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Home My WebLink About11-4001?u--o-OFF ICE 4i TIE ' `ROTHONOTA t.+ 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. SANDRA O ALVAREZ 181 Shippensburg Mobile Estate Shippensburg PA 17257-9508 Defendant 2011 r" "fi,-2 FM 12:4' CUMBERLAND COUNTY I'LNNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. \ l-L4 Doi C1k'? k 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-44746 S p'4'scaOD pd Q Ct * foods? IR4 asg(oI 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. SANDRA O ALVAREZ 181 Shippensburg Mobile Estate Shippensburg PA 17257-9508 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 Sandra O Alvarez, who resides at 181 Shippensburg Mobile Estate, 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 AT&T UNIVERSAL MASTERCARD credit card with account number ending in 1459 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 $6,513.25 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 $6,513.25, and the costs of this action. Burton Neil & Associates, P.C. By. Bt . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. rn rn xwDo vvrcloo 2 0 r M p Z -a> mmo3 31 n cI, M CD W 0 C D N D2)MD Fri p N :Z! X N p Vlm v) rn ui m 0 r„ m, n-V D Opp i to 3oc m X Z C6< u N rrn otnM p A > N r'1 M N v N X A O DtA9NZ r K Or ? a ? W a re p ? ? n v 3 m n v n R6 3 n o ? ash m g a c: vg z 0 3 n? 3 s a a &_ e 3 •• s u I I 3 ? ? v a ? D R?+ Y N e°A 1A N d_ f3 ar CL SITE:KCCL TM:CO-5000 ACID:IRB9737 10/05/10 22:08:21 Minimum Payment Due: New Balance: $6.513.25 $6,513.25 Payment Due Date: 07/14/2010 loco tine on aw paym nt uw 5:00 PM date. Late Payment Wanting. If we do not receive your minimum payment by the date listed above, you may have to pay up to a $39 late fee and your APRs may be increased up to the variable Penalty APR of 30.08%. Minimam Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no I You will pay off J And you will end additional charges jthe balance shown up paying an using this card and on this statement estimated total each month you pay... in about... of... Only the minimum 1 month(s) $6,513 payment For information about credit counseling services, call 1-877-337-8188. 1of 1 www.universaleard.com How to Reach Us Account Member 1-800-423-4343 SANDRA 0 ALVAREZ Customer Service Account Activity PO BOX 6500 2010 Account Number May 19-Jun 16 SIOUX FALLS, SO , 1459 57117.6500 Summary of Account Activity Categorized Purchase Activity Previous Balance $6.359.50 Air Travel Auto Rental Entertafnmeui Health Cara Lodging Merchandise Payments 00 0.00 0.00 00 0 0 0.00 0.00 tHer CredTls --_7$06-0 . . Purchases ?_???'-??' ??--' ??+$0.00 Miscellaneous Organizations Other Travel Restaurants services Vehlcle services Balance Transfers + 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Cash Advances _... +TO-C(5 Fees Fees n-l-resrtWa-ried -4_-+S71-gM Sale Post Description _ ... Amount _ ___. New Balance TOTAL FEES FOR THIS PERIOD .m.._,_.. 0.00 Past Due Amount $1,508.33 Amt. Over Credit Limit $1,07325 Interest Charged Post Description Amount Credit Limit W - A l bl C t d $5,440 ----- -- 06/16 0 PURCHASES* INTEREST CHARGE'PERIODIC RATE 153.75 vai a re i e Cash Advance Limit it Cash A ...... 00000000 y"500 _ _ 84 0000 0 ... ._-___ 70000000000 ..- ..............._ .._...._....._._._. Available Cash Limit 0 TOTAL INTEREST FOR THIS PERIOD 153.75 Statement Closing Date 06 16 2010 Days in Billing Cycle . 29 Rate Summary Days This Billing Period: 29 Balance Subject to Periodic Nominal ANNUAL PERCENTAGE Interest Charge Rate APR RATE PURCHASES _ _Standard Piu clF...__._.___ W6,4 3 42 ? 0.08241%(D) 36 0$?T. -fib ?l bsti .-._.__...._? ..............?..- ?._._._._.._..__ ._...,..._._._._.__._.._......_........._.._._ ADVANCES v91 anaa-rd"ddv.° ..7U7T TM W WRr_. _r6°'i7 0 .. 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. X02010 AT&T and the AT&T logo are trademarks of AT&T Intellectual Property, licensed to Citigroup Inc. Verification ,/lacy E. Crum 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-44746 Sandra O Alvarez Account number ending in 1459 1000 v ?s C__ ?== mW zM {._.. _ -<> AA C': ?C A ' ?.._. Y Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 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. SANDRA O ALVAREZ Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-4001 Civil : CIVIL ACTION - LAW Praecipe to Discontinue To the Prothonotary: Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates, P.C. By: Trenton A. Farmer, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-44746 / 314