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HomeMy WebLinkAbout11-8377'.» t ' Q1 i.Jt ern;rf 1 ,p.: {: 'r °, ??Lttr ? COUNT =:'=SYI_VA 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. KENNETH A SHOLLEY 2901 Society Hill Drive A Apt 101 Camp Hill PA 17011-8113 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 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-53466 OL04 C I- x610 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. KENNETH A SHOLLEY 2901 Society Hill Drive A Apt 101 Camp Hill PA 17011-8113 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 Kenneth A Sholley who resides 2901 Society Hill Drive A Apt 101, 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. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to Citibank (South Dakota), N.A., by means of a credit card account (hereafter the Account) with account number ending in 5391. 5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011. 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 $4,517.39 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 defenLsociates,' ,517.39, and the costs of this action. B on . B le ELAfeinstein, Esqu ire ttornev for Plaintiff In making this communication, we advise Burton Neil & *§sociates, P.C. is a debt collector. Now To Reach Us n ro = o Account wttlVlc www.untversakardcom 1.800-846.11444 V;5 ra Iz. g O -a E w = w. y Mar 08-Apr 07,2011 Account Member KENNETH A SHOL LEY Customr Service IF -z S , Y Account Num+Mr PO BOX 6500 X FALLS SD v o lr 3 two e 5391 Member Since 1993 57? = p s o o ° !? Minimom Payment Due. Nim, Balancc Summary of Account Activity r .. 3 $4,5117.39 $4,517.39 Previous Balance $4,480.40 Fees - zr it o c PayfnnftDue Mar Payments Amount R 05/03/2011 ? ? Utz C ifs ------- `?+ ....._..____._----_..._-- "TOTAL FEES FOR THIS PERIOD ---..... 0.00 knlaateeear e w W n Late PwyataM wwnhmIf we do not receive your minimum payment by the data listed above, you may have to l t f f t 35 d P Cash Advances _ Fees Cliarpid _ tS0 00 interest Charged t r I pay a a e ee o u an our A o 5 Rs ma Y v be Increased up to the variable Penalty APR of 30.00%. -• . - • .... _.. _ Mi i P New Balance 517 39 04/07 INTEREST CHARGED TO STANDARD PURCH _ - -' 3.47 n mum ayaaot warwiag: If you make only the 04/07 INTEREST CHARGED TOOFFER-004 9.30 minimum payment each period, you will pay more In Past Due Amount S9201 ......._....._._._._.-.---.._.._. 04/07 INTERE57 CHARGED TO OFFER-0OS __... 6 53 Interest and it will take you longer to pay off your ---.---...... _, _._....„... _....._ ....._._ _.:... _.._.... . ...... balance. for example: Amt. Over Credit Limit $257.39 04/07 INTEREST 04/0 CHARGED TO PUR PR 08/27(10. 1.76 It YOU make ; You w pay off And you ral and Credit Limit $4 260 04/07 INTERE57 CHARGED TD PUR PR-05/28/10. 15.93 n additional at charo ryea the baleen eheeeK up paytngan using this card and on this statement; ""maw total ..__.....__...,...._:_..._.?__??.,_,,.. Available Credtt TOTAL INTEREST FOR THIS PERIOD 96.99 each month you pay- i In about- of_ CatiliAvarice W-- -14,1_60 n P _.._ ..._...._..._ W theemiiilum _ , 1 month(s) $4,517 Ava1?aU`e Cash LIiMt?- w 0 ,...- ., . 2" Totals Year-t&04" c m - + a X i r> inrmnaif?nare a heel _ ._.__..Z. _ _.........._._.. t M e4r wt t ananatea. -. ._.._. . Statement GOSfng Date 04/Ofj2011 in F Days In 6BIIriq C cle ?' 31 Taw toes elver Oe! In am $O_00 N < y Tated Interest clterga! In 201t $36.99 s $ 9 a Catogorize4 Purchaee Activity W rF Air Travel Auto Rental Enters ament Realm Can Lespng marchaiatse 0.00 0.00 0.00 0.00 0.00 0100 p O to Mkcaummous Oryanizattens Other TrarN Restawmts Services 0 00 0 00 0 00 0 00 0 00 Vehicle Services 0 0 ' . . . . . .0 Interest Charge Cakulatien C 3 Your Annual Pereestaga Rate ("Ells the arrsal Interest rate an gar account. is a ype of balance AnRoU (APR) Anit? steno= to interest Ch or go .:' n OF ; PURCHASES - Standard Purch 30.000% (V) 513621(D) $3.47 a 1 Of 2 02011 AT&T and me AT&T logo are trademarks of AT&T Intesectuel Property, keened to Citigroup Inc UD =Now How to Reach Us 1-800-846-8444 Customer Servlce PO BOX 6500 Account Number SIOUX FALLS, SD 57117-6500 ** .... 5391 Access your account online: www.universalcard.com Interest Charge Calculation (continued) Annual Percentage Belem* ect to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES (continued) Offer4 6.990% $1,567.26(D) $9.30 Offers 3.990% $1,926.81(D) $6.53 Purch Prior 08/27/10 24.010% (V) $86.27 (D) $1.76 Purch Prior 05/28/10 23.990% $781.71(D) $15.93 ADVANCES Standard Adv 30.000% (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 Sam to 6 pm or Friday 8 am to 5 pm, Central time. 1-800-846-8444 2of2 Verification I, Shelli 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. 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. dC ELI L M a!WW--- Signature C-53466 Kenneth A Sholley Account number ending 5391 1008 =: ? ? ? ?Pn4N©NOTA?` W1 JAN _5 ??? 50 CUMgER? N ANA pENNS 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 : NO. 11-8377 civil KENNETH A SHOLLEY 2901 Society Hill Drive A Apt 101, Camp Hill PA 17011-8113 Defendant : CIVIL ACTION - LAW Praecipe to Reinstate To the Prothonotary: Please reinstate the Complaint. iates, P.C. Weinstein, Esquire ,v for Plaintiff The law firm of Burton Neil & Associates is a debt co C-53466 ??ia?a?a a acoRN??2 Qt-? talroi}'iit 70 i Z FEB 17 AM 11: 17 CUMBERLAND COUNT` ' PENNSYLVANIA a Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2121) Attorney for Plaintiff CITIBANK, N.A. Plaintiff V. KENNETH A SHOLLEY Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-8377 civil : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue Mark the above matter Settled, Ended and N P.C. 61e D. Weinstein, Esquire ttorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-53466 / 318