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Home My WebLink About11-7377t ?a l'? ,?.,. 2011 SEP 25 PM 11: '7, Li C',UM B ER LAND COI. d T` PEN'SSYLVAN , Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. / LEROY C EYSTER JR : NO. //- 73 7 7 C/ UI G __7e(`7 624 B Street Enola PA 170251632 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-53231 f .2 ?C c* 1066.3 P-#7;651,39 BURTON NEIL & ASSOCIATES, P.C. By: Edward J. O'Brien, Esquire, Id. No. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff V. CUMBERLAND COUNTY, PENNSYLVANIA LEROY C EYSTER JR 624 B Street Enola PA 170251632 Defendant NO. CIVIL ACTION - LAW Cam Taint 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Leroy C Eyster Jr who resides at 624 B 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. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to Citibank (South Dakota), N.A., by means of a CITI MASTERCARD credit card account (hereafter the Account) with account number ending in 9522. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A., effective July I, 2011, as approved by the Office of the Comptroller of the Currency. 6. Accurate records of all debits and credits to the Account were maintained by plaintiff. . , 7. Defendant was provided with monthly statements for the Account including the billing statement attached hereto as Exhibit A (redacted to remove confidential information). The monthly statements accurately stated the previous balance and the debits and credits to the Account for the prior billing period. 8. Defendant had for many months after receipt of a billing statement made payment on the Account or retained the statement without payment. 9. Defendant retained the Exhibit A statement without making payment by the stated due date. 10. Defendant's assent to the Account balance set forth in the Exhibit A statement is manifested through the prior conduct of defendant either making payment on the Account or retaining the statement without payment, after receipt of the monthly billing statements. 11. As a result of said assent, an account stated for the sum of $13,549.60 exists 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 $13,549.60, and the costs of this action. Burton/Neil s ates, P.C. By: ' E and .O'Brien, Esquire Attorney for Plaintiff In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. III M a, I zn,m o Or ' 0 O O-U p 3 N z N 0 _ ? ' te ti O D n 1 { N e y a to ? C + W -I rV M N r sZ m O rail .ld O N v W j e `e mm? SOD mx;O C O in A A W N N A, :3 F a3 gS ?= R u ?2 a :Y `-o In ru ru I- W Ln -0 Er C3 r Lu Ln ..0 ir C3 C3 C3 r in C3 C3 C3 r r Cl- ka E A I c www.citicards.com How To Reach us 1-a0L-THANAYou Account Member LEROY C EYSTER JR customer Service Account Activity Account Number BOX 6500 Mar 24-Apr 25, 2011 9522 Member Sh 1 SIOUX FALLS SD Minimum Payment Due: New Balance: ce 997 57117 $13,549.60 $13 549 60 Summary of Account Activity , . Payment Due Date: Previous Balance Payments $13,153.25 -tG QO Fees Qrj 212011 Payrrwnt musts ree.iele by 5:00 PM °r - --•----- "` Other Cr -edits . M??"'GG Sale Post Descr flan local time an the Payment dui seta Late Pa y If de not i P urcha ses + $0 .00 04/25 '-"'-----_. - LATE FEE MAR PAY MENT PAST DLL _ __ rece ve your minimum payment nt by by the date te listed above, you may have to pay a late fee of u to $35 d Cash Advances Fees Charged + G 00 X TOTAL FEES FOR THIS PERIOD '- 35.00 p an your APRs may be increased up to the variable Penalty jour of 29.99%. Interest Charged 35.00 _ 1?5 Interest Charged Minimum Payment Naming: it you make only the New Balance 13349.60 Post _ _De"scry j ion minimum payment each period, you will pay more in interest and It will take l Past Due Amount 2.361.11 04/25 - ° - - --. .--- INTEREST CHARGED TC STANCARD Pu R H .__? Amount 36t35 you onger to pay oft your balance. For example: Amt. Over Credit Limit $2,039.60 TOTAL INTEREST FOR THIS PERIOD 361.35 It you make no additional charges I You will Pay Off ; And you will and Are, balance shown uP Paying an Credit Limit $11 510 using this card and each month you Pa on this statement i estimated total I , Available Credit- '_ $C r -- OnN the mt rnum n about of_ ------------ -- ---- Cash Advance Lind- $70,500 Payment I mcntn(s) $13,550 Available Cash Limit .. Fa mrormaua? aboui creel co?nselin - v armces n i i-eie Statement Closing Date 04 T2§ p , u e» aa e. Days in Bili C ycle ng 33 r a n 2 A 8 d $ CL 410 8 1of2 2011 Totals Year-to-Date Standard Purch 29.990% 573,327.63 (D) SJ61-35 tnvaurrc Total fees char 9N In 2011 $70.00 Total interest chary/ N 2011 - - $1296 00 rest Charge cak:ulatlon Annual Percentage Rate Willis the annual interest rare cn your accwnt. of Balance Annual Percent ?'...?. ?_."...- '...°.°..- W! Balance Surlect to ...,....°__..... .-..... Rate (APR) Interest Rate Interest Charge :RASES Standard Adv 21990% $G.0'J iii) $U.Gi; 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-T HAN K Y OU Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 ............ 9522 Access your account online. www.citicards com Please be sure to pay on time. It you submit your payment by mail, we suggest you mail it no later than 05/14/2011 to allow for enough time for regular mail to reach us. 2of2 Verification Ashley Cooley 1, , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. CCSI is a service provider for Citibank in that it services credit card accounts owned by Citibank This includes accounts previously owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am authorized to make this verification on behalf of Citibank. 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. C-53231 Leroy C Eyster Jr Account number ending 9522 1000