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Home My WebLink About09-7092Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RONALD D ANTHONY : NO. (q - r109o.1 ?tV t? ?f'h'1 304 Kay Road Suite B9-65, Mechanicsburg Pa 17050 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-27289 Burton Neil & Associates, P.C. By• Yale D Weinstein Esquire ID. NO. 89678 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. RONALD D ANTHONY 304 Kay Road Suite 139-65, Mechanicsburg Pa 17050 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 Ronald D Anthony, who resides at 304 Kay Road Suite 139-65, 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 2950 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. 1 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $7,321.41 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 $7,321.41, and the costs of this action. Burton NeilA Asioc&es, P.C. By: Yale Weinstein, Esquire Attev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt 4 05/12/09 $7321.41 $7321.41 SITE:KC-CL A .M.. I W-1 CITI CARDS RONALD D ANTHONY P.O. BOX 6401 1280 VISON AVE THE LAKES, NV SUITE B9-65 88901-6401 NEW PORT BEACH CA 92660 CIV Advantage® World MasterCard® Account Number AAdvantage is a registered trademark of American Airlines, Inc. air 2950 Customer Swyllm Revolving Avatlaele Revolving 1-800-568-5000 Credit Line Credit Llne Cash Advance Limit Available Cash Limit BOX 6000 $13100 $0 $6000 $0 Statement/ Amount Over Purch/Adv THE LAKES r NY Closing Data Revolving Credit Line Pest Due Minimum Due 69163-6000 04117/2009 $0.00 $825.86 $109.00 Sale Date Post Date Reference Citi cares about our relationship with you. In light of the current economic conditions, we have waived interest and late fee if applicable this month, saving you $209.51. Citi Account Resolution is here o help. We can work with you to find a payment solution that makes sense. Please call 1-866-936-4813. 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. TM:CO-5000 ACID:IRB4980 07/14/09 22:51:16: C tl* New Balance $7321.41 Minimum Amount Due $7321.41 EXHIBIT Account Summary Previous (+ Purchases Balance &Advances - Payments &Credits + FINANCE CHARGE = Now Balance S $6 462.08 0.00 0.00 0.00 $6 462.08 CES 7 00 10. 00 10. 0 0 10. 321 41 TOTAL $ 321.41 . . . 0 $7, . Days This Billing Period: 29 Rate Summary Balance Subject to Periodic Nominal ANNUAL Finance Charge Rate APR PER CENTAGE RATE Purch $0.00 0.07942%(D) 28.990% 28.990% Adv $0.00 0.07942%(D) 28.990% 28.990% Verification I, Kris Dietz 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. C-27289 Ronald D Anthony Account number ending in 2950 1000 (ib jt: 2909 OCT 15 PM 3: 07 *18.50 AA ATrY WO &05Q7 ej* aaall9 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?ulits, of CU444)""1494 F1LFi} f; F1` OF Till. { 7A1Y Citibank (South Dakota) N.A. vs. Ronald D. Anthony ZL 9 OC' T ?0 ?'I Q, z) -I-- 2 CU"r, 1:v 1 } Case Number 2009-7092 SHERIFF'S RETURN OF SERVICE 10/29/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ronald D. Anthony, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Ronald D. Anthony. Per current resident of 304 Kay Road, Suite B9-65 Mechanicsburg, PA 17050 Ronald D. Anthony is currently located in China. An exact address is not available. SHERIFF COST: $51.00 SO ANSWERS, October 29, 2009 R THOMAS KLINE, SHERIFF 2010~t:~~4 ~-~~r1t.5.~ - ~r ;"~. " Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff v. RONALD D ANTHONY 304 Kay Road Suite B9-65 Mechanicsburg PA 17050 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7092 CIVIL TERM CIVIL ACTION -LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. Burton By: Weinstein, Esquire for Plaintiff The law firm of Burton Neil & Associates is a debt collector. S' C-27289 ~!l~.Od ~~/ e~- 7os<,y 1 ~~ ~3 7 Q~9 t t + srl?. I BAR --7 Pal 12: { Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. RONALD D ANTHONY Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-7092 CIVIL TERM CIVIL ACTION - LAW Praecipe to Discontinue Kindly discontinue the above-captioned action without Neil 7t cl Yale/h. ein: The law firm of Burton Neil & Associates is a debt collector. P.C. Esquire C-27289