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Home My WebLink About09-7291Burton 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. DALE A FLOR JR 2432 Lobach Drive, Mechanicsburg PA 17055-5376 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. Oq- `1 9-gI 0-?tvZ l (erM 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-20235 T 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. G q 7 ?+-? 4,.- DALE A FLOR JR 2432 Lobach Drive, Mechanicsburg PA 17055-5376 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 Dale A Flor Jr, who resides at 2432 Lobach 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(n) Sears credit card with account number ending in 6727 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 $3,948.61 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 $3,948.61, 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. Y/ ' SearsCharge PLUSe DALE A FLOR J Account 'WM 6727 Page 1 of 2 Your Account Summa Billing Cycle Closing Date 10/27108 Amount Over Credit Line $0.00 Amount Past Due $725.66 Total Minimum Due $894.05 Previous Balance $3,820.22 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $93.39 Account Balance $3,948.61 Your Credit Summary Total Credit Line $4,140.00 Total Credit Available $0.00 Payment Due Date 11/24/08 Activity Sale Date Poet Date Description Amount 10/22/08 10/22/08 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $3,820.22, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Corresponding Periodic Rate Periodic Daily ANNUAL D=Day FINANCE Rates *Rate Varies Balance Balance PERCENTAGE RATE M--Month CHARGE SEARS REGULAR $3,948.61 $3,871.61 26.65%* .0731%(D)* $93.39 Days in Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 26.65% Minimum FINANCE CHARGE: $0.00 Please follow payment Instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Charge Account Balance Due Date Mlrlimum Due Amount Enclosed J 0013531 ED 17 A 08301 1 TRS001 FIG 001 7 N 111.1111111111111111111111111111111111111111111111111111111111 Account Numbs 6727 Payment Total $3,948.61 11/24/08 $894.05 DALE A FLOR JR 2432 LOBACH DR MECHANICSBURG PA 17055-5376 Please make address changes on reverse side. 1111111111111111111111111111111111111111111111111111111111111) Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 Call us at 1-800-917-7700 Go to www.seemeard.com Write to us at PO Box 8283 Sioux Fells, SD 57117-6283 200 5049941006528613 0394861 0089405 0000000 1719 EXHIBIT SearsCharge PLUS® Call us at 1-800-917-7700 Go to www.womcord.com Write to us at PO Box 8283 Sioux Fells, SD 57117-6283 Cardmember News DALE A FLOR JR Account Number: XXXX XXXX XXXX 6727 Page 2 of 2 13531 Payment Due Date 11/24/08 The Sale Date is the Transaction Date. Your Total Minimum Payment on any Account Balance over $10 will no longer include the total amount of applicable insurance charges or credit protection fees assessed that billing period. Remember, you can pay these fees (and any other amounts owed on your account) at any time. Verification I, Tiena Reynolds , 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. f Signature C-20235 Dale A Flor Jr Account number ending in 6727 1031 0 29E9 C C T 22 PIN 2: 4 14 *72.50 PD ATt-y co(ONS6 W' a 3ays9 Sheriffs Office of Cumberland County R Thomas Kline FILED-OFa Sheriff . OF I THE P1 Yt. T Ronny R Anderson Chief Deputy 2003 OCT 28 AM 9" 4 2 Jody S Smith , M Ct?1?1Lri F ? IJ Civil Process Sergeant PENNSYLVAt4{A Edward L Schorpp Solicitor Citibank (South Dakota) N.A. Case Number vs. Dale A Flor, Jr 2009-7291 SHERIFF'S RETURN OF SERVICE 10/23/2009 08:05 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 23, 2009 at 2005 hours, she served a true copy of the within Complaint and Notice, upon the within namec defendant, to wit: Dale A. Flor, Jr., by making known unto himself personally, at 2432 Lobach Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWER October 27, 2009 R THOMAS KLINE, SHERIFF By / Deputy Sheriff