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Home My WebLink About11-74520 `..t?u-L'a IE r. ..I. 2i'll 1 SEP 29 FM 2-' 1 `?` CUMBERLAND 1 EN ISYLVANIfk 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN SHEAFFER NO. -Ve In 937 Paul Circle Mechanicsburg PA 170555743 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 na, C-52889 C-# 16 -7 q 7,5? 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, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. JOHN SHEAFFER 937 Paul Circle Mechanicsburg PA 170555743 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is John Sheaffer who resides at 937 Paul Circle, Mechanicsburg, 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 9693. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A., effective July 1, 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 $2,040.73 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 $2,040.73, and the costs of this action. Neil WAsodates, P.C. Ale D. em n, Esquire ttorney or Plaintiff In making this communication, we advise Burton Neil &iAssociates, P.C. is a debt collector. mW000 n"p= 0 S-VZZ 0 >>r"W 0 Z C I Z O n-Dm Nn>> n m A Z W C Z M m N a 2 Z1 D D Y O o to A A W O '0 M K alp Z O c + a ?°.P3 Pr c0 W d W s Y e 0 i n:0 rI 0P 30D [D <M m °m 1 C ??TT7t M / I O N X A S W N m N y3 E _1 A 2y ? pp ;y f: a :o . v Er -0 W C3 no C3 r C3 W C3 ru C3 O v W O C3 C3 W ru C3 C3 I- iT I- 0. ie t n a n L a M S ri It 3 S Z www.citicards.com How To Reach Us 1-800-983-6453 Account Member JOHN SHEAFFER Account Activity Account Number CORNELIA ANN SHE AFTER Mar 23-Apr 22, 2011 9693 Member Since 1974 Minimum Payment Due: New Balance: Summary of Account Activity $2,040.73 $2,040.73 Previous Balance $1.958.63_ ? Payments _5U.00 Payment Due Date: Other Credits 0.00 05/20/2011btal tkrw arl tY Pay,"tw, mustbence.ed by 6.00 PM w Peyrnwtt dew Bala Purchases + 0.00 Late Payment MartYrq: If we de not receive your ou ma d above li t b h d t Cash Advances + 0.00 00 + 35 y , y e s e y t e a minimum payment have to pay a late fee of up to $35 and y PuRr of AP2R 9599 y96 A the variable Penalt t d b i Fees Charged In eres Charged . + 7.10 y o ncrease up e New Balance $2,040.73 1lledmi m payment Wwnk g: If you make only the t 13 $367 minimum payment each period, you will pay more in Past Due Amoun . Interest and It will take you longer to pay off your Amt. Over Credit Limit $110.73 balance. For example: It you make no You will pay off 1 And you will end Credit Limit $1,930 additional charges She balance showry UP Paying an Available Credit _ __- - 0 using this card and on this statement I estimated total nce Limit C h Ad 930 earn month you pay in about- or_. as va _ Only the minimum _ 1 montn(s! i $2,042 Available Cash Limit payment Statement Closing Date 0 2 2012 For int-al o„ about aedA counseiing -1-, call I-877-337-8186. Days in Billing Cycle 31 loft Customer Service PO BOX 6500 SIOUX FALLS, SD 57117-6500 Fees Sale Post Description R Amount 04122 LATE FEE - MAR PAYMENT PAST DUE ?? 35.GG TOTAL FEES FOR THIS PERIOD 35.00 interest Charged - Post Description ? _ Amount 04/22 INTEREST CHARGED TO STANDARD ADV 1.28 04/22 INTEREST CHARGED TO STANDARD PURCH 45.82 TOTAL INTEREST FOR THIS PERIOD 47.10 2011 Totals Y041`441-Date Total fees chats" in 2011 $140.00 Totellinterest charq*d in 2011 - $172.82 Interest Charge CaltuMtlon Your Annual Percmtap Rate Willis the annual irterest rate on your account. Annual Percentage Balance SuI t to Type of Balance Rate (APR) r Interest Rate interest Charge PURCHASES Standard Purch 27.990% (V) $1.927.421D) $45.82 ADVANCES Standard A& 27.990% (V) $Sf.9tiD; 5126 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 1-800-983-6453 Customer Service PO 80X 6500 Account Number SIOUX FALLS, SD 57117-6500 ..., ......,. 9693 Access your account online:. www.citlcaras.com Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 05/13/2011 to allow for enough time for regular mail to reach us. 2of2 Verification 1 SheNi M. Stackhouse , 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. 1 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 unworn falsification to authorities. Signature C-52889 John Sheaffer Account number ending 9693 1000 LA'N'D C 0,jjj -y • a.d rr, 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, N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN SHEAFFER ' NO. I) _ '1 ?? S a C j V l A Defendant : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinue 1 Neil &YAsiociates. P.C. D. Weinstein, Esquire Ytornev for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-52889 / 318