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HomeMy WebLinkAbout11-4003i? C-C? i`ICc. PIRCTI- ONOTAR`' 2611MA'Y-2 PN12:;7 "UMBERLAND COUNTY !'ENINSYLYANIA 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 GLENN SULLIVAN : NO. 1 4- L1 WS 426 Allendale Way, Camp Hill PA 17011-8408 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. 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-44727 S' a" v1g9.60 rd a", "aSV40a3 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. GLENN SULLIVAN 426 Allendale Way Camp Hill PA 170118408 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 Glenn Sullivan, who resides at 426 Allendale Way, Camp Hill, 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 AADVANTAGE WORLD MASTERCARD credit card with account number ending in 1069 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 $5,855.79 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 $5,855.79, and the costs of this action. Burton Neil & Associates, P.C. By: B ' . Suttell, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. z-00 rnOr0 ;E m m 0O z cXZO 3 N c Ov m o m r f ? C W D D N Z Z D p 0 n 0 0 0 0 10 nvr1 PP - C: W0 m X Z C-. p rn m rn O LA M a+ A f' N ut x N A n INt ? yNt ? n o 3 N 3 N 3 m 0 'o tJ0 n O ^ mp n o Ra° s - 3 o ? 3 Z +s ^_ c g 9 3e en z' o g 0, 10 m8 9 3 SITE:KC-CL TWCO-5000 ACID:IRB8606 10/05/10 22:08:21 www.citi"rds.com How to Reach Us Account Member 1-800-967-9800 f GLENN SULLIVAN Acc u t A ti it ervice Custome S o n c v y Account Number B 0 X 606 2 - Jun 24-Jul 23, 2010 SIOUX FALLS, SO - ?69 57117 " Minimum Payment Due: New Balance: 3 Summary of Account Act ivity $5,855.79 $5,855.79 Previous Balance $5,772.78 Fees Payment Due Date: Payments ~1W- X0.00 ` Sale Post Description Amount 08/21/2010 Payment must be received by 5 *00 PM ether Credits 0.00 07/23 LATE FEE JUN PAYMENT PAST DUE 3200 local time on the payment due date. Purchases 00000000 000 66 0000 0000000000 Late Payment wsrninq:lf we do not receive your Cash Advances _ .„ T0.06 " "___.._....,_........_.__. _.._._.._...._._ TOTAL FEES FOR THIS PERIOD 39.J0 minimum payment by the date listed above, you may . Fees Charged + 39.00- 2 have to pay up to a $39 late fee and your APRs may be interes`ChargedF- +§44.01 increased up to the variable Penalty APR of 28.99%. New Balance 5,855.79 Interest Charged Miniwwe Payment Warning: If you make only the Past Due Amount $489 48 Post Description _ Amount minimum payment each period, you will pay more in Amt. Over Rev Cr Lt . $0 00 07/23 INTEREST CHARGED TO STANDARD PURCH 44.01 interest and it will take you longer to pay off your . . . 00000000 0000000000 -6z--'&0-0(5- balance. For example: ..v...__,?w..._.._..___., _...._....._ If you make no I You will pay off And you will end TOTAL INTEREST FOR THIS PERIOD 44.01 _ additional charges the balance shown up paying an Revolving Credit Limit ?- $6,920_ ?? using this card and Ion this statement estimated total Avail. Revolving Credit $0 2010 Totals Year-to-Date n each month you pay.. in about... of Cash Advance Limit $6,920 Only the minimum ( month(s) $5.85 - 6 Available Cash Limit Total Fees charged in 2010 $156.00 payment , -- .._.- .. ....._.. Statement Closing Date 07)23/2010 ___.__ .,..e..-.__..._ Total Interest charged in 2010 $231.53 For information about credit counseling servicas, Galt 1-877-337.8188. Days in Billing Cycle 30 0 Y a !7 2 n S N ? N : loft Interest Charge Calculation Your Annual Percen tage Rate (APR) is the annual interest rate on your account. Annual Percentage Balance Subject to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch 9.240% (V) $5,794.02 (D) $44.01 ADVANCES Standard Adv 19.990% (V) $0.00(D) $0.00 Your late fee was based on your account balance as of the payment due date (07/21/10), which was $5,772.78. GLENN SULLIVAN 1069 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 1-800-967.9800 Customer Service BOX 6062 SIOUX FALLS, SD 57117 Access your account online: www.citicards.com 2of2 Verification I Mary 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 unsworn falsification to authorities. d Signature C-44727 Glenn Sullivan Account number ending in 1069 1000 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. 11-4003 Civil GLENN SULLIVAN , 426 Allendale Way Camp Hill PA 170118408 r -9 ? Defendant : CIVIL ACTION - LAW rr, c- S - rn? ? Praecipe for Default Judgment To the Prothonotary: ; .-° Please enter judgment by default for want of an answer in the above case in fav6i ofT ?' plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $5,855.79 $5,855.79 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. :NO E GIVEN UNDER PA.R.CIV.P. 236 ro ono The law firm of Burton Neil & Associates is a debt collector. C-44727 Neil & associate's, P.C. ale emstein, Esquire tto for Plaintiff D. NO. 89678 060 Andrew Drive, Suite 170 Vest Chester, PA 19380 W. #lLlao eu# ra3 sgi u1iD14/ 3 AVY U/1111rin ?14,& rrracv CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-4003 Civil GLENN SULLIVAN Defendant : CIVIL ACTION - LAW TO: Glenn Sullivan 426 Allendale Way Camp Hill PA 170118408 DATE OF NOTICE: May 26, 2011 IMPORTANT NOTICE C-44727 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the once below. 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 BurttXNeJI &,4sociates, P.C. 'Yalck. Attey for Plaintiff Identification No. 89678 1060 Andrew Drive, Suite 170 West Chester, In making this communication, we advise our office is a (6 10) 696-2120 A 19380 debt collector. 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 Plaintiff V. GLENN SULLIVAN Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on_ 0 ,___? o c r Prothonotary By: ?10, ' e ty If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-4003 Civil Defendant : CIVIL ACTION -LAW The law firm of Burton Neil & Associates is a debt collector.