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Home My WebLink About12-4828t,L ED-OFFICE THE PROTHONOTARY 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 V. RICK T WISNER 206 Pennsylvania Avenue Camp Hill PA 17011-5436 Defendant 2012 AUG -2 PM 1: 35 "UMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. a- Ll 0A0 el vi I 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-37274 / 304 C?3 T?s (Z a*7g7 8S 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 Attornev for Plaintiff CITIBANK, N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. RICK T WISNER CUMBERLAND COUNTY, PENNSYLVANIA : NO. 206 Pennsylvania Avenue Camp Hill PA 17011-5436 Defendant CIVIL ACTION -LAW Complaint Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Rick T Wisner who resides 206 Pennsylvania Avenue, 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 8420. 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 $4,568.30 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 $4,568.30, and the costs of this action. 719 es I P.C. By arker, Es re may: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-37274 / 205 03/20/10 $9188.30 $9188.30 SITE:KC-CL TM:CO-5000 ACID:IRB9539 - ,r• w:: -? I 05/13/10 19:43:57: • Iffi-IM .. : CITI CARDS PO BOX 183051 RICK T WISNER COLUMBUS, OH 206 PENNSYLVANIA AVE 43218-3051 CAMP HILL PA 17011-5436000 Citie Dividend Platinum Select Card Clue Account Number: 8420 Customer Service: 1-800-756-4000 www.citicards.com BOX 6500 SIOUX FALLS, SO 57117 mry of Account Activity ious Balance $8,9 8.17 nC 0 0 redits r - . 0 bases + 0.00 nce Transfers + 0.00 Advances + 0.00 Char ed +$ 9.00 rest harped +$201.13 New Balance $9,188.30 Past Due Amount $1,705.31 Amt. Over Credit Limit $958.30 Credit Limit $8,230 Available Credit 0 Cash Advance Limit $8 0 Available Cash Limit 10 Statement Closing Date 02/22/2010 Days in Billing Cycle 28 Payment Information New Balance 9,188.30 Minimum Payment Due 108.30 Payment Due Date 033i0 2010 Late Payment Warning: If we do not receive your minimum pa ment by the date listed above, you may have to pay up to a 39 late fee and your APRs may be increased up to the variable Penalty APR of 28.99%. Minimum Payment Warning: If you make only the minimum payment each period, To will ay more in interest and it will take You longer to oav ofE Your balance. For example: 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 t month(s) $9,188 If you would like information about credit counseling services, call 1-877-337-8188. Sak Ddb Fee Daft ndwann Number ActMtt Saw Let statement Amount 2/22 LATE FEE - JAN PAYMENT PAST DUE 66 0000 TOTAL FEES FOR THIS PERIOD Interest Charged 2/22 PURCHASES+INTEREST CHARGE'PERIODIC RATE 2/22 PURCHASES•INTEREST CHARGE'PERIODIC RATE 84 0000 TOTAL INTEREST FOR THIS PERIOD Your late fee was based on your account balance as of the payment due date (02/19/10), which was $8,948.17. 39.00 0000000000 39.00 167.17 0000000000 33.96 0000000000 201.13 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. IXHIBIT__;? RICK T WISNER Sale Dote Post Dot* Refereaa Number Activity Slag Last Statement Amount Our records show home phone 717-761-1713 and business phone 000-000-0000. If incorrect, please update your account online at www.citicards.com or call us at 1-800-756-4000 to let us know. Contact us today - we can help! Go online at www.paymentsolutions.citicares.com to login or register. Dovs This BRllno Period: 28 Rate Summery Balance Subject to Periodic Nominal ANNUAL Interest Charne Ratak ADO IWAR UTAOR RAT! ES rd Purch $7.517.56 0.07942%(D) 28.990% 28.990% Sd12/22/2006 $1,527.21 0.07942%(D) 28.990% 26.990% rd Adv $0.00 0.07942%(D) 28.990% 28.990% Verification Wkki L. K O I, , am employed by Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. This includes accounts previously owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am authorized to make this verification on behalf of Citibank. The statements of facts set forth in the Complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Signature C-37274 Rick T Wisner Account number ending 8420 1000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~$~pta ~t uuarif~r~~~~~ ,. t~ c: rME ~ r`~~I~~ ~'l_e:.~~'~iF~'iCir. ,0~~ ~Htr ~~ ~~~~~~i~,~ ~~ ~~~ ~U13 ~ ~ ~~ 7~ 1 FEh~FtS`~LVANIA Citibank NA Case Number vs. Rick T. Wisner 2012-4'828 SHERIFF'S RETURN OF SERVICE 08/09/2012 04:33 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on Augu 2012 at 1fi33 hours, he served a true copy of the within Complaint and Notice, upon the wiithin named defendant, to wit: Rick T. Wisner, by making known unto Dixie Moody, Mother in Law to Rick T. Wisne 206 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at th same time handing to her personally the said true and correct copy of the same. . BITNER, SHERIFF COST: $43.00 August 13, 2012 SO ANSWER'S, G'- µ ~--..~..~ RON R ANDERSON, SHERIFF 9, at ',"c) CountySuite Sheriff, 7eleosoft, Inc. Burton Neil & Associates, P.C. By: Yale Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. V. RICK T WISNER To the Prothonotary: LEO- CF-FiCf, UF jIE PRO THONO 2014 SEP I I PN Oli CUMBERLAND PENCONSYLVANIA : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-4828 CIVIL Defendant : CIVIL ACTION - LAW Praecipe to Satisfy Judgment Mark the judgment Satisfied . Burton By: ociates, P.C. Yale Weinstein, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-37274 / 318 ( CSCk e,t_t sciosi %lb 99 s