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Home My WebLink About11-3554Burton 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. ALICE F DAVIDSON 121 Deerfield Lane Shippensburg PA 172578560 Defendant -FFIE 'A l HONOTA€tI, 2011 APR I I AM II* 13 J1,11P NNS LVAN A COUNTY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. `1 - 3 `JSL ?iVf( 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-47841 Ar?4 g`o.ev fbi ai6i 9+,267V/ 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ALICE F DAVIDSON 121 Deerfield Lane Shippensburg PA 172578560 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 Alice F Davidson, who resides at 121 Deerfield Lane, Shippensburg, 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 7269 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 $2,923.79 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 $2,923.79, and the costs of this action. Burton Neil & Associates, P.C By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. _2 N _r O ?Onp ?mm 0 m A m O '_1 v ° co rn D 3 Cr<_ A Avon -V r 0 N Z 0 D ° -zi N I Ln 0 n_U n 01 a 30y mx:0 N N N O un xm A A N_ CD N A co aseal-I N 3 N Z A ON. 3 %o 3 m p P a so n -4 -4 O c° b a s0 a m < m ,w° a 3 3 a v c o www,citicards.com Account Member ALICE F DAVIDSON How To Reach Us 1-800-756-4000 Customer Service Account Activity Account Number BOX 6500 SIOUX FALLS, SD Sep 21-Oct 20, 2010 _ 7269 Member Since 2007 57117 Minimum Payment Due: New Balance: Summary of Account Activity $2,923.79 $2,923.79 Previous Balance $2,818.49 Fees Payment Due Date: Payments $0.00 Sale Post Description Amount 11/16/2010 Payment must be received by 5:0o Other Credits -$0.00 10120 LATE FEE - SEP PAYMENT PAST DUE 35.00 PM local time on the payment due Late Payment Warnin dit d t i Purchases C h Ad +$0.00 -- TOTAL FEES FOR THIS PERIOD 35.00 g e o no rece ve your minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may be increased u to the bl P lt AP as vances Fees Charged I t t Ch d +$O.OC! +$35.00 +$ .3 Interest Charged p varia e ena y R of 29.99%. n eres arge 70 0 New Balance 2 92179 Post Description Amount Minimum Payment Warning: If you make only the , 10120 INTEREST CHARGED TO STANDARD ADV 16.68 minimum payment each period, you will pay more in Past Due Amount $715.90 10/20 INTEREST CHARGED TO STANDARD PURCH 53 62 interest and it will take you longer to pay off your . balance. For example: Amt. Over Credit Limit $123.79 TOTAL INTEREST FOR THIS PERIOD 70.30 If you make no You will pay off And you will and Credit Limit $2 800 additional charges the balance shown up paying an , using this card and on this statement estimated total Available Credit $0 each month you pay. .. ` In about._ of... Cash AdvanceLimit $900 Only the minimum 1 month(s) $2,924 Available Cash Limit $0 payment Statement Closing Date 1012012010 For information about cre dit counseling services, can 1-877-337-8198. Days in Billing Cycle 30 0 s w 0 9 ; C o? ? e 3 3n 6 N - _ b n _ n N o w Ao ? 3 a Iof2 2010 Totals Year-to-Date Total fees charged in 2010 $216.00 Total Interest charged In 2010 $630.78 Interest Charge Calculation Your Annual Percentage Rate (APR)Is the annual Interest rate on your account. Ann ual Acartage Ba? ect b? to Type of Balance Rate ( nte est a te Interest Charge ! PURCHASES Standard Purch 29.990% (V) $2,175.40 (D) $53.62 ADVANCES Standard Adv 29.990% (V) $676.93 (D) $16.68 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. How to Reach Us 1-800-756-4000 Customer Service 80X 6500 Account Number SIOUX FALLS, SO 57117 * **** **** 7269 Access your account online: www.citicards.com Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 11/09/2010 to allow for enough time for regular mail to reach us. 2of2 Verification 11 ebbie Motley , 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 unsworn falsification to authorities. r d Signature C-47841 Alice F Davidson Account number ending in 7269 1000 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. Plaintiff V. ALICE F DAVIDSON Defendant C= t,ma 3 -?3 r.? t rnm rr'1 . 7,0 _<T r- Z: Q < C-7 CD ? C- : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-3554 CIVIL : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Ass i s, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-47841 / 314