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HomeMy WebLinkAbout10-4140 V4 RM-WPOE' Au' (tJ1G: THE PRTHMTARY 1010 JUN 21 PN 1: 22 "M 40=w 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 Plaintiff V. RUSSEL M SUTTON 1924 Sterretts Gap Avenue Carlisle PA 17013-1060 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 4140 FIE" 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 800-990-9108x.00 ?p ATY'Y C-33450 a* 7AA ?'? a?l4 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RUSSEL M SUTTON 1924 Sterretts Gap Avenue Carlisle PA 17013-1060 : NO. 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 Russel M Sutton, who resides at 1924 Sterretts Gap Avenue, 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 credit card with account number ending in 6317 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 $8,996.90 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 $8,996.90, and the costs of this action. Burton Neil & Associates, P. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 01/12/10 RUSSEL M SUTTON 1924 STERRETTS GAP AVE CARLISLE 17013-1060000 $8996.90 $587.25 SITE:KC-CL TM:CO-5000 ACID:IRB4980 02/11/10 21:44:34: CITI CARDS PO BOX 183051 COLUMBUS, OH 43218-3051 PA Citi' Driver's Edge® Platinum Select Card-Options Rbts Account Number 6317 Customer Service: 1-800-866-9900 BOX 6062 SIOUX FALLS, SO 57117 C ti Minimum Payment Due Payment Due Date New Balance $587.25 1 01/12/2010 I $8,996.90 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a $39 late fee and your APRs may be increased up to the Penalty APR of 29.99%,. Credit Limit Available Credit Cash Advance Limit Available Cash Limit Statement Closing Date Days in Billing Cycle $23,000 $14,003 $10,000 $10,000 12/16/2009 30 iummary of Account Activity Previous Balance Payments Other Credits Purchases Balance Transfers Cash Advances $8,933.35 $0.00 $0.00 $39.00 $0.00 $0.00 Amt Over Credit Line Past Due Amount New Balance $0.00 $434.70 $8,996.90 Post Date Reference Number Activity Since Last Statement Amount St Purch d 12/16 LATE FEE - NOV PAYMENT PAST DUE 39.00 12/16 66 0000 PURCHASES*FINANCE CHARGE*PERIODIC RATE 0000000000 3.02 84 0000 0000000000 12/16 Balance Transfer - Charged To Offer 4 * PURCHASES FINANCE CHARGE*PERIODIC RATE 1,72 84 0000 0000000000 12/16 Balance Transfer - Charged To Offer 5 * PURCHASES FINANCE CHARGE*PERIODIC RATE ,82 84 0000 0000000000 12/16 q Balance Transfer - Cha To Of 6 * e PURCHASES FINANCE CHARGE*PERIODIC RATE 6 23 84 0000 , 0000000000 12/16 Balance Transfer - Charged To Offer 10 * PURCHASES FINANCE CHARGE*PERIODIC RATE 12 76 84 0000 . 0000000000 DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned 0.00 Ad"ustments / Expired -0.09 NE DRIVER'S EDGE REBATES -0.09 Previous Balance EXHIBIT Purchase Rebates Earned 1.44 PREVIOUS DRIVER'S EDGE REBATES 1.44 Submitted Redeemable Purchase Rebates 1.35 TOTAL DRIVER'S EDGE REBATES 1.35 0 RUSSEL M SUTTON Sale Date Post Date Reference Number Activity Since Last Statement Amount Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Citi Driver's Edge Card Options rebates expire 5 years after they are earned. Expired rebates will be deducted from your rebate account. 0.09 rebates expired on DECEMBER 16, 2009 0.09 rebates will expire on JANUARY 18, 2010 Your late fee was based on your account balance as of the payment due date (12/14/09), which was $8,933.35. Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am 5 pm, Central Time. Contact us today - we can help! Go online at www.paymentsolutions.citicar(is.com to login or register. Account Summary revious (+ Purchases (- Payments (+) FINANCE =) New Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES $8,933.35 $0 00 $39.00 0.00 $0 00 $24.55 $8,996.90 TOTAL . $8,933.35 . 0.00 $39.00 10.00 $0.00 $24.55 $0.00 $8,996.90 Days This Billing Period: 30 Rate Summary Balance Subject to Finance Charge Periodic Rate Nominal ANNUAL PURCHASES APR PERCENTAGE RATE Standard Purch Offer 4 184.10 0.05477%(D) 19.990% 19.990% Offer 5 699.89 1332.29 0.00819%(D) 0.00819%(D) 2.990% 2 990% 2.990% Offer 6 Offer 10 62,536.24 192 55 68 0.00819%(D) 0 00819% D . 2.990% 2.990% 2.990% ADVANCES , . . ( ) 2.990% 2.990% Standard Adv $0.00 0.06025%(D) 21.990% 21.990% Verification Lisa Blumer 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. Signature C-33450 Russel M Sutton Account number ending in 6317 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~xtr of ~u+Nbrr~~~~ C~ ; r, _ ~,.. q~~IGE "~: Tag SrsERi~F -, 4-I~f~' ; ,. , , ~ ~~~J ^I~- 1 2QI0 ,~~~ ~ ~ ~~ 9~ t1~3 Cl'Pv~{ ~~dTY Citibank (South Dakota) N.A. vs. Case Number Russel Morrow Sutton 2010-4140 SHERIFF'S RETURN OF SERVICE 07/14/2010 03:54 PM -Michael Ba rick, Deputy Sheriff, who being duly sworn according to law, states that on July 14, 2010 at 1554 hours, h served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rus I Morrow Sutton, by making known unto himself personally, at 1924 Sterretts Gap Avenue, Carlisle, Cum erland County, Pennsylvania 17013 its contents and at the same time handing to him personally the sai true and correct copy of the same. SHERIFF COST: $33.40 July 15, 2010 MI HAEL BARRIC , D PUTY SO ANSWERS, (:~ RON R ANDERSON, SHERIFF lc) CountySuite Shenif, Teleosoft. Inc.