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Home My WebLink About06-2316 t 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) NA 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. Ot.., - .;(31 b ~ Cw ; L 1 Cfi..~ MICHAEL S MICHALISZYN 320 S York Street, Mechanicsburg PA 170556302 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, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 C-9175 111111111111111111111111111111I111111111 1111111111111111I11111111111111111111111111I1111111I11111111111111111111111111I1111111I11111111 BURTON NEIL & ASSOCIATES, P.C. I By: Burton Neil, Esquire, J.D. 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 CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Dl - ), 3 n C;u~L~~ MICHAEL S MICHALIS2YN 320 S York Street, Mechanicsburg PA 170556302 Defendant : 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 S Michaliszyn, who resides at 320 S York Street, Mechanicsburg, 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. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180468111676 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 $14,461.20 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 $14,461.20, and the costs of this action. BURTON-NEIL & ASSOCIATES, P.C. , By: ~rto~;'eil, ~sqUlre The law firm of Burton Neil & Associates. P.c. is a debt collector. r4 G-q \Ie; 01/02/06 $14561,20 $14561,20 ~@!~~~~W~~~@lffl~~~~ ~~~~Mi~~~~ml.m@1~ ~~~~j@~~f~gr~ SITE:KC-CL TM:CO-5000 ACID:KCB3104 02/22/06 22:58:32: MICHAEL S MICHALIS2YN 320 S YORK ST MECHANICSBURG 17055-6302000 ClTl CARDS PO 80X 1830S4 COLUMBUS. OH 43218-3054 PA Citi~ Platinum Select~ Card clfr AttoUl"ltNurnber 5424 1804 6811 1676 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS. SO 57117 Total Crellit LIne $15900 St.tement/ Closlnq Date 12/07/Z005 A....allable Credit Une $0 Amount O...er Credit Line $0,00 Cash Advan~e Limit $2500 Past Due $1476.57 A'o'allable Cash Limit $0 Purch/Adv "1!nlmum Due $441.17 New Balance $14561,20 Minimum A.molJnt Due $14561.Z0 Salll Dote Post Date Reference Number 12/07 12/07 Activity Since Last Statement Standard Purch LATE FEE - NOV PAYMENT PAST DUE 66 0000 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Balance Transfer - CharQed To Offer 6 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Balance Transfer - CharQed To Offer 7 PURCHASES'FINANCE CHARGE'PERIODIC RATE 84 0000 Amount 35.00 0000000000 3.06 0000000000 12/07 216.58 0000000000 12/07 181. 53 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 It Account Summary PrevIous (+) Purchases (-) Payments (+) FINANCE (=) New Balance & Advances & Credits CHARGE Ba lance PURCHASES $14,125.03 $35.00 r.oo $401.17 $14.561. 20 ADVANCES $0.00 $0.00 0.00 $0.00 $0.00 TOTAL $14.125.03 $35.00 0.00 $401.17 $14.561. 20 Ba lance Subject to Perlodl C Davs ThIs Bllllng Perfod: 33 Rate Summary Nomlnaf ANNUAL Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $109.12 0.08490%(0) 30.990% 30.990% Offer 6 17.730.19 o .08490%(D} 30.990% 30.990% Offer 7 6.479.29 0.08490%(D} 30.990% 30.990% ADVANCES Standard Adv $0.00 o .08490%(D} 30.990% 30.990% Verification I, Kris Dietz 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: tJ .~-j?,- o\c. Sign~~=-~~___ ;::) \:l <Q P Ul. ~ Ul. -:z ..:t C> w ~ N ....:t - '\). " VI C) -..) \(- ::D +- +- --L. . .\ .- ~ re BURTON NEIL & ASSO IATES, P.C. ~y Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 17 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTII DAKO A) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. MICHAEL S MICHALISZ : NO. 06-2316 civil : CIVIL ACTION - LAW P ECIPE TO SETTLE, END & DISCONTINUE Settled, Ended and Discontinued. , BURTON NEI & ASSOCIATES, P.C. Burton Neil, Esq ire Attorney for Plaintiff The law firm of Burton Neil Associates is a debt collector. C-9175 1111111111111111111111111111111111111111 11111111111111111 11111 1111111I11111111111111I11111I111111111111111111111111I11111111 o c r--.) = c..::> CS"' C.- c::= -"""" ..a>~ ~. I C"> o -n -l :c .,-, rn~ Ill"'" ~"...,. '- ',...... <2 ~F(' --r:- ';J:J -< N ~_. SHERIFF'S RETURN - REGULAR CASE NO: 2006-02316 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS MICHALISZYN MICHAEL S 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 MICHALISZYN MICHAEL S the DEFENDANT , at 1843:00 HOURS, on the 2nd day of May , 2006 at 320 S YORK STREET MECHANICSBURG, PA 17055 by handing to MICHAEL S MICHALISZYN 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 Affidavit Surcharge So Answers: (~ 5};; 'if 0 4 18.00 17.60 .00 10.00 .00 45.60 r~~~ R. Thomas Kline 05/03/2006 BURTON NEIL day of By, ~4/ Deputy Sheriff Sworn and Subscribed to before me this A.D. Prothonotary