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Home My WebLink About04-3820BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 1060 Andrew Drive, Suite: 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60TH STREET NORTH SIOUX FALLS, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CARL BERLIN 8 SLATE I-fiLL ROAD CAMP HILL, PA NO. Ott· 3~'o/o ~ ~[-t~ CIVIL ACTION - LAW Defendant 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 Association 32 S. Bedford Street, Carlisle, PA 17013 800-990-9108 10018.034.6272 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60TH STREET NORTH SIOUX FALLS, SOUTH DAKOTA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CARL BERLIN 8 SLATE HILL ROAD CAMP HILL, PENNSYLVANIA Defendant NO. 0~/- : CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Fails, South Dakota. 2. The defendant is CARL BERLIN, who resides at 8 SLATE HILL ROAD CAMP HILL, CUMBERLAND County, Pennsylvania. 3. Plaintiff, a national banking association, engages 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 an account number 5491130143308849 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and nmning record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing cycle. 7. Defendant received the monthly statements from plaintiff for the credit card account, including the statement attached as Exhibit A, without protest, dispute or objection. 8. Defendant, by not protesting, disputing, or objecting to the statements includ'mg the Exhibit A statement, thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated less credits, if any issued subsequent to the Exhibit A statement, is $7533.76 Wherefore, plaintiff demands judgment against the defendant for the sum of $7533.76 and the costs of this action. ~ TO~& ASSOCIATES, P.C. Burtod Neil, Esquire Attorney for Plaintiff In making this commurdcation, we advise our finn is a debt collector. Your AT&T U versa/Card Statement August 11 - Ssptsmber 10, 2003 Page 1 o! 3 CARL BERLIN Account 5491 13~1 4330 8849 Calling Card + Pill No Annual Fee/Platinum Card How To Re,ch Us Account Online: www.univer salcard.com Customer Service: 1 800 423-4343 or w~ite Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 Minimum Payment Due ......................................... $846.99 Due Dste~ ................................................. October 8, 2~13 Amount Past Due .................................................. $471.61 Credit Line ......................................................... $11,410.00 Available Credit ............................................................ $0.00 Cash Advance Limit ................................................ $500.00 Available Cash Advance Limit .................................... $0.00 E[~vious Ba~anoe 7~28 65 . .Eayments and Adiustment~ 0 00 Master Card Activity 205 48 Total AT&T ,Cervices 0 00 New Balance $7,534.13 Note: Detailed aciivity starts on page 3. Credit Protector Your enrollment has been cancelled on your account effective 08/11/~003. Your account is now 3 MONTHS PAST OUE and currently closed. Please call the toll-free number shown above to learn about our special payment options. Our records show home phone 717-737-2597 and business phone 717-763-1538. Please update remittance coupon if incorrect. Too much debt and looking for a solution? If you are a homeowner, call CitiFinancial Mortgage at 1-888-722-9236 to apply for a home equity debt consolidation loan. Your preferred status number is 81212. Payment Record Amount Psid: _ Date Paid: Check Number: Please fl311ow payrneot instructions outli~ed in the 'Important InstrucUons E)r Making Payments' section pi tim statement. ACCOUnt Number 5491 1301 4330 6849 10106103 $7,534.13 cay I,,,lll.,lll,,.,,ll,.,lll,,,ll,,I,,,hl.,,llll,,.l,,I,,I,,ll CAEL ~EELIN 8 SLATE HILL RD CANP HILL PA 17011--7821 lil,,,h,,hll.lh,,.ll.h,l,,,hllh,.ll,,,l,l,I AT&T UNIVERSAL CARD PO BOX 8206 SOUTH HACKENSACK NJ 07606-8206 Ihl,h,lllllh,l,hl,l,lllll,,ll.lll,l,ll.hllh.hllhl,II 54911301433088490000646990007534132 EXHIBIT CARL BERLIN Account 5491 1301 4330 8849 August 11 - September 10, 2003 P~,ge 2 of 3 In the return envelope, please: Enck~e yom, cbcckor mm-.~ ord.. Include your account number and name on the front of your check or money order. Please, no cash or foreign currency. l~tdes~ ~m' pa~m~tt cot~x~. Do not staple or tape it to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. ~ARL BER'LIN Account ~491 1301 4330 8849 August 11 - September 10~ 2003 Page 3 of 3 Fees ................................................................................................................................................................ 35.00 Total MasterCard Activity ....................................................................................................................... $205.48 Total ~asterCar6 Purchases ............................................. $0.00 Cash Advance Limit ................................ $500,00* *This represents a portion of your total credit line. PURCHASES CASH ADYANC£S Ib t x $7,410 72 $17048 + $000 27.990% x $00~ = $000 + $000 27.990% Total FtNANCE CHARGE $170.48 Standard Purch 09/10 ~EE - AUG PAYM~[E ~otal Fees $35.00 AT&T Universal Calling Card Calls ......................................................................................................... $0.00 Verification TOI~O C1~°$$ is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Cifigroup, the within Plaintiff in this action. She/he verifies that the statcmaents of fact made in the foregoing Complaint are true and correct to the best of her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: Account number: 5491130143308849 Defendant: CARL BERLIN BURTON NElL & ASSOCIATES, P.C. BY: Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2 120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff VS. CARL BERLIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLANT) COUNTY, PENNSYLVANIA : NO. 04-3820 : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUe_ TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTON NF~L & ASSOCIATES, P.C. t~ffri~["]~l-t~il, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector 10018.034.6272 SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-03820 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS BERLIN CARL R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT BERLIN CARL unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , BERLIN CARL 8 SLATE HILL ROAD CAMP HILL, PA 17011 GIVEN ADDRESS IS CARL JR. , NOT FOUND , as to CARL SR'S ADDRESS IS 3399 E NORMANDY PARK DRIVE APT M2 MEDINA, OH 44256. Sheriff's Costs: Docketing 18.00 Service 11.10 Not Found 5.00 Surcharge 10.00 .00 44.10 So answers: R. Thomas Kline Sheriff of Cumberland County BURTON NEIL & ASSOC 08/11/2004 Sworn and subscribed to before me this /~ day of .~6..~. ~ ~o,,~ c/' A.D. pro~ot ar~ ~"~