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Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire ID. NO. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
CITIBANK, N.A.
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LLOYD GETTYS : NO. ?3
1530 Leigh Drive
Boiling Springs PA 17007
Defendant CIVIL ACTION -LAW
Complaint - Notice
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to
the claim set forth against you. You are warned that if you fail to do so, the case may proceed without
you and a judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERENCE AND INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street 3
Carlisle, PA 17013 /
Telephone No. 717-249-3166 or 800-990-9108
C-48268 / 304 C'#' ?? 2 Z
Complaint
1. Plaintiff is CITIBANK, N.A. with place of business located at 701 East 60th Street
BURTON NEIL, & ASSOCIATES, P.C.
Yale D. Weinstein, Esquire, Id. No. 89678
Brit J. Suttell, Esquire, Id. No. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
LLOYD GETTYS
1530 Leigh Drive
Boiling Springs PA 17007
Defendant CIVIL ACTION -LAW
North, Sioux Falls, South Dakota.
2. Defendant is Lloyd Gettys who resides 1530 Leigh Drive, Boiling Springs,
Cumberland County, Pennsylvania.
3. Plaintiff is a national banking association, engaged in various types of banking
business including consumer lending through the issuance of credit cards.
4. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to
Citibank (South Dakota), N.A., by means of a credit card account (hereafter the Account) with
account number ending in 6613.
5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011.
6. Accurate records of all debits and credits to the Account were maintained by plaintiff.
7. Defendant was provided with monthly statements for the Account including the billing
statement attached hereto as Exhibit A (redacted to remove confidential information). The
monthly statements accurately stated the previous balance and the debits and credits to the
Account for the prior billing period.
8. Defendant had for many months after receipt of a billing statement made payment on
the Account or retained the statement without payment.
9. Defendant retained the Exhibit A statement without making payment by the stated due
date.
10. Defendant's assent to the Account balance set forth in the Exhibit A statement is
manifested through the prior conduct of defendant either making payment on the Account or
retaining the statement without payment, after receipt of the monthly billing statements.
11. As a result of said assent, an account stated for the sum of $3,132.55 exists which
sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent
to the date of Exhibit A.
Wherefore, plaintiff demands judgment against defendant for the sum of $3,132.55, and
the costs of this action.
Burton ei & Associates, P.C.
By: ale D. Weinstein, Esquire
1By: Brit J. Suttell, Esquire
In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector.
C-48268 / 205
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//?????? Customer Service:
V traciorsupplYPer;;'atal.aocarfMortine?com
® Account Inquiries:
t-888-316-8480
Account Statement
Said Notke of Mlling Errors and Ctgtaner Sella Inquiries to:
TRACTOR SUPPLY CREDIT PLAN
PO BOX 653054, DALLAS TX 75265-3054
Summa of Account Activity
Previous Balance $3,034.20
Payments 0.00
Other Credits 0.00
Purchases +$0.00
Cash Advances +$0.00
Fees Charged +$35.00
Interest Charged +$63.35
New Balance
Past Due Amount $3,132.55
$454.00
Credit Limit 0.00
Available Credit 0.00
Statement Closin Date 11112/2010
Next Statement Closin Date 12/1412010
Days in Billing Cycle 29
Mailed payinenls mual Ixz rewiredyme by 5:00 PM at the
Payment Information addreea for aymar>is by the pant due dais.
New Balance $3,132.55
Minimum Payment Due $584.00
Payment Due Date December 10, 2010
Late Payment Warning: If we do not receive your minimum payment by the
date listed above, you may have to pay a late fee up to $35.00.
Minimum Payment Warning: If you make only the minimum payment each
period, you will pay more in interest and it will take you longer to pay off your
balance. For example:
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Only the minimum payment 21 years $8,060
$126 3 years $4,543
(Savings=$3,517)
If you would like Information about credit counseling services, cat 1-877-337-0188.
If you just need a great stocking stuffier idea, the perfect solution might well be the Tractor Supply Gift Card. TSC Gift Cards are available in
denominations of $25, $50, and $100 online. They are also available in-store at all of our more than 800 locations nationwide in various
denominations. Gift cards are designed to suit every individual, budget and taste.
Don't delay, call now. There are programs available to assist you to temporarily reduce your monthly payment and or interest charge and get you back on
track. We are available to provide assistance. Please contact us at 1-888-316-8480.
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4Health formulas. Tractor Supply now offers 4 new dog and cat formulas, including Lamb and Rice wet dog food,
Chicken and Rice wet dog food, All Life Stages Adult Cat and Kitten dry food & Indoor Cat Adult dry food. Come see
why 4Health is the best choice for your pet's health. To learn more about the healthy benefits of 4Health and the
great savings it offers visit: www.4HealthPetFood.com or ask a Team Member.
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account Is Issued by Citibank (South Dakota), N.A.
-----------------------------------------------------------------------------------------------------------------------------
® (?QT Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. +
TIMPTIUMN Make Checks Payable to:
V? TRACTOR SUPPLY CREDIT PLAN
t Past Due Amount is included in the Minimum Payment Due.
r s V Payment Due Date New Balance Past Due Amount r Minimum Payment Due Amount Enclosed
r t° December 10, 2010 $3,132.55 $454.00 $584,00 $
SAVE STAMPS TIME... AND TREES! V1stt Account Online and register now for Online 8111 Pay,
_ ' Paperless Statements and More.
6613031325500073000058400106
KBAVTYS 2 11112/10 7873 8
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I??III?I?Inllrlltll?lll?ll'Ir?l?llrl[Jill 11111111111111111111111
00
w LLOYD GETTYS
1530 LEIGH DR
BOILING SPRINGS, PA 17007
Print address changes above in blue or black ink.
TRACTOR SUPPLY CREDIT PLAN
PROCESSING CENTER
DES MOINES IA 503640001
11111111111111111[11111111-11.I'll 111111111111111111111111111111
EXHIBITA.
Information About Your Account.
How to Avoid Paying Interest on Purchases. Your payment due date is at least 25 days after
the close of each billing cycle. We will not charge you any interest on purchases if you pay your
New Balance by the payment due date each month. this is called a grace period on purchases. If
you do not pay the New Balance in full by the payment due date, you will not get a grace period
on purchases until you pay the New Balance in ful! for Iwo billing cycles in a row. We will begin
charging interest on cash advarxes (if available on your account) on the transaction date.
If you have a balance subject to a deferred interest or 0% APR promotion and that promotion
does not expire before the payment due date, that balance (the "excluded promotional balance")
is excluded from the amount you must pay in full to get a grace period, However, you must still
pay any separately required payment on the excluded promotional balance. In billing cycles in
which payments are allocated to deferred interest balances first. the deferred interest balance
will be reduced before any other balance on the account. However, you will continue to get a
grace period on purchases so long as you pay the New Balance less any excluded promotional
balances in full by the payment due date each billing cycle. We may refer to deferred interest
promotia15 as No Interest or No Monthly Interest promotions.
In addition, certain promotional offers may take away the grace period on purchases. Other
promotional offers not described above may also allow you to have a grace period on purchases
without haying to pay all or a portion of the promotional balance by the payment due date. Il
either is the case, the promotional offer will describe what happens.
How We Calculate Your Balance Subject to Interest Rate. For each balance, the letter
following the Annual Percentage Rate in the Interest Charge Ca culation section on the front of
the statement indicates the method we use to calculate interest charges. For Methods B and E,
we use an average daily balance method (including current transactions) to calculate interest
charges. For Methods C, D and M, we use a daily balance method (including current transactions)
to calculate interest charges. To find out more information about the balance computation
method that applies to your account and how the resulting interest charges were determined,
contact us at the Account Inquiries number on the front.
Credit Reporting Disputes. If you think we reported inaccurate information to a credit bureau
write us at the Customer Service address shown on the front
Report a Lost or Stolen Card Immediately. Call the Account Inquiries number shown on the
front.
What To Do If You Think You Find a Mistake on Your Statement
If VOL think there is an error on your statement, write to us at the Billing Errors address shown
on the front.
In your letter, give us the following information:
Account information: Your name and account number.
Dollar amount: The dollar amount of the suspected error.
Description of Problem: If you think there is an error on your bill, describe what you believe is
wrong and why you believe it is a mistake.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing. You may call us, but if you do we are not
required to investigate any potential errors and you may have to pay the amount in question.
White we investigate whether or not there has been an error, the following are true:
We cannot try to collect the amount in question, or report you as delinquent on that amount.
the charge in question may remain on your statement, and we may continue to charge you
interest on that amount. But if we determine that we made a mistake, you will not have to pay
the amount in question or any interest or other fees related to that amount.
While you do not have to pay the amount in question, you are responsible for the remainder of
your balance.
We can apply any unpaid amount against your credit limit.
Your Rights if You Are Dissatisfied With Your Credit Card Purchases
If you are dissatisfied with the goods or services that you have purchased with your credit card,
and you have tried in good faith to correct the problem with the merchant, you may have the
right not to pay the remaining amount due on the purchase.
To use this right, all of the following must be true:
1. The purchase must have been made in your home state or within 100 miles of your current
mailing address, and the purchase price must have been more than $50. (Note: Neither of
these are necessary it your purchase was based on an advertisement we mailed to you, or if
we own the company that sold you the goods or services.)
2. You must have used your credit card for the purchase. Purchases made with cash advances
from an ATM or with a check that accesses your credit card account do not qualify.
3. You must not yet have fully paid for the purchase.
If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in
writing at the Billinq Errors address shown on the front.
While we investigate, the same rules apply to the disputed amount as discussed above. After we
finish our investigation, we will tell you our decision. At that point, if we think you owe ar
amount and you do not pay we may report you as delinquent
Important Payment Instructions.
Crediting Payments. If we receive your payment in proper form at our processing lacility by 5 p.m.
local time there, it will be credited as of that day. A payment received there in proper term after that
time will be credited as of the next day. Allow 5 to 7 days for payments by regular mail to reach us.
There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form or
is not sent to the correct address. The correct address for regular mail is the address on the front of
the payment coupon. A payment made in-store is not sent to the correct address. The correct
address for currier or express mail is the Express Payments Address shown below.
Proper Form. For a payment sent by mail or courier to be in proper form, you must:
Enclose a valid check or money order. No cash. gift cards. or foreign currency please.
Include your name and account number on the front of your check or money order.
If you send an eligible check with this payment coupon, you authorize us to complete your
payment by electronic debit. If we do, the checking account will be debited in the amount
on the check. We may do this as soon as the day we receive the check. Also, the check
will be destroyed.
Copy Fee. We charge $5 for each copy of a billing statement that dates back 3 months or more.
We add the fee to the regular purchase balance. We waive the fee if your request for the copy
relates to a billing error or disputed purchase.
Payment Options Other Than Regular Mail.
Online Payments. Visit the web address on the front and sign up for online payments.
Enrollment may take a few days. If we receive your request to make an online payment by 5 p.m.
Eastern time, we will credit your payment as of that day. If we receive your request to make an
online payment after that time, we will credit your payment as of the next day. For security
reasons, VOL may be unable to pay your entire New Balance with your first online payment
Pay by Phone Service. You may use this service any time to make a payment by phone. You
will be charged 514.95 if a representative of ours helps expedite your payment Call by 5 pm.
Eastern 'Lime to have your payment credited as of that day. If you call after that time, your
payment will be credited as of the next day. We may process your payment electronically after
we verify your identity.
Express Payments. You can sent payment by courier or express mail to the Express Payments
Address. This address is: Customer Service Center, Dept. CCS 911, 4740 121st Street Urbandale, IA
50323. Payment must be received in proper form at the proper address by 5 p.m. Central time
to be credited as of that day. All payments received in proper form at the proper address after
that time will be credited as of the next day.
RPLG 10/10
700508 X E 09/01/01 24 01 000 97 T358 07/15/10 B P 4 5 9184 0575 0001 RPLG 10PO
Page 2of4
Account: **** ** * **"' 6,613
TRANSACTIONS
Trans Date Description
Reference #
Amount
FEES
11/10 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD $ 35.00
INTEREST CHARGED
11/12 Interest Charge on Purdiases $ 63.35
TOTAL INTEREST FOR THIS PERIOD $ 63.35
r. t .
Total Fees Charged in 2010 $134.00
Total Interest Charged in 2010 $601.51
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-SANTA STARTS AT -
TRACTOR SUPPLY
____________------ ________---- ____
At -tractor Supply, we. have a unique assortment of toys and gifts especially selected
and designed with you and the. kids in mind.. From a.john Deere ride-on pedal
tractor to an ERTLdie-cast General Lee, Farmopoly board game to plush pigs and
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when we i.ntrtxl.uce new toys and bring back "out here" classics. Get your shopping
started early for the best selection'
10TWURM
suffu CO.
INTEREST CHARGE CALCULATION
PVRCHASES Your Annual Percentage Rate (APR) is the annual interest rate oWnour acrount.
i v.
Standard 25.990/6 M $3,068.25 $63.35
CASH ADVANCES
Standard 29.95% M $0.00 $0.0D
-COOL CLOTHES FOR -
COOL WEATHER!
---------------------------------- __
Whether working hard or playing hard, we carry the clothing that fits you and your
lifestyle. From boots to jeans, hats to coveralls, jackets and overalls, and everything
in-between, Tractor Supply carries a wide selection of day wear and workwear from
Carhartt, C.C. Schmidt. Tustin, Wolverine. &- many more.
Shop TractorSupplycom 24 hours a day/7 days a week, or ask a team member about
our special order catalogs for an expanded selection of products, including additional
sizes, colors and styles.
®SUMECO.
Page 3 of 4
Account: **"* '*** *"** 6613
It's amazing how much brighter the season can be
when your past due amount is behind you.
Taking care of your past due amount now can help you enjoy the season. Bringing your
account current helps you avoid future late fees.
Having an up-to-date account will help brighten your season, So call us today. Our trained
Account Specialists will help you explore your payment options,
Call today to see what payment options
may be available to you. 1-866-676-5204
Page 4of4
Verification
I, Lisa BIUMW , am employed by Citibank, N.A. (hereafter Citibank), which
is successor in interest to Citibank (South Dakota), N.A. This includes accounts previously
owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I
am authorized to make this verification on behalf of Citibank. The statements of facts set forth in
the Complaint are true and correct upon my information and belief and are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities.
V
Signature
C-48268
Lloyd Gettys
Account number ending 6613
1027
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson - , ,-
Sheriff t - 0 ° t t
Jody S Smith
Chief Deputy ?D 12 MAY -I PM 2: 4 l
Richard W Stewart :UMBERLAND COUNT,
Solicitor PENNSYLVANIA
Citibank, NA
Case Number
vs.
Lloyd Gettys 2012-2373
SHERIFF'S RETURN OF SERVICE
04/19/2012 07:18 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
19, 2012 at 1918 hours, he served a true copy of the within Complaint and N i , upon the within named
defendant, to wit: Lloyd Gettys, by making known unto Stephanie Gett s, W e Defendant at 1530
Leidigh Drive, Boiling Springs, Cumberland County, Pennsylvania 17 cont nts and at the same time
handing to her personally the said true and correct copy of the same.
,WN HARRISON, DEPUTY
SHERIFF COST: $34.00
April 26, 2012
SO ANSWERS,
RONKfY R ANDERSON, SHERIFF
CJ 1911 `?J l •. J:^:i
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Y 17 FTI? 2:
PEIMSYLVAHIA'
Burton Neil & Associates, P.C.
By: Yale D. Weinstein, Esquire ID. NO. 89678
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attornev for Plaintiff
CITIBANK, N.A.
Plaintiff
V.
LLOYD GETTYS
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 12-2373-CIVIL TERM
CIVIL ACTION - LAW
Praecipe to Settle, End, & Discontinue
Mark the above matter Settled, Ended and Discontinued.
Burton
By:
ale
The law firm of Burton Neil & Associates is a debt collector.
P.C.
1Ve' stein, Esquire
for ff
C-48268 / 318