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Home My WebLink About09-3588 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 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DAVID M REED : NO. OQ _ 3SES 0,1v;(_TirA 6545 Molly Pitcher Hwy, Shippensburg PA 17257 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-21102 y 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 V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O 9- 351%8° T1?,,., DAVID M REED 6545 Molly Pitcher Hwy Shippensburg PA 17257-9373 Defendant : 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 David M Reed, who resides at 6545 Molly Pitcher Hwy, 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(n) credit card with account number ending in 2920 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 $3,650.01 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 $3,650.01, 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 Card® DAVID M REED Account Number: SP4100100 2920 Page 1 of 2 Your Account Summa Billing Cycle Closing Date 12129108 Amount Over Credit Line $510.01 Amount Past Due $945.46 Total Minimum Due $1,099.65 Previous Balance $3,532.82 Payments & Credits $0.00 Purchases & Debits $0,00 Other Charges $35.00 Total FINANCE CHARGES $82.19 Account Balance $3,650.01 Your Credit Summary Total Credit Line $3,140.00 Total Credit Available $0,00 Can us at 1-800-917-7700 Go to www.wersowd.com Write to us at PO Box 8283 Sioux Fella, SD 57117-8283 Payment Due Date 01/26/09 Activity Sale Date Post Date Description Amount 12/24/08 12/24/08 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $3,532.82, 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. 50110? 2920 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $3,650.01 01/26/09 $1,099.65 0000000 " 19 W364 I TR5006 FXe 001 7 M (111'?'111'II?IIIII ?1'lll'?IIII IIIII'111Illl?lllllll ll'IIII11' DAVID M REED 6545 MOLLY PITCHER HWY SHIPPENSBURG PA 17257-9373 IIIIIIII'lll'1'lli?l'11IIIII'1I'111I11Ilitl"'II'lllllllll Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. 200 5049940185412920 0365001 0109965 0000000 1918 EXHIBIT Sears Card' Call us at 1-806.917-7700 Go to www.seerecard.oom Write to us at PO Box 6283 Siam Fells, SD 57117-6283 Payment Due Date 01 /26/09 DAVID M REED Account Number. XXXX XXXX 1PCXX 2920 Page 2 of 2 0 Average Corresponding Periodic Rate Periodic Rates *Rate Varies Balance Daily Science ANNUAL D-Day PERCENTAGE RATE M=Month FINANCE CHARGE SEARS REGULAR $3,650.01 $3,578.81 25A0%* .0696%(D)* $82 19 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. r Verification I a a Reynolds 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. f 9L?'""' Signature C-21102 David M Reed Account number ending in 2920 1031 (2) IL ' "'F zP « juz r-.> #1g.5o PQ AT'rhl eg.'s 9A Q[' U11.00.3 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. Plaintiff V. DAVID M REED Defendant IN THE COURT OF COMM CUMBERLAND COUNTY, NO. 09-3588 Civil term CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. PLEAS 1NSYLVANIA C-21102 FILED-01-FICE OF THE P",,",P C':1 OT, Y 2003 JUN I I PH I : 3 :1t-`,J NiY PE.NNSYLVANA