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Home My WebLink About09-8676A Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. n XENOFON SKABOULOS NO. 09 - BL 74 l:. [ v L _7Lrn 195 Hickory Road, Carlisle PA 17015-9748 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-29219 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. d 9 - F& 7 (P C't? 7-e.,, 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 Xenofon Skaboulos, who resides at 195 Hickory Road, Carlisle, 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(n) Sears credit card with account number ending in 7515 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 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. XENOFONSKABOULOS 195 Hickory Road, Carlisle PA 17015-9748 Defendant account of the billing statement or retained the statement without payment. w 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $8,270.55 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 $8,270.55, and the costs of this action. BurtonXeil A Associates, P.C. Wtein, Esquire for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt ' Sears Gold MasterCard' XENOFON SKABOULOS Account Numbe.7515 Page 1 of 2 Your Account Summary Billing Cycle Closing Date 06/19/08 Amount Over Credit Line $80.55 Amount Past Due $1,550.47 Current Minimum Due $125.00 Total Minimum Due $1,756.02 Previous Balance $8,270.55 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $0.00 FINANCE CHARGES $0.00 Account Balance $8,270.55 Your Credit Summa Total Credit Line $8,190.00 Available Credit Line $0.00 Cash Access Line $1,638.00 Available Cash $0.00 Call us at 1-800-669-8488 Go to www.searscard.com Write to us at PO Box 6282 Sioux Falls, SD 57117-6282 Payment Due Date 07/09/08 Put this money toward bringing your account current. We have a number of solutions that may be available to help, including: • Save on fate has • Reduce your balance- • Lower your annual matched your payment percentage rate- ?r dollar up to $5" save finance charges • Settle your account • Lower your monthly for less than your payment total balance Call us today at 1-866-518-9052. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Average Corresponding Periodic Rate Periodic Daily ANNUAL D--Day FINANCE Rates *Rate Varies Balance Balance PERCENTAGE RATE M=Month CHARGE SEARS REGULAR $1,544.28 $0.00 28.99%* .0795%(D)* $0.00 EXTERNAL REGULAR $6,726.27 $0.00 28.99%* .0795%(D)* $0.00 CASH ACCESS REGULAR $0.00 $0.00 28.99%* .0795%(D)* $0.00 Days in Billing Period: 30 Effective ANNUAL PERCENTAGE RATE: 28.99% Minimum FINANCE CHARGE: $0.00 Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Gold MasterCard' Account Numbe 7515 Payment Total Account Balance Due Date Minimum Due Amount Enclosed $8,270.55 07/09/08 $1,756.02 0000000 EX 14 08171 1 TXS503 `FVG 001 7 W IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIl1IlI111IIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII111IIIIIIIIIIIIIIIIIIIIIIIIII Make check payable to XENOFON SKABOULOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3082 FF,M Please make address corrections above. LA l BIT 100 515 0827055 0175602 0000000 1415 Sears Gold MasterCard® Call us at 1-800.669-8488 Go to www.seemcard.com Write to us at PO Box 6282 Sioux Falls, SD 57117-6282 Cardmember News XENOFON SKABOULOS Account Number: XXXX XXXX XXXX 7515 Page 2 of 2 0 Payment Due Date 07/09/08 The Sale Date is the Transaction Date. Verification I Mark Molinarin , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I Ka4A ?s Signature C-29219 Xenofon Skaboulos Account number ending in 7515 1032 05 tt 1 tJ j." 3,, C. -r, II 19.2-60 1'?LAII-j Ge 6, 5y2/.-I- L L 5(--?. 241- as s?s?? SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor gt?N?N til CftntGrr/?? ? ?f0WTXU( ?.? 2fl16 JAN -6 Are 8:45 aI RAQ V V Citibank (South Dakota) N.A. I Case 2009-$676 Number vs. Xenofon Skaboulos SHERIFF'S RETURN OF SERVICE 12/29/2009 03:50 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2009 at 1550 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Xenofon Skaboulos, by making known unto himself personally, at 195 Hickory Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 December 30, 2009 SO ANSWERS, ?100 R THO S I E, SHERIFF By Depxtty Sheriff fc) Ccunf,SWte Sheriff. Teeosoft , lid. CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Street N : CUMBERLAND COUNTY, PENNSYLVANIA Sioux Falls, SD 57117 Plaintiff V. No: 09-8676- CIVIL TERM XENOFON SKABOULOS 195 Hickory Road Carlisle, PA 17015-9748 Defendant a "n ;e "-TIM NOTICE TO PLEAD T To: Citibank (South Dakota), N.A. c/o Yale D. Weinstein, Esquire ? rv ` Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 You are hereby notified to plead to the enclosed Preliminary Objections within twenty (20) days from the date of service hereof or a default judgment may be entered against you. Date: 1z ho Respectfujly SV6 nitted, Michael J. Pykosh, Esquire I.D. # 58851 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant, Xenofon Skaboulos Michael J. Pykosh, Esquire ID # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 Wykoshr.ddcdlaw.net Attorney for Defendant CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Street N : CUMBERLAND COUNTY, PENNSYLVANIA Sioux Falls, SD 57117 Plaintiff V. No: 09-8676- CIVIL TERM XENOFON SKABOULOS 195 Hickory Road Carlisle, PA 17015-9748 Defendant DEFENDANT'S. PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Xenofon Skaboulos, by and through his attorneys, DETHLEFS-PYKOSH LAW GROUP, by Michael J. Pykosh, Esquire, and hereby files Preliminary Objections to the Plaintiff's Complaint, and avers as follows: 1. On or about December 17, 2009, a Civil Complaint was filed at Docket Number 09- 8676 Civil Term. 2. Defendant now files the instant Preliminary Objections to Plaintiff's Complaint pursuant to Pa. R.C.P. 1028. PRELIMINARY OBJECTIONS PURSUANT TO Pa. R.C.P. 1028(a)(2) 3. Paragraphs 1 through 2 are incorporated herein by reference as though fully set forth below. 4. Pa. R.C.P. 1028(a)(2) allows a party to preliminarily object to a pleading if the pleading fails to conform to law or rule of court. 5. Plaintiff's Complaint fails to conform to Pennsylvania Rules of Civil Procedure and Cumberland County Local Rules. 6. Plaintiff has failed to attach a copy of the writing, more specifically the Loan/Credit Agreement, or the material part thereof, or, in the alternative, state, with the reason that the writing or copy thereof is not accessible to the Plaintiff and the substance of the writing in violation of Pa. R.C.P. 1019(i). See Remit Corporation v Miller 5 Pa. D&C 5th 43 7. Plaintiffs Complaint is in violation of Pa. R.C.P. 1019 (a) and (f) in that Plaintiffs Complaint fails to provide the specifics of the alleged credit card purchases or charges and application of interest and late charges. Remit Corporation v Miller 5 Pa. D&C 5th 43. See also Capital One Bank v Clevenstine, 7 Pa. D&C. 5th 153. WHEREFORE, for all the reasons set forth above, Defendant, Xenofon Skaboulos, respectfully requests that this Honorable Court sustain Defendant's Preliminary Objections, and dismiss Plaintiff's Complaint for failing to conform to law or rule of court pursuant to Pa. R.C.P. 1028(a)(2). PRELIMINARY OBJECTIONS PURSUANT TO Pa. R.C.P. 1028(a)(3) 8. Paragraphs 1 through 7 are incorporated herein by reference as though fully set forth below. 9. Pa. R.C.P. 1028 (a)(3) allows a party to object to a pleading if there is insufficient specificity in a pleading. 10. Plaintiff has not set forth sufficient facts regarding Defendant's Agreement relative to either the total amount due and that Defendant has agreed to pay the amount to Plaintiff. See Capital One Bank (USA), NA v Patricia L. Clevenstein No. 2008-4139 (Centre County 2009). WHEREFORE, for all the reasons set forth above, Defendant, Xenofon Skaboulos, respectfully requests that this Honorable Court sustain Defendant's Preliminary Objections, and strike Plaintiff's Complaint for failure to comply with Pa. R.C.P. 1028(a)(3). PRELIMINARY OBJECTIONS PURSUANT TO Pa. R.C.P. 1028(a)(5) 11. Paragraphs 1-10 are incorporated herein by reference as though fully set forth below. 12. Pa. R.C.P. 1028(a)(5) allows a party to object to a pleading if the Plaintiff lacks capacity to sue, nonjoinder of a necessary party, or misjoinder of a cause of action. 13. Plaintiff has failed to establish standing in that Plaintiff has not attached a properly executed assignment to support the allegation that Plaintiff is the successor to the original creditor. See Atlantic Credit and Finance. Inc. v Carmen L. Giuliana and Patricia Wilson a/k/a Patricia A. Maurizo 2003 Super 259; 829 A 2d 340 (PA Super 2003). WHEREFORE, for all the reasons set forth above, Defendant, Xenofon Skaboulos, respectfully requests that this Honorable Court sustain Defendant's Preliminary Objections, and dismiss Plaintiff's Complaint for lack of capacity to sue pursuant to Pa. R.C.P. 1028(a)(5). Date: t iZ [ a Respectfully Sub fitted, Michael J. yko re I. D. # 58851 2132 Market Street Camp Hill, Pennsylvania 17011 (717)975-9446 CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Street N : CUMBERLAND COUNTY, PENNSYLVANIA Sioux Falls, SD 57117 Plaintiff V. No: 09-8676- CIVIL TERM XENOFON SKABOULOS 195 Hickory Road Carlisle, PA 17015-9748 Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant, Xenofon Skaboulos, Preliminary Objections to Plaintiffs Complaint, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Citibank (South Dakota), N.A. c/o Yale D. Weinstein, Esquire Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Date: 2 I d Respectfully Submi#tl, Michael J. Pyosli, Esquire I. D. # 58851 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant VERIFICATION I, Xenofon Skaboulos, hereby verify that the statements of fact made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: (?/JO /?G /---,0 ro k/ > K ?y ( o Xenofon Skaboulos J , FILE! :dal E TF= - TA 'Y 2010 FEB - I A 9: 00 141 BURTON NEIL & ASSOCIATES, P.C. Neil Sarker, Esquire ID. No. 203465 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 PENNSYLVANIA V. XENOFON SKABOULOS : NO. 09-8676-CIVIL TERM Defendant : CIVIL ACTION - LAW Answer to Preliminary Objections Plaintiff Citibank (South Dakota) N.A., by its counsel, Burton Neil & Associates, P.C., hereby responds to defendant's preliminary objections as follows: 1. Admitted. 2. Admitted. 1. Pa. R. C. P. -1028(a)(2) 3. Plaintiff incorporates by reference above paragraphs 1 through 2 of its answer to defendant's preliminary objections. 4. Admitted. 5. Denied. Plaintiff's complaint is a document which speaks for itself. Denied also as a conclusion of law to which no response is required. W 6. Admitted in part, denied in part. It is admitted only that plaintiff did not attach a loan agreement. The balance of the allegation is denied. It is specifically denied that plaintiff was required to attach an agreement since its cause of action is not based on an agreement, but on an account stated. Further, plaintiff's complaint had attached a copy of the last monthly billing statement sent to defendant, the only document required to be attached when pleading an account stated cause of action. Rush's Service Center, Inc. v. Genareo, 10 Pa. D. & CAth 445, 447 (Lawrence County, 1991). Citibank (South Dakota), N.A. v. King, 2 Pa. D. & C. 5th 60, 63 (Centre County, 2007. 7. Denied as stated. Plaintiff incorporates by reference above paragraph 6 of its answer to defendant's preliminary objections as if set firth fully herein. By way of further response, it is specifically denied that plaintiff in setting forth and pleading the account stated was required to individually set forth the items of which the account consist, or to itemize the account. Ryon v. Andershonis, 42 Pa. D. & C.2d 86 (Schuykill County, 1967). WHEREFORE, Plaintiff prays this Honorable Court overrule defendant's preliminary objections. II. Pa. R. C. P. 1028(a)(3). 8. Plaintiff incorporates by reference above paragraphs 1 through 7 of its answer to defendant's preliminary objections. 9. Admitted. 10. Denied. Plaintiff's complaint sets forth all required material facts in support of its account stated cause of action. Rush's Service Center, Inc. v. Genareo, 10 Pa. D. & CAth 445, 447 (1991). Furthermore, defendant was the card holder to the account and therefore is privy to information regarding the card, which information is as much within his control as plaintiff's and ? y he should be in a position to refer to his own records in order to plead any appropriate defenses. See Cianfrani v Commonwealth State Employees Retirement Board, 78 Pa. Commw. 597, 468 A.2d 1151 (1983), aff'd, 505 Pa. 294, 479 A2d 468 (1984). WHEREFORE, Plaintiff prays this Honorable Court overrule defendant's preliminary objections. M. Pa. R. C. P. 1028(a)(5). 11. Plaintiff incorporates by reference above paragraphs 1 through 10 of its answer to defendant's preliminary objections. 12. Admitted. 13. Denied. Denied that plaintiff's complaint makes any mention whatsoever of any assignment or that plaintiff is a successor in interest. To the contrary, plaintiff brought the instant action to recover the balance due on a credit card that it, the original creditor, issued to the defendant as set forth in its complaint. WHEREFORE, Plaintiff prays this Honorable Court overrule defendant's preliminary objections. Burton Neil & Associates, P.C. By Neil Sarker, Esquire In making this communication, we advise our firm is a debt collector. }} r FILE r: F- 2010 FFB -1 All 9:00 ff''. f,&l; i' 4r p.I Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 V. : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8676 CIVIL TERM XENOFONSKABOULOS Defendant : CIVIL ACTION - LAW Certificate of Service I, Neil Sarker, Esquire do hereby certify that I served a true and correct copy of the within plaintiff s Response to Preliminary Objections on defendant's counsel, Michael J. Pykosh, Esquire pursuant to Pa R.C.P. 440 (d)(1) and (2) on January 29, 2010 by facsimile transmission. Burton Neil & Associates, P.C. Date: I 2 10 By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. XENOFONSKABOULOS 195 Hickory Road Carlisle PA 17015-9748 zoo 'n _V M O x?-n IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8676 CIVIL TERM Defendant : CIVIL ACTION -LAW Amended 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-29219 / 3 04 BURTON NEIL & ASSOCIATES, P.C. By: Neil Sarker, Esquire, Id. No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff V. XENOFONSKABOULOS Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8676 : CIVIL ACTION -LAW Amended 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. Defendant is Xenofon Skaboulos, who resides at 195 Hickory Road, Carlisle, Cumberland County, Pennsylvania. 3. At all times material and relevant hereto plaintiff was a national bank engaged in various types of banking business, including but not limited to consumer lending through the issuance of credit cards. 4. On our about August 1, 1998, defendant applied to Sears National Bank for a credit card. Defendant's application is no longer accessible because of the age of the document. The substance of the application, it is believed and averred, set forth defendant's full name, address, social security number, home telephone number, date of birth, occupation, employment information and earnings. 5. Pursuant to the application, Sears National Bank on or about August 1, 1998, opened an account for defendant with account number now ending 7515. 6. Sears National Bank provided defendant a credit card for the account together with terms and conditions (the card agreement) which defendant received. 7. Citibank USA, N.A. through acquisition obtained the Sears National Bank accounts in November 2003. On October 1, 2006, Citibank USA, N.A. merged into Citibank (South Dakota), N.A., the plaintiff in the instant litigation. 8. Citibank (South Dakota), N.A. merged into Citibank, N.A., effective July, 1, 2011. Citibank, N.A. is successor-in-interest to the account. 9. The card agreement sent to defendant with the original credit card is no longer accessible to plaintiff. Subsequent to its being issued, the card agreement was revised and modified. Attached hereto, incorporated herein and marked Exhibit A is a copy of the current card agreement applicable to defendant's account. The substance of prior versions of the card agreement is reflected in Exhibit A. 10. From the inception of the account and continuing through on or about January 20, 2008, defendant conducted transactions on the credit card account. Attached hereto, made a part hereof and collectively marked Exhibit B are copies of monthly billing statements with closing dates from June 26, 2006, through May 2, 2008. 11. Accurate running records of all debits and credits to defendant's account were kept. 12. Defendant was provided with the aforesaid monthly billing statements which accurately stated the previous balance, the debits and the credits to the account for the prior billing period, the new balance and minimum amount due. 13. As noted in the statements, defendant's conduct after receipt of certain statement was reflected by her making payment to plaintiff with the entry "PAYMENT THANK YOU" and the amount of the payment. 14. Defendant last made a payment to plaintiff which was posted on or about January 20, 2008, in the amount of $250.00. 15. The last statement plaintiff provided to defendant had a closing date of May 20, 2008. 16. In using the credit card she received, defendant agreed to pay in full the new balance reflected on the billing statement or pay the minimum amount due reflected on the statement. The Exhibit B statements reflect the payments made by defendant. 17. Defendant after receipt of the May 20, 2008, statement failed to pay either the balance in full or minimum amount due. Count I - Breach of Contract (In the Alternative to Count II) 18. Plaintiff incorporates by reference the averments of paragraphs 1 through 17. 19. Defendant's conduct in failing to pay the balance in full or pay the minimum amount due reflected in the billing statement constituted a breach of the card agreement. 20. Having breached the agreement defendant is liable to plaintiff for the balance due as reflected in the billing statement with a closing date of May 20, 2008, in the sum of $8,270.55. WHEREFORE, plaintiff prays that judgment be entered on its behalf and against defendant on Count I in the sum of $8,270.55 and the cost of this action. Count II - Account Stated (In the Alternative to Count I) 21. Plaintiff incorporates by reference the averments of paragraphs 1 through 17. 22. As aforesaid, a running account of the activity in defendant's credit card account was kept. 23. As aforesaid, each month defendant was provided with a billing statement which reflected the account activity. 24. As aforesaid, each month until the time of default defendant received the billing statement and after reviewing the same made a payment to plaintiff thereby assenting to the account. 25. Defendant's actions as set forth above constituted an account stated between the parties for the sum of $8,270.55 being the balance in the statement with a closing date of May 20, 2008. WHEREFORE, plaintiff prays that judgment be entered on its behalf and against defendant on Count II (in the alternative to Count I) in the sum of $8,270.55 and the cost of this action. BURTON NEIL & ASSOCIATES, P.C. By: Neil Sarker, t squire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. Your Rkft acrd ow Resppeasommiie Anti we Re"1W Yoar Miler Awes. We must admowbdge your leltor withM 30 days, union we have corrected the error by than. Within 90 days, we must either comet the error or explain why we believe your account staternent was corral After we receive your letter, we cannot try to coked any amount you question, or retort t the our account as dellriquoil We can e to bill you for amount you questim IndudNtg Alliance continuchaviles, and we can apply any unpaid amount apainsit your credit fine. You do not have to pay any quested amount while we are inves- tigating, but you are still obloted to pay the parts of your balance that am not in question. If we find that we made a mistake on your account statement, you will not have to pay Mhance related to any have to pay fkwlcc charges and ? will have to muakeeuup arty missed pis on the questioned amount. In either case, we will send you a statement of the amount you owe and the date it is due. If you fail to pay the amount that we think you owe, we may report you as went. However, it our explanation does not satisfy you and you write to us within 10 days tsi tg us that you still retiree to pay. we must tell anyone we report you to that you have a question about your bill. And, we must tell you the name and address of anyone to whom we. reported your account information. We must tell anyone we report 9 ou to that the matter has been settled between us when it finally settled. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your account statement was correct. Speda/ Rule for Credit Card f3erckwa. If you have a problem with the quall of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: • You must have made the purchase ins home state or, 0 not within your home state, within 100 mites of your current address; and • The purchase price must have been more than $50. These limitations do not apply 0 we own or operate the mer- chant, or if we maffed you the advertisement for the property or services. `0 2000 Citibank USA, N.A SGMe Pr. OWN !09060 09/06 CARD AGREEMENT This Card Agreement, which includes your Supplemental Pric; n Udormation rSup ftmmY}, is your contract with us ara? governs the use of you card and account. The Supplement contains Important account Information. Indud- ing your annual percent lp rates. Please net and keep these documents for your records. FACTS ABOUT RATES AND FEES For ins in a then a facts. please see the RATES-FINANCE CHARGES Pull ehae and Cash Awes APR See Supplement All APRs based on the Prime Rate may vary each kg cycle. DIMN APR: See Supplement. The Default APR equals the Prime Rate plus up to 23.99%. AN APRs may automatically increase up to the Debut APR if you fail to make a payment to us when due, exceed your credit line, or make a payment to us that is not honorad. Minimum SO=@ Charlr Stoo. TRANSACTION FEES-FINANCE CHARGES Sallow TrahWW Fee: 3% of each transaction, $5 minimum. PunAases Made M a Forsip Cum" Fee. 3% of each purchase after its conversion into U.S. dollars. Cash Accra Far 3% of each transaction, $5 minimum. t?rHER FEES Late Payment Fen $15 on balances up to $50; $39 on balances of $50 and over. Over•ths-Credit-line Fee: $35. Returned Payment Fee: $29. Retumed Comrenlenoe Cliedt Fee. $29. Stay Payment Oil Convenience Check Fee: $29. Rates, lass, and terms may change: We may change the rates, fees, and terms of your account at any time for any reason. These reasons may be based on Information in your credit report such as your failure to make payments to another creditor when due, amounts owed to other creditors, the number of credit accounts outstanding, or the number of credit inquiries. These reasons may also include competitive or market-related factors. If we make a change for any of these reasons, you wig receive advance notice and a right to apt out in accordance with applicable law. EXHIBIT 4 . lot v ohs o? t a xs"- 3 °• fig, Q ?e I . pill 16 i3 t-al'ard AWE a t ??cma N geCBar ??' x ? ?. 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C i's 0.59 1 0 mm? N A O w o f '? _ l E SAU] Ira, !!Jg -9 - ?? r. C' NA V r a _ A a IL ? - c 'A CH i? a s CCm 0 ,-a NJ I all Flies -ij I : !,:=O.3i ° - z bill a ? «. 9 HS `? m o` a N s ?.muzeii o.1 A w0g1jam.m a m o ?5 a?.Y 'd PZ a e ;? ?E P?'? "E32? o f E +.5 $zs S` 2 ??j a'a @1:1MA N?Nm?.-°.?- =u, ?,ga?ft a?v ?'cYZ`$c$$a 5.520, c earn S?'i'? ?' X'..-y ° m• 'O ° -? N C? ON7 yp? {O d .? w. C m o? T m ? adR??N79Q?0.?-?O?w-?`?_. .. G ApAG `gam„ ? cmj E ?kof Tw e?epp. a m ?• N S. N i+ 6i _N r. V O '-• C tIj a m ?, C A 6t C R .- R •j n,,, y C RtA ?6? Z ?i' 'C.r3'0 .-i/I?eRUwN°+?Cm °? O '?it''a?n L N '? 67 O R° C C N L' N ?• r+ U C.7 ?. e? a E._m 404° ~N 4Q cm O?m mA ym? ?3 m fir„ N mo a a= t?fm?c?vE a.R?`$N3'm 3 m? a s tv?iE?E •=eag52?`tdNs?l?v?}acmJl .'c'mEoo Y$au?o ° + _- y.e T R MW GmtwU.°S ems'-A«Nm? y.7 pC?001 e«mC`O?mCN NW' R ?-. O .7 p E$bE? r %CL:d L3ns°acn?3S }?NEmam5 o?ot?. ca?'cav?c . issued and used according to any instructions we give. The checks must not be used to pay an amount owed us under this or another Card Agreemert that you have with us. We do not certify these checks or return any such checks that have been paid. information on Foreign Currency Conversion Procecims if you make a transaction in a foreign wrew. MasterCard converts the amount knlo U.S. dollars. MasterCard complies with its operating regulations or foreign cw ency conversion procedures then in aNd MasterCard currerrily saes a con- version rate in effect one day prior to ib transaction process- ing date. Such rate Is either a wholesale market rate or the government-mandated rate. The foreign c unary conversion rate in effect on the a pGca- bie processing data for a transaction may differ from the rate in effect on the Transacdon or Post date an your account statement for that transaction. If a transaction is converted by a third prior to such transaction being processed by Mastercar the foreign cur- rency conversion rate for that transaction wilt be the rate selected by that third party. rnertft; Total Minknum Dw: Each biding cycle you must pay at least the Total Minimum Due by the payment due date. The sooner you pay the Account Balance, the less you wig pay in periodic finance charges. The Total Minimum Due is based on the "Calculated Account Balance." The Calculated Account Balance equals the Account Balance on your account staterrient, less any promotional bal- ances where the tarts of the promodml offer do not require a payment To calculate the Total Minimum Due, we begin with any past due amount and add any amount In excess of your credit rme and any additional amount specified in a promotional offer. We then add the largest at the following: • The Calculated Account Balanced is less than $10; • $10 N the Calculated Account Balance Is at least $10; • I% of the Calculated Account Balance (which calculation is rounded to the next h' her whole dollar amount) plus 11 finance charges and any appN- the amount of your bit cable late payment fee; or • 1.5% of the Calculated Account Balance (which calcula- tion is rounded to the next higher whole dollar amount). However, the Total Minimum Due never exceeds the Calculated Account Balance. Additional Payments: If you pay more than your Total Mini- mum Due, .re may apply arty excess to the Total Minimum Due for up to the next two billing cycles. If we do, this will reduce the Total Minimum Due you would ottswwise be re- quired to pay. We will continue to assess finance charges as applicable. Apptiallon of Peynee ft You audwrt s us to apply payments and credits in a way that Is most bvm*h or convenient for to. This may include such paynt?s and credits to low APR b&bnces before APR balaricas and to longer promotional period balances beta shorter prarattonraf period balances. Payments iaefrroefM are credited in accordance wiiddfr the paynront Instructions; on the accowrt staterna t. You must pay us in U.S. dollars using a sheds, shndr Instrument, or autatgtie debut the is drawn an and honored by a bards in the U.S. Do not.sead cash.- We can accept late or partial payments, and payments that reflect "paid in full' or other restdclive endorsenterta, without being our forNgnt ax reserve the to accept paynterdnt made info rency and drawer on funds on deposit outside the U.S. If we do, we select the currency conversion rate at our discretion and credit your aeootant In U.S. dollars after deducting any costs incurred In processing your payment, or we may bill you separately for such costs. Optimal Pay by Plana Santee: You may request to make your psymeW by phorro using our opftW Pay by Phase Service. Each time you make such a request, you agree to pay us the amount shown In the Pay by Phone section on the hock of the account statement. Our representatives are tralned to tell you this amount If you decide to use this optional Pay by Phase Service. Credit Reporting We may report information about your account to credit reporting agencies. Late payments. missed payments, or e s on your account may appear an your credit report If you request cards on your account for others, we may report account information in the rams of those other people as well. We may also obtain fA w-up credit reports on you (for example, when we review your account for a credit line Increase). If you wish to know which agencies we contacted, write us at the Customer Service address on the account statement. If you think we reported erroneous intom ation to a credit reportingp agency, write us at P.O. Box 6921, The Lakes. NV 88901. INe will promptly investigate the matter and if we agree with you, we will contest each credit reporting agency to which we reported and request a correction. If, after our investigation, we disagree with you, we will tell you in writing or by telephone and tell you how to submit a statement to those agencies for inclusion in your credit report na. c lot E { i Us till E g ,,tt .. R s . its r s a Elf - tli Is ItI111,401V SIC S all al 's 1111111-12, ? T ' ?. iL o v C? es es J ? .rs i5 ? .'`a ?t ? ac __i A. ?g n w ,,fi}gg ? O _?. is.-Ill fit fit, ill golf .$ - - CR - r? $ V .. 3 = 131 Q 11 j 1 4 yr 1 t 11 3 7i .. 9 • .?! t4 .9 3 ? ! w c /° y. A Aff till w $GC?c?? ?? Wa 'a i OR Za .2 -1 0. .1-1 f S y ? ? 8 3 a o a ?C ? ,Y m = ? m ,? $ 3 ? ? ? ? y Is is tT'O •7 ??-'O- 'f to _ T. OGA?.?A..1 CSY'.. y'? ?Q7 ? a •7 O • •? 0 .? T A ,$ A E C. ?6 N O 7 IL ?N N A 4 C - eIQ = i Ira -A- S'yaf? O °? y gig; T+r 4 ?¢ T ?jr lit Qi. g 91 ? ? s'?b s I ° Ila, Its S I ?. it rig Z a in't 1L illy . a.? lit4.ra?. r - . a let too Art all its o s?. °. gall 16 MIS ?. u l a s all %- Its $1 Aui mat .? po ?+y,? ?wgyy J.?? vet WW ?[SG 3wOa?a`3 $ 3 '"'y$? coo 3, 'a??????"?6?0??'4'??o.°..isn.<s?, ?`°??d w?• ? 3,,,'??'?39?m?.5???;"'gsa g??301 cs.3 3,s 3 ... Sears MasterCard' Your Account Summa XENOFON SKABOULOS Account Number. Page 1 of 1 Bfifing Cycle Closing Date 06127106 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $0.00 Total Minimum Due $0.00 Previous Balance $7,723.27 Payments & Credits $250.00 Activity $0.00 Other Charges FINANCE CHARGES $0.00 $140.65 Account Balance $7,613.92 Your Credit Summa Total Credit Line $8,600.00 Available Credit Line $686.00 Cash Access Line $1,700.00 Available Cash $886.00 ?? r ?, K? Call us at 1-800 AOY-84E8 Go to www.aeusoardoont write to us at PO Box 8Y22 The Lake*, W 88001-8Y22 17515 Payment ON$ Date 07/25/06 Check ad year near easy is lad statement! You'll find that It is aader for you to lo" to lawlent Infannatlon you need regarding you account Thank you for heft a valued cuden r. Activity Sale Des Post Date Deecripdon Amount 06/16/06 06/16/06 PAYMENT -THANK YOU -250.00 Avenpe Dally Rates 'Rate Varies Balance Balance SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in Billing Period: 34 Periodic Rate Perl"c D.Day FINANCE M-Month MAMM $1,566.68 $1,68729 19.58X.• .0537%(D)' $30.81 $6,047.24 $8,016.29 19.58X.• .053796(D)' $109.84 $0.00 $0.00 18.80X.' .051596(D)' $0.00 Effective ANNUAL PERCENTAGE RATE: 19.58% Mlydmum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number: 7515 Acaalnt Balows Q Date Mk*mun Due Mna+lt Enclosed $7,613.92 07/25/06 F$0.00 0007M 18 238A 08178 1 7X,4509 FVG 001 7 N IIIIII IIIIIIIIII III III IIII III IIIIIIIIIIIIIII IIIIIII IIIIIIIIIII 11IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIII IIIIIIIIII IIIIIIIIIIIII Make check payable to XENOFON SKABOULOr. SEARS CREDIT CARDS 1326130TH ST PO BOX 183082 FLUSHING NY 11356-1917 COLUMBUS, OH 43218-3052 Please make address corrections above. 100 7515 0763392 0000000 0025000 1819 EXHIBIT 7- Your Account Summa Sears MasterCard XENOFON SKABOULOtiS Account Number: Page 1 of 2 Billing Cycle Closing Date 07126106 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $193.91 Total Minimum Due $193.91 Previous Balance $7,613.92 Payments & Credits $300.00 Activity $0.00 Other Charges $0.00 FINANCE CHARGES $118.91 Account Balance $7,432.83 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $1,067.00 Cash Access Line $1,700.00 Available Cash $1,067.00 Cat us at 1-80044411486 Go to www.sewsowd.com Write to us at PO &w O= The Was, NV se901-O= 7513 Payment Due Date 08/23!06 Check out year awe asop 1b read etotneanti You'll And that It Is saefer Qi /J for you to bide the kWrbud V iretorntete you need ragardh0 ,d(1 yaw account f?s Thank you for be* , a valued cuetmaer. Activity sale flea Post Deft D"ali tin Amount 07/14/06 07/14/06 PAYMENT - THAW YOU -300.00 Arwaps Daily Rates 'Rate varies Balance SWanos SEARS REGULAR EXTERNAL. REGULAR CASH ACCESS REGULAR Days in Billing Period: 29 POI 10 Rea Parikldk D-Dey FINANCE M-#Aonth WWI= $1,400.08 $1,493.13 19.83%' .0544Nq' $23.56 $6,032.75 $8,044.12 19.83%' .054 Np- $93.33 $0.00 $0.00 19.05%' .0522%(D)' $0.00 Effective ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number: 7515 Aeew d Balanne Due Dih Milan Due Anvo nt Endosod L 67,432.83 08/23/06 $193.91 lT 0009654 17 16786 08207 1 TXMI M 001 7 N llttelt11t?11111tt1tt1111111tt1 Itttlltttllttllltl,lltllll?ttill?Itltttlllttll?tllltllt,fttlti 111111 1111111111 111111 111111111 Make check payable to XENOFON SKABOULOS SEARS CREDIT CARDS 1326130TH ST PO BOX 183082 FLUSHING NY 11356-1917 COLUMBUS, OH 43218-3082 Pease make address corrections above. 100 7515 0743283 0019391 0030000 1712 Sears MasterCard' XENOFON SKABOULOS Account Number= X)000 XXXX 7515 Page 2 of 2 9W Cwxdrrwmber News Call us at 1-800-0049M Go to www."orocwd.com We to us at PO Box 0622 The Lskee, NV00e01-OM Payment Due Date 08!23/06 Update: Effective 09/0101, MastarRentidO Insurance coverage Is not available for vehicles rented in Ireland, Israel, or Jamaica. Cell 1-800-MC-ASSIST to request a copy of your Quids to Benefits, or visit rnastercard.comIRESW to view your benefits online. Certain tame, conditions, and exclusions apply to all benefits. PAYMENT ALERT: To avoid a late fee, please yet your payment to us by the cutoff time on the due date shown on your billing statement. Did you know that you can buy online at seers corn and pick up the item In stm? It's fast, easy. S convenient. Beat of all, there's no shipping cost! Go to asam.com for details. before they go back to school, come to Sears.[ everything they want at prices you can afford ccmom T Sears MasterCard' XENOFON SKABOULOS Account Number. > Page 1 of 2 Call us at 1-WO.080401; Go to www.sealaoard.com write to us a1 PO Beat OW The L.akee, NV Mot.Wn ,7515 Payment Due Date 1 09/21/06 Your Account Summa Billing Cycle Closing Date 08124106 Amount Over Credit Line $893.25 Amount Past Due $193.91 Current Minimum Due $259.83 Total Minimum Due $1,348.99 Manage your account onlin t-it's FREE Pay your bill-track purchases...set email alerts... even request a credit line Increase-do it all online at SearsCard.com. It's a great way to stay on top of your account. Previous Balance $7,432.83 Payments & Credits $0.00 Activity $1,759.59 Other Charges $74.00 FINANCE CHARGES $126.83 Account Balance $9,393.25 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $0.00 Cash Access Line $1,704.00 Available Cash $0.00 D Register today at SsarsCardcom. Ws tree, and you won't believe how much time you can am, See for ==aa s=is jSis yourself at SeamCard.oom. Activity safe Date Poet Date Deeorlption Amolslt 08116/06 08/18/08 DELIVERY CHARGES 1,759.59 KM STN SXS 08/24106 082406 OVERLIMIT FEE 35.00 08!23/06 0823106 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Sears MasterCard' Account Number; 7515 Paynterst TOM Aoount askmos Dull Date MLtrtmm ous Amount tabebeed $0,39325 0921/06 $1,346.99 0256872 X 16 A 06238 1 7X3503 FVG 001 7 N IIII?I111IIlIIII IIIIIIII11111II IIIII I1IIIIIIIIIlIIIIIIIIIIIIlI XENOFON SKABOULAS 1326130TH ST FLUSHING NY 11358-1917 III lllllltl lllllllllllllllllllllllllllllllllllllllllllllllll Make G1sok payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 Please make address corrections above. 100 7515 0939325 0334699 0000000 1616 ,,,. Rates 'Rate Varles Sears MasterCarcr XENOFON SKABOULOS Account Number )O= XXXX XXXX 7515 Page 2 of 2 2SM72 Aaerape Cady Bdenw Bale" Cal us at 1400.O04M Go to wwwAearecerd.oom Write to us at PO Box Oe22 The Laken, NV bOe014M P ellt Due Date 09/21/06 POMMO Periodic Rate Pedodk AL D.Dey FINANCE ENTAGERATE M.Month CHARGE SEARS REGULAR $3,264.60 $1,960.74 19.93X' .0544%(D)' $30.93 EXTERNAL REGULAR $6,128.65 $6,078.91 19.83X' .0544%(D)' $95.90 CASH ACCESS REGULAR $0.00 $0.00 19.05X• ,0522%(D)' $0.00 Days In OlIlktg Period: 29 Effective ANNUAL PERCENTAGE RATE: 19.83% Minknum FINANCE CHARGE: $0.00 Sears MasterCard' XENOFON SKABOULaa Account Number Page 1 of 2 Your Account Summa Billing Cycle Closing Date 09122106 Amount Over Credit Line $541.48 Amount Pad Due $0.00 Current Minimum Due $239.23 Total Minimum Due $780.71 Previous Balance $9,39325 Payments & Credits $500.00 Activity SO-00 Other Charges $0.00 FINANCE CHARGES $14823 Account Balance $9,041.48 Your Credit Summ Total Credit Una $8,500.00 Available Credit Una $0.00 Cash Access Una $1,700.00 Available Cash $0.00 Call us at 14800.01119-8488 Go to www,sowocwd.com Write to us at PO Box Se22 The Lakes, NV SOW -ee22 7315 Payment Due Date 10/20/06 Manage your account online-it's FREE Pay your bill ...track purchases... set emall alerts- even request a credit line Increase-do It all online at SearsCard.com. its a great way to stay on top of your account. Register today at SaaraCardoom. It's frogs. and you won't !believe how much time you can save. See for 4 ___-=-3se s:-a zzzz yourself at SearsCard.com_ Activity sate Deb Post Dote D nw*tion Amount 09/19106 09/19/06 PAYMENT - THANK YOU -600.00 YOUR ACCOUNT BALANCE 18 OVER THE CREDIT UNE. PLEASE PAY THE DIFFERENCE BETWEEN YOUR CREDIT LINE AND YOUR CURRENT ACCOUNT BALANCE IF YOU HAVE ALREADY BENT US THIS PAYMENT, THANK YOU. Aware" Cone.pordkly Pedodkl Rate Periodle Defy ANNUAL D-Day FINANCE Rates `Rate Yaries Balance Belenee P °NTAGE RATE M=Month CAGE SEARS REGULAR $3,007.08 $3,246.95 19.83%* .0544%(D)• $31.23 EXTERNAL REGULAR $5,034.40 $6,140.15 19.83X" .0544%(D)' $97.00 CASH ACCESS REGULAR 00.00 $0.00 19.05%* .052296(0)' $0.80 Days In Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 19.M Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number. 7515 Aenowd Balanoa Duaw WIN Mhdowan Duo Amount Endowed L $9,041.48 1 1020106 -? ( $780.71 001MIlt 015 245M OWN 1 TMM3 "001 7 N Is 11111111111111111111111111111111111ifIIIIIIIIIIIIIIIIIIIIIII XENOFON SKABOULOS 1328130TH 8T FLUSHING NY 11356-1917 Please make address corrections above. I IIIIIIIII I Il it l Il Il111111I III II111I t1I111111111I111111I1111I Males check payable to BEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 100 7515 0904148 0078071 0050000 1511 Sears MasterCarde XENOFON SKABOULOS Account Number. X7000 XXXX XXXX 7515 Page 2 of 2 15MI Cardmember News Effective October 1, 2006, C ?bank (South Dakota), NA. will be the loam of your account. From that date, the words 'we, us, end our' as used In your card agreement will refer to Citibank (South Dakota), NA. Kids at college? Stop simpkyseerscdlege.com, Find the 40"MAIS they need to get organized, things they forgot, pus cool per for Fall. Don't miss the special deals and gnat selection for the perfect oogepe experlence from Seers. Shop simptyeseracogspe.com for an the college 1vkV gear you need. SAVE 70% ON FINE JEWELRY AND 40% ON STERLING SILVER AT KMART. Shop at your local Kmart store during the JAM PACKED SALE, starting Sunday, September 24th through Saturday, October 7th. You will find great savings of $100 million on the NEW fine jewelry krventory. Call us at t-M0004M Go to www.saeswrd.oom Write to us at PO Box OM The, Lakes, NV 00101-8M P nt Due Ode 10120/06 '7 Your Account Summa Sears MasterOard° Call us at 1-MON-M Go to www.esereoerd.oom write to us at PO Box Suss The Lakes, Nay 89YM 4W22 XENOFON SKABOULOS p M Ous Ogle Account Number. + 7515 Page 1 of 2 11f20/06 Billing Cycle Closing Date 10123106 Amount Over Credit Line $244.22 Amount Past Due $0.00 Current Minimum Due $240.74 Total Minimum Due $484.96 Previous Balance $9,041.48 Payments & Credits $45040 Acdvlty $0.00 Other Charges $0.00 FINANCE CHARGES $152.74 Account Balance $8,744.22 Your Credit Surma Total Credit Une $8,500.00 Availabie Credit Line $0.00 Cash Access Una $1,700.00 Available Cash $0.00 Manage your account online-it's FREE Pay your bill ...track purchases... set email alerts... even request a c radh line Increase-do It all online at SearsCard.oom. It's a great way to stay on top of your account. Register today at SesrsCOVILCO . Its free, and you wont believe how much time you can save. See for _ yourself at SeamCwd.com. Activity axle Dete Poet Oats Deeorilsdon Amount 10/20/06 10/20/06 PAYMENT • THANK YOU -450.00 Averepe Odly RStea 'Rate Varies Balance Bosons, SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in Billing Period: 31 periodic note periods NDay FINANCE M -Month WOM $2,704.44 $2,986.15 19.83%• .0544%(D)` $50.36 $6,039.78 $6,071.36 19.83%' 0544%(D)• :102.38 $0.00 $0.00 19.05%' 052296(D)• $0.00 Effective ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Sears MastwCArrle A ownt Number, 7515 Total AoooUnt 6ataince D Dais Mlnbnum Due AmoWd Esafooed $8,744.22 11/20/66 $484.98 $ W43M O 15 23576 06298 1 7X3503 FVG 001 7 N (111111111111111111111111111r111111rr111111r11111111111r11r111 XENOFON SKABODU06 1326130TH ST FLUSHING NY 11356-1917 Please make address corrections above. III J III 111111111111111 III J 11111r 11111111 i1111111111111111 Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 432184082 100 7515 0874422 0048496 0045000 1519 r Sears MasterCard° cal us at 14600-M-O188 Go to www.oowscwif.com Write to us at PO Box 9622 The Lakes, NII 9660144 XENOFON SKABWLOS P at Due Date Account Number; XXXX XXXX XXX 7515 Page 2 of 2 11/20/06 45M Cardmember News please note, effective Immediately, we are charging your Card Agroemefd ss follows: The total periodic rate finance charge for a bilgog cycle will now be the sun of the periodic rate finance charges for each balance, rounded to the newest cent (rather than rounded to the next highest cent). Phase keep this notice. Confused About Medicare BeneAts4 Kmart Pharrralste Are Here To Help. Prescription Transfers, Feed & Easy. AN Meim Medcaars Plane Accepted. Cali 1-800-$66-0085 For Nearest Location. T Sears MasterCard"' XENOFON SKABnr rr nc Account Number. Page 1 of 1 Ceti us at 1-800-M-a10t88 Go to www.soarsowd.com write to us at Po Box 8922 The Lakes, NV 8a901 41e22 1 T515 P nt Due Date 12119/06 Your Account Sunwna Billing Cycle Closing Date 11121106 Amount Over Credit Una $422.26 Amount Past Due $240.74 Current Minimum Due $288.04 Total Minimum Due $931.04 Previous Balance $8,744.22 Payments & Credits Purchases & Debits $0.00 $0.00 Other Charges FINANCE CHARGES $39.00 $139.04 Account Balance $8,922.26 Your Credit Summon Total Credit Line $8,500.00 AvaW* Credit Una $0.00 Cash Access Una $1,700.00 Available Cash $0.00 Activity Sds DOW Poet Dab Description Amount_ 11 /20IN 11 /20/06 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Avaape 0-r-porndinp Periodic Rees Psdodic Dsiy ANNUAL D.Dait FINANCE Rate$ 'RetsYariea Balance Balance C NTAGERATE M-Montlr AMall SEARS REGULAR XTE L $2,786.47 $2,727.82 19.83%' .054496(D)' $43.03 E RNA REGULAR $5,135.79 561086.00 19.83%' .05"*D)' $96.01 CASH ACCESS REGULAR $0.00 $0.00 19.05X' OMND)* $0.00 Days in Billing Period. 29 Efkctiva ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number i 7515 Tallal AcCount Balance Dw Dab MM ii III"' Due Amble" Enclosed $8,922.26 12/19/06 $01.04 OOOe063 X 15 B 08325 1 773509 FbG 007 7 N 111111 1111111 life III lrn l11nnnrrrinrlrnnrrutrnrlr11r11rurilln111 ?IIII'n1II111'IIIII?IIUIIIII?IIII IIIIIIIIIIIIVIII IIII?I VIII Make cheek payable to XENOFON SKABOULOS SEARS CREDIT CARDS 1326130TH 3T PO BOX 183082 FLUSHING NY 11356-1917 COLUMBUS, OH 43218-3082 Reese make address correction above. 100 7515 0892226 0093104 0000000 1519 ,1, Your Account Summa Sears MasterCard' XENOFON SKA8nu1 nc Account Number: Page 1 of 1 Billing Cycle Closing Date 12120/06 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $0.00 Total Minimum Due $0.00 Previous Balance $8,99 28 Payments & Credits $900.00 Purchases & Debits $O.OD Other Charges $0.00 FINANCE CHARGES $133.45' Account Balance $8,155.71 Your Credit Sunmt Total Credit Line $8,500.00 Available Credit Line $344.00 Cash Access Line $1,700.00 Available Cash $344.00 Cali us at 1-800.0004MM Go to www.e4arw4wd com Write to us at PO Sm 8022 The Lakes, NV ea00t-11822 7515 F nt Due Date 01/17107 Shop 24/7 online Shop Sears.com any time that's convenient for you. See Sears' current ads, find a store nearest you, make a purchase and pick it up at the store, or have it shipped to your home. It"s total convenience at your fingertips, and you can use your Sears card to make things even better. It's fast, simple and secure. So why not try us today? Visit Sears.aom. Activity sale Daa Post DNS Desorloon Amount 11 /22A6 1122/06 PAYMENT - THANK YOU -500.00 12/19/06 12/19/06 PAYMENT - THANK YOU -400.00 Average e Riffs -Bete varies Balance Be ilpla SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in Billing Period 29 Peniodio Rate Perlod10 awwy FINANCE AB•Mortll ZR W $2,123.93 $2,47628 19.83%' .054496(D)• $39.07 $6,031.78 $5,982.84 19.83%' .0544460` $94.38 $0.00 $0.00 19.03%" .0522 %0' $0.00 Effeetlve ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Sears MasterCae Account Number. 7515 TOW Aooount Selene Dew Dits IMkirnlm Dua Amount Erlatoaad $6,155.71 01/17/07 $0.00 l 000361 7 14 148 OM 1 TXM FVG 001 7 N I111IIIIIII/IIII1I1I11II11111IIIII11111IIIIIII11I1111111111111 XENOFON SKABOULOS 1326 130TH ST FLUSHING NY 11356-1917 Please make address corroetfons above. IIIIIIII IIIIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII Make check payable io SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 432183082 100 7515 0815571 0000000 0090000 1414 Sears MasterCard" XENOFONiSKABOULOS Account Number: _ Page 1 Of 1 Call us st 1-800.191-SM Go to www.amswrd.oom write to us at PO Box 8671 The takes, W MM -81W 7S1S R let Due Date 02/19/07 Your Account Surnma B81ing Cycle Closing Date 01122107 Amount Over Credit Une $0.00 Amount Past Due $0.00 Current Minimum Due $55.92 Total Minimum Due $55.92 Manage your account online-it's FREE Pay your bill ...track purchases ..set email alerts... even request a credit line Incneese-do it all online at SearsCard.com. It's a greet way to stay on top of your Previous Balance $8,155.71 Payments & Credits $0.00 Purchases $ Debits $0.00 Other Charges $0.00 FINANCE CHARGES $147.69 Account Balance $8,303.40 Your Credit Summa Total Credit Line $8,500.00 Available Credit Une $196.00 Cash Access Line $1,700.00 Available Cash $196.00 O Register today at SeeraCard com. Ith free, and you won't believe how much time you can save. See for misi'aam$ yourself at . iard.com. Avereps corre"-wing PModle Rete Periodic only ANNUAL D.Day FINANCE Rates 'Rate Varies Bole" Balance PERCERTAGE RATE M.Moni h WRIM SEARS REGULAR $2,162.39 $2,142.52 19.93%' .054496(D)' $39.46 EXTERNAL REGULAR $8,141.01 $6,064.57 19.93X• .0544%(D)' $109.25 CASH ACCESS REGULAR $0.00 $0.00 19.05%' .0522%(D)' $6.00 Days in Billing Period: 33 Eifectiv* ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE; $0.00 Cardmember Nem Show Someone They're Special on Valentine's Day. Get Grant Designs at Great Prices on all Fine Jewelry at Seam Sears MasterCard' Ao=unt Number. 7815 d Taftl Aoeount Balows Dw Date Minknuum Due Anxturd Eneloeed $6,303.40 02/19/07 $55.92 OOe623 14 124M 07022 1 7X3503 FVG 001 7 N IIIIIIIIIIIIIIIIIIIIIIII1111IIIIIIlI11III111I11IlI1IIIIIIIIII XENOFON 3iCABOULOS 1328 130TH ST FLUSHING NY 11356-1917 IIIIIIIIIIIIIII111IIIIIIIIIIII !IIIIIII IIIIIII IIIIIiIIIIIIIII Make check payable to SEARS CREDIT CARDS PO BOX 163062 COLUMBUS, OH 43216-3082 Please make address corrections above. 100 7515 0830340 0005592 0000000 1413 T Sears MasterCard' XENOFON SKABOIll MQ Account Number. Page 1 of 1 Call w at 11-800-00-M Go to wwwaaerecerd.oom Write to us at Po Box can The Laker, W SOM-Bti22 7515 P M Due Ode 03J20/O7 Your Account Summ Billing Cycle Closing Date 02120107 Amount Over Credit line $0.00 Amount Past Due $0.00 Current Minimum Due $209.49 Total Minknum Due $209.49 Manage your account online-It's FREE Pay your bill...track purchases... set email alerts... even request a credk line increase-do It all online at SearsCard.com. Its a great way to stay on top of your account. Previous Balance $8,303.40 Payments 3 Credits $400.00 Purchases b Debits $0.00 Other Ch FINANCE CHARGES $0.00 $128.38 Account Balance $8,031.78 Your Credit Summa Total Credit Una $8,500.00 Available Credit Line $468.00 Cash Access Line $1,700.00 Available Cash $468.00 Register today at SearsCard oom. ft's t'se, and you won't believe how much time you can save. See for yourself at SearsCard.com. Acthfity sale Dew Poet Date Description Amount 01 /22/07 01/22/07 PAYMENT - THANK YOU -200.00 01/22/07 012207 'FINANCE CHARGE' PREV CYCLE PURCHASES -0.11 02/18/07 02/18/07 PAYMENT - THANK YOU -200.00 Average Corresi-Wing Periodic Rote Parladio Daily ANNUAL D-Dey FINANCE Ratios 'Rate Varies Balance Balance STAGE RATE M.Mordh SEARS REGULAR EXTERNAL $1,998.44 $2,053.05 19.83%' 05"96(D)* $32.55 . REGULAR $6,033.34 $6,081.54 19.83X• .0544*D)' $95.94 CASH ACCESS REGULAR $0.00 $0.00 19.05X• .0522%(D)' $0.99 Days in Billing Period: 29 Eltective ANNUAL PERCENTAGE RATE: 19.84% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number 7515 PV~ Total Account 58W M Due Data Minimum Due Amorsrt Enobaad $8,031.78 03/20/07 $209A9 $ Aawsd p Ildle el EmIllivest Yes! By s4 ft, I Mart to en h h the o*nW AccourdCus pan and lei protect my acwunt. I mceired tlre 1:SlQr41Ure embsed Prooram Summary. Bill the fee to my account 00Oea14 14 12WM 07061 1 7X3508 FVG Dpi 7 N XENOFON SKABOULOS 132e 130TH ST FLUSHING NY 11356-1917 Make check paya6e to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 Please make address ocrrections above. 112 7515 0803178 0020949 0040000 1411 Sears MasterCard' XENOFON SKABOULOS Account Number Page 1 of 1 Call us at f-800 M-IM88 Go to www ooorw ird.com Write to us at PO Box eM The Lakes, NV 801101-81M 7515 Payment Oil$ Ogle 04/18/07 Your Account Surfmt Billing Cycle Closing Data 03111107 Amount Over Credit Line $0.00 Amount Past Due $209.49 Current Minimum Due $248.72 Total Minimum Due $458.21 Previous Balance $8,031.78 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $127.72 Account Balance $8,198.50 Manage your account on9ne-ifs FREE Pay your bill ...track purchases... set email alerts... even request a credit line Increase-do It all online at SearsCard.com. It's a great way to stay on top of your account. o Register today at SearsCardcom. It's free, and you won't believe how much time you can save. See for :::----= ---s sxxe yourself at SearsCard.com. Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $301.00 Cash Access Line $1,700.00 Available Cash $301.00 Activity Sala Date Pop Date Description Amount 03/20/07 0320/07 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. AVeraile Dally Rates `Ratevarks Below* Belanoe Periodic Rata Periodb D-Day FINANCE 1011-Month FZGE SEARS REGULAR $2,05925 $2,016.42 19.83%` .054496(0)• $31.81 EXTERNAL REGULAR $6,12925 $6,079.51 19.83%• D54496R* $93.91 CASH ACCESS REGULAR $0.00 $100 19.05%• .0522%(D)' $0.90 Days In Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 19.83% Mirdmum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number 7515 paym" Aooount Balance Due Dote MlNmum Due Amourt Enoroaad $8,198.50 04/1SM7 $45821 0017048 0 14 0 07080 1 1X5808 FVG 001 7 N Irrrlllrrrlllrrrrrrilrlrlrlrlrrirrrlrlrrllrritlll,rrlrlrrlrrll XENOFON SKABOULAS 195 HICKORY RD CARLISLE PA 17015-9748 rlrrirrilrrrlrlrrrlllrrlrrrilrilrrrlrrltttirllrrlrrrirll4lrr Make check payshle to SEARS CREDIT CARDS PO BOX 183062 COLUMBUS, OH 43218-3082 Reese make address cormctions strove. 100 ?535 0814850 0045821 0000000 1413 T Sears MasterCard' XENOFON SKABell Account Number. Page 1 of 2 cell us at 1-8011-888-8418 Go to www.atlarocard.oorn write to us at PO Bolt 8922 The Lama, Nv 88601-6822 7315 Payment Due Date 05/17/07 Your Account Summs Bong Cycle Closing Date 04119107 Amount Over Credit Line $0.00 Amount Past Due $25821 Current Minimum Due $248.63 Total Minimum Due $506.84 Previous Balance $8,198.50 Payments & Credits $200.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $127.63 Account Balance $8,165.13 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $534.00 Cash Access Line $1,700.00 Avah"a Cash $534.00 Activity sataDate PoetDaa Doggodpotm Alnourlt 03/26/07 03/26/07 PAYMENT - THANK YOU -200.00 04118/07 04/18/07 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Sears MastarCard' Account Numbw. 7515 Payment Total Account Belanaa Dw Date Mk*nuin Due Anwlrlt Miclosed 53 05/17/07 $506.84 0239970 0 14 7A 07100 1 T)MM FVO 001 7 N II IIIIII Il I III II III III [I[I IIIIII {1111Ill[I II II I II IIIIIII I II II I I111111fill I III[ I IIIII III IIIIII IIt11I11I111It[ [fell III I III III I Make cheek made to XENOFON SKABOUL08 SEARS CREDIT CARDS 193 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3082 Please make address oormotiorts above. 100 7515 0816513 0050684 0020000 1410 T Sears MasterCarde XENOFON SKABOULOS Account Number )O= XXXX XXXX 7515 Page 2 of 2 293M Rates 'Rate Varies Avers" Dally !sane Ealence Call us at 1-e004*44e6 Go to wwmeearecrd.oom write to us at PO Box 9922 The Lekee, NV 8811011 -0122 Payment Oue Date 05/17/07 pondhp Periodic Rate Periodic IAL D.Day FINANCE FNTAGERATE M.Month CHARGE SEARS REGULAR $2,075.96 $2,031.92 19.83%• .0544960' $32.06 EXTERNAL REGULAR $6,089.18 $5,058.46 19.83%* .05"%(D)- $95.57 CASH ACCESS REGULAR $0.00 $0.00 19.05%• 052296(D)- $0.00 Days in 8llling Period: 29 Effective ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Cardmember News Please see the enclosed privacy notice for important inforrnation. TT Sears MasterCard' XENOFON SKASOULOS Accourd Number' Page 1 o11 Gag us at 1-0004004486 Go to www.mormard.com write to us at PO Box e922 The Lakes, NV MM-8922 7515 P em Due Date I 06/18/07 Your Account Summa Billing Cycle Closing Date 05121107 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $215.22 Totaf Minimum Due $215.22 Previous Balance $8,165.13 Payments & Credits $505.00 Purchases & Debits $14.95 Other Chimes $0.00 FINANCE CHARGES $136.38 Account Balance $7,811.46 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $688.00 Cash Access Line $1,700.00 Available Cash $688.00 Manage your account online-it's FREE Pay your bill-track purchases... set email alerts... even request a credit Me Incra se-do It all online at SearsCwd.com. k's a great way to stay on top of your account. Reglatar today at SarsCardcom. It's free, and you wonI behave how much time you can save. See for ---a eels yourself at Sear6Card.own. Activity Selo Doe Post Date Do-%Ytlon Amount 04/19/07 04!19107 PAYMENT - THANK YOU -200.00 04119/07 04/19/07 'FINANCE CHARGE' PREV CYCLE PURCHASES -0.11 05/01/D7 05/01/07 PAY-BY-PHONE FEE DEERFIELD IL 14.95 05/01/07 OM M PAY-BY-PHONE PAYMENT DEERFIELD IL -305.00 Averepe Daly Rates 'Rate Varies Bstenoe "once Periodic Rift Pedodl0 0-101111, FINANCE SEARS REGULAR $1,76925 $1,820.10 19.6394• .0544%(D)' $31.68 EXTERNAL REGULAR $6,04221 $6,021.03 19.83%' .0544%0' $104.61 CASH ACCESS REGULAR $0.00 $0.00 19.05%' .0522960' $0.06 Days in Billing Period: 32 Effeetlw ANNUAL PERCENTAGE RATE: 19.84% Ntlrdmum FINANCE CHARGE: $9.06 Sears MasterCard' Account Number 7515 PBYMwd TOW Account Belanos Dual Mirdmurrt Due Amount Enclosed 67,811.48 170y--,"7 $21522 0017616 14 M908 07141 1 TXM FVG 001 7 N Irrrlllrrrlllrlrtrtlltlrllltlrrlrrrlrlrrllrrlrlrltrrlrlrtlrrll XENOFON SKA004JL08 195 HICKORY RD CARLISLE PA 17015-9748 Please make address corrections above. Irrirrtirrrlrltrrllllrlrlrllrllrrtllrlrrrlrllrrllrrltllrllr Make dick payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 100 7515 0781146 0021522 0050500 1411 T' Sears MasterCard" XENOFON SKAP^I Account Number: Page 1 Of 1 Call us at 1400-W41wi8S 0o to www.o"r a rd.com Mite to us at PO Box 8M The Lek**, NV SIM -8M T51S Payment Due 09e 07/18/07 Your Accouryt Sum Billing Cyde Closing Date 0612010T Amount Over Credit Line $0.00 Amount Past Due $215.22 Current Minimum Due $247.55 Total Minimum Due $482.77 Previous Balance $7,811.46 u ses S Debits $0.00 Other Charges $39.00 FINANCE CHARGES $128.55 Account Balance $7,979.01 Your Cr M Summa Total Credit Line $8,500.00 Available Credit Line $520.00 Cash Access Line $1,700.00 Available Cash $520.00 ACtJvity Sale Date Post Dab Description Alnotlrrt 06/18/07 08/18/07 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Av-%o CornspordNq Pellodio Rats Pei is FINANCE ANNUAL Rates 'Reteyaries Balance ? TAGERATE M•? Ml+ CHAR SEARS REGULAR $1,837.41 $1,787.17 19.83x• .0544%(D)• $29.16 EXTERNAL REGULAR $6,141.60 $6,090.11 19.83%• 054496(!' $99.39 CASH ACCESS REGULAR $0.00 $0.00 19.08X' .0522960' $0.00 Days In Blliktg Period: 30 Effective ANNUAL PERCENTAGE RATE: 19.83% thtktimum FINANCE CHARGE: $0.00 Sears MasterCa rd" Account Number: 7513 ? Aeeomt Betarler DIIa Oale MYhin um Due Amoard Eliclosed $7,979.01 07/18M7 5482.77 0017 0 14 A 07171 1 7X950 M 001 7 N loll 11111111111MIII r161r11IIII IIIuIIIII IIIIIIIIIIIIIIIuI Matra check payable m X=NOFON SKABOULAS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3082 Please make address correctlons above. 100 7515 0747901 0046277 0000000 1414 T Your Account SurrBrta Sears MasterCard XENOFON SKABOULOS Account Number: Page i of i Biting Cyde Ching Date 07120/07 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $244.84 Total Minimum Due $244.84 Previous Balance $7,979.01 Payments & Credits $420.00 Purchases & Debits $0.00 Other Charges FINANCE CHARGES $1$27.84 Account Balance $7,725.85 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $774.00 Cash Access Line $1,700.00 Available Cash $774.00 Cell us st 1-SM40044M Go to www.eeereoell .lwm Write io us at Po Box 5922 The Lakes, Nv 8a9Q1-SW 7515 P ant Due Bete 08/17/07 Will vard.COM mm*e yw seams a" s=e 24/7 lair aw b a r" and rAnt IpdsU tad ?ap1 •Payw •Viewmwacb* •10dMsp in SM cad bl$ • V1mN up b 12 infderetlm •Twdwabelaxe .00 01 •Sdupemelalerts IVA*d b etatarlerlb • Paplae a lost card womwoft • Get a ckiellle Oilers • PtNa Seers et9ro aoelRle r10 \lt 1 2- Activity sw flea Poet Dees Deew"on Amou d 08/24/07 0824/07 PAYMENT - THANK YOU -220,00 07/19/07 07/19)07 PAYMENT - THANK YOU -200.00 07/18/07 07/18/07 LATE PAYMENT FEE 99.00 Avsrar 0--poWing Periodk Rea Periodic Do* ANNUAL D-Day FINANCE Rates 'Rate Varies Belenoe Babnc. PERCERTAGE RATE MM.MoMh -CH) EE SEARS REGULAR N $1,689.83 $1,790.39 19.83%• .0544%(13)' $29.22 EXTER AL REGULAR $6,036.02 $6,043.02 19.83%' .0544%(D)' $08.82 CASH ACCESS REGULAR $0.00 $D.00 19.05%' 052296(13)' $0.00 Days In Billing Period: 30 Effective ANNUAL PERCENTAGE RATE 19.83% Minimum FINANCE CHARGE: $0.00 Sears MasterCard` Account Number: 17315 Aoaawd Bdwws Dw Oea Mkrliwel Dull AnwUnt Eackwed $7,725.85 08/17/07 $244.84 $ 0017100 14 19457aB 07207 1 TXBS03 FNl3 001 7 N IIIII1IIIII'III1111'IIIIIIII'll?tlllllllllpill llIlllllltlIll'I IIIIIII VIII IIIIIII VIII'I[fill I'lillllllllIIII11II11'II'I?III Make check Payable to XEWFON SKABOULA8 SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARUSLE PA 1 701 5-9 748 COLUMBUS, OH 43218-3082 Please make address corrections above. 100 17515 13772585 0024484 0042000 1410 ,17 Sears MasterCard' XENOFON SKABout.na Account Number. Page 1 of 1 Cell us at 1-80aM410108 Go to www.ssarscsrd.oom Write to us at PO BczaW The Lakes, WSOW-$= 7515 Payment Due Date 09118/07 Your Account Summa Rang Cycle Closing Date 08121107 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $195.25 Total Minimum Due $195.25 Previous Balance $7,725.85 Payments & Credits $300.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $135.41 Account Balance $7,600.26 SAFE Secure paymeltts *ad from your checking or savings account QUICK Nyments are credited io your account the next business day. FREE Enrollment is Fly which meane no need for temps *wwatulatl- mtr*A0btkknimmerytbVIIIII aIceWNwama Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $899.00 Cash Access Line $1,700.00 Available Cash $899.00 Acflvity ads Dab Pat Dow De.otipdon Amount 08/20/07 08/2W07 PAYMENT - THANK YOU -300.00 08117107 08/17197 LATE PAYMENT FEE 39.00 Av-ps COrraeporm" Periodfo Rob Periodic Dsay ANNUAL D-Day FINANCE Rates -Rateyarlee Balance Balance PERU NNTAGERATE M-fAcri h HAWSE SEARS REGULAR $1,557.01 $1,W7.66 19.83%' .0544%(D)' $29456 EXTERNAL. REGULAR $6,043.25 $6,081.02 19.93X• .054496(D)' $105.83 CASH ACCESS REGULAR $0.00 $0.00 19.05%• .0522%(0)' $0.00 Days In Billing Period: 32 Effective ANNUAL PERCENTAGE RATE: 19.83% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number:. .7515 Account Balawas Dula Mkdnnm Due Amount EaNdowd $7,60026 09/18/07 $19525 $ Araargm ttpduW EueiMUW Yesl By sipeln0, I want lomrol io the low lwp lact my Es natme eD*RW losed Proms 0 Sam unary N ft in to my acccooutcl?,. I received then 0017225 14 1294676 07233 1 7X8503 FVG 001 7 N IIIIII'It IIIIII1111'?1'i IIIIIIIIIII?IIIIIIIIIIIIIIIIII'IIIIII' IIIIIIII?IIII?IIIII IIIIIIIIIII1I?111I11'111I II IIIIIII'illlllll Make check payable to XENOFON SKABOULOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3082 Please make address ooaoowne above. 115 7515 0760026 0019525 0030000 14112 Sears MasterCard' XENOFON SKABOur ne Account Number. Page 1 of 1 Call us at 1-80G-AEY-M86 Go to www.eearsoard oom Write to us at PO Box 8842 The Labs, RVSW-d= 7515 Payment Due Date 10/19/07 Your Account Summa Billing Cycle Closing Date 09/21107 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $175.78 Total Minimum Due $175.78 Previous Balance $7,600.26 Payments & Credits $260.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $125.53 Account Balance $7,504.79 Your Credit Sunertta SearsCard.."" 24/7 Manage your Soars card a10001Nlt Payl aw sere %%w art ftw epd IAanpe • Par M • VM 18calt acuft • UDdab Dersonai Seas Card bill • View up is 12 Ydrnaedon • Tmn*r a balance DOW • Set up and derls mosstia etelemenle ' PapYce a lost card • Gel er kWo alert • Pdn1 Seem etas rtoelpM =10 \ 2? Total Credk Line $8,500.00 Available Credit Line $995.00 Cash Access Line $1,700.00 Avallable Cash $995.00 AotlVlty Sale Date Poet Dote Deew"kin Aereefart 09/19/07 09/19107 PAYMENT - THANK YOU -260.00 09/18107 09/18/07 LATE PAYMENT FEE 39.00 Aw "o Conwpondinp Pellodio Rate Periodic Daly ANNUAL D.Day FINANCE - Rates 'Rate varies Balance BaMeet» P TAGE RATE M-Morffi C" WE SEARS REGULAR $1,467.48 $1,569.55 19.33%• OSW%R* $25.62 EXTERNAL REGULAR $6,037.31 $6,06128 19.33%' osw%q* $99.91 CASH ACCESS REGULAR $0.00 $0.00 18.55%• OSN%P)• $0.00 Days in Billing Period: 31 Effective ANNUAL PERCENTAGE RATE: 19.33% Mlnlmum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number. 7515 Amount Salonm 57,504.79 Dw Mk* nr Due Mraatt 6adosed Flo/1"7 J L s176.78 Fs Ace m we Oplnnnl EwIllAtnt Yes! By soft. I wad to enrol in the 1 received He my S!gnabre sw1wed Pmpran Swmary. Bill s in W m yr aaccunt. W17478 14 246A 07284 1 TXM FVG Wl 7 N IIIrllIIIIIIleeeeeI1111111111111fell Ile[III rlelllrrel11rr11111 Irleeletlleeelrleeelllr11fe111111eeelerleeelelleelerelrll11e11 Make dick payable to XENOFON SKABOULOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9746 COLUMBUS, OH 43218-3082 Please make address corecdona above. 117 7515 0750474 0017578 0026000 1410 T Your Account Summa Sears MasterCard' XENOFON SKAB0111 nc Account Number Page 1 of 1 Billing Cycle Closing Date 10122107 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $198.86 Total Minimum Due $198.86 Previous Balance $7,504.79 Payments & Credits $214.95 Purchases & Debits $14.95 Other Charyes 2 8 FF NANCE CHARGES $1 3. 6 Account Balance $7,428.65 Your Credit Summa Total Credit Line $8,500.00 Available Credit Line $1,071.00 Cash Access Line $1,700.OD Available Cash $1,071.00 Cell UB at 1-swe0Y-M Go to wwlv.seanard oom w** to us at Po Box SM The Lakes, W 88'01-t>022 7515 Payment Due Date 11/19/07 Shop 2417 online Shop Sears.com any time that's convenient for you. See Sears' currerd ads, find a store C3 nearest you, male a purchase and pick It up at the store, or have it shipped to your home. it's total cnnveniertce at your fingertips, and you can use your Sears card to make things even better. k§ fast, ample and secure. So why not try us today? Malt Sears.com. Activity Selo Des. Pat Date Demor"on Amount 10/19/07 10/19/07 PAY-BY-PHONE FEE DEERFIELD IL 14.95 10119/07 10/19/07 PAY-BY-PHONE PAYMENT DEERFIELD IL -214.95 Avers Day Rates "Rate Van" Balanos 9alence SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in Billing Period: 31 Psrbdio Rats Palladio D.Dey FINANCE M-Month $1,391.48 $1,488.27 19.33%* .053096(D)* $24.09 58,037.17 $6,072.64 19.33%' .053096(D)* $99.77 $0.00 $0.00 1&55%* .0509%(D)* $9.90 Effective ANNUAL PERCENTAGE RATE: 19.33% Minimum FINANCE CHARGE: $0.00 l seals MasterCard' Account Number: 7515 Payment 701111 Aeoowd Balms Due Dase Mk*rmn Due Mount Enolosed $7,429.65 F11/19)07 $198.86 owass2 14 12873 072M 1 rAS503 M 001 7 N 11111111 loll 111111 hill 11111 ME40FON SKABOULOB 195 HICKORY RD CARLISLE PA 17015-9748 Pease make addreas corrections above. rErrlrrllrrllrirrrlllrrlrrrllrllrlrlrrlrrrlrlirrlrrrl111rlrr Make cheek payable to SEARS CREDIT CARDS PO BOX 183052 COLUMBUS, OH 43218-3082 100 7515 0742865 0014886 0021445 1413 T Your Account Summa Sears MasterCard' XENOFON SKABOUt MQ Account Number. . Page 1 of 1 BiMng Cycle Closing Date 11/20107 Amount Over Credit Line $0.00 Amount Past Due $198.86 Current Minimum Due $228.54 Total Minimum Due $427.40 Previous Balance $7,428.65 Payments & Credits $0.00 Purchas es & Debits $0.00 h or Cm 1 FINANCE CHARGES 3.54 $1 Account Balance $7,681.19 Your CrelSt Summa Total Credit Line $8,500.00 Avail" Credit Line $918.00 Cash Access Line $1,700.00 Available Cash $918.00 Cal us at 1-Me 04M Go to www.searseard.eom Write to us at PO Box 8922 The Lakes, NV 89601-M x515 Payment Due Dote 17/18/07 Activity Salle Date Post De% Description Amount 11/19/07 11/19417 LATE PAYMENT FEE 39.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Rates -Fate varies Av ra" Coweel-Wing Pedodic Rea Pelfodic Day ANNUAL D.Day FINANCE Balance Balance STAGE RATE M-Month -d 4 M SEARS REGULAR EXTERNAL REGULAR CASH ACCESS REGULAR Days in ENNng Pedod: 29 $1,451.79 $1,404.40 19.00X' .0523%(D)• $21.31 $6,129.40 66,081.31 19.08X' .0523%P* $92.23 $0.00 $0.00 16.30X' .0502%%- $0.09 EibcM ANNUAL PERCENTAGE RATE: 19.08% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number. 7515 Total ADMIAnt Balance D Dits MM MM Due Anwurrt 6ncloaed $7,581.19 12/18/07 6427.40 + $ 0010aeo D 14 A 07324 rr1 TXSM FVG 001 7 N IIIIIIIIf II{III'II IIII?II IIIIIIII IIII?II'Illtll?l??llill II11''IIII'IIII111?'III?IIIIIIIIIIII ItII'Il'1'1IIIIIIIIIIIIII 111111 Make check payable to XENOFON SKABOULOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARUSLE PA 1 7 01 5-9 748 COLUMBUS, OH 43218-3082 Please make address oorrecWns above. 100 ! -7515 0758139 0042740 0000000 1415 'r Sears MasterCard' XENOFON SKABOUL_na Account Number. Page 1 of 2 Your Account Summa BON Cycle Closing Date 12120107 Amount Over Credit Line $0.00 Amount Past Due $227.40 Current Minimum Due $308.89 Total Minimum Due $536.29 Previous Balance $7,581.19 Payments & Credits $200.00 Purchases & Debits $0.00 Other Charges FINANCE CHARGES $39.00 $192.89 Account Balance $7,613.08 Your Credit Summa Total Credit Lime $8,500.00 Avallable Credk Lime $866.00 Cash Access Line $1,700.00 Available Cash $886.00 Call us at 11-800-M41011, Go to www.aearward.com Write to us at PO Box 8902 The Lakes, NV 88901-e924 1515 Payment Due Date 01/17/08 Activity $We D@% Poet Date Deaaiptlon Amount 11/26/07 11 /26/07 PAYMENT - THANK YOU 12/18/07 12/18/07 LATE PAYMENT FEE THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. THE APR ON YOUR ACCOUNT HAS BEEN INCREASED FOR ONE OF THE FOLLOWING REASONS: YOU FAILED TO MAKE PAYMENT TO US ON THIS OR ANY OTHER ACCOUNT THAT YOU HAVE WITH US WHEN DUE, YOU EXCEEDED YOUR CREDIT LINE ON THIS OR ANY OTHER ACCOUNT YOU HAVE WITH US, OR YOU MADE A PAYMENT TO US ON THIS OR ANY OTHER ACCOUNT YOU HAVE WITH US THAT WAS NOT HONORED BY YOUR BANK. Sears MasterCard' Account Number. 7515 Aooornt Baiseroe Drr MUir? Due Amoret t3rdoaad $7,613.08 01/17/08 $53629 - 200.00 39.00 WZM13 D 14 A 07354 1 TXSS03 FVG 001 7 N Ir,.III.,rII1UrrrlllrlrlrlrlrrlurlrirrlI,r1r1r1pr111Uhill ? MsM check pWs paya UrdrrdlJLrrLJrrdrlLJrr?LllrLrl Male cW to XENOFON SKABOULOS SEARS CREDIT CARDS 193 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3082 Please make aWms3 mrecWna above. 100 7515 0763308 0053629 0020000 1419 T, Sears MasterOard° XENOFON SKABOULOS Account Ntmbsr. )O= )O=)O= 7515 Page 2 of 2 237813 Avw"o Can Deily ANr Rates 'Rstovariw Beiencs Bohm* PEP Call us at 1-8wEEY-Ow Go to www"Grecnd.eom Write to us at PO Ow SM The Lakes, W MWI -OM Parma Due Oslo 01/17/08 ponding P«iodk Rd* Pntodic IAll. D.Dey FINANCE I TTAGE RATE M.Month CHARGE SEARS REGULAR $1,482.26 $1,435.62 31.24%' OSM94(D)' ;36.87 EXTERNAL REGULAR $6,130.82 $6,075.91 31.24%' 0656%(D)' $156.02 CASH ACCESS REGULAR $0.00 $0.00 31.24%' 0856%(1)' 30.00 Days in BIIfing Period: 30 Effective ANNUAL PERCENTAGE RATE: 31.24% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' XENOFON SKARM 11 nc Account Number, Page 1 of 1 Your Account Summ Billing Cycle Closing Date 01122108 Amount Over Credit Line $0.00 Amount Past Due $0.00 Current Minimum Due $324.74 Total Minimum Due $324.74 Previous Balance $7,613.08 PWnents 81 Credits $500.00 Pur+ctmes & Debits $0.00 Other Charges $99.00 FINANCE CHARGES $211.74 Account Balance $7,363.82 Your Credit Summa Total Credit lane $8,500.00 Available Credit Une $1,396.00 Cash Aocese Line $1,700.00 Available Cash $1,396.00 Call us at 1-11004044811 Go to www's"Imrd.oom Write to us at PO Box Oe22 The Lakes, NV 80001-8M 175`15 P M Due 090 02/19/08 SAFE Secure Payeeirls direct hm your c heckinl; or savilps account QUICK Payments are credited N pip acco in the most busness day. FREE Enrollment is FWE which means no need t0r stamps VMaNWAN NnWNNipbokanises apbvowyalfM*YIr1111W10. Activity Sala Date Poet Onto DeeerWon AmUnt 12/28/07 1286/07 PAYMENT - THANK YOU -250.00 01/19/08 01/19/08 PAYMENT-THANK YOU -250.00 01/17/08 01/17/08 LATE PAYMENT FEE 39.00 Averep CorrvapondkV Periodic Rate, Periodic Dally ANNUAL NDNY FINANCE Rates 'Rate Varies Balarloa Brlcela PERNWAGERATE M>vMaidt SEARS REGULAR $1,255.20 $1,434.43 31.24%* 0856%w $40.52 EXTERNAL REGULAR $6,106.62 $6,061.49 31.24X' OM%(D)• $171.22 CASH ACCESS REGULAR $0.00 $0.00 31.24%' .0856%(D)• $0.00 Days In Billing Period: 33 Etl wive ANNUAL PERCENTAGE RATE: 31.24% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number. 17515 Total Aeooulnt Bahasa Dw Mkd 1 jm Due Amount Eroloned 57,363.82 02/19/08 $324.74 AeeeaYCas -fteaitEnMnent Yes! By sill" I YW11t to enrol in the optlotld oouttCare Plan and help Preto my account. I received fhe a Egna tlae enc NW Propaam Summary. Bill the lee to my account. 0020026 14 1233011 00022 1 1')(6503 FVG 001 7 N IIIII?IIIIII?111111III'I?IIIIl1I11111111Illlltl lllllll'II ?II?I ?IIIII111IIIIII'111?1?/l IIIIIII IIII1?11IIIIII?IIIIII IIIIIIIIII Mane shook payable to )tcNOFON SKABOULOS BEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3062 Please make address corrections above. 120 7515 0736382 0032474 0050000 1412 1 Sears MasterCard' XENOFON SKABnr 11 ^e Account Number: Page 1 of 1 Call us at 1400-000-M Go to www.ssaraeard.com write to us at PO Box. 8M The Lakes, NV S M-a= Isis P nt Dee Ode 03119/08 Your Account Summa Billing Cycle Closing Date 02120108 Amount Over Credit Line $0.00 Amount Past Due $324.74 Current Minimum Due $292.64 Total Minimum Due $617.38 Previous Balance $7,363.82 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $39.00 FINANCE CHARGES $177.64 Account Balance $7,580.46 Your Credit Summa Total Credit Line $8,500.00 Available Credit line $919.00 Cash Access line $1,700.00 Available Cash $919.00 Activity Wo Dow Post Dab Dasoriplton AMOWN 02119/08 02/19/09 LATE PAYMENT FEE $9.00 THE AMOUNT DUE SHOWN ABOVE INCLUDES A PAST DUE AMOUNT. YOU SHOULD SEND THE ENTIRE AMOUNT DUE NOW. IF PAYMENT HAS BEEN MADE RECENTLY, THANK YOU. Averepe Corrssl)wWkV psi 10 Rate Periodic Deny ANNUAL D-Dsy FINANCE Rates 'Rats varies Balance Billerica STAGE RATE M-Month CHAR € SEARS REGULAR EXTERNAL $1,324.64 $1,272.44 29.99%* .082296(0)• $30.34 REGULAR $6,255.92 $8,179.43 29.99%' .0822960' $147.30 CASH ACCESS REGULAR $0.00 $D.00 29.99%' .0822960' $0.00 Days in Billing Period: 29 Eflrctlve ANNUAL PERCENTAGE RATE: 28.99% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' Account Number: 7513 Aoeowd Balance Dus Data TOM Mlnhman Due Amount 6rolm" $7,580.49 03119/08 $817.38 0019193 0 14 A 00051 1 TXM Fv6 001 7 N I„,Illrr rll lr,, r„11,!,1,1,1„I,r,ir 11111 fill l,lr„I,I„f„II loll Ir,I11IIlrl,,,III,rIr„Ilr ll„, f„Ir„I,II to I„IIII irl„I Malts shock payable to XENOFON SKABOULOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17Dl"748 COLUMBUS, OH 43218-3082 Please make address oonections above. 100 7515 0758046 0061738 0000000 1413 T Sears MasterCard* Call w at 11-1143040-M Go to www.emrseard.com write tow at PO Box SM The Lakes, NV 8W -ffn XENOFON SKABel11 MA Account Number Payment Due Drte r 615 Pape 1 of 2 04/17/08 Your Account Summa BOV Cycle Closing Date 03120/08 Amount Over Credit Line $0.00 Old you know? There may be a quick (and simple) Amount Past Due $617.38 way to bring your account up to date. Current Mk*num Due $300.86 Totes Minimum Due $91824 Call 1-866-518-9050 today. Previous Bahr" $7,580.46 rm "be able to" Even H rw. Kole here a roe walw-wean w Purchases & Debits $0.00 w0rgvouezoarw aepreataoeamwlmwr cwom ow mama Other Chars $39.00 reruea hna dww wwr w t w Per aw neeac M~ above FINANCE CHARGES $182.86 °"`P°°10""' "M u Account Balance $7,802.32 vo to to W a aakoon, ?en. nn`ovrb Your Cresol Summa Total Credit Line $8,190.00 Available Credit Line $367.00 Cash Access Line $1,638.00 Available Cash $387.00 ACth ty See Daft Pot Dow Deeatptlon Amount 03/19/08 03/19/08 LATE PAYMENT FEE 39.00 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. DUE TO YOUR CREDIT PERFORMANCE, WE HAVE DECREASED YOUR CREDIT LINE. CREDIT LINES ARE REVIEWED REGULARLY. YOUR PROMPT AND REGULAR PAYMENTS OF THE 'MINIMUM AMOUNT DUE' WILL IMPROVE YOUR CREDIT STANDING. Sears MasterCard' Amount Number: 7515 Aoemild Bslanes ltua Dais AeniTom Due Amount Enclosed $7,802.32 04/17/08 "18.24 l T 0225256 D 14 0 06060 1 TXM FVG 001 7 rt Itrel1111rllle11Mill IIIIlelerlrlrlllrel[lilt lelerrlrlet11111 11111111111 gill I Melee check payable to XENOFON SKA MLOS SEARS CREDIT CARDS 195 HICKORY RD PO BOX 183082 CARLISLE PA 17015-9748 COLUMBUS, OH 43218-3062 Please make address aorwWro above. 300 7515 0780232 0091824 0000000 1413 Sears MasterCard' XENOFON SKABOULOS Account Number. XXXX XX)(X XXXX 7515 Page 2 of 2 2252M R8t83 'Rate varies Averepe Daly Balance Baisme Call us at 14W4119-M Go to www.sestson com write to us at PO Box ee22 The Lakes, NY O W 4W22 P merd Dee Date 04/17/06 Ponding Periodic Rate Periodic AL D.Day FINANCE ENTAGERATE M.Momh CHAR ARM SEARS REGULAR $1,395.55 $1,342.58 29.99°x' .0822%(D)* $32.01 EXTERNAL REGULAR $5,406.77 $8,328.44 29.99%` .0822%(D)' $150.85 CASH ACCESS REGULAR $0.00 $0.00 29.99%' .0822%(D)• $0.00 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 29.99% Minimum FINANCE CHARGE: $0.00 Sears MasterCard' XENOFON SKABr" ' Account Number: Page 1 of 2 Can us at 1-800 OMMM Go to www.se er"ard com wrhe to w at PO Box e0B2 Slow Feb, sc 57117-M 17515 P of Out Date 05/19/08 Your Account Summa Billing Cycle Closing Date 04121108 Amount Over Credit Line $0.00 Amount Past Due $918.24 Currant Minimum Due $322.64 Total Minimum Due $1,240.88 Previous Balance $7,80232 Pa"ents & Credits $0.00 Purchases & Debits $0.00 Other Charges FINANCE CHARGES $39.00 $202.64 Account Balance $8,043.96 Your Credit Summa SwN Is about ho starts. So let us help you take a new look at bri *g your a000Unt current Tw w" k a good flee to tike Core o yalr Past doe atllalad end naps a aceI bmilloloI w sour acooent. And the good ooolws K you dolt h Ma b da It abne. w#w ten b I" w101 P1Pw pace and soubrs far you b oao"K. WI VA b yow 0011oenn and mWest ways you ew rake a don swap. Let as week wN yea - sell Ug" wa oae work towwds flyd q a Pis eek dae to could up IN M" yea ww" c tweed saw no fete laaa baa Cal a belay at 1410.3N-iOPt so we pre help yon stele a hah an the *ft. Total Crm* Una $8,190.00 Available Credit Una $146.00 Cash Access Una $1,638.00 Available Cash $146.00 Activity sells, Dots Pow Dace Dssaiption Aottoult 04/17/08 04/17/08 LATE PAYMENT FEE $9.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $7,802.32, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT 18 SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment Instructions on reverse side. Psymewit most be received by 5:00 p.nL local time on Payn wit Due Dab. Sears MasterCard' Account Number: 117515 M TOM Aoeownt Balance t Dets Mb nwn this Amount Enclosed $8,043.96 ? 0V W06 I $1,240.88 01921 D 1+ A 06112 1 TXM M 001 T N 111111111111111111111111 111 1111 1111111111111111 111111111111111111 XENOFON SKABOULOt3 195 HICKORY RD CARLISLE PA 1 701 5-9 748 111111111111111111111111111111111111111111111111111111111111 Make check payable to SEARS CREDIT CARDS PO BOX 183082 COLUMBUS, OH 43218-3082 Pleas make address cwrections above. 100 - -- 7515 08043% 0124088 0000000 1416 Sears MasterCard' XENOFON SKA804JLOS Atxount Number: XXXX XXXX XXXX 7515 Page 2 of 2 192W Average D*W Rates -Rate varies Balance Balance Call us at 1.800.OO94M80 30 to www.eNllq?d,- Write to us at PO Box 8282 Sioux Fde, SD 57117-0282 P meet Due Me 05/19/08 r -rKm g Perladk Rate P rlodle JAL D.Dey FINANCE NTAGE RATE M.Mordh CHARGE SEARS REGULAR $1,470.92 $1,419.11 29.24%• .0801 *D)' $36.37 EXTERNAL REGULAR $6,573.04 $6,486.94 29.24%• .0801 %(D)' $166.27 CASH ACCESS REGULAR $0.00 $0.00 29.24% .0801 %(D)' $0.00 Days In Billing Period: 32 Effective ANNUAL PERCENTAGE RATE: 29.24% Mlnlmum FINANCE CHARGE: $0.00 fi Sears MasterCard' XENOFON SKABnULOS Account Number Page 1 of 2 Call us at 1-800.001-A4!!E Go to www.ewsesrd.oom Write to us at PO Box OM Sioux Foam, SD 571174= 7575 P M Bus Date 06/17/06 Your Account Stxtarra Billing Cycle Closing Date 05120108 Amount Over Credit Line $80.55 Amount Past Due $1,240.88 Current Minimum Due $309.59 Total Minimum Due $1,631.02 Previous Balance $8,043.96 u rchases 6 Debits P $0.00 Other Charges $39.00 FINANCE CHARGES $187.59 Account Balance $8,270.55 Your Credit Summa Total Credit Line $8,190.00 Available Credit Line $0.00 Cash Access Line $1,838.00 Available Cash $0.00 Put this nunwy toward btiWng ywr acowrttCUEFW t We have a number of solutions that may be available. Call us today at 1-866-515-9052 to find out how we can help. Activity sell Date PoN Dete DeeMplion Anloult 05/19/08 05/19108 LATE PAYMENT FEE 39.00 YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $8,043.96, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE 18 SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment Instructions on reverse side. Paymaint must be received by 5:00 p.m. local Um on Payment Due Data. Sears MasterCard' Account Number: 7515 Tatal Aaeoult Balance f Dets Mlnhnwn Due Amount 6ldoead $8,270.55 06/17/08 $1,631.02 034915 Fit 14 SA 08141 1 TXS303 FVG 001 7 {N III{II`IIIIIIII III IIIIIIIII 111 11 111113 111111111 111111 1111111111 XENOFON SKABOULOS 195 HICKORY RD CARLISLE PA 17015-9748 111t11111111111111111111111111111111111111111111111111111111 Make check payable 10 SEARS CREDIT CARDS PO BOX 183002 COLUMBUS, OH 432183052 Please make address cormbons above. 100 7515 0827055 0163102 0000000 1410 'IT Sears MasterCard' XENOFON SKABOULOS Account Number: )O= X)000 )000( 7513 Page 2 of 2 Seas Cah us at 1-804009-6180 Go to www.aeerow"Loom Write to us al PO Box e2s2 Sioux Fels, W 5711T-OM Payment Due Date 06/17/09 Avers Daily Rates 'Bete Varies Belertcs Balance Periodic Rats Partadia D.Day FINANCE M=Month CHARGE SEARS REGULAR $1,54428 $1,490.09 20.99%' .0795960' $34.36 EXTERNAL REGULAR $9,72627 $6,946.71 28.99%' .079596(D)" $153.23 CASH ACCESS REGULAR $0.00 $0.00 28.99X• .0796960` $0.00 Deys in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 26.99% Minimum FINANCE CHARGE: $0.00 Cardmonber News The Sale Date is the Transaction Date. Please see the enclosed privacy notice for Important Wdlomwdlon. Tr Verification Neil Sarker, Esquire, attorney for plaintiff, CITIBANK (SOUTH DAKOTA), N.A. , makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Amended Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Counsel, rather than an officer or other representative of plaintiff is verifying the foregoing Amended Complaint because plaintiff's officers and/or representatives are outside the jurisdiction of the court and the verification of none of them could be obtained within the time required to file this pleading. Plaintiff s counsel is verifying plaintiff's Amended Complaint based upon information and belief from information in his file. Date: I2 ZR 1 X;?/ Neil Sarker, Esquire Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. XENOFON SKABOULOS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8676 CIVIL TERM : CIVIL ACTION - LAW Certificate of Service I, Neil Sarker, Esquire do hereby certify that I served a true and correct copy of the within Amended Complaint on defendant's counsel, Michael J. Pykosh, Esquire at his address of record via first class mail, postage prepaid on the date set forth below. Burton Neil & Associates, P.C. Date: 1430111 By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 . ' Reply to New Matter 26. Requires no response. By way of further response, plaintiff incorporates by reference ILFD-OFFIC o« i ?'r0TIJONO ? 20!2 FEB 17 AN I1: 17 CUMBERLAND COUNTY BURTON NEIL & ASSOCIATES, P.C. PENNSYLVANIA Neil Sarker, Esquire ID. No. 203465 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, PENNSYLVANIA V. NO. 09-8676 XENOFONSKABOULOS Defendant : CIVIL ACTION - LAW the averments of its previously filed complaint. 27. Denied. It is denied that plaintiff's cause of action is barred by the statute of limitations. The complaint set forth a cause of action based upon defendant's default on a credit card account. The applicable limitation for plaintiff's claim against defendant is four years from the date of the last payment on the credit card account. See 42 Pa. C. S. § 5525 et. seq. The last payment made on the credit card account that forms the subject matter of the complaint was posted on January 20, 2008. Plaintiff filed the instant action on December 4, 2009. Since the date of the last payment reflects a payment made within the applicable four year statute of limitations, plaintiffs claimed relief for the subject matter credit card account is not barred by the statute of limitations. 28. Denied. There are no facts alleged in the averment to which a responsive pleading is required. The allegation is denied pursuant to Pa R.C.P. 1029(d). 29. Denied. There are no facts alleged in the averment to which a responsive pleading is required. The allegation is denied pursuant to Pa R.C.P. 1029(d). By way of further reply, defendant objections on this issue were already overruled by the Court. 30. Denied. There are no facts alleged in the averment to which a responsive pleading is required. The allegation is denied pursuant to Pa R.C.P. 1029(d). 31. Denied. There are no facts alleged in the averment to which a responsive pleading is required. The allegation is denied pursuant to Pa R.C.P. 1029(d). 32. Denied. There are no facts alleged in the averment to which a responsive pleading is required. The allegation is denied pursuant to Pa R.C.P. 1029(d). WHEREFORE, plaintiff prays that judgment be entered on its behalf and against defendant as set forth in the complaint. BURTON NEIL & ASSOCIATES, P.C. By: Neil Sarker quire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. Verification Neil Sarker, Esquire, attorney for plaintiff, CITIBANK (SOUTH DAKOTA), N.A., makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Reply to New Matter subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Counsel, rather than an officer or other representative of plaintiff is verifying the foregoing Reply to New Matter because plaintiff s officers and/or representatives are outside the jurisdiction of the court and the verification of none of them could be obtained within the time required to file this pleading. Plaintiff s counsel is verifying plaintiff s Reply to New Matter based upon information and belief from information in his file. Date: s Neil Sark , Esquire ,.WP , . % Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 V. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8676 CIVIL TERM XENOFONSKABOULOS Defendant : CIVIL ACTION - LAW Certificate of Service I, Neil Sarker, Esquire do hereby certify that I served a true and correct copy of the within Reply to New Matter on defendant's counsel, Michael J. Pykosh, Esquire at his address of record via first class mail, postage prepaid on the date set forth below. Date: (S Burton Neil & Associates, P. v By: _ Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 rnCo -n M Z;* M CO `") rr,, in r"3 ?.; C: < v J , r-- z ,< A C.. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. XENOFONSKABOULOS Defendant NO. 09-8676 CIVIL TERM CIVIL ACTION - LAW Praecipe to Substitute Verification To the Prothonotary: Kindly substitute the attached verification for the attorney verification filed with plaintiffs Reply to New Matter. Burton Neil & Associates, P 9 By: Neil Sarker, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. C-29219 Verification I, _ Sherri Smith , am employed by Citibank, N.A. (hereafter Citibank), which is successor in interest to Citibank (South Dakota), N.A. This includes accounts previously owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I am authorized to make this verification on behalf of Citibank. The statements of facts set forth in the pleading are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Signature Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. XENOFON SKABOULOS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8676 CIVIL TERM : CIVIL ACTION - LAW Certificate of Service I, Neil Sarker, Esquire do hereby certify that I served a true and correct copy of the within Praecipe to Substitute Verification on defendant's counsel, Michael J. Pykosh, Esquire at his address of record via first class mail, postage prepaid on the date set forth below. Burton Neil & Associates, P. Date: l I? S Z By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 Michael J. Pykosh, Esquire I D # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717)i, 975-2309 { ' ILL i a"12 A113 21 Pm is 5G4 PENNSYLVANNIA for Defendant CITIBANK (SOUTH DAKOTA), N.A.: IN THE COURT OF COMMON PLEAS 701 East160th Street N : CUMBERLAND COUNTY, PENNSYLVANIA Sioux Fads, SD 57117 Plaintiff V. XENOFOIN SKABOULOS 195 Hickory Road Carlisle, 'PA 17015-9748 Defendant No: 09-8676 - CIVIL TERM CIVIL ACTION - LAW NOTICE TO ATTEND To: Corporate Representative of CitiBank (South Dakota), N.A, with the knowledge to testify to and be cross examined relative to the documents to be admitted into evidence pursuant to PA R.C.P. 1305: (1)) You are directed to come to the law offices of Ball, Murren & Connell, 2303 Market Street, Camp Hill, Pennsylvania, 17011, on September 12, 2012 at 2:OOPM, the time and place scheduled for arbitration of the above matter to testify on behalf of Plaintiff at the request of Defendant in the above case, and to remain until excused. (2) And bring with you the following: Documents to be used as exhibits or intended to be admitted into evidence by PA R.C.P.1305 or otherwise by Plaintiff. If you fail'to attend or to produce the documents or things required by this notice to attend, you may be subject to the sanctions authorized by Rule 234.5 of the Pey(nsylgania Rules of Civil Procedure. Date: 12-1 l Z Mt"chael J. Pykotl ,, Esquire- I. D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Attorney for Defendant Michael J. Pykosh, Esquire ID # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717)1975-2309 for Defendant CITIBANK (SOUTH DAKOTA), N.A.: IN THE COURT OF COMMON PLEAS 701 EastI60t' Street N : CUMBERLAND COUNTY, PENNSYLVANIA Sioux Falls, SD 57117 Plaintiff V. No: 09-8676 - CIVIL TERM XENOFOIN SKABOULOS 195 Hickory Road CIVIL ACTION - LAW Carlisle, IPA 17015-9748 Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Notice to Attend, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows as well as via facsimile to (610) 696-4111: CitiBank (South Dakota), N.A. c/o Neil Sarker, Esquire Burton Neil & Associates, P.C. 1 060 Andrew Drive, Suite 170 Wiest Chester, PA 19380 Respectfully S bmitt Date: Michael J. Pyk sh, Esquire I. D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Attorney for Defendant Burton Neil & Associates, P.C. ~'~~~ ~~(1~)-~ ~~i~ By: Neil Sarker, Esquire ID. N0.203465 t'QlZ S ~~~ ~~~ 1060 Andrew Drive, Suite 170 ,~ ~~ ~~ ~ ~ P~f ~; 2~ West Chester, PA 19380 f~~~LAN 610-696-2120 ~~~~~ ~'~ ~~ Q~rY Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff v. CUMBERLAND COUNTY, PENNSYLV NO. 09-8676-CIVIL TERM XENOFONSKABOULOS Defendant :CIVIL ACTION -LAW Notice to Attend and Produce TO: Xenofon Skaboulos c/o Michael J. Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 You are directed to come to the law offices of Ball, Murren & Connell, 2303 Market S Camp Hill, Pemisylvania,17011, onSeptember 12, 2012 at 2:OOP.M., to testify on behalf of pla Citibank (South Dakota), N.A., in the above case, and to remain until excused. You are requi bring with you your bank records from June 2006 through May 2008. Bring all stubs for n orders, receipts for wire transfers, and/or receipts or other proof of payments on account. Y~ further directed to bring with you each credit card sales slip or receipt for each purchase you to your Sears Mastercard credit card account ending in 7515. If you fail to attend as required by this Notice to Attend, you maybe subject to the authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure. Date: ~ 29 ~ Z BURTON NEIL & ASSOCIATES, P.C. By: Neil ark r, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-292 to are t9 • Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 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 v. :CUMBERLAND COUNTY, PENNSYLV. N0.09-8676 CIVIL TERM XENOFONSKABOULOS Defendant :CIVIL ACTION -LAW Certificate of Service I, Neil Sarker, Esquire do hereby certify that I served a true and correct copy of the wi Notice to Attend on defendant's counsel, Michael J. Pykosh, Esquire at his address of record first class mail, postage prepaid on the date set forth below. Date: ~ 2~ r Burton Neil & Associate .C. By: Neil Sar er, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 HONG rA OCT Py ?$ tj8E-'q 5 2. RE.)NS Y? aCOU, 41A Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. XENOFONSKABOULOS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8676 CIVIL TERM : CIVIL ACTION - LAW Praecipe to Settle, End, & Discontinue To the Prothonotary: Mark the above matter Settled, Ended and Discontinued. Burton Neil & Assoc' , P.C. By: Neil arke Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29219 / 318