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Home My WebLink About09-4638 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 BRIAN J WILLIAMS : NO. d4 _ y(o38 ?1V<1 em 109 Ewe Road, Mechanicsburg Pa 17055-6917 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-18447 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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. NO. O 1- 5/L 3 7 ?c w P -r.1 ,-. BRIAN J WILLIAMS 109 Ewe Road, Mechanicsburg Pa 17055-6917 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 Brian J Williams, who resides at 109 Ewe Road, 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 credit card with account number ending in 1359 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 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 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 $6,344.90 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 $6,344.90, and the costs of this action. Burton Neil & ciates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 08/01/08 $6344.90 $6344.90 SITE:KC-CL TM:CO-5000 ACID:KCB0201 10/01/08 2 3 : 5 9 : 21 CITI CARDS BRIAN J WILLIAMS PO BOX 183054 COLUMBUS, OH 109 EWE RD 43218-3054 MECHANICSBURG PA 17055-6917000 11 j J 4 Citi"' Dividend Platinum Select* Card Account Number 1 1359 Customer Strvice. 1-800-568-5000 Total Credit Line Available Credit Line BOX 6500 $4900 $0 SIOUX FALLS, SD Statement/ e Amount Over e 57117 07/0812008 $1444.90 Sale Date Post Date Reference Number Activity Since Las Cash Advance Limit Available Cash Limit $2000 $0 Past Due Mlriimum Di $1083.88 $265.0 C tl? New Balance $6344.90 Minimum Amount Due $6344.90 7/08 Standard Purch LATE FEE - JUN PAYMENT PAST DUE 39.00 66 0000 7/08 PURCHASES*FINANCE CHARGE*PERIODIC RATE 0000000000 106.88 84 0000 0000000000 Standard Adv 7/08 ADVANCES*FINANCE CHARGE*PERIODIC RATE 56.18 84 0000 0000000000 Your Minimum Amount Due on any New Balance over $20 will no longer include the total amount of your transaction fees. These fees include balance transfer, cash advance, and foreign purchase fees. Remember, you can pay these fees (and any other amounts owed on your account) at any time. Your late fee was based on your account balance as of the payment due date (06/30/08), which was $6,142.84. 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 give us the opportunity to assist you. Our records show home phone 717-763-0178 and business phone 717-506-2053. Please update coupon if incorrect. EXHIBIT Account Summary Previous (+) Purchases (-) aymen s (+) FI NC (_) New Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES 4,026.48 2,116.36 1 0.00 00 :$0 $106. 88 4 172 , .36 TOTAL 6,142.84 . f0.00 $39.00 0.00 $56 . 18 $163 06 , J2 172 .54 . . 6,344.90 Rate Summary Balance Subject o erio is Days This Billing Period: 33 o Finance Charge Rate mina ANNUAL APR PURCHASES PE RCENTAGE RATE Standard Purch ADVANCES $4,078.07 0.07942%(D) 28.990% 28.990% Standard Adv $2,143.48 0.07942%(D) 28.990% 28.990% Verification I Shauna Houghton 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 unswom falsification to the authorities. I a1J"AL;:-f Signature C-18447 Brian J Williams Account number ending in 1359 1000 0 Fi ZQQS Jyw 1 0 F C+ $ `T8 . Bo P Q AT'N C,V-tt 6l0 Liq I 2a7 80 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OFFICE T" SHERIFF OF Ltd OF THE r,r • - ,; 2009 jJL 16 A IC: 6 I ?..y. Citibank (South Dakota) N.A. vs. Case Number Brian J. Williams 2009-4638 SHERIFF'S RETURN OF SERVICE 07/13/2009 08:40 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2009 at 2040 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brian J. Williams, by making known unto himself personally, defendant at 109 Ewe Roac Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 July 14, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy heriff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v, BRIAN J WILLIAMS 109 Ewe Road Mechanicsburg Pa 17055-6917 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4638 CIVIL TERM : CIVIL ACTION - LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $6,344.90 $6,344.90 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UN ER PA.R.CIV.P. 236 P Prothono Bur A ciates, P.C. By: Edward J. O'Brien, Esquire Attorney for Plaintiff I.D. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-18447 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. BRIAN J WILLIAMS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4638 CIVIL TERM : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Brian J Williams 109 Ewe Road Mechanicsburg Pa 17055-6917 IMPORTANT NOTICE C-18447 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office 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 DATE OF NOTICE: August 4, 2009 In making this communication, we advise our office is a debt collector. Burton Neil & Asso ' , P.C. By: Edward rien, Esquire Attorney for Plaintiff Identification No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 'i Pt _ THE: 7.,.1,^, Tt'1q1 2009 AUG 20 Ail i 1: 26 fit' i ••J ?`?>?'Y'(..??`?? ?"?b?! CV,* 583 t I kT*- aaq 5o( 10 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN J WILLIAMS NO. 09-4638 CIVIL TERM Defendant : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on $ L.10 to 9 rothonota By: Deputy If you have any questions concerning the above, please contact: Edward J. O'Brien, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. r, ~~ ~,'~-~ Burton Neil & Associates, P.C. By Edward J. O'Brien, Esquire ID. NO. 32985 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 Plaintiff v. BRIAN J WILLIAMS Defendant CUMBERLAND COUNTY, PENNSYLVANIA N0.09-4638 CIVIL TERM CIVIL ACTION -LAW Praecipe to Satisfy Judgment To the Prothonotary: Mazk the judgment Satisfied . eil & Ass4~es, P.C. By: Attorney The law firm of Burton Neil & Associates is a debt collector. Esquire C-18447 '~~ ~~ p~. ~~ U ~(J ~~/o~ 1Z~C~ atls~i~