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HomeMy WebLinkAbout13-1665 -A Blatt, Hasenmiller, Lelbsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 CITIBANK, N.A. r") 7J C) Syretta Martin Attorney I.D. #309370 CIO " 7 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. No. STILES M GAFFNEY 1319 3RD ST APT 14 ENOLA PA 17025-3188 Defendant. 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 P13 ATN 0 488qll 2801577 PPTCPADI "ISO 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 Attorney for Plaintiff, Morris Scott CITIBANK, N.A. Syretta Martin 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. No. STILES M GAFFNEY 1319 3RD ST APT 14 ENOLA PA 17025 -3188 De COMPLAINT Plaintiff, CITIBANK, N.A. claims as follows: 1. The Defendant(s), STILES M GAFFNEY , is a resident of Cumberland County, Pennsylvania. 2. Defendant opened a credit account with Plaintiff on or about February 18, 2004. 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 Defendant 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 $13975.06. 7. An account stated for the sum of $13975.06 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 or about 09-14-2010. 2801577 PPTCCITI WHEREFORE, Plaintiff, requests Judgment in the amount of $13975.06, plus court costs and interest from the date of Judgment. Respectfully submitted, d� Morris Cott, Attorney_NpA3587 Syretta ey No. 309370 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 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. No. STILES M GAFFNEY 1319 3RD ST APT 14 ENOLA PA 17025 -3188 Defendant(s). AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Morris Scott/Syretta Martin, 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. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: February 7, 2013 By: Morr ott Syretta Martin 2801577 PPTJCAMI �I�I�I�I�hII�tniI�NlI Verification l KATHY RIZOR , am employed by Citibank, N.A. (hereafter Citibank) which is successor in interest to 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 complaint are true and correct upon my information and belief and are made subject to the penalities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 7 1 Sigature 2801577 PPTXCITI III M I M I �N�N�II�RIIIIIII Exhibit " A " PPTXEXAI i How To Reach Us _ wwai.citicards.com 1-800-756-4000 3 d y 0 ' F F o Account Member i> rn 0 y�j a 3 A STILES M GAFFNEY Customer Service ,O 3 o g 3 b e to Account Activity Account Number SIOUX FAL SD so 3 P m Mar 11-Apr 12, 2011 —3918 Member Since 2004 57117 m�� o °opv C 2 N m P < m = Minimum Payment Due: New Balance: Summary of Account Activity o rn a o 3 D o 0 ' $13,975.06 $13,975.06 Previous Balance $1 3 ,616.41 Fees o ° Payment Due Date: Payments _ _ - 0.00 sale __, Post _ Description _ _ Amount u+ m I PaymeMmustbemceivedby5:00PM Other Credits _�O.DO 04/12 LATE FEE- MA R PAYMENT PAST DUE 35.00 05/08/2011 __ . _ .__._ -__ u kxaltkiwontMpsymentdwdate. Purchases +$0.00 TOTAL FEES FOR THIS PERIOD 35.00 w Lett Payment tfarnkI If we do not receive your Cash Advances r minimum payment by the date listed above, you may Fees Charged + 35.00 have to pay a late fee of u to $35 and your APRs r Interest Charged be increased up to the variable Penalty APR of 29.99%. Interest Charged + 23.65 k New Balance $13,975.06 _ Post Description _ Amount w Minim= Payment Nanning: If you make only the 04112 INTEREST CHARGED TO STA NDARD PURCH 323.65 -D minimum payment each period, you will pay more in Past Due Amount $2,518.03 TOTAL INTEREST FOR THIS PERIOD 323.65 Ln interest and It will take you longer to pay ofi your C3 balance. For example: Amt. Over Credit Limit $2,275.06 c" If you make no ! You will pay off And you will end 2011 Totals Yew-to -Date additional charges the balance shown up paying an Credit Limit $11,700 U using this card and on this statement estimated total Available Credit _. -�0 Total fees charged In 2011 $345.49 each month you pay in about_ of------- Cash Advance Limit 0 -o 0 �] " 11 the minimum __. ._ . 700 Total Interest charged in 2011 $1,157.26 . W 1 month(s) $13975 Available Cash Limit C Gl 0 C3 I P6Vmeot Statement Closing Date 04 12 20'1i ____ _ —_. __. _ - . - -.-_ Interest Charge Calculation For Information about credit counseling services. WII 1-877-337-1118 3 o a Ir I Days in Billing Cycle 33 C x p You Annual Percentage Rate (APR)is the annual Int erest rate on your account. In O) N C3 - ut C3 Annual Percentage Balance Subject to _ Z o Typ of Balance Rate (APR) Interest Rate Interest Charge a w A C3 PURCHASES m 0 ; Standard Purch 25.990% (V) $13.772.70(D) $323.65 Ln C g C7 S ADVANCES 0 3 3 - Standard Adv 25.990% (V) $0.00 (D) $0.00 Wg a 11.1 Y Help is available! Please call the toll -free number shown above to learn about our E " w s s pecial payment op t i ons. Call Monday Friday, 7 am to 9 m, or Saturday 8 am to 5 3i � n ° s P P Y P� Y Y. P Y. o 2 pm, Central Time. Please give us the opportunity to assist you. $ oo C! • g n R N II 1of2 i How to Reach Us 1- 800.756-4000 Customer Service BOX 6500 Account Number SIOUX FALLS, SD 57117 "" "'• "" 3918 Access your account online: www.citicar4s.com Please be sure to pay on time. if you submit your payment by mail, we suggest you mail it no later than 05/01/2011 to allow for enough time for regular mail to reach Us. Credit Protector Your account protection eligibility has been cancelled on your account effective 03/10/2011. 2of2 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, VS. CIVIL ACTION /��" No. - i ISJIlI U vvilTeo STILES M GAFFNEY 1319 3RD ST APT 14 "J � ENOLA PA 17025 -3188 Defendant(s). rte` Co 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: February 7, 2013 By: A Mo)A' oft Attorney Syretta Martin Attorney 2801577 PPTXPEAI I NO 0 1MEN 10 �MII�I�II SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff M Uj :Z- r, ti�jv rr��� Jody S Smith 1 �► v Chief Deputy Richard W Stewart Solicitor Citibank, N.A. vs. Case Number Stiles M Gaffney 2013-1665 SHERIFF'S RETURN OF SERVICE 04/02/2013 09:14 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Stiles M Gaffney at 1319 Third Street,Apt. 14, East Pennsboro/W. Fairview, Enola, PA 17025. ASON KINSLER, DEPUTY SHERIFF COST: $43.00 SO ANSWERS, April 03, 2013 RON R ANDERSON, SHERIFF 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 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. , No. 13-1665CIVIL TERM C-5 STILES M GAFFNEY k ;z 1319 3RD ST APT 14 ENOLA PA 17025-3188 Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant STILES M GAFFNEY in this matter in the amount of $13,975.06 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2)was mailed separately to each defendant on 05/07/2013 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: May 29, 2013 By: I�Q M& is Cott 41(..50 IPA t�Y Syretta Martin C*8,1_5gN 0 a qml 2801577 PPTJPFJI 11111111111111111111111111111111111111111111111111111111111111 1 11111111 1 111 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 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. No. 13-1665CIVIL TERM STILES M GAFFNEY 1319 3RD ST APT 14 ENOLA PA 17025-3188 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Morris Scott/Syretta Martin, 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. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: May 29, 2013 By: cott Syretta Martin 2801577 PPTJCAMI (05/01/2013) 11111111 VIII 1111111111 III 111111 VIII VIII VIII VIII VIII VIII VIII IIII IIII SCRA 3.0 y+491Y rt '-- ' ' Staff Report Pmumt 0 Savicemembim Civil Relief Ac Last Name: GAFFNEY First Name: STILES Middle Name: M Active Duty Status As Of: May-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA�d �, •_"�; :.� .._�-�-_ - No\.. NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component , ar �. NA a NA :` -:ti No NA This response reflects where the individual left active duty status within'367 days preceding the Active Duty Status Date A It The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start D.t.:= Order Notification End Date Status Service Component NA W%NA,;�� `k+ '��f�¢No.z+':�0 NA 'it' ,, This response reflects whether the individual or his/her unit has received eaHy notcalion to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based 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,NOAA,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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 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.htmi. 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: K34CO140HOC2D80 CITIBANK,N.A. Plaintiff, IN THE COURT OF COMMON PLEAS Vs. CUMBERLAND COUNTY, PA STILES M GAFFNEY CIVIL ACTION 1319 3RD ST APT 14 ENOLA PA 17025-3188 No. 13-1665CIVIL TERM Defendant(s). TO: STILES M GAFFNEY Date of Notice: May 7, 2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, LEIBSKER &MOORE, LLC vto"& A .Saab By: Morris Scott Syretta Martin 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2801577 PPTNLRSI IIIIIIII 11111 II 111111 IIIII IIIII 1111111111 IIIII IIIII 1111111 II IIII CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA VS. STILES M GAFFNEY CIVIL ACTION 1319 3RD ST APT 14 NO. ENOLA PA 17025-3188 Defendant(s). No. 13-1665CIVIL TERM TO: STILES M GAFFNEY 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. PRO ONO ARY -�h-3 Dated: By: `% IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker& Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2801577 PPTNDJNI 111111111111111111 VIII III 11111111111 VIII VIII 11111 VIII VIII IIII VIII IN