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Home My WebLink About04-4440BURTON NElL & ASSOCIATES, P.C. By:Burton Nell, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 70l East 60th Street North, Sioux Falls, SD Plaintiff DALE T MEISER 2007 Lincoln Street, Camp Hill PA 17011-3842 Defendant 1N 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/NFORMATION 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-1907 BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff DALE T MEISER 2007 Lincoln Street, Camp Hill, PA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Complaint 1. The plaintiffis Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Dale T Meiser, who resides at 2007 Lincoln Street, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff, a national banking association, engages 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 credit card with account number 4428135071297501 hereinafter referred to as the credit card account. 5. Plaintiffmaintalned an accttrate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiffmailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. CIVIL ACTION - LAW 9. The mount due plaintiffon the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $9,503.92. Wherefore, plaintiff demands judgment against defendant for the sum of $9,503.92, and the costs of this action. ~t~+;N/~n~ & ^ssoc~T~s, P.C. By: lg~n Esquire Attorney f~r Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 06/07/04 $9503.92 $9999.99 S[TE:KC-CL DALE T ME[SEE ATTNY ACCOUNT-COD£=LB34 CAMP HILL 17011~384Z000 PA CHOZCE VISA P.O. BOX 8107 S HACKENSACK, NJ 07606-8107 TM:CO-5000 o6/08/o4 ACID:KCB7150 18:51:23: Choice* 4428 1350 71Z9 7501 Cus[~ner senace: 1-800-925- 8871 Total Crealt Line $8940 BOX 6~48 statement/ SZOUX FALLS, SD cIo~ln Date s?t~? o5/~1/z~o4 Available Credit Line Cash AdVance Limit Available Cash Limit $0 $7200 $0 $563.92 $1588.16 $203.00 $9503.92 $9503.92 Please note that payments must be received by 1:00 p.m., local time, on a bank business day at the payment processing facility that handles your payments, in order to be credited to ~our account as of that day, and payments must contorm to the payment instructions set forth on the reverse side. All conforming payments received at the payment processfnq faclhty after that time will ne credited as of the following bank bus09ess day. Help is available! Please call the toll-free number shown above to learn about our special ~ayment options. Call Ronday - Friday, 7 am to ~ pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Our records show home phone 717-737-7307. Please update the attached coupon if incorrect. Previous (+) Purchases (-) Payments Account Summary Balance & Advances & Credits PURCHASES $9,503.92 $OOO0 $0.00 AOVANCES $0.00 $0oO0 $0.00 TOTAL $9,503.92 $0.00 $0.00 Balance Su~actto Periodic Rate Summery Finance Charge Rate PURCHASES Standard Purch $0.00 2.33250%(¥) ADVANCES Standard Adv $0.00 0,07668%(F) (+) ~NANCE (4 New CHARGE Balance I 0.00 $9.503°92 0.00 $0.00 0.00 $9,503.92 OaysThls Billing Perloa: 32 Nominal ANNUAL APR P£RCENTAGERAT£ 27.990~ 27.990% 27,990% 27,990% EXHIBIT VERIFICATION orney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: Dale T Meiser 4428135071297501 SHERIFF'S CASE NO: 2004-04440 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS MEISER DALE T RETURN - REGULAR BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon MEISER DALE T DEFENDANT , at 2036:00 HOURS, at 2007 LINCOLN STREET CAMP HILL, PA 17011-3842 NANCY MEISER, WIFE a true and attested copy of COMPLAINT & NOTICE the on the 13th day of September, by handing to together with law, 2004 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.36 Affidavit .00 Surcharge 10.00 .00 38.36 Sworn and Subscribed to before me this /4 ~ day of ~-~ , ~Oo~ A.D. ~ P~othonotary ' So Answers: 09/14/2004 BURTON NEIL & ASSOC Sheriff BURTON NElL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. DALE T MEISER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4440 Civil : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BIJI~TON ~EIL & ASSOCIATES, P.C. Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-1907