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Home My WebLink About12-7435>. r 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. DAVID W CROSBY NO. ~ ~ - ~ ~~`~ 5235 Wertzville Rd Enola PA 17025-1260 Defendant :CIVIL ACTION -LAW Complaint -Notice ~~wr l 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 A ~} C-59369 / 304 ~~ d~ d3 1ST ~' y CI~-~ ~ ~~ (~3 1611 DEC 10 PM I~ 02 AM0 C YLfY ~`'tL~y~'~'Ft~'~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BURTON NEIL & ASSOCIATES, P.C. Derek C. Blacker, Esquire, Id. No. 202150 Brit J. Suttell, Esquire, Id. No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attomey for Plaintiff CITIBANK, N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. DAVID W CROSBY 5235 Wertzville Rd Enola PA 17025-1260 CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant :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 David W Crosby who resides at 5235 Wertzville Rd, Enola, 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 0402. 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 $6,959.68 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 $6,959.68, and the costs of this action. B o ssociates, P.C. B~': De k C. Bl ker, Esquire By: Bnt J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-59369 / 205 s~aa v 0 m ~ N b~ m 0 DA ~ N 3 °: mo d A; O p ~ 3 ,, o P ' < u i w ID N N O ~ W ~ O O n N m ~ m t nr '~~D O 3 N m O ~ ~ 0 0 •° m r ~ ~ ~ ~ ~ ~ }3 ~ tl1 ~r _n ~ ~ ~~ ~ !p ~~~ ~ O ~ ~~ o_. ~ 3 a n~r~ $% $ n I ion A 'ah -.. 0, C -+ p ~P~ ~ ~ ~ O O to F ~ ~ x m O A A ..0 W ~ N m x O 3 ,~ ~ N m a ° * , ~ o A "• x nJ ~ n ~ O ,.i o '~ A N 3 ey d o. a www.clticards.com How To Reach Us Cities Diamond Preferred Card 1800-756-4000 Account Member Member Since 2011 DAVID W CROSBY Customer Service Account Activity Box 6500 Aug 03-$ep 04, 2012 SIOUX FALLS, SD 57117 Account Number **~« xwax *•** 0402 ~, x Minimum Payment Due: New Balance: $6 959 68 $6 Summary of Account Activity , . ,959.68 Previous Balance $6,924.68 Fees Payment Due Date: Payments -$0.00 Sale 09/28/2012 Other Credits -$0.00 Purchases +$0.00 Leta Payment Warning: If we do not receive your Cash Advances +$p.00 minlmum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs mayy Fees Charged +$35.00 Interest be Increased up to the variable Penalty APR of 29.999b. Interest Charged +$0.00 Mlnlmum Payment Warnlnq:lt you make only the New Balance 6,959.68 minlmum payment each perlotl, you will pay more In Past Due Amount $609.00 Interest and It will take you longer to pay off your balance. For example: If you make no ;You will pay oft the- And you will entl Amt. Over Credit LImIt $199'68 additional charges ;balance shown on ; up payIng an Credit Llrnlt $6,760 using this card and ;this statement In _ estlmatia total each month you pay...; about... of... gyallable Credit $0 Only theminlmum - CashAdvanceLlmlt $O payment I month(s) $6,950 Available Castt Llmlt $0 Statement Closing Date 09/04/2012 r°~ rnro~mAu°° abo~~t ,veer, c°~nsennq services, r~u rnna3t-elan. Days In Bllling Cycle 33 0 2 S 2 loft Post pescrlptlon 09/04 LATE FEE - AUG PAYMENT PAST DUE TOTAL FEES FOR THIS PERIOD L~m _ ___ _ _ .Amount 35.00 35.00 srged Post Description Amount TOTAL INTEREST FOR THIS PERIOD 0.00 2012 Totals Yeer-to-Date Total fees charged In 2012 $200.00 Total Interest charged in 2012 $0.00 Nair Annual Parcantaga Rata (APR)Is the annual Interest rate on your account. ' Annual Percentage Balance SubJectto Type of Balance Rate (APR) Interest gate Interest Charge PURCHASES Standard Purch 0.000°h $531.68 (D) $0.00 Offer 4 0.000% $6,393.00 (D) $0.00 ADVANCES Standard Adv 25.240Mo (V) 50.00 (D) $0.00 You may pay all or part of your account balance at any time. I-lowever, ynu must pay, by the payment due date, at least the minimum payment clue. 'Z1 How to Reech Us Cities Diamond Preferred'D Card reoo-7s6-4oo0 Customer Service BOX 6500 SIOUX FALLS, SD 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. Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 09/21/2012 to allow for enough time for regular mail to reach us. Access your account online: www.clt.icards,com Account Number **** *"** **** 040? C ti` 2of2 Verification I, Vikki L. Koch , 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 201 L 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. d Signature C-59369 David W Crosby Account number ending 0402 1000