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Home My WebLink About09-1252Burton 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT B JACOBS NO. (A- I0150? 01vit (erM 25 N Penn Street, Shippensburg PA 17257-1309 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-18861 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 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT B JACOBS NO. 25 N Penn Street, Shippensburg PA 17257-1309 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 Robert B Jacobs, who resides at 25 N Penn Street, 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 credit card with account number ending in 7583 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 $3,582.28 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 $3,582.28, and the costs of this action. Burton Neil & Associates, P.C. t By: ' Brit . Suttell, Esquire Att rney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 10/14/08 $3582.28 $3582.28 SITE:KC-CL TM:C0-5000 ACID:KCB0201 I?aar a`a# 11/01/08 20:32:47: ROBERT B JACOBS 25 N PENN STREET SHIPPENSBURG 17257-1309000 PA CITI CARDS PO BOX 183063 COLUMBUS, OH 43218-3063 C? r?1 Citi® Platinum Select" Card C ti0 Y of A 7583 ? Customer SmIce: 1-800-950-5114 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit $2700 New Balance $0 $900 $0 BOX 6500 $3582.28 Statement/ Amount Over Pureh/Adv SIOUX FALLS, SO Closin Date Credit Line Past Due inimum Due 57 7 09 2 Minimum Amount Due 11 /19/ 08 $882.28 $924.15 119.31 $3582.28 Sale Date Post Date Reference Number Activity Since Last statement Amount Standard Purch 9/19 * RCH FINANCE CHARGE *PERIODIC *PERIODIC RATE 15.25 0000 70000000000 84 Purch/Adv Thru 07/20/2007 9/19 RCH 000*FINANCE CHARGE *PERIODIC *PERIODIC RATE 69.06 70000000000 84 0 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 ive us the t it t , . g oppor un y o assist you. 17XHIBI Account Summary Previous {+) Balance & Purchases Payments Advances & Credits +) FINANCE CHARGE (=) New Balance PURCHASES ADVANCES $3,497.97 $0 00 0.00 0.00 0 00 1 $84.31 $3,582.28 TOTAL . $3,497.97 . 0.00 0.00 10.00 $0.00 $84.31 $0.00 $3,582.28 Days This Billing Period: 30 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch Purch/Adv $639.93 0.07942%(D) 28.990% 28,990% thru 07/20/2007 $2,898.62 0.07942%(D) 28 990% 28 990% ADVANCES . . Standard Adv $0.00 0.07942%(D) 28.990% 28.990% f• Verification Shauna Houghton C-18861 Robert B Jacobs Account number ending in 7583 1000 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 R Zz? i T Sheriffs Office of Cumberland County R Thomas Kline $ jr ?of clutib". Edward L Schorpp Sheri' Solicitor Ronny R Anderson Jody S Smith C h i e f D e p u t y OFFICE O F T wE S.?ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/19/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert B. Jacobs, but was to unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Robert B. Jacobs. A new address for the defendant is 377 Florida Avenue, Shenandoah, Pennsylvania 17976. SHERIFF COST: $69.00 (PAID) SO ANSWERS, March 19, 2009 R THOMAS KLINE, SHERIFF 2009-1252 Civil Term Citibank (South Dakota) VS Robert B. Jacobs C"? r ? ??, ? 5 :? t-r- ??r -?' 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1252 CIVIL TERM ROBERT B JACOBS Defendant CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. B on N '1 & oci tes ,P.C. By: t Brit J. uttell, Esquire Atto ey for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-18861 RED-UFra ? 7HE PFIOT?", MARY 2009 APR -2 PM E : 06 e'