Loading...
HomeMy WebLinkAbout13-4256 i Supreme Co., nnsylvania Coll l' _fi )� � f C - d linnr!<o .Pleas For Prothonotary Use Only: _ i ll 4_OV,81'S,�t Docket No: ri Cumberla �` �'�'' r: - County 13 - q - ?S6 Cu The information collected on this form is used solely for court administration Purposes. This form does not supp lement or re lace the filing and service ofpleadings or other o ers as required by law or rules o court. Commencement of Action: S 21 Complaint El Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: C MIDLAND FUNDING LLC DEBORAH HARPER T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? [R] Yes ❑ No (check one) []outside arbitration limits O N Is this it Class Action Suit? ❑ Yes ® No Is this an MDJAppea/? ❑ Yes U No A, Name of Plaintiff/Appellant Attorney: Daniel J. Santucci, Esci. ❑ Check Isere if you have no attorney (area Self- Represented [Pro. Sel Litigant) Nature of the Case Place an "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 most important. TORT (do not include Alass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑.Malicious Prosecution 10 Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other © Board of Elections Nuisance Dept. of Transportation ❑ Premises Liability Statutory Appeal: Other S ❑ Product Liability (does riot include mass tort) ❑Employment Dispute: F' Discrimination ❑ Slander/Libel/ Defamation L'' ❑Other: ❑ Employment Dispute: Other ❑Zoning Board Other: T I ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Ejectment E3 Common Law /Statutory Arbitration ® Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B ❑ Ground Rent 8 Mandamus ❑ Landlord /Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage f=oreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin Legal ❑ Quiet Title ❑ Other: Medical ❑ Other: Other Professional: Updated 1 /1/2011 143465 f ` _'.� T IiE PIRG I H0IN 0Tf,'R Daniel J. Santucci, Esq. Attorney ID # 92800 Z 0;3 J; 22 P M I%: 2 P.O. BOX 517 Essington, PA 19029 -0517 CUMBERLAND COUN 866 - 626 -5053 P EI }d t', 5 Y LVA N I A MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 Cumberland San Diego, CA 92123 COUNTY, PA Plaintiff, CIVIL ACTION ., VS. NO. J :3 DEBORAH HARPER 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 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 PHONE: 800 - 990 -9108 143465 AVISO USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta Demanda 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 falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n 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 u 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 SIGUIENTE 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 POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN 143465 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029 -0517 866 - 626 -5053 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 Cumberland San Diego, CA 92123 COUNTY, PA Plaintiff, CIVIL ACTION NO. VS. DEBORAH HARPER Defendant(s). COMPLAINT 1. Plaintiff, MIDLAND FUNDING LLC ( "Plaintiff'), is a limited liability company with an address of 8875 Aero Drive, Suite 200, San Diego, CA 92123, and is registered to do business in the Commonwealth of Pennsylvania 2. Defendant, DEBORAH HARPER ( "Defendant "), is a resident of Cumberland County and has a last known address of 1942 Monterey Dr Mechanicsburg, PA 17050. 3. By this complaint, Plaintiff seeks to recover amounts owed by Defendant. The underlying account that is the basis of this lawsuit is a credit account that Defendant held with creditor CITIBANK, N.A. account no. XXXXXXXXXXXX4948 (the "Account "). Prior to filing this complaint, all right, title and interest to the Account were sold and assigned to Plaintiff. Plaintiff owns the Account and stands in the place of the original creditor and is entitled to collect on the Account as if it were the original creditor. To the extent that Plaintiff acts in its capacity as successor -in- interest to the original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor -in- interest. (Please see attached documents) 4. Defendant opened, used, and derived benefit from the Account through Defendant's own use of the Account or by another's use at Defendant's direction. By using the Account, Defendant expressly agreed or impliedly promised to repay Plaintiff. 143465 MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION 5. Plaintiff Midland Funding LLC owns portfolios of consumer receivables, which it attempts to collect. When working with individual consumers, Plaintiff Midland Funding LLC and its affiliates (collectively, "Midland ") generally attempt to contact consumers like Defendant through several means, all in an effort to establish contact and to resolve the underlying obligation. In doing so, Midland attempts to assess each consumer's willingness to pay, through phone calls, letters or other means. Midland attempts to exclude consumers from its collection efforts, where Midland believes those consumers are facing extenuating circumstances or hardships that would prevent them from making any payments. 6. When Midland contacts consumers, it strives to treat consumers with respect, compassion and integrity. Midland works with consumers in an effort to find mutually - beneficial solutions, often offering discounts, hardship plans, and payment options. Midland's efforts are aimed at working with consumers to repay their obligations and to attain financial recovery. Midland strives to engage in dialogue that is honorable and constructive, and to play a positive role in consumers' lives. 7. Despite Midland's efforts to reach consumers and resolve the consumer's obligations, only a percentage of consumers choose to engage with Midland. Those who do are often offered discounts or payment plans that are intended to suit their needs. Midland would prefer to work with consumers to establish voluntary payment arrangements resulting in the resolution of any underlying obligations. 8. However, the majority of Midland's consumers ignore calls or letters, and some simply refuse to repay their obligations despite an apparent ability to do so. When this happens, Midland must decide then whether to pursue collection through legal channels, including litigation like the present action against Defendant. Although the Account is now in litigation, Plaintiff remains willing to explore a mutually - beneficial solution through voluntary payment arrangements, if possible. 143465 FIRST CAUSE OF ACTION (Account Stated) 9. Plaintiff alleges and incorporates by reference the foregoing paragraphs. 10. Within the last four (4) years, Defendant became indebted on the Account to Plaintiff in the sum of $24,258.20 on an account stated in writing by and between Plaintiff and Defendant in which it was agreed that Defendant was indebted to Plaintiff. 11. Plaintiff has made demand on Defendant for repayment of the account stated but Defendant has failed and refused to pay the balance due. 12. As of the date of this complaint, there is a total amount due and owing of $24,258.20 (Please see attached documents) WHEREFORE, Plaintiff demands Judgment in its favor and against the defendant(s) in the amount of $24,258.20 plus court costs and interest. Date: <� � l MIDLAND ENDING LLC By: Daniel J. Santucci Attorneys for Plaintiff MIDLAND FUNDING LLC * 4 1 4 3 4 6 5 S C P 4- 1- 143465 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029 -0517 866 - 626 -5053 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 Cumberland San Diego, CA 92123 COUNTY, PA Plaintiff, CIVIL ACTION NO. VS. DEBORAH HARPER Defendant(s). AFFIDAVIT OF NON - MILITARY SERVICE 1 (�q�,� (u , being duly sworn according to law, depose and say I am the attorney for the plaintiff and I am authorized 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 Service member's Civil Relief Act of 2004 and any amendments thereto. I also hereby 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. Date: //� Z 3 - MIDL ING LLC By: Signature 143465 Verification Emily Walker, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ( "MCM "), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiffs behalf. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. "JUN o 4 20i Date Erm y W alker CAI 17 Midland Funding, LLC - Page - 2 - IIIIIII�IN�INIINIIINIIIINIII11b�I��IIN111NN � I�IIINIIINIIIINII�II�II�IIIIINNN - ` II�NNIIIIIII�IIIIII��III�ININNIII�1 0143465AFF2 -1- 8553178231 AFFINDEBTMEDIA Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: C Customer Service: HOME DEPOT CREDIT SERVICES myhomedepotaccount.com PO Box 790328, St. Louis, MO 63179 Account Inquiries: t ® 1- 866 - 458 - 7683 Summary of Account Activity Payment Information Previous Balance $23,699.02 New Balance $24 Payments -$0.00 Minimum Payment Due $3 Other Credits -$0.00 Payment Due Date November 20, 2011 Purchases +$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 +$524.18 Minimum Payment Warning: If you make only the minimum payment each New Balance $24,258.20 period, you will pay more in interest and it will take you longer to pay off your Past Due Amount $2,757.77 balance For example Credit Limit $0.00t� Available Credit $0.00 Only the minimum payment 37 years $68,398 Statement Closing Date 10/24/2011 $974 3 years $35,078 Next Statement Closing Date 11/23/2011 (Savings = $33,320) Days in Billing Cycle 31 It you would like Information about credit counseling services, call 1- 877- 337 -8188. Your minimum payment due is $3,559.77. To avoid interest charges, pay $24,258.20 by %; A14VTREES! P.Ati Fi S TAMPS, Register now for Paperless November 20, 2011 (residual interest may apply). EMI .,,, Statements and more at rrtyhornedepxotatccount.com TRANSACTIONS Trans Date Description Reference # Amount FEES 10/20 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 8HD15 NOTICE! SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, N.A. - - -- ----------------------------------------------------------------------------- - - - - -- ----- - - - - -- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. T Make Checks Payable to: HOME DEPOT CREDIT SERVICES 1 Past Due Amount is included in the Minimum Payment Due. iGj>:dp Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed ?>k'4Fr NOVEMBER 20, 2011 $24,258.20 $2,757.77 $3,559.77 $ HOME DEPOT CREDIT SERVICES PO BOX 182676 DEBORAH J HARPER COLUMBUS, OH 43218 -2676 1942 MONTEREY DR MECHANICSBURG, PA 17050 -8514 Print address changes above in blue or black ink. Information AboutNour Accouret. How to Avoid Paying Interest on Purchases. Your payment due date What To Do If YouThinkYou Find a Mistake on Your Statement is at least 25 days after the close of each billing cycle. We will not If you think there is an error on your statement, write to us at the charge you any interest on purchases if you pay your New Balance by Customer Service address shown on the front.. the payment due date each month. This is called a grace period on In your letter, give us the following information: purchases. if you do not pay the New Balance in full by the payment • ArcounF irfor^ ration Your name and account number due date, you will not get a grace period on purchases until you pay o �( The dollar amount of the suspected error. the New Balance in full for two billing cycles in a row. • lion 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. If you have a balance subject to a deferred interest, 0% APR or Equal You must contact us within 60 days after the error appeared on your Payment Plan promotion and that promotion expires before then , ay call u S b payment due date, that balance (the "excluded promotional balance ") state , b You must notify ut if you rte we are oat required any potential tr t l errors io InvastiInvestigate to wr itin g . potential You n 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 errors and you may have to pay the arriou rt in question. excluded promotional balance. In billing cycles in which payments are While we investigate whether or not there has been an error, the allocated to deferred interest balances first, the deferred Interest following are true: balance will be reduced before any other balance on the account, cannot try Jr) coaled the amount in question, or report you as t. delinquent on that amount. However, you �llt continue to get a grace period on purchases so long • The charge in question may remain on your statement, and we may as you pay the New Balance less any excluded promotional balances continue to charge you interest on that amount. But, if we determine that in full by the payment due date each billing cycle. We may refer to we. made a mistake. you will trot have to pay the amount in question or deferred interest promotions as No Interest promotions• any interest or other fees related to that amount. e While you do not have to pay the amount in question, you are In addition, certain promotional offers may take away the grace period responsible for the remainder of your balance. on purchases. Other promotional offers not described above may also . We can apply any unpaid amount against your credit limit. allow you to hav a grace period on purchases w ithout having to pay Your Rights If You Are DlssaNsfled With Your Credit Garcia Purchases all or a portion of the promotional balance by the payment due date. If If you are dissatisfied with the goods or services that you have either Is the case, the promotional offer will describe what happens. purchased with your credit card, and you have tried in good faith to Now We calculate Your Balance: Subject to Interest Rate. For each correct the problem with the merchant, you may have the right not to pay balance, the letter following the .Annual Percentage Rate in the Interest the remaining amount due on the purchase. Charge Calculation section on the front of the statement indicates the To use this right, all of the following roust be true: method we use to calcuiam interest charges. For Methods C. H and M, I. The purchase must have been made in your home state or within 100 we use a daily balance rnethod (including current transactions) to miles of your current mailing address, and the purchase price must calculate interest charges. For Methods I and 1.., we use an average have been more than. $50. Porte: Neither of these are necessary if daily balance method (including current transactions) to calculate your purchase was based on an advertisement we mailed to you, or I charges. For Method K, we use an average daily balance if we own the company that sold you the goods or services.} method (excluding current transactions) to calculate interest charges, 2.You must have used your credit card for the purchase. Purchases To find out more information about the balance computation method made with cash advances from an ATM or wfth a check that accesses that applies to your account and how the resulting interest charges your credit card account do not quality. were determined, contact us at the Customer Service number shown 3. You must riot yet have fully paid for the purchase. on the front. If all of the criteria above are met and you are still dissatisfied wit i the Credit Reporting Disputes. If you think we reported inaccuiale purchase, contact us in_writln�c. at the Customer Service address shown Information to a credit bureau write us at the Customer Service address on the front - shown on the front_ While we investigate, the same rules apply to the disputed amount as discussed above, After we finish our investigation, we will tell you our Report a Lost or Stollen card Immediately. Call the Customer Service decision. Atthat point, "we think you owe an amount and you do not pay number showy, on the front. we may report you as delinquent. KEY CRERITTERMS -- NO INTEREST IF PAID IN Fi LLWiTHIN d MONTHS * . $294 minimum purchase required. Minimum payments required. Interest will be charged to your account from the purchase data if the purchase balance (including premiums for optional credit insurance) Is not pold In full within 8 months or If you make a late payment. With credit approval for qualifying purchases made on The Home Depot or D(PO Resign Center Consumer Credit Card, 17.99°!0 - 26.99% APR. Minimum interest charge: $2. See card agreement for details including APR applioable to you. Offer is only valid for consumer accounts and is subject to chang without notice. — i Important Payment instructions, Payment Options Other Then Regular Mail. Right to Pray Your Account. You may �y all or part of your account •Orillne Payments. Vislt mytnwrier,epov and sign up for free balance at any tirria. However, you must. pay, by the payment due date, at least online payments. Enrollment rnay take a fear days. Uwe receive your request to the minimum payment due. make an online pact nt by 5 .m. Eastern time, we will credit your payment as Crediting Payments. If we receive your mailed payment in proper form at czar or that day and ft sxlll st within three business days. if we receive your request be credited as of processing facility by 5 p.m. proper form after that tame wi ll local time' here, d volt be ore sited as of that day. A to make an online payment after that time, we wriil credit your paymant as of the payment received there in ll y the next day and it will post within three business da�yys. For security reasons, you next day.. Allow 5 to '7 days Tar payments by regular mail to reach us. There may my be unable to pay your entire New Balance wrth your first online payment . be a delay of up to 5 days in creddanqq a payn rc?nt we raceirve that. is not in proper •Pay b� Phone Service. You may use this service any time to make a form or is not sent tD the correct ad lie correct address for regular mail pavmerrt phone, if your account is eligible. You will be charged $14.95 to use is the address on the front of the ppayment aauoan. A payment made in - store is this service :f a represents ive of ours helps exnedi e your payment. Gal! r 5 not sent to the correct adcTess. Tt� correct address for courier or express mail p m Eastern time #a hive corer payment craditexi as of that day and pasted is the Cxpress Payments Address shown below. within ttxee buBine.7s days. if you call after chat time, your payrrient w ill be Proper Form. For a payment sere by mat or ecw i^r to be in proper fom^, you mtt: credited as of the next ray arxi posted wifhln fhrec busirx ss delays. Are may • Ender e a valid check er money cycler made payable to Home Depot Credit process your payment electronically after we verily your identify. Services. No crash, gift cards, or foreign rurrenry please, *Express Payments. You can send payment by courier or express mat to the • include your n r tiid al rxxrt,%4 on the frost of yw che�;k or money arder. morass Payments Address. This address is: Customer Service Center, It you sand an eligible check with this payment coupo you authortze us Attention: Payment Wit Qraening, 1500 Boftonfield St., Columbus, 011 43228. to complete r payment try electronic do-bit. If we do, the checking Payment must to raceive In proper form at the proper address by 5 p.m. local account will be (do led in the amount on the checir, Wa may do this as time to be credited as of that day, All payments received in proper form at the soon as the day we receive the check. Also, the check will be destroyed. proper address after that time will be credited as of the next day. Cur Fee. We charge $b for each copy at a billing statement that Bats back 3 •in Store Payments. For your added convanier!ca, paymems can be made at moms or more. We add the fee to a balance of our choosing. We reserve the right The Horne Depot® storo s with no :service fee. Payments made at the store prior to add this fee to balances subject to a higher annua! percentage rate. We waive to the store closing time will be posted to your account as of that stay but the fee if your request for the copy relates to a balling error or dim led purchase. availability may be subject to verification of funds. Ht)fEX QCT'dt 9196 -0400- 0001 -X -E- 03101/00 -23- - 113- 90 -H17B- 06125!10- B- P- 5 -8 -N- - Page 2 of 4 Account 4948 TRANSACTIONS (cont. Trans Date Description Reference # Amount INTEREST CHARGED 10/24 INTEREST CHARGE ON PURCHASES $ 524.18 TOTAL INTEREST FOR THIS PERIOD � $ 524.18 Total Fees Charged in 2011 $175.00 l Total Interest Charged in 2011 $2,550.48 i INTEREST CHARGE CALCUL 77ON Your Annual Percentage Rate (APR) Is the annual Interest rate on your account. • .,� � ' r i t g... T4h' _'4� 1 r+9 , - ".:.. .� �: �; i,�t ..:� t w ns �,.y�.. r! • x�d,l.. F Sr ..•4 , :,. s,+.r � ?� ,..,. :,�" ._ .. ' s.) �'• ,r�` � ,s..�r. PURCHASES Rev ance 25. M $22 $498.88 MAJOR PURCHASE PLAN 21,99% M $385.17 $7.19 MAJOR PURCHASE PLAN 21.99% M $970.08 $18.11 Page 3of4 Account: 4948 Page 4of4 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated September 17, 2012, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank ") to Midland Funding LLC, organized under the laws of the State of Delaware, with its headquarters /principal place of business at 3111 Camino Del Rio North, Suite 1300, San Diego, CA 92108 ( "Buyer "). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated October 20, 2011, between Buyer and the Bank (the "Agreement "), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts listed in Asset Schedule and the final data file. With respect to information for the Accounts listed in Asset Schedule, to the best of the Bank's knowledge, the Bank represents and warrants to Buyer that (i) the Account information constitutes the Bank's own business records and accurately reflects in all material respects the information in the Bank's database; (ii) the Account information was kept in the regular course of business; (iii) the Account information was made at or near the time by, or from information transmitted by, a person with knowledge of the data entered into and maintained in the Account's database; and (iv) it is the regular practice of the Bank's business to maintain and compile such data. Citibank, N.A. By: (Signature) Name: Patricia Hall Title: Financial Account Manager Field Field Data ACCOUNT NUMBER 94 ACCOUNT NUMBER CROSS - REFERENCE NUMBER 5766 ACCOUNT OPEN DATE 3/25/2000 CHARGE OFF AMOUNT 24258.2 CHARGE OFF DATE 10/25/2011 CO- BORROWER FIRST NAME HARPER DEBTOR BIRTH DATE 11/30/1965 DEBTOR NAME FIRST DEBORAH J DEBTOR NAME LAST HARPER DEBTOR RESIDENCE ADDRESS 1 1942 MONTEREY DR DEBTOR RESIDENCE CITY MECHANICSBURG DEBTOR RESIDENCE PHONE 7176572679 DEBTOR SOCIAL SECURITY NUMBER * * ** *2423 DEBTOR STATE PA DEBTOR ZIP CODE 170508514 LAST PAYMENT AMOUNT 425 LAST PAYMENT DATE 5/22/2011 LAST PURCHASE DATE 3/14/2010 SALE AMOUNT 24258.2 Data printed by Midland Credit Management, Inc. from electronic records provided by Citibank, N.A. pursuant to the Bill of Sale / Assignment of Accounts transferred on or about 9/17/2012 in connection with the sale of accounts from Citibank, N.A. to Midland Funding LLC. Contact Information: Tel: (866) 626 -5053 Ads% M Facsimile: (877) 291 -8938 Ar NA P.O. f3ox 939033, San Diego, CA 92193 midland credit management, inc. July 16, 2013 To: To the Sheriff of Cumberland One Courthouse Square Carlisle, PA 17013 RE: Midland Funding, LLC v. Deborah Harper Cumberland County Docket Number: TO THE SHERIFF OF CUMBERLAND, Please serve the defendant(s) at the following address(s); DEBORAH HARPER 1942 Monterey Dr Mechanicsburg, PA 17050 Sincerely, Daniel J. Santucci, Esquire Attorney for Plaintiff Daniel.Santucci@mcmcg.com Enc. 111111111111111111111111111111111111 11 * Q 1 4 3 4 6 5 P O S 4- 1- 143465 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029 -0517 866 - 626 -5053 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 Cumberland San Diego, CA 92123 COUNTY, PA Plaintiff, CIVIL ACTION NO. VS. /3 DEBORAH HARPER Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above captioned matter on behalf of PLAINTIFF MIDLAND FUNDING LLC Papers may be served at the address set forth below: Daniel J. Santucci, Esquire _ v" P.O. BOX 517' MM - TI Essington, PA 19029_ - cn r r"� Telephone Number 866 - 626 -5053 2 ' c. Date: By: Daniel J. Santucci Attorneys for Plaintiff MIDLAND FUNDING LLC 143465 SHERIFF'S OFFICE OF CUMBERLAND COUNTY-r ::. L1_u—a.. : tC= Ronny RAnderson irf i € 0T19 0 i-1 r a I Sheriff 040xtn Wt ian � l rl 13 ��l 1 AK 10 ' ' n, Jody S Smith : , Chief Deputy Cl Richard W Stewart P4 �dSYLV�� )t� Solicitor OFPIC ,1FTk'.'sPpslr Midland Funding LLC Case Number vs. Deborah J Harper 2013-4256 SHERIFF'S RETURN OF SERVICE 07/29/2013 05:18 PM-Deputy Amanda Cobaugh, 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: Deborah J Harper at 1942 Monterey Drive, Hampden Township, Mechanicsburg, PA 17050. �&J� AWMID3\COBAUGH, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, July 30, 2013 R-ONO R ANDERSON, SHERIFF (c)CountySuite Sheriff:Teleosoft,Inc. Daniel J. Santucci, Esq. Attorney ID #92800 P.O. BOX 517 `I H L L Essington PA 19029-0517 ' } u T ` 0 T 866-626-5053 7013 tCT 22 PH 2: 5 I MIDLAND FUNDING LLC IN THE COURT OP u', T 8875 Aero Drive, Suite 200 CUMBERLAND CO IE,ipxLvA NI A San Diego, CA 92123 CIVIL ACTION Plaintiff, NO. 13-4256 vs. DEBORAH HARPER Defendant(s). PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice Respectfully sue i d, Danligntucci, E �! 111 111 11111,1 111111 I 1111 * 4 1 4 3 4 6 5 D J D 4 - 1 - * Daniel J. Santucci, Esq. Attorney ID#92800 P.O. BOX 517 Essington PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS 8875 Aero Drive, Suite 200 CUMBERLAND San Diego, CA 92123 COUNTY, PA Plaintiff, CIVIL ACTION NO. 13-4256 vs. DEBORAH HARPER Defendant(s). CERTIFICATE OF SERVICE I Daniel Santucci, Esquire, counsel for the plaintiff, do hereby certify that I sent a true and correct copy of this Praecipe to dismiss Without Prejudice, to the Defendant or if represented to the Defendant's attorney at the below listed address. DATE: (0 Deborah Harper 1942 Monterey Dr Mechanicsburg, PA 17050 .4616 Dan J. Santucci, Esquire