DR PO BOX 183081 MECHANICSBURG PA 17050-3135 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 5049941373186656 0170761 0055509 0000000 0117 6_41K Exhibit /? Sears Card" SAMUEL J CHAMBERS Account Number: XXXX XXXX XXXX 6656 Page 2 of 2 79034 Call us at 1-800-917-7700 Go to www.seemcard.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 Payment Due Date 10/31/08 Average Corresponding Periodic Rate Periodic Deily ANNUAL D--Day FINANCE Rates 'Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $1,707.61 $1,657.28 27.15%* .0744%(D)* $38.22 EXTERNAL REGULAR $0.00 $0.00 27.15%* .0744%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 27.15%* .0744%(D)* $0.00 Days in Billing Period: 31 Effective ANNUAL PERCENTAG E RATE: 27.15% Minimum FINANCE CHARGE: $0.00 Cardmember News The Sale Date is the Transaction Date. Your Total Minimum Payment on any Account Balance over $10 will no longer include the total amount of balance transfer and cash advance transaction fees or applicable insurance charges or credit protection fees assessed that billing period. Remember, you can pay these fees (and any other amounts owed on your account) at any time. Verification I, Pam Cline 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 C-19404 Samuel J Chambers Account number ending in 6656 1031 9.> c D 6) SHERIFF'S RETURN - NOT SERVED CASE NO: 2009-01066 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS CHAMBERS SAMUEL J R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: CHAMBERS SAMUEL J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT , CHAMBERS SAMUEL J 105 BROOK MEADOW DRIVE MECHANICSBURG, PA 17050-3135 PER FAX RECEIVED FROM ATTORNEY, SERVICE WAS STOPPED. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 Not Served 5.00 33.00 So answers: R. Thomas Kline Sheriff of Cumberland County BURTON NEIL & ASSOCIATES 02/25/2009 Sworn and Subscribed to before me this day of A. D. .7 `ti t _3 i i" 9z E]j HE