HomeMy WebLinkAbout09-7457a
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.
ANDREW BRUNNER
22 Saint Johns Rd, Camp Hill PA 17011-6941
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. (j1 - 7 57 Ol vi i Term
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-27866
a
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. IN THE COURT OF COMMON PLEAS.-
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANDREW BRUNNER
22 Saint Johns Rd, Camp Hill PA 17011-6941
Defendant
NO. (91- I YS'7 " 7-.„
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 Andrew Brunner, who resides at 22 Saint Johns Rd, Camp Hill,
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 1026 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 $5,032.91 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 again defendant-€or the sum of $5,032:91, and
the costs of this action.
Burton a&es, P.C.
By:
squire
Attorney for Plaintiff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
ot
?c
m
N
VI M
W N
N
s
'o
X V
it
S? x?I=
V°m4 r?i
• ut
W
N
C
J Q;
v 'D
C N
W ? Q
N
13
_
r Qg
V
?
D O
4 e
!
7 ?
14
O
99 In
O b
N
e
ON
$ N Q; 011
m
?e
O M M
`
1 O
!6 O
P,
N dO , Vi iR
datf [u47
Total Now Balance:
Mknlmum Amount Due:
?l.VI
Payment Due Date:
07/30/=000
000000 MC 32 A 0
ANDREW BRUNNER
22 SAINT JOHNS RD
CAMP HILL PA17 011-69 41
11
e. r
4r
;a
i .•1 n
O, n
i N
n
o
m
P
N
N L
e•1
C!
0
I
O
O
O]
10
0
f
E
Y? M
O
litt!
?K
t6
S
ko:
O
is
u
i >
J
, y
• C
d
J
! yy
1
N
i d
! m
a
C
A
C
c
dg
=E
0Z
u?
d
> w
0. C
O O O O
QD M O H H
O ul !D y
M .-1
N c N
tee; C P
E O
D u C N E
y
_
d °
?a
o?
?$ ? 1O
_uY4E
00
?
O
?O• F-
N
1ten 1
?
'
` 0
y
? C T
p
Q
"' y
'
U
C
?
C V
v o N ?p
I
i
gym. ElND
C
E ?-.
E
a N C
N? y C'
sdco
?
C
' J of 9 .
y O 0 ".C
y v 0
y r 3 c -2 14
v c V E "
?
9
a`J
a! o
d w
,
dM La
10gV
> >a
M
r J a
:o
Q a C LO
v M i D 0
N
c c v aJ
°X.2
0
H
Q
V
Q
E
> O 5
=
0 O 1!f 7
0@6 p _ _____ De1M1 YM aAMM paymmo vawvotl l on
?wNN
mawo.ep.y w,«CM Cards
C g??
026
n d:
P"M newt M naNnO by 5:00 PM
1"a tw" on tM p4vnmM aw Enfw
CIT. CARDS EXHIBIT
P.O. BOX 162564
COLUMBUS. OH 43218•2564
Verification
I, / Mi C Mp/-? am employed by Citicorp Credit Services, Inc. (USA)
(hereafter C 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 unworn falsification to authorities.
ASignature
C-27866
*-Andrew Brunner
count number ending in 1026
IOC.,
a
M1, i
0
-?I-rICF
OF PP?F;N?JTARY
2009 OCT 28 PH 2: 4 9
CUMbL F .' `•-N7Y
PE, lNS''VU/,"V AA
$'18.50 po prrl
Cev6t oa4
R 1,34 Io4(p
r4
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
OFFICE ,F T, -1EP1;;CF
ALED-a ICE
OF THE PR-0-PH,,0N0TARY
2009 NOW 19 PM 12: 5 7
C.; ;JjLffy
MNSYLUANA
Edward L Schorpp
Solicitor
Citibank (South Dakota) N.A. Case Number
vs. 2009-7457
Andrew Brunner
SHERIFF'S RETURN OF SERVICE
11/16/2009 06:58 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on November
16, 2009 at 1858 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Andrew Brunner, by making known unto Jennifer Vance, adult in charge at 22 Saint
Johns Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $41.50
November 17, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
By
Deputy Sheriff
(cj CountySuite Sheriff. Te!eosoft, Inc.