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Home My WebLink About11-3145, I ' LL "DI, Fi r HE P 2911 MAP 21 Pit 1: ' 4 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 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEWART A MCGARVEY NO. I I ' '1 S 2252 Dover Court Mechanicsburg PA 170555700 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. C-49064 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 (3? au* 14 ga00 Pda*i 0, VP O'4g5 V *i9!5108 o 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. STEWART A MCGARVEY 2252 Dover Court Mechanicsburg PA 170555700 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 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 Stewart A McGarvey, who resides at 2252 Dover Court, 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 9735 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 $10,584.05 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 $10,584.05, and the costs of this action. Burton Neil & Associate By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Tm 1. W K W --I O X N :E 0 Z 0;0 O ?r >; ? ?1 n C n M-4ow 0 >> y <o m O ? Ln J 0 0 non 0b-4 Cmn r O > CD X z C O N O N O N 2 01 AA N 0) P A N w N 3 N z O ?. O F ra w lA W m a O m` UOi .ac toil m 'v m a? 3 -3 n" n o? m 0 m? n 3n w t'+ o A? 3 4 n x n rt l7 m n 1A I u O x 2 S How To Reach Us www.cltlcards.com 1-800-756-4000 Account Member Customer Service Customer STEWART A MCGARVEY Account Activity Account Number BOX 6500 SIOUX F ALLS, SD Oct 27-Nov 24, 2010 -9735 Member since 2002 57117 Minimum Payment Due: New Balance: Summary of Account Activity $10,584.05 $10,584.05 Previous Balance $10,300.78 Fees Payment Due Date: Payments -$000 Sale Post Description Amount 12/22/2010 Payment must beracehiedby 5:00 PM Other Credits $0.00 11124 1. ATEFEE -OCTPAYMENTPASTDUE 35.00 local time on the payment due date. PurCliases +$0.00. TOTAL FEES FOR THIS PERIOD 35.00 Late Payment Warning: If we do not receive your gash Advances +$0.00 minimum payment by the date listed above, you may Fe11 1 es Charged +$35 00 have to pay a late fee of up to $35 and your APRs may be increased up to the variable Penalty APR of 29.9996. Interest Charged . +$248.27 Interest Charged New Balance 10,584.05 Post Description Amount Minimum Payment Warning: If you make only the 11124 INTEREST CHARGED TO STANDARD ADV 31.96 minimum payment each period, you will pay more in Past Due Amount $2,172.92 1124 INTEREST CHARGED TO STANDARD PORCH 210 40 interest and it will take you longer to pay off your . balance. For example: Amt. Over Credit Limit $584.05 11124 INTEREST CHARGED TO PURCH/ADV-11/05. 5.91 If you make no You well pay off And you well end TOTAL INTEREST FOR THIS PERIOD 248.27 additional charges the balance shown ! up paying an Credit Limit il edit bl C A $10,000 using this card and each month you pay. on this statement ... In about._ estimated total of... r va a e Cash Au mince Lin it $0 $3,500 2010 Totals Year-to-Date Onlythe mum 1 month(s) $10 ,534 Available Cash Limit $0 - --- ----- -------------- -- -------- Total fees charged In 2010 $364.00 payment Statement Closing Date 11/24/2010 For information about cre dit coonseiing services, can 1-877-337-8188. Days in Billing Cycle 29 Total Interest charged In 2010 $2,581.08 J 1of2 Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual Interest rate on your account. Annual Percentage Balance Subject to Type of Balance Rate (APR) _ Interest Rate ,.:_. _.... Interest Charge PURCHASES Standard Purch 29.9900/. (V) $8,830.70(D) $210.40 Purch/Adv Thru 11/28/2005 29.990% (V) $248.16 (D) $5.91 ADVANCES Standard Adv 29.990% (V) $1,341.28 (D) $31.96 How to Reach Us 1-800-756-4000 Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 *" *` "'"* 9735 Access your account online: www.clticards.com 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. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 12/15/2010 to allow for enough time for regular mail to reach us. 2of2 Verification I, Lisa Bluffer , 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 unworn falsification to authorities. Signature C-49064 Stewart A McGarvey Account number ending in 9735 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor gttl?l? Gt ': wrq+ "j41141 O ? Hr- ?E??f 1?0?"i?p (i Y 2011 MAR 3Q PM 3: 24 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. vs. Stewart A. McGarvey Case Number 2011-3145 SHERIFF'S RETURN OF SERVICE 03/28/2011 07:23 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2011 at 1923 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Stewart A. McGarvey, by making known unto Lugene McGarvey, Wife of Defendant at 2252 Dover Court, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. A14 UT HALL, DEPUTY SHERIFF COST: $38.00 March 29, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF i:;cun'yS?.?ae 5ner'I. Te!eoscq b,c.