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Home My WebLink About12-2151t, J r; 'T 07A Js IqERL?,-'in,o COUNTY Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. t? CHARLES SABULSKI NO. C z:o-;L 1 5 Hemlock Drive Mechanicsburg PA 17055-4712 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 11. 70U WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. C-39434 / 304 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 a if /I P9 Is, (2 ff -Y1 BURTON NEIL & ASSOCIATES, P.C. Yale D. Weinstein, Esquire, Id. No. 89678 Brit J. Suttell, Esquire, Id. No. 204140 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. CHARLES SABULSKI 5 Hemlock Drive Mechanicsburg PA 17055-4712 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 Charles Sabulski who resides 5 Hemlock Drive, 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 Hilton HHonors Visa credit card account (hereafter the Account) with account number ending in 9983. 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 $6,654.98 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 $6,654.98, and the costs of this action. Burton Neil & Associates, P.C. 6Y e D. Weinstein, Esquire Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-39434 / 205 03/03/10 $6654.98 $6654.98 SITE:KC-CL TM:CO-5000 ACID:IRB8606 06/23/10 21:34:51: I. IN .4 M CITI CARDS PO BOX 183051 CHARLES SABULSKI COLUMBUS, OH 5 HEMLOCK DR 43218-3051 MECHANICSBURG PA 17055-4712000 Hilton HHonors"' Visa Gold Account Number: &9983 www.hhonorscard.occountonii..,.com Summary of Account Activity Previous Balance $6,577.40 Payments - 0.00 Other Credits - 0.00 Purchases + 0.00 Balance Transfers + 0.00 1 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged +$77.58 New Balance $6,654.98 Past Due Amount $1,206.60 Amt. Over Credit Limit $0.00 Credit Limit $7,000 Available Credit O Cash Advance Limit Available Cash Limit ;3,5 000 Statement Closing Date D i Bil i 02/05/2010 ays n l ng Cycle 28 Customer Service: 1-888-977-6687 PO BOX 6500 SIOUX FALLS, SD 57117-6500 ?q 34 Cak i by 5W Pe Payment Information loaf tiw an Hu p"at due dds. ,654.98 New Balance D66541.98 Minimum Payment Due Payment Due Date 03/2010 Late Payment Warning: If we do not receive your minimum aa$39nlate the andeyourtAPRsb you may to variable Penalty APR of 28.99%. Minimum Payment Warning:If you make only the minimum pa meat each period, you will pay more in interest and it wilt take you longer to pay off your balance. For example: If you would like information about credit counseling services, call 1-877-337-6188. If you make no You will pay And you will end additional charges off the balance up paying an using this card shown on this . estimated total and each month you statement in of... paY••• about... Only the minimum payment 1 month(s) 561655 Sant Dab Pat Dab Rafaraan Number AetMltl Sinn Last Statement Amount Fels TOTAL FEES FOR THIS PERIOD 2105 8 0000 2/05 800 Interest Chargqed ADVANCES*INTEREST CHARGE*PERIODIC RATE PURCHASES*INTEREST CHARGE*PERIODIC RATE TOTA LINTEREST FOR THIS PERIOD 0.00 70000000000 700000000001.46 76.52 77.58 EXHIBIT A CHARLES SABULSKI Sab Date Post Data Ratareace Number Adhity Slace Last Statement Amount * Important Change to Your Account Terms * We are changing your account terms. The standard # cash advance APR on your account will no longer * increase when the U.S. Prime Rate increases. Effective * 02/22/10, this variable APR changes to a non-variable * APR as follows: # * * Standard Cash Advance **APR**: 19.99% ##*##**#####*####**###***#*****##*#**##*######*###########** We thank you for being our customer and appreciate your business. 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. Contact us today - we can help! Go online at www.hhonorscard.accountonline.com to register or login. Raba Summary Balance Sub)ect to Perlod)c Nominal ANNUAL Interest Charge _Rate APR DraerUTA&W Dare VIIf?J LJ -- Standard Purch $6,545.76 0.04175%(D) 15.240% 15.240% DVANCES Standard Adv $68.97 0.05477%(D) 19.990% 19.990% Verification I, ikA dIMW , am employed by Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. 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. f Signature C-39434 Charles Sabulski Account number ending 9983 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson irk:. •?. r Sheriff ' °'? "a x v Jody S Smith Chief Deputy Richard W Stewart _ _- Solicitor . IT Citibank, NA vs. Charles P. Sabulski Case Number 2012-2151 SHERIFF'S RETURN OF SERVICE 04/09/2012 07:24 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2012 at 1924 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles P. Sabulski, by making known unto Diane Wilkens, Daughter of Defendant at 5 Hemlock Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. . UTSHALL, DEPUTY SHERIFF COST: $38.00 April 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF C-;9~.~. / ~ e +.. gk rv, t .~4ry ~9 ~ ? ~~ s~ ~ ~ ~~~ ~~ ~~ 'ii il~liL,4y,.i~(:i C~pU,I~~`,,: 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. 12-2151 CIVIL CHARLES SABULSKI Defendant :CIVIL ACTION -LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Di P.C. By: Y e D. Weinstein, Esquire tornev for Plaintiff The law firm of Burton Neil & Associates is a debt