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HomeMy WebLinkAbout13-4984 Supreme C© nnsylvania COu Cobh leas For Prothonotary Use Only: , TAM .� Docket No: F �u d ^� .S C 'Ian � 9 tiA 9 County / The information collected on this form is used solely for court administration purposes. This form does not supplement or replace t he filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: j G Complaint ® Writ of Summons ® Petition ® Transfer from Another Jurisdiction [3 Declaration of Taking E - Lead Plaintiff's Name: Lead Defendant's Name: American Express Centurion Bank,a Utah state chartere6 BRIAN DANZIS T Dollar Amount Requested: within arbitration limits Y Are money damages requested? Yes E3 No (check one) outside arbitration limits O N Is this a Class Action Suit? [3 Yes El No Is this an MDJAppeal? ® Yes El No A Name of Plaintiff/Appellant's Attorney: DEMETRIOS H TSAROUHIS 130330 ® Check here if you have no attorney (are a Self- Represented [Pro Sej 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. j TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional 13 Buyer Plaintiff Administrative Agencies E3 Malicious Prosecution 8 Debt Collection: Credit Card [3 Board of Assessment Motor Vehicle ® Debt Collection: Other © Board of Elections ® Nuisance U Dept. of Transportation 0 Premises Liability Statutory Appeal: Other 4 S ® Product Liability (does not include mass tort) E [3 Employment Dispute: 0 Slander/Libel/ Defamation Discrimination C ® Other: E3 Employment Dispute: Other ® Zoning Board T+ ® Other: A I — ® Other: O MASS TORT E3 Asbestos N ® Tobacco ® Toxic Tort -DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: 13 Ejectment ® Common Law /Statutory Arbitration B Eminent Domain/Condemnation ® Declaratory Judgment (� Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Residential Restraining Order Mortgage Foreclosure: Commercial ® Quo Warranto j ® Dental Q Partition 13 Replevin E3 Legal [] Quiet Title ® Other: 13 Medical ® Other: i ® Other Professional: l Updated 1/1/2011 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW American Express Centurion Bank,a Utah state chartered bank r� Plaintiff r V. No. wo , BRIAN DANZIS - Defendant ` -` 7- � • 130330.001 4.61 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 34 S. Bedford Street Carlisle, Pennsylvania - telephone number 717 - 249 -3166 I do hereby certify that the within is a true and correct copy o he original filed in this action. Demetrios H Tsarouhis oe Q /# /y3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW American Express Centurion Bank,a Utah state chartered bank, Plaintiff V. No. BRIAN DANZIS, Defendant ]30330.00]/ COMPLAINT Plaintiff, American Express Centurion Bank,a Utah state chartered bank, by and through its counsel, Demetrios H. Tsarouhis, files this Complaint and aver as follows: 1. Plaintiff, American Express Centurion Bank,aUtah state chartered bank, ( "Plaintiff") is a UT business corporation having its corporate offices at 4315 S 2700 W, SALT LAKE CITY UT 84184. 2. Defendant, BRIAN DANZIS , is an adult individual resident of Pennsylvania who maintains an address at 301 CHESTNUT RIDGE DRIVE , MECHANICSBURG PA 17055. 3. At all relevant times herein, Plaintiff was engaged in the business of extending credit to potential clients. 4. Defendant applied for and received a credit card issued by Plaintiff with the account number ending in * * * * * * * ** *84007. 5. Use of the credit card was subject to the terms and conditions of the Cardmember Agreement (hereinafter "Agreement "). Incorporated herein by reference as if set forth herein at length and attached as Exhibit "A" is a true and correct copy of the Cardmember Agreement. 2 6. Defendant used the credit card with account number ending in * * * * * * * * * * 84007, for purchases, cash advances and /or balance transfers. Use of the card in this manner constituted acceptance of the terms and conditions and subjects the Defendant to the terms and conditions contained therein. 7. The Defendant was mailed monthly account statements relative to the Defendant's use of the subject credit card. Incorporated herein by reference as if set forth herein at length and attached as Exhibit `B" is a true and correct copy of the most recent statement. 8. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 9. The account became delinquent on or about 10/19/2011 and Defendant has failed to pay any amounts since that time. 10. The principal amount due at such time was $21,813.53. 11. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows: a) Judgment in the amount of $21,813.53 due on the account; b) Costs of suit; COUNT II Alternative to Count I - Unjust Enrichment 12. Plaintiff incorporates the allegations of every paragraph enumerated above this Complaint as if said paragraphs were fully set forth here at length. 13. At Defendant's request, Plaintiff conferred a benefit upon Defendant by providing the credit described in the exhibits attached hereto. 3 14. Defendant received and accepted the benefit of said credit provided by Plaintiff. 15. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid credit to Defendant and that Plaintiff expected to be paid for such. 16. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide said credit and to incur damages. 17. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said credit without paying Plaintiff fair and reasonable compensation. 18. Allowing Defendant to retain the benefit of said credit without paying fair compensation would be unjust. 19. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs expense, an implied contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff the quantum meruit value of the credit described in the exhibits attached hereto in the amount of $21,813.53. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows: a) Judgment in the amount of $21,813.53 due on the account; b) Costs of suit. Respectfully Submitted, DC DEMETRIOS H. TSAROUHIS I.D. #88513 Attorney for Plaintiff 21 S. 9 th Street —Suite 200 Allentown, PA 18102 610 - 439 -1500 Date: August 6, 2013 130330.001 4 Cardmember Agreement: Part 1 of 2 As of 01/10/2011 Platinum Card@ Cardmember Name: Brian E Danzis Issuer: American Express Centurion Bank Account Ending In: 83009 Rates and Fees Table Interest Rates Annual Percentage Rate 15 .24% (APR) This APR will vary with the market based on the Prime Rate. Penalty APR and When it 27.24% Applies This APR will vary with the market based on the Prime Rate. This APR will apply to your account if you: 1) make one or more late payments; or 2) make a payment that is returned. How Long Will the Penalty APR Apply? If the Penalty APR is applied, it will apply for at least 6 months. We will review your Account every 6 months after the Penalty APR is applied. The Penalty APR will continue to apply until you have made timely payments with no returned payments during the 6 months being reviewed. Paying Interest Your due date is at least 25 days after the close of each billing period. We will begin charging interest on charges as of the date they are added to a Pay Over Time balance, including Select & Pay Later. We will not charge interest on charges added to a Pay Over Time balance automatically if you pay the Account Total New Balance by the due date each month. Annual Membership Fee $450 Transaction Fees • Foreign Transaction 2.7% of each transaction after conversion to US dollars. Penalty Fees • Late Payment Up to $35; however, if you do not pay for two billing periods in a row, our fee will be $35 or 2.99% of the past due amount, whichever is greater. • Returned Payment Up to 35 How we calculate interest: We use the Average Daily Balance method (including new transactions). See the How we calculate interest section in Part 2. Your Billing Rights: See Part 2 for information on how to exercise your rights to dispute transactions. CMAEUAA00000101 Page 1 of 9 Exhibit "_� How Rates and Fees Work Rates for Pay Over Time balances See About Pay Over Time features in Part 2 of this Agreement Calculating The Annual Percentage Rate (APR) for variable rates is determined by adding an amount (margin) APRs and DPRs to the Prime Rate (see Determining the Prime Rate in Part 2). The Daily Periodic Rate (DPR) is 1/365th of the APR, rounded to one ten - thousandth of a percentage point. Rate Description Prime + Margin APR DPR Annual Percentage Rate Prime + 11.99% 15.24% 0.0417% Penalty APR Prime + 23.99% 27.24% 0.0746% Penalty APR for The penalty APR applies to new transactions if: If the Penalty APR applies to a balance, it will new transactions • you do not pay at least the Minimum Payment apply to charges added to that balance 15 or Due by the Closing Date of the billing period more days after we send you notice. in which it is due 3 times in 12 billing periods, • you do not pay at least the Minimum Payment We will review your Account every 6 months after Due by the Closing Date of the billing period the Penalty APR is applied. The Penalty APR will in which it is due and you still do not pay it by continue to apply until you have made timely the Closing Date of the next billing period, or payments with no returned payments during the • your payment is returned by your bank. 6 months being reviewed. Penalty APR for If you do not pay at least the Minimum Payment Due within 60 days after its Payment Due Date, we existing balances can apply the penalty APR to those balances it does not already apply to. After you pay on time for 6 billing periods in a row, the penalty APR will no longer apply to those balances (but it may still apply to other balances as described above). Annual Membership This fee is on the Rates and Fees Table on page 1 of Part 1. We will charge $175 for up to 3 additional Platinum Cards, $175 for each additional Platinum Card after the first 3, $45 for up to 5 additional Gold Cards, and $45 for each additional Gold Card thereafter. Late Payment Up to $35 or 2.99% of the amount past due. If you do not pay the Amount Due on a billing statement before the 20th day after the next Closing Date, the fee is $25. If this happens again within the next 6 billing periods, the fee is $35 instead. In both cases, if you do not pay the amount past due by the following Closing Date, we will charge, in that same billing period, the greater of $35 or 2.99% of the amount past due. For each subsequent billing period that an amount past due remains unpaid, the fee is the greater of $35 or 2.99% of any amount past due. However, the late fee will not exceed the Minimum Payment Due. Paying late may also result in a Penalty APR. See Penalty APR for new transactions and Penalty APR for existing balances above. Returned Payment Up to $35. If your payment is returned unpaid the first time we present it to your bank, the fee is $25. If this happens again within the next 6 billing periods, the fee is $35. However, the returned payment fee will not exceed the Minimum Payment Due on the last Payment Due Date before the payment is returned. A returned payment may also result in a Penalty APR. See Penalty APR for new transactions above. Returned Check $38 if you use your card to cash a check at one of our approved locations and the check is returned unpaid. We will also charge you the unpaid amount. Statement Copy $5 for each statement you request, except for the 3 most recent billing periods. Account Re- opening $25 if your Account is cancelled, you ask us to re -open it, and we do so. Foreign Transaction 2.7% of the converted U.S. dollar amount. This fee is a finance charge. See Converting charges made in a foreign currency in Part 2. Part 1, Part 2 and any supplements or amendments make up your Cardmember Agreement. CMAEUAAO0000101 Page 2 of 9 I ! rx� L Car Ag P 2 of 2 CD 27737 Introduction About your This document together with Part 1 make up the supplements or amendments are also part of the Cardmember Agreement Cardmember Agreement (Agreement) for the Agreement. When you use the Account (or you sign Account identified on page 1 of Part 1. Any or keep the card), you agree to the terms of the Agreement. Changing the Agreement We may change this Agreement, subject to to some terms may require 45 days advance notice, applicable law. We may do this in response to the and we will tell you in the notice if you have the right business, legal or competitive environment. to reject a change. We cannot change certain terms We cannot increase the interest rate on existing during the first year of your Cardmembership. balances except in limi circumstances. Changes Words we use in We, us, and our mean the issuer shown on page 1 Card means any card or other device that we issue the Agreement of Part 1. You and your mean the person who to access your Account. A charge is any amount applied for this Account and for whom we opened added to your Account, such as purchases, fees and the Account. You and your also mean anyone who interest charges. A purchase is a charge for goods agrees to pay for this Account. You are the Basic or services. Cardmember. You may request a card for an To pay by a certain date means to send your Additional Cardmember (see About Additional Cardmembers in Part 2). payment so that we receive it and credit it to your Account by that date (see About your payments in Part 2). About using your card Using the card You may use the card to make purchases. You may not required to) tell these merchants about your also use the card at an ATM to get cash from a Account status or changes to your card number or checking account you designate. expiration date. You must notify the merchants We decide whether to approve a charge based on directly if you want them to stop charging your how you spend and pay on this Account and other Account. accounts you have with us and our affiliates. We also Keep your card safe and don't let anyone else use it. consider your credit history and your personal If your card is lost or stolen or your Account is being resources that we know about. used without your permission, contact us right away. You may arrange for certain merchants to charge You may not use your Account for illegal activities. your Account a r egu l ar interv W e m ay (b ar Promise to pay You promise to pay all charges, including: • charges you make, even if you do not present your card or sign for the transaction, • charges that other people make if you let them use your Account, and • charges that Additional Cardmembers make or permit others to make. Declined transactions We may decline to authorize a charge. Reasons we We are not responsible for any losses you incur if we may do this include suspected fraud and our do not authorize a charge. And we are not assessment of your creditworthiness. This may occur responsible if any merchant refuses to accept the even if your Account is not in default. card. About Pay Over We may add features to your Account that allow you outside the U.S. If you enroll in the Extended Time features to pay certain charges over time. These features Payment Option, we will automatically place all include Select & Pay Later, Sign & Travel`s and the eligible charges into a Pay Over Time balance. A Extended Payment Option. charge is eligible if it equals or is more than a certain Select & Pay Later lets you pay a charge over time in dollar amount. We will tell you this amount when you two ways. You may ask a travel industry merchant at enroll, and it is subject to change. We will tell you if the time you make the charge, or ask us after the we change it. Certain charges are not eligible, such charge appears on your statement. If we approve as cash and similar transactions. your request, we will place the charge into a Pay We will not place any charge into a Pay Over Time Over Time balance. If we decline your request, you balance if it causes the total of your Pay Over Time must pay the charge in full upon receipt of your balances to go over $35,000. We will tell you if we billing statement. change that amount. You must pay in full all charges If you enroll in Sign & Travel, we will automatically that are not placed into a Pay Over Time balance place eligible travel - related charges into a Pay Over upon receipt of your billing statement. We may Time balance. Some examples are airline and cruise change which charges are eligible to be placed into ship tickets, hotels, car rentals and charges made a Pay Over Time balance. CMAEUACM0000101 Page 3 of 9 About your payments When you must pay Payment of the New Balance is due upon receipt of of the same day it is received. your statement. If a statement includes a Pay Over Each statement also shows a Closing Date. The Time balance, it will show a Minimum Payment Due. Closing Date is the last day of the billing period In this case, you must pay at least the Minimum covered by the statement. Each Closing Date is Payment Due by the Payment Due Date. Each about 30 days after the previous statement's Closing statement also states the time and manner by which Date. you must make your payment for it to be credited as How to make payments Make payments to us in U.S. dollars with: your billing statement. If we receive it after that time, • a single check drawn on a U.S. bank, or we will credit the payment on the day after we • a single negotiable instrument clearable through receive it. the U.S. banking system, for example a money If your payment does not meet the above order, or requirements, there may be a delay in crediting your • an electronic payment that can be cleared through Account. This may result in late fees and additional the U.S. banking system. interest charges (see How Rates and Fees Work on When making a payment by mail: page 2 of Part 1). • make a separate payment for each account, If we decide to accept a payment made in a foreign • mail your payment to the address shown on the currency, we will choose a rate to convert your payment coupon on your billing statement, and payment into U.S. dollars, unless the law requires us • write your Account number on your check or to use a particular rate. negotiable instrument and include the payment coupon. If we process a late payment, a partial payment or a If your payment meets the above requirements, we payment marked with any restrictive language, that will have no effect on our rights and will not change will credit it to your Account as of the day we receive this Agreement. it, as long as we receive it by the time disclosed in How we apply payments If a statement includes a Pay Over Time balance, it rate and then to balances with higher interest rates. and credits will show a Minimum Payment Due. The Minimum After the Minimum Payment Due has been paid, we Payment Due is the Pay In Full New Balance plus the Pay Over Time Minimum Due. apply payments to the remaining Pay Over Time bal- ance. When we do this, we apply payments first to If you have a Pay Over Time balance, we generally the balance with the highest interest rate and then to apply payments up to the Minimum Payment balances with lower interest rates. Due first to the Pay Over Time Minimum Due and In most cases, we apply a credit to the same bal- then to the Pay In Full New Balance. When applying ance as the related charge. We may apply payments a payment to the Pay Over Time Minimum Due, we and credits within balances, and among balances apply it first to the balance with the lowest interest with the same inte rate, in a ny o w c About your Minimum Payment Due How we calculate your The Minimum Payment Due is the Pay In Full amount plus any Pay Over Time Minimum Due. Minimum Payment Due To calculate the Pay Over Time Minimum Due for each statement, we start with the highest of the EXAMPLE: Pay Over Time Minimum Due following three amounts: Assume that your Pay Over Time New Balance (1) 2% of the Pay Over Time New Balance; or is $3,000, interest is $29.57 (see the example on (2) interest charged on the statement plus 1 % of the the next page), and you have no Pay Over Time Pay Over Time New Balance (excluding interest amounts past due. on the statement), not to exceed 4% of the Pay Over Time New Balance; or (1) 2% x $3,000 = $60.00 (3) $20. (2) $29.57 + i % x ($3,000 - $29.57) = $59.27 Then we round to the nearest dollar. After that, we (3) $20.00 add any Pay Over Time amount past due. The highest of the three amounts is $60.00. However, your Pay Over Time Minimum Due will not So the Pay Over Time Minimum Due is $60.00. . exceed your Pay Over Time New Balance. Adjusting your Pay Over If you regularly pay more than the Minimum Payment Due described above, we may adjust the Pay Over Time Minimum Due Time Minimum Due in future billing periods. This may let you make a smaller minimum payment from time to time. But if you then do not regularly pay more than the Minimum Payment Due described above, we will stop making the adjustment and return to the formula above. If we start or stop making the adjustment, we will do so for at least six billing periods in a row. To adjust the Pay Over Time Minimum Due, we will not add 1 % of the Pay Over Time New Balance in (2). Then, if (2) is the highest (but less than 4% of the Pay Over Time New Balance), we will add $15. continued on next page... CMAEUACM0000101 Page 4 of 9 AMERICAN EXPRESS ...continued from previous page We will do this if over six billing periods the sum of payments credited to your Pay Over Time balance is more than the sum of the Pay Over Time Minimum Dues (not adjusted, except any Pay Over Time amount past due is counted only in the first of those six periods). We will also make the adjustment if over six billing periods the sum of the Pay Over Time Minimum Dues (not adjusted) is not more than $120 and equals the sum of payments credited to your Pay Over Time balance. However, we will not make the adjustment if the sum of the Pay Over Time Minimum Dues is zero and we did not adjust the Pay Over Time Minimum Due the last time it w as not zero. About interest charges on Pay Over Time balances When we charge interest For charges added at your request If you pay the Account Total New Balance on a We charge interest on charges that are added at statement by the Closing Date shown on the next your request to a Pay Over Time balance as of the statement, then on that next statement we will not date the charge is added. If you pay the Account charge interest on those charges. Total New Balance on a statement by the Closing If you paid the Account Total Previous Balance on a Date on the next statement, then on that next statement by its Closing Date, and you pay less than statement we will not charge interest on any Pay the Account Total New Balance on that statement by Over Time portion of that Account Total New the Closing Date of the next statement, then we will Balance. not charge interest on the portion of automatically For charges added automatically added charges that we apply your payment to. But We charge interest on charges that are added we will charge interest on the remaining portion of automatically to a Pay Over Time balance beginning those charges. on the transaction date. However, you can avoid Also, we will not charge interest on automatically paying interest on those charges as described added charges shown on a statement if the Account below. Total Previous Balance on that statement is zero or a credit balance. How we calculate interest We calculate interest for a billing period by first figuring the interest on each balance. Balances within each feature such as Select & Pay Later, Sign & Travel and Extended Payment Option may have different interest rates. We use the Average Daily Balance method Daily Balance (including new transactions) to figure interest For each day a DPR is in effect, we figure the daily charges for each balance. The total interest charged balance by: for a billing period is the sum of the interest charged • taking the beginning balance for the day, on each balance. • adding any new charges, Interest • subtracting any payments or credits; and The interest charged for a balance in a billing period, • making any appropriate adjustments. except for variations caused by rounding, equals: We add a new charge to a daily balance as of its • Average Daily Balance (ADB) x transaction date. • Daily Periodic Rate (DPR) x • number of days the DPR was in effect. Beginning balance For the first day of a billing period, the beginning ADB balance is the ending balance for the prior billing To get the ADB for a balance, we add up its daily period, including unpaid interest. For the rest of the balances. Then we divide the result by the number billing period, the beginning balance is the previous of days the DPR for that balance was in effect. If the day's daily balance plus an amount of interest equal daily balance is negative, we treat it as zero. to the previous day s daily balance multiplied by the DPR DPR for that balance. This method of figuring the A DPR is 1/365th of an APR, rounded to one ten- beginning balance results in daily compounding of thousandth of a percentage point. Your DPRs are interest. shown in How Rates and Fees Work on page 2 of When an interest rate changes, the new DPR may Part 1. come into effect during not just at the beginning -- of the billing period. When this happens, we will EXAMPLE: Calculating Interest create a new balance and apply the new DPR to it. Assume that you have a single interest rate of To get the beginning balance on the first day for this 15.99 %, your ADB is $2,250 and there are 30 new balance, we multiply the previous day's daily days in the billing period. balance by the old DPR and add the result to that The DPR is 15.99%—.- 365 days = 0.0438 % day's daily balance. Interest is $2,250 x 0.0438% x 30 days = $29.57 Other methods _ To figure the ADB and interest charges, we may use other formulas or methods that produce equivalent results. Also, we may choose not to charge interest on certain types of charges. CMAEUACM0000101 Page 5 of 9 Determining the We use the Prime Rate from the Money Rates use the Prime Rate from any other newspaper of Prime Rate section (or successor section) of The Wall Street general circulation in New York, New York. Or we Journal. The Prime Rate for each billing period is the may choose to use a similar published rate. Prime Rate published in The Wall Street Journal If the Prime Rate increases, variable APRs (and days before the Closing Date of the billing period. corresponding DPRs) will increase. In that case, you The Wall Street Journal may not publish the Prime may pay more interest and may have a higher Rate on that day. If it does not, we will use the Prime Minimum Payment Due. When the Prime Rate Rate from the previous day it was published. If The changes, the resulting changes to variable APRs Wall Street Journal is no longer published, we may take effect as of the first day of the billing period. Other important information About Additional At your request, we may issue cards to Additional You authorize us to give Additional Cardmembers Cardmembers Cardmembers. They do not have accounts with us information about your Account and to discuss it with but they can use your Account subject to the terms them. of this Agreement. If you want to cancel an Additional Cardmember's You are responsible for all use of your Account by right to use your Account (and cancel their card) you Additional Cardmembers and anyone they allow to must tell us. use your Account. You must pay for all charges they make. Converting charges made If you make a charge in a foreign currency, we will identify from customary banking sources on the in a foreign currency convert it into U.S. dollars on the date we or our conversion date or the prior business day. This rate agents process it. Unless a particular rate is required may differ from rates that are in effect on the date of by law, we will choose a conversion rate that is your charge. We will bill charges converted by acceptable to us for that date. The rate we use is no establishments (such as airlines) at the rates they more than the highest official rate published by a use. government agency or the highest interbank rate we Changing your billing You must notify us immediately if you change the: If you have more than one account, you need to address • mailing address where we send billing statements; notify us separately for each account. or We may update your billing address if we receive • e -mail address to which we send notice that your information that it has changed or is incorrect. billing statement is available online. Closing your Account You may close your Account by calling us or writing to us. Cancelling or suspending We may: We may do any of these things at our discretion, your Account • cancel your Account, even if you pay on time and your Account is not in • suspend the ability to make charges, default. • cancel or suspend any feature on your Account, If your Account is cancelled, you must destroy your and cards. We may agree to reinstate your Account after • notify merchants that your Account has been a cancellation. If we do this, we may: cancelled or suspended. • reinstate any additional cards issued on your If we do any of these, you must still pay us for all Account, charges under the terms of this Agreement. • charge you any applicable annual fees, and • charge you a fee for reinstating the Account. About default We may consider your Account to be in default if: If we consider your Account in default, we may: • you violate a provision of this Agreement, • suspend your ability to make charges, • you give us false information, • cancel or suspend any feature on your Account, • you file for bankruptcy, • require you to pay more than your Minimum • you default under another agreement you have Payment Due immediately, and with us or an affiliate, • require you to pay your Account balance • you become incapacitated or die, or immediately. • we believe you are unable or unwilling to pay your debts when due. Credit reports You agree that we may obtain credit reports about term of this Agreement. This may have a negative you, investigate your ability to pay, and obtain impact on your credit record. information about you from other sources. And you If you believe information we have given to a credit agree that we may use such information for any reporting agency is incorrect, write to us at: purposes, subject to applicable law. American Express Credit Bureau Unit, P.O. Box You agree that we may give information about your 981537, El Paso, TX 79998 -1537. When you write to Account to credit reporting agencies. We may tell a us, tell us the specific information you believe is credit reporting agency if you fail to comply with any incorrect. CMAEUACM0000101 Page 6 of 9 s'kME #'3tLAr�t - ' �C t � Collection costs You agree to pay all reasonable costs, including attorneys' fees, that we incur to collect amounts you owe. Sending you notices We mail you notices through the U.S. mail, postage prepaid, and address them to you at the latest billing address on our records. Any notice that we send you this way is deemed to be given when deposited in the U.S. mail. We may contact you From time to time, we may contact you about topics to ensure the quality of customer service or when it ranging from servicing to marketing offers to is required by law. collecting amounts you owe. We may monitor and You can choose to not receive marketing offers from record phone calls between you (or any Additional us. To do this, call us at 1- 800 - 297 -8378 or log on to Cardmembers on your Account) and us. We do this ww About insurance products We or our affiliates may tell you about insurance and another affiliate is the insurer or reinsurer. non- insurance products, services or features that Compensation may influence what products and may have a fee. One of our affiliates may act on providers we or our affiliates tell you about. behalf of a provider of these products. The affiliate We may share information about you with our may be compensated for this. The insurance affiliates so they can identify products that may products are not offered or sold by us or on our interest you. We may be compensated for this behalf. Our affiliates may get additional information. compensation when Amex Assurance Company or How we handle When you pay us by check, you authorize us to If we do this, your payment may be deducted from electronic debits from electronically deduct the amount from your bank or your bank or other asset account on the same day your checking account other asset account. We may process the check we receive your check. Also, you will not receive that electronically by transmitting to your financial cancelled check with your bank or asset account institution: billing statement. • the amount, If we cannot collect the funds electronically, we may • the routing number, issue a draft against your bank or other asset • the account number, and account for the amount of the check. • the check serial number. ExpressPay Cards issued on your Account may be equipped with ExpressPay. ExpressPay enables you to make charges without having the card swiped or imprinted. You can call us to deactivate ExpressPay at any time. Also, we may deactivate ExpressPay at any time. Privacy Act of 1974 notice Some federal agencies may accept the card under authority of statute. When you make charges at these agencies, we collect certain charge information. That information may be put to routine uses, such as processing, billing and collections. It may also be aggregated for reporting, analysis and marketing use. Other routine uses by agencies may be published in the Federal Register. Changing benefits We have the right to add, modify or delete any benefit or service of your Account at our discretion. Assigning the Agreement We may sell, transfer or assign this Agreement and your Account. We may do so at any time without notifying you. You may not sell, assign or transfer your Account or any of your obligations under this Agreement. Assigning claims If you dispute a charge with a merchant, we may You agree that you will not pursue any claim against credit the Account for all or part of the disputed the merchant for the credited amount. And you must charge. If we do so, you assign and transfer to us all cooperate with us if we decide to do so. rights and claims (excluding tort claims) against the merchant. We do not waive our rights We may choose to delay enforcing or to not exercise rights under this Agreement. If we do this, we do not waive our rights to exercise or enforce them on any other occasion. Governing law Utah law and federal law govern this Agreement and We are located in Utah. We hold your Account in your Account. They govern without regard to internal Utah. We entered into this Agreement with you in principles of conflicts of law. Utah. Arbitration This Arbitration provision sets forth the or relating to your Account, this Agreement, corporate parent, or wholly or majority owned circumstances and procedures under which the Electronic Funds Transfer Services subsidiaries, affiliates, any licensees, claims may be arbitrated instead of litigated in Agreement, and any other related or prior predecessors, successors, assigns, any court. agreement that you may have had with us, or purchaser of any accounts, all agents, Definitions the relationships resulting from any of the employees, directors and representatives of As used in this Arbitration provision, the term above agreements, except for the validity, any of the foregoing, and other persons claim means any claim, dispute or enforceability or scope of this Arbitration referred to below in the definition of claims. controversy between you and us arising from provision. For purposes of this Arbitration Claim includes claims of every kind and provision, you and us also includes any continued on next page... CMAEUACM0000101 Page 7 of 9 ...continued from previous page 9 U.S.C. §§ 1 -16, as it may be amended with the FAA and applicable statutes of nature, including but not limited to, initial below. (FAA), provided that any such limitations, shall honor claims of privilege claims, counterclaims, cross - claims and third- organization and arbitrator(s) will enforce the recognized at law, and, at the timely request party claims and claims based upon contract, terms of the Restrictions on Arbitration of either party, shall provide a brief written tort, fraud and other intentional torts, statutes, subsection set forth below. explanation of the basis for the decision. regulations, common law and equity. Claim Significance of Arbitration The arbitration proceeding shall not be also includes claims by or against any third IF ARBITRATION IS CHOSEN BY ANY governed by any federal or state rules of civil party using or providing any product, service PARTY WITH RESPECT TO A CLAIM, procedure or rules of evidence. Any party may or benefit in connection with any account NEITHER YOU NOR WE WILL HAVE THE request that the arbitrator expand the scope (including, but not limited to, credit bureaus, RIGHT TO LITIGATE THAT CLAIM IN of discovery by doing so in writing and third parties who accept the card, third parties COURT OR HAVE A JURY TRIAL ON THAT copying any other parties, who shall have 15 who use, provide or participate in fee -based CLAIM. FURTHER, YOU AND WE WILL NOT days to make objections. The arbitrator will or free benefit programs, enrollment services HAVE THE RIGHT TO PARTICIPATE IN A notify the parties of his /her decision within 20 and rewards programs, credit insurance REPRESENTATIVE CAPACITY OR AS A days of any objecting party's submission. The companies, debt collectors and all of their MEMBER OF ANY CLASS OF CLAIMANTS arbitrator shall take reasonable steps to agents, employees, directors and PERTAINING TO ANY CLAIM SUBJECT TO preserve privacy. The arbitrator's award shall representatives) if and only if, such third party ARBITRATION. EXCEPT AS SET FORTH be final and binding, except for any right of is a party in connection with the claim. The BELOW, THE ARBITRATOR'S DECISION appeal provided by the FAA; however, either term claim is to be given the broadest WILL BE FINAL AND BINDING. NOTE THAT party shall have 30 days to appeal that possible meaning that will be enforced and OTHER RIGHTS THAT YOU OR WE decision by notifying the arbitration includes, by way of example and without - WOULD HAVE IF YOU WENT TO COURT organization and any other parties in writing. limitation, any claim, dispute or controversy ALSO MAY NOT BE AVAILABLE IN The organization will then appoint a three - that arises from or relates to (a) any of the ARBITRATION. arbitrator panel which shall consider anew accounts created under any of the Restrictions on Arbitration any aspect of the decision objected to by the agreements, or any balances on any such IF EITHER PARTY ELECTS TO RESOLVE A appealing party. The panel shall issue its accounts, (b) advertisements, promotions or oral or written statements related to any such CLAIM BY ARBITRATION, THAT CLAIM decision, by majority vote, within 120 days of accounts, goods or services financed under SHALL BE ARBITRATED ON AN the appealing parry's written notice. Judgment INDIVIDUAL BASIS. THERE SHALL BE NO upon any award rendered by the arbitrator or any of the accounts or the terms of financing, RIGHT OR AUTHORITY FOR ANY CLAIMS panel may be entered in any court having (c) the benefits and services related to Cardmembership (including fee -based or free TO BE ARBITRATED ON A CLASS ACTION jurisdiction. benefit programs, enrollment services and BASIS OR ON BASES INVOLVING CLAIMS Location of Arbitration rewards programs), and (d) your application BROUGHT IN A PURPORTED Arbitration hearings you attend shall take for any account. We shall not elect to use REPRESENTATIVE CAPACITY ON BEHALF place in the federal judicial district of your arbitration under this Arbitration provision for OF THE GENERAL PUBLIC, OTHER residence. any claim that you properly file and pursue in CARDMEMBERS OR OTHER PERSONS Payment of Fees a small claims court of your state or SIMILARLY SITUATED. The arbitrator's You will be responsible for paying your share, municipality so long as the claim is individual authority to resolve claims is limited to claims if any, of the arbitration fees (including filing, and pending only in that court. between you and us alone, and the administrative, hearing and /or other fees), but arbitrator's authority to make awards is limited only to the amount of the filing Initiation of Arbitration to awards to you and us alone. Furthermore, y p fees you would have incurred if you had brought a Any claim shall be resolved, upon the election claims brought by you against us, or by us by you or us, by arbitration pursuant to this against you, may not be joined or claim in the state or federal court closest to Arbitration provision and the code of consolidated in arbitration with claims brought your billing address that would have had procedures of the arbitration organization to by or against someone other than you, unless Jurisdiction. will be responsible for any which the claim is referred in effect at the time agreed to in writing by all parties. No additional arbit tration fees. At your written the claim is filed (code), except to the extent arbitration award or decision will have any request, will consider in good faith making the code conflicts with this Agreement. Claims preclusive effect as to issues or claims in any a temporary advance of all or part of your shall be referred to either JAMS or the dispute with anyone who is not a named parry share of any arbitration fees. You will not be American Arbitration Association AAA , as assessed any arbitration fees in excess of ( ) to the arbitration. Notwithstanding any other our share if you do not r y selected by the party electing to use y provision of this Agreement (including but not y prevail in an arbitration. If our selection of either of these limited to the Continuation subsection below) arbitration with us. organizations is unacceptable to you, you and without waiving either party's right to Continuation may select the other organization within 30 appeal such decision, should any portion of This Arbitration provision shall survive termi- days after you receive notice of our selection. this Restrictions on Arbitration subsection be nation of your Account; voluntary payment of For a copy of the code, to file a claim or for deemed invalid or unenforceable, then the the Account balance in full by you; any legal other information, contact either: JAMS (1920 entire Arbitration provision (other than this proceeding by you or us to collect a debt Main St #300, Irvine, CA 92614 or sentence) shall not apply. owed by the other; any bankruptcy by you or jamsadr.com) or AAA (335 Madison Ave, New Arbitration Pd us; and any sale by us of your Account (in the roceures York, NY 10017 or adr.org). case of a sale, its terms shall apply to the This Arbitration provision is made pursuant to Account our buyer of In addition to the organizations listed above, transactions involving interstate commerce y y ) If any portion this claims may be referred to any other arbitration and shall be governed by the FAA. The Arbitration provision, except as otherwi se pro organization that is mutually agreed upon in arbitration shall be governed by the applicable vided in the Restrictions on Arbitration sub - writing by you and us, or to an arbitration code, except that this Agreement shall apply if section, is deemed invalid or unenforceable, it s organization or arbitrator appointed shall not invalidate the remaining portions of 9 () pp there are any conflicts. The arbitrator shall provision. pursuant to § 5 of the Federal Arbitration Act, apply applicable substantive law consistent this p CMAEUACM0000101 Page 8 of 9 nr� =s ?�car� CXfxriCSS Your Billing Rights: Keep this Document for Future Use This notice tells you about your rights and our While we investigate whether or not there has Your Rights If You Are Dissatisfied With responsibilities under the Fair Credit Billing been an error: Your Credit Card Purchases Act. • We cannot try to collect the amount in If you are dissatisfied with the goods or What To Do If You Find a Mistake on Your question, or report you as delinquent on services that you have purchased with your Statement that amount. credit card, and you have tried in good faith to If you think there is an error on your • The charge in question may remain on your correct the problem with the merchant, you statement, write to us at: statement, and we may continue to charge may have the right not to pay the remaining American Express you interest on that amount. amount due on the purchase. PO Box 981535 • While you do not have to pay the amount in To use this right, all of the following must be El Paso TX 79998 -1535 question, you are responsible for the true: remainder of your balance. 1. The purchase must have been made in In your letter, give us the following . We can apply any unpaid amount against your home state or within 100 miles of your information: your credit limit. • Account information: Your name and current mailing address, and the purchase account number. After we finish our investigation, one of two price must have been more than $50. • Dollar amount The dollar amount of the things will happen: (Note: Neither of these are necessary if suspected error. • If we made a mistake: You will not have to your purchase was based on an • Description of problem: If you think there is pay the amount in question or any interest advertisement we mailed to you, or if we an error on your bill, describe what you or other fees related to that amount. own the company that sold you the goods believe is wrong and why you believe it is a . If we do not believe there was a mistake: or services.) mistake. You will have to pay the amount in 2. You must have used your credit card for question, along with applicable interest and the purchase. Purchases made with cash You must contact us: fees. We will send you a statement of the advances from an ATM or with a check that • Within 60 days after the error appeared on amount you owe and the date payment is accesses your credit card account do not your statement. due. We may then report you as delinquent qualify. • At least 3 business days before an if you do not pay the amount we think you 3. You must not yet have fully paid for the automated payment is scheduled, if you owe. purchase. want to stop payment on the amount you think is wrong. If you receive our explanation but still believe If all of the criteria above are met and you are your bill is wrong, you must write to us within still dissatisfied with the purchase, contact us You must notify us of any potential errors in 10 days telling us that you still refuse to pay. in writing at: writing. You may call us, but if you do we are If you do so, we cannot report you as American Express not required to investigate any potential delinquent without also reporting that you are PO Box 981535 errors and you may have to pay the amount questioning your bill. We must tell you the El Paso TX 79998 -1535 in question. name of anyone to whom we reported you as delinquent, and we must let those While we investigate, the same rules apply to What Will Happen After We Receive Your q the disputed amount as discussed above. Letter organizations know when the matter has After we finish our investigation, we will tell When we receive your letter, we must do two been settled between us. you our decision. At that point, if we think you things: If we do not follow all of the rules above, you owe an amount and you do not pay, we may 1. Within 30 days of receiving your letter, we do not have to pay the first $50 of the amount report you as delinquent. must tell you that we received your letter. you question even if your bill is correct. We will also tell you if we have already corrected the error. 2. Within 90 days of receiving your letter, we must either correct the error or explain to you why we believe the bill is correct. CMAEUACM0000101 Page 9 of 9 AMERICAN Platinum Card® E7�RE55 p. 1/3 m BRIAN E DANZIS Closing Date 04/18/13 Account Ending 5 -84007 New Balance Earn points on all of your $21,813.53 purchases, everywhere you use Minimum Payment Due $218.00 the Card. Visit www.americanexpress.com /rewards Payment Due Date 05/13/13 Account Summary Pay In Full Portion Previous Balance $0.00 Payments /Credits -$0.00 New Charges +$0.00 Fees +$0.00 New Balance = $0.00 PayOver Time Portion Minimum Payment Warning: If you make only the minimum payment each period, Previous Balance $22 ,113.53 you will pay more in interest and it will take you longer to pay off your balance. For Payments /Credits - $300.00 example: New Charges +$0.00 Fees +$0.00 If you make no additional You will pay off the Pay Over And for the Pay Over Time Interest Charged +$0.00 charges and each month you Time balance shown on this balance you will pay an New Balance — $21 813.53 pay... statement in about... estimated total of.- Minimum Due $218.00 Onlythe 28 ears Minimum Payment Due Y $48.773 Account Total Previous Balance 522,11353 $759 3 years �(Savings=$21,4�46) 27'327 Payments /Credits - $300,00 New Charges +$0.00 If you would like information about credit counseling services, call 1 888 - 733 - 4139. Fees +$0.00 Interest Charged +$0.00 Q Seepage 2 for important information about your account New Balance $21,81353 Minimum Payment Due $218.00 Q Your account is cancelled Days in Billing Period: 30 Customer Care 0 Please note, your preset line is $0.00. You have spent $21,813.53. PaybyComputer amencanexpress.com /pbc Customer Care Pay by Phone 1- 800 -525 -3355 1- 800-472 -9297 See Page 2 for additional information. + Please fold on the perforation below, detach and return with your payment + ® PaymentCoupon rml Pay by computer �PaybyPhone Account Ending 5-8007 Do not staple or use paper clips americanexpress.com /pbc 1- 800 -472 -9297 Enter account number on all documents. Make check payableto American Express. BRIAN E DANZIS 301 CHESTNUT RDG DR Payment Due Date MECHANICSBURG PA 17055 -5181 05/13/13 New Balance $21.81353 Minimum Payment Due $218.00 AMERICAN EXPRESS ❑ Check here if your address or P.O. BOX 1270 $ phone number has changed. NEWARK NJ 07101 -1270 Amount Enclosed Note changes on reverse side. IIi �� 1ii �� iliilr � i � ll ,1'rlllillrr'i'ril 0000349990954447324 002181353000021800 15 d Exhibit _rr BRIAN E DANZIS Account Ending 5 -84007 p 2/3 Payments:Your payment must be sent to the payment address shown on your statement and must be received by 5 p.m. local time at that address to be credited as of the day it is received. Payments we receive after 5 p.m. will not be credited to your Account until the next day. Payments must also: (1) include the remittance coupon from your statement; (2) be made with a single check drawn on a US bank and payable in US dollars, or with a negotiable instrument payablein US dollarsand clearable through the US banking system;and (3) include your Account number. If your paymentdoes not meet all of the above requirements, crediting may be delayed and you may incur late paymentfees and additional interest charges. Electronic payments must be made through an electronic payment method payable in US dollars and clearable through the US banking system. If we accept payment in a foreign currency, we will convert it into US dollars at a conversion rate that is acceptable to us, unless a particular rate is required by law. Pleasedo not send post -dated checks as they will be deposited upon receipt. Any restrictive language on a payment we accept will have no effect on us without our express prior written approval. We will re- present to your financial institution any payment that is returned unpaid. If you have a Pay Over Time balance, you may pay more than the Minimum Payment Due, up to your New Balance, at anytime. Permission for Electronic Withdrawal: (1) When you send a check for payment, you give us permission to electronically withdraw your payment from your depositor other asset account. We will process checks electronically by transmitting the amount of the check, routing number, account number and check serial number to your financial institution, unlessthe check is not processable electronically or a less costly process is available. When we process your check electronically, your payment maybe withdrawn from your depositor other asset account as soon as the same day we receive your check, and you will not receive that cancelled check with your financial account statement. If we cannot collect the funds electronically we may issue a draft against your depositor other asset account for the amount of the check. (2) By using Pay By Computer, Pay By Phone or any other electronic payment service of ours, you give us permission to electronically withdraw funds from the depositor other asset account you specify in the amount you request. Payments using such services of ours received after 8:00 p.m. MST may not be credited until the next day. How We Calculate Your Balance: We use the Average Daily Balance (ADB) method (including new transactions) to calculate the balance on which we charge interest for Pay Over Time balances on your Account. Call the Customer Service number listed below for more information about this balance computation method and how resulting interest charges are determined. The method we use to figure the ADB and interest results in daily compounding of interest. Paying Interest: If you have a Pay Over Time balance, your due date is at least 25 days after the close of each billing period. We will begin charging interest on transactions added to a Pay Over Time balance as of the date they are added. However, we will not charge interest on charges added to a Pay Over Time balance automatically (forexample, Sign &Travel and Extended Payment Option) if you pay the Account Total New Balance by the due date each month. Foreign Currency Charges: If you make a Charge in a foreign currency, we will convert it into US dollars on the date we or our agents process it We will choose a conversion rate that is acceptable to us for that date, unless particular rate is required bylaw. The conversion rate we use is no more than the highest official rate published by a government agency or the highest interbank rate we identify from customary banking sources on the conversion date or the prior business day. This rate may differfrom rates in effect on the date of your charge. Charges converted by establishments will be billed at the rates such establishments use. Credit Balance: A credit balance (designated CR) shown on this statement represents money owed to you. If within the six -month period following the date of the first statement indicating the credit balance you do not request a refund or charge enough to use up the credit balance, we will send you a check for the credit balance within 30 days if the amount is $1.00 or more. 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. Customer Care& Billing Inquiries 1- 800 -525 -3355 Hearin Im aired International Collect 1- 336 - 393 -1111 TTY: 1-800-221-9950 a Mobile Site: amexm bile. om Large Print& Braille Statements 1-800 -525 -3355 FAX: 1-800-695-9090 Car Rental Loss and Damage Insurance 1-800 -338 -1670 In NY: 1-800-522-1897 Customer Care Travel Emergency, Worldwide Personal 1- 800 -345 -AMEX & Billing Inquiries Payments Assistanceand Fine Dining P.O. BOX 981535 P.O. BOX 1270 PlatinumCard Travel Service and 1-800-443-7672 EL PASO, TX NEWARK NJ Fine Hotels, Resorts & Spas 79998 -1535 07101 -1270 By Invitation Only 1-800 -321 -RSVP Changeof Address If correct on front, do not use. • To change your address online, visit www. americanexpress .com /updatecontactinfo Pay Your Bill with AutoPay • For Name, Company Name, and Foreign Address or Phone changes, please call Customer Care. Avoid late fees • Please print clearly in blue or black Ink only in the boxes provided. Save time Deduct your payment from your bank Street Address account automatically each month City, State FEP+ I Visit americanexpress.com /autopay today to enroll. Zip Code Area Code and Home Phone Area Code and Work Phone For information on how we protect your Email privacy and to set your communication and primacy choices, please visit ion scom/privacy. AMERICAN Platinum Card® p 313 EXPRESS ® BRIAN E DANZIS Closing Date 04/18/13 Account Ending 5 -84007 Payments and Credits Summary Pay In Full Pay Over Time ♦ Total Payments $0.00 - $300.00 - $300.00 Credits $0.00 $0.00 $0.00 Total Payments and Credits $0.00 - $300.00 - $300.00 Detail *Indicates posting date Payments Amount 04/17/13• ONLINE PAYMENT-THANK YOU - $300.00 [ Fees Amount Total Fees for this Period $0.00 Interest Charged Amount Total Interest Charged for this Period $0.00 2013 Fees and Interest Totals Year -to -Date Amount Total Fees in 2013 -$1,177.82 Total Interest in 2013 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual 8alance5ubject Interest Percentage Rate to Interest Rate Charge Sign & Travel /Extended Payment Option 15.24 %(v) $0.00 $0.00 Total $0.00 (v) Variable Rate VERIFICATION I, Demetrios H. Tsarouhis, Esquire, verify that the statements contained in the aforementioned Complaint are true and correct based on my communications with my client. I make this verification because my client is unavailable to sign this document at this time. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Sec. 4904 relating to unsworn falsification to authorities. By: Demetrios H. Tsarouhis, Esquire Date: August 6, 2013 130330.001 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith 4lv r of i`1l PfiU �ONfl �€ ' Chief Deputy 2213 SEQ —6 3: 36 .,* 6,�'r�,R Richard W Stewart �,{ CO UN" Solicitor OFFICE F'THE SOERIF'r cu ERLAND LVUN 1 PENNSYLVANIA American Express Centurion Bank, a Utah state charted bank Case Number vs. Brian Edward Danzis 2013-4984 SHERIFF'S RETURN OF SERVICE 08/29/2013 06:10 PM- Deputy Shawn Harrison, being duly sworn according to law, se ed th requ sted Complaint & Notice by"personally" handing a true copy to a person representing t e v s to be the Defendant, to wit: Brian Edward Danzis at 301 Chesnut Ridge Drive, Upper Allen, e i sburg, A 17055. S WN HA ISO PUTY SHERIFF COST: $39.30 SO ANSWERS, August 30, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,TeleosoR,Inc.