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HomeMy WebLinkAbout09-7958Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 JEFFREY A PARKER NO. CA - rIa58 CVi kGry, 713 Manor Road, Camp Hill PA 17011-1718 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-27164 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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. NO. 09 9 S P e.e Tom. JEFFREY A PARKER 713 Manor Road, Camp Hill PA 17011-1718 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 Jeffrey A Parker, who resides at 713 Manor Road, 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(n) Sears credit card with account number ending in 3961 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 $2,614.75 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 $2,614.75, and the costs of this action. Burton NL 1 MAssociates. P.C. By: D"ere'K-C. Blasker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Premier Card® JEFFREY A PARKER Account Number:d&UWWPWM 3961 Page 1 of 2 Your Account Summa Billing Cycle Closing Date 06/02109 Amount Over Credit Line $174.75 Amount Past Due $626.45 Total Minimum Due $759.45 Previous Balance $2,508.75 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $39.00 Total FINANCE CHARGES $67.00 Account Balance $2,614.75 Your Credit Summary Total Credit Line $2,440.00 Total Credit Available $0.00 Call us at 1-800-917-7700 Go to www.womeard.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 Payment Due Date 06/30/09 Need to know how to bring your account curmnt? Call us and we will show you the way. We understand that of that can help bring your unforeseen things can happen account current. mid sometimes 4 can be hard We-ll wok with you, listen to to follow Through on your bill your concerns and identify a payments. But a past due payment solution Thal may fit bill can really impact your your personal situation. future financial outlook. We Important that yaU call We want you to know that 1-866-518-9053 IherP may bee payment. ' so w6 can help. solutions you aren t aware www.g argGrd.com Activity Selo Date Post Data Description Amount 05/29/09 05/29/09 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $2,508.75, 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 Number 3961 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $2,614.75 -1 06/30/09 7 ( ( $759.45 0069884 EX 01 A 09153 1 TR8006 FXG 001 7 N IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIiI JEFFREY A PARKER 713 MANOR RD CAMP HILL PA 17011-1718 Please make address changes on reverse side. Illllllll 11111 ll 111 llllllll ll 11111 11111 11111 ll lit 11111 111 ll 111 39.00 Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 n EXHIBIT 200 5049940145893961 0261475 0075945 0000000 0114 Seam Premier Car& JEFFREY A PARKER Account Number: XXXX XXXX XXXX 3961 Page 2 of 2 69984 Call us at 1-800-917-7700 Go to www.seamoord.com Write to us at PO Box 6283 Sioux Fells, SD 57117-6283 Payment Due Date 06/30/09 Average Corresponding Periodic Rate Periodic Dairy ANNUAL D=Day FINANCE Rates 'Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $2,614.75 $2,547.07 29.99%* .0822%(D)* $67.00 EXTERNAL REGULAR $0.00 $0.00 29.99%* .0822%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 29.99%* .0822%(D)* $0.00 Days in Billing Period: 32 Effective ANNUAL PERCENTAGE RATE: 29.99% Minimum FINANCE CHARGE: $0.00 Cardmember News The Sale Date is the Transaction Date. The "Effective ANNUAL PERCENTAGE RATE" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. If the "Effective ANNUAL PERCENTAGE RATE" is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. Verification Lin Blumer I, , 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 unworn falsification to authorities. r ! Y Signature C-27164 Jeffrey A Parker Account number ending in 3961 1031 r r.: G` ?? •.?, 02-60 PC) ATN a& (Al (o'1 04 as3wog. SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor F k +?i OFD C F, C'T14 ?- RIFF OF ?FcLEUr "; OVARY 2009 KG0 24 Ali 8* 33 1 CLPa" ?U?? , Citibank (South Dakota) N.A. vs. Jeffrey A. Parker Case Number 2009-7958 SHERIFF'S RETURN OF SERVICE 11/1912009 02:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on Novembei 19, 2009 at 1420 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey A. Parker, by making known unto Courtney Parker, wife of defendant at 713 Manor 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 20, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ?ipuSheriff C) Co,intySua Shr;? ft. Ie;eosoft. !i:c.