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Home My WebLink About04-3836BURTON NEIL & ASSOCIATES, P.C. By: Burton Nell, Esquire 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 NortE Sioux Falls, SD Plaintiff CHAD MOWERY 17734 Cumberland Highway, Newburg PA 17240-9713 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth/n 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 C393 BURTON NEIL & ASSOCIATES, P.C. By: Button 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. 701 East 60th Street North, Sioux Falls, SD Plaintiff CHAD MOWERY 17734 Cumberland Highway, Newburg, PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant CIVIL AC"lION - LAW Complaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Chad Mowery, who resides at 17734 Cumberland Highway, Newburg, 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 consmer credit to the defendant by means of a credit card with account number 5424180189588871 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/ts books of account. 6. Plaimiffmailed 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 pla/ntiffon the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $3,733.81. Wherefore, plaintiff demands judgment against defendant for the sum of $3,733.81, and the costs of this action. BURTONIL &~?OCIATES, P.C. B~Esquire -- Attorne31 for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 02/18/04 $4481.81 $246.00 $[TE:KC-CL TM:CO-5000 AC[D:KCB7150 CHAD NOWERY ATTNY ACCOUNT-CODE=CXBE NEWBURG 17Z40-9713000 PA P.O. BOX 8117 S HACKENSACK, NJ 07606-8117 Citr Platinum Select* Card 5424 1801 8958 8871 01/27/2004 $4740 $0 $0.00 + 1-800-950-5114 ~a,,.s,m~,~m~.~ BOX 6500 *af~da~km,q~p SIOUX FALLS, SO $Z500 $0 $448~. 81 $~48.00 + $98.00 : $Z46.00 Your account is two months past due and your credit privileqes have been discontinued. Please call the toll-free number shown above, ~onday - Friday. 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. If you have a)ready sent us th)s payment, thank you. Our records show home phone 717-423-5569 and business phone 717-53Z-2857. Please update above coupon if incorrect. Previous (+) Purchases (-) Payments Account Summary Balance & Advances & Credits PURCHASES $2,031.12 $0, O0 ~0. O0 ~DVANCE5 ~2. 450.69 $0. O0 $0. O0 FOTAL 54,481.81 $0. O0 $0. O0 tate Summery Balance Subjectto Periodic Finance Charqe Rate JRCHASES ~tandard Purch $0.00 0,0T668~(0) )VANC£S ;tandard Adv $2,480.04 0.07665%(D) (+) FINANCE (=) New CHARGE Balance I 0. O0 $2,031.12 0,00 $2,450.69 0.00 $4,481.8! Nominal ANNUAL APR PERCENTAGE RATE 27,990% Z7.990% VERIFICATION TtlPtl CP055_ is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiffin 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 unsworn falsification to authorities. Chad Mowery 5424180189588871 BURTON NElL & 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. Plaintiff VS. CHAD MOWERY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3836 : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTON ~[L & ASSOCIATES, P.C. BY: Burton Neil, Esquire Attorney for Plaintiff The law finn of Burton Neil & Associates is a debt collector. C393