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HomeMy WebLinkAbout12-4527_r ?luEi4UONaNOT??Z' c'?12 ,SU't 20 PM 1:56 CUMBERLAND CH A TY PENK 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 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHAD A MILLER NO. 4410 Chestnut Street Camp Hill PA 17011-4106 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 HA 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 C 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 X103. 7 S C-58367 / 304 S ? KL - S ? r BURTON NEIL & ASSOCIATES, P.C. Neil Sarker, Esquire, Id. No. 203465 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. CHAD A MILLER 4410 Chestnut Street Camp Hill PA 170114106 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Complain 1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Chad A Miller who resides 4410 Chestnut Street, 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 4780. 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 plainti 7. Defendant was provided with monthly statements for the Account including the bill 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 $3,936.77 exists which sum reflects the Exhibit A statement balance less credits, if any, which were applied to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $3,936.77, the costs of this action. B ;on N ' Associates, P.C. B ei arker, Esquire y: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-58367 / 205 C) A rl D A S O ; O D O X O O a w 3 e? Z u < D = = i= rn ;0 ?3 0 3 w 17 r- n r y.Tl N N q o t. a -r 0 A v 3 W ;? o a a `o r aiy S C3 ok^ $ W ? a R 3E • W > s r .J A a ? °F3 C7 xI W n TO 3 % `a 0p-a ` f • W KO aa a$ Cr D O G xa c v ? s 0 En n C3 C3 S of O N r N to • • C3 ch i r • 0 C3 M e A m 0 X Citi ThankYou" Card How To Roach Us 1-800-THANKYOU www•citlcards.com Account Member Member Since 2007 C t'' CHAD A MILLER Account Activit y Customer Service BOX 6500 Mar 16-Apr 13, 2012 SIOUX FALLS, SD 57117 Account Number eeee ee•e eeee 4780 Minimum Payment Due: New Balance: g $3,936.77 $3 936 77 Summary of Account Activity , . Previous Balance $3,867.09 Fees Payment Due Date: Payments -$0.00 Sale Post Description 05/10/2012 Other Credits $0.00 04/13 LATE FEE - MAR PAYMENT PAST DUE Amount Purchase s +$0.00 -- - 35.00 Late Payment Warning: If we do not receive your minimum payment by the date listed above you ma Cash Advances . 150.00 TOTAL FEES FOR THIS PERIOD 35.00 , y F have to pay a late fee of up to $35 and your APRs may be increased up to the variabl P l Fees Charged I ?$35A0 Interest Char ed e ena ly APR of 28.99%. nterest Charged +$3468 g & o Minknum Payment Wrning:if you make only the New Balance 3,936.77 Post Description Amount minimum payment each period, you will pay more in Past Due Amount $588 83 04/13 INTEREST CHARGED TO STANDARD PURCH 34.68 interest and it will take you longer to pay off your . TOTAL INTEREST FOR THIS PERIOD 34 68 balance. For example: . It you make no You will pay off the And you will end Amt- Over Credit Limit $0.00 additional charges balance shown on uV pa Inq an ., uslnq this card and this statement In estimated tot l Credit Limit $4,500 2012 Totals Yen-to•Date a oath month you pay... about._ of._ Available Credit " $0 Total foes charged In 2012 $140 00 u only the minimum - Cash Advance Limit . 9 payment 1 month(s) $3,937 Available Cash Limit S $0 Total Interest charged in 2012 $139.59 For information about credit counseling services, can 1-877-337-8188- tdtement Closing Date 04/13/2012 Days in Billing Cycle 29 E z n t E P ? f1 r• 3 w 1 a it to x 1of2 Interest charge Calculation You Annual Percentage Rata (APR)is the annual Interest rate on your account. Annual Percentage Balance Sub)ectto TYP0 of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Standard Purch i1.240% (V) $3,883.81(D) $34.681 Standard Adv 19.990% $0.00 (D) $0,00 You may pay all or part of your account balance at any time. However, you must pay, by the payment due date, at least the minimum payment due. How to Reach Us Citi ThankYoul Card 1-800-THANKYOU Customer Service loop, -0" BOX 6500 a SIOUX X FALLS, SIOLLS, SO 57117 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. Access your account online: wrrw.citkards.com Account Number "•.. ••.. .••• 4780 C tl. 2of2 Verification 1, VMdd L 8odi , am employed by Citibank, N.A. (hereafter Citibank), w ' h 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. Signature C-58367 Chad A Miller Account number ending 4780 1000 SHERIFF'S OFFICE OF CUMBERLAND Ronny R Anderson r ROTHO Sheriff 2 12 AUG -7 AM 9: C2 Jody SSmith Chief Deputy MERZM CIiU-...3, Richard W Stewart PENNSYLVANIA Solicitor OFFICE S>4ERIFF Citibank NA Case Number vs. Chad A. Miller 2012-4527 SHERIFF'S RETURN OF SERVICE 07/31/2012 07:11 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on July 31, 2012 at 1911 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chad A. Miller, by making known unto Patty Miller, Wife of Defendant at 4410 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.00 August 03, 2012 RYAN BURGETT, SO ANSWERS, RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. IN THE CO"'mO" ~~URT OF Cumberland COUNTY, STATE OF PA Plaint fink, NA vs. 7001 East 60th Street N Sioux Falls, SD 57117 Defendant Chad A Miller NUMBER: 12-4527 20 ~2 BUG 20 PM I ~ 0~ ~UM~E~LAND C , QTY 5 P~HNSYLVI~t~ A ANSWER TO COMPLAIlVT COMES NOW the Defendant in the above styled cause to answer the Plaintiffs Complaint as follows: I recognize the debit that I have with the plaintiff and entered into an agreement with freedom debit to assist in helping me recover from the debit I have acxumuiated with the lenders that have accumulal due to high interest and payments that was becoming overwhelming and hard to meet the obligations I had on a monthly basis. 1 felt this was my only option to help avoid foreclosure or bankruptcy. Dated this August 18 , 2012 Respectfully Submitted, ~~- ~ / Si¢nature of Defendant CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I have served the Plaintiff or its attorney with a copy of this pleading by US mail, postage pre-paid, on this the t~ay of August , 201_. /T~ Defendant C-58.367 / ,' 8 #LEO-Gi FIC". 2012 DEC 19 Ply 2: 22 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. CHAD A MILLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012-4527 CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Ass at , P.C. f By. Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector.