The URL can be used to link to this page

Home My WebLink About11-9417FILED-OFFICE OF THE PROTHCNOTARY 2011 DEC 27 PM 2: 19 CUMBERLAND COUN"CY PENNSYLVANIA Burton Neil & Associates, P.C1 By: Neil Sarker, Esquire ID. NO. 203465 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 V. LONNIE R MILLER 571 Conodoguinet Avenue Carlisle PA 170158972 You have been sued in court. you must take action within appearance personally or by ; the claim set forth against yo you and a judgment may be e claimed in the complaint or f or property or other rights im IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. //- ?0/ /71 Il ?/ G Defendant : CIVIL ACTION -LAW Complaint - Notice f you wish to defend against the claims set forth in the following pages, 0) days after this complaint and notice are served, by entering a written torney and filing in writing with the court your defenses or objections to . You are warned that if you fail to do so, the case may proceed without tered against you by the court without further notice for any money r any other claim or relief requested by the plaintiff. You may lose money ortant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN=AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FOUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INF RMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFO TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INF RMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE ERSONS 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-52003 / 304 C5) L# f? P6 9? BURTON NEIL & ASSOCIATES, P.C. By: Neil Sarker, Esquire, Id. No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorna for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. LONNIE R MILLER 571 Conodoguinet Avenue Carlisle PA 170158972 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complaint Plaintiff is CITI$ANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Lonnie R Miller who resides 571 Conodoguinet Avenue, Carlisle PA 170158972, 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 obtain?d 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 271. 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 f?r many months after receipt of a billing statement made payment on the Account or retained the, statement without payment. 9. Defendant retaihed 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 pridr 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 $9,692.13 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 $9,692.13, and I the costs of this action. Burton Neil & Asso P.C. By: Neil Sark r, Esquire Attorney for Plaintiff In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. G 0 , o E ° d ?v o i V N qtD NOJ o? ?? 3 O X a>c?? 0CO v0 S. Vm0 ul 00 K Ld S N NN O m v Y oa rt vP Q N N Op u? 1- r 0 0 J V W A E ?t y W v E- E ?M z s •1 - C W G 0z oz 9 Q J Q M p r, O O p O ? P Q c U Q C A C A M ,W ^ d • p d E d N d rn 6 Y O no ? N v M v ? Q ? f7 G ? Y r 2 21 C4 V 7 a to d m r ? N ! z V D 6 Yf • O a ^ f E C C Z N tC a? 'Uto mid yr w.cltkerda.com New Balance: $9.692.13 Minimum Payment Due: $9,692.13 Payment Due Date: 08/09/2010 000000 MC 34 A 0 LONNIE R MILLER 571 CONODOGUINET AVE CARLISLE PA 17015-8972 CITI CARDS P.O. BOX 182564 COLUMBUS, OH4 3 218-2 564 EXHIBIT A 0 ? in Yt N Y O t ? O F O N p N .£ O ? N • i 4 w e i r r ° v S • in 0 U N to c • Y P S : z C; M ?` N is to ? v A uCL a o I I< tT 0? _ a • N N G a 1W CC o - .. • i Q V A V C C P V ` r ° ? w G to e 3 m a q 2 < < ° u a v G i r o °a w` 10 O 10 'ct 0! K Q N N ? N N O _ d E ? q m E E G u C J G > ? m ymrpo E V U A U - E m > m m d d ? - 0 0 m a q E c v = m n A m E ° > e i i'e a s u a a o v - d C <' O O • a? $E' N mpO v as. 7E = c ; p p qO E . + E e y e c «'• S 7 ti c 0 0 `+ o E ! ? L O S q a zcE e m; xA o a E 4 c o E v u c 8 E o cr?ru CXJA 10 q 0 c ?- 3tE d `• to o?> >.,Q q d ? dh o?y vav 5 E 2 >o>'o >a Do C ? q Do EEGOw E?O L -- d c N ? d `da 00 E au?? C., y ? d c c. ?drE c L p G d ; d tt? O c:: M=E m0u M E-0 d co rodA> a>wq >= pav O Evw 0 -E=lc E V > 6 Detach ahd fellow P-"m t Y1.tnlttfew on revers. M.a.ch-k Wab1.tcCkj Cards AecmnT r-•-?-- 2271 Payment mat ee recaNad by 5-OD PM Iocal tome - the Payment due data. Verification 1, Lisa Blamer (hereafter CCSI), a subsidi interest to Citibank (South services credit card account Citibank (South Dakota), N authorized to make this veri complaint are true and corrc penalties of 18 Pa. C.S. Sec . , am employed by Citicorp Credit Services, Inc. (USA) J of Citibank, N.A. (hereafter Citibank), which is successor in akota), N.A. CCSI is a service provider for Citibank in that it owned by Citibank This includes accounts previously owned by ?. which merged into Citibank in or about July 2011. I am cation on behalf of Citibank. The statements of facts set forth in the t upon my information and belief and are made subject to the on 4904, relating to unsworn falsification to authorities. d Signature C-52003 ?I Lonnie R Miller Account number ending 227 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff d r { Jody S Smith ' r AM 9 Chief Deputy ''1i' 2 JP 25 i ?} Richard W Stewart t]M8Ei;Lj';1 0 L,jU1 Solicitor PE NSYLVAWA Citibank, NA vs. Lonnie R. Miller Case Number 2011-9417 SHERIFF'S RETURN OF SERVICE 01/19/2012 09:13 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2012 at 2113 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lonnie R. Miller, by making known unto himself personally, at 571 Conodoguinet Avenue, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 January 20, 2012 RYAN BURGETT, DEP SO ANSWERS, 2 RON R ANDERSON, SHERIFF r i 'I Iq 0 TA R' 2012 FEB 23 A1111:56 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. Plaintiff V. LONNIE R MILLER Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-9417 : CIVIL ACTION - LAW Praecipe to Discontinue Kindly discontinue the above-captioned action without prejudice. Burton Neil & Associates . By: _ _--o'_? Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-52003 / 314