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Home My WebLink About10-0725 a ' 2010J3?L 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. RICHARD C THOMAS 155 Ken Lin Drive, Carlisle Pa 17015-9753 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 7d5 30v;t-rte, 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. Q 32 South Bedford Street Carlisle, PA 170134 a •oo P Telephone No. 717-249-3166 or 800-990-9108 ev_*' 009.0 C-31610 RT'E' a31o9?!0 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 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD C THOMAS 155 Ken Lin Drive, Carlisle Pa 17015-9753 Defendant NO. 10 _ 'oZ C'v urn : 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 Richard C Thomas, who resides at 155 Ken Lin Drive, Carlisle, 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) AT&T Universal credit card with account number ending in 1353 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 $25,956.38 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 $25,956.38, and the costs of this action. Burton Neil & Associates, P.C. By: 4tt7 uttell, EVsquir, Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. OR jig ?? 4 ? V N 1 1 A ji A N N V loot i N I_ji it ¦i e o: 01 18 ? s N N N y 40 N dM ow _ i?k04M WW Total Now Balance: SaRA"sa Mm 1hwn Amount Due: $29"" io Payment Due Datc 000000 PM 32 A 0 RICHARD C THOMAS 155 KIM LIN DR CARLISLE PA 17015-9753 cSd ?aa a a W QR Cf O a a 3 = eoe ei .9 - Z? N O W P P ut in N N if M O N ?or+ 0010 oleo II °o P 1+! M ?O b e N N O Q ~ Q O N N O A Y CC M M ?; .? Ins N 9 4 >? ? b ? c A c ._ E y?N9 ??S :0 :3 c Sim > $ U ? a y '??oV .A. q '?b Y 7MIlj ° C ' ly QB a F -C V a _ >oN i V aC f 1813.1 CMCk• M06 Yf N-NNIA10 ft%n%M$S WAM Wda dwt Pwdk to AT&T Universal Card l (G Aetxlrt! 353 Amount Inclowd: 14~= e. wdtIMM1M0 M wd" AT&T UNIVERSAL CARD P.O. BOX 182564 COLUMBUS, OH43216-2564 D(HIBIT?_ 4 e ? o m O F u 0 rc t rc'? ? N + + E M ? w Sn e ? g ?? N O T y j des Verification I Leola Phenix 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. - Q J Signatur r ` C-31610 Richard C Thomas Account number ending in 1353 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 177 Jody S Smith - ZQI??? 16 D 2; 5 Chief Deputy Edward L Schorpp r? a y di` Solicitor `' y- Citibank (South Dakota) N.A. Case Number vs. Richard C. Thomas 2010-725 SHERIFF'S RETURN OF SERVICE 02/09/2010 08:40 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on February 9, 2010 at 2040 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard C. Thomas, by making known unto Jeff Thomas, Brother of defendant at 155 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $44.20 February 11, 2010 SO ANSWERS, NY R ANDERSON, SHERIFF E yy 'P ? Deputy Sheri