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Home My WebLink About09-8704i Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 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 JASON UHAZIE : NO. oil 1 T rM 440 Waterleaf Court, Mechanicsburg Pa 17050-2489 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-25045 M Complaint Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 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. JASON UHAZIE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 440 Waterleaf Court, Mechanicsburg Pa 17050-2489 Defendant : CIVIL ACTION - LAW 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Jason Uhazie, who resides at 440 Waterleaf Court, 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 credit card with account number ending in 0100 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 $6,034.38 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 $6,034.38, and the costs of this action. Burton Neitr Associates, P.C. By: o eil, Esquire Attorney` for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 02/16/09 $6034.38 $6034.38 SITE:KC-CL TM:CO-5000 ACID:KCB0219 t #>_a == a 9 s =ssR? ss 04/30/09 22:04:29 CITI CARDS PO BOX 183051 JASON UHAZIE COLUMBUS, OH 440 WATERLEAF CT 43218-3051 MECHANICSBURG PA 17050-2489000 " o C ti• Advantage World MasterCard Citi . AAdvantage is a registered tradeeark of American Airlines, Inc. Account Number 0100 Y lfY?Cl: Revolving Available Revolving 1-800-566-5000 Credit Line Credit Line Cash Advance Limit Available Cash Limit New Balance $5000 $0 $1500 $0 $6034.38 BOX 6062 Statement/ Amount Over Purch/Adv Minimum SIOUX FALLS, SO Closing Date Revolving Credit Line Past Due Minimum Duo Amount Due 57117 01/22/2009 $1034.38 $1220.13 $244.75 $6034.38 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 1122 LATE FEE - DEC PAYMENT PAST DUE 39.00 66 0000 0000000000 1122 PURCHASES*FINANCE CHARGE*PERIODIC RATE 145.75 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (01/16/09), which was $5,849.63. The pur/adv min due displayed above includes any transactions that exceed your revolving credit line. Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Our records show home. Phone 717-443-0089 and business phone 717-591-5707. Please update coupon f incorrect. Credit Protector Your account protection enrollment has been cancelled on your account effective 12/22/2008. Account Summary Previous Balance (+) Purchases & Advances (-) Payments & Credits (+) FINANCE CHARGE (=) New' Balance PURCHASES $5,849.63 $39.00 0.00 $145.75 $6,034.38 ADVANCES $0.00 $0.00 0.00 1 $0.00 $0.00 TOTAL $5,849.63 $39.00 0.00 $145.75 $6,034.38 Da s This Billing Period: 31 Rate Summary Balance Subject to Periodic omina ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $5,919.85 0.07942%(D) 28.990% 28.990% ADVANCES EXHIBIT Standard Adv $0.00 0.07942%(D) 28.990% 28.990% Verification AAA . r- n ,. _ 1 I, I ?W L? (, LkA k , am employed by Citicorp Credit Services, Inc. (USA) (hereafter Al), 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. C-25045 Jason Uhazie Account number ending in 0100 1000 0 -s FiL 20U9 DEC 1 8 11: 36 *9a.oo po Arn e,,:* io&sto P-T* a-6 sa-01 ~,- ?~«,ri~~ ~~ G~i ~~ ~~ -. ~~~ _, 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. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASON UHAZIE Defendant NO. 09-8704 Civil Term CIVIL ACTION -LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: ~'~ '~ Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-25045