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Home My WebLink About09-6611G 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. JASON W FLETCHER 308 Andersontown Road, Mechanicsburg PA 17055-6024 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. dQ - GD(Dl' a Vv i lTer?A 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-26566 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 NO. U9- G 611 04,?j JASON W FLETCHER 308 Andersontown Road, Mechanicsburg PA 17055-6024 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 Jason W Fletcher, who resides at 308 Andersontown 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 8045 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 $1,753.79 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 $1,753.79, 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. JOIN ' a ti 17?ment Due Date JUNE 01 2009 140547 140547 DI 1 05 Make checks payable to: CITI MASTERCARD Account Statement z ?$1,753 ew Balance Your Account Number L Amount Minimum Amount Past Due Payment Due Enclosed . 79 8045 $183.00 $278.1 $ z 68 GP Please follow payment instructions on reverse side. Minimum Payment z Due must be received by 5:00 pm local time on Payment Due Date. 8045017537900021000027800103 140547 JASON W FLETCHER ss r 308 ANDERSONTOWN RD AVGP MECHANICSBURG PA 17055-6024 Print address changes above. a h 0 0 CITI MASTERCARD PROCESSING CENTER DES MOINES IA 50364-0001 llllll? • Please detach here. Send Notice of Billing Errors to: C l t l CITI MASTERCARD PO BOX 689182, DES MOINES IA 50368-9182 Customer Service: 1.866-510-2761 THIS ACCOUNT ISSUED BY C177BANK (SOUTH DAKOTA), N.A. Account: 8045 Closing Date Nutt Closing Date Cash Limit' Cash Available Credit Line Credit Available Amount Over Limit 05/07/09 1 06/08/09 S.,300-00 1 so-OO I - $1,80O.Oo S46.00 SO_ Previous Balance Payments & Credits Purchases/Other Charges Cash Advances FINANCE CHARGES New Balance $1.675.61 . $0.00 1 $39.00 1 $0.00 $3 .1111 1 11 7 7 CURRENT ACT/VIT Y Transaction Date 05/03 05/07 Transactions LATE FEE *BILLED FINANCE CHARGES* Amount $ 39.00 $ 39.18 The "ANNUAL PERCENTAGE RATE on the account" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "ANNUAL PERCENTAGE RATE on the account" 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 EXHIBIT of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. Notification of Entertainment Sweepstakes: Your Citi Mastercard could get you closer to the ultimate New York City Experiencel Visit www.priceless.com/nyc for details. May 15 through June 30, 2009. ANNUAL PERCENTAGE RATE on the account: ?S 4 S S Previous 0% APR FOR 3 MOS-PMT REQ $200.29 0% APR FOR 3 MOS-PMT REQ $133.00 0% APR FOR 3 MOS-PMT REQ $163.20 Plan FINANCE $200.29 $133.00 $163.20 Subject to DAILY Finance Charge Periodic Rate ANNUAL v PERCENTAGE RATE Billing FINANCE FINANCE Period CHARGES CHARGES Current Billing Period 0% APR FOR 3 MOS-PMT REQ 0.07942%(D) 28.99% 29 0% APR FOR 3 MOS-PMT REQ 0.07942%(D) 28.99% 29 - 0% APR FOR 3 MOS-PMT REQ 0.07942%(D) 28.99% 29 STANDARD CASH ADVANCES 0.07942%(D) 28.99% 29 - Previous Billing Period 0% APR FOR 3 MOS-PMT REQ 0.07942% 28.99% 30 - 0% APR FOR 3 MOS-PMT REQ 0.07942% 28.99% 30 - 0% APR FOR 3 MOS-PMT REQ 0.07942% 28.99% 30 - NONE *The Cash Limit is a portion of your Credit Line. S3046P PAGE 1 OF 3 CBEF01 -140547 ' PAGE 2 OF 3 CURRENT ACT.IVIT Y Transaction Date Transactions Amount Your late fee was based on an account balance of $1,675.61, o 0 which was your account balance on the Transaction Date for the fee. Additional Finance Charge Summary z z r 0% for 3 months on purchases of $99 or more - 0.00000% daily periodic o rate (0.00% corresponding ANNUAL PERCENTAGE RATE) o 0% for 6 months on purchases of $299 or more - 0.00000% daily periodic rate (0.00% corresponding ANNUAL PERCENTAGE RATE) Any balances on these plans are reflected below. ° SPECIAL PROMOTIO NS Billed Accrued Previous FINANCE Payments 8 Plan FINANCE Expiration Balance CHARGES Credits Balance CYACP_CQ n.re FINANCE CHARGE SUMMARY Balance Corresponding Days In Periodic Other Subject to DAILY ANNUAL Billing FINANCE FINANCE Finance Charge Periodic Rate PERCENTAGE RATE Period CHARGES CHARGES Current Billing Period STANDARD PURCHASES $1,701.10 0.07942%(D) 28.99% 29 $39.18 Previous Billing Period STANDARD PURCHASES - 0.07942% 28.99% 30 - Now you can access your Citi MasterCard Credit Account Online! Log on to www.citicards.com for secure 24-hour account access that lets you: • Make payments online • View and download statements • Review and update personal information • Get answers to frequently asked questions It's Fast - It's Simple - It's FREE Log on today to www.citicards.com for more information. 140547 PAGE 3 OF The Perfect Card for all of Your Everyday Purchases With a 0% APR for 3 months on each purchase of $99 or more,* or for 6 months on each purchase of $299 or more,* the Citi MasterCard is the perfect card for your everyday payment needs. * After the applicable promotional offer ends, your standard purchase APR, which is shown on the enclosed statement, will be applied to any unpaid balance. As of March 1, 2009 for accounts In good standing APRs are up to 29.99%. The standard variable cash advance APR is 28.99%. However, all your APRs may automatically increase up to 29.99% variable default APR If you fail to make any payment to us when due, go over the credit line, or make a payment that is not honored. Minimum FINANCE CHARGE is $2. Foreign Purchase Transaction Fee: 3%of the purchase amount after its conversion into U.S. dollars. Cash advance transactions fee: 5% of amount; min. $5. See card agreement for details. Share the joy of cardmembership. Free additional cards. Want additional Citi cards for your family? We're glad to provide them, with no annual fee. You can add family members - like spouses or students - as authorized users, so they all can have Citi cards of their own. The account is still yours, but the benefits (like worldwide acceptance and more) extend to them, too. To order additional cards, call Customer Service at 1-866-510-2761, Monday through Friday from 9am to 8pm ET. Pay your monthly bills with your CitiO MasterCard®. Cable, phone, health club memberships and more. Enjoy the peace of mind of paying your monthly bills on time, all the time, and in no time.* Simply contact your service providers today to set up regular payments with your Citi® card. 3 z?z Z ° 0 0 r r z .. z o 0 a *As long as the company you are paying processes your request in a timely manner. Verification I, L. "MUMer , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Signature C-26566 Jason W Fletcher Account number ending in 8045 1027 0 FILED-(,,rFlGE OF THE PPOTONOTARY 2009 OCT -S PM 12:3 7 CU BIIJ`i 14u C:OLM PENNSYLVANIA *18.50 Po A?'M Ck,* 5q8 X15 _ . R? a.31 ?a(o Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 193 80 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASON W FLETCHER Defendant NO. 09-6611 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: Neil Sarker, squire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-26566 2009 QC T 16 H c: f 9 i ? r r 1! t s