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Home My WebLink About09-6795 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. ROSS M CLEVELAND 4101 Clubhouse Drive Mechanicsburg PA 17050-9120 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Cq (01g5 CIVIC-0,fro : 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-28699 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. ROSS M CLEVELAND 4101 Clubhouse Drive Mechanicsburg PA 17050-9120 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 Ross M Cleveland, who resides at 4101 Clubhouse Drive, 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 KeyBank credit card with account number ending in 7113 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 $15,189.79 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 $15,189.79, and the costs of this action. Burtc(n V?41& Associates, P.C. By: Der-bk C. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 4 06/29/09 $15189.79 $15189.79 SITE:KC-CL TM:CO-5000 ACID:KCB0203 ='ss artit iii aa#suii 08/28/09 21:10:50: KeyBank ROSS M CLEVELAND PO BOX 183051 JOY CLEVELAND COLUMBUS, OH 4101 CLUBHOUSE DRIVE 43218-3051 MECHANICSBURG PA 17050-9120000 ( I I AV, '? KeySmart® ONW. Account umber 7113 Customer Service. 1-800-444-4539 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $13870 $0 $10000 $0 $15189.79 PO BOX 142319 Statement/ Amount Over Purch/Adv Minimum IRVING, TX Cloaln Date / a Credit Line $1319 79 Past Duo $1954 54 inimum Due 524 54 Amount Due $15189 79 75014-2319 06/04 2 09 . . . . Sak Data Post Date Reference Number Activfty Since Last Statement Amount Purch 6/04 LATE FEE - MAY PAYMENT PAST DUE 0 600 CR 6/04 EDIT LIMIT FEE OVER 62 0000 0 6/04 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 0 Balance Transfer - Charged To Offer 6 6/04 RCH ES*FINANCE CHARGE*PERIODIC RATE PU AS 39.00 70000000000 35.00 70000000000 301.24 70000000000 33.30 70000000000 Your late fee was based on your account balance as of the payment due date (05/29/09), which was $14,781.25. 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. IXHIBIT____L_ Account Summary Previous (+) Balance & Purchases -) Payments Advances & Credits (+) FINANCE CHARGE (=) N e;7 Balance PURCHASES $14,781.25 0.00 $74.00 $334.54 $15,189.79 ADVANCES $0.00 1 $0.00 0.00 $0.00 $0.00 TOTAL $14,781.25 $74.00 0.00 $334.54 $15,189.79 Days This Billing Period: 30 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PE RCENTAGE RATE PURCHASES Standard Purch $13,454.90 0.07463%(D) 27.240% 27.240% Offer 6 $1,487.42 0.07463%(D) 27.240% 27.240% ADVANCES Standard Adv $0.00 0.07463%(D) 27.240% 27.240% Verification 1 Mark Molinari , 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 unsworn falsification to authorities. r Signature C-28699 Ross M Cleveland Account number ending in 7113 1000 0 ?iLtU-C't ?iL CF TlE: PP. 3'' °H, ,NDTAPY 2009 OCT 13 PM 1: 58 CUM, cc`M ioooqa x31843 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ????tr of ?umbrr?fi? ?..? QFFfGE OF r.,s; SuERIFF r 2004OCT 20 AM g: S0 CU',ti Citibank (South Dakota) N.A. vs. Ross M. Cleveland Case Number 2009-6795 SHERIFF'S RETURN OF SERVICE 10/16/2009 06:10 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2009 at 1810 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ross M. Cleveland, by making known unto Joy Cleveland, wife of defendant at 4101 Clubhouse Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 19, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By Deputy Sheriff