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Home My WebLink About06-1865 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 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(" - I PtsS C!iu~( c,-0-hf MICHAEL PAXTON 60 Subdivision Road, Newville PA 17241-8602 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-9230 111110111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 , BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, 1.0. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) NA 701 East 60th Street North, Sioux Falls, SD Plaintiff v. MICHAEL PAXTON 60 Subdivision Road, Newville PA 17241-8602 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 010 - IPLS Cwl'f&l : CIVIL ACTION - LAW Complaint 1. Plaintiff is Citibank (South Dakota) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Michael Paxton, who resides at 60 Subdivision Road, Newville, 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. Plaintifffurnished consumer credit to the defendant by means of a credit card with account number 5424180517250004 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $4,076.75 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$4,076.75, and the costs of this ) , f BURTON NEIL fL' ASSOCIATES, P.C. action. The law firm of Burton Neil & Associates, P.C. By:// ~ rei], Esquire is a debt collector. . , 03/03/06 $4076.75 $4076.75 [~~~r:M~~~~W[~i~t~~~ ~~~~@i~~~~~~l~ ~~~~~~~~~~#g~}~l~~ SITE:KC-CL TM:CO-5000 ACID:KCB3104 03/09/06 22:06:21: MICHAEL PAXTON 60 SUBDIVISION RD NEWVILLE 17241-8602000 C IT I CARDS PO BOX 183056 COLUMBUS, OH 43218-3056 PA (1/181JO l Citr Card _. eltl ACCQl.lfIt HI.If'Ilber 5424 1805 172S 0004 Customer Service: 1-800-925-8871 BOX 6500 SIOUX FALLS. SO 57117 Total Credit Line $3150 Statement! Closlnq Oat. 02/08/2006 Available Credit Line $0 Ami:>unt Over Credit Line $926.75 Cash Advance Limit $3000 Past DUll $891. 02 Avallable Castt Limit $0 Purctt/Adv h1!nlmum Due U05.68 Newealance $4076.75 Minimum Amount Due $4076.75 Sale Date Post Date Reference Number 2/08 Activity Since Last Statement Standard Purch PURCHASES"FINANCE CHARGE"PERIODIC RATE 84 0000 Purch/Adv Thru 07/11/2005 PURCHASES"FINANCE CHARGE"PERIODIC RATE 84 0000 Amount 9.35 0000000000 2/08 91. 33 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. EXHIBIT 'f- PrevIous (+) Purchases (~) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Balance $3,976.07 10.00 10.00 $100.68 $4,076.75 $0.00 0.00 0.00 $0.00 $0.00 $3.976.07 0.00 0.00 $100.68 $4,076.75 Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Purch/Adv thru 07/11{2005 ADVANCES Standard Adv Balance Subject to Finance Charge PeriodiC Rate Days ThIs Bllllf1q Period: 29 Nominal ANNUAL APR PERCENTAGE RATE $373.77 $3,650.69 $0.00 0.08627%(0) 0.08627%(0) 0.08627%(0) 31. 490% 31. 490% 31.490% 31. 490% 31. 490% 31. 490% , Verification Kris Dietz I, am an employee of Citicorp 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 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: O~~\ ~ -0<.0 Signatur8:==~=~L_ ~ ~ ~ r--J " ,'-'" 8 tr't ',' \- Y\ "~','" ;-::\ -..... ;('1. en. :::',) ~ t,' - () 0 ..:c ~ \). ~ - .- ~ ...:t (,. ---e::. "32- \...J --...0 0;' ~ - ----------- ---- 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 OMMON PLEAS Plaintiff : CUMBERLAND CO TV, PENNSYL Y ANIA YS. : NO. 06-1865 civil MICHAEL PAXTON Defendant : CIVIL ACTION. LA PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudic . BY: Burton ei, Esquire Attorne fI Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-923 0 1111101 m I~m 1~111~lIllm I~IIIII 1IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIImlllllmMMI~IIMIIII miD I mllm~~11 ~1111~IMDlllmllll ~IIIII (') \=; ~;. r "'" ~ C-::O C1"\ o -n ---1 mill -1'"1,"'-: ",0 " i -~i~? ::J:: :;::." --". (..) ~ -:.'" ,;,--:::.:.' ;,,?C) C:-sn'1 ~ $ -< <.., SHERIFF'S RETURN - REGULAR CASE NO: 2006-01865 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS PAXTON MICHAEL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PAXTON MICHAEL the DEFENDANT , at 1448:00 HOURS, on the 12th day of April , 2006 at 60 SUBDIVISION ROAD NEWVILLE, PA 17241-8602 by handing to NANCY PAXTON, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Aff idavi t Surcharge So Answers: 18.00 11.44 .00 10.00 .00 39.44 Y- r~-:"'<:~ R. Thomas Kline 04/13/2006 BURTON NEIL me this iq"" day of By: c24z~/ Deputy She:r;;iff Sworn and Subscribed to before ~ .J 0'0 (, A.D. Prothonotary