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HomeMy WebLinkAbout12-2237Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, CITIBANK, N.A. CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, V3. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA r j ?3 } CIVIL ACTION' - N o. C D NOTICE TO DEFEND 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 twenty (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 claims 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 C#686 2662644 PPTCPADI AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, CITIBANK, N.A. CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, VS. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff, CITIBANK, N.A. claims as follows: 1. The Defendant(s), ROSEMARY C CROUSE, is a resident of Cumberland County, Pennsylvania. 2. Defendant opened a credit account with Plaintiff on or about September 12, 2007. 3. Defendant used the account to make purchases and charges and/or receive cash advances. 4. Plaintiff billed the Defendant for payment of charges on the account and Defenant has assented to the account. 5. Defendant has failed to make payment for the amounts due and owing. 6. There currently remains a balance of $20755.50. 7. An account stated for the sum of $20755.50 exists which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. 8. Defendant last made a payment on the account on 11-11-2010 . 2662644 PPTCCITI WHEREFORE, Plaintiff, requests Judgment in the amount of $20755.50, plus court costs and interest from the date of Judgment. Respectfully No. 92800 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 CITIBANK, N.A. Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850.1079 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, VS. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: March 12, 2012 2662644 PPTJCAM I I I By: Gregory R. Dye VERIFICATION Abbie Motley am employed by Citibank, N.A. (hereafter Citibank) which is successor in interest to plaintiff Citibank (South Dakota), N.A. This includes accounts previously owned by plaintiff Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. 1 am authorized to make this verification on behalf of Citibank. The statements of facts set forth in the Reply to New Matter 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. DATE: 3-ZF-?2- Signature 2662644 PPTXCTVI I I N I N1I Exhibit "A" PPTXEXAI ?-66d-04 CITIBANK, N.A. ) } Plaintiff, ) VS. ) Case No. ROSEMARY C CROUSE ) Defendant. ) AFFIDAVIT STATE OF MISSOURI ) ) as. COUNTY OF PLATTE ) Before me, the undersigned authority, personally appeared the person identified below, who being by me duly sworn, deposed as follows: 1. MY name is Cheryt Prestm I am of sound mind, lawful age and capable of making this Affidavit. The statements set forth in this affidavit are thus and correct based on personal knowledge and review of the business records described herein. i am authorized to make this affidavit on behalf of Citibank, N.A. (referred to herein as "Citibank"). This Includes accounts previously owned by Citibank (South Dakota), N.A., which merged into Citibank in or about July 2011. 2. 1 am employed by Citicorp Credit Services, Inc. (USA) (referred to herein as "CCSI'). CCSI is a subsidiary of Citibank and services accounts owned by Citibank, including maintaining and recording Information in Citibank's records. Citibank Is a National Bank with its home office in Sioux Falls, South Dakota. 3. My employment duties Include being a custodian of records for CCSI and Citibank with respect to accounts owned by Citibank. As a custodian of records, I have knowledge of, and amass to, account Information and records concerning the defendant's Citibank account number currently ending in 7074, which is the subject of this lawsuit (the "Account"). 4. Citibank's records regarding the Account contain the name and billing address of the defendant, the Account number (and predecessor account numbers, if any), the Account's history, including charges made, interest and/or fees assessed, payments and/or credits received, and the minimum payment due and the total outstanding balance due on the Account, all of which are collectively referred to as the "Account Information 5. Citibank and CCSI maintain records and the Account Information in the ordinary course of business, which is made at or near the time of each event recorded by someone with personal knowledge of the events, or from informatkm transmitted by someone with personal knowledge of each event, and a business duty to record such information. 6. The Account Information reflects that charges were made on the Account to purchase goods and services and/or obtain cash advances. Defendant was provided periodic billing statements for the Account when there was Account activity, which described the charges on the Account, along with interest, fees, payments, credits and the amount due on the Account. Attached hereto and Incorporated herein as Exhibit A are true and correct copies of the Account statement transaction detail for the period from 5119/2011 to 6/17/2011 that was sent to the defendant (the "Account Statement"). 7. The Account Information shows that the Account Statement was sent to the defendant either by regular mail or by electronic mail. The attached Account Statement does not reflect any outstanding disputes on the Account. 6. As reflected in the Account Information, defendant did eventually fail to make required payments on the Account. 9. As a result of defendant's failure to make proper payments on the Account, defendant is presently in default on the Account. 10. As reflected on the attached Account Statement, the balance on the Account is $20,755.50. After the attached Account Statement was sent to the defendant, an additional payment or credWdebit was received on the Account in the amount of $0.00. As of the date of this affidavit, the Account balance of $20,755.50 Is due and owing. 11. The debt reflected herein is delinquent, past due and remains due and owing. Citibank is the owner of the Account and the party and entity to whom the delinquent debt is owed. By: e. Name: efy r S rn STATE OF MISSOURI ) ) ss. COUNTY OF PLATTE ) On this _4 day of . 20A before the undersigned Notary Public In and for the state of Missouri, personally appeared Cheryl Preston known to me to be the person who executed the Affidavit on behalf of the above-named Plaintiff, and acknowledged to me that he/she executed the same for the purposes therein stated. v? --zT- Notary Public My commission expires: (i$ } ? a S? o h VI J Fo ??Ox O 5533x?C I0 UmvO-i? a$ O O C ?° o N N Y i O S « Y N ? y 3 I L q ro 1?j? 1 S I + O O 'd 7dI=- O ` T 8 H 'd v? 0 `S C v Q! ? S 3 y a, E t g 10 W a o ?= W N A s ,-fin O ? ? M C SS'' g ? ? O X10 ?01 ? 1jh1 N P,N ,?+1 1 Ly «I` N w e E utou a ° hT i Nj.2gs ? lilt : ? ? - C.&,! 11 1 fix s'?= IL h -IZ E°$ Iffle' N 40 40 28 d.Wpdd wnoadpdd ch.ckM_ www.cKkwdlLc 7074 New Balance.. $20.755.40 Minimum Payment Our. $20.755.50 Payment Due Date.. 07115120M 000000 MC 34 A O ROSEMARYC CROUSE 350 MEADOWS RD NEWVILLE PA 17 2 41-97 33 s 0A.M -d I"- p.pte..l kulrvatl.n. w rw.rw M.k. w .A MY.M. t.CK1 Cards 7074 Amount Endoaed: p ym.,d t : r.eMrN w sso pM IoW em..o the p.rlnwd du. dN.. CITI CARDS P.O. BOX 1a2564 CRUM9US, OH 4321a-2564 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-5641567 Attorney for Plaintiff, CITIBANK, N.A. CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. f/? -,V3 / 1, IV 1'6- I PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINT14 C, CITIBANK, N.A.. Papers may be served at the address set forth below: -< W 1_ Blatt, Hasenmiller, Leibsker & Moore, LLC T 1835 Market Street, Suite 501 r'o Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASEN & MOORE, LLA Dated: March 12, 2012 By: Gregory R. Dye 2662644 PPTXPEAI ININ ER, LEIBSKER SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?gtlttil{' ©{ ?0tttli?F'r,? 11fi'I ,E - TkE f'1I Eb-GF FiCE 1012 APR 20 AM 8: 45 CUMBERLAND COUNTY PENNSYLVANIA Citibank NA vs. Rosemary C. Crouse Case Number 2012-2237 SHERIFF'S RETURN OF SERVICE 04/13/2012 06:56 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 1856 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rosemary C. Crouse, by making known unto herself personally, at 350 Meadows Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. WN SHAL EPUTY SHERIFF COST: $40.00 April 18, 2012 rj Crim?`>'Su tl S:-ertl SO ANSWERS, RON R ANDERSON, SHERIFF 23256 osemar C Crouse .? oams % ss) • (Phone) DfftE /2 P?D_ uF THE m,N,,M r- 0 T?'j t??fAY - AM 9:42 CUMSERL.4NQ CQN 1 Y PENNS YLVANt IN THE COURT OF COMMON CITIBANK, N. A. VS. Plaintiff, ROSEMARY C CROUSE Defendant(s) PLEAS CUMBERLAND COUNTY,PA W ?'iz?'C.1:,. ? J/ ANSWER TO COMPLAINTAND AFFIDAVIT DEFENDANT ROSEMARY C CROUSE'S ANSWERTO PLAINTIFF'S COMPLAINT AND AFFIDAVIT Defendant, Rosemary C Crouse, answers the Complaintand Affidavitfiled by Plaintiff, Citibank N.A., as follows: 2. By specifically denying the entire allegations contained in Paragraph 2 to 5 of the Complaint, Defendant submits that Defendant never opened thealleged credit account with Plaintiff.Defendant never made purchases and charges and/or cash advances to the account as alleged. Defendant does not owe Plaintiff as alleged. Plaintiff has failed to submit the copies of account opening form duly signed by Defendant, account agreement executed between Defendant and Plaintiff, invoices, bills, receipts and such other valid documentary evidence to prove the entire allegations contained in Paragraph 2 to 5 of the Complaint. Rosemary C Crouse- Answer Page I of 3 3. By specifically denying the entire allegations contained in Paragraph6 to 8 of the Complaint, Defendant submits thatDefendant does not owe Plaintiff for $20755.50 as alleged. Defendant never opened the alleged account with Plaintiff. Defendant never made payment to Plaintiff on 11-11-2010 as alleged. Plaintiff has failed to submit the copies of account opening form duly signed by Defendant, account agreement executed between Defendant and Plaintiff, statements of account, receipts for payment made by Defendant, bills, invoices and such other valid documentary evidence to prove its allegations. In this regard, in the case of it has been stated as follows: "To recover on a suit on account, a Plaintiff must show an offer, an acceptance, and consideration between the parties as well as the correctness of the account and the reasonableness of the charges." It further states as follows: "Such evidence consists of proof that: 1) Defendant requested Plaintiff to furnish merchandise or services; 2) Plaintiff accepted the offer of the Defendant by furnishing such merchandise or services; and 3) the charges were reasonable"So,the burden of proof is on Plaintiff to submit valid documentary evidence to prove the entire allegations. Further, Defendant challenges the veracity of Exhibit "A" attached with the Complaint. 4. Answering to Paragraph 1 and 2 of the Affidavit, Defendant submits that Defendant has no sufficient knowledge or information to form a belief as to the truth or falsity of the statements contained in Paragraph 1 and 2 of the Affidavit. Rosemary C Crouse- Answer Page 2 of 3 5. Answering to Paragraph 3 to 7 of the Affidavit, Defendant submits Defendant did not open the account having number ending in 7074 as alleged. There is no valid credit agreement executed between Defendant and Plaintiff. Defendant did not make charges on the account to purchase goods and services and/or to obtain cash advances. Defendant never received account statements or billing statements from Plaintiff. Further, Defendant does not owe Plaintiff for $20755.50 as alleged in the Affidavit. Affiant has failed to submit the signed copies of credit application and credit agreement, copies of proof of service of account statements or billing statements delivered to Defendant, bills, invoices, receipts for payment and such other valid evidence toprove the entire allegations contained in Paragraph 3 to 7 of the Affidavit. Defendant challenges the veracity of Exhibit A attached with the Complaint. Further, Affiant is only a custodian of records of Plaintiff and therefore, neither making nor checking of records is the duty of Affiant and hence the Affiant cannot know about the veracity of therecords Defendant specifically denies the entire allegations contained in Paragraph 3 to 7 of the Affidavit. Answering to Paragraph 8 tol 1 of the Affidavit, Defendant submits that Defendant never opened or used the account as alleged. Defendant reiterates that there is no valid credit agreement executed between Defendant and Plaintiff. Defendant never agreed with Plaintiff regarding the terms and conditions of a credit account. Defendant never received billing statement from Plaintiff or made payments to Plaintiff. Defendant does not owe Plaintiff for amount of $20755.50as alleged.Affiant has failed to submit the signed copies of credit application and credit agreement, copies of statements of account, receipts for payment made on the account, proof of service of billing statements delivered to Defendant and such other valid evidence to prove the entire allegations contained in Paragraph 8 to l lof the Affidavit. Defendant specifically denies the entire allegations contained in Paragraph 8 to 11 of the Affidavit except the statement that Defendant is neither an infant nor an Rosemary C Crouse- Answer Page 3 of 3 Exhibit 'A' CITIBANK SOUTH DAKOTA v. WHITELEY CITIBANK (SOUTH DAKOTA) N.A., A Bank Corporation, Plaintiff-Respondent, v. Danny H. WHITELEY, Defendant-Appellant. No. 25925. -- November 23, 2004 Daniel T. Moore, Moore & Walsh, L.L.P., Poplar Bluff, for appellant.Mayer S. Klein, Michael J. Payne, Frankel, Rubin, Bond, Dubin, Siegel & Klein, P.C., St. Louis, for respondent. Citibank (South Dakota) N.A., (plaintiff) brought a suit on account against Danny H. Whiteley (defendant). The case was heard by the trial court without a jury. Judgment was entered for plaintiff in the amount of $4,218.58 principal, interest in the amount of $728.14, and costs. Defendant appeals. This court reverses and remands with directions. Plaintiffs petition alleged defendant was "indebted to it on account of goods, services and/or merchandise provided by Plaintiff at Defendant's instance and request"; that "*t+he charges for said goods, services and/or merchandise provided by Plaintiff to Defendant *were+ reasonable." Plaintiff alleged that payment was demanded but had been refused.1 Plaintiff called an employee, Paula Sullinger, as a witness. Ms. Sullinger stated she was "a manager in the recovery unit" located in Kansas City. Ms. Sullinger identified plaintiff as a banking corporation authorized to do business in Missouri. Ms. Sullinger testified, over the objection of defendant, that although there was no documentation of a credit card account, she had knowledge that defendant maintained a credit card account with plaintiff. She testified, over the objection of defendant, that an account maintained by plaintiff revealed a balance owed by defendant. Ms. Sullinger explained, again over defendant's objection, that charges were posted to accounts based upon notification by merchants of charges made by a cardholder; that any documentation for a charge belonged to the merchant and was not maintained by plaintiff. Ms. Sullinger was asked whether she had knowledge about what goods were purchased by defendant for which charges were made to the account plaintiff sought to collect. She had no knowledge concerning what defendant would have purchased from a particular merchant. Ms. Sullinger had no knowledge whether charges were fair and reasonable. No other evidence was offered on the question of reasonableness of charges. Ms. Sullinger was asked the following questions and gave the following answers about the nature of plaintiffs business. Q. My question is, you, being Citibank of South Dakota, didn't provide any merchandise, did you? A. No. Q. You didn't provide any goods to the defendant, did you? A. No, just a service. Q. And you didn't come out and perform any services for the defendant and charge him for that, did you? A. No, just paid the merchants for him. Defendant asserts one point on appeal. He argues the trial court erred in granting judgment for plaintiff on its suit on account "because there was no evidence to support the judgment in that *plaintiff] failed to prove that *defendant+ received any goods, services or merchandise provided by *plaintiff+." Defendant contends further that there was no evidence that anything plaintiff claims defendant received was reasonable in cost. Defendant further asserts that any theory of recovery plaintiff may assert, other than the suit on account it pleaded, would constitute a variance to which plaintiff timely objected at trial. "A suit on open account means a suit in contract for each purchase transaction." Medicine Shoppe International, Inc. v. Mehra, 882 S.W.2d 709, 713 (Mo.App.1994). To recover on a suit on account, a plaintiff must show an offer, an acceptance, and consideration between the parties as well as the correctness of the account and the reasonableness of the charges. Welsch Furnace Co., Inc. v. Vescovo, 805 S.W.2d 727, 728 (Mo.App.1991). "Such evidence consists of proof that: 1) Defendant requested plaintiff to furnish merchandise or services; 2) plaintiff accepted the offer of the defendant by furnishing such merchandise or services; and 3) the charges were reasonable." Id. Even if this court were to accept plaintiffs assertion that providing credit to a credit card holder amounted to providing a service for purposes of maintaining a suit on account, an issue this court need not and does not address, the evidence was silent as to the reasonableness of any charge that was made to defendant. A party bringing a cause of action cannot prevail if one or more elements of the cause of action are not supported by substantial evidence. Vintila v. Drassen, 52 S.W.3d 28, 38 (Mo.App.2001); Mills Realty, Inc. v. Wolff, 910 S.W.2d 320, 322 (Mo.App.1995). Further, as asserted by defendant, defendant scrupulously objected throughout the trial to any evidence that was outside plaintiffs pleadings. Defendant's point is granted. The judgment is reversed. The case is remanded. The trial court is directed to enter judgment for defendant. FOOTNOTES 1. Plaintiffs attorney assured the trial court at the commencement of trial that plaintiff had no credit card agreement signed by defendant; that plaintiff was "suing on an account theory, suit on account." SHRUM and BARNEY, JJ., concur. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CLAA 4 Plaintiff : NO. 1. 2. - 22,31 20 1 2 VS. • at U I --` "''_' 1 • p • C,roust._ Defendant : r'rt rs7 rt.! RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially ireiX Following form: "<l> PETITION FOR APPOINTMENT OF ARBITRATORS BITRATORS >c, -2 ci zer TO THE HONORABLE,THE JUDGES OF SAID COURT: �? KICAT-CA SCc`SS e-kn N M, counsel for th plaintff defendant in the above action(or actions),respec:fuIly represents that: 1. The above-captioned action(or actions)is(are)at issue. 2. The claim of plaintiff in the action is$ 2 D,7S gp Pt\) COUc4—C=uS' The counterclaim of the defendant in the action is The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to whom the case shall be submitted. a % v SO'vk a N Respectfull itted, .G bA- Q},:v si as ORDER OF COURT AND NOW, ,200 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action(or actions) as prayed for. By the Court, Kevin A.Hess,P.J. ti Blatt,Hasenmiller,Leibsker& Moore,LLC Attorneys for Plaintiff Morris A. Scott,AttyID#83587 Syretta J. Martin,AttyID#309370 1835 Market Street, Suite 501 Philadelphia,PA 19135 800-850-1079 CITIBANK,N.A. do Blatt,Hasenmiller,Leibsker& Moore,LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. CIVIL ACTION ROSEMARY C. CROUSE NO. . 12-2237 CIVIL TERM Defendant(s). CERTIFICATE OF SERVICE I, Morris A. Scott/ Syretta J. Martin, as counsel filing the attached pleading, hereby certify that I mailed an exact copy of the attached to the party(ies) below at the address indicated by U.S. Mail first class postage prepaid,unless otherwise stated below. WORLD LAW GROUP ATTN: BRAD HASKINS, ESQ 2201 DONLEY DRIVE AUSTIN, TX 72758 �c r� Morris . Scott/Syretta J. Martin D e Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 CITIBANK,N.A. Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK,N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION .� s vs. CZ No. 12-2237 CIVIL TERM ROSEMARY C CROUSE r, :? Cn 350 MEADOWS RC Y "< ' car NEWVILLE PA 17241-8733 -- Defendant(s). C1 C)-� . - f --t eU PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK, N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker& Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: September 11, 2013 By: Morria Scott Attorney Syretta Martin Attorney 2662644 PPTXPEAI 111111111 IN 11111111111111 IIIII 11111 IIIII 11111111111111111 III IN zc�c�Z(.c5 � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff NO. 2 —223 20_LZ- vs. Defendant r n co :z r rl r-n r-n RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially it� ' :Z)i , Following form: en_ PETITION FOR APPOINTMENT OF AIRBITRATORS o W C)tr- TO THE HONORABLE,THE JUDGES OF SAID COURT: r x counsel for th plaintif defendant in the above " action(or actions),respectfully represents that: 1. The above-captioned action(or actions)is(are)at issue. 2. The claim of plaintiff in the action is$ 2-U,7S-,M D\S COU�C'DS� The counterclaim of the defendant in the action is The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to S� whom the case shall be submitted. "'Z "SC'-?:k a Respectfull itted, CX4 9 ORDER OF COURT AND OW, 209PJ in consideration of the foregoing jetition, Esq.,and �n = sq.-end ' Esq., are a pointed arbitrators in the above - captizio action( actions)as prayed for. < > ,.�c-) cc) ;,�->`.- By the Court, , 1 -- c ) M �n A.Hess,P.J. C11 z C c=a M �y��s �•'l e� 9 f��i3 Blatt,Hasenmiller,Leibsker& Moore, LLC Attorneys for Plaintiff Morris A. Scott,AttyID#83587 Syretta J. Martin,AttylD#309370 1835 Market Street, Suite 501 Philadelphia,PA 19135 800-850-1079 CITIBANK,N.A. c/o Blatt,Hasenmiller,Leibsker&Moore,LLC IN THE COURT OF COMMON PLEAS Plaintiff, CrUMBERLATt;D COUNTY, PA VS. CIVIL ACTION ROSEMARY C. CROUSE NO. . 12-2237 CIVIL TERM Defendant(s). CERTIFICATE OF SERVICE I, Morris A. Scott/ Syretta J. Martin, as counsel filing the attached pleading, hereby certify that I mailed an exact copy of the attached to the party(ies)below at the address indicated by U.S. Mail first class postage prepaid,unless otherwise stated below. WORLD LAW GROUP ATTN: BRAD HASKINS, ESQ 2201 DONLEY DRIVE AUSTIN, TX 72758 IC !3 Morris X. Scott/Syretta J. Martin D e a In the Court of Common Pleas of Cumberland rPlaintiff V l4sr, County, Pennsylvania No. Defendant Civil Action—Law. Oath We do solemnly swear(or affirm)that we will support, obey and defend the Constitution of the United States and the onstitution Commonwealth and that we will discharge the duties of our office with fidelity. S' afore Signatye Sigh'affie Name(Chairman) Name Name Law Firm Law Firm Law Firm Address Address zj Address C��45� V/ I 7rl 3 eA- /:�b I City, Zip City, Zip City, Award We,the undersigned arbitrators,having been duly appointed and sworn(or affirmed),make the following award: (Note: If damages for delay are awarded,they shall be separately stated.) UJ 9+fv a6v Arbitrator, dissents. Insert name if applicable.) ( PP ) Date of Hearing:\ Date of Award: la 75 o (Chairman) Notice of Entry of Award Now,the 26�� day of eQ(.� t ,20 /3 , at AL 'OCR 74 M.,the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 4//Z-S-Z) sy: I--, — ar�o Prothonotary Deputy DIE PROTHOl' I3 OCT 30 Ali 10: 0 CUMBERLAND COUNTY PENNSYLVANIA e..s IVIC .61' A/VA/o 3 Blatt,Hasenmiller,Leibsker& Moore,LLC Attorney for Plaintiff' t ' `I GNC7] ;t Morris Scott Attorney I.D. #83587 ,_'U13 Pilot' t Syretta Martin Attorney I.D. #309370 PIL 1835 Market Street, Suite 501 "��; 'L41, D Philadelphia, PA 19103 PENNSYLVANIA 800-850-1079 CITIBANK,N.A. Wo Blatt,Hasenmiller,Leibsker&Moore,LLC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, VS. CIVIL ACTION ROSEMARY C CROUSE 12-2237 CIVIL TERM Defendant(s). NOTICE OF APPEAL FROM THE AWARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is hereby given that Citibank,N.A. appeals from the Award of Arbitrators entered on October 30, 2013 A. Jury Trial is NOT Demanded. B. I hereby certify that the compensation of the Arbitrators has been paid. Morris Scott, Attorney No. 83587 Syretta Martin, Attorney No. 309370 C��\Xk- 9a7o9 a vk� Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. 12-2237 CIVIL TERM ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Defendant(s). CERTIFICATION OF SERVICE I, Morris Scott, attorney at Blatt, Hasenmiller, Leibsker and Moore, do hereby certify that I sent a true and correct copy of the NOTICE OF APPEAL FROM THE AWARD OF ARBITRATORS via U.S. Regular Mail, to the DEFENDANT'S ATTORNEY on 11-12-13. WORLD LAW GROUP ATTN: BRAD HASKINS, ESQ 2201 DONLEY DRIVE AUSTIN, TX 72758 Morris Scott, Esq. Syretta Martin, Esq. BHLM, LLC 2662644 PPTNCOSI In the Court of Common Pleas of Cumberland Plaintiff 1 C7S C Cir yc.GS� County, Pennsylvania No. Defendant Civil Action—Law. Oath We do solemnly swear(or affirm)that we will support, obey and defend the Constitution of the United States and the onstitution s-Commonwealth and that we will discharge the duties of our office with fidelity. Sjfnafure Signa e —S-4 7a e Name (Chairman) Name Name Law Firm Law Firm Law Firm J4,1/y /j �, fs 9, t (;� uje5t— 61, Address Address Address City, Zip City, Zip City, -tip Award We, the undersigned arbitrators,having been duly appointed and sworn(or affirmed),make the following award: (Note: If damages for delay are awarded, they shall be separately state/d.) UJ /'� f�tj �G C� ��.�. y�IQ��,� l %` ✓ ' Q� �c(mss `f'l�Y� Arbitrator, dissents. (Insert name if applicable.) Date of Hearing:,, Date of Award: /� o (Chairman) 1 . Notice of Entry of Award Now,the 26"y day of Or s, ,20 /3 , at M.,the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 1AZ•S7� 12�� •'� t (.t1J t� COPY FR By' _ ProthB>a y whereof, I here unto set my hand Deputy end the seal of said Cou at ntosfet my This , day of�,20 1-3 Crl(G RECEIVED NOV 012013 /C_ Prothonotary Y d Citibank, N.A. c/o Blatt,Hasenmiller, Leibsker&Moore. LLC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION C vs. C"3 r.. "71 NO. 2012-2237 CIVIL TERM Rosemary C. Crouse u , ti (1Defendant cr> r CD T APPLICATION TO CONFIRM ARBITRATION AWARD - .f -rc NOW COMES the Petitioner, CITIBANK,N.A., by and through its attorneys, Blatt, Hasenmiller, Leibsker& Moore, LLC, and requests this court to confirm an arbitration award in its favor and against the Respondent, Rosemary C. Crouse. In support thereof, Plaintiff states: 1. This application is filed pursuant to the Federal Arbitration Act, 9 USC §9. 2. On or about April 9, 2012, Plaintiff, through its counsel, Blatt, Hasenmiller, Leibsker, and Moore, LLC filed a lawsuit in Cumberland County Court of Common Pleas case Number 12-2237 seeking damages in the amount of$20,755.50 plus court costs for a past due amount claimed on the Citibank account ending in 7074. 3. The Defendant elected arbitration with the American Arbitration Association"AAA" after the Plaintiff filed suit against her in this case. Defendant further filed an arbitration claim with the AAA asserting various claims against Plaintiff. See Defendant's Arbitration claim attached as Exhibit 3. Plaintiff,through its counsel, Blatt, Hasenmiller, Leibsker, and Moore, LLC, filed Counterclaim in the Arbitration proceeding seeking the recovery of the amount owed on the underlying debt on the account ending in 7074. Additionally, Citibank included a second account opened by Defendant ending in 0206. Pursuant to the terms of the charge account agreement the parties agreed to arbitrate any claim or disputes in both accounts. See the charge agreement corresponding to account ending in 7074 attached as Exhibit 1 and charge agreement corresponding to account ending in 0206 attached as Exhibit 2. 5. The counterclaim also sought the amount of underlying debt owed on the account ending in 0206 ($5087.80) plus additional interest, attorney's fees, and costs. Both accounts were the subject of AAA Case 14 434 E 01525 13. 6. After hearing on all documents submitted, the AAA arbitrator issued the Award in favor of Citibank for the net amount of$26,432.05 (inclusive of costs) and denying Defendant's claims in their entirety. Attached hereto is a copy of the Arbitrator's Award entered by the American Arbitration Association in favor of Citibank,N.A. (the respondent in the arbitration proceeding)on March 31, 2014. See Exhibit 4. • 7. The Award also ordered that the Defendant Crouse reimburse Citibank the sum of $2250.00, representing that portion of the fees in excess of the apportioned costs previously incurred by Plaintiff. See Exhibit 4. 8. As of today, Defendant has failed and/or refused to comply with this provision. 9. The Arbitrator's Award is final, no application to vacate or modify the award having been filed pursuant to 9 USC §§10 or 11. 10. Allowing for all just claims and set-offs the balance due on the award is $28,682.05 (representing $25,843.30 on the aggregate underlying debt on accounts ending in Accounts 7074 and 0206, costs of$588.75, and $2250.00 in costs that were ordered to be reimbursed to Plaintiff but have not). 1 I. Plaintiff has also spent previous additional costs in filing, serving, and prosecuting the state court action and will spend additional costs in confirming the Award. WHEREFORE, the Plaintiff, CITIBANK, N.A., prays that this court confirm the Arbitrator's Award in favor of Plaintiff and against Defendant, Rosemary C. Crouse, in the amount of$28,682.05 plus further court costs associated with filing the state court action and confirming the Award. Respectfully submitted, • CITIBANK, N.A. One of its a orneys 4'4+ Blatt,Hasenmiller,Leibsker&Moore,LLC Attorneys for Plaintiff 1835 Market Street Suite 501 Philadelphia,PA 19103 800-850-1079 THIS IS A COMMUNICATION FROM A DEBT COLLECTOR Citibank,N.A. do Blatt,Hasenmiller,Leibsker&Moore,I IC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION vs. NO. 2012-2237 CIVIL TERM Rosemary C. Crouse Defendant NOTICE TO FILE ANSWER A Party to these proceedings has filed a motion to confirm an arbitration award. If you oppose the motion, you are required to file an answer to the motion within thirty (30)days from the date you are served with this Petition setting forth your objections to the motion. If you fail to file an answer, a money judgment based on the arbitration award may be entered against you without further notice. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 or 249-3166 THIS IS A COMMUNICATION FROM A DEBT COLLECTOR • Blatt, Hasenmiller, Leibsker& Moore, LLC Attorneys for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19135 800-850-1079 CITIBANK,N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. CIVIL ACTION ROSEMARY C. CROUSE Defendant(s). NO, 2012-2237 CIVIL TERM CERTIFICATE OF SERVICE I, Syretta J. Martin, as counsel filing the attached pleading, hereby certify that I mailed an exact copy of the attached Plaintiff's Application to Confirm Arbitration Award to the party(ies) below at the address indicated by U.S. Mail first class postage prepaid, unless otherwise stated below. Rosemary Crouse c/o World Law Group 350 Meadows Road Newville, PA 17241 World Law Group c/o Rosemary Crouse Attn: Brad Haskins, Esq. PO Box 82641 Austin, TX 78708 401/7 Syretta J. Martin Date h • 1 I h I . ..h Year BHltna Rights:Keep MO I1ountnt for Future Ilse •Mk you do not ham to pay the emote In question, 2.You must Mw teed your creel and for Mo purchase. This moths tab yea about Your nab and our reapoudbtt• you ars responsible for the remainder of your 011100.. Purchases mods Mm cab admen from an ATM or Nat stair the Fair Craft allay eel •Iii I0P any mpald amount epeeist Your Peart a check that wanes your credit and account do CARD AGREEMENT Went To OH 11101.IOlAMl0ake On Your 5falemeel After we tithes our hnaofyita,Cu,el two tangs not<toady. 3.You must rot yet hove fully paid lot the purchase TMe Card Agrarian!u tate contrast with e.It governs It you think terve is an mor on your statement,write to us et will kapyer. 11 all of the criteria above are met and you are sem dMalafled the we of your card end secouhl Tha encased Prkr e Me address Ca Wog imarles and correspondence shown •U ea made a nate)m You who not have to pay the will the purchase,contact us imago a the address to alternation Table and Useable Terne Information(together. on Me front of your statement amount m question or any Illaasi a oma fat'Piled Meng 0quktes and corraspondua sham on tow host of IW`Fed Sheet,ars cart of Ods Agreement Peau lead this In your letter.are us Ow mtidwirq Information: to the 0010rt. . your 0Mement Aetmmhlt kaceudbp the Fact Steel cushy.Heap mem Your anew and tion: lumber. •B we do not beam there was a You oaf have yy we Imest4•te,the same mks apply to the disputed your records. •Mg amount TM duller meowed Ue suspected enos to pay the amount In questa'',Cora with appliab mount as distorted above.Ater we flesh Our investigation. 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You mud roily us of any atonal errors Walls.You gots know when Ms matter has been men settled batus. nes,a, unman 0001*(Salm Ualaul,NA.,me may mil us,bel if you do es ue not to tem tt oto H w da not farm d of la odes above,yeu da not have to ktam d your aCOoahR es marked any potenthf ears and you may has to pay He amount MI� t$50 d tW amount you question eve H your Wt yes,yamsad year mean 1M person Mo mated so open question. le amount.H also near any oma person responsible for airching with this Agrsement Y(pat WHI Heaerytilif}Y.Remit'Yaw Ulla Yeur Mlabh H Yeo An Obaalhlled WIm but Carie Your Account when urs mete yea lever,we map do Iwo things: You agree s on your account M accordance who this 1.Main 30 days et mainmainyour tetter,we mud toil you If yore diessas d with the goods or Makes Mat you Agreement You mot pay as fa all amounts due on your that we maned your litter.We MP Men he you t we two purchased who your dads cord,and you Nov.01d In account.Tres Agreement is binding on you nkat you don have atmbay weeded the error good tsM to correct ma problem with the merchant you may your account Otto 30 days alto reatvag to cad end you 2.Within 90 days or making your letter,we must Other have the right not to pry the remain 1111011111 due a.the hive eat used or aumorbed ate of the card.Your aaaull correct the mar or eaten to you My we begot the purchaee. must any be used for Intl trmudfona. tail Is coed, To use ass nom,aft M the lapwing must be true NMlarlead Users.You MlY epouut addltoru!aerie for Wats we Invadeale abetter a ed mere hat been 1.The purchase mud has barn made In your Mme arae Mhortred users.You mal pay w to all herpes made by is error. an wean 100 mea of your current nailing address, authorized uses.You must pry to even N you did not Intend •We aorta try to mace the amount In question,or and me Dubaee price Ma nays been more mho$50. to be responsible for those etagee.You must notify us to report you as delinquent at that remount. (Note:Neither M mese ale naaswy O your isnot a telltale any ymmission you give to an authorized user to •The chop to cream may amain on your datanant, wee based on an advertisement we mated la you,or use your accountt and we nay armee to One you Wad n that H we own Ito company that told You the goods or Croat UmM.TM roe wool at your credit until ts audible amount. services.) to as Mieee the and le honored.Pott al your credit limit . . •aoab•w room NW.).rte ispeed the atm tient emit It Is nasal for ash eraNtw ma • advmee.We may Mian or e000ale your credit omit or cosh idmnre Omit st any time for any mason Is omitted II rat w .��.- • -----• ..._.—...��_.... _ .—____ Vis' / • by taw.We we notify you of cry Mow,but the chino may APR may continue b appy to both new and edatnp b00ui •only edsaes(6ululhp corned Irmo Wens)MMOwd. mum Pennine Due Pres the Meed Over Credit timh shown ion edea beton you raceme the notice.You should always 1beflakly. 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THE MOAT TO A JURY AND THE RIGHT TO PARTICIPATE dint It wee a govaanantua dad rater rowan to en your srrmrm may be retain In your diet report We Pnapbwrhal CIiEn.Wo may suspend IM adomtic or Ill A CLASS ACTION OR SIMILAR PEOCEEOWG.IN ARSE done m not.It uses a edd•nW rude rate.Our dTIawt may moon scored alormatn In your nnw and the nomas dM anothorhod card carps you arrange wOh a den MOON,A OMPUTE IS RESCUED BY AN ARSITRATOR proodur,cry amps horn huh flew MmaR rota a wpraUcd res.We may Moo arta llowge dadan. INSTEAD OF A JUOCE OR JURY.AREITRATION PROLE- The carman rats you at b me aimed en the Pane repOrw on you. 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Account APRs.For the APRs on your account,see the Fact Interest and Fees("Fact Sheet")Is part of this Agreement. Credit Limit.The full amount of your credit limit Is available to Sheet. Please read this Agreement,Including the Fact Sheet,carefully. use where the card is honored.Wo will notify you separately if Variable APRs Based on Prime.If any APR is based on the Keep them for your records. your account has a cash advance feature.If it does,part of your U.S.Prime Rate("Prime Rate"),the APR wits equal the Prime credit limit Is called the cash advance limit.It is available for Rate plus en additional amount.The additional amount appears Definitions account means the relationship established between you and us cash advances.If your account Coes not have a cash advance on the Fact Sheet In the Details About Your interest Rate table, by this Agreement. feature.the terms of this Agreement relating to cash advances If the Prime Rate increases,It will rause me APR to increase. do not apply to your account.We may reduce or increase your If the Prime Rate decreases,it will cause the APR to decrease. APR means an annual percentage rate. credit limit or cash advance limit at any time for any reason, For each billing cycle we use the Prime Rate published in The aathodred user means any person you allow to use your as permitted by law,We well notify you of any change,but the Wall Street Journal two business days before the Statement account. change may take effect before you receive the notice.You should Closing Date.II the Prime Rate causes an APR to change,we card means ons or more cards or other access devices that always keep your total balance below the credit limit.However, put the new APR into effect as of the first day of the billing cycle we give you to get credit under this Agreement.This includes if the total balance goes over yew credit limit you still must pay for which we calculate the APR.We apply the new APR to any account numbers. us.Ii your account has a credit balance,we may reduce the existing balances.subject to any promotional rate that may credit balance by arty new charges on your account.You may apply.If The Wall Street Journal does not publish the Prime we,us,and on,mean Citibank,N.A,the issuer of your account. not maintain a credit balance in excess of your credit limit. Rate,we will use a similar published rate. Citibank.NA.is located In Sioux Falls,SD. Checks.We may provide you with convenience checks.When Penalty APR.II your account has a Penalty APR.the Fact Sheet • you,your,and yours mean the person who applied to open we do•we will tell you in writing whether they may be used shows the amount of the Penalty APR and when it applies to the account.It also means any other person responsible for for balance transfer transactions or cash advance transactions. your account. complying with this Agreement If we tell you they may be used for balance transfer Uansac• Effect of APR Increases.If an APR increases,Interest charges Your Account lions,any use will be a balance transfer transaction.You may increase.Your minimum payment may Increase as well You agree to use your account in accordance with this Agree- use them to transfer a balance to your account or make other meet You must pay us for all amounts duo on your account transactions.II we tell you they may be used for cash advance Promotions This Agreement is binding on you unless you close your transactions,any use will be a cash advance transaction even We may offer promotional temps for all ora part of any balances. account within 30 days after receiving the card and you have If you use the check to nuke a payment to another creditor. Any promotlomal terms may apply for a limited period of ume. not used or authorized use of the card.Your account must only You may not use convenience checks to pay an amount owed They wit be governed by the terms of the promotional offer and be used for lawful transactions. to us under this Agreement or to pay another account with this Agreement.Your promotional terms will end when the pro- us or an affiliate.We do not certify these checks or return any motional period expires or,to the extent permitted by law,if you Authd users.Each authorized may r user iis your agent and mayuse, checks that have been paid. make a late payment.The promotional offer will tell you it we 0Billing Statement.Your billing statement shows the New require a separate minimum payment on the promotional balance. manage,and receive information about the account to rho same Balance.This is the total amount you owe us on the Statement It a promotional offer is a deferred interest otter,no interest extent as you,subject to any limitations we may Impose.You Closing Date.To determine the New Balance,we begin with charges will be Imposed on the deferred Interest balance if must pay us for all charges made by authorized users.You must bre total balance at the start of the billing cycle.We add any you pay the balance in full by the end of the promotional period pay us even if you did not intend to be responsible for those charges.You must notify us to withdraw any permission you purchases,balance transfers or cash advances.We subtract for that deferred interest balance.We will impose interest give to an authorized user to use your account. any credits or payments.We then add any Interest charges or charges on the deferred Interest balance al the APR for regular Joint Accounts.If this Is a)plot account each of you is respon• fees and make other adjustments. purchases horn the date of purchase if you do not pay the balance in full by the end of the promotional period. Your bitting statement also shows your transactions;the Mini- mum sibte individually and together for all amounts owed.Each of Payment Due and payment due date;your credit limit and you is responsible even I the account is used by only one ofInterest Charges Based on APRs you.You will continue to be liable for the entire balance of the cash advance limit;and your Interest charges and fees. Interest Ch account,even Ifyour co-applicant Is ordered by a court to pay We deliver a billing statement to only one address.You must your account We impose interest.Wd charges every when by apply not Customer Service of a changeinAlias periodicyour rate. bglet a da We this , day using rrv.You will remain liable to us if your co-applicant toils to pay 1y address.We may stop a daily rate.To pet a dairy periodic rate,we divide the as ordered by the court.Your account status will continue to sending you statements if we deem your account uncollectible APR by 365. 1 a a • e•SGM-1211 When Interest Charges Begin.We begin to impose interest daily compounding of Interest charges.)Wo add any now take a cash advance If you use a cash advance convenience charges the first day we add a charge to a daily balance.The charges.We then subtract any now credits or payments. check;get money through an automated feller machine(ATM): charges we add toe dally balance include purchases,balance •We multiply each daily balance by the daffy periodic rate or get money through home banking or a financial institution, transfers,and(ash advances.They also include Interest that applies to it.We do this for each day In the billing You also take a cash advance it you make a wire transfer,buy charges and fees.We continue to Impose interest charges until cycle.This gives us the daily interest charges for each of a money order,traveler's check lottery ticket,casino chip,or we credit your account with full payment al the total amount your different balances. similar item;or engage in a similar transaction. you owe us. •We add up all the daily interest charges.The sum is the Transaction Fee for Balance Transfers.The Fact Sheet shows Grace Period on Purchases.You can avoid interest charges total interest charge for the billing cycle. the amount of this fee.We add this tee for each balance transfer. on purchases.but not on balance transfers and cash advances. •You authorize us to round interest charges to the nearest This lee is in addition to any periodic fee that may be imposed This is called a grace period on purchases.The grace period is cent. with a promotional offer.You make a balance Transfer if you use at least 25 days.To get a grace period on purchases,you must When we calculate daily balances,we add a purchase,balance a balance transfer convenience check or contact us to transfer pay the New Balance by the payment due date every billing transfer,or cash advance as of the Transaction Date.(The a balance. cycle.If you do not you will not get a grace period unto you transaction Date for a balance transfer or cash advance is the Transection Fee ter Foreign Purchases.The Fact Sheet shows pay the New Balance for two billing cycles In a row. date we gel a request to complete a transaction.When you send the amount of this fee for foreign purchases.(Detail in Fact If you have a balance subject to a deferred interest promotion a convenience check directly to someone,the Transaction Dale Sheet) and that promotion does not expire before the payment due is the date we receive the check for payment.The Transaction Late Fee.The Fact Sheet shows the amount of this lee.We may date,that balance(the"excluded promotional balance")Is Date Is on the billing statement.)We add a transaction fee to the add a late fee for each billing cycle in which you have a past due excluded from the Amount you must pay in full to get a grace same balance as the transaction.We generally add other fees, payment.For late fee purposes,you have a past due payment period.However,you must still pay any separatelyrequired Including credit protection fees and Insurance charges,to the m time you Cr i payitthe wnMinimumanPaymentDue(less the Payment co the excluded promotional balance.In billing cycles regular purchase balance.We add any remaining balance from Amount Over Credit Limit shown on your billing statement)by In which payments are allocated to deferred interest balances a balance transfer at a promotional APR to the regular purchase the payment due date.We add this fee to the regular purchase first,the deterred interest balance will be reduced before any balance.We do this on the day after the promotional period balance. other balance on the account.However,you will continue to expires.We subtract a payment or credit as of the day it is get a grace period on purchases so long as yes pay the New credited to the account and then make other adjustments.We Returned Payment Fee.The Fact Sheet shows the amount of Balance less any excluded promotional balances in tel by the treat a credit balance as a balance of zero. this fee.We may add a returned payment lee for a returned payment due date each billing cycle. Minimum Interest Charge.It we charge you interest,the Fact chcheck,or A returned payment instrument,an etectrons.debit payment In addition,certain promotional otters may takethe race Sheet shows the minimum amount we will charge.We add the We to or similar this payment t your that ment issted unpaid., Y away g g We may add this tee the first time payment returned, period on purchases.Other promotional offers not described charge to the regular purchase balance or allocate it among one even if it is not returned upon resubmission.We add this leo above may also allow you to have a grace period on purchases or more of the balances that accrues interest. to the regular purchase balance, without having to pay as or a portion of the promotional bal- Balance Sub)ect to Interest Rale.Your statement shows a Returned Convenience Check Fee,The Fact Sheet shows the once by the payment due date.II either Is the case,the promo- Balance Subject to Interest Rale.II shows this for each different amount of this fee.We may add a returned convenience check tional otter will describe what happens. balance.The Balance Subject to Interest Rate Is the average of fee for a returned convenience check.A returned convenience Calculation of Interest Charges—Daily Balance Method the daily balances during the billing cycle.A billing cycle begins check is any convenience Check we do not horror.Wo may not (Including Current Transactions),We ukulele interest charges on tire day altar the Statement Closing Date of the previous honor these checks If the amount of the check would cause the each billing cycle.To da this: billing cycle.It includes the Statement Closing Dale of the cur- balance to go over the cash advance limit or credit limit_We also •We start with each of your different balances.These rent billing cycle. may not honor these checks i1 you default if you did not comply balances include,for example,regular purchases,Old with our instructions regarding the check If your account has Balances,regular cash advances,and different promotional AnnualFees Membership Fee.It an annual membership fee applies, been closed:or for other reasons.We add this fee to the regular balances.(When we calculate Interest charges,we treatPD purchase balance. each deferred Interest transaction separately even it k has the Fact Sheet shows it.We will refund the annual membership the same terms as another deferred interest transaction lee if you notify us that you are closing your account within Stop Payment on Convenience Check Fee.The Fact Sheet and we treat balance transfers as regular purchases unless 30 days of the malling or delivery date of the billing statement shows the amount of thls fee.We add this fee if we honor your a promotional rale applies.) on which the fee appears.The tee Is otherwise non-refundable. request to stop payment on a convenience check.Write us at •We cakvlate the daily balance for each of your different It this fee applies,we add it to the regular purchase balance. P.O.Box 6275,Sioux Faits,SD 57117 to stop payment on a balances.To get a daily balance,we start with the balance Tramaetioe Fee for Cash Advances.The Fact Sheet shows the conveniencemthecbck You statement. also Howll the Customer call,youe as o1 the end of the previous day.We add any interest amount of this fee.We add this fee for each cash advance.You number co on mbilling in rmngt. thin 14rtyou r charge on the previous day's balance.(This results in must confirm the call in writing*thin 14 days.A written stop • 6 0 • 1 II I I .c+r..l I r t.. .. r I - • • E-SGM-1211 payment orderis good for 6 months unless renewed in writing. or other restrictive endorsements,without losing our rights. the terms of this Agreement.II you default,we may close your We add this lee to site regular purchase balance. We also reserve the right to accept payments made in foreign account and,to the extent permitted by law,demand immediate Information on Foreign Currency Conversion currency and instruments drawn on funds on deposit outside payment of the total balance. thOur network provider is MasterCard.MasterCard converts we U.S.c edwe do.weselectouthe currency conversion after leo rete.We Refusal of the Card,Closed Accounts, will then credit your account in U.S.dollars after deducting any transactions In foreign currencies into U.S.dollars.MasterCard costs Incurred in processing your payment Or we may hill you end Related Provisions follows its own procedures to do so.These may change from separately for these costs. Refusal of the Card.We do not guarantee approval at trensac- time to time without notice.Currently,MasterCard uses a con. tions.We ere not liable for transactions that are not approved. version rate in effect one day before its transaction processing Optional Pay by Phone Service.You may use our optional Pay That is true even if you have enough credit.We may limn date.It uses a govemntent•mandated rate if required to do so.If by Phone Service to make your payment by phone.To do so, the number of transactions approved in one day.If we detect not,it uses a wholesale market rate.A third party may convert a call us to request the service.You agree to pay us the Pay by unusual or suspicious activity,we may suspend your credit transaction into U.S.dollars or another currency before sending Phone fee shown in the Pay by Phone section on the back of the •privileges. it to MasterCard.In these cases,the third party selects the billing statement when a representative of ours helps expedite • conversion rate.In all cases,the conversion rale you get Is the your payment Our representatives are trained to tell you this Prealdherizad Charges.We may suspend any automatic or one used on the transaction's processing date.This may be amount when you use this service. other preauthorized card charges you arrange with a third party. W different from the one in effect on the Transaction Date or post Credit Reporting Nwecha do Nis account you nfont y rea cant fs lest or is,yo;or date for the transaction. ble your theear any reason.If we do this,you are We may report information about your account to credit bureaus. responsible for paying third party directly if you wish to do Payments late payments,missed payments,or other defaults on your so.You am also responsible for reinstating the preauthorized Minimum Peymerd Due.You must pay at least the Minimum account may be reflected in your credit report.We may report charges if you wish to do so and we permit it Payment Due by the D account information in your name and the names of authorized ypayment due date each billin le. Lost or Stolen Calla,Account Numbers,or Convenience The sooner youthe New Balance,the lessyou will payin users.We may also obtain follow-up credit reports on you. pay Checks.You must can us if any card.account number,or interest charges.The Fact Sheet shows the minimum payment If you think we reported incorrect Inlormetion to a credit bureau, check is lost or stolen.You must also call us if you think calculation method that applies to your account write us at the Customer Service address en the billing state- someone used or may use them without permission.When Application of Payments.Payments in excess of the Minimum men!.We will investigate the matter.We will than tell you if we you call,we may require you to provide infomiation to help our Payment Due are applied in accordance with law.This means agree or disagree with you.II we agree with you,we win contact irrvesligation.We may require you to provide this information that we will generally apply payments in excess of the Minimum each credit bureau to which we reported and request a coffee- in writing.For example,we may ask you to Identity any charges Payment Duo to higher APR balances first However,excess lion.If we disagree with you,we will tall you that. that were not made by you or someone authorized by you.We payments received before a deferred interest promotion expires Information Sharing may also ask you to confirm that you received no benefit from are applied to the deferred Interest promotional balance first You authorize us to share information about you as permitted those charges. in the last two billing cycles of the promotional period.And,it by law.This includes information we gel from you and others. Closing Your Account.You may close your account by notifying the expiration date of a deterred Interest promotion Is before It also Includes information about your transactions with us. us In writing or over the phone.It you close your account,you the payment due date in the billing cycle In which the deferred Please see our Privacy Notice for details about our information must still repay the Iota!balance in accordance with this Agree- interest promotion expires,excess payments received before the sharing practices. meet.We may also close your account or suspend account deferred Interest promotion expires are applied to the deferred privileges at any time for any reason.We may do bits without interest promotional balance first in the last three billing cycles Changes to this Agreement prior notice to you.Wo may also reissue a different card at any of the promotional period.Payments equal to or less than the We may change the rates,tees,end tams al this Agreement time.You must return any card to us upon request. Minimum Payment Due and credits are applied at our discretion from time to time as permitted by law.The changes may add, arra you authorize us to apply payments and credits In a way replace,or remove provisions of tilts Agreement.We wilt give ARBITRATION that IS most favorable or convenient for us.This may include you advance written notice of the changes and a right to opt PLEASE READ THIS PROVISION OF THE AGREEMENT applying such payments and credits to lower APR balances first out to the extent required by law. CAREFULLY.IT PROVIDES THAT ANY DISPUTE MAY BE and to balances with longer promotional periods first RESOLVED BY BINDING ARBITRATION.ARBITRATION Default REPLACES THE RIGHT TO GO TO COURT.INCLUDING Payment Instructions.We credit your payments in accordance You default under this Agreement if you fall to pay the Minimum THE RIGHT TO A JURY AND THE RIGHT TO PARTICIPATE with our payment instructions on the billing statement.You Payment Due by its due date:go over your credit limit pay by a IN A CLASS ACTION OR SIMILAR PROCEEDING.IN ARBITRA- must pay us In U.S.dollars,To do so,you must use a check, check or similar instrument that is not honored or that we must TION,A DISPUTE IS RESOLVED BY AN ARBITRATOR INSTEAD similar instrument,or electronic debit that is drawn on and return because It cannot be rocessed;pay by electronic debit OF A JUDGE OR JURY.ARBITRATION PROCEDURES ARE honored by a bank In the U.S.Do not send cash.We can accept that Is returned unpaid:file far bankruptcy:or fail to comply with SIMPLER AND MORE uMITMD THAN COURT PROCEDURES. late or partial payments,or payments teal reflect'paid In lull` 7 e e 9 • , , I r c E-SGM'1211 Agreement to Arbitrate:Either you or we may,without the or our assignee.We and any assignee may seek arbitration recognized at law,and will have rho power to award to a party other's consent,elect mandatory,binding arbitration for any on an Individual basis of any Claim asserted by you,whether any damages or otter relief provided for under applicable law. claim,dispute,or controversy between you and us(called In arbitration or any proceeding,Including In a proceeding to You or we may choose to have a hearing and be represented "Claims"). collect a debt-You may seek arbitration on an individual basis by counsel.The arbitrator will make any award In writing and, Velma Covered of any Claim asserted against you,including in a proceeding it requested by you or us,will provide a brief statement of the What Claims are sub(ed to arbitration?All Claims relating to to collect a debt. reasons for the award.An award in arbitration shall delamtine your account,a prior related account,or our relationship are How Arbitration Works the rights end obligations between the named parties only,and subject to arbitration,Including Claims regarding the application, How does a party Initiate arbitration?The party filing an only in respect or the Claims in arbitration,and shall not have enforceability,or Interpretation et this Agreement and this arta- arbitration must choose one of the loltowinp Iwo arbitration any bearing on the rights and obligations of arty other person, or on the resolution o1 any other dispute. Intim provision,Al Claims are subject to arbitration,no mailer firms and follow Its rules and procedures for initiating and what legal theory they are based on or what remedy(damages. pursuing an arbitration:American Arbitration Association or Who pays?Whoever files rho arbitration pays the initial filing or Injunctive or declaratory relief)they seek.This includes JAMS.My arbitration hearing that you attend will be held ala lee.If we file,we pay,H you rile.you pay,unless you gel a fee Claims based on contract,tort(including intentional ton), place chosen by the arbitration firm In the same city as the U.S. waiver under the applicable rules of the arbitration lino.If yuu fraud,agency,your or our negligence,statutory or regulatory D-slricl Court closest to your than current baling address,or have paid Cho Initial filing lee and you prevail,we will reimburse provisions,or any other sources o1 law,Claims nada as at some other place to which you and we agree In writing.You you far that lee.it there is a hearing,we will pay arty lees of the counlertlalms,cross-claims.third-party claims,Interpleaders or may obtain copies of the current rules of each of the arbitration arbitrator and arbitration firm for the first day of that hearing. otherwise;and Claims made independently or with other claims. firms and forms and instructions for initiating an arbitration by All other fees will be allocated as provided by the rubs of the A party who initiates a proceeding in court may elect arbitration contacting them as follows: arbitration firm and applicable law.However,we will advance or with respect to any Claim advanced in that proceeding by any reimburse your tees A the arbitration firm or arbitrator deter- Americanrbitration Association A other party,Claims and remedies sought as part of a class mines there Is good reason for requiring us to do so,or if action,private attorney general or other representative action BO( 778.7879(toll-free) you ask us and we determine there Is good reason for doing are subjectto arbitration www.adcorp ation on an Individual(non-class,oar so.Each party wig bear the expense of that party's attorneys, representathe)basis,and the arbitrator may award relief only JAMS exports,and witnesses,and other expenses,regardless of which on an individual(non"cfass,nonrepresentative)basis. 800-352-5267(loll-free) party prevails,but a party may recover any or all expenses Whose Claims are subject to arbitration?Not only ours and Website:www.Jarrswdreom from another party if the arbitrator,applying applicable law,so yours,but also Claims made by of against anyone connected At any time you or we may ask an appropriate court to compel determines. with us or you or claiming through us or you,such as a arbitration of Claims,or to stay rha litigation of Claims pending Who can be a party?Claims must be brought in the name of on co-applicant or authorized user of your account,an employee, atbitratlon,even II such Claims are part of a lawsuit,unless Individual person or entity and must proceed on an individual agent,representative,affiliated companypredecessor or a trial has begun ora final Judgment has been entered.Even (non-class,non-representative)basis.The arberetor wilt not successor,heir,assignee,or trustee In bankruptcy. it a party falls to exercise these rights at any particular time, award relief for or against anyone who is not a party.II you or What lime frame applies to Claims sullied to arbitration? or In connection with any particular Claims,that party can still we require arbitration of a Claim,neither you,we.nor any other Claims arising in the past,present,or future,Including Claims require arbitration at a later time or In connection with any other person may pursue the Claim In arbitration as a class action, ansing before the opening of your account,are subject to Claims. private attorney general action or other representative action. arbitration. What procedures and law are applicable In arbitration? nor may such Claim be pursued on your or our behafi In any Broadest Inlerprelellen.Any questions about whether Claims A single,neutral arbitrator will resolve Claims.The arbitrator will litigation In any coon.Claims,Including assigned Claims,al two are subject to arbitration shall be resolved by interpreting this be either a lawyer web at least len years experience or a retired or more parsons may not bo joined or consottlatod in the same arbitration provision in the broadest way the law will avow h or termor judge,selected in accordance wnh the rules of the arbitration,However,applicants,co-applicants,authorized users to be enforced.This arbitration provision is governed by the arbitration frim.The arbitration will follow procedures and rules on a single account and/or related accounts,or corporate alfil- federal Arbitration Act(the"FAA"). of the arbitration firm In effecton the data the arbitration Is filed laces are here considered as one person. What Claims filed In Small Claims Count Claims Bled In nless those procedures and rules are Inconslstem with this When Is an arbitration sward final?The arblratorb award a het about claims C court are not Slto riaou ?Cl long as the Agreement,in which case this Agreement will prevail.Those is final and binding on the parties unless a party appears II in a matter remains aims court andbt arbitration,only an o Individual procedures and rules may Ilrnit the discovery available to you writing to the arbitration firm whin fifteen days of notice of the mater reIIn s such advancesdlaor us.The arbitrator wit take reasonable steps to protect cos- award.The appeal must request a new arbitration before a panel (non-clamer account intonation and other confidential IMormoUon of three neutral arbitrators desIgnated by the same arbitration What about debt collections?We and anyone to whom we if requested to do so by you or us.The arbitrator will apply firm.The panel will consider all factual and legal Issues anew, assign your debt will not initiate an arbitration proceeding to applicable substantive law consistent with Me FAA and follow the same rutos that apply toe proceeding using a single coned a debt from you unless you assert a Claim against us applicable statutes of limitations,win honor claims of privilege arbitrator,and make decisions based on the vote of the majority. re u rr e E-SGM-1211 Costs will be allocated In the same way they are allocated for Spanish Language Translation While we Investigate whether or not there has been an error: arbitration before a single arbitrator.An award by a panel is As a customer service,we will provide you with a copy of this •We cannot try to collect the amount In question,or report fetal end binding on the parries after fifteen days has passed.A Agreement In Spanish upon your request and for your con- you as delinquent on that amount. final and binding award is subject to Judicial review and venience.To obtain such a copy,write to us at P.O.Box 6275, •The charge in question may remain on your statement,and enforcement as provided by the FAA or other applicable law Sioux Fells,SO 57117,or call us at 1.800{638488. we may continue to charge you interest on that amount, Survival and Sovarabillty of Terms Como un servicto a nuestros cliemes,le proveeremos •una Copia •While you do not have to pay the amount in question,you are responsible for the remainder of your balance. Thos arbitration provision shall survive:(i)termination or de esle Acuerde en mendst usted asl to solclta.Para obtener •ria can apply any unpaid amount against your credit lint changes In the Agreement,the account or the relationship dicha copra,puede escribhnos al P.O.Box 6275,Sioux Falls,SD between you and us concerning the account;(Ii)the bankruptcy 57117,o llamarnos al 1.800-6838488,y solicitor una version en After we finish our investigation,one of two things of any party;and(iii)any transfer,sale or assignment of your espanot de este Acuerdo. will happen: mount,or any amounts owed on your account,to any other •Uwe made a mistake:You will not have to pay the amount person or entity.II any portion of this arbitration provision is In question or any Interest or other lees related to Ilial deemed invalid or unenforceable,the entire arbitration provision amount shall net remain In force,No portion of Ihls arbitration •provision •ll we do not believe them was&mistake:Yeti wig have to may be amended,severed or waived absent a written Your Billing Rights:Keen this Document tor Future Use pay the amount in question,along with applicable interest agreement between you and us. Title nonce tells you snout your rights and ear responsibilities and fees,We will send you a statement of the amount under the Fair Credit Billing Act, you owe and the date payment is due.We may then report Lew and our Rights you as delinquent it you do not pay the amount we think dooming Governing FeLa law Enforcingf law of Soou gh What To Do II You Find A Mistake On Your Statement you owe. where we areLalocated,govern and terms and ouchenforDakota,ment of it you think there is en error on your statement,write to us al If you receive our explanation but still believe your bill Is wrong, where ies Agreement the address for billing inquiries and correspondence shown on you must write to us within JO days telling us that you still the front of your statement. refuse to pay.I1 you do so,we cannot report you as delinquent Enforcing this Agreement.We will not lose our rights under In your letter,give us the!allowing information: without also reporting that you are questioning your bit.We this Agreement because we delay in enforcing them or fall to •gt:rount information•Your name and account number, must tell you the name of anyone to whom we reported you enforce them. •Dollar amount:The dollar amount of the suspected error, as delinquent,and we must tel those organizations know when Collection Costs.To the extent permitted by law,you are liable •Description o1 problem:II you think them is an error on the matter has been settled between us. to us for our legal costs if we refer collection of your account your bili describe what you believe is wrong and why you II we do not follow ail of the rules above,you de not have to to a lawyer who is not our salaried employee,These costs may believe it is a mistake. pay the first$50 of the amount you question even It your Dill Include reasonable attorneys'lees.They may also include costs You must contact us: Is conest and expenses of any legal action. •Within 60 days alter the error appeared on your statement Assignment.We may assign any or all e1 our rights and o0liga• •At least 3 business days before an automated payment is Your Riabls If You Are Dissatisfied Wills Your Credit tions under this Agreement to a third party. scheduled,it you want to stop payment on the amount you Card_Puruhases For Further Information think is wrong. II you are dissatisfied with the goods or services that you have Call us loll-tree for further information.Call the toll•rree You must notify us 01 any potential errors N writing.You may purchased with your credit card,and you have tried In good Customer Service telephone number shown on the billing call us,but if you do we are not required to Investigate any go- faith to correct the problem with the merchant you may have statvrnent or on the back of your card.You can also call local IenUal errors and you may have to pay the amount in question. the right not to pay the remaining amount due on the purchase. or toll-tree 0iirectory Assistance to get our telephone number. To use this right,all of the Wowing must be true: d''' Whet Will Happen Alter We Receive Your Letter 1.The purchase must have been made In your home state When we receive your letter,we must do Mo things: or within 100 miles of your current mating address 1.Within 30 days of receiving your biter,we must tell you that we received your letter.We will also tell you If • and the purchase price must have b0en more than�50. we (Note:Neither of these are necessary if your purchase Ken Stark Citibank,NA have already corrected the error, was based on an advertisement we mated to you,or it we Vice President P.O.Box 6000 2.Within 90 days of receiving own the company that sold you the goods or services.) g your tatter,we must either 2.You must have used your credit card for the purchase. Slow Falls,SD 57117 correct the error or explain to you why we believe the billPurchases made with cash advances from an ATM or is correct. with a check that accesses your credit card account do not quality, to I. ,a • E-SGk1-1211 3*You must not yet have holly paid for the purchase. II all of the criteria above are met and you are still dissatisfied with the purchase,contact us iff1111112 at the address for billing Inouiries and correspondence shown on the pont of your statement. While we investigate,the same rules apply to the disputed amount as discussed above.Atter we finish our investigation, we will tell you our decision,At that point,it we think you owe an amount and you do not pay,we may report you as delinquent O 2011 awMit,N.N. ESOM-1111 I4111 • le I ' I I Oct 29 13 O4:O1p BB # p.3 • AMERICAN ARBITRATION ASSOCIATION SUPPLEMENTARY PROCEDURES FOR CONSUMER-RELATED DISPUTES How to file a claim;consumers should: flow to tile a claim; businesses should: •Pill out this form and retain ono copy for your records. •Fill out this form and retain one copy for your records. i. •Mail a copy of this form and your check or money •Mall a copy of this form and your check or money order made payable to the AAA,to: order made payable to the AAA, to: AAA's Case Filing Services,1101 Laurel Oak Road AAA's Case Filing Services,1101 Laurel Oak Read Suite 100,Voorhees,NJ 08043. Please consult Section Suite 100,Voorhees,NJ 08043. Please consult Section • C-8 of the.Sum.demenmry Procedures for Consumer• C•8 of the Supplementary Procedurerfor Consumer- Related Disputes for the appropriate fee. Related Disputes for the appropriate fee. •Send a copy of this form to the business. •Send a copy of this form to the consumer by registered malt,return receipt requested. 1 Flow is this claim being filed?Check only one. [x]By request of the consumer(A copy of the arbitration agreement must be attached.A copy of this form must also be sent to the business) ' [ ]By request of the business(A copy of the arbitration agreement must be attached.A copy of this form must also be sent to the consumer by registered mail return receipt requested) [ ]By mutual agreement("submission")of the parties(both parties must sign this form) • 2 Briefly explain the dispute. Disputed debt and fees.Also,FOCPA violations. 3 Do you believe there is any money owed to you? [x]Yes [ ]No If yes,how much?$10,000.00 4 Are you seeking any other relief? [ ]Yes [x]No If yes,what Is it? 5 Preferred hearing locale(if an in-person hearing is held) Columbia.Pennsylvania 6 Amount enclosed:$200.00 • 7 Fill in the following information: Consumer Business Name of Consumer Rosemary C.Crouse Name of Business Citibank,NA. Address 1254 Lancaster Ave. Address City/State/Zip Columbia,PA 17512 City/State/Zip Telephone Telephone Fax Fax Email Address Email Address Signature of Consumer Signature of Business Representative Morris Scott Representative Brad Haskins/Sue Miller Rc p Firm World Law Group Firm Blatt,Hasenmiller,Lelbsker&Moore LLC Address 2201 Donley Drive,Suite 200 Address 1835 Market St.,Suite 501 City/State/Zip Austin,Texas 78758 City/State/Zip Philadelphia,PA 19103 Telephone 347-230-7318 Telephone 215.564-1587 Fax 888-227.7129 Fax 215-564-3818 Email Address attomeys22 a@worldlawdirecLcom Email Address AAA Case Filing Services 1-877-495-4185 www.adr.org Cyd f AMERICAN ARBITRATION ASSOCIATION Commercial Arbitration Tribunal In the Matter of the Arbitration between: Re: 14 434 E 01525 13 Rosemary C.Crouse ("Claimant") and Citibank,NA ("`Respondent") AWARD OF ARBITRATOR I, THE UNDERSIGNED ARBITRATOR, having been designated in accordance with the arbitration agreement entered into by the above-named parties, and having been duly sworn, and oral hearings baying been waived in accordance with the Rules,and having fully reviewed and considered the written documents submitted to me,do hereby,FIND and AWARD,as follows: Claimant's claim is denied in its entirety. Respondent is the prevailing party in this matter. Respondent's claims for additional interest and counsel fees are denied. Respondent's request for court costs of$588.75 is granted. Therefore,.Claimant shall pay to Respondent on Respondent's counterclaim the sum of Twenty Six Thousand.Four Hundred Thirty Two Dollars and Five Cents($26,432.05)consisting of Twenty Five Thousand Eight Hundred Forty Three Dollars and Thirty Cents($25,843.30)on the claim plus $588.75 in court costs. The administrative fees of the American Arbitration Association totaling$1,700.00($200.00 paid by Claimant/$1,500.00 paid by Respondent)and the compensation of the arbitrator totaling • $750.00($750.00 paid by Respondent)shall be borne by Claimant. Therefore,Claimant shall reimburse Respondent the sum of$2,250.00,representing that portion of said fees in excess of the apportioned costs previously incurred by Respondent The above sums are to be paid on or before thirty(30)days from the date of this Award. This Award is in full settlement of all claims and counterclaims submitted to this Arbitration. All claims not expressly granted herein are hereby,denied. Date Richard M.Rosenbleeth Rosemary C. Crouse 3 i2) i4/moi s Z � , � ��, � _ ,�f (Address) /7:24V 7/7 77G — - tit...77, JUL i 1 P11 I2: 15 CUMBERLAND COUNTY PENNSYLVANIA CITIBANK, N. A. Plaintiff, vs. ROSEMARY C CROUSE Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 2012-2237 CIVIL TERM RESPONSE TO PLAINTIFF'S APPLICATION TO CONFIRM ARBITRATION AWARD DEFENDANT ROSEMARY C CROUSE'S RESPONSE TO PLAINTIFF'S APPLICATION TO CONFIRM ARBITRATION AWARD Defendant, Rosemary C Crouse, files this Response to Plaintiff, Citibank, N.A.'s Application to confirm arbitration award and states as follows: 1. Plaintiff herein moves this Court to confirm the Arbitration Award entered against Defendant. Defendant humbly submits that Pennsylvania Court has no jurisdiction to confirm the private arbitration award and hence Plaintiff's Motion should be dismissed. Moreover, Defendant has moved an appeal against the arbitration award and the arbitration proceedings still going on in this case. 2. Defendant further submits that Plaintiff's motion may kindly be dismissed as this Court has no jurisdiction to confirm the award of the AAA's arbitrator. Plaintiff and Defendant have 2012-2237 Rosemary C Crouse — Response to P's Application Page 1 of 7 selected the `United States District Court' in and for the district wherein the award was made by agreeing upon the condition that "a final and binding award is subject to judicial review and enforcement as provided by the FAA" in the arbitration clause contained in the agreement. The specific language in the arbitration clause in the agreement is copied below: Judgment upon the award rendered by the arbitrator may be entered in any Court having jurisdiction." 3. The judicial review of the arbitration award means and includes confirmation, vacation or modification of the award. See the ruling of United States Court of Appeals in Booth v. Hume Pub., Inc., 902 F.2d 925 (1990). In Booth, the federal appellate Court held that "A party initiates judicial review of an arbitration award not by filing a complaint in the district Court, but rather by filing either a petition to confirm the award or a motion to vacate or modify the award. 9 U.S.C.S. §§ 9, 12, 6. These rules further the Federal Arbitration Act's policy of expedited judicial action because they prevent a party who has lost in the arbitration process from filing a new suit in federal Court and forcing re -litigation of the issues. Moreover, the district Court need not conduct a full hearing on a motion to vacate or confirm; such motions may be decided on the papers without oral testimony." 4. The vacation and modification of the award are governed by Sections 10 and 11 respectively of the FAA. Pursuant to Section 10 and 11 of the FAA, the United States District Court has jurisdiction to hear and decide the motion for vacation or modification of the award. 5. The confirmation of the award is govemed by Section 9 of the FAA. Pursuant to Section 9, if the parties agreed in the arbitration clause that a judgment of the Court shall be entered upon the award made pursuant to the arbitration, and shall specify the Court, then at any time within one year after the award is made any party to the arbitration may apply to the Court so specified for an order confirming the award, and thereupon the Court must grant such an order 2012-2237 Rosemary C Crouse — Response to P's Application Page 2 of 7 unless the award is vacated, modified, or corrected as prescribed in sections 10 and 11 of this title [9 USCS §§ 10, 11]. In the arbitration clause, the parties have chosen United Stares District Court in and for the district wherein the award was made by mutually agreeing upon the judicial review and enforcement of the award as provided by the FAA. The selection of judicial review and enforcement by the FAA clearly indicates that the confirmation is to be done in the United States District Court in and for the district wherein the award was made. As the parties have agreed on the United States District Court in which the confirmation is to be made, this Court has no jurisdiction to confirm the award of the arbitrator. Therefore, Plaintiff's motion should be dismissed with prejudice. 6. Secondly, the governing law of the card member agreement is `federal law' and the disputes in the arbitration before the AAA included federal questions regarding FDCPA and Regulation Z violations of the Plaintiff. Therefore, this Court has no subject matter jurisdiction to hear and decide Plaintiff's motion for confirmation of the award. The United States District Court in and for the district wherein the award was made has the original subject matter jurisdiction in this motion. The Supreme Court of the United States in Grable & Sons Metal Prods. v. Darue Eng'g & Mfg., 545 U.S. 308 (2005) held that "28 U.S.C.S. § 1331's provision for federal - question jurisdiction is invoked by and large by plaintiffs pleading a cause of action created by federal law (e.g., claims under 42 U.S.C.S. § 1983). There is, however, another long-standing, if less frequently encountered, variety of federal "arising under" jurisdiction, judicial precedent having recognized for nearly 100 years that in certain cases federal question jurisdiction will lie over state -law claims that implicate significant federal issues. The doctrine captures the commonsense notion that a federal Court ought to be able to hear claims recognized under state law that nonetheless turn on substantial questions of federal law, and thus justify resort to the experience, solicitude, and hope of uniformity that a federal forum 2012-2237 Rosemary C Crouse — Response to P's Application Page 3 of 7 offers on federal issues". See another decision of a federal Court regarding FDCPA violations and federal jurisdiction. "Federal -question jurisdiction can be based purely on a state claim if its resolution necessarily requires the construction of federal law. The rule is well settled that a state claim "arises under" federal law if the complaint, properly pleaded, presents a substantial dispute over the effect of federal law, and the result turns on the federal question. The vast majority of cases brought under the general federal -question jurisdiction of the federal Courts are those in which federal law creates the cause of action, but a case may also arise under federal law where the vindication of a right under state law necessarily turns on some construction of federal law". Chase v. United Residential Mortg., LLC, 2011 U.S. Dist. LEXIS 7693. 7. Therefore, this Court cannot invoke jurisdiction either under the agreement between the parties or under the Federal Arbitration Act. CONCLUSION Wherefore, Plaintiff's Application to confirm arbitration award may kindly be denied and award cost to Defendant for preparing this response to Plaintiff. Dated: July // 014 2012-2237 Signature of Defendant: Rose ' ary C Cro e Rosemary C Crouse — Response to P's Application Page 4 of 7 Rosemary C Crouse 5.-d 1 2 u.s 2,D N P4 • (Address) i7. 4'7 7/7 —2 7,--4.5-y(Phone) CITIBANK, N. A. Plaintiff, vs. ROSEMARY C CROUSE Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 2012-2237 CIVIL TERM AH 1DAVIT IN SUPPORT OF RESPONSE TO PLAINTIFF'S APPLICATION TO CONFIRM ARBITRATION AWARD AFFIDAVIT IN SUPPORT OF DEFENDANT'S RESPONSE TO PLAINTIFF'S APPLICATION TO CONFIRM ARBITRATION AWARD I, Rosemary C Crouse, do hereby solemnly affirm and state as follows: 1. I am an individual above 18 years of age and competent to be sworn in this affidavit. 2. I am the Defendant in the above captioned proceedings. 3. I submit this affidavit in support of my Response to Plaintiff's Application to Confirm Arbitration Award. 4. By agreeing to the condition - a final and binding award is subject to judicial review and enforcement as provided by the FAA - in the arbitration clause in the agreement between Citibank, N.A. and me, our intent was to get the judicial review and enforcement of the 2012-2237 Rosemary C Crouse — Response to P's Application Page 5 of 7 arbitration award by the United States District Court in and for the district wherein the award was made. Therefore, the original jurisdiction to confirm the arbitration award is with the United States District Court. Respectfully submitted this the /1 day of July, 2014 2012-2237 Signature of Defend osem C ou Rosemary C Crouse — Response to P's Application Page 6 of 7 CERTIFICATE OF SERVICE A copy of this Response to Plaintiff's Application to confirm arbitration award was served upon Plaintiff's attorney at the following address: Syretta J. Martin Blatt, Hasenmiller, Leibsker & Moore LLC, 1835 Market Street, Suite 501, Philadelphia, PA 19103 By ordinary U. S. Mail, this // � day of July, 2014. 2012-2237 Rosemary C Crouse — Response to P's Application Page 7 of 7 Citibank,N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC VS. Rosemary C. Crouse Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 2012-2237 CIVIL TERM r5 r7 - ORDER CONFIRMING ARBITRATION AWARD AND NOW this / y. day of 2014, upon consideration of Citibank, N.A.'s Petition to Confirm Arbitration Award, any response thereto and good cause appearing therefor, it is hereby ORDERED AND DECREED that the award entered by the panel of the arbitrators in the above captioned matter is hereby confirmed in all respects. Judgment is entered in favor of Plaintiff, Citibank, NA and against Defendant Rosemary C. Crouse in the amount of $28682.05 plus the costs of filing and litigating this state court action action and confirming the Award. Judge Blatt, Hasenmiller, Leibsker & Moore, LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff CITIBANK, N.A. c//o Blatt, Hasenmiller, Leibsker & Moore, LLC VS. ROSEMARY C CROUSE Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION c� r 2012-2237 CIVIL TERM-, c-) (7) N .-c PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT per the order dated July 14, 2014 in favor of the Plaintiff, CITIBANK, N.A., and against the Defendant, ROSEMARY C. CROUSE, in the amount of $25,843.30 plus court costs. BLATT, HASENMILLER, LEIBSKER & MO 0'/ LLC Bv: 2662644 Syretta Martin, OPui 611, ,)pA -. ro (Me . .1 Citibank,N.A. do Blatt, Hasenmiller, Leibsker & Moore, LLC VS. Rosemary C. Crouse Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 2012-2237 CIVIL TERM r— r (:) ; ORDER CONFIRMING ARBITRATION AWARD AND NOW this Atli.- day of 2014, upon consideration of Citibank, N.A.'s Petition to Confirm Arbitration Award, any response thereto and good cause appearing therefor, it is hereby ORDERED AND DECREED that the award entered by the panel of the arbitrators in the above captioned matter is hereby confirmed in all respects. Judgment is entered in favor of Plaintiff, Citibank, NA and against Defendant Rosemary C. Crouse in the amount of $28682.05 plus the costs of filing and litigating this state court action action and confirming the Award. Judge if 16,1.4.zs..s.„)a RECEIVED JUL 2' 1014 CITIBANK, N.A. vs. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 12-2237 CIVIL TERM TO: ROSEMARY C CROUSE NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: By: PROTHON•TARY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 2662644 PPTNDJNI (05/13/2014) I 11 11111 111111 1111 11 1 11 III 111 111 11111 11111 11111 11111 11111 11111 1111 111 11 101 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. ROSEMARY C CROUSE 350 MEADOWS RD NEWVILLE PA 17241-8733 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 12-2237 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE I, attorney for Plaintiff, states: 1. That the Defendant(s) is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; 2. The statement that Defendant(s) is not on active military service is based upon Defendant(s) Military Status Report pursuant to 50 U.S.0 App. Section 521, 525 which was obtained from Plaintiff's undersigned counsel's firms search of the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scra/scraHome.do). See Defendant(s) Military Status Report attached hereto. 3. That the Defendant(s) ROSEMARY C CROUSE is (are) older than eighteen (18) years of age. 4. That the employment status of the Defendant(s), ROSEMARY C CROUSE is (are) unknown. 5. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. 2662644 P PTJ CAM I (07/16/2014) I111111111111 111111IIII III 111111 11111 11111 11111 11111 11111 11111 11111 IIII IIII I affirm under penalties of perjury that the foregoing representations are true and correct. Dated: SUBSCRIBED AND SWORN Before me this 01-0 day of Aijust , 20_ c• By: GateIQu/ Ndtary Public By: BLATT, HASENMILLER, - & MOORE, LLC Syretta Martin, .q. PA Bar #309370 Frank Janello,-Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 COMMA ACTH OF PENNSYLVANIA NOTARIAL SEAL MATTHEW MA,iESKI, Notary Public City of Philatlniphia, Phila, County My Conirrr'3;ci Expires June 27, 2018 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Department of Defense Manpower Data Center Status Repoe Pursuant to Servicemembers Civil Relief Act Last Name: CROUSE First Name: ROSEMARY Middle Name: Active Duty Status As Of: Aug -20-2014 Results as of : Aug -20-2014 05:09:16 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA •. -_ .. ... No- NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA . - NA .. . '. ,7 . _ .. 'No -. . NA This response reflects where the individual left active duty status withln'367 days preceding the Active Duty Status Date 4 r . The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA •No . NA This response reflects whether the individual of hisiher unit has received early notificatiohto report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOM, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 4CREX2A93067870