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Home My WebLink About10-7214 ~~ ~_j7r i"~~ ,~, , . r ? .. ~._ ~ , Iz ~~ E~,. ` S ~~ Burton Neil & Associates, P.C. By: Daniel A. Payne, Esquire ID. N0.202294 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 BRICE JOHNSON NO. ~~ - 7~ ~ ~7 ~` l V ~ 1110 Louisa Lane, Mechanicsburg PA 17050 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 HIItING 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 S Carlisle, PA 17013 ~ ~ Telephone No. 717-249-3166 or 800-990-9108 DG,~ ~~a.~(~ C-41821 f ~~ ~~ ~ ~~~ ~ (~~l S1~3 Burton Neil & Associates, P.C. By: Daniel A. Payne, Esquire ID. N0.202294 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 BRICE JOHNSON 1110 Louisa Lane, Mechanicsburg PA 17050 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 Brice Johnson, who resides at 1110 Louisa Lane, 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) FRED MEYER credit card with account number ending in 1986 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 $2,080.31 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 $2,080.31, and the costs of this action. Burt Neil & Associates, P.C. 4 By: Daniel A. Payne, uire Attorney for Plaintiff 'The law firm of Burton Neil & Associates, P.C. is a debt collector. ~LITTMAw~~~ewr-~.wws Bt11~CI~t1Y un"J•'" ~ e ~••• J i W t L [ R t Account Statement Payment Due Date New Balance Your Account Number Amount Minimum Amount Past Due Payment Due Enclosed FEBRUARY 11 2010 $2 080.31 1986 $696.00 $808.00 $ tos7e tone w e t os a rv Please folbw payment instructions on reverse side. Minimum Payment Make checks payable to: Due must be received by 5:00 pm bcal time on Payment Due Date. LITTMAN &BARCLAY PLAN 010978 >~ BRICE JOHNSON s 1110 LOUISA LN nvrv MECHANICSBURG PA 17050-7290 ~nr~~~ur~~~nn~t~i~~nr~ni~n~r~~r~n~~nnn~~~~nt~n~t~ Print address changes above. ~~` LITTMAN &BARCLAY PLAN PROCESSING CENTER DES MOINES IA 50364-0001 t~t~r~~nnr~~n~~ni~n~~~nr~~nt~~nnn~~~t~n~r~nu : Please detach here. ® B1~C1~I~Y Send Notice of Billing Errors to: a.[rr[nwr ~~w~~~ws LITTMAN 8 BARCLAY PLAN PO BOX 653054, DALLAS TX 75265-3054 .R."•"""°"• °•~`°=B••• J W ~ " Customer Service: 1-888-316-8480 O O O ~" 0 z o r o 0 t~ i. i~ i~ ~_ ilk THISACCOUNTISSUEDBYGRBANK(SOUTHDAKOTA).N.A. ACCOUnt: 1S1AR Cloain Date Next Closi Date Caah Limit* Cash Available Credit Lina Credit Available Pravioua Balance Pa manta & Crodits Purchases/Other Char Caah Advances FINANCE CHARGES Naw Balanco -- CURRENTACTIVITY Transaction Date Transactions 01/11 LATE FEE 01!14 *BILLED FINANCE CHARGES* The "ANNUAL PERCENTAGE RATE on the account" includes all transaction and periodic finance charges imposed this billing period on all balances on which finance charges were imposed. Ifi the "ANNUAL PERCENTAGE RATE on the account° is N/A, no finance charges (after adjustments) were imposed this billing period. Finance charges may be accruing on promotional balances and may be billed to your account under the terms of the promotional offer. Refer to the corresponding APR for the APR that applies to each balance. Your late fee was based on an account balance of $1,989.87, which was your account balance on the Transaction Date for the fee. ANNUAL PERCENTAGE RATE on the account: Amount $ 39.00 $ 51.44 vrwtn~ rrcvwsvrrvna Previous cmea FINANCE Payments 8 Plan Minimum Monthly Accrued FINANCE Expiration Balance CH GES Credits Balance Payment CHARGES Date NO INT FOR 12MOS-PMT REQ $1 , 454.72 - - $1 , 454.72 - _ Balance Corresponding Days n Periodic Other Sut~ject to DAILY ANNUAL Billing FINANCE FINANCE Finance Charge Periodic Rate PERCENTAGE RATE Period CHARGES CHARGES NO INT FOR 12MOS-PMT REQ - 0.08216 (M) 29.99~V 31 - CASH ADVANCES - 0.08216~(M) 29.99AsV 31 - REGULAR REVOLVE CREDIT PLAN $2,019.61 0.08216~(M) 29.99~V 31 $51.44 Provioua Billing Period NO INT FOR 12MOS-PMT REQ - 0.08216 29.99 32 - NONE REGULAR REVOLVE CREDIT PLAN - 0.08216 29.99 32 - - `The Cash Limit is a portion of your Credit Line. V =RATE MAY VARY PAGE 1 OF 2 EXHIBIT S304FR CSEF01 2 OF Exclusively ours 6 t~ ~~,'~ ~f1,G ~th~GC` }ru~w CoufrcCGcoh.~" LOVE CREATE8 A PERFECT HEART ~~C%/~A/IG~ JEM/ELERS • ~~.~u ~ s~ ~^• fredmeyerj ewelers.com When we asked people to describe the perfect heort, there were o lot of answers. A heort that strives toward patience, k~dness, sefRessness. A heart that stays steadfast, even when the road gets rocky. A heart tfi'~cnows, through the ups and downs of life, that love endures. Because whether it's saters, a mother and child, best friends or soul mates - if is in loving that we create a perfect heart. Prices starting at 549.99 For the store nearest you please call 1-800-457-5977 LITTMAN ®JEWtLERS• '~..nu s~ ~.r~• littmanjewelers.com z N O o r a n 0 o e ~~ 0 iii ~_ Verification Abbie Motley I, , 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 aze true and correct upon my information and belief and aze made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. d Signature C-41821 Brice Johnson Account number ending in 1986 1027 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE y THE P0TIiGt j,), Sheriff : ; O` r r ?. n'f' Jody S Smith Chief Deputy Richard W Stewart Solicitor Citibank (South Dakota) N.A. vs. Brice Johnson PM 2: "01MBERLAIjD i. i T:I S Case Number 2010-7214 SHERIFF'S RETURN OF SERVICE 12/15/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brice Johnson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Brice Johnson. Request for service at 1110 Louisa Lane, Mechanicsburg, Pennsylvania 17050 the defendant was not found. The Mechanicsburg Postmaster has advised, Brice Johnson's new address is 548 Lincoln Street, Steelton, Pennsylvania 17113. SHERIFF COST: $42.00 SO ANSWERS, December 15, 2010 RONW R ANDERSON, SHERIFF N "I t JAS! 18 Pr i "Jfy£ ERI AND PEN - Y, - Burton Neil & Associates, P.C. By: Daniel A. Payne, Esquire ID. NO. 202294 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. BRICE JOHNSON Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7214 CIVIL : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action mahout prejudice. M&M A. Payne, Attorney for Plai The law firm of Burton Neil & Associates is a debt collector. , P.C C-41821