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Home My WebLink About05-2824 , ~ BURTON NEIL & ASSOCIATES, P,C. By: Burton Neil, Esquire Identification No, 11348 1060 Andrew Drive, Suite 170 West Chester, P A 19380 (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 JASON C LILLER 1805 Main Street, Mechanicsburg PA 17055 NO, Dr:; -;;U>.:2f (}t~~L~'lK~ 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LA WYER 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-4979 . BURTON NEIL & ASSOCIATES, P,C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, P A 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N,A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. OS -(;21>d.,/ C?Lu...l't-~ JASON C LILLER 1805 Main Street, Mechanicsburg P A 17055 Defendant : CIVIL ACTION - LA W Complaint I, The plaintiff is CITIBANK (SOUTH DAKOTA) NA, with place of business located at 70 I East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Jason C Liller, who resides at 1805 Main Street, 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 5424180478362368 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 $8,718,54. Wherefore, plaintiff demands judgment against defendant for the sum of $8,718.54, and the costs of this action, , BURTOIY-NEIL & ASSOCIATES, P.c. By: L. ' B;on 'ii, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. ~ 03/05/04 ~~j~@t@~~~~~~t~j~ $8718.54 ~j~~Wi~~~~M~~~j~l $9999.99 SITE:KC-CL TM:CO-5000 02/09/0S ACID:KCB7150 01:48:24: ........._---.-........ ;:;:;f6m:::A~;:::9f.lt::::: ...........nn......... ............n......... JASON C LILLER 1805 MAIN 5T LISBURN MECHANICS BURG 17055 CITI CARDS P.O. BOX 8106 S HACKENSACK. NJ 07606-8106 PA Citi'" Platinum Select'" Card for Customer Servlc~,call orwrjt~ 1.800-950'5114 Account Nu mber 5424 1804 7836 2368 PAY~[NT MUST BE RECEIVED BY 1:00 PM LOCAL TIME ON 03/05/Z004 Toreportbllllnq......on,M'lte tothls.~ess:e...llng...1l notpr_veyo~rlghts. BOX 6500 SIOUX FALLS, SO 57117 statement/Closing Date 02/09/2004 Total Credit Line $7800 Available Credit Lirle $0 Amount Over Credit Line $918.54 Cash Advance limit $3500 Past Due $1144.30 Available Cash Limit $0 PurchjAdv Minimum Due $182.44 New Salance $8718.54 Minimum Amount Due $8718.54 Sale Oat. Post Date Relerence Number 2/09 2/09 Activity Since Lest statement Standard Purch OVER CREDIT LIMIT FEE 62 0000 PURCHASES'FINANCE CHARGE' PERIODIC RATE 84 0000 Amount 29.00 0000000000 182.44 0000000000 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. PrevIous (+) Purchases H Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance $8,507.10 $29.00 10.00 $182.44 $8, 71B. 54 $0.00 $0.00 0.00 $0.00 $0.00 $B,507.10 $29.00 0.00 $lB2.44 $8,718.54 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Balance Subject to Finance Charge PeriodiC Rate Days This BJIIlng Period: 31 Nominal ANNUAL APR PERCENTAGE RATE $8,595.05 $0.00 0.06B47%(D) 0.06B47%(D) 24.990% 24.990% 24.990% 24.990% EXHIBIT ----B ~ Verification I, am an employee ofCiticorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA) N.A, retained to perform services including but not primarily limited to collecting delinquent debt I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief I understand that the statements made herein are subject to the penalties of] 8 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Cf ~ (:/ Date: ") [l)j e Si Jason C Liller 5424]80478362368 C-4979 , r:J -be. 8 iU h C') 1 '-II --.. ~ ::J ~ vt ., D '~,.) - ~ --.- 6"- -u -.c. 0- ~ F c.:; -0 1"",) --.......) ~ f-<; -F- '---C... 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 : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS, : NO.05-2824-Civil JASON C LILLER Defendant : CIVIL ACTION - LAW PRAECIPE TO SETTLE, END & DISCONTINUE TO THE PROTHONOTARY: Mark the above matter Settled, Ended and Discontinued. .....------.. "-." BURTON NEIL r ASSOCIATES, P.C. .YB~e Attorney Jhr Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-4979 1IIIUlm 1I1111111a111ll1UIII~11111 111~alllllll 'IIIII~IIII~ 1lllllIallllllllllllllall~111I ~IIIIIIIIIIIIIIIII' IIII (2 ~f: 1"'- ~ C;;:> eft ~ .-- - cJ1 -n -oc' -- Sf, :;;-;J;J ,.,. r-: -orn -"t;:' C?\O .:~y:.:H ,)~ .-/(') :,~rn ~ ~~ ~ '-i: o c..:> -