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Home My WebLink About12-3270IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE, LLC No: Plaintiff r vs. CIVIL ACTION - LAW , JENNIFER APA -, Defendant(s) 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 an 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 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 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. CUMBERLAND COUNTY - COURT ADMINISTRATOR 32 S BEDFORD ST. CARLSILE PA 17013 Telephone 717-249-3166 Q,?? vlu?'ISpd a? ck?a?s?s?py p? a ? sUI LP PA-0 10 1 File No.: 11-31975 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE, LLC No: Plaintiff vs. I CIVIL ACTION - LAW JENNIFER APA Defendant(s) AVISO PARA DEFENDER USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defenderse de ]as demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demands y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted fall de tomar accion como se describe anteriormente, el caso pude proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad au otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY - COURT ADMINISTRATOR 32 S BEDFORD ST. CARLSILE PA 17013 Telephone 717-249-3166 PA 0101 File No.: 11-31975 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE, LLC No: 28405 VAN DYKE WARREN, MI 48093 Plaintiff CIVIL ACTION - LAW vs. JENNIFER APA Defendant(s) COMPLA! T AND NOW, comes Plaintiff, by and through its attorneys, FULTON, FRIEDMAN & GULLACE, LLP, and files this Complaint and in support avers as follows: 1. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all rights, title and interest to Defendant's CITIBANK account XXXXXXXXXXXX- 6414 (ASSET ACCEPTANCE, LLC Number 11-2675268) (hereinafter "the account"). 2. Upon information and belief, Defendant(s), JENNIFER APA, has a last known address(es) of: 131 LISBURN RD, MECHANICSBURG, PA 170555540. 3. Upon information and belief, the account is based on a written credit agreement entered into between Defendant and the original grantor; as provided to Plaintiff, the material terms of the agreement applicable to accounts issued by CITIBANK are attached hereto. 4. Upon information and belief, Defendant(s) used or authorized the use of the account to obtain loans from the original credit grantor for the purpose of obtaining goods, and/or services and/or cash advances. 5. Defendant(s) failed to make full payment of the amount owed on the account. 6. Upon information and belief, the last payment posted to the account on January 16, 2009. 7. The account shows that the Defendant(s) owe(s) a balance of $13,937.99 plus interest which has accrued from the date of assignment at a rate of 6.00 % per year, the amount of interest which has accrued is $732.42. PA 0100 File No.: 11-31975 Client Acct No.: 11-2675268 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $14,670.41, plus costs of this action and any other relief this Court deems just and reasonable. DAVID R. GALLOWAY 87326 FULTON, FRIEDMIk 130B GETTYSBUR MECHANIC SBURG. 1-877-386-5383 Attorneys for Plaintiff J & GULLACE, LLP PIKE PA 17055 PA 0100 File No.: 11-31975 Client Acct No.: 11-2675268 VERIFICATION I verify that the facts set forth on this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. Because of my title, I am authorized to make this verification on behalf of Plaintiff. Date: b g 1 0-- By CHRISTINE NIEMAN Print Name C w?,GvY ? Signature REPRESENTATIVE Title with Plaintiff PA 0100 File No.: 11-31975 Client Acct No.: 1 1-267 5268 EXHIBIT A PA 0]00 File No.: I1-31975 Client Acct No.: 11-2675268 CITIBANK CARD AGREEMENT This Agreement and the folder containing the card are your CitibanK Card Agreement. The folder contains important ;-count information, including the arnual percentage rrie and ,he ;mount or any membership fee ?lease -cad :rc :Keep 'he :older and :his Agreement for your records. To simplify the rest of this Agreement for you, the following definitions Ndl ioniv The words you, your. and yours mean the person responsible for this ement. 'o whom :ve direct the billing statement. The word card means one or more cards which we have issued with your account number The words ;ve, us. and our mean Citibank (South Ctakotai, N.A. The words Citibank checks mean one or more checks that we may provide to access your Citibank .ard account. This agreements binding on you unless you canoe, lour account within 30 days after receiving the card and you have not ;ec )r authorized use of your account. Using Your Account and Your Credit Line: The card must be signed to be used. Your initial credit line appears on the foider containing the card. A portion of your credit line. called the cash advance limit, is available for cash advances. At our discretion and at any time, we may change your credit line or cash advance limit. We will notify you if ve do. either by mad or through a billing statement sent either before or after the change takes effect. You may request a change to your credit line or cash advance limit by contacting Customer Service by telephone or mail. The full amount f your -,edit ine is available to buy or lease goods ;r services wherever the card is honored. Your cash advance limit is available for cash through any bank or automated teller machine that accepts the card or by using Citibank checks. The total amount charged on your account, including pur- chases, cash advances, finance charges, fees, or other charges. must always remain below your credit line. However. if that total amount exceeds your credit line you must still pay us. Additional Cards: You may request additional cards on your account for yourself or others and you may permit another person to have access to the card or account number. However, if you do, you must pay us for all charges made by those persons, including charges for ,vhich you may not have intended to be responsible. You must notify us to revoke permission for any person you previously authorized to use your account. If you tell us to revoke another person's use of your account, we may close the account and issue a new card or cards with a different account number. You are responsible for the use of each card issued on your account according to the terms of this Agreement. Membership Fee: The folder containing the card indicates whether your account is subject to a membership fee. If it is, the fee is added to the purchase balance and is non- refundable unless you notify us to cancel your account within 30 days from the mailing date of the billing statement on which the fee is billed. Billing: Your billing statement shows the balance, any finance charges, fees, the mini- mum payment, and the payment due date. It also shows your current credit line and cash advance limit: an itemized list of current charges, Citibank t, 4 l- ?y Y _3 checks, payments arc. credits: a summary showing separately the ?ur:base and cash advance balances, and finance charges on each balance: and other i important information. It your account becomes delinquent, we can. in our sole liscretion, stop sending you billing statements it ,vp deem your acro!,rt inrri- ectibla, or it we institute delinquency collection proceeding; by sencln ; ; 'a an wtside collection agency or attorney For collection You must notify us of a change in ,our address by ;ontacbng CustcTe, Service by telephone or mail. We viil ma l :r deiv/,?r'he r l'.inq, only one mailing address. How We Determine the Balance: The :otal outstanding balance (the amount you owe usi appears as -re ''le:i 3aiarce' on the billing staterrert. To determine the i\lew Balance..ve begin ! dith the outstanding balance on jour account at the beginning of -ae i ;iVino /:. Ia?d'h°, :'irl!S Sal? ^? ^r a!I!;'.r ,.^:f6 'n' = .. ;has-'s and cash advances and suotract an payments ano reams :-a; s- receive. We then ado :he appropriate finance charges and fees ar. -are )h-r applicable adjustments. Annual Percentage Rates for Purchases and Cash ; Advances: Your annual percentage rates and the corresponding daily periodic rates appear on the folder containing the card. A daily periodic rate is the applicable annual percentage rate divided by 365. Whether or not an annual percentage rate is variable is indicated on the folder containing the card. Variable Annual Percentage Rates for Purchases and Cash Advances: it your account has a variable annual percentage rate. we will calculate the rate by adding the fixed percentage amount that appears on the folder containing the card, to the ITS. Prime Rate published in The Wall Street Journal on 'he third luesday or March. June, September. and Decemoer of each year if :he third Tuesday is a holiday. eve will use the Prime Rate published the next day. It more than one Prime Rate is published. we may choose the highest rate If The t Wait Street Journal ceases publication or to publish the Prime Rate we -ray use the Prime Rate published in any other newspaper of general circulation, or we may substitute a similar reference rate at our sole discretion. Any increase or decrease in a variable annual percentage rate takes effect on the first day of the billing period directly following the month in which we calcu- late the rate. Each time a variable annual percentage rate changes, we will apply it to any existing balances, subject to any promotional rate offer that may ? apply. The annual percentage rate in effect and any subsequent changes to it t will appear on the billing statement. An increase in the variable annual percent- f age rate means you will pay a higher finance charge and perhaps a higher mini- mum payment. If you are in default under any Citibank Card Agreement because you failed to make a payment to us or any other creditor when due, because you exceeded your credit limit, or because you made a payment to us that was not honored by your bank, we may immediately increase the ANNUAL PERCENTAGE RATE (including any promotional rate) on all purchases and cash advances to a higher variable rate of up to 12.9% plus the Prime Rate as determined above. Factors considered in determining this higher rate may include the length of time the account has been open, the existence, seriousness, and timing of past Citibank Card Agreement defaults, and other indications of account usage and performance. This higher rate will not be lower than 19.8% unless we elect a lower rate. Your account may again become eligible for a lower annual percent- age rate on new purchases, new cash advances, or both after you have met the terms of this and any other Citibank Card Agreement for six months lour existing purchase and cash advance balances will remain subject to the higher rate until they are paid in full. Promotional Rate Offers: At our discretion, we may offer you a promotional annual percentage rate for ail or a part of the purchase andior cash advance balances. Th i aenod it 'ime 'or hich the promotional rate applies may oe :imited. Any prnmctlon:a corresponding periodic rates. and the period of time runng 'Nnicn t ,s :n - ; will appear on the folder containing the card. We may also offer you a t promotional annual percentage rate to enccurage specific transactirns. >Lcn a i. transferring balances from accounts you have with other credit card issuer; Any promotional rate offer will be subject to the terms of the offer and this Agreement. Finance Charges: Finance charges will begin to accrue from the date of the advance for cash advances and from the date of the transaction for purchases and continue to accrue until payment in full is credited to your account. However, it you paid the total New Balance listed on the last billing statement by the payment Cue date on that statement and you did not transfer a balance from another account during that billing period. you will have until the payment due date an your current statement to pay your total New Balance to avoid imposition of finance charges on purchases. In certain cases, this same grace period for purchases may apply even if you have transferred a balance from another account during the billing period. If there is io such ;race period for ourchases. the balance transfer offer vill so :noicrte. 'rle will calculate finance charges as follows M We figure a portion of she finance charge on your account by rnuitioly ng 'he daily balance on purchases and the daily oaiance on cash 3avances dy the applicable daily periodic rate and adding together any such finance charges for purchases and for cash advances for each day in the billing period. 0 For finance charge calculation purposes. the billing period begins on the day after the StatemenVC losing Date of the previous billing period and varies with the number of days In the billing period. It includes the Statement/Closing Date of the current billing period. M To calculate the daily balances. we take the beginning balance'cr pur'-chases and the beginning balance for cash advances each day, add any new transac- tions and fees and any finance charge an the previous day's balance, subtract any payments or credits, and make other adjustments. Unless we elect to use a later date, we add a new purchase to the purchase balance as of the date of the purchase and a new cash advance to the cash advance balance on the date of.the advance. A credit balance is treated as a balance of zero. ¦ The "balances subject to finance charge' for purchases and for cash advances on the billing statement are each the average of the respective daily balances during the billing period. If you multiply these figures by the number of days in the billing period and by the applicable daily periodic rates, the results will be the finance charges assessed on purchases or cash advances. except for minor variations caused by rounding. M If the balance for purchases or cash advances is subject to more than one rate (for example, because of purchases or cash advances made during a pro- motional rate offer), we will separately calculate the balance subject to finance r r charge and the resulting finance charge in the same manner as described r: ,'•;,; above. Cash Advances and Tran `ou hav saction fey e ootained a Cash machine (ATP,1) through a Citibank c,fhec financial institution: check. lhroulthro a :unr; r ; a„ aurCmate d teller n bankln order, traveler's the kalottery payment: make vrrP g homlc ,,r. g• Or through engage in another simicket , r / 'rCaet bettinr, or CaSlno hto arrwrP .? monay honaf FINANCE CHARGE tar Tans r'af '''M'far''"^ r ]C n: ' r 7r r r' Ir ' n yan t h 1Y r.lurP 3 surrhar , b7llnr,? c .. punt 3"' transacnon fee m 9e :hat the AT:b'1 owner m may cause the P r say ash advance . on 'ahirh the rash advanre r^annual The pPrCPntage _,L, gash 3dvanr,= •1('P r rite ./ ppears t0 ?,rr?Pd the _•,rrg statement Minimum Frn "'nnuai percent- if the finance ,;h_ once Charge; rates ,;s;ass 3 'tmi lr rates for purchases arc ,ash a '. 1o^'' 0 e add *hp 3m ... • unr FINANCE CHARGE d?1nCP; ]non Credit C,.,: cr .::1sn Balance: 3cvance bal- rou may not maintain assigned credit li a credit balance on Your our account n ex, mit. We Mil returnt° , amount has ,our be z` 3 .r • a refund of a en on your acrount or, er than credit im°unt -- o credit balance at am g n ;t7ree :f ;hc credit balance Y time. We may montfrs You Tay r by the amount of new Y 'educe the amount of anyeSr Security interest f charges billed b your account Thr, folder containin or Secured Accounts: it is. g the card indicates if You have given us a Your account i account to secure r secuh P ty interest in a c S a secured account. 3 the certificate of payment of your account?tificate of dPprs:; ]r a if sa, deposit or savor Y°U mlthdra.v ,ings Charges Ma 9s account, we "V111 close /our funds from t tar de in Foreign Cu Your card accoun if a ''• ge is InrurrP rrencies: MasterCard d in .1 foreign currency. char international. depending on which card is used, : j with their operating regulations or IS, and MasterCard wilt dl convert the the transaction is conversion in et in accordance vide that the Processed. procedures Currenffy. their regulations and effect at the time rate or 9urr ency conversion rate the procedures pro- rate a overnment-mandated rate in effect rate andM Use is either Ing date. Visa increases this cdnve i one (r' wholesale market asterCard increases this non rate b day Priorto the r and MasterCard keep this increase. Sion rate by one percent. Both Vis t Y Visa or MasterCard b We Increase the conversion rate provided r .a currenc by up [o two a Y conversion rate calculated in thIS manner and cessing date ma kse in effect o ease. The posting date. y differ from the rate in effect on the transaction date or r ' the pro- *7 MIUm Amount Due: the Each month you must The first is an Pay a minimum amount that is the total of two y previous amount that is past due plus any amount ''' your credit line. The second is the in excess figures. r _ `k charges or one of the fod ; greater of the amount of of k-61 ? r ¦ The New Balance on the bign Your billed finance ,: ?i ,.? ??r '>. ?' `? ¦ $20, it the 9 statement if i ,,? # , New Balance is it is less than $20, f .: ¦ ff the New Sal at least $20 and n °r . ,? , ., :.•) `` ;? ,r • ante exceeds of greater than $960, or to the nearest dollar 5960, 1148 of the New Balance r" 19 J.T •:: ' , ;fir!; • k ,-y .` •v If -? (rounded down • ?; a `•{ a -??• N; y;?, ?}?? N ?. s , ? i ini? ;,..?.;t'? 1' :'list .n, ...Irtl?Uf;l ?;^f i;.^f ',)'J •hF' lav-,?•.. a,.. '?U pay mcr? at any time : ithout a penalty f you ;)a;! r,r? 'ndl: h? - r.- ,rum. Ne will allocate the excess amount to the purchase or rash advance bai- .irce at our discretion. The sooner you pay the New Balance. the less you .-4111 pay in finance charges. We may also 310'N you to skip 3 payment. if NP r;o we will notify you If you choose to skip a payment when offered. NP will continue to assess finance rharges. Payments: not send cash payments. We can accept ate or partial payments as :,eJ as payments 'hat reflect paid in full' .,r other restrictive ?rdome.npntS. '.I.- :osing any or our rights under 'his Agreement. There may De -) relay of :.c 'c `i'1P, lays ir. ?'edimg .] pa`/meat I It s rRcaived at an aicVss athP,r'har '^P irawn on funds on deposit in the United ' gates ,is ng a parm:r['c' instrument. or automatic debit that will be processed and nonored by ;our bank. We reserve the right to accept payments made ;n foreign currency. :f NP do. we will charge a currency conversion fee based upon Me conversior rates existing at the time of conversion. Over-the-Credit-Line Fee: We will add a S25 fee to the purchase balance for each Nling period tha, the New Balance exceeds your credit line. Late Fee: We will add a S25 fee to the purchase balance for each billing period you `all 'o make the minimum payment by its due date. Returned Payment Fee: We will add a S25 fee to the purchase balance when a payment check or similar instrument is not honored, vvhen we must return it because it cannot be processed. or when an automatic debit is returned unpaid. At our option. we will assess this fee the first time your check or payment is not honored. even if it is honored upon resubmission. Citibank Checks: Citibank checks may be used to purchase goods and services or to obtain cash up to the amount of your available cash advance limit unless that amount will cause the balance to exceed your credit line. We will treat Citibank checks as a cash advance and charge them against your cash advance limit. Each Cibbank check must be in the form we have issued and must be used according to any instructions we give you. Citibank checks may be used only by the person whose name is printed on them. Citibank checks may not be used to pay any amount owed to us under this or any other Citibank Card Agreement. We will not certify any Citibank checks, nor will we return paid Citibank checks. Returned Citibank Check Fee: We will add a S25 fee to the cash advance balance if we decline to honor a Citibank check. We may decline to honor a Citibank check if, for example. the amount of the check would cause the balance to exceed your cash advance limit or credit line, if you are in default, if you did not comply with our instructions regarding the check, 4 your account has been closed, or if the ., . card has expired. Stop Payment Fee: to the cash advance balance when payment of a Citibank W ill dd $25 f e w a a ee check is stopped at your request. You may stop payment on a Citibank check by notifying us in writing at P.O. Box 6500, Sioux Falls, South Dakota 57117 or . . t. , `? wLa?i}. t? . • T1,J ) .?? ?•Ij???"•'fi-i??t? 1?. ??. )' ?± ; ?v.', . _ _{ ., , `? .Y • ^7 L y {fir. * hl( Y ` ` . + ' jI. 1 l l jou pus: c:,ntlrT :he ?,;il n payment order will remain in effect for six months unless renewer; n wriur; )nca :i ;harge s made thrnugh !he :use of :he card or account rum;=r : e cannot stop payment' on the charge. if there is a dispute invoiving a cnarge on your account. please refer to the section entitled 'What To Do If There S An Error In Your Bill ' Lost or Stolen Cards, Account Numbers or Citibank Checks: it any card. account number or Citibanx checx s lost or ato en or I ;n, ring someone used or may use them without your permission. nonhli ,s at nr.ce by railing the telephone number shown on the billing statement or ,he number Obtained by calling toll-free or local Directory Assistance. We may require you to provide certain information in writing to help us find out what hap- pened. Dona use the card or the Citibank checks after we ve been notified. even if they are found or returned. You may be liable for unauthorized use of . ;. ']Ci rat `or more than S50. You wont be liable for unauthorzed ,iurrhases or cash advances made after we've been notified of the loss or the however. you must identify for us the charges on the billing statement 'hat were not made by you. or someone authorized by you and `rf rr ;v?ich you received no benefit. Default: You are in default if you fail to pay the minimum payment listed on eacn billing statement when due, fail to make a payment to any other creditor Nhen due. file for bankruptcy, exceed your credit line without permission. pay by a Cneck or similar instrument that is not honored or that we must return because it cannot be processed. pay by automatic debit that is returned unpaid. or default on any other Citibank Card Agreement. If you are in default. we may close your account and demand immediate payment of the full bal- ance. If you have given us a security interest in a savings account or certificate of deposit. we may use :he deposit amount - ?ay :any arrourt you owe. Preauthorized Charges: If you are in default, if the card is lost or stolen. Of we change your account or account number for any reason, we may suspend automatic charges on rhat account to third-party vendors for insurance premiums or other goods or services. If preauthorized charges are suspended, you must contact the third- party vendor to reinstate them. You are responsible for making direct pay- ment for such charges until you reinstate automatic charges. Collection Costs: If we refer collection of your account to a lawyer who is not our salaried employee. you will have to pay our attorney's fee plus court costs or any other fees, to the extent permitted by law. If we sue to collect and you win. we will pay your reasonable legal fees and court costs. Customer Privacy: We will safeguard, according to strict standards of security and confidentiality, any information you share with us. We will limit the collection and use of any such information to the minimum we require in order to deliver you superior service, which includes advising you about our products, services, and other opportunities and to administer our business We will permit only authorized employees, who are trained in the proper handling of customer information, have access to your information. Whenever we hire other organi ? ?, >• -4 Pll? +,. . ire them to conform to our privacy Support services. we vill requ provide llow us to audit them for compliance. r Information. u standards and to a ro Of Yo tional offers from in control over the ling nd p mo We will always mainta exp We will, however. facilitate relevant marketing and p companies are no ressedlt our naeds These . ll ll t a y y y e t reputable companies that mee d to retain any of your intormation unless you have specifica It you do not want to receive these n tr?e es i - l 'll . e c Sled o numnef interest in their products or serv 'Ne namee? a dress d account number. write or call us at the m otters, sure to include e Y yo Your ear of your right to be excluded fro h f ' y remind you at least once eac will tin r g redit repor these offers. erformance under ;his Agreement to c ments on fe' It You , `. p We may report Your to make minimum pay a agencies, including your failure r on your account for others In the names 01 d s name as well as for request additional car Cfedit reports on Y j may report account :ntormab also our obtain follow up If You wish account for a credit line increas at those other people. We may the your review when we have contacted. " hone le u . 1Ve telep examp agencies we the of to know the names on the billing statement. We will try to notify you W , you an o d on us in order to g Y ess listed d r ad Process serve or by mail of any legal rohibds the notice- credit report- unless the ts to t , nity to object to i and except for reporItted share with in this Agreement to set forth nt s t i n a o Excep our accou informat out and collection agencie iven n ormation ab ing else wiIt be g proper legal authority. no affiliates, Citibank our knowledge, authorization or tibank Affiliates: t y Ci withou mation Among that f or products and services Sharing Customer In ou with ou To alert you to special otters and provide y Citibank affiliates share information about y to you ll . y are tailored specifica i r on a confidential basis. law to share any information about the rov?de to us or s are permitted by mation you p t e Citibank affilia will not be transactions or experiences with you. Other intor credit examp n shared among rties i t o o h into mot suc that we obtain from thsr that not ant you do nobly shared d you Citibank affiliates. time. Please send your us in writing ofyour instruction at an statement), along with your tif nt y - You may no ) ecurity number tc Citibank it ears on name and address (a account number and So r al Saccou anyat 07606. t e nc account yp , ude processing Center at C% 3178, South envelope ma d oes of i ed e you mail your instruction in a stamp other correspondence. nd Recording din g hone calls regar Telephone Monitoring a nd record r time to time we may mondor a rvice our From ith us to assure the quality of your account w Correcting your Credit Report: n credit reporting agertey. s ime f mation to I or We will PrOmf if you think we reported erroneous in sitement tg ht we wig contact d on the billu t l ri ac t e is g you are ? ress write us at the add r atfon shows Y , sr 3t the matter and'rf our irnestiq will reques they ~ '' + ou ' ti ll rep ? .? , ?,. . y t > t to whom we we wN te ' each credit reporting agency after out Investlgatfon, ,?. . , Y our credit red the report ry Wince you ho n b?s? e a pat Y te"hOn i. ; . in wtidng ,C agencies. Your statementt to those , .r . . Pow - :` record with them. 4 { 777i ' J Pr - A 1 1 ti ?• ?t .•- 1 b•' ` . ( 1?,J '? l ori?, ?.;rc ?7,r•, i :1 +? ? .?. .t, .J.- t r?J. Closing Your Account: Youumayremainclose your account at any time by notifying us in writing. However. yo responsible tc pay the alanca ac,?rCing to he terms of ,However. Agreement. We may close your account or suspend your account privileges or Citibank checks at any time without prior notice. We may also reissue a differ- ent card, account number, or different checks at any time.- You must return the card or the Citibank checks to us upon request. Refusal of the Card: We are not responsible if a purchase or cash advance on your accoum is not approved, either by us or by a third party. even if you have sufficient credit available. We may limit the number of purchases or cash advances 'Nhich may be approved in one day. If we detect unusual or suspicious activity on your account, we may temporarily suspend your credit privileges until we can verify the activity. We may approve purchases or cash advances which cause the balance to exceed your credit line without waiving any of our rights unCer'this Agreement. Changing this Agreement: We can change this Agreement, inclueing all fees and the annual percentage rate, at any time. However, if the change will cause a fee, rate or minimum payment to increase, we will mail you written notice at least 15 days before the beginning of the billing period in which the change becomes effective. If you do not agree to the change, you must notify us in writing within 25 days after the effective date of the change and pay us the balance. either at once or under the terms of the unchanged Agreement. Otherwise. the change in the notice is binding on you. Unless we notify you otherwise. use of the card after the effective date of the change shalt be deemed acceptance of the new terms. even if the 25 days have not expired. Enforcing this Agreement: We can delay in enforcing or fail to enforce any of our rights under this Agreement. without losing them. Assignment., We reserve the right to assign any or all of our rights and obligations under this Agreement to a third party. Applicable Law: The terms and enforcement of this Agreement shall be governed by federal law and the law of South Dakota, where we are located. For Further Information: Call us at the telephone number shown on the front of the billing statement. You can also call toll-free or local Directory Assistance to get our telephone number. Thomas W. Jones Citibank (South Dakota), N.A. President & CEO Box 6000 ID1998 Citibank (South Dakota), N.A. Sioux Falls, SD 57117 1 • L.M t` ..? 31 / rµ. `yj?•,y W ... {? 1l'+.T....? • - _ .- ?/ l 5.;-? 1. - , - A ?: ` '? J.• { ?..- .7' 4 t'•` ? '. a tit '•?' " ? 'ti _ ! t ll, .?: t ?'3, .? ! - 1 t, ' t c '? +? ?, ! • t , '?? 4 ba 7a What To Do !f There's An Error In Your Bill. # Your Billing Rights. Keep This Notice For Future Use. # This notice contains mporant information :ior,ut ; ,,:r ir;ht; jr,,, )ur . Psocr c bllltlPS under the Fair 0redit Billing Act. Notity Us in Case of Errors or Questions About Your Bill. If you think your billing statement is wrong, or if you need more information about a transac!ion on your billing statement, write to us (on a separate sheet) at the address shown on the front of your billing statement Write to us as soon as possible. We must hear from you no later'han AG f13ys of ?r „o .ant yr.'u t ." first billinrl statemPP, on :vn ch the arror !)r pr001PT 3p0°,3rP'; phnnP ,s but loinrg ;;) ,ot prascrfe your right,. In .)our letter. give us the following information: 0 Your name and account number. The dollar amount ^.f 'he suspected ?rrrr' `. ¦ Describe the error and explain. if you can, why you believe there is an error. If you need more information. describe the item you are not sure about. ¦ Please sign your letter, f If you have authorized us to pay your credit card bill automatically from your savings or checking account you can stop the payment on any amount you think is wrong. To stop the payment you must tell us at least three business days before the automatic payment is scheduled to occur. Your Rights and Our Responsibilities After We Receive Your Written Notice. 'Ne :must acknowledge error by then. Within gQ days, ve within must either correct the error or correct t whye z we believe your billing statement was correct. After we receive your letter. we cannot try to collect any amount you question, or report your account as delin- quent. We can continue to bill you for the amount you question, including f} finance charges, and we can apply any unpaid amount against your credit limit. t You do not have to pay any questioned amount while we are investigating, but t you are still obligated to pay the parts of your balance that are not in question. If we find that we made a mistake on your billing statement. you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your bill. And, we must tell you t the name and address of anyone to whom we reported your account informa- tion- We must tell anyone we report you to that the matter has been settled between us when it is finally settled. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your billing statement was correct. r t r a ? 1 a? y ?c\ l rjT /- _?f. ` MY.:w?;?•,..`i.`'w ;.a -a`, (? e...j. "? • r , r/ Ci s tT , a ` ?? ?_ , •..1 ".a?? t? ?l U IT s ?i?. M1 ' t :`?'.. 4.{.;{:'.l t 1 t -Ji Special Rule for Credit Card Purchases. It you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: You must have made the purchase in your home -state or. if not within your home state, within 100 miles of your current address: and The purchase price must have been more than S50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services ' fi .. ? .:?•`,? '. t ''?'?. _.1_ _ _'\..t.,' r:.... •.?.L'tl! ,A qF Y.?-'.C.1 ?.??. _? ;k .?)f. ??.? ? ?,F {? r1 C? ` ' ':l ^?ylYy y:?,?t Y,?z?, I,' lt`Ty71 N_¢ `Jp y7ry1+J !"'TAN, ,?C; ' 1(Y??i \;f I' `?,rt- '' <r?• ` V '{T T?,:l??`l?.?},K`\N Y y `? q4ii ':i? ?3-:?, i?t ?') GS Kt'?Irry?^?.d ' .•?F? t. ?? YAi.••y?s,???\ a.: ?., :?agiln \ . y ?..:,4.?y. 335814518049170 10/98 j, ti tom- ? Y•, 1 F ! `.?•5 !r?l.y'\ ';' ` ?' 7 tr?? yry, d? ?r ` f ?? ?.2r11 ?1 f'-'(! \ xt' ?. •? ,•,i7.? l { k?7y e i t , ?l {}l !y .rS S'?',?.f'•`? F?1 7t. ???'.? :?? Ir\ S. ?r ?,'ri?? b,', ?, ? ''!•: aMJ!lI • }\ ?•'1 IM`',7 •? ?? , ??! {?r?-?` ?,y •?t.'• f R !1 ?' ? l+.? ?t ' 1 .,?1 • ?? w•?•? : ?+ M `; + , f •\?f? ?N?? ??y? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson r 4 r 'j Sheriff 1 rI i Jody S Smith , ti"12 t j. Chief Deputy Richard W Stewart `i.! "tG L? LUN 1 Solicitor F? S Y LVA i Asset Acceptance LLC Case Number vs. Jennifer Apa 2012-3270 SHERIFF'S RETURN OF SERVICE 05/30/2012 05:34 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 30, 2012 at 1734 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer Apa, by making known unto herself personally, at 131 E. Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHEN ENDER, DEPUTY SHERIFF COST: $38.00 June 04, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shentt, Teleosott, Inc. 4 PRAECIPE FOR LISTING CASE FOR ARGUMENT 2C A 3 FEB 20 PM 1' 3" (Must be typewritten and submitted in duplicate) rfJMBBLAND COUNTY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: PENNSYLVANIA Please list the within matter for the next Argument Court. ------------------------------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (Plaintiff) VS. J (Defendant) No. Term bV l 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): 2. Identify counsel who will argue cases: (a) for plaintiff: L 4\c ?? tv?? ?C `Gtr i 1? VCA ?- . ?? U > > (Name d Address) c (b) for defendant: (Name and Address) 3. I will notify all parties in writing within two days that this case has been listed for argument. 4, Argument Court Date: Date: ?l ??? ?? - . g o l Signature tLY ?G1? 1 1 V", Print your name Attorney for amt???-?D da C 04 q:5 /-a 613 v V9 ?Fv) (,? ( • Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE, LLC, Plaintiff v. JENNIFER APA, Defendant TO THE PROTHONOTARY: Civil Action No. 12-3270 CIVIL CERTIFICATE OF SERVICE I hereby certify that a copy of the Praecipe to List Case for Argument was served this date by depositing same in the Post Office, first class mail, postage paid, addressed as follows: Jennifer Apa 16 Chain Saw Rd Dillsburg, PA 17019 Respectfu y sA?ed, Date: U) By: L Michael B. Volk, Esquire #88553 Fulton, Friedman & Gullace, LLP 130B Gettysburg Pike Mechanicsburg, PA 17055 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ASSET ACCEPTANCE,LLC, Plaintiff CIVIL ACTION -LAW V. No. 12-3270 CIVIL C-) JENNIFER APA, —� Defendant(s) SM -0m MCI ENTRY OF APPEARANCE cam zo MC .... c> TO THE PROTHONOTARY: v .. Kindly enter the appearance of the undersigned 7behal a P laintiff in the above- referenced matter. Michael B. Volk#88553 Fulton Friedman&Gullace,LLP 6 Kacey Ct., Ste 203 Mechanicsburg,PA 17055 (717)610-3117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ASSET ACCEPTANCE,LLC, Plaintiff CIVIL ACTION -LAW c -i V. No. 12-3270 CIVIL , rn- ro JENNIFER APA, tq' °o Defendant(s) PRAECIPE TO SETTLE.DISCONTINUE &END vc -N °..-iy, �' �Rcn TO THE PROTHONOTARY: -4 Zn Please mark the above captioned action as settled,discontinued !ed. Respectfully Su i , By: Michael B Volk#88553 Fulton Friedman&Gullace, LLP' 6 Kacey Ct., Ste 203 Mechanicsburg,PA 17055 (717)610-3117 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office, first class mail,postage prepaid, addressed as follows: Jennifer Apa 131 E Lisburn Rd Mechanicsburg,PA 17055 APR 10 2013 Date Michael B. Volk Attorney ID #88553 File No. 11-241872