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Home My WebLink About11-3428 ' C?-i?F F iCE ?D! 1 PJIT -4 PM ! l 6 C!.? PENN YLVAN A TY 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 N Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ERICK C JENSEN : NO. 11- 3y a B Gi vi 141 W Louther Street, Carlisle PA 170132938 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-47423 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 am tcaoo?d 0"t ma- 99S2a 'dS-7z&11 Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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 N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. ERICK C JENSEN 141 W Louther Street, Carlisle PA 17013 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 Erick C Jensen, who resides at 141 W Louther Street, Carlisle, 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 AT&T UNIVERSAL MASTERCARD credit card with account number ending in 3560 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 $17,364.83 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 $17,364.83, and the costs of this action. Burton Neil & Associates, P.C. By: B oY Suttell, Esquire A ney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. T? r) m D A p O 00 a, sf0Z t O 00 Im CC g D 3 7 a m - ?Xm? p ? N 3 a zn Im (n M M N A A < v m W W m er 0 D o 3 d UD W OD a m O O In i n?D OOH _\ \v u C CO ? 30c V CO XZ C < N N m M O rn S O > 01 w A ? v N O ? N v R" - ul A oa q' ? s ,i 1 ? a? - W C 7 » m 0 2 -ti - do W 3 n or 3 CL www.universalcard eom How to Reach Us Account Member 1-800-423-4343 ERICK C JENSEN Account Activity Customer Service Sep 11-Oct 12 2010 ber PO BOX 6500 , 3560 SIOUX FALLS, SD 57117-6500 Minimum Payment Due: New Balance: $17,364.83 $17,364.83 Summary of Account Activity Previous Balance $16 880.17 Categorized Purchase Activity Payment Due Date: Payments , -50.00 Air Travel Auto Rental Entertainment Health Care Lodging Merchandise 11/08/2010 Payment must be mceNed by 5:00 PM Other Credits 50.00 0.00 0.00 0.00 0.00 0.00 0.00 local time on the payment due date. Purchases +$0.00 Miscellaneous Organizations Other Travel Restaurants Services Vehicle Services Late Payment Warning: If do not receive your Cash Advances +$0.00 0.00 0.00 0.00 0.00 0.00 0.00 minimum payment fee the date e listed above, you, may have pay a late fee of t $ and your APs may Fees Charged +$35.00 r ri l e be increased up to the varable Penalty APR of 30.00%. Interest Charged +$449.66 Fees Minimum Payment Warning: if you make only the New Balance 17,364.83 Sale Post Description Amount minimum payment each period, you will pay more in Past Due Amount $2,316.55 10112 LATE FEE SEP PAYMENT PAST DUE 35.00 interest and it will take you longer to pay off your . TO7AL FEES FOR THIS PERIOD 35 00 balance. For example: Amt. Over Credit Limit $1,364.83 . If you make no You will pay off And you will end additional charges the balance shown, up paying an ' Credit Limit $16,000 Interest Charged using this card and on this statement'. estimated stimated total Available Credit $0 Post Description Amount each month you pay... In about._ oI Cash AdvancF un'ut $9,600 10112 INTEREST CHARGED TO STANDARD PURCH 449 66 payment Only the minimum t month(s) $17,365 Available Cash Limit $0 TOTAL INTEREST FOR THIS PERIOD . 449.66 - - Statement Closing Date 1011212010 For information about credit counseling services, call 1-877-337-8188. Days in Bluing Cycle 32 2010 Totals Year-to-Date Total Fees charged in 2010 $138.00 Total Interest charged In 2010 $3,756.96 1of2 Your Annual Percentage Rate (APR)ls the annual Interest rate on your account. Type of Balance 11 Annual Percentage Rate (APR) Balance Sub eet to Interest ate Interest Charge PURCHASES Standard Purch 30.000% (V) $17,096.99(D) $449.66 ADVANCES Standard Adv 30.000% (V) $0.00(D) $0.00 02010 AT&T and the AT&T logo are trademarks of AT&T Intellectual Property, licensed to Citlgroup Inc, How to Reach Us 1-800-423-4343 Customer Service PO BOX 6500 Account Number SIOUX FALLS, SD 57117-6500 **** **** **** 3560 Access your account online: www,unlversaicard.com Don't forget to use your AT&T Universal Platinum Card which offers you up to 30 free calling minutes good toward U.S. domestic and international calls, and 2 free directory assistance inquiries per month. Help is available! Please call the toll-free number shown above to learn about our special payment options. Please give us the opportunity to assist you. 2of2 Verification I, Lisa Blumer , 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-47423 Erick C Jensen Account number ending in 3560 1000