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HomeMy WebLinkAbout09-7323 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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 CHARLES F TODD JR : NO. CA - 78aS aili(TIM 803 W Keller Street, Mechanicsburg PA 17055-4029 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-19980 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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. CHARLES F TODD JR 803 W Keller Street, Mechanicsburg PA 170554029 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .NO. 09-13.230 72,r. 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 Charles F Todd Jr, who resides at 803 W Keller Street, 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 8660 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 $10,452.57 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 $10,452.57, and the costs of this action. Burton Neil & Associates, P.C. By Brit . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Premier barde Call us at 1-800-917-7700 Go to www."amcard.com Write to us at PO Box 828:1 Sioux Fells, SD 57117-8283 CHARLES F TODIUR Account Number: gggp Payment Due Date Page 1 of 2 11/19/08 Your Account Summary Billing Cycle Closing Date 10/22/08 Amount Over Credit Line $452.57 You're in charge. Amount Past Due $2,041.53 We may have the payment solludon just for you, Total Minimum Due $2,429.88 and you're In control of how you do K. Previous Balance Payments & Credits $10,169.22 $00.0 .00 Manage your account online OR by phone Purchases & Debits $0.00 • You can quickly 9o online or cat to get personal assistance Other Charges $35.00 . See when a payment Is due or posted . Select from affordable payment options to meet your needs that Total FINANCE CHARGES $248.35 may: Account Balance $10,452.57 - Lower your annual percentage rate - Lower your minimum payment Contact us today-we can help. Your Credit Summary v Total Credit Line $10,000.00 Total Credit Available $0.00 Activity Sale Date Post Date Description Amount 10/17/08 10/17/08 LATE PAYMENT FEE 35.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $10,169.22, 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. Please follow payment Instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Premier Card* Account Numbe8660 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $10,452.57 11/19/08 $2,429.88 0021525 EX 14 A 08298 1 TR8006 FXG 001 7 N IIIIIIIIIIIII111IIIIIIII IIIIIII III IIIII IIIIIII IIIIIIIIIIIII III CHARLES F TODD JR 803 W KELLER ST MECHANICSBURG PA 17055-4029 Please make address changes on reverse side. IIIIIIIIIIII IIII IIIIIIII IIIIIII IIIIIIIIIIIIIII III IIIIIII IIIIII Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 200 8660 1045257 0242988 0000000 1411 EXHIBIT A Sears Premier bard® CHARLES F TODD JR Account Number: XXXX XXXX XXXX 8660 Page 2 of 2 21525 Call us at 1-800-917-7700 Go to www's"mcard.com Write to us at PO Box 8283 Sioux Fells, SD 57117-8283 Payment Due Date 11/19/08 Average Corresponding Periodic Rate Periodic Deily ANNUAL D-Day FINANCE Rates *Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $10,452.57 $10,295.43 26.65%* .0731%(D)" $248.35 EXTERNAL REGULAR $0.00 $0.00 26.65%* .0731%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 26.65%* .0731%(D)* $0.00 Days in Billing Period: 33 Effective ANNUAL PERCENTAGE RATE: 26.65% Minimum FINANCE CHARGE: $0.00 Cardmember News 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 balance transfer and cash advance transaction fees or 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 1, "Time 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. Signature C-19980 Charles F Todd Jr Account number ending in 8660 1031 0 OF nHVEaW 20 OCi23 FM et 1i "%"am *79.So Pc? A-ny 00401415 e asaso7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY f?;• Iu R Thomas Kline ; LEE--C . ? E Sheriff OF TP„r' F=': ., L,nN0.TARY r Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ????,tu at 4Nr,r14rrp4? , ,. 2009 NOY -4 Ali 11: 04 QPFi E 3 RIFT QUIlk- _.UN11 k F ?f. JI y 4 V'.)T LYI}? ;I. Citibank (South Dakota) N.A. vs. Charles F. Todd, Jr. Case Number 2009-7323 SHERIFF'S RETURN OF SERVICE 11/02/2009 09:02 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 2, 2009 at 2102 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles F. Todd Jr., by making known unto himself personally, at 803 W. Keller Street Mechanicsburg, Cumberland County, Pennsylvania 17055 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 ANSWERS, ? 00*1996? a 0 01 ( November 03, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff (C) Count,Suite Shenff, ieleosoft, Inr,.