The URL can be used to link to this page

Home My WebLink About10-2528Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. CARD 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. RONALD L ALLANDER 12 Windsor Way, Camp Hill PA 17011-1750 Defendant P1t}-C;?rICE t?`iF THi P T !OV)TAPY 1010 APR 16 PH 3: 13 CUh9 caluwy r"Etti1vS`r'0? NI A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ID - o1bo1B 0-'W't i 7e-rM 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 s Telephone No. 717-249-3166 or 800-990-9108 *ga,po Pb ATtV C-21574 0,0'7, 2834 Q,*940(c'/S Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. RONALD L ALLANDER 12 Windsor Way, Camp Hill PA 17011-1750 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 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 Ronald L Allander, who resides at 12 Windsor Way, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including commercial lending through the issuance of credit cards. 4. Plaintiff furnished commercial credit to the defendant by means of a(n) Citi Profession credit card with account number ending in 7428 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 $4,663.05 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 $4,663.05, and the costs of this action. Burton DF61V Associafes. P.C. By: Ya .Ypids'lein, Esquire A ev for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt Citi Ptofessionaig" Card November 5 - December 4, 2008 RONALD L AL NDER Accou 7428 Statement/Closing Date: 12/04/08 Quick Reference Minimum Payment 466305 Payment Due Date* December 24, 2008 *Payment must be. received by 5:00 pm Ivcal time on the payment due date. Amount Past Due 988.22 Amount Over Limit 663.05 Amount Over Limit Total Credit Line 4,000.00 Available Credit Line 0.00 Cash Advance Limit 1,200.00 Available Cash Advance Limit 0.00 Account Summa Previous Balance 4,518.81 Payments and Adjustments 0.00 Purchases 39.00 Cash Advances 0.00 Fees & Finance Charges 105.24 New Balance $4,663.05 Page 1 of 2 Now to Reach Us wO9@ ftewh cilia Citibank Customer Service Ctr BOX 6060 SKH&AKE19, 3l%DW53-6000 1-800-ase-713= Cardmember News Your late fee was based on your account balance as of the payment due date (11/28/08), which was $4,518.81. Help is available! Please call the toll-free number to learn about our special payment jh 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. / t I I Our records show home phone 717-732-6442 and j business phone 000-000-0000. Please update [ Coupon if incorrect. Purchase Categories Total Purchases $0.00 Contact us today - we can help! Go online at: www.paynientsoltitions.citicards.com to login or register. date paid amount paid check t# Please follow payment Instructions outlined In the "Important Instructions for Making Payments" section of the statement. Your Account Number 05528150022407428466305999995912 428 Ne"a Eller AmouW,?,t Enclosed Pavmmnt Must Be Recokod By Yow 616eatsnee tdlmmkra i Amount w I F$ 24N PM 32 A 1 AR7322225 RONALD L ALLANDER CITI CARDS 12 WINDSOR WAY PO BOX 183053 COLUMBUS, OH 43218.3053 CAMP HILL PA 17011-1750 EXHIBIT -k November 5 - December 4, 2008 RONAL Accoun 7428 Page 2 of 2 Statemen osing a e: 04/08 Payments and Adjustments Salo Date Post Date Activity Amount Total Payments and Adjustments $0.00 Purchases Salo Date Post Date Activity Amount Total Purchases $0.00 Cash Advances Sale Date Post Date Activity Amount Total Cash Advances $0.00 Fees & Finance Charces Standard Purch Sale Date Post Date Activity Amount 12/04 LATE FEE - NOV PAYMENT PAST DUE $39.00 12104 PURCHASES*FINANCE CHARGE*PERIODIC RATE $105.24 Total Fees & Finance Charges $144.24 Finance Chagae Information Days In Balance Periodic Transaction ANNUAL Nominal Periodic x Billing x Subject to = FINANCE + Fee/FINANCE PERCENTAGE APR Rate Period Finance Charge CHARGE CHARGE RATE PURCHASES Standard Purch 28.990% .07942%(D) x 29 x $4,569.41 = $105.24 + $0.00 28.990% CASH ADVANCES Standard Adv 28.990% .07942%(D) x 29 x $0.00 = $0.00 + $0.00 28.990% Total FINANCE CHARGE = $105.24 Verification 1, Jennifer Shepherd am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services on its behalf. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Signa e C-21574 Ronald L Allander Account number ending in 7428 1023 OT Rit VIr1 - E 1 CjTjjQN A"' 2013 SEP 12 R1 E• l,' CUMBERLAND COUNTY PE NNYLVNA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-2528 CIVIL TERM RONALD L ALLANDER Defendant : CIVIL ACTION - LAW Statement of Intention to Proceed To the Court: Plaintiff, CITIBANK(SOUTH DAKOTA),N.A., intends to proceed with the above captioned matter. BURTON N OCIATES, P.C. Date: By: Yale e nstein, Esquire Att y for mtiff In making this communication, we advise our firm is a debt c lector. C-21574 n� C-21574/324 F'k ED-OFFIC' O THE PRO T HONOTA 2013 SEP 18 AM 11: 32 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil &Associates, P.C. By: Yale D. Weinstein, Esquire ID.NO. 89678 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 Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 10-2528 CIVIL TERM RONALD L ALLANDER Defendant : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinue . Burt Neil sociates, P.C. B : al . Wei in, Esquire A e r Plaintiff This is an attempt to collect a debt, and any informatio btained will be used for that purpose. This communication is from a debt collector.