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HomeMy WebLinkAbout13-2685 Supreme Court of Pennsylvania For Prothonotary Use Only: Court of Common Pleas Docket No: _ Civil Cover Sheet 13 61VII term CUMBERLAND County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings and other papers required by law or rules of the court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S E Lead Plaintiffs Name: Lead Defendant's Name: C CITIBANK, N.A. ELIZABETH K COON T I O Any money damages requested ?: ® Yes 13 No Dollar Amount Requested: ® within arbitration limits N (check one) ❑ outside arbitration limits A Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No Name of Plaintiff/Appellant's Attorney: Brit J. Suttell, Esquire ❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant) Nature of the Case Place and "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider mo important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Possession ® Debt Collection: Credit Card ❑ Board of Assessment S ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections E ❑ Nuisance ❑ Depart. of Transportation C ❑ Premises Liability ❑ Statutory Appeal: Other T ❑ Product Liability (does not ❑ Employment Dispute: I include mass tort) Discrimination O ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board N ❑ Other: ❑ Other: B ❑ Other: MASS TORT • Asbestos • Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant • Toxic Waste • Other: REAL PROPERTY MISCELLANEOUS ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: 11 Other Professional: C) C - w + rnCO M rn -- ; r^ cn ._ C:) C) CD �-- 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. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ELIZABETH K COON : NO. 1,_5 -c16 85 Civi I e rm 1917 Spring Road. Carlisle PA 17013 -1196 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 C Cumberland County Bar Assoc. s 32 South Bedford Street _ Carlisle, PA 17013 (p 7 Pp A Telephone No. 717- 249 -3166 or 800 - 990 -9108 C i 3101 C -60807 / 304 0 4� J r , BURTON NEIL & ASSOCIATES, P.C. Derek C. Blasker, Esquire, Id. No. 202150 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 CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ELIZABETH K COON 1917 Spring Road Carlisle PA 17013 -1196 Defendant CIVIL 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 Elizabeth K Coon who resides at 1917 Spring Road, Carlisle, 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 The Home Depot credit card account (hereafter the Account) with account number ending in 0887. 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 $14,332.93 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 $14,332.93, and the costs of this action. J B on iate , P.C. By: Der . Blasker, Esquire ./lY: Brit J. Suttell, Esquire 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 -60807 / 205 r . Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: 6r Customer Service: HOME DEPOT CREDIT SERVICES PO Box 790328, St. Louis, MO 63179 myhomedepotaccount.com Account Inquiries: A��oir►t?iVtS`r�t�cY ® 1- 866 - 458 -7683 J: r.:. _ %r:5 { '•'. ; .r. ^.t y'r. r 5 ,,,. y'.a }a. Summary of Account Activi Payment Information Previous Balance $14,009.11 New Balance $14 332.93 Payments -$0.00 Minimum Payment Due $2,160.00 Other Credits -$0.00 Payment Due Date February 10, 2013 Purchases •1.$0.00 Late Payment Warning: if we do not receive your minimum payment by the Fees Charged +$35.00 date listed above, you may have to pay a late fee up to $35. Interest Charged +$2$8•$2 Minimum Payment Warning: If you make only the minimum payment each New Balance $14,332.93 period, you will pay more in interest and it will take you longer to pay off your $1,692.00 balance. For example: u Past Due Amount rnak3actd>ti6lafr wit,�r�ayfte�w,Arfyo0vrl �" t cfat9esin 'hlsardaanc2twngrl paa Credit Limit $0.00 �eCf3GalOrlt} �T*• 7Q�1s• Ya ^:n= a.•..�_T1...(fNfFlaE?4v.Tda 'flf'.� tOliiA� >. 'i Available Credit $0.00 Only the minimum payment 27 years $40,449 Statement Closing Date 01/14/2013 $586 3 years $21,$1 (Savings = $19,364) Next Statement Closing Date 02/11/2013 information would like infoation about credit counseling services, call 1 877 - 337 - 8188. Days in Billing Cycle 31 Your minimum payment due is $2,160.00. To avoid interest charges on your non - promotional (revolving) balance and any expiring promotions, pay $13,264.37 by February 10, 2013. If you pay your non - promotional balance in full every month, no additional billed interest charges will apply. Interest accrues dairy from your statement closing date until we receive your payment, so please check your next statement for any additional interest you may have incurred. You must pay your promotional balance of $624.42 in full by 04110/13 to avoid paying deferred interest charges. You must pay your promotional balance of $444.14 in full by 08/10/13 to avoid paying deferred interest charges. We may be able.to temporarily reduce your monthly payment and interest charge. Our Account Resolution Specialists are available to provide assistance. Please contact us at 1 -866- 752 -0874, visit us online at myhom denotaccount com or go to your local The Home Depot store. - _ Everything you need to know about your account is here — in one easy-to-read statement: accoul1 number, payments, fees, interest, ' ' -• .::� �:. °'• - ' .. , • � - " `� -" credt limit, contact informa and more. Please see page 4 for additional information. 8HD8 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, N.A. -------------------------------------------------------------------------------------- ------------- --------------------- - - - - -- + Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. + tPast Due Amount is included in the Minimum Payment Due. ,Lt, a't(oyt_AcCourltc Number; Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed FEBRUARY 10, 2013 $14,332.93 $1,692.00 $2,160.00 $ 38871433293004000002160 Make Checks Payable to: HOME DEPOT CREDIT SERVICES PO BOX 182676 ELIZABETH K COON COLUMBUS, OH 43218-2676 1917 SPRING RD CARLISLE, PA 17013-1196 EXHIBIT A Print address changes above in blue or black ink. information About Your Account. "slow to Avoid Paying interest an Purchases. Your payment due date is at least 25 days after the what ti 11 Happen After We ReceivO Your Letter close of -ad biking cycle. We will not charge you any inierost on purchases if you pay your New Whha, we receive our letter, w must do two Balance by the payment things: flue date each month. This is called a grace period on purchases. If you do 1. Within 30 days at receiving your letter. we must tell you that we received your letter. We will aiso ` not pay the New Balance in full by the payment due date, you will not get a grace period on r purchases tell you if we have already corrected the error. until you pay the New, Balance in hwil tar two billing cycles in a row. 2. within 90 days of receiving ;'cur letter. we nvust either correct the error or explain to you why we Oaro APR promotion and that promotion dog not believe the bill is correct. If you have a balance subject to a deferred interest or expire before the payment due date, that balance (the `excluded balance ") is excluded from the While we investigate whether or not there has been an error: amountyou must pay In full to get a grace period. Haw%Twr. you must still pay any ocated to reeqquired payment on the excluded balance. in billing cycles in w, ich pa inennts are allocated to dat2rled ° We cannuti}y to collect the amount in question, or report you as y c o n an that charge yo i nterest interest balances first, the deferred interest balance will be reduced before any other balance on the • The charge in question may remain on your statement, and we may c to charge you account However, you will continue to get a grace periiuf on purchases s3 long as you pay the New ont y . do oat ha+e to pay the amount in question, you are responsible for the remainder df Balance less any excluded balances in full by the payment due date each billing cycle. w e may refer •,. h to deferred interest promotions as No Interest promotions. your balance. In addition, certain promotional afters may take any the grace period on purchases. tither a 6-p, can apply any unpaid amount against your credit limit promotional offers not described above may also allow you to have a grace period on purchases After we finish our investigation, one of two things will happen: without having to pay all or a portion of the Droutionai balance by the payment due date. if either is • dw„ ode a .nuke: You will not have to Pay the amount in question or any inlemi or other tees the case, the promotional Offerwilf describe what happen related to that amount Howe We Calcol ®t>s your Balance Subject to interest Rate. For each balance, the letter o g iw do not behove there was a ,mistake: You will have to pay u1e amouni in question, along wwith following the Annual Percentage Rate in the Interest Charge Calculation sec5on on the front of the applicable irrteaest and fees. We wilt send you a statement of the amount you owe and the date statement indicates the method vie use to calculate interest charges. For Methods C, Hand M, we use payment is due. We may then report you as delinquent if you do not pay the amount we think you owe, a daily balance method (including current transactions] to calculate interest charges- For iwtelhods I If du receive our explanation but stilt believe your bill is w7dng, you must write to us within 10 dm L, vrs use an average daily balance method (including current transactions) to calculate interest telling us that you still refuse to pay. If you do so, we cannot report you as delinquent without also charges. For Method K we use an average daily balance method (excluding current transactions) to reporting that y ou are questioning your bill We must tell you #h2 name of anyone to whom we report calculate Mod late interest charges. To find out more information about the balance computation method that ties to your account and how the resulting interest charges were determined, contact us at yy oouu a delinquent, and vb must 121 those organizations krRwv when the master has lotion se d., applies betw,sen us. Customer Service number on the front. ormation to a credil bureau wvrite q uestio n we o n even it your not follow yo ur bill is eared. all of the rules above, you do not have to pay the first W of the amount you Credit Reporting Disputes. If you hinkwve reported inaccurate inf us at the Customer Service address shown on the front. q Report a lost or Stolen Card Immediately. Call the Account Inquiries number shown on It you ae d is f tisfie Ar t co ds or s e r vic e s s that y h se e vi es Rep the front. It you are dissatisfied with the goods or servrie2s brat you have purchase) with your credit card, and tte front. To pis If You Find A Mistake On i'ocrr Statement h to correct the problem with the merd nt you may have. the. right oat td you have tried in good fait if you think there is an error on your statement, write to us at the address for billing inquiries and pay the re-maining amount due an the purchase. correspondence shown on the front of your statement To use this right, all of the following must be tiuT In your letter, glue us the following information 1. The purchase must have been made In your home state or within 100 miles of your current • Accorfot iafarrnaridn: Your Warne and account number. mai ling address, and the purchase price must rave been more than M. (Nate: Neither of these are necessary if your purchase was used on an advertisemert we mailed to you, or if we own the ® Dol4rarrount. The dollar amount of the suspected error. company that sold you the goods or services.) • Description of praiitern. If you think there is an error on your bill, describe what you believe is wrong 2 You must have used your credit card for the purchase. Purchases made with cash advances from and why you believe it is a mistake. an ATM or with a check that ayces&" your credit card account do not quality. You must contact us: • within 60 days after the error appeared on your statement. 3. You must not yet have fully paid for the purchase. a At least 3 business days before an awtomaisd payment is scheduled, if you want to stop payment on if all of the criteria above are met and you are still dissatisfied with the purchase, contact us in wvrf,iTg the amount you think is wroi ig. at the address for billing inquiries and correspondence shown oft the front of your statement. You rm3st notify us of any potential errors in tvri?rng. You may call us, bit it you de. we are not iequ -AlterW8 finish we to investigate any potential errors and you may have to pay the amount in question. � on, we wil l fell you ourd eQiis on2At poirrcww�h think discussed u owe amount and you our do not pay, we, may report you as delinquent. KEY CREDIT TERMS — NO INTEREST IF PAID IN FULL W ITHIN 6 MiONTHS% $229 minimum purchase required. Minimum payments required. interest will lie charged to your account from the purchase date It the purchase balance (including premiums for optional credit insurance) is not paid in full within 6 maritfws or if you make a fate payment. h credit approval for quafitying purchases made on The Hdme Depot or EXPt} Cosign Center Consumer Credit Card, 17.99% - 26.99% APR. Minimum Interest charge: $2. See card agreement for details including APR applicable to you. Offer fs only valid for consumer accounts and is subject io change without notice. lmpmrtant Payment Instructions. payment options Other Than Reguiar Mail. at our processing facility by night to Prepay Your Account. You may pay all or Part of your, account balance at any time. • online Payments. Visit myhomed€pofaccaur;tram and sign up for free online payments. a few days. it we receive your request to make an online payment by p .m. However, you must pay, by the payment due Me, at least the minimum payment due. Enrollment may take l�odi;i ng p aymen t s . . if vru receive your mailed pa inert in proper form Eastern time, we will credit your payment as of that day and it will post within thee business days. 5 P.M. local time treys, d grill be credited as of that lf. A paymcint received there in proper farm after if we. receive your request to make an online payment after that time we will credit your payment le that time volt be cr20tled as of the next day. Allow 5 to 7 days for payments by regular marl to react of the newt day and d will post within three business days. For security reasons, you may be unable us. There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form to pay your entire New Balance with your first online payment. or is not sent to the correct address. The correct address for regular mail is the address on the front of * AutoPay Service. it you are enrolled in ibis service, your payment amount will be deducted the payment coupon. The correct address for courier or express marl is the Express Payments Address automatically each month on your due date from the bank account you Wed. shown below. • Pay by Phone Service. You may use this service anytime to make a payment by phone, if your Proper Form. For a payment sent by mail or courtier to be in proper form, you must aunt is eligible. You will be charged $14.95 to use this service H a representative of ours helps • Encim a valid check or money order made payable tow Home Depot Credit Services. No cash, expedite your payment. Call by 5 p.m, Eastern time to have your payment credited as of that day and gilt rams, or foreign, currency please. posted within three business day's. it you call after that time, your payment will be credited as of he next day and posted within three business days. We may process your payment electronically after • include your name and account number on the front of your aleck or money order, we verily your identify. if you send an eligible check with this payment coupon, you authorize us to complete • Express Pa mends. You can send payrrirent by courier or express mail to the Express Payments your payment by electronic debit. if we do, the checking account will be debited in the Address. This address is: Cu tom2r Service Gents , Attention: Payment Mail Opening, 1500 amennt on the check. We may do this as soon as the day w e receive Este chard;. Also, Bollonfietd St., Columbus, DH 43228. Payment must be received in proper farm at the proper the check will be deslruyed. address by 5 p.m. Eastern time to be. credited as of that day. All payments received in proper form at Copy Fee. We charge $5 for each copy of a Nif ing statement that dates back 3 months or ;Wore. We th proper address after That time will be credited as of the next day. add the fee to a balance of our choosing. We reserve the right to add this fee to balances subject to a The Home Do OIFS higher annual percentage rate. We waive the fee if your request for il� copy relates to a hitting error or • In -S t ore ores with no seMce f Ar Payment c o n venien ce, farm accepted in­ a will be credited as of that disputed purchase. day. However, credit availability may be sublet to verification of funds. HEf/EXJUt12 AV T02354- 9196-0400 - 0002 -E-0-X- 08/01/06 -60- 113- P- 0-- 4- 5-0- NOPLAY- 06/22/12 -HF5B- December 14,2012-0-0 N— Page 2of4 Account: * * ** * * ** * * *' 0887 TRANSACTIONS Reference # Amount Trans Date Description FEES $ 35.00 01/10 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD INTEREST CHARGED 288. 01/14 INTEREST CHARGE ON PURCHASES $ 288.82 TOTAL INTEREST FOR THIS PERIOD a. k 2�'l t3tBraff - tQ bafe Total Fees Charged in 2013 $35.00 Total Interest Charged in 2013 $288.82 Original Previous Payments Billed New Promo Deferred Trans Trans Promotion and Interest Promotion Monthly Interest Expiration PROMOTION Amount Date Balance Credits C harqes Balance _P ayment Charges Date NO INT FOR 12MOS -PMT REQ $824.50 04/01/12 $624.42 _ $624.42 $144.87 04/10/13 NO INT FOR 12MOS -PMT REQ $444.14 07/19/12 $444.14 $444.14 $60.70 08/10/13 INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual, interest rate onyour_ account_ j'yg of�3aTance� �'.. , :�' r.;,�.�:._ _..:.� , - ':ti�n traiP�'r_ .' e.Raie:I>;FFi .,- �� 'B'atance`SubectfointerestRate s .r.;Jnieres'��Cha, a .?.. PURCHASES Revolving Balance 25.99% M $13 085.36 $288.82 NO INT FOR 12MOS -PMT REQ 25.99% M NO INT FOR 12MOS -PMT REQ 25.99°/ M Page 3 of 4 Account: * * ** * * ** * ** 0887 �� ��6Idar.�ni��� tc� rya. .: . Statements are wntten;in everyday language thatiyou II be able :to read and understand They show you exadtly how mudh you ve spent; fides Yiiuch ydu owe when you owe it and how iong,d will take you to'pay it otfi 6; cortt�se The information is 'bucketed into sections that make tt easy to find what you're looking 1or.and is wntten m norrriai everyday language Easy to read ' Not :only are the words themselves easier to undeestand they re in a larger and easier to read type fa Ce M. MW at4i mow xnw MW =W Azu A 097 AW-W Maur ARM LAW PEW Summary of Account Activity Monthly account activity - payments, i credits, fees, and interest charged Transactions Account Number /Contact Information See clearly the activity that Payment Information occurred to create your monthly i Your balance, minimum payment and due date i t balance: purchases, payments P Calculatora-� -- a-�- -° and credits, fees and interest An estimated time it will take to pay off your g for the billing period balance when making the minimum payment i and how much you should pay each month 1 Promotions Section to pay off your balance in 36 months Customer- friendly summary Account Statem t so you know how your balance "MED." C TSE IAMEBEPOr OP�TSERVICES MuloglBrSm PO BO:C 65300 �011A9 TX T5265.90m was calculated and how your ,� h.qurte,: payments are applied. Promotions are also listed Aoj�, a3r� 1R v or a99.9999e PrB�icus,Balerra Sss,999.89 New Balarw� .. In the order Of expiration -M ,999 . 99 . teHmGn FarmernDw_ .. ys9,9se99- Olne+' CredRS . - 599.999.99 'Pa t Due Date Mordb D0. YYYY <. '- -.•'� Purcfia32s' -_._• .:. �,.- f tmP rve y ,>,,. - ". mB dme woad Bb—. yes m" trove m PW tam tee 0 m M Fees CI+�+Yed - „ y Inmrwt Charged .. ..... #S9Y.ais.99 Wnk „ Paymns Wa InW. H you maim only the mnlr p0ylnere N.. Belerce :.:,::o ::..:: -. r':#9s,s �, wm. MI av mae n intent and k rnA ml�yae tx,pa m j I - Pay M ydr be Fv enmpe: .r +'; �•� .,. Pa6t DUB ARIB _. '..� a 'mel+e atldMlmel:: "W WII'piej'pH lhe' :.: And yoU Wl'. • w..i� d go"i:de`+J V+I bed b4,16 On lbh M w PeYti�J' _ y'. CCae�dI lJmA .591,9999fl V>9itip:ydU P}y =.. 'et�meltt'l:_3bOtiL:: e61i1141Bd 107at AYBYahle Gediz .. •} On 'bye minlmm peymen 10 Yeah $99,we i .« ......«• 9999 SBtarotM Cbsing D010 _ M MrDD Y t x.5959 3 K° lS.w �G• 11R y. Nm0 8t.%B nt Cban_$ DBIe � �, w iiwaeoinesm ibee ae q^1707F ;d. 1=MEN A Uayc in eas FMS WPM BA OeWfP Oh ypySpFitir P=��NUifM�plPpB.y f P_BB.BT � ,d twa*G5fED PJmava � �. _ /NOME����3gEa.. - -... P mOS A Tvc, C'°EPG3'B^ +At1.r'°`"`•n,.oawtA.V+"'P'"-. = �. Irw �F.A csf aciWret�lx+ s �. W it 7HrW u IIWM GHEBR FEE mPEWOB '+ CNARMW CHI:nOE ttiSES �"F' - NJfICE:SEE itVEPSE SSE FOP NPOPOINT MFVHltfION PV. 1Nf ~ ��I `rud :';:.Spg 90964 Tsar Pees H"' - ''- tro�a+/ taeva+ in yyyy ,�,��, ,,���. �,,+�,. I Original Transaction Amount A y � 4 ��e Allows you to reference the ' fie, :r: .. original purchase Sri~ .58899899.. � yves9e� '9 59e o chase amount 2' ..a Y Poe • . �,�.es s�.w%ae :.- P �ae�e; New Promotion Balance �f [7d;k3L+= C.�O,g�lFL^'+�. fiat.l 9 ➢9 S9.9H099899 � ,@� track of the amount of the original promotional pUPts. - ... _ .. BB9. ��.. 9 p p f d m purchase which remains unpa na .. 99989 ... .. ...'... '9089 HWEX AUG 1 i tvi �� Pee Page 4of4 Verification KATHY RIZOR 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. n Signa e C -60807 Elizabeth K Coon Account number ending 0887 1025 SHERIFF'S OFFICE OF CUMBERLAND COUNTY 11 C:G-O FICE Ronny RAnderson ,F THE ?ROTHO OTARt Sheriff Jody S Smith ,xvoturxr 2013 MAY 30 AM 11* 00 Chief Deputy `� �' CUMBERLAND COUNTY Richard W Stewart > OF T SK RIP: PENNSYLVANIA Solicitor Citibank, N.A. Case Number vs. 2013-2685 Elizabeth K Coon SHERIFF'S RETURN OF SERVICE 0511712013 03:36 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Lisa McLain, Contractor, who accepted as"Adult Person in Charge"for Elizabeth K Coon at 1917 Spring Road#2, North Middleton, Carlisle, PA 17013. DEN)KS FRY, DE . TY SHERIFF COST: $34.78 SO ANSWERS, May 23,2013 RON R ANDERSON, SHERIFF (C)CountySuito Sheriff,7oieosott,Inc. C-60807 /314 G 17 2013 JUN 21 FM 1: �6 CUMBERLAND COUNTY RENNS`1 LVANIA Burton Neil &Associates, P.C. By: Derek C. Blasker, Esquire ID.NO. 202150 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. 13-2685 CIVIL TERM ELIZABETH K COON Defendant : CIVIL ACTION - LAW Praecipe to Discont ue To the Prothonotary: Kindly discontinue the above-captioned action wi o t prejudice. Burt it &Associates, P.C. By: 11 C. Blasker, Esquire A \ey 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.