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Home My WebLink About06-6363 .. Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. 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 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HARRISONWPATNO 544 North Enola Drive, Enola PA 170252120 Defendant NO. Of..o - ~3'-3 C;fJJ_j-~ : CIVIL ACTION - LA W 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-9602 11111111 III 111111 I1II11I111 1111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111I11111111 .. Burton Neil & Associates, P,C. By: Burton Neil, Esquire, LD. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIDANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO, Or,- (,3(,3 ~~ HARRISON W P A TNO 544 North Enola Drive, Enola PA 170252120 Defendant : CNIL ACTION - LAW Complaint 1. Plaintiff is CITIDANK (SOUTH DAKOTA) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Harrison W Patno, who resides at 544 North Enola Drive, Enola, 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 5424180889212681 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 $27,367.91 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 ~, sum of $27,367,91, and the costs of this action. Burton Neil &. sociates, P.C. ,~ -,- -' The law firm of Burton Neil & Associates, P.c. is a debt collector. I.. Q-q{cm. 03/14/06 ~~~mi~Ji~~ii~~~~~~~~ $26623.03 ~~~.~~~~~~~@ $5021.05 :~:~#ii~~~:~:mi:~:~: ........................ .....--................... SITE: KC-CL TM:CO-5000 09/09/06 ACID:KCC5750 16:41:28: HARRISON W PATNO 544 N ENOLA DR ENOLA 17025-2120000 CITI CARDS PO BOX 183063 COLUMBUS, OH 43218-3063 PA . Citie Diamond Preferrecr Entertainment Card Account Number 5424 1808 8921 2681 Customer Service: 1-800-866-9900 BOX 6500 SIOUX FALLS, SO 57117 S8It Da Poet Date cffr Total Credit Line $25000 Statementl Cl051n9 Date 02/17/2006 c...., ~val...ble Credit Line $0 Amount Over Credit Lint Past Due $1623.03 + $2442.23 + Actlvlty $1.- Lut st.wn.nt Standard Purch LATE fEE - JAN PAYMENT PAST DUE 66 0000 OVER CREDIT LIMIT fEE 62 0000 PURCHASES*fINANCE CHARGE*PERIODIC 84 0000 Cnh ~dvante Limit $500 Available C<lsh Limit $0 Purth/Adv Minimum OUt $955.79 = New Balante $26623.03 Minimum Amount OUt $5021.05 Amount 2/17 2/17 2/17 35.00 0000000000 35.00 0000000000 565.21 0000000000 RATE 2/17 Balance Transfer - Charged To Offer 4 PURCHASES*fINANCE CHARGE*PERIODIC RATE 84 0000 90.58 0000000000 ****Citi Card ThankYou Points Summary**** Base Points Earned Total ThankYou Points Earned This Period Points Transferred to Your ThankYou Network Member Account Activity This Period o o o Go to thankyouredemptions.com to review your ThankYou Point balance and redeem! Bonus Points may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Log on to www.thankyouredemptions.com where rewarding yourself has never been easier. You can review your ThankYou Points balance, browse through the full redemptions collection, and redeem online! Your account balance is over the credit line. In order to continue earning ThankYou Points with your card, you must bring your account balance under the credit line now. If you have not already done so, please pay the Minimum Payment Due. Don't forget! Your Citi Diamond Preferred Entertainment Rewards Card is the card that rewards you for all of your everyday purchases with ThankYou Points. Why use a card that doesn't give something back? Visit www.thankyouredemptions.com or call 1-877-7-REDEEM for more information! EXHIBIT - -4 - l ...,).. HARRISON W PATNO SllII DN Post D* Amount C.-.orv ActIvIty SInce Last stlltllMnt Account Summary PURCHASES ADVANCES TOTAL Rate Summary PURCHASES Standard Purch Offer 4 ADVANCES Standard Adv PrevIous Balance $25,897.24 $0.00 $25,897.24 Balance Subject to Finance Charge $22,591.99 $3,620.48 $0.00 (+) Purchases & Advances $70.00 $0.00 $70.00 (-) Payments & Credits to.OO 0.00 0.00 Periodic Rate 0.08627%(0) 0.08627%(0) 0.08627~(D) (+) FINANCE CHARGE $655.79 $0.00 $655.79 (=) New Balance $26,623.03 $0.00 $26,623.03 Days This BllIlng Period: 29 Nominal ANNUAL APR PERCENTAGE RATE 31.490% 31. 490% 31.490% 31. 490% 31.490% 31. 490% , ' \ .. ,. I Verification I,~~wc-r~::1o~ fd 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 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. ~J&~J CCcJo~ I~ cPJ(f) Harrison W Patno 5424180889212681 ~ (J ~ ~ ~ """- ~ tJ? ~ " () ~ ~ p:! ~ CY (: ~ ~ 8 ~ 0 (0) ~ ~~ c"" ,1 ~-:.)'"_ <=) "-I C') :I ..,..., _j l"11f"" w -0 rr: -:_0 c:: ;.~~.~~ (1 t ~'~ :!: ~,~ '.- ~ w :~5m c--{ '" ~:o -..J -< Burtc~ Neil & Associates, P .C. By: Burton Neil, Esquire ro. NO. 11348 1 U60 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 v. HARRISON W PATNO Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-6363 : CNIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. iates, P.C. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-9602 1111111111I111111111111111I1111111111111 11111111111111111111111 1111111111111111111111I11111I111111111111111/1111111111111 /111 r--.) C~ c.:..::::J t;".;..""'""' o -n ::;J o r-.; n (',) --J c:; .. C)