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Home My WebLink About05-1509 BURTON NEIL & ASSOCIATES, P.c. By:Burton Neil, Esquire Identification No. I 1348 1060 Andrew Drive, Suite 170 West Chester, PAl 93 80 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD IN THE COURT OF COMMON PLEAS Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA CHRISTIAN J HOLLAND 10 Railroad Avenue, York PA 17403-3610 NO. OS' - IS-O? CI 0 ~ C-T&L..yyt 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 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-4867 BURTON NEIL & ASSOCIATES, P.c. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SO Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYL VANIA NO. O~ - IS-OJ c.'lu~tT0LYvl CHRJSTIAN J HOLLAND 10 Railroad Ave., Mechanicsburg, P A Defendant : CIVIL ACTION - LAW Complaint I. The plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Christian J Holland, who resides at 10 Railroad Ave., Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff, a national banking association, engages in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180570257631 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $5,720.58. Wherefore, plaintiff demands judgment against defendant for the sum of $5,720.58, and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. By: Lfruh6n N~il, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 10/15/04 $5587.08 $9999.99 SITE: KC-CL TM:CO-5000 02/09/05 ACID:KCB7150 01:48:31: ...,.....,...,............0..-.-.-......,..-.-... ::::P.M:j;::iOOj:i!::::R~lt::::::;: ........n............... __.....n.......__....... ._.H...n....._......__ .,__....._.n....__.... ~~~~~~~~~~~~I~~ ~~~~~~~~~~~~~~~~@~~~~~ CHRISTIAN J HOLLAND 4900 CREEKVIEW RD MECHANICSBURG 17050-2114000 C IT I CARDS P.O. BOX B114 S HACKENSACK. NJ 07606-8114 PA Citi~ Dividend Platinum Select~ Card _. Cltl AccountN~r 5424 1805 7025 7631 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS. SD 57117 Total CredIt Lln~ $4700 Stat.mentl Closing Oat. 09/21/2004 A""Uable Credit Line $0 Amount Over Credit line $887.08 + Cash Advance Limit $1500 Past Due $354.27 + Avallilble C:<Ish Limit $0 Purt;h/Adv Minimum Dn $141. 04 = New Balance $5587.08 Minimum Amount Due $1382. 39 Amount Saki Date Post Date Relerence Number 9/21 9/21 9/21 Activity Since last statement Standard Purch LATE FEE - AUG PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Standard Adv ADVANCES'FINANCE CHARGE'PERIODIC RATE 84 0000 35.00 0000000000 35.00 0000000000 95.68 0000000000 9/21 40.36 0000000000 Please pay the Minimum Amount Due shown. Your account is past due and your balance is over the credit line. Regular monthly payments will help establlsh a good payment history with us. If you have already sent this payment, thank you. IMPORTANT INFORMATION ABOUT CREDIT REPORTING: WE MAY REPORr INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS, MISSED PAYMENTS, OR OTHER DEFAULTS ON YOUR ACCOUNT MAY BE REFLECTED IN YOUR CREDIT REPORT. PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance 13.784.60 $70.00 r.OO 195.68 r,950.28 1,596.44 $0.00 0.00 40.36 1.636.80 5,381. 04 $70.00 0.00 $136.04 5,587.08 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Balance Subject to finance Charge PeriodiC Rate Davs This Billing PerIod: 32 NomInal ANNUAL APR PERCENTAGE RATE $3.830.74 $1,615.90 0.07805%(D) 0.07805%(D) 28.490% 28.490% 28.490% 28.490% fI EXHIBIT ---.J::j VERIFICATION M.c(- ,J-erfSc ~.e is Attorney Management Specialist for Citibank (South Dakota) N.A. the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best ofthe undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date:4los , at ."7 /~/ ? .r:~,/ . - /~~~? // Christian J Holland 5424180570257631 ~ --;,,\J lr1 ~~~ \rl -::rQ ~ -~ fJlr 1: -r-- ~ - ~ G,;y '-", --0'--;' ~:;t':i\ ~~..~ i.h -~ Q (; ,...> % <.t' :%- ~ f'ol -- c. ",--. { " 2;..C! ..?~~ S1 -------- q, ---1--n r-,;~ :\" q ,;%~ CJ I....~.....~ -;.~.. ...(\ Dn ~~..fr\ ...._~ ~? '.~ -- r-> ((3 --c ,. s:- o- - -. , BURTON NEIL & ASSOCIATES, P.C. BY: Ya]e D Weinstein, Esquire Identification No. 89678 ]060 Andrew Drive, Suite] 70 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff I i I i , : IN THE COURT OF COMM<DN PLEA~ : CUMBERLAND COUNTY, Ji>ENNS+ ANIA I VS. : NO. 05-]509 Civil CHRISTIAN J HOLLAND Defendant : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without . dice. // / B~TON NE L & ( BY: The law firm of Burton Neil & Associates is a debt collector. C-4867 _J , -",. '-:-:"j c...) ":""'1 :..,. (') '-':~} ..-..~ ...-' ;\ _.':.. ':"! c<> ..