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Home My WebLink About10-6635r FILEDi f'-OFFICE OF TI I OTHONOTARY 2010 OCT 19 AM 10: 29 CUMBERLAND COUNTY PENNSYLVANIA 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. WILLIAM DICKENS 406 Keller St, Mechanicsburg PA 17055 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 10 - (x1035 Cw,) Tierra : 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 *ga,00 Pb AITY C-41929 018(o4Q3 0 O?ggSal r Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. WILLIAM DICKENS 406 Keller Street, Mechanicsburg PA 17055 Defendant CIVIL ACTION - LAW 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is William Dickens, who resides at 406 Keller Street, 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(n) CITI MASTERCARD credit card with account number ending in 8482 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 $3,172.47 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 $3,172.47, and the costs of this action. Burton Neil & Associate C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. A. 06/20/10 $3172.47 $3172.47 SITE:KC-CL TM:CO-5000 ACID:IRB8606 =• 08/17/10 22:10:02: #:c87F?: i:: :;=:a1?i•':::: :y:=?6$? fY?1Fiy3S?::`:: CITI CARDS PO BOX 183051 WILLIAM DICKENS COLUMBUS, OH 406 W KELLER ST 43218-3051 MECHANICSBURG PA 17055-3731000 Citi® BronzeIA''Advanta e* Card ti AAdvantage is a registered tradenm rk of axierican dines, Inc. Account Number: 8482 Customer Service: 1-800-756-4000 www.citicards.com BOX 6500 SIOUX FALLS, SD 57117 Summary of Account Activity Previous Balance $3,052.19 Payments - 0.00 Other Credits - 0.00 Purchases + 0.00 1 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 39.00 Interest Charged + 81.28 New Balance $3,172.47 Past Due Amount $761.67 Amt. Over Credit Limit $542.47 Credit Limit $2,630 Available Credit $0 Cash Advance Limit $1,500 Available Cash Limit 0 Statement Closing Date 05/24/2010 Days in Billing cycle 32 Pavment Information New Balance 3,172.47 Minimum Payment Due 3,172.47 Payment Due Date 06/20/2010 Late Payment Warning: If we do not receive your minimum pa ment by the date listed above, you may have to pay up to a 39 late fee and your APRs may be increased up to the variable Penalty APR of 29.99%. Minimum Payment Warning: If you make only the minimum pa ment each period, lo will pay more in interest and it will take you longer to Dav off vour balance. For example: If you make no You will pay And you will end additional charges off the balance up paying an using this card shown on this estimated total and each month you statement in of... pay... about... Only the minimum payment 1 month(s) $3,172 If you would like information about credit counseling services, call 1-877-337-8188. Fees 5/24 LATE FEE - APR PAYMENT PAST DUE 66 0000 TOTAL FEES FOR THIS PERIOD Interest Char d 5/24 PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 5/24 PURCHASES*INTEREST CHARGE*PERIODIC RATE 84 0000 TOTAL INTEREST FOR THIS PERIOD Your late fee was based on your account balance as of the payment due date (05/20/10), which was $3,052.19. 39.00 0000000000 39.00 6.57 0000000000 74.71 0000000000 81.28 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. EXHIBIT 14 WILLIAM DICKENS Sale Date Post Date Reference Number Activity Since Last Statement Amount Rate Summary Balance Subject to Periodic Nominal ANNUAL Interest Charge Rate APR PERCENTAGE RATE Standard Purch $249.90 0.08216%(D) 29.990% 29.990% Offer 4 $2,841.48 0.08216%(D) 29.990% 29.990% DVANCES Standard Adv $0.00 0.08216%(D) 29.990% 29.990% Verification I, Ahhie MAt1e , 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. 1 WY 141 1 Signa C-41929 William Dickens Account number ending in 8482 1000 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. WILLIAM DICKENS Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6335 CIVIL, T CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Assoc' to , .C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-41929 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard MI Stewart Solicitor Citibank; (South Dakota) N.A. vs Case Number . William M. Dickens 2010-6635 SHERIFF'S RETURN OF SERVICE 11/02/2010 03:56 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 2, 2010 at 1556 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William M. Dickens, by making known unto himself personally, at 406 W. Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same, i 9f !6 MA O AUG , D PU SHERIFF COST: $37.00 November 05, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF