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Home My WebLink About09-3586Burton 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 R BRENT THOMPSON AKA BRENT THOMPSON :NO. (A - 358(0 C;-J'Lt-WrM 550 Boxwood Lane, Carlisle PA 17015-4301 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-21594 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. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. O fi- 3s g-1 C( 7 ? R BRENT THOMPSON AKA BRENT THOMPSON 550 Boxwood Lane, Carlisle PA 17015-4301 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 R Brent Thompson aka 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) Sears credit card with account number ending in 2468 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 $2,256.02 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 $2,256.02, and the costs of this action. Burton Neil & Associates, P.C. By: . Suttell, Es uire ABrirney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Card' mber R Account Number Account Page 1 of 2 Your Account Summa Billing Cycle Closing Date 12/29/08 Amount Over Credit Line $336.02 Amount Past Due $658.97 Total Minimum Due $777.33 Previous Balance $2,463.66 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $57.36 Account Balance $2,556.02 Your Credit Summary Total Credit Line $2,220.00 Total Credit Available $0.00 Payment Due Date 01/26/09 You're in charge. We may have the payment solution just for you, and you're In control of how you do ft. Manage your account online OR by phone • YW can quickly go online, or cat to get personal assistance • See payment is due or posted • Select *am etiordable payment options to meet your deeds that "'??- Lower your annual percentage rate - Gower your minin um payment Contact us today-we can help. Activity Sale Date Post Date Description Amount 12124/08 12124/08 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,463.66, 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 Car& Account Number: ¦ Payment Total Account Balance Due Date Minimum Due Amount Enclosed L $2,556.02 01126/0 L$777.33 0000000 EX 19 08384 1 TR8006 FXO 001 7 ¦ IIIIIIIIIIIIIIII IIIIIIIIIIIIItI IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII R BRENT THOMPSON 550 BOXWOOD LN CARLISLE PA 17015-4301 IIIIIIIIIII III IIIIIII III II IIIIIIII IIIII IIIIIII I11It 111IIIIIII? Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 35.00 Please make address changes on reverse side. 200 5049948101762468 0255602 0077733 0000000 1919 EXH18tY ------t""' Call us at 1-800-917-7700 Go to www.saerw.wd.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 r Sears Card' R BRENT THOMPSON Account Number: XXXX XXXX XXXX 3466 Page 2 of 2 0 Call us at 1-800.917-7700 Go to www."orecord.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 Payment Due Date 01/26/09 Average Corresponding Periodic Rate Periodic RateS * Deily ANNUAL D-Day FINANCE Rate Varies Balance Balance PERCENTAGERATE M--Month CHARGE SEARS REGULAR $2,556.02 $2,497.66 25.40%* .0696%(D)* $57.36 EXTERNAL REGULAR $0.00 $0.00 25.40%* .0696%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 25.40%* .0696%(D)* $0.00 Days in, Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 25.40% Minimum FINANCE CHARGE: $0.00 Cardmember News The Sale Date is the Transaction Date. The "Effective ANNUAL PERCENTAGE RATE" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "Effective ANNUAL PERCENTAGE RATE" is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. i. . Verification Tiena ReYnOlds 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-21594 R Brent Thompson Account number ending in 2468 1031 0 d? *-M.5o fro Ar" C054'T4q R:* -Utaoo 5 Sheriffs Office of Cumberland County R Thomas Kline ?xott' of "'autbirj7 Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OMC.E '?Et"EPIrF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/08/2009 12:33 PM - Bryan Ward, Sergeant, who being duly sworn according to law, states that on une 8, 2009 at 1233 hours, he served a true copy of the within Complaint and Notice, upon the within na ed defendant, to wit: R. Brent Thompson, by making known unto himself personally, defendant at 1 Cou house Square, Room 303 Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the sam time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 SO ANSWERS, June 08, 2009 2009-3586 Citibank V R. Brent Thompson '-R THOMAS KLINE, S R IFF FILEID-OHRCE OF THE PiRM-H",iIK)TAPY 2009 JUN I I PM 2: Q 4 ?S?TJ?c?.?ii.-?•?,{YY vtp rS?JI?iT .?