The URL can be used to link to this page

Home My WebLink About10-1208" n r FILED 20 10 FEB 22 Pi'l 12: S 1 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. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. PATTI HAUT : NO. /O - 2O8 n- U? L`T l? l l 1601 Lindsay Lot Road, Shippensburg PA 172578598 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 09a • oo CL 47` Carlisle, PA 17013 ell ,?,o33?y? Telephone No. 717-249-3166 or 800-990-9108 / C-32098 k11_ 'Z-nett ' s Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. p. / NO. PATTI HAUT 1601 Lindsay Lot Road, Shippensburg PA 172578598 Defendant CIVIL ACTION - LAW 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. 701 East 60th Street N Sioux Falls, SD 57117 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Patti Haut, who resides at 1601 Lindsay Lot Road, Shippensburg, 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 3448 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 $6,471.19 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 $6,471.19, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. PATTI HAUT 1601 LINDSAY SHIPPENSBURG 17257-8598000 09/22/09 $6471.19 $6471.19 SITE:KC-CL TM:CO-5000 ACID:IRB0021 i:# .. a 1E ::; :.#3i k# ##as 12/23/09 20:54:39 CITI CARDS PO BOX 183051 COLUMBUS, OH LOT RD 43218-3051 PA C? * ti0 Citi Card 3448 Customer Servke: 1-800-566-5000 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limit New Balance $5400 $0 $3300 $0 $6471.19 BOX 6500 SIOUX FALLS, SO Statement/ Closiny Data Amount Over Credit Line Past Due Purch/Adv Inimum Due Minimum Amount Due 57117 08/26/2009 $1071.19 $1100.42 249.40 $64T1.19 Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 8/26 LATE FEE - JUL PAYMENT PAST DUE 39.00 66 0000 0000000000 8/26 PURCHASES*FINANCE CHARGE*PERIODIC RATE 144.14 84 0000 0000000000 Standard Adv 8/26 ADVANCES*FINANCE CHARGE*PERIODIC RATE 2.26 84 0000 0000000000 Your late fee was based on your account balance as of the payment due date (08/20/09), which was $6,285.79. 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. Account Summary Previous (+) Purchases {-) Payments (+) FINANCE =) New Balance & Advances & C redits CHARGE Balance PURCHASES $6,188.86 $39.00 0.00 $144.14 $6,372.00 ADVANCES $96.93 $0.00 0.00 1 $2.26 $99.19 TOTAL $6,285.79 $39.00 0.00 $146.40 $6,471.19 Days Th is Billing Period: 29 Rate Summary Balance Subject to Periodic omina ANNUAL Finance Charg e Rate APR PERCE NTAGE RATE PURCHASES Standard Purch $6,258.17 0.07942%(D) 28.990% 28.990% ADVANCES Standard Adv $98.02 0.07942%(D) 28.990% 28.990% 4:::?t in- M X W a Verification 1, Abbie madit , 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. Si ature C-32098 Patti Haut Account number ending in 3448 1000 ?f-+ Pt in i r TApy 2010 MAR 12 ('ll 1: I I GUP?' A 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 PATTI HAUT Defendant : NO. 10-1208 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-32098