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Home My WebLink About04-3830BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 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 North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CARL E SNYDER SR NO. o4- 3 FJ 3? 201 York Road, New Cumberland PA 17070-0545 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 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 C-1102 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 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 North, Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CARL E SNYDER SR 201 York Road, New Cumberland, PA Defendant : 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 Falls, South Dakota. 2. The defendant is Carl E Snyder Sr, who resides at 201 York Road, New Cumberland, 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 account number 43 053 1 0060294 1 77 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running 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 period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including 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 $6,450.58. Wherefore, plaintiff demands judgment against defendant for the sum of $6,450.58, and the costs of this action. BUR BY° ?Bur?on eil, Esquire Attorn _ for Plaintiff P.C. The law firm of Burton Neil & Associates, P.C. is a debt collector. 05/03/04 $6450.58 $9999.99 SITE:KC-CL TM:C0-5000 ACID:KCB7150 NNNOW NEw`Wt?! `:?` "AM 04/15/04 17:39:14: CITI CARDS CARL E SNYDER SR P.O. BOX 8106 DEBBIE J SNYDER S HACKENSACK, NJ ATTNY ACCOUNT-CODE=LA34 07606-8106 NEW CUMBERLND PA 17070-0545000 Gold Citia' Card Amount Number 4305 3100 6029 4177 Customer Service: 1-800-950-5114 Total Credit Line $5530 PO BOX 142319 m D t IRVING, TX alo D Clo ate 04/ a04 / 75014-2319 08 2 Sale Date Post Date Reference Number Available Credit Line Cash Advance Limit Available Cash Limit $0 $3000 $0 Amount Over Porch/Adv Credit Line Past Due minimum Duo $920.58 $3757.00 $161.00 Activity Sinn Last Statement 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. CI is New Balance $6450.58 Minimum Amount Due $6450.58 Amount Previous (+) Purchases (-) Payments (+) FINANCE (=) New Account Summary Balance & Advances &Credits CHARGE Balance PURCHASE S s 3 020.58 0.00 0 00 0 Go 3 20.58 '0 AADVANCES f 3:4 0.00 1 0.00 1 1 0100 3 430.00 1 TOT 56,4 0 .00 0.00 0.00 6,450 58 Days This Billing Period: 30 Rate Summary Balance Subject to Periodic Nominal ANNUAL fff??\ Finance Charge Rate APR PERCENTAGE RATE Ly PURCHASES Standard Purch $0.00 0.00000%(D) 0.000% EXHIBIT000% ADVANCES Standard Ally, $3,430.00 0 .00000%(D) 0.000% 0.000% VERIFICATION Tara Cross is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's 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 unworn falsification to authorities. Date: 71 t l eq ??r2k lJ A (off Carl E Snyder Sr 4305310060294177 ??) ??? -s_ ? ?., ?? ??> ?_ r, '- ._-? '\. ` ? ?. v \ C? .. ff}TI )1 I (\ ? _ ? ` . r c/?. C? SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-03830 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SNYDER CARL E SR R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SNYDER CARL E SR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 201 YORK ROAD NEW CUMBERLAND, PA 17070 SNYDER CARL E SR ADDRESS IS LOCATED IN YORK COUNTY. NOT FOUND , as to Sheriff's Costs: So answers' Docketing 18.00 Service .00 Affidavit .00 R. Thomas line - Surcharge 10.00 Sheriff of Cumberland County .00 28.00 BURTON NEIL & ASSOC 08/09/2004 Sworn and subscribed to before me this day of 02 aoll A.D. Prot rYOtary Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3830 CARL E SNYDER SR Defendant CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without ice. urton Nei ociates, P.C. By: - -? u to Neil, Esquire Attom for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-1102 ?_ ? _ ? ?c? , ?? ? ? ?. ` i .-? ?. r•a -- _." ?: - ;'i __? r ?: