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HomeMy WebLinkAbout13-0230~'~ ~ ~~ F'~~C NQ~~1 TA~~ `r 201 JAN ! 4 Pry t~ 28 CUM~E~LANp CQUNi Y ~Et~AtSYLyAh!!A Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. N0.204140 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 v. SHANA L PEERY 107 East Springville Road Boiling Springs PA 17007-9737 Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1?j • ~2~ ~V ~' 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. C-59673 / 304 LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 ~, ~~,`1 s d G ~ C~`~~ ~ S ~ C~-~-~ a 530 ~~a,~ . y BURTON NEIL & ASSOCIATES, P.C. Trenton A. Farmer, Esquire, Id. No. 209422 Brit J. Suttell, Esquire, Id. No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attomey for Plaintiff CITIBANK, N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff v. SHANA L PEERY 107 E Springville Rd Boiling Springs PA 17007-9737 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CNIL ACTION -LAW Complaint 1. Plaintiff is Citibank, N.A. with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Shana L Peery who resides at 107 E Springville Rd, 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 Sears credit card account (hereafter the Account) with account number ending in 5650. 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 $6,587.68 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 $6,587.68, and the costs of this action. B on s ciates, P.C. B rr ton A. F er, Esquire ~' By: Brit J. Suttell, Esquire In making this communication, we advise Burton Neil & Associates, P.C. is a debt collector. C-59673 / 205 Account Statement sears Sears Premier Card Customer Service: 6 searscard.com ® Account Inquiries: 1-aoo-s17-7700 Send Notice of &IGrg Errors and Customer Service Inquiries to: SEARS CREDIT CARDS D s7t t 7-s2a3 oux al s, PO ox 6283 '... ...... ...,.... . 'Acct>ttrrtt Nteratx~: ;r~~$p.; Credit Limit 0.00 Available Credit 0.00 Amount Over Credit Limit 987.68 Statement Closin Date 10/29/2012 Next Statement Closin Date 11/28/2012 Da s in Billin C cle 31 TRANSACTIONS Trans Date Description New Balance $6 587.68 Minimum Pa ment Due $1 724.51 Payment Due Date November 25, 2012 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. Minimum Payment Warning: If you make only the minimum payment each penoa, you wlll pay more to Interest a to n wm rand yw rvr yea w I,ay vn yvur balance. For example: ' ity~ureriG:ad~O~2ils ~'oywtfto'ffthe Ar~dyotlvrils; charm. s-usirsglhis card ba{arlcestx~vn~n tFliss,. end°yP P~t?~9~ antl eaehTrlcir~i:j+bu pay.:, ,s#At6rCl8rtt lit bout... - _. e~itriated totaj of._.. Only the mu>Iimum payment 19 years $15,666 $263 3 years $9,459 (Savings=$6, 207) t you woukl like infomratan abotrt credit counseing services, call 1-877-337-8188. Reference # Amount FEES 10/25 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD 5 35.00 INTEREST CHARGED 10/29 INTEREST CHARGE ON PURCHASES ~ 1~•~ TOTAL INTEREST FOR THIS PERIOD $ 138.04 8 SE 19 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, NA. 't' Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. T Sears Premier Card' tPast Due Amount is included in the Minimum Payment Due. ~YourAceguntNertaber' ` Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 56t5f! NOVEMBER 25, 2012 $6,587.68 $1,484.47 $1,724.51 $ SAYE STAMPS TIME... AND TREES! Usit Account Online and register note for Online Bill Pay, ~ Paperless Statements and More. 022 5650 0658768 0172451 0017000 191 OOD 7 Make Chedts Payable to: SEARS CREDIT CARDS PO BOX 183081 SHANA L PEERY COLUMBUS, OH 4321&3081 107 E SPRINGVILLE RD BOILING SPRINGS, PA 17007-9737 EXHIBIT Print address changes above in blue or blade ink. Information About Your Accourrt. How to Avoid Paying Interest on Purchases. Your payment due date is at least 25 days after~he 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 rolled 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 full for two billing cycles in a row We will begin charging interest on cash advances and balance transfers (if available on your account) on the kransaction date. If you have a balance subject to a deferred interest 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 promotion. 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 tong as you pay the New Balance less any excluded promotional balances in full by the payment due date each billing cycle. In addition, certain promotional offers may take away the grace period on purchases. Crther promotional offers not described above may also allow you to have a grace period on purchases without having to pay all or a portion of the promotional balance by the payment due date. If either is the case. the promotional offer will describe what happens. How YYe Calculate Your Balance Suitject to Interest Rate. We use a daily balance method (including current transactions) to calculate interest charges. To find out more information about the balance computation method and how the resulting interest charges were determined, contact us at the Account Inquiries number on the front. Balance Transfers. Balance transfer amounts are included in the "Purchases" line in the Summary of Account Activity (if balance transfers are available on your account). Transaction Date. The Transaction Date shown on the statement is also the Sale Date. CreAt 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 Stden Gard -nvnediately. Call the Account Inquiries number shown on the Front What To Do if You Find A Mistake On Your Statement If you think there is an error on your statement, write to us at the address for billing inquiries and correspondence shown on the front of your statement. to 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. • At least 3 business days before an automated payment is scheduled, if you want to stop payment on the amount you think is wrong. 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. What Wrll Happen After We Receive Yovr Letter When we receive your letter, we must do two things: 1. Within 30 days of receiving your letter; we must tell you that we received your letter. We will also tell you if we have already corrected the error. 2. Within 90 days of receiving your letter, we must either correct the error or explain to you why we believe the bill is correct. While we investigate whether or not there has been an error: • 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. • 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. After we finish our investigation, one of two things will happen: • If we made a mistake: You will not have to pay the amount in question or any interest or other fees related to that amount • If we do not believe there was a mistake: You will have to pay the amount in question, along with applicable interest and fees. We will send you a statement of the amount you owe and the date payment is due. We may then report you as delinquent ff you do not pay the amount we think you owe. If you receive our explanation but still believe your bill is wrong, you must write to us within 10 days telling us that you still refuse to pay. tf you do so, we cannot report you as delinquent without also reporting that you are questioning your bill. We must tell you the name of anyone to whom we reported you as delinquent, and we must let those organizations know when the matter has been settled between us. hf we do not follow all of the rules above, you do not have to pay the first $50 of the amount you question even if your bill is correct. Your Rights !f 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: t. The purchase must have been made in your home state or within 1DO miles of your current rnailinq address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if 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 alwve are met and you are still dissatisfied with the purchase, contact us in writing at the address for billing inquiries and correspondence shown on the front of your statement. While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our deciswn. At that point, if we think you owe an amount and you do not pay, we may report you as delinquent EM SMC-TGI•SCC-SCP-HIPs 07/12 Importaint Payment Instructions. Right to Prepay Your Accounk You may pay all or part of your account balance at any time However, you must pay, by the payment due date, at least the minimum payment due. Credkinq Payments. tf we receive your payment in proper form at our processing facility by S p.m. local time them it wiN be credited as of that day. A payment received there in proper form 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. The correct address for courier or express mail ;s the Express Payments Address shown below. Proper Form. for a payment sent by mail or courier to be in proper corm, you must • Enclose a va1Kf 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 eNgible check with this payment coupon, you authorize us to complete your payment by electronic debit. ff we do, the chledeinq account will be debited in the anwurrt 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 $3 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. 702388-9351-5000-0029-P-E-34X-11/01/941-P-o-Y-7-0-0-0---02/2&12-PKKB-September 28, 2012-0~V N- Payment Options Other Than Regular Mail. • In-Store Payments (Where Available}, Any payment in proper form accepted in-store will be credited as of that day. However, credit availability may be subject to verification of funds. Not all stores accept payments. Contact your local store to see if in-store payments are accepted at that location. • OnNne Payments Visft 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, you may be unable to pay your entire New Balance with your first online payment. • AutoPay Service. If you are enrolled in this service, your payment amount will be deducted automatically eacfi month on your due date from the bank account you select. • Pay by Phone Service. You may use this service any time to make a payment by phone. You will be charged $14.95 'rf a representative of ours helps expedite your payment. Call by 5 p.m. Eastern time to have your payment credited as of that day. If you call after that time, your payment will be credted as of the next day. We may process your payment electronically after we verify your identity. • F_xpress Payments. You can send payment by courier or express mail to the Express Payments Address. This address is: Payments Department,15O0 Boltonfieid Street, Columbus, OH 43228. Payment must Ue received in proper form at the proper address by 5 p.m. Eastern 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. Page 2 of 4 A~r:ntint~ ****''*** **** 5650 Total Fees Charged in 2012 $235.00 Total Interest Charged in 2012 $1,238.01 INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual ir~erest rate on your account. °[`. a#e .,. ;_ ;~ A~nciatpetce~tajef~a~~_(AiP'~t ~aru:e`~bje~fvin+est`Raie, `, `In1t'ChlaFge ,;~- PURCHASES REGULAR 25.24% D V 486.26 139.04 Variable Rate D = Dai Page 3 of 4 Account: **** **** **'`* 5650 Page 4 of 4 Verification I, Vikki 1. Koch , 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 unsworn falsification to authorities. d Signature C-59673 Shana L Peery Account number ending 5650 1031 Burton Neil&Associates,P.C. , ' r Fi' By: Trenton A. Farmer,Esquire ID.NO. 209422 a �' �;f�T # `' 1060 Andrew Drive, Suite 170 1",13 NIA ; 22 PH 2. West Chester, PA 19380 Telephone: 610-696-2120 J '; V F R L A N0 C 0 u'j T Attorney for Plaintiff l ,d o Y' CITIBANK,N.A. IN THE COUR OF ON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 13-230-CIVIL SHANA L PEERY Defendant : CIVIL ACTION-LAW Praecipe for Entry of Judgment on Stipulation To the Prothonotary: Pursuant to the authority set forth in the attached agreement between the plaintiff and defendant, enter judgment on behalf of the plaintiff, CITIBANK,N.A., and against the defendant, SHANA L PEERY, and assess damages in the sum of$6,587.68, less credits in the amount of $900.00, for a total balance of$5,687.68 plus costs. BURTON NEIL& OCIATES, P.C. B v. a Trenton A. Farmer, Esquire C,Lfl7a�j �c� Attorney for Plaintiff F--1 a$F/yl , AND NOW,this day of , 201,�,judgment is entered on behalf of the plaintiff, CITIBANK,N.A., and against the defendant, SHANA L PEERY, in the sum of$6,587.68, less credits in the amount of$900.00, for a total balance of $5,687.68 plus costs. Prothono of C YBE AND C Deputy The law firm of Burton Neil &Associates is a debt collector. C-59673 C_4 IG ill ' G . GADhA A1 �-7 1 From John VVIIis Fax:(888)551-5053 To: +1 6 1069641 1 1 Fax: +16106964111 Page 3 of 5 V3118/2013 9:04 P L Burton Neil&Associates,P.C. By: Trenton A. Farmer,Esquire ID.NO. 209422 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-230-CIVIL SHANA L PEERY Defendant : CIVIL ACTION- LAW Settlement Agreement with Stipulation for Entry of Judgment This Settlement Agreement is made by and between plaintiff CITIBANK,N.A. (hereinafter referred to as "Citibank") and defendant Shana L Peery(hereinafter referred to as "Peery"): Whereas, Citibank filed legal action against Peery seeking recovery for the balance owed on credit card account no. xxxx-xxxx-xxxx-5650(hereafter "the Account")in the sum of r $6,587.68 plus court costs in the sum of$203.75 (hereinafter"the Litigation"); and Whereas, Peery acknowledges liability on the Account to Citibank but is not able to pay the amount due in the Litigation lump sum; and Whereas, Citibank and Peery by this Settlement Agreement intend to resolve the Account and the Litigation in the manner set forth hereinafter. Now,therefore, in consideration of the mutual covenants and conditions herein contained, and in lieu of further litigation,the parties expressly intending to be legally bound hereby, agree as follows: C.l. IC 2 A 1 0 C . CADkA A177 From:John Willis Fax:(888)551-5063 To:+16106964111 Fax: +16106964111 Page 4 of 5 3!18!2013 9:04 1. Peery agrees that judgment may be entered on behalf of Citibank and against Peery for the amount due in the Litigation as set forth above.Interest will accrue on the judgment at 6% from the date it is entered on the records of the court. 2. Citibank agrees to accept and Peery agrees to pay the sum of$2,000.00 without interest in full and complete satisfaction of the judgment in installment payments, as follows: a_ An initial payment of$900.00 due February 28, 2013; and b. l l payments of$100.00 each due the 30`'day of each month beginning March 30, 2013 3. All checks are to be made payable to Citibank and mailed to Burton Neil& Associates, P.C. at 1060 Andrew Drive, Suite 170, West Chester,PA 19380, 4. Citibank agrees to take no action on the judgment provided payments are made by Peery in accordance with this agreement. 5. When the Settlement is paid, Citibank will file with the court a praecipe to mark the judgment satisfied. 6. Should default occur,the full judgment amount including accrued interest will be due and owing less credit for all payments made by Peery pursuant to this agreement. "Default"shall mean any of the following: Peery's failure to make a required payment due hereunder by the due date or a check being returned NSF. 7. Whenever $600.00 or more in Principal of a debt is forgiven as a result of settling a debt for less than the balance owing,the creditor, Citibank,may be required to report the amount of the debt forgiven to the Internal Revenue Service on a 1099c form, a copy of which would be mailed to Peery by the creditor, Citibank. Peery is encouraged to consult with a legal or tax advisor if there is uncertainty regarding the tax consequences. From:John Willis r n CFI,:(888)55175063 To: +16106964111 Fax: +16106964111 Page- .5`tof 7 3/18/2013'9:04 In witness hereof the parties&4reby execute sh;s =cut Ag memtnt.intending to be bound legally thercby.A facsimile signatare shalt have the.same force and effect as an-original signature_ Burton B Trenton armer,Esquire Sham L Pwry Attornev for Citibank Date: &.3 mss%_ Date.; In making this.communication,we.advise our. is a debt collector. Burton Neil &Associates, P.C. By: Trenton A. Farmer, Esquire ID.NO. 209422 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-230-CIVIL SHANA L PEERY Defendant : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Wavd-� 010( A E . Prothono By: ri If you have any questions concerning the above, please contact: Trenton A. Farmer, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil&Associates is a debt collector. Burton Neil &Associates, P.C. By: Trenton A. Farmer, Esquire ID.NO. 209422 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 CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-230-CIVIL SHANA L PEERY 107 East Springville Road Boiling Springs PA 17007-9737 Defendant : CIVIL ACTION- LAW Certification of Address Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities,I verify that the above are the precise last-known addresses of the judgment creditor and debtor. BURTON NEIL&ASSOCIATES, P.C. B Trenton A. armer, Esquire Attorney for Plaintiff The law firm of Burton Neil &Associates is a debt collector. Burton Neil&Associates, P.C. By: Trenton A. Farmer, Esquire ID.NO. 209422 1060 Andrew Drive, Suite 170 West Chester,PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-230-CIVIL SHANA L PEERY Defendant : CIVIL ACTION -LAW Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA)the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. BURTON NEIL OCIATES, P.C. By: nton A. Farmer, Esquire Attorney for Plaintiff The law firm of Burton Neil&Associates is a debt collector. 2014 FEB 20 PM I: ti 0 PEAS YL A 4N T Y Burton Neil &Associates, P.C. By: Trenton A. Farmer, Esquire ID. NO. 209422 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK,N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 13-230-CIVIL SHANA L PEERY Defendant : CIVIL ACTION-LAW Praecipe to Satisfy Judgment To the Prothonotary: Mark the judgment Satisfied . Burton Neil &Associates '.C. By: j�. 4.4P. armer, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-59673 /318 DO q.so a /kj/ C k._#/3y9oy 7ti-- Sol Fin