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Home My WebLink About09-7150Burton 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. HECTOR A VAZQUEZ JR 208 Hickory Lane, Shippensburg Pa 172579495 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - )'!S6 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-28360 I J 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 NO. HECTOR A VAZQUEZ JR 208 Hickory Lane, Shippensburg Pa 172579495 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 Hector A Vazquez Jr, who resides at 208 Hickory Lane, 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 credit card with account number ending in 9462 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 $4,653.06 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. I- - - Wherefore, plaintiff demands judgment against defendant for the sum of $4,653.06, and the costs of this action. Burto eil ssociates, P.C. 0 By: d J. O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. o N N O J 6' O N 'Ox jai f N r _ W m yr n N g yl i M ? N R ? < > g 4 tt??11 Y/ N z co°° R? y N O ? F -c TP c o o 0 0 0 0 0 0 OOO EU? 000 b O '4 O O O Hof O USA d N N 1 ?T 2 _O yy yy? 10 Q S 6a c g 0 ?p O J f .ewf in ? +I y o i yj V N OMt OW Om opl Paid _ Total New Balance: $4AMMM MIRWAM Amount Due: Payment Due Date: 07/!1/106P 000000 MC 32 A 0 HECTOR A VAZOUEZ JR 200 HICKORY LN SHIPPENSBURGPA 17257.9495 P " ? Cw C V N p G A E?t?OdVi r C Z C ? QI IJa V?7M ? o I°o a°•rc ? s?Vr°q Euce aV !? z Q O 6 3 ? at a" ?Acs dT Ao u 11°e O?v=V? ; i me 12.0 VIC 41C U V ?a'O..N V? 8 0 0 0 Q .H M N C E € C J = E 0*ck __? a aa.Id rwMa rwwua YUMMI1MMnwN Mrn MWl ev w rrCKI Cabs 9462 Amount Endo"* rrff'"I.nt w rs.MN w emo wl MW MM M Mt IGVMN* dIM d" CITI CARDS P.O. BOX 102564 COLUMBUS, ON 43216.2564 EXHIBIT s N J X81 `? f x Is m? Ln ?O of 4 - . 2 ? d ow r? a i o o h N q r gay E 1T07 Cp di CL 1 q Y YON V C N OY o'a N ? E4H t A pC q Y Z P V = N c - . 14 Verification h , am employed by Citicorp Credit Services, Inc. (USA) (hereafter SI), 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. i ?%I J"r- Signature C-28360 Hector A VAZQUEZ JR Account number ending in 9462 1000 oll 7 THE 2M OCT 19 Fib 3: 51 eK? a6 scY J ?. a3?2ay Sheriffs Office of Cumberland County FILM-OFFICE R Thomas Kline OF THE PROT,CNOTAW Sheri `- " "" ?o?''xt? of ??rru6rrlrl?d Ronny R Anderson 2009 OCT 28 Alf 9: 43 Chief Deputy ' Jody S Smith Civil Process Sergeant car E `=?G >`? ??r PEMNSYLb'RNIA Edward L Schorpp Solicitor Citibank (South Dakota) N.A. Case Number vs. Hector A. Vazquez, Jr. 2009-7150 SHERIFF'S RETURN OF SERVICE 10/27/2009 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: Hector A. Vazquez, Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Hector A. Vazquez, Jr. Current resident of 208 Hickory Lane Shippensburg, PA 17257 is the defendant's father, he stated Hector A. Vazquez, Jr. currently lives in Virginia. An exact address is not available. SHERIFF COST: $51.00 October 27, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF s IL D-OF IGE . H PROTHONOTAP `i 7011 APR -4 AM 11: 37 CUMBERLAND COUNTY PENNSYLVANIA 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. Plaintiff V. HECTOR A VAZQUEZ JR Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7150 CIVIL TERM CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burt n Neil ssociates, P.C. By: Edward J. O' en squire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-28360