The URL can be used to link to this page

Home My WebLink About02-4543BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 7920 NW 110th Street Kansas City, MO Plaintiff V. WILLIAM W MCGUIRE 367 Maple Lane Carlisle, Pa Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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. LAWYER REFERENCE AND iNFORMATION SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 Telephone No. 800-990-9108 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 7920 NW 110TH STREET KANSAS CITY, MO Plaintiff : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM W MCGUIRE 367 MAPLE LANE CARLISLE, PA Defendant CIVIL ACTION - LAW Complaint 1. The plaintiff is Citibank South Dakota N.A., with place of business located at 7920 NW 110TH STREET, KANSAS CITY, MO. 2. The defendant is WILLIAM W MCGUIRE, who resides at 367 MAPLE LANE, CARLISLE, CUMBERLAND County, Pennsylvania. 3. At the defendant's request, plaintiff issued the defendant a credit card with account number 4271382089795898 for the defendant's use in making credit purchases and securing cash advances subject to the terms and conditions governing the use of the credit card. Attached hereto, made a part hereof and marked Exhibit A is a true and correct copy of the terms and conditions. 4. The defendant accepted the credit card and the terms and conditions governing its use for the purchase of goods, merchandise and services and/or cash advances from vendors who accepted plaintiffs credit card. In using the credit card, the defendant agreed to comply with the terms and conditions governing its use which included the obligation to pay plaintiff for all the charges made in full upon receipt of the statement or in installments subject to monthly finance charges. 5. The defendant utilized the credit card by making/obtaining purchases of goods, merchandise and services and/or cash advances from vendors who accepted the credit card. Monthly statements were sent to the defendant which detailed the charges made to the account including finance charges, late and/or over limit charges. The balance due for the charges made by the defendant including any finance charges, late or over limit charges is $2,960.30. 6. Defendant did not pay the balance due in full upon receipt of the billing statements and failed to make the required minimum monthly payment set forth in the the billing statement. As such, defendant is in default of the terms and conditions governing the use of the credit card. 7. Although demand has been made by plalntiffupon defendant to pay the sum of $2,960.30, the defendant failed and refused to pay all or any part thereof. 8. Plaintiff alleges it is entitled to recovery of attorney's fees from defendant pursuant to the terms and conditions governing the account. Plaintiffs counsel is not a salaried employee of Citibank South Dakota N.A. Plaintiff seeks recovery of attorney fees in the sum of $562.46. WHEREFORE, plaintiff demands judgment against the defendant in the sum of $2,960.30, attorneys fees in the sum of $562.46 and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. By: t~ ~ ~t/ Burton Neff, Esquire t, Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. Verification Jermifer Sisson is an attorney management specialist for Citibank (South Dakota), N.A. and Citicorp Credit Services, Inc., wholly owned subsidiaries of Citigroup, the within Plaintiff in this action. She verifies that the statements of fact made in the foregoing Complaint are true and correct to the best of her knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-04543 P COMMONWEALTH OP PENNSYLVP~NIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA N A VS MCQUIRE WILLIAM W R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MCCGUIRE WILLIAM W unable to locate Him COMPLAINT & NOTICE in his bailiwick. but was He therefere returns the NOT FOUND as to the within named DEPENDANT MCCGUIRE WILLIAM W UNABLE TO SERVE PRIOR TO EXPIRATION, ALTHOUGH 17 ATTEMPTS WERE MADE. Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 R. Thomas Kline ~ Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this ~ day of ~ ~2~ ,~_ A.D. Pro~lo~ot ary ~ BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification number: 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 7920 NW 110TH STREET KANSAS CITY, MO Plaintiff V. 7142 WILLIAM W MCGUIRE 367 MAPLE LANE CARLISLE, PA Defendant To the Prothonotaxy: Please reinstate the Complaint. : IN THE COURT OF COMMON PLEAS : CUMBERLAJqD COUNTY, PENNSYLVANIA : NO. 024543 : CIVIL ACTION - LAW Praecipe to Reinstate ~ItJRTO~NEIL & ASSOCIATES, P.C. / By: Attorney for Plaintiff 10015.034.278 SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-04543 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA N A VS MCQUIRE WILLIAM W R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: MCCGUIRE WILLIAM W unable to locate Him COMPLAINT & NOTICE but was in his bailiwick. He therefore returns the the within named DEFENDANT NOT SERVED , as to , MCCGUIRE WILLIAM W UNABLE TO SERVE PRIOR TO EXPIRATION ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 -]4.90 R. THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY BURTON NEIL & ASSOC 01/07/2003 Sworn and subscribed to before me BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. 701 East 60~ Street North Sioux Falls, SD Plaintiff VS. WILLIAM W MCGUIRE 367 Maple Lane Carlisle, PA Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4543 : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above-captioned action without prejudice. BURTON NEIL & ASSOCIATES, P.C. ~4~~sq/Uire Attorney for Plaintiff