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Home My WebLink About14-7045 Supreme Court of Pennsylvania Court Of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: Cumberland County )V- The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the ftling and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ElTransfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: KEYURKUMAR M PATEL C CITIBANK, N.A. Are money damages requested? ® Yes ❑No Dollar Amount Requested: ® within arbitration limits (Check one) ❑ outside arbitration limits 0 N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: Syretta Martin, Frank Janello, Beth Arnold Howell, Kami S. Miller, Christoph r Titus ❑ Check here if you have no attorney (are a Self-Represented [Pro Se] Litigant) Nature of the Case:Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT/do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution PC Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability (does not include mass tort) ❑Employment Dispute: C ❑ Slander/Libel/Defamation Discrimination T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board 1 ❑ Other: 0 N 11 Other: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ 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 ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111120 2959793 PPTXCPRI(07/18/2014) 11111111111111 IN 11111111111111111111111111111111111111111111111111111 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606u �f FIL o-`'�'FICE Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 ZL l'�� Blatt, Hasenmiller, Leibsker & Moore, LLC 5 p;412: 59 1835 Market Street, Suite 501 f Philadelphia, PA 19103 1�1- T,'�'LA ,i� CoUliTy TELE: 215-564-1567 5 i LVA FAX: 215-564-3818 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA VS. Plaintiff, CIVIL ACTION No. KEYURKUMAR M PATEL 35 JOHNS DR ENOLA PA 17025-2694 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 S cw� CJ�; 16b Sod - 2959793 PPTCPADI (07/18/2014) IZ4 3J / � d i AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. KEYURKUMAR M PATEL 35 JOHNS DR ENOLA PA 1.7025-2694 Defendant. COMPLAINT Plaintiff, CITIBANK,N.A., claims as follows: 1. Defendant(s), KEYURKUMAR M PATEL, , is an adult individual with last known address of 35 JOHNS DR ENOLA PA 17025-2694 2. It is averred that Defendant(s) was indebted to CITIBANK, N.A. on 12-04-12 with account number XXXXXXXXXXXX5565 (hereafter referred to as "Account"). A copy of the Defendant(s) statement is attached hereto and collectively marked as Exhibit "A". 3. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 4. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 2959793 PPTCGDCI (08/26/2014) 1111111111111 IIII 11111111111111111111111111111111111111111111111111111 IIII 5. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 6. Defendant(s) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 01-08-2013. 7. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $3719.51. 8. Despite reasonable demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) KEYURKUMAR M PATEL, in the amount of $3719.51, plus costs of this action and-any other relief as the Court deems just and reasonable. Respectfully Submitted, Dated: Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 . Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 Exhibit " A " 2959793 PPTXEXAI ( 04/17/2014 ) Verification IKATHY RIZOR , am employed by Citibank, N.A. (hereafter Citibank) which is successor in interest to plaintiff Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. 1 am authorized to make this verification on behalf of Citibank. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Si nature 2959793 PPTXCITI 1111111111111 III 111111 VIII VIII VIII 11111 VIII VIII 111111111 IIII Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: 6 Customer Service: SEARS CREDIT CARDS Searscardcom PO Box 6283 Sioux Falls,SD 57117.6283 Sear'S Card Q Account Inquiries: , : �- ,,, 1-800-917-7700 Summary of Account Activity Payment Information Previous Balance $3,611.32 New Balance $3,719.51 Payments ---$0.00 Minimum Payment Due $1,005.13 Other Credits -$0.00 Payment Due Date July 18,2014 Purchases +$0.00 Cash Advances +$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 alate fee up to$35. Interest Charged +$73.19 Minimum Payment Warning: If you make only the minimum payment each New Balance $3,719.51 period,you will pay more in interest and it will take you longer to pay off your balance For example Past Due Amount $858.94 fouffilkenoaddlUonal:ti Y4uwi0 �;ctSargi3s'tising 1l1'is card._.w ba1a#rae shown:cxt this end uP paying an grid each tnonth Ygt3( `staletijent in"about ,, :esbr at Total of:.':ti J 5„ I Y'.§ Credit Limit 0.00 Only the minimum payment 14 years $8,280 Available Credit $0.00 $148 3ears $5,341 Amount Over Credit Limit 719.51 y (Savings=$2,939) Statement Closing Date 06/20/2014 If you would like Information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 07/22/2014 Days in Billing Cycle 29 TRANSACTIONS Trans Date Description Reference# Amount FEES 06118 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 06120 INTEREST CHARGE ON PURCHASES $ 73,19 TOTAL INTEREST FOR THIS PERIOD $ 73.19 8 SE 14 PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4. Page 1 of 4 This Account is Issued by Citibank,N.A. ---------------± Please detach and return lower portion with our a mens to Insure pro r credit. Retain u r rtion for your records. y ----------------------------------Y---e-�-------------�------------P�-�°��-III-nnnn-nnnn-ummu-II-1111tht-��--I-tltltltl--pppp-metroro--------------------- sea rs® Your Account Number is 5565 1IYIIIe 111111lllll� Payment Due Date II July 18,2014 PO Box 6286 New Balance $3 SIOUX FALLS,SD 57117.6286 ,719.51 Past Due Amountl $858.94 Minimum Payment Due $1,005.13 Statement Enclosed tPast Due Amount is included in the Minimum Payment Due. Please print address changes on the reverse side. Make Checks Payable tow SEARS CREDIT CARDS KEYURKUMAR M PATEL PO BOX 183081 1429 APPLE DR APT 154 COLUMBUS,OH 43218-3081 MECHANICSBURG,PA 17055-3933 5565 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 is you must: at least 25 days after the close of each billing cycle.We will not charge you Enclose a valid check or money order.No cash,gift cards, any interest on purchases if you pay your New Balance by the payment or foreign currency please. due date each month.This is called a grace period on purchases.if you do Include your name and the last four digits of your account number. not pay the New Balance in full by the payment due date,you will not get a grace period on purchases until you pay the New Balance in full for two Payment Other Than By Mail. billing cycles in a row.We will begin charging interest on cash advances and In-Store(Where Available).Any payment in proper form accepted in- balance transfers(if available on your account)on the transaction date. store will be credited as of that day.However,credit availability may be If you have a balance subject to a deferred interest promotion and that subject to verification of funds.Not all stores accept payments.Contact promotion does not expire before the payment due date,that balance(the your local store to see if in-store payments are accepted at that location. "excluded promotional balance")is excluded from the amount you must Online.Go to the URL on Page i of your statement to make a payment. pay in full to get a grace period.However,you must still pay any separately For security reasons,you may not be able to pay your entire New required payment on the excluded promotion.In billing cycles in which Balance the first time you make a payment online.The payment cutoff payments are allocated to deferred interest balances first,the deferred time for Online Bill Payments is midnight Eastern time.This means that interest balance will be reduced before any other balance on the account. we will credit your account as of the calendar day,based on Eastern However,you will continue to get a grace period on purchases so long as time,that we receive your payment request. you pay the New Balance less any excluded promotional balances in full by AutoPay.Sign up at Account Online to have your payment amount the payment due date each billing cycle. automatically deducted each month from the account you choose. In addition,certain promotional offers may take away the grace period on Your card account will be credited on the due date with that amount. purchases.Other promotional offers not described above may also allow Phone.Call the phone number on Page 1 of your statement to make you to have a grace period on purchases without having to pay all or a a payment.We may process your payment electronically after we portion of the promotional balance by the payment due date.If either is verify your identity.The payment cutoff time for Phone Payments is the case,the promotional offer will describe what happens. midnight Eastern time.This means that we will credit your account How We Calculate Your Balance Subject to Interest Rate.We use a as of the calendar day,based on Eastern time,that we receive your daily balance method(including current transactions)to calculate interest payment request. charges.To find out more information about the balance computation Express Mall.Send payment by courier or express mail to:Payments method and how the resulting interest charges were determined,contact Department,1500 Boltonfield Street,Columbus,OH 43228.Payment us at the Account Inquiries number on the front. must be received in proper form at the proper address by 5 p.m.Eastern Balance Transfers.Balance transfer amounts are included in the time to be credited as of that day.All payments received in proper form "Purchases"line in the Summary of Account Activity(if balance transfers at the proper address afterthat time will be credited as are available on your account), of the next day. Transaction Date.The Transaction Date shown on the statement is also If you send an eligible check with this payment coupon,you authorize the Sale Date. us to complete your payment by electronic debit.If we do,the checking account will be debited in the amount on the check.We may do this as Other Account and Payment Information. soon as the day we receive the check.Also,the check will be destroyed. Payment Amount.You may pay all or part of your account balance at any time.However,you must pay,by the payment due date,at least the minimum payment due. When Your Payment Will Be Credited.If we receive your payment in proper form at our processing facility by 5 p.m.local time there,it will be credited as of that day.A payment received there in proper form after that time will be credited as of the next day.Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form or is not sent to the correct address.The correct address for regular mail is the address on the front of the payment coupon.The correct address for courier or express mail is the Express Mail Address shown in the Express Mail section. T03174 PLEASE SEE IMPORTANT INFORMATION ON PAGE 4 SMC/rGI/SCC/SCP/HIPs-2 APR13 Page 2 of 4 Change of Address Please print address changes in blue or black ink. Account: **"* **** **** 5565 Lotal Fees Charged in 2014 $210.00 otal Interest Charged in 2014 $421.10 INTEREST CHARGE CALCULATION Your (AfRAnual ai�n"ise Se Rate tt the annual rate account. PURCHASES REGULAR 25.24%(D)(V) $3,650.11 $73.19 TV)=Variable Rate D =Daily Page 3 of 4 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 shown on Page 1. If we made a mistake:You will not have to pay the amount in question Report a Lost or Stolen Card immediately.Call the Account Inquiries or any interest or other fees related to that amount. number shown on Page 1. q If we do not believe there was a mistake:You will have to pay the amount 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 errors and customer service inquiries shown on amount we think you owe. Page 1 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. • Account information:Your name and account number. If you do so,we cannot report you as delinquent without also reporting • 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 not 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,all of the following must be true: What Will Happen After We Receive Your Letter 1. The purchase must have been made in your home state or within 100 When we receive your letter,we must do two things: miles of your current mailing address,and the purchase price must 1. Within 30 days of receiving your letter,we must tell you that have been more than$50.(Note:Neither of these are necessary if we received your letter.We will also tell you if we have already your purchase was based on an advertisement we mailed to you,or corrected the error, if we own the company that sold you the goods or services.) 2.Within 90 days of receiving your letter,we must either correct 2.You must have used your credit card for the purchase.Purchases the error or explain to you why we believe the bill is correct. made with cash advances from an ATM or with a check that accesses While we Investigate whether or not there has been an error: your credit card account do not qualify. • We cannot try to collect the amount in question, 3.You must not yet have fully paid for the purchase. or report you as delinquent on that amount. If all of the criteria above are met and you are still dissatisfied with the • The charge in question may remain on your statement, purchase,contact us in writing at the address for billing errors and and ch may continue n charge you interest on that amount. customer service inquiries shown on Page 1 of your statement. • While we investigate,the same rules apply to the disputed amount as While you do not have to pay the amount in question, you are responsible for the remainder of your balance. discussed above.After we finish our investigation,we will tell you our 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. EM T03175-SE-9351-5000-0023-9E-34-X-12/01/12.93--P-E-0-Y-7-0-0.0--05(16/13-PDAB-May22,2014.0-0-V N— PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 SMC/TGI/SCC/SCP/HIPs-4 APR13 Page 4 of 4 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 :._: Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 �F Blatt, Hasenmiller, Leibsker& Moore, LLC = ` ' 1835 Market Street, Suite 501 r l ' G� u Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. KEYURKUMAR M PATEL 35 JOHNS DR ENOLA PA 17025-2694 Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK,N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: ' `ry By: Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 PPTXPEAI (07/18/2014) 2959793 Attorneys For Plaintiff 111111111111111111111111 i t 111111111111111111111111111111111111111111111 IN Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY j'�j`'IUr Ik vi)„,,, TA Citibank, N.A. vs. Keyurkumar M Patel Case Number 2014-7045 SHERIFF'S RETURN OF SERVICE 12/30/2014 02:30 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Keyurkumar M Patel, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 35 Johns Drive, East Pennsboro Township, Enola, PA 17025. Deputies were advised that the defendant no longer resides at this address. SHERIFF COST: $83.85 SO ANSWERS, December 31, 2014 (c) CountySuite Shenff, Teieosoft, Inc. RONR-R ANDERSON, SHERIFF