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Home My WebLink About05-2822THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Terry R. Lindsey, Jr. 120 S. Hanover St. B Carlisle, PA 17013, Plaintiff Vs. Citifinancial 1 Valley St. Suite 103 Carlisle, PA 17013 also Citfinancial 6010 Fairview Rd. SU 105 P.O. Box 22164 Charlotte, NC 28222-1649 Defendant NOTICE CIVIL ACTION NO. t_ is L( TftZ -.-1 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 THE 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 COUNTERCLAIMT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE DEFENDANT. 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. PA BAR ASSOCIATION P.O. BOX 186 HARRISBURG, PENNSYLVANIA 17018 717-238-6715 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Terry R. Lindsey, Jr. 120 S. Hanover St. B Carlisle, PA 17013, Plaintiff Vs. Citifinancial 1 Valley St. Suite 103 Carlisle, PA 17013 also Citfinancial 6010 Fairview Rd. SU 105 P.O. Box 22164 Charlotte, NC 28222-1649 Defendant CIVIL ACTION NO.?a COMPLAINT 1. Plaintiff is Terry Lindsey, an adult individual residing at 120 S. Hanover St. B, Carlisle, PA 17013. 2. Defendant is Citifinancial, a corporation conducting business throughout the Commonwealth of Pennsylvania with the following business addresses: Citifinancial 1 Valley St. Suite 103 Carlisle, PA 17013 Citifinancial I Sally Street, Suite 103 P.O. Box 1232 Carlisle, PA 17013 Citifinancial 6010 Fairview Rd. SU 105 P.O. Box 22164 Charlotte, NC 28222-1649 Citifinancial P.O. Box 8020 South Hackensack, NJ 07606-8020 Citifinancial P.O. Box 913 Owings Mills, MD 21117-0700 Citifinancial P.O. Box 17099 Baltimore, MD 21297-0194 Citifinancial P.O. Box 499 Hanover, MD 21076 3. On or about January 12, 2005, February 8, 2005, February 9, 2005, March 14, 2005, March 28, 2005, March 29, 2005, April 6, 2005, Aril 9, 2005, April 11, 2005, and May 16, 2005 Defendant(s) purposely, knowing and intentionally committed the following act(s), as documented in Exhibit(s) A-O: a. Contacted a consumer Debtor that Defendant knew or should have known was represented by an attorney. Exhibits A-E demonstrate that Defendant knew or should have known that Plaintiff was represented by an attorney. Exhibits F-O demonstrate a repeated course of conduct of harassing phone calls and letters by Defendant toward Plaintiff. b. Made confusing, misleading and false statements concerning an alleged debt. Given the fact that the debt was litigated in Court and a judgment was rendered in favor of Terry Lindsey, by continuing to write and call Plaintiff, Defendant made false and misleading statements regarding the debt. c. Also engaged in unlawful debt collection activity including but not limited to visiting Defendant's home, and demanding post-dated checks from Defendant, and causing Defendant to be distressed and embarrassed. COUNT ONE: VIOLATION OF PENNSYLVANIA UNFAIR TRADE AND CONSUMER PROTECTION ACT (73 PS 201, ET.SEQ) AND THE FAIR CREDIT EXTENSION UNIFORMITY ACT (73 PS 2270), ET. SEQ. Defendant is a debt collector for purposes of Pennsylvania Unfair Trade and Consumer Protection Law, and the Fair Credit Extension Uniformity Act. 5. Plaintiff is a consumer debtor within the meaning of Pennsylvania Unfair Trade and Consumer Protection Law, and the Fair Credit Extension Uniformity Act. 6. By committing the above-referenced acts, Defendant committed a violation of PENNSYLVANIA UNFAIR TRADE AND CONSUMER PROTECTION ACT (73 PS 201, ET.SEQ) AND THE FAIR CREDIT EXTENSION UNIFORMITY ACT (73 PS 2270), ET. SEQ.D DAMAGES Plaintiff's actual damages are $25.00 more or less, including but not limited to postage, phone calls, mileage, etc. 8. $1,000 statutory damages under the FDCPA. 9. $100.00 Statutory damages under PENNSYLVANIA UNFAIR TRADE AND COMSUMER PROTECTION ACT (73 PS 201, ET.SEQ) AND THE FAIR CREDIT EXTENSION UNIFORMITY ACT (73 PS 2270), ET. SEQ . There are a total of at least 16 violations for a total of $1,600,00. 10. Attorney fees of $3,750.00 at a rate of $250.00 per hour, more clearly defined in Plaintiff's Exhibit P. 11. Plaintiff demands punitive damages against Defendant in the amount of $10,000.00 for anxiety, harassment and intimidation because the acts committed by Defendant were willful, wanton and intentional. Wherefore, Plaintiff demands judgment against Defendants in the amount of $15,375.00 (actual damages, statutory damages, attorney fees and punitive damages). $25.00 Actual Damages $1,600.00 Statutory Damages $3,750.00 attorney fees $10,000.00 punitive damages $15,375.00 Vicki Piontek, Esquire Date 24 West Governor Road Hershey, PA 17033 717-533-7472 Fax: 800-362-7919 palaw@justice.com COMMONWEALTH OF PENNSYLVANIA r COUNTY OF CUMBERLAND 1',- 09-3-03 DJ Name. Hon. SUSAN R. DAY Address 229 14,ILL STREET, BOX 167 MT., LLY' SPRINGS, PA 7elephoe (7170 486-7672 17065 A,TTORNEY''DEF PRTVA rF NOTICE OF CONTINUANCE PLAINTIFF. NAME and ADDRESS rCITIFINANCIAL 1 VALLEY ST. SUITE 103 LCARLISLE, PA 17013 VS: DEFENDANT NAME a,afAZWA ADDRESS FLINDSEY.JR, TERRY 120 S HANOVER -ST APT/STE B CARLISLE, PA 17013 J VICKI A. PIONTER L J 116 W GREEN ST DocketNo.:CV-0000300-04 BOX 173 Date Filed: 10/01/04 MECHANICSBURG, PA 17055-0173 ?Q Please note that the hearing in the above captioned case, which was scheduled to occur on: 11/12/04 has been continued to: Date e: 1 12 :4529 04 PM 7MSPRINGS, OURT 09-3-03' STREET, BOX 167 Tim PA 17065 If you have any questions, please contact this office immediately. Continuance requested by: PIONTEK, VICKI ANN If you are disabled and require assistance, please contact the Magisterial District office at the address above. 11/04/04 Date DlstrlctJustice My commission explret first Monday of Janu2.o ry, 10 -? SEA,0 ' L_AHISIT A AOPCS1s-oz DATE PRINTED:11/04/04 9:15:23 AM HEALTH OF PENNSYLVANIA OF: CUMBERLAND . +^ 09-3-03 lame. Hon. SUSAN K. DAY Add,`- 229 MILL STREET, BOX 167 MT. HOLLY SPRINGS, PA eiaPnone (717 ?" 486.7672 17065 ATTORNEYDEF PRIVATE : VICKI A. PIONTEK 116 W GREEN ST BOX 173 MECHANICSBURG, PA 17055-0173 NOTICE OF INTENT TO DEFEND PLAINTIFF: FCITIFNANCIAL NAME and ADDRESS 1 VALLEY ST. SUITE 103 LCARLISLE, PA 17013 vs. NAME and ADDRESS 7LINDSEY JR, TERRY 120 S HANOVER ST APT/STE B - CARLISLE, PA 17013 L 7 J 7 J Docket No.: CV 0000300 04 Date Filed: 10/01/04 ' :vss HEARING: ' CIVIL ACTION, HEARING . + - Date: 12/29/04 Time: 1:45 PM PLAINTIFF: CITIFINANCIAL, r +.. -- ,-,.t Place:DISTRICT COURT 09-3-03 229 MILL STREET, BOX 167 MT. HOLLY SPRINGS, PA 17065 You are hereby notified that the defendant named below has given notice of his intent to present a defense at the hearing in the above case. DEFENDANT: LINDSEY JR, TERRY 11/04/04 Date District Justice 6 4 My commission expires first Monday of January, 2010. % SEAL DATE PRINTED:11/04/04 9:15:50 AM nH IAIT AOPC 623-93 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND No 09-3-03 DJ Name. Hon. SUSAN R. DAY AOd'0551 229 MILL ST, BOX 167 MT. HOLLY SPRINGS, PA Telephone (717) 486-7672 17065 ATTORNEY DEF PRIVATE : VICKI A. PIONTEK 116 W GREEN ST BOX 173 MECHANICSBURG, PA 17055-0173 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE rCITIFINANCIAL NAME and ADDRESS -1 1 VALLEY ST. SUITE 103 LCARLISLE, PA 17013 Vs DEFENDANT: . J NAME and ADDRESS FLINDSEY TR, TERRY 120 S HANOVER ST APT/STE B CARLISLE, PA 17013 L _J DocketNo.: CV-0000300-04 Date Filed: 10/01/04 M THIS IS TO NOTIFY YOU THAT: ? ' Judgment" DEFAULgT TrTnMffim DFF -: ?X Judgment was entered for: (Name) T.TNDc!py TR TFRRV Judgment was entered against: (Name) C_TTT FTNAN( TAT in the amount of $ nn on: (Date of Judgment) X29104 Defendants are jointly and severally liable. (Date & Time) El Damages will be assessed on: 7 This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ Judgment Costs $ Interest on Judgment $ Attorney Fees $ Total It Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE-ENTRY -OPJUDGMENT-BY-FILING A'NOTtCE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THIS?JUI?6TvtEN4. MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR.FIXA S)N F!1CL1,/SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 4l 1,2` '/ Date _ G Distr tt Justice I certify that this is a true nd Correct copy of the reco d of th proceedings containing the 6u lgment;, Date District Justice My commission expires first Monday of January, 2010 . SEAL E A H 8 IT C AOPC 315-03 DATE PRINTED: 12/29/04 2:28:57 PM Vicki A. Piontek, Esq, t Cory D. Piontek, Esq. t' t-also licensed in Wisconsin • - also licensed in Virginia PIONTEK LAW OFFICE 24 WestGovemorKoad Hershey, PA 17033 February 4, 2005 Telephone: 717-533-7472 Fax: 800-362-7919 palaw@justice.com Citifinancial 1 Sally Street, Suite 103 P.O. Box 1232 Carlisle, PA 17013 By Certified U.S. Mail Re: Citifmancial vs. Terry Lindsey Account No. 67330658-3425790 To Whom it May Concern Once again I am writing to your company by certified mail. Be advised that we represent the above captioned consumer debtor, Terry Lindsey. Cease and desist all telephone calls and letters to Terry Lindsey. He is not able to pay the alleged debt which you company is claiming that he owes. He does not intend on paying the alleged debt. We have taken this matter to court, and we won against your company at the district justice level. The district justice granted a judgment which your company is not able to appeal, and your company may never bring suit on this action ever. Terry Lindsey wishes to be left alone. He wishes not to be contacted by your company. Do not call him. Do not write to him. Do not send him any collection letters. Do not send him any invoices. Do not cause any third party agent or bill collector to write to him, send him any invoices or send him any collection letters. Sincerely,,- Vicki Piontek, Esquire Attorney at Law -ExH1617 _D Z 7p03 ]68p pppy 8 abO? a l6gp ppp4 p43 95pg o y m gp 4 SO 3 95pg Wo 001 .? 3?? ?3 _ n T 8 v co O 3 w m J m 2 1 8 i S i n . ? m c a E-X H 16 ji N D? $l N N 0 z O ui W I ? cr m (b O O O 0 ip Cl ui W -0 cn E3 C33 ti 1 O ^ 1 . O w A S ? ? b m 3 ? 2 c IR ?o? Q ? O 0 3 3 'o 0- n "?f5 rn m n '" N 3 p ?5 3 d?. o mg;:w QSn=? m m n lm` n ygda?+D • S o ? A o 3??H.09 w g m `? 3 • a O ?b m m $ tA n n ?i 3 0- y ?n O 00 Z or Vicki A. Piontek, Esq. t Cory D. Piontek, Esq. t* f-also licensed in Wisconsin * -also licensed in Virginia PIONTEK LAW OFFICE 24 WwGovm1orRoad Hershey, PA 17033 March 1, 2005 Citifinancial 1 Sally Street, Suite 103 P.O. Box 1232 Carlisle, PA 17013 Telephone: 717-533-7472 Fax: 800-362-7919 palaw@justice.com By Certified U.S. Mail Re: Citifmancial vs. Terry Lindsey Account No. 67330658-3425790 To Whom it May Concern Once again I am writing to your company by certified mail. Be advised that we represent the above captioned consumer debtor, Terry Lindsey. Cease and desist all telephone calls and letters to Terry Lindsey. He is not able to pay the alleged debt which you company is claiming that he owes. He does not intend on paying the alleged debt. We have taken this matter to court, and we won against your company at the district justice level. The district justice granted a judgment which your company is not able to appeal, and your company may never bring suit on this action ever. Terry Lindsey wishes to be left alone. He wishes not to be contacted by your company. Do not call him. Do not write to him. Do not send him any collection letters. Do not send him any invoices. Do not cause any third party agent or bill collector to write to him, send him any invoices or send him any collection letters. Sincerely, Vicki Piontek, Esquire Attorney at Law >EAH 181-r r1 9 5 0a33 ?,m _ m =?woav 4- 0 3 5 3 J EL m P ? =+- ;: a??=gam 2 D ?? a N W a ? 0 p 5aH O y O 3 0 N 0 3 -J w g >R o m ? o ? r A W O ??'9 A3 ru e -- o ?b(3y ? nZ r o b ru 13- Lnn f 3 C) L ? y o ? N ? ? ? m ttff z t ? o 3 ?lOi `iEKLt1 VV Ql'1'1CL', 24 West GovanorRoad Hersl?, PA 17033 March 1, 2005 palaw@justice coin Telephone: 717-533-7472 Fax: 800-362-7919 By Certified U.S. Mail ndsey 325790 to your company by certified mail. Be advised that we caner debtor, Terry Lindsey. Cease and desist all telephone leged debt which you company is claiming that he owes. eged debt. We have taken this matter to court, and we won against your company at the district justice level. The district justice granted a judgment which your company is not able to appeal, and your company may never bring suit on this action ever. Terry Lindsey wishes to be left alone company. Do not call him. Do not write to him. He wishes not to be contacted by your Do not send him any collection letters. Do not send him any invoices. Do not cause any third party agent or bill collector to write to him, send him any invoices or send him any collection letters. U l.1?- `t , uvCtL(Z Sincerely, Vicki Piontek, Esquire Attorney at Law V"191T Ed, r.? ?rv yA r Y? n 7004 1160 0002 1104 2854 7004 1160 0002 1104 2854 my G o ? 3v :p ?:? w cm ¢m m ? ? ? _ V ? V V V W ? W V W ? V V ? V V ? a V E"XHt8 (i L3 Total Payment DUe $1,366.48 Due Date 02/01/05 Prior Balance $11 022 40 r Curent Balance' $11 62-2,40 gp 'Payments received after the as of date will not be reflected on this statement. Please mad your payment 6S7 days prior to the due dale to ensure that it is received by us on or before the due dale. DESCRIPTION AS OF PAYMENTS 1/12/05 BCREDITS APPLIED TO I APPLIED TO BALANCE INTEREST/FEES SERVICES/ PRODUCTS Regular Payment Amount No Activity " cnarges nor reuected on mis statemel FOR STATEMENT INQUIRIES: CitiFinancial 6010 FAIRVIEW RD SU 105 P O BOX 221649 CHARLOTTE, NC 28222-1649 (800) 256-1116 186.86 a REFERENCE YOUR ACCOUNT NUMBER: 67330658-3425790 Credit Bureau Disputes: CitiFinancial, Credit Bureau Corrections Dept., P.O. Box 499, Hanover, Maryland 21076 In North Carolina: CitiFinancial, Inc.; CitiFinancial Services, Inc. CITIFRNANCIAL SERVICES, INC P O'BOX 221649 CHARLOTTE, NC28222.1649 A d Payment Due Date 02101 / 05 bo uritNumber 0733:06'58-34,25790 Regular Payment ? ? ?yM ate Payment /Cha Late q? 186.86 ?79 62 ?nanC(a L Address Service Requested L Sar vices 8 Pro duets $o 00 g d TOTAL PAYMENT DUE 1 366 48 c Additional al Late Late Charges Du O 02/12/06 Please mail this coupon Total Payment $ a with your payment. Amount Enclosed Please check here to indicate mailing a dress / p7-7, ? number changes and enter them on back of coupon. Mail Payment To: CitiFinancial 01 01 14910 P.O. Box 8020 TERRY R LINDSEY JR 0 South Hackensack, NJ 07606-8020 120 S HANOVER ST B gsol CARLISLE:, PA 17013-3420 1111 11 1111111 1111111111 111111111111 1111111111 ?ILnn111111111111111 067330658034257901366480018686000000007606802009 E xH tB i T F 02/01/05 CITIFINANCIAL PO BOX 222178 CHARLOTTE NC 28222 1-888-877-6168 February 8, 2005 TEMP - RETURN SERVICE REQUESTED TERRY R LINDSEY JR 120 S HANOVER ST # B CARLISLE PA 17013-3420 Re: Customer Assistance Plan Acct. #: 3306580342579 Dear Customer(s), L W k ::: IRE NI C ME E SSAGE Content of Message Created by Sender 016512 Printed & Mailed a( Direction of Sender by National Telewire Corp. 6512 Enclosed you will find a Customer Assistance Plan Agreement. If approved, this program can: 1. Reduce your monthly payment amount from $187 to $121 2. Bring your account current 3. Reduce your interest rate from 18.99% to 4.40%, 4. Protect your credit rating All you need to do to qualify for this program is: 1. Sign the enclosed agreement. 2. Above your signature, enter the reason you are requesting a Customer Assistance Plan. 3. Enter and/or correct all personal information on top section of form. Two telephone numbers where Yom-ran be reached MUST be entered. grder to be considered for anorec_t 4. Make the first payment of $121. You have the choice of two payment methods. A) Pay by phone, or B) mail a check or money order. A) To pay by phone, call 1-888-877-6168. Have your checkbook in hand when you call B) Mail check or money order to Citirinancial, PO Box 222178, Charlotte, HC 28222 Be sure to enclose the agreement and write your account number on the payment. 5. Mail or fax the enclosed Customer Assistance Plan Agreement so we receive it as soon as possible. You may fax it to us at 1-972-657-1713 or mail it to us at the address above. If you do not have a fax machine, you may go to the branch where you obtained your loan. The branch will be happy to fax the agreement to us at no cost to you. We encourage you to take advantage of this o assistance, please call us at 1-888-877-6168pportunity. If we can be of further Sincerely, CitiFinancial CH1 EXH 1 13 IT G -A. This is an attempt to collect a debt and any information will be used for that purpose. Tayments received after the 'as of'dale will not be reflected on this statement. Please mail your payment 5-7 days pro, to the due dale to ensure that it is received by us on or before the due date, w??w DESCRIPTION Regular Payment Amount " * No Activity ""' AS OF 01/13/05 03/01/05 PAYMENTS APPLIED TO APPLIED TO A CREDITS BALANCE INTEREST/FEES charges not reflected.on this statement elf your account is precompNed check ou have on youura c payment has b, ext, FOR STATEMENT INQUIRIES: CihFinancial 6010 FAIRVIEW RD SU 105 P 0 BOX 221649 186.86 SERVICES/ PRODUCTS r ca pvX 2211519 ', CHA'RLG5TP' , Md 2b2'?8?1 X49 I' , . ' t. di 'Payment Due D 03 01 0s Ad tlyryt'?JpMbe? ?67A9A' ` • 65A .34 F5Y9A Regular Payment ?+ fiM ?, $186.86 Ct} li fin n?fal L Addr ess Service Requested ate Pay nt /Ch g 1 386 07 - Services & Products ° 0. 00 ' TOTAL PAYMENT DUE u 51 72 93 _ Addibonel Late Charges Due On 0.312 OS Please mail this coupon Total Payment with your payment. Amount Enclosed $ Please check here to indicate mailing address / phone ? b num er changes and enter them on back of coupon. Mail Payment To: CitiFinancial 01 01 16546 P.O. Box 8020 TERRY R LINDSEY JR 0 South Hackensack, NJ 07606-8020 120 S HANOVER ST B 8301 CARLISLE, PA 17013-3420 Illltllltlllllttlllllll lltllllllllllltllllllllltllllllltllllll IIIIIIIIIIIIIttrllllltrllftlllltllrlltllllltrltlllllllltllllll 0 ie1- H -X 0673306580342579015729300186860000000 0680 FindLaw@Justice.com Mail Read Mail in Inbox FindLaw I Legal Professionals I Students I Business I Public I News FindLaw, email@Justioe.com 'a... , Cases & Codes I Forms Legal Subjects I Federal I State I Library I Boards Lawyer Search City or ZIP State Select a Practice Area palaw@justice.com h hS Reply Reply all Forward Move to Trash From: Terry lindse <'a t Folders Inbox Sent Drafts Trash Filters Addresses Preferences Help Emote Trash I 7 pe equara@yahoo.com> Date: 1 Mar 07:37 (PST) To: palaw@justice.com Subject: Citi Finacial Case ...Terry Lindsey Save Address Print- View Show Headers Show as Text Report Junk_Mail Yesterday i received a phone call from Citi telling me that they have not received any certified mail telling them they could not be in contact with me...The date and time of the phone call was February 28th at 6:15 pm. The phone number that they called from was 614-352-4803. The lady was very rude and actually hung up the phone on me...Also i have received yet another statement in the mail from them.. Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://maii.yahoo.com Change message text width in Settings. FindLaw RESOURCES Advertising Info • Add URL • Help - Comments Company I Privacy_F?olicy Disclaimer Page I of I Markpt r-nta, Law Firm FirmSites I Let Find I Inbox message 4 of 23 AA Jobs@FmdLaw - Site Mao Copyright ® 1994-2003 Findl-aw RxH181T z* A?J A N W • Top Headlines Supreme Court Commentary Crime Cyberspace International US F D RA LeW Constitution Codes Supreme_CourtOpinons Circuit Opinions U ESTA7SEARCHeLaw Stata Coostitutions State Codes Case La Law w RE: yer Directory vendor Directory Dictionary Forms LawCrawler Library Summaries of LEGAL SUBJECTS: Constitutional Intellectual Property Criminal Labor more... GOVERNMENT RESOURCES: US Federal us State Directories more... COIN7ERNUNT R O R Country Guides T- dg World Constitutions more.- I NITY' Message Boards Newsletters Gre-dy_Associates Boards TOOL S Ogi0 Calendar CLE Wes_t_wprkSpace Fir-§-- Toolbar http://mail.justice.com/mai I/msg?fld=lnbox& id=2595 3/l/2005 Past Due Loan Amount $ 1 , 595.32 Loan Payment $ 186.86 Total Payment Due $ 1,782.18 • DESCRIPTION Due Date Current Balance` Prior Balance AS OF_ I AMOUNT 04 / 01 /05 'Not a payoff balance: $ 11 , 022.40 call us for details. 5 11,022.40 APPLIED TO LATE APPLIED TO FOR STATEMENT INQUIRIES: CitiFinancial 6010 FAIRVIEW RD SU 105 P O BOX 221649 CHARLOTTE, NC 28222-1649 (800) 256-1116 as REFERENCE YOUR ACCOUNT NUMBER 67330658.3425790 Credit Bureau Disputes: CitiFinancial, Credit Bureau Corrections Dept:, P.O. Box 499, Hanover, Maryland 21076 In North Carolina: CitiFinar ial, Inc.; CitiFinancial Services, Inc. P 0. BOX 22154 CHARI INC 28222.TS4y AcdourYt7+lumber 673$U6'S6? 34257'96 Total Payment Due c CltlfmanclalS" 92 18 £ Address Service Requested Payment Due Data - 04/01/05 Late Charges Due Aft 04112/05 19.26 5 Please mail this coupon Total Payment with your payment. Amount Enclosed $ Please check here to indicate mailing address / phone ? number changes and enter them on hack of coupon. Mail Payment To: CitiFinancial TERRY R LINDSEY JR 01 01 24129 P.O. Box 8020 120 S HANOVER ST B 60 South Hackensack, NJ 07606-8020 CARLISLE, PA 17013-3420 Rs01 ?xH?Bj-r T? 067330658034257901782180018686D00000007606802001 you direct us Past Due Loan Amount $ 0 .00 Due Date 04/01/05 `Not a payoff balance Loan Payment Current Balance' $ 186.86 Prior Balance $ 8,326.40 0 ; call us for details. $ 8,326.40 Total Payment Due $ 186.86 DESCRIPTION I AS OF APPLIED TO AMOUNT MbRIeS LATE APPLIED TO FOR STATEMENT INQUIRIES: CitiFinancial 11436 CRONHILL DR STE H P O BOX 913 OWINGS MILLS, MD 21117-0700 (800) 346-3051 • -r --1 will ue eppueu as msclosed in the loan contract unless you direct us otherwise m wrRing. REFERENCE YOUR ACCOUNT NUMBER: 67200908-0325046 Credit Bureau Disputes: CitiFinancial, Credit Bureau Corrections Dept., P.O. Be, 499, Hanover, Maryland 21076 In Maryland: CitiFinancial, Inc. Address Service Requested Please mail this coupon with your payment. Total Payment - Amount Enclosed $ Please check here to indicate mailing address / phone ? number changes and enter them on back of coupon. Mail Payment To: CITIFINANCIAL 01 01 17760 P 0 BOX 913 TERRY R LINDSEY JR 0 OWINGS MILLS, MD 21117-0700 120 S HANOVER ST B RS02 CARLISLE, PA 17013-3420 nl nl unn??n??ur??n?n ?n?l???nu1?l???nr?nl?? -T 067200908032504600186860018686000000021117070001 ' P.O. Box 17099 Baltimore, MD 21297-0194 TERRY R LINDSEY JR 120 S HANOVER ST B CARLISLE PA 17013 Account: 09080325046 US/ 2W U5 Because your loan wasn't paid as agreed, the loan office has charged it off, and has sent your loan to our centralized collections office. We understand that many people have money problems from time to time. There are still good reasons for you to arrange to make payments on this loan. Agreeing to a repayment plan can still improve your credit rating, even on a charged off account. We'll work with you to find a way to get this loan back on track. Maybe we can work out reduced monthly payments or a settlement for less than the full loan balance. We'll be calling you soon to talk about this, or you can call us at the toll free number listed below. Sincerely, TEMA Toll Free: 1-800-451-1329 PLEASE NOTE, THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE /lco ?XH ?8 j7' L? c ti financial V bb L?j ??.;?J et- 0.n 1 ; n? vm r, P K 13 ??, hs y ? ,w J I? ??'7 `717- y2I -?s-J;z EXHIBIT m* Past Due Loan Amount $ 0.00 Due Date 05 / 01 / 05 `Not a payoff balance; Loan Payment Current Balance` $ 8,326.40 call us for details. $ 186.86 Prior Balance g 8,326.40 Total Payment Due $ 186.86 DESCRIPTION AS OF' I AMOUNT as disclosed in the loan contract unless you direct us OWINGS MILLS, MD 21117-0700 Account Nlugl6ar 6720 Address Service Requested citi financial" Please mail this coupon with your payment. APPLIED TO FOR STATEMENT INQUIRIES: Cibl'inancial 11436 CRONHILL DR STE H P O BOX 913 OWINGS MILLS, MD 21117-0700 (800) 346-3051 808.0325046 Total Payment Due $186.86 Payment Due D t 05 / 01 / 05 Total Pa ment Amount Enclosed $ number changes and enter them on back of coupon Mall Payment To: CITIFINANCIAL 01 01 14080 P 0 BOX 913 TERRY R LINDSEY JR 0 OWINGS MILLS, MD 21117-0700 120 S HANOVER ST B CARLISLE, PA 17013-3420 asaz IIIIIIIIIII11Illlllllllllllll 11 llrllllll llllllllllllllllllllll I III III II III nl nlul nll..l??nlllllnlultl?llnulllllnl?urll 06720090803250460018686001868600000002111?7707000/ or w Vicki Piontek Full Name: Lindsey, Terry Last Name: Lindsey First Name: Terry Home: (717) 421-9512 5-16-05 tcfc tt Terry. He got another phone call from Citifinancial. EXNIg17 ®* PLAINTIFF'S ATTORNEY FEES Review of File: 2 hours .................................................. $ 500.00 Consultation with Client: 2 hours ...................................... $ 500.00 Drafting of Complaint: 3 hours ........................................ $ 750.00 Driving to Courthouse to Attend Hearing at District Justice Susan Day's Office. Round trip. 3 hours .................................... $ 750.00 Court Hearing: 1 hour ............................................... $ 250.00 Document Preparation & Service of Process: 2 hours ............. $ 500.00 Correspondence with Defendant: 2 hours ........................... $ 500.00 Total for Attorney Vicki Piontek's Lawyer fees ($250.00 per hour): $ 3,750.00 Exhibit P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Tent' R. Lindsey, Jr. 120 S. Hanover St. B Carlisle, PA 17013, Plaintiff CIVIL ACTION NO. c)s-?2Pa -2, vi C Vs. Citifinancial I Valley St. Suite 103 Carlisle, PA 17013 also Citfinancial 6010 Fairview Rd. SU 105 P.O. Box 22164 Charlotte, NC 28222-1649 Defendant APPLICATION FOR LEAVE TO PROCEED IN FORMA PAUPERIS Plaintiff / Applicant wishes to file a civil action against Defendant for unlawful debt collection activity, and to prevent further violation of Pennsylvania's laws on debt collection. 2. Applicant / Plaintiff by counsel applies for leave to proceed in forma pauperis, and request that the filing fee for this civil action will be waived. 3. Counsel hereby certifies that said applicant is insolvent, and counsel has received no funds from Applicant / Plaintiff for this civil action. Wherefore, Plaintiff prays that the filing fee and the Sheriff service fee for this civil action will be waived. AL, =?c pk T-91-oS VPionte, Esquire Date Attorney for Plaintiff 24 West Governor Road Hershey, PA 17033 717-533-7472 ORDER AND NOW, this day of , 2005, upon presentation and consideration of the above Application for Leave to Proceed in Forma Pauperis and certification thereof, said Application is hereby granted. The filing fee and the sheriff service fee shall be waived. _r lil ='. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Terry R. Lindsey, Jr. 120 S. Hanover St. B Carlisle, PA 17013, Plaintiff Vs. Citifinancial 1 Valley St. Suite 103 Carlisle, PA 17013 also Citfinancial 6010 Fairview Rd. SU 105 P.O. Box 22164 Charlotte, NC 28222-1649 Defendant CIVIL ACTION NO. ),,0.2 2,_ 0 v k 't c APPLICATION FOR LEAVE TO PROCEED IN FORMA PAUPERIS Plaintiff / Applicant wishes to file a civil action against Defendant for unlawful debt collection activity, and to prevent further violation of Pennsylvania's laws on debt collection. 2. Applicant / Plaintiff by counsel applies for leave to proceed in forma pauperis, and request that the filing fee for this civil action will be waived. 3. Counsel hereby certifies that said applicant is insolvent, and counsel has received no funds from Applicant / Plaintiff for this civil action. Wherefore, Plaintiff prays that the filing fee and the Sheriff service fee for this civil action will be waived. V -- ; ",T JC 5- 31- o. Vicki Piontek, Esquire Date Attorney for Plaintiff 24 West Governor Road Hershey, PA 17033 717-533-7472 ORDER AND NOW, this .3? day of N , 204 upon presentation and consideration of the above Application for Leave to Proceed a Pauperis and certification thereof, said Application is hereby granted f-Tie filing f and the sheriff service fee shall be waived. r v ' 1r zI 9 -C '?r." C-- i'lGi`! 9002 Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ns - ® 82;Z , CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573