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HomeMy WebLinkAbout13-4273 Supreme Court of Pennsylvania For Prothonotary Use Only: Court of Common Pleas Docket No: Civil i Cover Sheet 13 . 40�2 t�, CUMBERLAND County The information collected on this form is used solely for court administration purposes. This form does not su lement or replace theftiling 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. TINA M GORDON T I O Any money damages requested ?: ® Yes ❑ 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 Se] 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 most 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: • Other Professional: w r; U 13 JUL 22 PH 12: 46 C UMBERLt� 9) COUNTY PENNSYLVANIA 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. TINA M GORDON NO. i3 7d� 7 Northview Drive 23 Carlisle PA 17013 -9654 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 Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 A93. l e'( - 0 4 Telephone No. 717- 249 -3166 or 800 - 990 -9108 C -61269 / 304 4 BURTON NEIL & ASSOCIATES, P.C. Edward J. O'Brien, Esquire, Id. No. 32985 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. TINA M GORDON 7 Northview Drive Carlisle PA 17013 -9654 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 Tina M Gordon who resides at 7 Northview Drive, 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 3473. 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 $6,802.77 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 $6,802.77, and the costs of this action. B on ciates, P.C. rd B . dw J. O'Brien, Esquire y: 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 -61269 / 205 Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: HOME DEPOT CREDIT SERVICES (y SHOP �� a myhomedepotaccount. corn PO Box 790328, St. Louis, MO 63179 ANYTIME, ® Account Inquiries: Acebunti�lurnber 3#73. ANYWHERE! rxduNE rt0 IN 1 -866- 458 -7683 Summary of Account Activity Payment Information Previous Balance $6,646.78 New Balance $6 Payments -$0.00 Minimum Payment Due $1 Other Credits -$0.00 Payment Due Date April 10, 2013 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 +$120.99 Minimum Payment Warning: If you make only the minimum payment each New Balance $6,802.77 period, you will pay more in interest and it will take you longer to pay off your balance. For example: Amount ,.: -_ -. _ _ -- - _ - __ __ Past Due A 803.00 ti �,Eytt3�+r�iak� +ai9dt6�orfaf vir�ay�f#'tt�ey i � ,gridynl#yu��� � charge §�strlg�his£arci �alartc��sflown arl this- 'iellcktt�tiie ara Credit Limit $0.00 c- a�td _eac,rnonthyoifpa�lStne Available Credit $0.00 Only the minimum payment 21 years $19,533 Statement Closing Date 03/14/2013 $283 3 years $10,189 Next Statement Closing Date 04/12/2013 1 1 1 (Savings= $9 ,344) Days in Billing Cy 31 If you would like information about credit counseling services, call 1- 877 -337 -8188. Your minimum payment due is $1,028.00. To avoid interest charges on your non - promotional (revolving) balance and any expiring promotions, pay $5,573.68 by April 10, 2013. If you pay your non - promotional balance in full every month, no additional billed interest charges will apply. Interest accrues daily 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 $1,229.09 in full by 02110/14 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 my omedepotaccount com or go to your local The Home Depot store. Please see the enclosed privacy notice for important information. Your tax refund can help bring your account up to date. Many customers have resolved overdue amounts by using their tax refund money. It's simple and convenient. If you're not expecting a refund, we may have payment options available. - °- - ° -- - »Call 1 -866- 518 -6160 today. For our TDD line call 1400- 995-9305. AHnA PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4 Page 1 of 6 This Account is Issued by Citibank, NA + Please detach and return lower portion with your payment to insure proper credit Retain upper portion for your records_ _ y ------------- --- ----- ------- -- ------ ------ --------------- -- -------- -----` Your Account Number i 3473 P.O. Box 790393 ` St. Louis, MO 63179 Payment Due Date April 10, 2013 ti New Balance $6,802.77 Past Due Amountt $803.00 Minimum Payment Due $1,028.00 Statement Enclosed. Arr�ourt# Encloea » TPast Due Amount is included in the Minimum Payment Due Print address changes on the reverse side Make Checks Payable tow HOME DEPOT CREDIT SERVICES TINA M GORDON PO BOX 182676 7 NORTHVIEW DR COLUMBUS, OH 43218 -2676 CARLISLE, PA 17013 -9654 03000 0102800 0680277 0017500 3473 O A A H I B I T A Information About Your Account. Proper Form. For a payment sent by mail or courier to be in proper form, How to Avoid Paying Interest on Purchases. Your payment due date you must: is at least 25 days after the close of each billing cycle. We will not charge Enclose a valid check or money order made payable to Home Depot you any interest on purchases if you pay your New Balance by the Credit Services. No cash, gift cards, or foreign currency please. payment due date each month. This is called a grace period on purchases. Include your name and account number on the front of your check If you de not pay the New Balance in full by the payment due date, you or money order. will not get a grace period on purchases until you pay the New Balance in If you send an eligible check with this payment coupon, you authorize full for two billing cycles in a row. us to complete your payment by electronic debit. If we do, the If you have a balance subject to a deferred interest or 0% APR promotion checking account will be debited in the amount on the check. We and that promotion does not expire before the pays lent due date, that may do this as soon as the day we receive the check. Also, the check balance (the "excluded balance ") is excluded from the amount you will be destroyed. must pay in full to get a grace period_ However, you must still pay any separately required payment on the excluded balance. in billing cycles Copy Fee. We charge $5 for each copy of a billing statement that dates in.mhich payments are allocated to deferred interest balances first, the back 3 month=_ or more. We add the fee to a balance of our choosing. We reserve the right to add this fee to balances subject to a higher annual deferred interest balance will be reduced before an W . We other balance oil the account. However, you will continue to get a grace period on purchases so Percentage ratee waive the fee it year request for the copy relates Iona as you pay the New Balance less any excluded balances in full by the to a billing error or disputed purchase. payment due date each billing cycle. We may refer to deferred interest Payment Options Other Than Regular Mail. promotions as No Interest promotions. online Payments. Visit myhomedepotaccount.com and sign up for In addition, certain promotional offers may take away the grace period on free online payments. Enrollment may take a few days. if we receive purchases. Other promotional offers not described above may also allow your request to make an online payment by 5 p.m. Eastern time, we you to have a grace period on purchases without having to pay will credit your payment as of that day and it will post within three all or a portion of the promotional balance by the payment due date. business days, If we receive your request to make an online payment If either is the case, the promotional offer will describe what happens. after that time, we will credit your payment as of the next day and it . How We Calculate Your Balance Subject to Interest Rate. For each will post within three business days. For security reasons, you may be balance, the letter followin the Annual Percentage Rate in the Interest unable to pay your entire New Balance with your first online payment. Charge Calculation section on the front of the statement indicates the AutoPay Service. If you are enrolled in this service, your payment method we use to calculate interest charges. For Methods C, H and M, amount will be deducted automatically each month on your due date we use a daily balance method (including current transactions) to from the bank account you select. calculate interest charges. For Methods I and L, we use an average Pay by Phone Service. You may use this service any time to make daily balance method (including current transactions) to calculate a payment by phone, if your account is eligible. You will be charged interest charges. For Method K, we use an average daily balance method $14.95 to use this service if a representative of ours helps expedite (excluding current transactions) to calculate interest charges. To find your payment. Call by 5 p.m. Eastern time to have your payment out more information about the balance computation method that credited as of that day and posted within three business days_ If you applies to your account and how the resulting interest charges were call after that time, your payment will be credited as of the next day determined, contact us at Customer Service number on the front. and posted within three business days. We may process your payment Important Payment instructions. electronically after we verify your identity. Right to Prepay Your Account. You ,-nay pay all or part of your account Express Payments. You can send payment by courier or express mail to the Express Payments Address. This address is: Customer balance at any time. However, you must pay, by the payment due date, at Service Center, Attention: Payment Mail Opening, 1500 Boltonfield 5t., least the minimum payment due. Columbus, OH 43228. Payment must be received in proper form at the Crediting Payments. If we receive your mailed payment in proper form proper address by 5 p.m. Eastern time to be credited as of that day. at our processing facility by 5 p.m. local time there, it will be credited as All payments received in proper form at the proper address at that of that day. A payment received there in proper form after that time will time will be credited as of the next day. be credited as of the next day. Allow 5 to 7 days for payments by regular In -Store Payments. For your added convenience, payments can be mail to reach us. There may be a delay of up to 5 days in crediting a made at The Home Depot' stores, with no service fee. Any payment payment we receive that is not in proper form or is not sent to the correct in proper form accepted in-store will be credited as of that day. address. The correct address for regular mail is the address on the front However, credit availability may be subject to verification of funds. of the payment coupon. The correct address for courier or express mail is the Express Payments Address in the Express Payments section. PLEASE SEE IMPORTANT INFORMATION ON PAGE 4 HD-2 JAN13 Page 2 of 6 Change of Address Print address changes in blue or black ink. 'AMPS E IM - AND 1 REED Register now for Paperless Statements and more at myhomedepotaccount.com ' Account: * * ** * ** * ** 3473 TRANSACTIONS Trans Date Description Reference # Amount FEES 03/10 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 03/14 INTEREST CHARGE ON PURCHASES $ 120.99 TOTAL INTEREST FOR THIS PERIOD $ 120.99 Total Fees Charged in 2013 $105.00 Total Interest Charged in 2013 $341.75 Original Previous Payments Billed New Promo Deferred Trans Trans Promotion and Interest Promotion Monthly Interest Expiration PROMOTIONS Amount Date Balance Credits Charges Balance Payment Charges Date NO INT FOR 18MOS - PMT REQ $1,229.09 07/24/12 $1,229.09 - $1,229.09 - $222:69 02110/14 INTER CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual interest rate on your account. _,n..,, . rc _ .... . * Aitquat.een i:l3atePA , _ .- .Balaticett �ctfp lttberest.Rate ff1}etesra r` PURCHASES Revolving Balance 25.99% M $5 $120.99 NO INT FOR 18MOS -PMT REQ 25.99% M Page 3 of 6 Credit Reporting Disputes. If you think we reported inaccurate After we finish our investigation, one of two things will happen: information to a credit bureau write us at the Customer Service address If w made a mistak You will not have to pay the amount in question shown on Page 1. or any interest or other tees related to that amount. Report a Lost or Stolen Card Immediately. Call the Account Inquiries If we do not b elieve there was a mis You will have to pay the number shown on Page 1. amourit in question, along with applicable interest and fees. We will What To Do If You Find A Mistake On Your Statement send you a statement of the amount you owe and the date payment If you think there is an error on your statement, write to us at the is due. We may then report you as delinquent if you do not pay the address for billing inquiries and correspondence shown on Page 1 amount we think you owe. of your statement. if you receive our explanation but still believe your bill is wrong, you In your letter, give us the following information: must write to us within 10 days telling us that you still refuse to pay. Ef you do so, we cannot report you as delinquent without also reporting Account information: Your name and account number, that you are questioning your bill. We Must tell you the name of Dollar amount: The dollar amount of the suspected error. anyone to whom we reported you as delinquent, and we must let those Description of problem: If you think there is an error on your bill, organizations know when the matter has been settled between us. describe what you believe is wrong and why you believe it is a mistake. If we do not follow all of the rules above, you do net have to pay the You must contact us: first $50 of the amount you question even if your bill is correct. Within 60 days after the error appeared on your statement. Your Rights if You Are Dissatisfied With Your Credit Card Purchases At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goods or services that you have purchased if you want to stop payment on the amount you think is wrong. with your credit card, and you have tried in good faith to correct the You must notify us of any potential errors in writing You may call us, problem with the merchant, you may have the right not to pay the but if you do we are not required to investigate any potential errors and remaining amount due on the purchase. you may have to pay the amount in question. To use this right, ail of the following must be true: tff at y¢`ili Happen After We R eceive Your Letter 1. The purchase must have been made in your home state or within 100 When we receive your fetter, we must do two things miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if 1. Within 30 days of receiving your letter, we must tell you that your purchase was based on an advertisement we mailed to you, or we received your letter. We will also tell you if we have already if we own the company that sold you the goods or services.) corrected the error. 2. You must have used your credit card for the purchase. Purchases 2. Within 90 days of receiving your letter, we must either correct made with cash advances from an ATM or with a check that accesses the error or explain to you why we believe the bill is correct. your credit card account do not qualify. While we investigate whether or not there has been an error: 3. You must riot yet have fully paid for the purchase. We cannot try to collect the amount in question, if all of the criteria above are met and you are still dissatisfied with the or report you as delinquent on that amount. purchase, contact us in writing at the address for billing inquiries and The charge in question may remain on your statement, correspondence shown on Page 1 of your statement. and we may continue to charge you interest on that amount. While we investigate, the tame rules apply to the disputed arnount as While you do not have to pay the amount in question, discussed above. After we finish our investigation, we will tell you our you are responsible for the remainder of your balance. decision. At that point, if we think you owe an amount and you do not We can apply any unpaid amount against your credit limit. pay, we may report you as delinquent. KEY CREDIT TERMS - NO INTEREST IF PAID IN FULL WITHIN 6 (MONTHS *. $299 minimum purchase required. Minimum payments required. Interest will be charged to your account from the purchase date if the purchase balance (including premiums for optional credit insurance) is not paid in full within 6 months or if you make a late payment. *With credit approval for qualifying purchases made on The Home Depot or EXPO Design Center Consumer Credit Card, 17.99 % - 26.99% APR. Minimum interest charge $2. See card agreement for details including APR applicable to you. Offer is only valid for consumer accounts and is subject to change without notice. T02918- 9198-0400 - 0002 -E-0 -X -07/01 /05-05- 113-P- 8-0- 4- 5- 0- NOPLAY -TC -02/13112 -H53B- February 11, 2013 -0-0 N— PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 HD-4 JAN13 Page 4 of 6 01/13 075 WHAT DOES CITIBANK DO WITH YOUR PERSONAL INFORMATION? _ .... ... _ ... .. _........._.. _.._. __..._ _......_........_...-..__. ._._........_.._ ............... _.._ ..... ... .... _.__....... _.._..._ .__. _.._...__..... _.; Financial companies choose how they share your personal information. ` r Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect t - your personal information. Please read this notice carefully to understand w' . •_ �� what we do. sd , "��......._ _.. _ . _ _ _ _ . ......... _ . .... _ ;.., .. ............... ....... :..::.::.....::...:.:........:.::.::.:::..::::.:.:...::.: ::::::.......::........:....... ......... ............................... The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number and income _ • account balances and employment information credit history and transaction history -- ...._..... - -- — ----- ---- .._... - — ......_.._..._.._.... -- .... .. ----------•------------------------- v �_,. All financial companies need to share customers' personal information 4 to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Citibank chooses to share; and whether you can limit this sharing. -- I For our everyday business purposes such as to process your transactions, r maintain your account(s), respond to court Yes No orders and legal investigations, or report tto credit bureaus .......... ....__.._.__.._.._.......----......._.._..----..__.._.__.._ ............ ._._.__....._...._....._......_ ._..._..__._....._....___...__.._.._.._...__.._.._.._.._...._.._.._ ......_.....__..- _- .__.__.._.._ ..._.._. ._.._......_._..._..__._..._..; For our marketing purposes — i to offer our products and services to you Yes No ...- - _.._....._.._.... -- - - ..... .._----------------- - - - - -- _.... _..__....._._.. For joint marketing with other `financial companies Yes No For our affiliates` everyday business purposes — information about your Yes No transactions and experiences - -- - - - ----- -.._.. For our affiliates' everyday business purposes — information about your Yes Yes creditworthiness For our affiliates to market to you Yes Yes i ............ - - For our nonaffiliates to market to you Yes Yes ....... ... -- ....................................... .................................................. ..._..- .._......__............. ....... ; Call 1- 877 - 491 -0607 — our menu will prompt you through your choice(s). Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us any time to limit our sharing. Call 1- 877 - 491 -0607 or call the Customer Service number on the back of your credit card or on your billing statement. _.._...._._. ........ _ _ ._... _ _.._...._ _. _..._... _.._..._..__. ___ _.._......._..._....._ _._..__._ ......_ ................. ........... _._.._.....__..._ _....': r Page 5of6 01/13 076 � N M 'ems., M . I NS 'Who is providing You are receiving this notice from the retail partner cards group of this notice? 'Citibank, N.A., the bank that issues your credit card. How does Citibank To protect your personal information from unauthorized access and use, we protect my personal use security measures to comply with federal law. These measures include information? computer safeguards and secured files and buildings. How does Citibank We collect your personal information, for example, when you ;collect my personal • provide account information or give us your contact information information? • provide employment information or apply for a loan use your credit or debit card We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. ........ . .... --_....._...._..._ .._.._..._..._....... ....._.... __.._.._...._.._...._...._..._. Why can't I limit Federal law gives you the right to limit only all sharing? ; • sharing for affiliates' everyday business purposes — information about your creditworthiness • affiliates from using your information to market to you • sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit .... sharing. See below for more on your rights under state law. Affillates Companies related by common ownership or control. They can be financial '•. and nonfinancial companies. • Our affiliates include companies with a Citi name; financial companies I such as Citigroup Global Markets Inc. and Banamex USA. _ ......................_.__..... __._....---- ._..___.___.._.._;. _._....__.._._.._..._....... _.._........._.... ......._.___..__..__.___....__....__.._......_._..._._._...__......__..__._...._..__ ......... _._. ..------- _._.__..__...___._.__; Nonaffiliates 'Companies not related by common ownership or control. They can be ;financial and nonfinancial companies. • Nonaffiliates we share with can include companies engaged in direct marketing and the selling of consumer products and services. Joint marketing A formal agreement between nonaffiliated financial companies that I together market financial products and services to you. �Y a C 8 8 P •8�� For Vermont Residents: We will not share information we collect about you with nonaffiliated third: parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account. In addition, we will not share information about your creditworthiness with our affiliates except with your authorization. For California Residents: We will not share information we collect about you with nonaffiliated third; parties, except as permitted by California law, such as to process your transactions or to maintain your account. We may share your personal information, as permitted by law, with the retailer whose name is on your card and with the companies related to the retailer. You cannot limit this sharing. Important Information about Credit Reporting We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. Page 6 of 6 Verification I, KAT HY 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. Date: ( JSignae C -61269 Tina M Gordon Account number ending 3473 1025 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff i HI: PROTHO�q���h;(-; � Jody S Smith ° Chief Deputy 1013 AUG - 1 0 IG: 34- Richard W Stewart ��..�ffpp �°°[[ p, !_` Solicitor OFFICE OF TI-ESWEi4F- '�,;�„tt�BERLAiQ GOW4� d� PENIS YLVAMA Citibank, N.A. vs. Case Number Tina M Gordon 2013-4273 SHERIFF'S RETURN OF SERVICE 07/29/2013 08:58 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: Tina M Gordon at 7 North View Drive, North Middleton, Carlisle, PA 17013. p SON KINSLER, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, July 30, 2013 RbNW R ANDERSON, SHERIFF (c)CountyS.ulte Sheriff,Toleosoft,Inc, A. C-61269/221 CITIBANK,N.A. : IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 cis e+.a `: Plaintiff : CUMBERLAND COUNTY,PENNSYL NI. _.., E,2, O V. "C r , NO. 13-4273 CIVIL 4- TINA M GORDON r""z —I cp 7 Northview Drive 1+t-, me —11 Carlisle PA 17013-9654 A o Defendant : CIVIL ACTION-LAW .-+ Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: $6,802.77 TOTAL $6,802.77 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys,if any,after the default occurred,and at least ten days prior to the date of the filing of this praecipe. 3. 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. JUDGMENT BY DEFAULT ENTERED B .r : r, :• :.ii=r.s+•iat; P.C. AND MA SAS SSED AS AVE. , _/ ir/p,NOTIC GIVE UN PA.R.CI, . . 236 B . .I�►, �f�fi B r' J. Suttl uire ~'V A orney fo miff Pro' rothonotary I.D. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 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. /4,-- -Z--) pi. Ct4 . :,p,_:., -el% £# /31.1 a7y' lili-,...... `J1 rucl C-61269/265 CITIBANK, N.A. ' : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY- PENNSYLVANIA v. : NO. 13-4273 CIVIL TINA M GORDON Defendant : CIVIL ACTION - LAW TO: Tina M Gordon 7 Northview Drive Carlisle PA 17013-9654 DATE OF NOTICE: October 12, 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 (10) 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 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 REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 P.p.: .,;1., trton Neil A.- ociates. P.C. �•.. 13 L` �I,•V But .I. Sot I, Esquire Attorney •or Plaintiff This is an attempt to collect a debt, and any information Identification No. 204140 obtained will be used for that purpose. "Ibis 1060 Andrew Drive, Suite 170 communication is from a debt collector. West Chester, PA 19380 (610) 696-2120 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 Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 13-4273 CIVIL TINA M GORDON 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 -71 at) . C/ . ,2c9/3 Prothonotary Deputy If you have any questions concerning the above, please contact: Brit J. Suttell, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 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.