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Home My WebLink About11-3813T H f- -OFFICE •? c )P 0Ti10N0TAfi PP 20 Pty (: p;' ^01-'1,3ERI.AND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. CHARLES E GOOD 1017 Valley Street, Enola PA 170251339 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. \ VNI3 CM \ : 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-49789 D?'A ?q-a.oo Oti dk4i 100(0 20 9JA aSRa0y Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 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. CHARLES E GOOD 1017 Valley Street, Enola PA 170251339 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 Charles E Good, who resides at 1017 Valley Street, Enola, 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 8517 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 $4,984.69 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 $4,984.69, and the costs of this action. Burton Nell M Astfociates, P.C. Y: Y fie D. einstein, Esquire ttorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt www.citicards.com r I'o MEW85177 1/21/11 $4984.69 $542.17 ? 4c, I ?q 00 V1 0197 1 MC 4 CHARLES E GOOD 1017 VALLEY ST ENOLA 17025-1339000 PA CITI CARDS P.O. BOX 182564 COLUMBUS, OH 43218-2564 Citi® Dividend Platinum Select" Card Account Number: VMNM 8517 Customer Service: 1-800-866-9900 www.citicards.com BOX 6500 SIOUX FALLS, SD 57117 Summary of Account Activity Payment Information Payment must be recened by 5:00 PM local time on the Payment due date. Previous Balance Payments Other Credits Purchases Cash Advances Fees Charged Interest Charged New Balance Past Due Amount Amt. Over Credit Limit Credit Limit Available Credit Cash Advance Limit Available Cash Limit Statement Closing Date Days in Billing Cycle $4,925.13 New Balance $4 984.69 - 0.00 Minimum Payment Due 1542.17 - 0.00 Payment Due Date 01/21/2011 + 0.00 +10.00 Late Payment Warning: If we do not receive your minimum +$35.00 payment by the date listed above, you may have to pay a r AP +$24.56 to theevariabl yp etPenaltynAPRoof 29899% may be increased up $4,984.69 Minimum Payment Warning: If you make only the minimum $378.92 pa ment each period, yyou will pay more in interest and it $54.69 will take you longer to pay off your balance. For example: If you make no You will pay And you will end additional charges off the balance up paying an $4,930 using this card shown on this estimatted total $0 and each month you statement in of... $4.93o pay••• about... 12/23/2010 Only the minimum payment 21 year(s) $8,373 30 $141 3 year(s) $5,460 (Savings= $2,913) If you would like information about credit counseling services, call 1-877-337-8188. Sale Date Post Date Reference Number Activity Since Last Statement Amount Fees 12/23 LATE FEE - NOV PAYMENT PAST DUE 35.00 TOTAL FEES FOR THIS PERIOD 35.00 12/23 Interest Charged INTEREST CHARGED TO STANDARD PURCH 12/23 INTEREST CHARGED TO OFFER-004 TOTAL INTEREST FOR THIS PERIOD 2010 Totals Year-to-Date Total Fees charged in 2010 130.00 Total Interest charged in 2010 272.01 ****Dividend Dollars Summary**** Previous Statement Dividend Dollars Total 31.35 Base Dividend Dollars Earned 0.00 Total Dividend Dollars Earned this period 0.00 Total Dividend Dollars Available 31.35 9.66 14.90 24.56 EXHIBIT A SEND PAYMENTS TO: 262 PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. www.citicards.com 00 V1 0197 1 MC 4 CHARLES E GOOD A0 'IV& a ti* Sab Date Post Data Reference Number ActMty Since Last Statement Amount i If I" Your account is serious9y past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am 5 pm, Central Time. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 01/14/2011 to allow for enough time for regular mail to reach us. Interest Charge Calculation Your Annual Percentage Rate, (APR) is the annual interest rate on your accourrt. Annual Percentage Balance Subject to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch Offer 4 Z9.990% $391.73(D) $9.66 ADVANCES 3.990% $4,545.25(D) $14.90 Standard Adv 21.990% $0.00(D) $0.00 SEND PAYMENTS TO: 262 PLEASE REFER TO THE REVERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. Verification I, Lisa Blaney ,. 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. et.., Signature C-49789 Charles E Good Account number ending in 8517 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny ff RAnderson r ICE Sheri atIf117 se7? Jody S Smith ?.°ti`?t?r' Chief Deputy '• Richard W Stewart WAD- Solicitor OFF ,,`, ` 7"F Citibank (South Dakota) N.A. vs. Charles E. Good Case Number 2011-3813 SHERIFF'S RETURN OF SERVICE 04/21/2011 05:15 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 21, 2011 at 1715 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles E. Good, by making known unto himself personally, at 1017 Valley Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.00 April 25, 2011 MUZ"OTSRALIL, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) countySuite Shenff. i eleosoft. Inc.