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Home My WebLink About11-39310 rw . R O I i 01 i PCt 3' 1 `.,PR 21 Vi I I • 'I r.:,;. MBERLAND COUNTY PENNSYLVANIA 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. SHAWN M CALDWELL 242 East Garfield Street Shippensburg PA 172572034 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. l -3131 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-49361 Q '53ysa 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. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. SHAWN M CALDWELL 242 East Garfield Street Shippensburg PA 172572034 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 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 Shawn M Caldwell, who resides at 242 East Garfield Street, 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 2229 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 $7,124.85 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 $7,124.85, and the costs of this action. Burton Neil & Associates, P.C. By: YV)01?- BV(t J. Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. How To Reach Us www.cltlcards.com 1-800-846-8444 ONO O N n 00 Z 0 m O v H 3 H Z -I - .I 5 Account Member SHAWN M CALDWELL OX Customer6500 Service 0 M c i n 3 0 z C : f N m W m N Account Activity Account Number SIOUX FALLS SD o to p 0 . N •'. m 3 0 a n Nov 06-Dec 07, 2010 X2229 Member Since 2008 , 57117 Am.w O?v NNn ` 0 v 0 a n v m n m < ? w A Minimum Payment Due: New Balance: o Summary of Account Activity + 0 $ 3 a $7,124.85 $7,124.85 Previous Balance $6,946.13 Fees N r o Payment Due Date: Payments -50.00 Sale Post Description , Amount Payment must be received by 5:00 PM 01/03/2011 Other-redlts $0.00 TOTAL FEES FOR THIS PERIOD 0.00 N 0 local time on the payment due datc Purchases +$0.00 A Late Payment Warning: If we do not receive your Cash Advances +$0.00 Interest Charged minimum payment by the date listed above, you may Fees Charged +$0.00 have to pay a late fee of up to $35 and your APRs may Post Description Amount be increased up to the variable Penalty APR of 28.99%. Interest Charged +$178-72 12/07 INTEREST CHARGED TO STANDARD PURCH 178.72 New Balance 7,124.85 a' Minimum Payment Warning: If you make only the TOTAL INTEREST FOR THIS PERIOD 178.72 minimum payment each period, you will pay more in Past Due Amount $3,967.88 interest and it will take you longer to pay off your Amt. Over Credit Limit $2,907.25 2010 Totals Year-to-Date Q z 0 _U n 0b1 Cdo0 30n mxz u, N irn A A w N 0) N A balance. For example . If you make no You will pay off And you will and Credit Limit $4,000 additional charges the balance shown- up paying an - m using this card and -' on this statement'. estimated total Available Credit $0 x each month you pay. ; In about._ of... Cash Advance Limit $1,200- ?` Only the minimum 1 month(s) $7,125 Available Cash Limit $0 payment Statement Closing Date 12/07/2010 For information about credi t counseling services, call 1-877-337-8188. Days In Billing Cycle 32 0 X R? u3 3 g ; . 3. G N e - n 2 - ;o n 3 3 CL CL (A R 1 off Total fees charged in 2010 $0.00 Total interest charged In 2010 $1,663.82 Interest Charge Calculation Your Annual Percentage Rate (APR)is the. annual interest rate on your account. Annual Percentage Balance sub'ectto f Type of Balance Rate (APR) Interest ate Interest Charge PURCHASES Standard Purch 28.990% (V) $7,032.32(D) $178.72 ADVANCES Standard Adv 28.990% (V) $0.00 (D) $0.00 Minimum Payment Due includes past due amounts. Your account may be with a collection vendor and when you call our number, you may be referred to the vendor. Please call the toll-free number shown above Monday-Thursday 8am to 6 pm or Friday 8 am to 5 pm, Central time. 1-800-846-8444 _CZ) QY l V Verification 1, ' gene Reynolds , 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. , ia'-' 4"/IL, Signature C-49361 Shawn M Caldwell Account number ending in 2229 1000 ;= Im ?t?i.2g COUNjY ?'?? p ?.N?dS NQ ANl A Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 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 Plaintiff V. SHAWN M CALDWELL Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3931 CIVIL : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action Burton N By: A The law firm of Burton Neil & Associates is a debt collector. P.C. , Esquire C-49361