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Home My WebLink About12-7530I.IF' TNT! FCC ~N N~3 i; "' arc z612 DEC 17 ~ ~# ID: V ~, CUMC~Ri~,t~D CCUNTY ~'E~f~'SYL~'ANIA 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 571 l7 Plaintiff v. CHRISTOPHER E HARTMAN 3115 Dickinson Ave Camp Hill PA 17011523 ] Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA G~~~~ No. ~ o~ ~ 15 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 HII2E 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-59409 / 304 a~ X03. ~s~~ a ~~ ~~8U358 • - ~ 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. CHRISTOPHER E HARTMAN 3115 Dickinson Ave Camp Hill PA 170115231 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CNIL 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 Christopher E Hartman who resides at 3115 Dickinson Ave, 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 1531. 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 Exhibil: 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 $10,705.11 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 $10,705.11, and the costs of this action. B ton ssociates. P.C. B e arker, Esquire y: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-59409 / 205 r7 w r~ n :x v v v yr O O E O 1 .~ ~ =Fa o~ m N 3 N w ~ Z = ~ ~ o O ar N iJl 3 U w nom U' o v ~ v ~ Z m N N m < :°. o m D o ~ j to ~ .. w 3 ~ n :? z r~vn O -1 ~ 00 n 3xa N ~ A o;'v = W A N w m x s -a r Lrr w ~.~Q ~ 3 ~'~ ~ ~X o ~' Spa O ~^~ ~ Y s R3~ ~ a e ~ P, b' ' o 2M ~ ~ "? ~ :r Q' Ln a $ 0 3 L-r ~C~ - ~-' °`~ e O S3 O ru Cl 0 „ o s 3 o c x ~j ..o m t. n " ' ~ o a www.cltlcards.com How To Reach Us Citiy Platinum Seleet'~ Card i c30G-'SC 4000 Account Member Member Since 2010 CHRISTOPHER E HARTMAN wciCl ,. Customer Service Account Activity eox 6500 AU l~i-Sep 13 2012 SIOUX FALLS SO 57117 Account Number **** ***" *"** t53t _ .-,. -~ 9 _ _ , _ Mlnimum Payment Due: New Balance: Summary of Account Ac tivity s $10,70$.11 $10,70$.11 Previous Balance $10,539.48 Fees Payments -$0.00 Sale Payment Due Date: otherOredits So.oo 10/09/2012 PurClases +S.^.,.00 Lato Payment Werninq: If we do not receive your Cash Advances +50.00 minimum payment by the date fisted above, you may Fees Charged +$35.00 3 have to )a a late fee of app to $36 and your APRs ma be Increased up to the variable Penalty APR of 29.44. Interest Charged Interest +$130.63 New balance 10,705.11 - Mlnimum Payment Warnlnq:lf you make only [he mhllmum payment each period, you will pay more in Past Due Amount $1,326.27 Interest and It will take you longer to pay off your balance. For example: Amt. Over Credit Limit $O.UO If you make no 'YOU will pay oft tha. And you will end atldltlonal charges ;balance shown on ' up pa Ing an Credlf l.ilnit $17.,500 using this card and '. this statement In '.. estimated total Available Credit $0 m each month you pay.... about... '.. of... Cash Advance Limit $3,BUG a Only the minimum 1 month(s) 510,705 payment Available Cash Limit 50 Statement Closing Date 09/13!7.017_ rw Intormannn about uedit counseunq services, can 1 un ~3rnlan. Days in Bllling Cycle 30 0 a: 4 3 Sr - n ~ ru ; -, < ~ & tof2 Post Description 09!13 LATE PEE - AUG PAYMENT PAST UUE TOTAL FEES FOR THiS PERIOD ~~~ Amount 35.00 35.00 Post Description Amount 09/13 INTEREST : HAROED TO STANDARD PIJRCH 130.63 TOTAL INTEREST FOR THIS PERIOD 130.63 2012 Totals Year-to-Date Total foes charged In 2012 $200.00 Totallnterest charged In 2012 $713.90 Interest Charge Calculation Your Annual Percentage Rat* (APR)IS the annual Interes t rate on your account. Annual Percentage Balance SubJect to Type of Balanee Rate (APR) Interest Rate Interest Charge PIJRCHASES ~.. Standard Purcfl 14.990% (V) S10,601..49 QI) $130.c;"1 ADVANCES Standard Adv 25240% (V) $0.00 (U) 50.00 You may pay all or part of your account balance at any tune. However, you must pay, by the payment due date. at least the minimum payment due. Citi~' Platinum Seiectfi Card How to Reach Us 1 B00-756-4000 .t acid Customer Service ^ BOX 6506 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 !~e Sure to pay on time. If you submit your payment by mail, we suggest you rTrail it no later than 10/02/201.7. to allow For enough lime for regular mail to reach us. Access your account online: www:citlcercls.com Account Number **** *"* **'* 1531 c te~ zotz Verification Vikki L Koch 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 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. Signature C-59409 Christopher E Hartman Account number ending 1531 1000