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Home My WebLink About12-7529t)~` r.~-~~fi~-OF~F~I~'r 212 DEC i 7 l~~ 10: v~ {JUPENNSyLD ~DUN1'!~ A h ~,~ Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2 ] 20 Attorney for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falts, SD 57117 Plaintiff v. MEENA K SINGH 3411 Hawthorne Dr Camp Hill PA 170112719 Defendant IN THE COURT OF COMMON PLEA S CUMBERLAND COUNTY, PENNSYLVANIA NO. Iv~•~So~_l ~l-1~ 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-59622 / 304 n1 ~n~ ~ ~~3, ~1~ Q~~ ~ ~E~ l a~~y~ r2~ a8~3s7 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA NO. MEENA K SINGH 3411 Hawthome Dr Camp Hill PA 170112719 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 Meena K Singh who resides at 3411 Hawthorne Dr, 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 1860. 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 $4,268.58 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 $4,268.58, and the costs of this action. B o •1 ~~A sociates, P.C. By• e D. Wein tein, Esquire may: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-59622 / 205 m x _2 ~_ °'.~ nw3 D Arn O ~ ~ m ~ ~ynO ... 'O N 3 N 2 ~~ A ~ A m r~~ 3 r-x`-^ N m phi 3 N~ OD c 3 -opZ n Z S o p ~ ~ N m ~ ~ v N ~ v r^ a o 3 p O ~ N J ~ a m .'. p G m Ga ~~F 0' O ~~~ ~ o a r g6 6 "= a r1J g y ~ tp $ .~ E M Lrt y " !^ (p M S g 6 O #.~~ -C non ~: s.~ 3 X R1 D-. o O ~ ~ do^ ° W 3 o n x "a~ a a Q n c ~, ;CK °' o~l°n gSg ; o = W O P ~ ~ W N ~ m ~ w ~ ~ O w w o o w N r^ ~ f~ * e W 6 O, O How To Reach Us www.citicards.com /'"+~ a Giti~ Diamond Preferred'° Card 1-800-756-4000 Account Member Member Since 2011 CI~~ 1 MEENA K SINGFI Account Activity Customer Service gox 6500 Sep 08-Oct OS, 2012 SIOUX FALLS, SD 57117 Account Number **** **** **** 1860 d Minimum Payment Due: New Balance: Summary of Account Act ivity o. $4.268.58 $4.268.58 Previous Balance $4,233.58 Fees Payment Due Date: Payments $0.00 Sale Post Description Amount 11/03/2012 Other Credits $0.00 10/08 LATE FEE SEP PAYMENT PAST DUE 35.00 ~ Late Payment Warning: If we da not receive your Purchases Cash Advances +$0.00 +$0.00 TOTAL FEES FOR THIS PERIOD 35.u0 minimum payment by the date listed above, you may ~ have to pay a late tee of ap to $35 and your APRs may Fees Charged +$35.00 Interest Charged be Increased up to the variable Penalty APR of 29.99°/x. Interest Charged +$0.00 New Balance 4,268.58 Post Description Amount - Mlnlmum Psyment Wsrnlnq:lf you make only the TOTAL INTEREST FOR THIS PERIOD 0 00 minhnum payment each period, ynu will pay more in Past Due Amount $429.00 . Interest and it will take you longer [o pay off your balance. For example: 2012 Totals Year-to-Date If you make no ;You will pay off the: And you will entl Amt. Over Credit Limit $168.58 - ~~ --~ "~--- -"- addltlonat charges ~ balance shown on ~ up payying an Credit Limit $4,100 Total fees charged In 2012 $200.00 using this cartl anA this statamant In estimatatl total aacn month you pay... about... of... Available Credit $0 Total Interest charged In 2012 $0.00 u Only theminimum Cash AdvanceLlmit $1,30G payment 1 month(s) j4,269 Available Cash Llrnit $0 Interest Charge Calculation Statement Closing Date 10/08/2012 __._.__ For Information about credll <xunselfng services, call 1-077-J37-oloFJ. Days III Billing Cycle 31 Your Annual Parcantaga Rata (APRIIs the anntl2l Interest fate on your account. _. Annual Percentage Balance Subject to Type of Balance Rata (APR) Interest Rate Interest Charge ~ PURCHASES s Standard Purch 0.000% $4,233.56 (D) $0.00 a: y ADVANCES s ° Z Standard Atlv 25.240x/0 (V) $0.00 iD) $0.00 3 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 minirnurn payment clue. ~ Help is available) Please rill the toll free numbershown above fo learn abcuL nur s ,ecial a ment o bons. Call Monda F rich / am to 9 xn, or Sahu'da f3 am to S P V, ~ a o a pin, Cer r l Time. %lease give us the pportunity Lo assist you. n ; t^ i of 2 How to Reach Us Cities Diamond Preferred Card ' ~0°-7J6_4°°° Customer Service BOX 6500 SIOUX FALLS, SD 57117 Please be sure to pay on time. If you submit your payment by mail, we suggest you mail it no later than 10/2!/2012 to allow for enough time for regular mail to reach us. Access your account online: www,clt_Icards.com Account Number *++' **++ <*++ 1860 C tl~ 2at2 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 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-59622 Meena K Singh Account number ending 1860 1000