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Home My WebLink About05-3615 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 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D~ - 2l,15 Cio;L~Y"rJ ROBERT A SHOKES 840 Yverdon Drive, Camp Hill P A 17011-1850 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-6042 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, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. OS' - 3/.,1,5' {!luLL ~82-"1 ROBERT A SHOKES 840 Yverdon Drive, Camp Hill PA 17011-1850 Defendant : CIVIL ACTION - LAW Complaint 1. 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 Robert A Shokes, who resides at 840 Yverdon Drive, Camp Hill, 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 5424180402191990 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 $4,934.82. Wherefore, plaintiff demands judgment against defendant for the sum of $4,934.82, and the costs of this action. BURTON N, & ASSOCIATES, P.C. By:__,.:~ ___..-/ H' Burton Neil, E~e. Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. 12/01/04 $5786.23 $9999.99 5ITE:KC-CL TM:CO-5000 05/13/05 ACID:KCB7150 20:25:16: .__ .n.n.....____,",_... ........n.............. .......n....____...... If{~~~~~@~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~: ~~~~~~~!~t~~t~~~~I~~ ROBERT A SHOKES 840 YVEROON DRIVE CAMP HILL 17011-1850000 CITI CARDS P.O. BOX 8105 S HACKENSACK. NJ 07606-8105 PA Citi" Platinum Select" Card _. Cltl Account Number 5424 1804 0219 1990 Customer Service: 1-800-950-S114 80X 6500 SIOUX FALLS. SD 57117 Total Credit Line $5000 Statement! Closing Date 11/05/2004 Available Credit LIne $0 Amount Over Credit Une $786.23 + Cash Advance limit Available C.ash Limit $2500 $0 Purch/Adv Past Due Minimum Due $387.07 + $129.60 = New Balance $5786.23 Mlnlml.lm Amount Due $1302.90 Sale Date Post Date Reference Number 11/05 11/05 11/05 Activity SInce La,t Statement Standard Purch LATE FEE - OCT PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT FEE 62 0000 PURCHAsEs'FINANCE CHARGE'PERIODIC RATE 84 0000 Amount 35.00 0000000000 35.00 0000000000 124.60 0000000000 Your account is past due and your balance is over the credit line. To ensure you continue to receive the many benefits of your cardmembership, please send the Minimum Amount Due shown. If you have already sent us this payment, thank you. PrevIous (+) Purchases (-) Payments (+] FINANCE (=) New Balance & Advances & Credits CHARGE Balance $5,591. 63 $70.00 10.00 $124.60 $5.786.23 $0.00 $0.00 0.00 $0.00 $0.00 $5,591. 63 $70.00 0.00 $124.60 $5,786.23 Account Summary PURCHASES AOVANCES TOTAL Rate Summary PURCHASES Standard Purch ADVANCES Standard Adv Balance Subject to Finance Charge Periodic Rate Davs This Bfllfnq Period: 2B Nominal ANNUAL APR PERCENTAGE RATE $5.651. 48 $0.00 0.07874%(D) 0.07874%(D) 28.740% 28.740% 28.740% EXHI~'i~ Verification 1,th1J:{A JdQ CQlYr< am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiffCITIBANK 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 off act 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 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: n/-!2R (OS- C1;f}Jrh~ Signature Robert A Shokes 5424180402191990 ;v ("::) Xl. #- l .0 ........ (y 9 r--- ...... 0- i:: 0 ...., ~ D () C (:~':> 0 C~.::> "- p.::. ~<. "" oj W ~ :;:J ~ ['.;, :TJ r-. I',"t U1 ,----, '. ~ -n C) -c, - -.T~ ,. '. -'0. \~-=-:) , - \'? i'Tl --' -< l",", - SHERIFF'S RETURN - REGULAR CASE NO: 2005-03615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SHOKES ROBERT A BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHOKES ROBERT A the DEFENDANT , 2005 CAMP HILL, PA 17011 by handing to ROBERT A SHOKES a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 12.00 .37 10.00 .00 40.37 .r~~ R. Thomas Kline 07/19/2005 BURTON NEIL Sworn and Subscribed to before By: J~_~ . Dep y Sheriff me this d..J,"",,- day of '-f' tl- d-V1:Ji A.D. l ~fln:t~V" "A~' 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, PENNSYL Y ANIA YS. : NO. 05-3615 Civil ROBERT A SHOKES Defendant : CIVIL ACTION - LAW PRAECIPE TO SETTLE, END & DISCONTINUE TO THE PROTHONOTARY: Mark the above matter Settled, Ended and Discontinued. __:7 & A&SOCLmuC .....B..y:. ~ ~) Burton Neil, Esquire -_.. Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-6042 II11I111 m 1I11~ I1111 lUll IKK III11I11 1IIIIKIIIIIIIIUIIIIIIIlIlII1~1 U~IIIIIIIIIIIUIIIIIIIIIIIIIIIIIIIIUIIIIIIIIIIIII (} ~~:>. _'\\."; ($1\\., ~~J;~ . "(::". ':~~>(~:t . ,.;", '';.L.. ~ 'fJ. ~ ,p ~ ~ t'9 'f), Q, ~.-c\. ~~~ -<>Q -'\C) I:?< :;~ ~"Sn "z.," .~ -2 ':;i