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Home My WebLink About05-5791BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - Sl? LOUISE M LAMOREAUX 850 Yverdon Drive Camp Hill PA 17011-1850 Defendant CIVIL ACTION - LAW" COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-8037 BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls. SD Plaintiff V. LOUISE M LAMOREAUX 850 Yverdon Drive Camp Hill PA 17011-1850 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS -SW/ 7-I 1 CIVIL ACTION - LAW Complaint 1. The plaintiff is CITIBANK (SOUTH DAKOTA) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. The defendant is Louise M Lamoreaux, who resides at 850 Yverdon Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff, a national banking association, engages in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180035318168 hereinafter referred to as the credit card account. 5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card account in its books of account. 6. Plaintiff mailed defendant a written statement each month which accurately stated the debits and credits to the credit card account for the prior billing period. 7. Defendant received the monthly statements from plaintiff for the credit card account including the statement attached hereto as Exhibit A statement without protest, dispute or objection. 8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A statement thereby assented and agreed to the correctness of the balance due on the credit card account so as to constitute an account stated. 9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the Exhibit A statement, is $10,722.42. Wherefore, plaintiff demands judgment against defendant for the sum of $10,722.42, and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Attorney for The law firm of Burton Neil & Associates, P.C. is a debt collector. • 08/05/05 $15632.42 $3389.32 SITE:KC-CL TM:CO-5000 ACID:KCB7150 [=:vbi:':$>=aaE:>'- E:oifvi:>aaee>"::: A;A? 09/14/05 2 0: 40 : 3 7: CITI CARDS PO BOX 183058 LOUISE M LAMOREAUX COLUMBUS, OH 850 YVERDON DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Cities Driver's Edge olrka, Cltlm Platinum Select Card-Charter Rbts Account Number 5424 1800 3531 8168 Customer Sarviee: 1-SOO-866-9900 Total Credit Line Available Credit Line Cash Advance Limit Available Cash Limi t New 11alance $13940 $0 $5600 $0 $15632.42 BOX 6500 Statement/ Amount Over SIOUX FALLS. SD Closing Date Credit Llna Past Due Purch)Adv Minimum Minimum Due Amount Due 57117 07/13/2005 $1692.42 + $1270.77 + $426.13 = $3389.32 SPie Data Post Date Reference Number Activity Since Last Statement Amount Standard Purch 7/13 CREDITSHIELD PREMIUM 8.92 74 0000 0000000000 7/13 LATE FEE - JUN PAYMENT PAST DUE 39.00 66 0000 0000000000 6/20 6/20 X1TX5R00 AIG LIFE - TERM INS 301300075620 DE 58.79 61 N5969USA o r 75414915171 7/13 PURCHASES*FINANCE CHARGE*PERIODIC RATE 382.13 84 0000 0000000000 DRIVER'S EDGE REBATES SUMMARY Purchase Rebates Earned Ad7?ustments / Expired NEW DRIVER'S EDGE REBATES Activity This Period 1 -1 0 Purchase Rebates Earned PREVIOUS DRIVER'S EDGE REBATES Total Rebates Earned Total Rebates Expired Total Rebates Redeemed Total Rebates Available Previous Balance 150 Lifetime Activ303 153 0 150 Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 2.26 rebates will expire on AUGUST 11, 2005 Your late fee was based on your account balance as of the payment due date (07/07/05), which was $15,202.37. Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am - 5 pm, Central Time. EXHIBIT Sale Date Post Date aeterence Number Activity Since Last Statement Amount Account Summary Previous (+) Purchases (- Payments +) FINANCE (_) New Balance &Advances &Credits CHARGE Balance PURCHASES $15,143.58 $106.71 0.00 $382.13 $15,632.42 ALCES 0.00 4 0. 0 00 1 8 3 TOT $15,1 3 .58 $1 6. 0.00 $3 2.13 $15,6 2.42 Rate Summary Sd Purch $15,374.40 0.08285%(D) 30.240% 30.240% rd Adv $0.00 0.08285%(D) 30.240% 30.240% Verification 6Y Brit _ am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff Citibank (South Dakota) N.A. retained to perform services including but not primarily limited to collecting delinquent debt. 1 am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 P; Section 4904, relating to unsworn falsification to Date:_ "l J Signature: i z , ca rT .J GJ :{ SHERIFF'S RETURN - REGULAR CASE NO: 2005-05791 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS LAMOREAUX LOUISE SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LAMOREAUX LOUISE M the DEFENDANT , at 1720:00 HOURS, on the 9th day of November at 850 YVERDON DRIVE CAMP HILL, PA 17011-1850 by handing to ROBERT LAMREAUX, HUSBAND 2005 a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 .00 41.44 Sworn and Subscribed to before me this !?'? day of %VOVe,Mber ront5- A.D. rot ary So Answers R. Thomas Kline 11/14/2005 BURTON NEIL & ASSOCIATES By: -Deputy Sher' f CITIBANK (South Dakota) N.A. Plaintiff, V. LOUISE M. LAMOREAUX, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 05- 5791 Civil Term CIVIL ACTION - LAW ANSWER AND NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted, 4. Admitted. 5. Denied. Proof is demanded. 6. Denied. Any statements did not accurately reflect debits or credits. 7. Denied. Objections have periodically been made concerning charges for unauthorized debits for credit-shield programs, life insurance, late fees, interest rate, etc. 8. Denied. Defendant has not assented to the correctness of any alleged balance due to Plaintiff Citibank. 9. Denied. Proof is demanded. NEW MATTER 1. Beginning August, 2005 sums totaling $5,410.00 have been remitted to Plaintiff and should have been credited to Defendant's account. The account is therefore not in arrears, nor is it a "bad debt." t 2. This action may involve an attempt to obtain fees and costs or otherwise may be in violation of the Fair Debt Collection Practices Act. WHEREFORE, Defendant demands a dismissal of this action. - 850 Y?erdon Drive Cato Hill, PA 17011 (717) 379-8237 Pro Se 4A CERTIFICATE OF SERVICE I, Louise Lamoreaux, Defendant in the matter docketed to Civil Action 05-57919 hereby certify that I have, this day, deposited a true and correct copy of Answer and New Matter in the United States mail, postage prepaid, addressed to: Burton Neil & Associates, P.C. 1060 Andrew Drive Suite 170 West Chester, PA 19380 November 21, 2005 :? 'ii ,_ ?; ?J_ co __ t-_ BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE LAMOREAUX NO. 05-5791 Civil Defendant : CIVIL ACTION - LAW Plaintiff's Reply to New Matter 1. Denied. Defendant made payments totaling $4,910.00 since August 25, 2005 as follows: plaintiff received a payment from defendant in the sum of $4,410.00 on August 25, 2005 and a payment in the sum of $500.00 on October 17, 2005. It is admitted that these sums were credited to defendant's account. The account was in default prior to these payments and remains in default. 2. Denied. There are no allegations of fact set forth in this averment. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required. BURTQN.NEIL & ASSOCIATES, P.C. By: - 7 Burton Nei T, Esquire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. Verification Burton Neil, attorney for plaintiff Citibank (South Dakota) N.A. hereby verifies the statements of fact in lieu of plaintiff as plaintiff is outside the jurisdiction of the court and the verification of plaintiff can not be obtained within the time allowed for the pleading. The averments of fact in the within pleading are true and correct upon information and belief based on information provided to the undersigned verifier by plaintiff. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unworn falsification to the authorities. t Burton Neil, Esquire BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5791 Civil LOUISE M LAMOREAUX Defendant : CIVIL ACTION - LAW Certificate of Service I, BurtonNeil, Esquire, do hereby certify that I served a true and correct copy of the within Plaintiff's Reply to New Matter onpro se defendant, Louise M Lamoreaux, at her address of record via first class mail, postage prepaid on the date set forth below. BURTON NIL & ASSOCIATES, P.C. Date: 1 + D BY. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-8037 F.. M1 ?? _+ 4. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, Id. no. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attomey for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M. LAMOREAUX NO. 05-5791 Civil Defendant : CIVIL ACTION - LAW Plaintiffs Motion For Sanctions Plaintiff, Citibank (South Dakota) N.A. by and through counsel, Burton Neil, Esquire and Burton Neil & Associates, P.C., moves the Court pursuant to Pa.R.C.P. 4019 for sanctions against defendant Louise M. Lamoreaux due to her failure to serve answers to interrogatories. 1. Plaintiff served defendant with interrogatories on December 17, 2005. A copy of the interrogatories is attached as Exhibit A. 2. Defendant did not respond to the interrogatories. 3. On January 26, 2006, plaintiff s counsel wrote defendant requesting that she contact plaintiffs counsel to confer regarding her failure to respond to the interrogatories. 4. Concurrence of opposing side was sought. On February 5, 2006 and February 15, 2006, voicemail messages were left for defendant to contact plaintiffs counsel. 5. To date of this motion, defendant did not answer the interrogatories. WHEREFORE, plaintiff moves the Court to enter an Order compelling defendant to serve full and complete response to plaintiff s interrogatories aspejfthe attached proposed Order. BURTON NEIL &.ASSOCIATES, P.C. By: o Neil, Esquire Attorn y for Plaintiff In making this communication, we advise our firm is a debt collector. BURTON NEIL & ASSOCIATES, P.C. Burton Neil, Esquire, Id. no. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COLNTY, PENNSYLVANIA V. NO. 05-5791 LOUISE LAMOREAUX Defendant : CIVIL ACTION - LAW Plaintiff's First Set of Interrogatories to Defendant Plaintiff hereby serves these written interrogatories upon defendant who is to furnish written answers within thirty (30) days after service of these interrogatories in accordance with the Pennsylvania Rules of Civil Procedure. The answers shall be inserted in the space provided after each of the interrogatories; please attach additional pages if more space is needed for the answers. These interrogatories are continuing and demand is hereby made to amend or supplement the answers as is required by the Pennsylvania Rules of Civil Procedure. If the answering party is a minor, a decedent's estate or an individual who is incompetent or under legal disability to provide answers, the individual providing answers shall state his or her name and the authority under which he or she is providing the answers. Full and complete answers the interrogatories must be provided and signed by the party making the answers. 1. If you contend that any credits reflected in the monthly billing statements you received were not accurate, explain in detail all reasons why you deny or dispute that the credits posted to the account were inaccurate. Set forth the date and amount of each inaccurate credit, the amount you believe is the correct credit and the date of the monthly billing statement in which the inaccurate credit appeared. EXHIBIT 2. To the extent you deny or dispute the accuracy of the credits posted in the monthly billing statements, did you send a written billing error notice to Citibank (South Dakota) N.A. to dispute or protest the credits you contend were not accurate? 3. If you contend that any debits reflected in the monthly billing statements you received were not accurate, explain in detail all reasons why you deny or dispute that the debits posted to the account were inaccurate. Set forth the date and amount of each inaccurate debit, the amount you believe is the correct debit and the date of the monthly billing statement in which the inaccurate debit appeared. 4. To the extent you deny or dispute the accuracy of the debits posted in the monthly billing statements, did you send a written billing error notice to Citibank (South Dakota) N.A. to dispute or protest the debits you contend were not accurate? 5. In paragraph 7 of the answer to the complaint, you alleged that objections were periodically made concerning charges the account. When were these objections made and to whom were they made? 6. With respect to objections periodically made, provide detail for each objection a. Describe all reasons why you claimed a charge was not accurate. b. If you wrote to Citibank (South Dakota) N.A. did you enclose any information such as sales slips, payment records or other documents to support your position that the amount was not accurate, c. With respect to the disputes about billing errors do you contend there were any unauthorized charges to the account? d. Do your objections pertain to any charges that listed the wrong date or amount? If so, describe any such charges. 7. With respect to objections periodically made, did you describe any failures to post payments and other credits, such as returns? 8. With respect to objections periodically made, did you describe any failures to send bills to your current address? If so, did you provide plaintiff with your change of address, in writing, at least 20 days before the billing period ends? 9. With respect to objections periodically made, did you describe any charges for which you asked for an explanation or written proof of purchase along with a claimed error or request for clarification? 10. Provide the date and amount of each payment comprising the $5,410 in credits referenced in paragraph 1 of defendant's new matter. 11. According to defendant's own records, what is the current balance owed to Citibank (South Dakota) N.A. on the account? Burton Neil & Associates, P.C. By Burton Neil, Esquire In making this communication, we advise our firm is a debt collector. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, Id. no. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M. LAMOREAUX NO. 05-5791 Civil Defendant : CIVIL ACTION - LAW Plaintiffs Memorandum of Law in Support of Motion For Sanctions Plaintiff, Citibank (South Dakota) N.A. filed suit against defendant to recover the balance owed on a credit card. Defendant filed an answer to the complaint. Plaintiff served defendant with interrogatories which are attached to plaintiff s motion. Defendant failed to respond to plaintiffs discovery. Pursuant to Pa. R.C.P. 4109 seeks the Court to enter an order compelling defendant to respond to plaintiff s discovery. Pa R.C.P. 4019(a)(1)(i) provides "The court may, upon motion, make an appropriate order if a party fails to serve answers... to written interrogatories under Rule 4005." An appropriate order would be one pursuant to Rule 4019(c)(5), that is, "such order with regard to the failure to make discovery as is just " Under the circumstances, plaintiff requests that an order be enter compelling defendant to answer plaintiff s interrogatories. BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK SOUTH DAKOTA N.A. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05-5791 Civil LOUISE M LAMOREAUX Defendant : CIVIL ACTION - LAW Certificate of Service I, Burton Neil, Esquire do hereby certify that I served a true and correct copy of the within Motion for Sanctions, proposed Order and supporting Memorandum of Law onpro se defendant, Louise M Lamoreaux at his/her address of record via first class mail, postage prepaid on the date set forth below. BURTON NEIk'& ASSOCIATES, P.C r Date: G BY: uon eil, Esquire Atton for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-8037 , ? '? ?- ' , L a t FEB 0 9 2007,F/ CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5791 Civil LOUISE M. LAMOREAUX Defendant : CIVIL ACTION - LAW ORDER AND NOW, this day of wry , 2006 on consideration of Plaintiff's Motion to Compel Answers to Interrogatories, it is hereby Ordered that the Defendant Louise M. Lamoreaux is directed to answer Plaintiff's interrogatories within 20 days of the date SX,V "46. -1 of this Order. A BY THE COURT: e o`% 9 1 .g WV £ 1933 LQQI kViO NOHIOdd 3HI 30 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX Defendant NO. 05-5791 Civil : CIVIL ACTION -LAW Certificate of Service I, Burton Neil, Esquire, do hereby certify that I served a true and correct copy of the Court's February 12, 2007 Order on pro se defendant, Louise M Lamoreaux, at her address of record via first class mail, postage prepaid on the date set forth below. Date: f 0 Burton Nei'-& AAsociates, P.C. Burton Neil, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-8037 1 -L?1 ',? ? ?;r?I ?..ry ? .. i r ? . r 4 M J .? -.. i ?. y - _,L ?, ??? ? ? { -? + ?{ i ? ? f ?"'yj ? t =?4 ?? G..7 V i BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, Id. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX : NO. 05-5791 Civil Defendant : CIVIL ACTION -LAW Plaintiffs Motion for Summary Judgment Plaintiff, Citibank (South Dakota) N.A., hereby moves under Pa R.C.P. 1035.2 for summary judgment against defendant in the sum of $9,222.42 for the following reasons: 1. The pleadings, which consist of the complaint and answer, are closed. 2. Plaintiff served defendant with requests for admission which defendant failed to answer. A copy of plaintiff s requests and proof of mailing are attached hereto as Exhibit A. 3. Plaintiff s affidavit in support of the motion is attached as Exhibit B. As reflected in the affidavit, subsequent to the filing of the lawsuit defendant paid $1,500.00 which reduced the lawsuit balance from $10,722.42 to $9,222.42. 4. There is no genuine issue of material fact which will require a trial. Therefore, plaintiff is entitled to summary judgment. J WHEREFORE, plaintiff Citibank (South Dakota) N.A. moves the Court enter summary judgment pursuant to Pa R.C.P. 1035.2 for it and against defendant in the sum of $9,222.42 plus record costs of $96.94 for a total judgment of $9,319.36. BURTON N & ASSOCIATES, P.C. By: Attorney for Pl ntiff In making this communication, we advise our firm is a debt 9 LAW OFFICES Burton Neil BURTON NEIL & ASSOCIATES, P.C. Edward J. O'Brien 1060 ANDREW DRIVE, SUITE 170 Yale D. Weinstein WEST CHESTER, PENNSYLVANIA 19380 Derek C, Blasker 610-696-2120 Brit L suttell Facsimile 610-696-4111 Neil Sarker Email: Burton.neil@burt-law.com Refer to File # April 23, 2007 C-8037 Louise M Lamoreaux 850 Yverdon Drive Camp Hill PA 17011-1850 RE: Citibank South Dakota, NA Account with Louise M Lamoreaux Dear Ms. Lamoreaux: I herewith serve upon you Plaintiffs Request for Admissions. Very truly yours, Burton Neil BN/sb In making this communication, we advise that this firm is a debt collector. U.S . P ost al Se rvice CE R TIF IED MAIL RE CEI PT = (Dom For d esti elive c M rv ini ail Only on.,ar ; No Ins urance Cover age Pr ovided) fu V7 a N W7 M C7 Q 0 Q rq t3 r Ca r` EXHIBIT_ A __ t ¦ Complete Items 1, 2; and 3. Also complete item 4 If Restricted DsINwy Is desired. ¦ Print your nerve and address on the reverse so that we can return the card to you. ¦ Attach this card to the beck of the mailpieoe, or on the front If space permits. 1../ Ar icis Addressed to F-ouiSG Ls'"O?'ea4d?C A. S%F%d re E3 Agent X li3?e A-4-41 B. llecelred by (Prh J MW* C. Dame, of DWtMY ?TC1ftn Y-24-2 0. Is delrsry address dnlere A from asm 1 T MY" it Yes, errter delivery address below. 0 No ?So yyshi'e?1 Q??dG ? (?- ?03? Pfl /-?.Oft a servic.lyps Certified Mal ? Mel D Reylstensd R'Retrxn Reoelpm for Merdumdiae E3 knumd mom 0 C.O.R. 4. Restricted DelvsryR X%VS FON 13 Yee z Article Number 7006 0100 0005 5052 0975 (Th new from service Ps Form 3811, February 2004 Domestic Rerun Reoelpt 1025,540 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK SOUTH DAKOTA N.A. Plaintiff V. LOUISE M LAMOREAUX Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.05-5791 Civil : CIVIL ACTION - LAW Plaintiffs First Set of Requests for Admission to Defendant Plaintiff, by its undersigned attorney, hereby serves upon defendant the within Request for Admissions pursuant to Pa.R.C.P. No. 4014. Your attention is called to Rule 4014(b) which provides: Each matter of which an admission is requested shall be separately set forth. The matter is admitted unless, within thirty days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission an answer verified by the party or an objection, signed by the party or by the party's attorney; but, unless the court shortens the time, a defendant shall not be required to serve answers or objections before the expiration of forty-five days after service of the original process upon him or her. If objection is made, the reasons therefore shall be stated. The answer shall admit or deny the matter or set forth in detail the reasons why the answering party cannot truthfully do so. A denial shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify the answer or deny only a part of the matter of which an admission is requested, the party shall specify so much of it as is true and qualify or deny the remainder. An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless the answering party states that he or she has made reasonable inquiry and that the information known or readily obtainable by him or her is insufficient to enable him or her to admit or deny. A party who considers that a matter of which an admission has been requested presents a genuine issue for trial may not, on that ground alone, object to the request. That party may, subject to the provisions of Rule 4019(d), deny the matter or set forth reasons why he or she cannot admit or deny it. Requests for Admission 1. With reference to the monthly billing statements for defendant's credit card account with plaintiff copies of which are attached hereto as requests for admissions exhibits 1 through 25: a. Defendant admits that the detail set forth in each monthly billing statement accurately reflected for the monthly billing period defendant's use of the account and accurately reflected all charges and credits to the account. b. Within 60 days after defendant's receipt of each monthly billing statement defendant admits that no writing or other communication disputing, protesting or objecting to any of the charges or credits appearing in the monthly billing statements was sent by defendant to plaintiff. c. Defendant admits that with respect to each monthly billing statement, a written billing error notice was not sent to plaintiff. 2. Defendant admits that after receipt of the monthly billing statements marked exhibits 1-4,6-8,10-12,14-17,19,21 defendant made a payment which was reflected as a credit in the following month's statement. 3. Defendant admits that after receipt of the monthly billing statements marked exhibits 5,9,13,18,20,22-25 defendant did not send a payment to plaintiff. 4. Subsequent to receiving billing statement 25, defendant admits that the following payments were applied to her account: a. $4,410.00 b. $500.00 c. $500.00 d. $1,000.00 5. Defendant admits that the last payment made on the account was posted by plaintiff on August 25, 2005. 6. Defendant admits that balance owed on the account is $9,319.36. Burton Neil & Associates, P.C. By: Burton Neil, Esquire In making this communication, we advise that this office is a debt collector. C-8037 Verification 1, Louise M Lamoreaux, defendant in the within action, hereby verify that the statements of fact made in the foregoing Requests for Admission are true and correct to the best of the undersigned my knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: d - - Louise M Lamoreaux 08/07/03 $9747.36 3203.00 SITE:KC-CL TM:CO-5000 ACID:KCB5076 $-i_ ° M OWN. W. 1 12/09/05 18:52:55: CITI CARDS P.O. SOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 rcr a ? OO °`N . Citl' Driver's Edge* Platinum Select Card-Charter Rbts Account Number n^r?+r~ wan.,rea BOX 6500 5424 1800 3531 8168 SIOUX FALLS, SO PAYMENT MOST ME RECEIVE@ BY 2.00 PM LOCAL TIME On 00/07/2003 mtpra vwff Wa 57117 Wenwr4ft- I ; Oats Total Cndit Lin. Avaiabk CrWR Lim Cash Adva * LkMi Avalabl. Cash Lbws Now parano. 07/14/2003 $25000 $152p5v?2 $5600 !$5/600 $9747.36 crWt iJaa ` Past OWN klNnaie Du. Mlr*mm Armad Ow $0.00 ; $0.00 f $203.00 a $203.00 ..n..,.. ,www ... P.-W-Y aiaw ?fc ac.ww AMMwat 6/30 7205 Be Pa nts Credits A Adjustments 62 25 PO ME NOHANK YOU -200.00 0000 7/14 CREDITSHIELD PREMIUM 6.13 6/24 6/24 SV7LTTLS 74 0000 UNITED 0167512510367 MANKATO MM 0000000000 269,00 6124 6/24 2W?LTTLS 61 E3000US 1019 UNITED 0167512510368 MANKATO MN 93410193176 269.00 6/24 6/24 CXQORS30 6L E3000US 1019 Orbitz • Service Fees WWWORBITZCOM IL 93410193176 10.00 6/24 6/24 9MPS1.OO 61 A4722US 1065 AIG LIFE - TERM INS 301300075620 DE 88541863176 37.42 7/14 61 M5969USA 2019 PURCHASESOFINANCE CHARGE•PERIODIC RATE 75414913175 118.19 84 0000 OOOOOODOOD CASH WHEN YOU NEED IT - It's easier than ever to get cash up to your available CasA Advance Limit. Vear off the attached check, deposit it into your bank account, or use it like any personal check. Convenience Checks access the cash advance portion of your credit line. Refer to your Citibank Card Agreement for specific finance charges. • CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 174.71 Earned this Month 11.71 Redeemed/Expired 0.00 Current Balance 186.42 Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be'deducted from your rebate account. 23.42 rebates will expire on DECEMBER 31, 2003 Please see the enclosed privacy notice for important information. EXHIBIT I LOUISE M LAMOREAUX beY DOW PWt Date ntalirews Number Aetblq slaw Last Sta wont Am=M Account Summary PURCHASES ADVANCES TOTAL Rata Swmnary PURCHASES Standard Purch ADVANCES Standard Adv $9,237.62 =0.00 $9,237.62 =9,575.90 MOD 551.55 $2 00.00 $59/.55 5200.00 Periodic Rate 0.03740X(0) 0.05477%(D) $1 8.19 $9,747.36 1 $18.9 $9,747.36 Da s ThiS 9pM PDttod: 33 Nominal ANNUAL APR p g0J ff r RATE 13.650% 13.650% 19.990% 19.990% 09/08/03 $9691.50 ;201.00 SITE:KC-CL TM:CD-5000 ACID;KC85076 # N a w.1_ v 12/09/05 18:52:55: CITI CARDS LOUISE M LAMOREAUX P.O. BOX 8108 850 YVERDON DRIVE S HACKENSACK, NJ CAMP HILL PA 07606-8108 17011-1850000 Citi Driver's Ed e' rorcusbamar=??o?? g Platinum Select Card-Charter Rbts 1-800-967-8500 A=ount Number 5424 1800 3531 8168 To am mom avem a,Ma BOX 650D 4100 - 0011041M PATMES7 MafT RE RECEIVED BY 1:00 PM LOCAL TIME ON 09/06/100 SIOUX FALLS, SD 57117 snab"Wr tXbow; Date TOUT CredR LW Available Croft Line Cash Advance Lkn t Avaaabla Caah Limn Now Balance 08/13/2003 $25D00 $ 1 5 308 $5600 $5600 $9691.50 m ou M Credt Lit r $0 00 Part Ow MWMI-W . Ad CZ. MlnNwm Amouaa ow . $0.00 + $201.00 - $201.001 6/06 43731122 8/13 7/21 7/21 3D33HT00 8/13 PATMENTsfHANK YOU R Adiustnaents 70 0000 0000 -220.00 Standard Pureh C 74 0000 REDITSHIELD PREMIUM 6.26 AI 0000000000 AIG LIFE FE - TERM INS 301300075620 DE 37.42 61 N5969USA 2019 75414913202 PURCHASES•FINANCE CNARGE•PERIODIC RATE 120.46 84 0000 0000000000 CASH WHEN YOU NEED IT - It's easier than ever to get cash up to your available Cash Advance Limit. tear off the attached check deposit it into your bank account, or use it Tike any personal check. Convenience Checks access the cash advance portion of your credit line. Refer to your Citibank Card Agreement for specific finance charges. • CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 1a6.42 Earned this Month 0.75 Redeemed/Expired 0.00 Current Balance 187.17 Account SLnmary revious + ur s - ants (+) FINAKU = r-T PURCHASES ADVANCES Beane & $9,747.36 $0 00 Advances & Cyr dit s t<43.68 $210.00 0 00 0 0 CHARGE z $1 00 e w . 9,6 TOTAL 59.7 . . . 0 .68 $ 543 5220.00 $0. $120 46 0.00 . $9,691.50 Rites Summary SuWact o c Periodic Da This BRII Period: 30 h- 0 Finan e C Rate APMai ANNUAL PURCHASES P ERCENTASE TE Standard Purch ADVANCES $9,776.96 0.04107%(D) 14.990% 14.990% Standard Adv $0.00 0.05477%(D) 19 990% . 19.990% EXHIBIT 10/OT/03 $9995.48 $208.00 SITE:KC-CL TM:CO-5000 ACID:KC85076 ".$ 12/09/05 18:52:55: CITI CARDS LOUISE M LAMOREAUX P.O. BOX 8108 850 YVERDON DRIVE S NACKENSACK. NJ CAMP HILL 07606-8108 PA 17011-1850000 Citi Driver's Edge' 1 -60D Fer?,?te.e.r=. ,?aerWF" Platinum Select Card-Charter Rbts -967-8500 Account Number Tar-taaryn..eR.,b BOX 6500 5424 1800 3531 8168 to#6brtaagaaagalli SIOUX FALLS, 5D PAYrENT MoS1 It RECEIVED NY 1:00 ?n LOCAL TIME on 10/07/2003 nrtre.ws.T«el.yb 57117 Sfatem KICW" Date Total Cra lk Line Avail" Ceadt tine CashA&are Lbntf Available Cash LNaa New Balance 09/12/2003 $25000 $15004 $5600 $5600 $9995.48 Amount Over A? Credit Llno Past DUO M11 DW Lnnlnum Aneoud Duo $0.00 + $0.00 + $208.00 = $208.00 e ? 6/19 8/28 8/28 8/28 9/02 9/06 9/12 8/19 8/28 8/28 8/28 9/02 9/12 42903199 OZ0e9000 3CDZ266S ML4BK4DC ML4BK4DC OID2163G Pa wants. Credits ii Adfrstfnents 70 PAYMENT 0000 THANK YOU 0000 AIG LIFE - TERM INS 301300075620 DE 61 N5969USA 2019 ONLIKENOTEL RESERVATIO 8002569089 TX 61 A4722US 1141 US AIRWA03774556812165 ARLINGTON YA 61 E3063US 1141 US AIRWA03774556812176 ARLINGTON VA 61 E3063US 1141 URBAN NUTRITION INC. TEL2018762570 NJ 61 A5499U5 PURCHASES'FINANCE CHARGE•PERIODIC RATE CASH WHEN YOU NEED IT - It's easier than ever to get cash up to your available Cash Advanca limit. tear off the attached check deposit it into your bank account, or use t l(ke any personal check. Convenience Checks access the cash advance portion of your credit line. Refer to your Citibank Card Agreement for specific finance charges. • CITI DRIVER'S EDGE CHARTER MEMBER REBATES 'TOTAL Last Month's Balance 187.17 Earned this Month 7.91 Redeemed/Expired Current Balance 195.08 Remember. every time you use your Driver's Edge Card for ppurchases, you earn Driver's Edge Rebates that can be used towards the purchase or lease of a new or used vehicle. See your Driver's Edge Directory of Services for complete details. -220.00 00000000006.35 754149132317 42 785059432419.89 934507932419 00 119.00 93450793241 39 98450963246 .99 122.33 0000000000 EXHIBIT 3 LOUISE M LAMOREAUX 3010 Dab Post Data astsnaa nlaaraf Actift Slats Lad Uataawat Aawuat Account Summary PURCHASES ADVANCES $9,6 1.50 0.00 $4 1.65 $2 0.00 10 00 il $122.33 Ce =9.9 TOTAL $9,6 1.50 . 0.00 $401.65 $220.00 0.00 $112.33 $s0. $9,945.48 0a Thk aMMa Period: 30 Rate Summary Balance Subject Periodic om , Finance Charge Rate APR ANNUAL PURCHASES Standard Purch ADVANCES $9,928.83 0.04107%(D) 14.990% 14.990% Standard Adv $0.00 0.05477%(D) 19.990% 19.990% 11/06/03 $10889.91 $226.00 SITE:KC-CL TM:CO-5000 ACID:KC85076 12/09/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE OT606-8108 CAMP HILL PA 17DIl-1850000 Citi' Driver's Ed e' ForCustoanrBar&*,calorvIF" g Platinum Select Card- Charter Rbts 1-800-967-6500 Ac:couatHumber 5424 1800 3531 6168 110"c"600"Mmkoft, ftme r.wtel" " t BOX 6500 SIOUX FALLS SD PAYMENT MIST It VICEIYED BY 1900 PM LOCAL 719E 01 11/06/2003 ru R-"-y-dor? , 57117 stale" WIC"Ag ode Total C99d* LIM 10/14/2003 $25000 AvaNaBY Cmdk Uro Cash AdvocA Undl AraNable Caab Unit Maw eaNnce 4 0 $1 1 1 $5600 $5500 A eu ?t p ? r C9Mt Uw Pad Due $10889.91 WAd M1=. CZ. Nh*num AwmrA gut $0.00 + $0.00 + $226.00 = $226.00 10/06 41976525 10/14 9/18 9118 TRX2Y400 10/01 10101 R5ZQXIRL 10/14 PAYMENTsTHANKaYOU >i Adjustments 70 0000 0000 -250.00 Standard Purch REDIT5 HIELD PREMIUM 6 68 ? 74 AIG LIFE - TERM INS 301300075620 DE . 0000400000 37 42 61 M5969USA 2019 . 75414913261 NCL-RESERVATIONS MIAMI FL 963 08 61 A4411US 1065 PURCHASES*FINANCE CHARGEOPERIODIC RATE . 97499673274 137 25 84 0000 . 0000000000 " CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 195.08 Earned t is Month 20.01 RedeemedLExpired 0.00 Current BBBBalance 215.09 Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 23.42 rebates will expire on DECEMBER 31. 2003 Our records show hone phone 717-761-8236 and business phone 717-238-6715. Please update above coupon if incorrect. The Bose Nave radio/CD delivers lifelike sound. Yet it' s small and si"lle to use. Your satisfaction is qq . To u8 00-249- 673 Ext his r r 1 8 2 brought to 79. T . TO after is you by Media Syndication Global. an k to rent a car from He o nd enjo d a r Y g rti vin4 reat a the world! Call 1-800-654-2200 and mention s s your Citibank Hertz COP number 160005. L? EXHIBIT R LOUISE M LAMOREAUX Sob Daft Pat We Weraw wmNr wdm sine ud usblant Abrm* Account Summary Previous M Purchases "an s + FINANCE :) ew Balance 6 Advanegs s Credits CHARGE Balance PURCHASES ADVANCES $9,995.48 $1,097.18 10.00 $0 00 $2 0.00 0 00 11 $117.25 $10.889.91 TOTAL . $9,995.48 $1,007.18 . 0.00 $2 60.00 $137.25 0.00 $10.89.91 0a This BRR Padit 32 Rate Suamary a ante Sub)ecf to Finance Charge Periodic Rat Nominal ANNUAL Dnoruacrc e APR P ERCENTAGE RATE Sd Porch $10,443.16 0.04107%(D) 14.990% 14.990% rd Adv $0.00 0.05477%(0) 19.990% 19.990% M 12/08/03 $11720.93 $244.00 SITE:KC-CL TM:CO-5000 ACID:KC65076 12/09/05 18:52:55: ism CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citi' Driver's Edge" rsm•rS.rYk.,a0orwtxo Platinum Select Card-Charter Rbts ? Account 5424 1800 3531 8168 Tar+uthma.a-ML MR. t BOX 6500 SIOUX FALLS SD PAYMENT MOST RE RECEIVED IT 1:00 Pa LOCAL TIME OR 12/OS/ZO03 as poonve" r4ftL , 57117 St;absmant/Cb" Cabo TOW C"dR Lim 11/12/2003 $25000 AVallaW Crack Use CashA 4 , Limit AaaNabla Cash umR Mar ealsapa $1 32 7 9 $5600 $56 0 0 $11720.93 ?'?f 13 Q ?""" " ` d ? MMlmun ADua Mlrkmm Amw t Duo $0.00 + $0 00 + $244.00 = $244 00 Sak b f. P-6 B.&. - ----- ..??. ..??..--- • --- -• - - . 10/31 4174IZ31 Psrrments Credits A AdfustRUnts PATMENT fzK YOU 10/22 10/22 •S3VOV3o CARNIVALOCRUISE/MANUAL0MIAMI FL 71 4411U5 1065 11/12 CREQITSHIEL.ELD rcPREMIUM 10/20 10/20 OYTC•V30 74 CARNIVALLOCRUISE TKT/RE MIAMI FL 10/20 10/20 Y2KL3R30 61 EXPEDIA SERVICE FEE 10 SOO-EXPEDIA wA 10/20 10/20 L7V4OXYG 61 A4722US 1065 DELTA 00675274278243 ATLANTA GA 10/20 10120 6eV40XYG 61 E305SUS 1734 DELTA 00675274278254 ATLANTA GA 10121 10/21 GP632200 OUS AIG LIFE - TERM INS 173301300075620 DE 30/27 10/27 RD219R30 61 N5969USA 2019 EXPEDIA CORPORATE TRAV 888-249-3978 wA 11/12 PURCHO FINANCE CMARGEOPERIODIC RATE • CITI ORIVER'S EDGE CHARTER MEMBER REBATES •TOTAL Last Month's Balance 215.09 Earned t11??is Month 18.41 Redeemed[ Expired 0.00 Current ggalance 233.50 Your Citi MasterCard could turn your holiday shop- fin9 into something stupendowsl ften was the last time you enjoyed a vacation filled with lauahter and fun with friends or family? 11/1 through 12/3172003. For details visit https://www.Mastercard.com Get $5 Statement Credit. Sign up for All Electronic. You'll have instant access to your statement online, without that pile of paper. Get an a-mail notice when your statement is ready. Register or sign-on to citicards.con and choose Manage My Account. -235.00 975418632970.00 00000000007.37 501.96 9TS41863294 29.99 88541863295 934173432948?? 934173432948.00 37 4Z 75414913294 15.00 88541863302 0000000000 .28 EXHIBIT_ 5 a LOUISE M LAHOREAUX Sata Dab Past Dab 11191mm" iMo?lor AetMtr NM L" Steb Mat Aa t Account Summary rrwious B (t) Purchases aym s + FINANCE (:) Now alance i Advances i Credits CHARGE Bal PURCHASES ADVANCES $10,g¢9.91 00 10 $9¢7.74 =275.00 00 60 $1 8.28 ance =11, 0.93 TOTAL . ;10,889.91 . 0.00 ;967.74 $215.00 518.28 70 $11,720.93 B l D This BIN Parkxt 29 Rata Sumtaary a ance ec t o Periodic Nominal PURCHASES Finance Charge Rate PR ANNUAL CEN GE RATE Standard Purch ADVANCES $11,610.28 0.04107%(D) 14.990% 14.990% Standard Adv $0.00 0.05477%(D) 19.990% 19.990% 01/06/04 $12853.85 $510.59 SITE:KC-CL TM:CO-5000 ACID:KC85076 swap= 12/09/05 18:52:55: CITI CARDS lOUISE M LAMOREAdX P.O. BOX 8108 5 850 YVERDON DRIVE SACK, Ni CAMP HILL 07660606--818108 PA 17011-1850000 Citi Driver's Edge' PorCus4sbwrSarrke aMar-. Platinum Select Card-Charter Rbts 1-600-967-8500 Account Number To?eertM"ana,a-aa BOX 6500 5424 1800 3531 8169 to'Z -=- SIOUX FALLS, SD PATMENT MOST NE RECEIVED BY 1:00 PE LOCAL TIME ON 01/06/ZO04 ?'? ' ` 57117 Sdtan@i/cW np Dab Total Credt Line AVaNMM Croft Line Cash ACranc• LbWt Aralf"k Cab Umlt new 84110p 12/12/2003 $25000 $?1g221p4Va6 $5600 $5600 $12853.85 CC $0.00r + Part Due YM1?mWn?Dw YlMmuia Amotnt Duo =243.59 + $267.00 = $510.59 Sob Date Poet Dab Adwomca NuWAff AdM q Shoe Last Stabmaat ._?. 12/01 88988888 12/12 12/12 12/12 11/13 11/13 VD3X8T00 11/13 11/13 5CH74YVD 11/13 11/13 DGM74YVO 11/18 11/18 C•LY9P00 12/04 12104 VK9MMND3 12/05 12/05 KXCFN7MM 12/09 12/09 XHJK"P30 12/09 12109 HDJK•P30 12/12 CR SN nARTZ SETTLEMENT AR NND 800 558-5854 72 0000 9999 i P FEE DEC 03-MOV 04 ELD PREMIUM - NOY PAYMENT PAST DUE AIR ffM INS OKS 201 TION :SSA TX K YORK TX Y YORK TX ,300075620 DE x-8309532 CA NORTH TX -845-8856 FL -B45-8856 FL ERIODIC RATE • CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 233.50 Earned this Month 18.70 Redeemed/Expired Current Balance 252.20 ofithetsettiemedtclndtheaSchwartz lawsuit Portion The Annual Percentage Rate on your account is subject to increase and Your ability to redeem or earn Citi Driver's Edge Card rebates may be suspended when you fail to make a payment to us or any other creditor when due, exceed your credit limit, or make a payment to us that is not honored by your bank. -.41 00000000000.00 00000000007.97 00000000005.00 785003733182.00 854386433193.44 654386433193.44 754149133228.79 784507833388 784101933432'34 88541863344 '50 885 41863344 '00 154.80 0000000000 EXHIBIT 6 LOUISE M LAMOREAUX Bob Dots Post Date Retemrn NwAar Ac"My State List Stalawwr t MaMt Your current nominal annual percentage rate for purchases may vary W thly and is based on the (fall Street Journal Priam Rate plus 10.990%. However if you default on any card Agreement, our ra{e may increase. The new rate will be the rime Rate pus up to 23.990%, based on the nature of defaults and performance indications. These rates apply to your account at the time this statement was priinted. Please see the enclosed Notice of Change in Terms to Your Card Agreement for important information regarding changes to your card Agreement. Get rewarded for paying your taxes! Charge yyour taxes on your Driver's Edge Card. Call 1-B00-2PAY-TAX for more information. Account Summary Balanea (+ c aces MA & Advances Credits FINANCE "CHARGE Do= PURCHASES $11,720 .93 MOM 0 41 54.80 $1 $12,8 3.85 TOTALCES 0 00 $11 720 93 $918. 00 10 : 4/ s 00 4. 83 85 . . 0. $15 8 0 $12, . Da This Biting Period 30 Rate Summary Balance iac to Periodic Nominal AIINUAL Finance Charg e Rate APR PERCEMTAGE RATE Purch $12,564.02 0.04107%(0) 14.990% 14.990% Adv $0.00 0.05477%(D) 19.990% 19.990% 0205104 $12632.10 $263.00 SITE:KC-CL TM:C0-5000 ACID:KC65076 010, 12/09/05 18:52:55: ERNME INANOW INN M-1 CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YYERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citi' Driver's Ed e' or *oft g Platinum Select Card-Charter Rbts AccountNombar 5424 1800 3531 8168 rra.irr?oiW a? BOX 6500 SIOUX FALLS 5D PATtaENT MIST DE RECEIVED eT 1:00 PU LOCAL TIDE ON 02105/1604 ?w....eTRrtow. , 57117 Stats.aent/CkainO Csta Total CredR Lb* AvaeaNe Cron Line Cash AWanCs Licit AvaRahls Cash LIm1t Him 831sew 01/13/2004 $25000 $123 6 7 $5600 $5600 $12632.10 p ?r? Anount Crad6l0» r Put Due Y1i1 L Mtnhnum AwmW on $0.00 + $0.00 + $263.00 = 3263.00 12/15 97679245 Pa mots Credits A Adjustments PAYMENT fHANK YOU 70 0000 0000 c 1/13 PREMIUM CREDITSHIELD 12/15 12/15 ESZ00000 SPEEDPAYOSERVICE FEE 12/17 12/17 96RNGVFP CUSTOM WOOLEN MILLS O?CARSTAIRS CAN 35.75 CANADIAN DOLLAR = 12/18 12/IB 07336SOD 61 B5699CA 9385 AIG LIFE - TERM INS 301300075620 DE 1/09 1/09 VNOWK500 61 X5969USA 2019 BLAIR * 800-458-6057 PA 1/13 PURCHASES`FINANCE CMARRGGEE`PERIODIC RATE 84 0000 * CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 252,20 Earned this mouth 2.03 Redeemed/Expired 23.42 Current Balance 230.81 Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 23.42 rebates expired on DECEMBER 31 2003 35.76 rebates will expire on DECEMRU 31. 2004 Your Citibank credit card provides the convenience of transacting in foreign currencies worldwide wherever MasterCard is accepted without having to exchange and carry more foreign currency than you need for your transaction. Your transaction is converted into U.S. dollars based on a wholesale market rate or a government-mandated rate. MasterCard increases that rate by 1%, and Citibank increases the rate provided to i by MasterCard by 2%. -511.00 7.99 0000000000 000000000004.95 27.67 75186893352 58.79 7541491335Z 14.98 78432864009 00000000004.87 .r EXHIBIT LOUISE M LAMOREAUX sw ode put Doh netereece number Acthal Siece Last Statement Ameuet Account Summary Previous +) ure aces (- Payments + FINANCE N Now balance & Advances & Credits CHARGE Balance PURCHASES CES $12.8130: 85 $1$24.38 $511.00 4.87 $1 $12,? 2.10 TOTAL $12,.85 $124.38 $511.00 0 $164.87 $12,632.10 Days This exx Perhrt 32 RNte Summary Balance SuWect t Finance Charge o Periodic Rate Nominal APR ANNUAL ' PURCHASES pE R CENTA RATE Standard Purch ADVANCES $12.544.74 0.04107%(D) 14.990% 14.990% Standard Adv $0.00 0.05477%(D) 19.990% 19.990% t 03/05/04 $12991.04 $270.00 SITE:KC-CL TM:CO-5000 ACID:KC85076 IN 12/09/05 18:52:55: CITI CARDS LOUISE M LAMOREAUX P.O. BOX 8108 850 YVEROON DRIVE S SACK. NJ CAMP HILL PA 0766D606--818108 17011-1850000 Citr Driver's Edge' F?t ??.«• 1-800-967-8500 Platinum Select Card-Charter Rbts 5424 AM' Number 3531 8268 [ 601'" "Oft Fm 1 "P"" "1M Box 65.00 SIOUX FALLS SD PATN n1 RNST SE NECUVEO By 1:00 PM LOCAL TIME ON 01/05/2004 , 57117 sh** ant/Ciasinq Date Taal Crudlt Line AveliAleCradn Line CwhAdvwe Limit AwOabb Cash UMN New oweaa 02/11/2004 $25000 $1122008 $5600 $5600 $12991.04 A cradt, , Pat Due N VUL Mtlmum Amawl Ow $0.00 + $0.00 + $270.00 = $270.00 Sub Date, Pant OVA ftgfw== Num ber Aetk*W Sloe. L.d st.e.....r 2111 61705587 PAYMEENNTsIHANKdYOU J~ A/justttents 70 0000 0000 2/11 CREDITSHIE PREMIUM 2/11 74 0000 LATE FEE - JAN PAYMENT PAST DUE 1/15 1/15 Lk5T6P30 IMAGINATION SAIL 6 SIG MIAMI FL 1/18 1/18 1Y4C8D39 61 D4411US 1065 WAL MART MECHANICSBURG PA 1/22 1122 GQZZRXOO AIG LIFE - TERM INS 106301300075620 DE 2111 61 N5969USA 2019 PURCHASES+FINANCE CHARGE+PERIODIC RATE 84 0000 When you pay your bill by check. you authorize us to electronically process your payment. If your check is processed electronically, your checking account may be debited on the sane day we receive the check and it will not be returned with your checking account statewent. Yf someone other than you ora bill paying service pays your bill, you :lust give a copy of this notice to them before the payment is sent to as. e CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 230.81 Earned thhis Month 8.69 Redeemed Expired 0.00 Current 999alance 239.50 IMPORTANT PROGRAM INFORMATION: MasterCard renewed their insurance coverage with Virginia Surety Company, extendingq Purchase Assurance, Extended Warranty and MasterRental through January 31, 2005. -275.00 00000000008.33 35.00 0000000000 705418640 64.80 141.13 70483824018 58.79 75414914022 000000001005.89 EXHIBIT U LOUISE M LAMOREAUX Sate Do. Pmt tiek newam a!wib.r Activity Stew Lost Staftmat Amount Account SimTary B l y ens s (-s PU ADVAKES RCHASE TOTAL a ance 6 $12,6:232.10 .1 Advancer Credits $4 8 0.05 $270.00 15 CHARGE $1 0.00 Balance $12,991.04 $12.63 0 $ 8 . $Z75.00 5 S1 .89 $12,991.04 Rate Su.nmary ° Ge ec o Periodic Days TAIL 8NI Period; 29 o Finance Char a Rate m n APR ANNUAL PURCHASES C _RTE Standard Purch ADVANCES $13,088.50 0.04107%(0) 1{,990% 14.990% Standard Adv $0.00 0.05477%(D) 19.990% 19.990% 04/05/04 $12949.10 $269.00 SITE:KC-CL TM:CO-5000 ACID:KCB5076 9 ( MIN " ? 12/09/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 7YERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citi' Driver's Edges Cltie Pla lnum Select Card-Charter Rbts 5424 1600 3531 8168 Cttatotaer serYlca: 1-800-!67-8500 Total t 25000 Line Available CmM Line Cath Advance, umlt Available Cash Limit $12050 $5600 $5600 New Balance Box 6500 $12949.10 SIOUX FALLS, SO ST117 03/1 c=, h A r`A0°nMt p t z: Past Vale 1/2004 0 00 + M + Parch/Adv 'mom Dee mwmvm Amount Daa . OO 269.00 = $269.00 sob Deft Post Date l1werem Num ber Activity Sine Lot statement Amami 3/10 61850269 Parnests Credits 6 Adjest?attts AYM ANK YOU PO ?D00 0000 -340.00 Standard Purch 3111 CREDITSHIELD PREMIUM 8.34 3/11 74TE F?- FEB PAYMENT PAST DUE 0000000000 35 00 2/18 2/18 9wNBNMoO 66 0000 AIG LIFE - TERM INS 301300075620 DE . 0000000000 58 79 3/11 61 M5969USA 2019 PURCHASES*FINANCE CHARGE*PERIODIC RATE . 7541441 55 93 84 0000 . 0000000000 * CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 239.50 Earned this Month 1.19 Redeemed/Expired 0.00 Current Balance 240.69 Accent Staatnwy Previous + urc ases (-) synlen s (4) FINANCE : ew Balance & Advances & Credits CHARGE Balance PURCHASES ADVANCES TOTAL $12,991.04 60.00 $102.13 $300.00 $0.00 60.00 ; 10.00 $12.949.10 $12,941.04 $102.13 #300.00 3155.93 $12,949.20 0e, s This Nang Period; 29 Rata Summary Balance Subject to Finance Charge erro Ic Rate om?na ANNtiU1l FuRCNASES APR PER CEyiTAG TE Standard Purch ADVANCES $13,092.16 0.04107%(0) 14.940% 14.990% Standard Adv $0.00 0.05477%(D) 19.990% 19.990% EXHIBIT 05/06/04 $13568.46 $600.90 SITE:KC-CL TM:C0-5000 ACID:KC85076 12/09/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 r Citi Driver's Edge' CI 1 Pla inum Select Card-Charter Rbts 5424 1800 3531 6168 Customer servh:e• i-800-96T-6500• TOW Credt LMe $25000 AvWl" Cmdt LMa Cash Adveoce Urtk $11431 $5600 Available Case LWW $5600 New valance $13568.46 00 BOX 65 SIOUX FALLS, SD cfselData 2 A'nd"Min: Pest Due r? .1. D ? 90 = e sw t 90 600 ST117 04 04/12/ 0.00 + 5269.00 + 1331. . Sala Deft Pod Date OWWWRoe Raba Adh'tt/ WW8 tat sNtenwt Atemot Standard Pureh 4/12 CREDITSHIELD PREMIUM T4 0000 4/12 LATE FEE - MAR PAYMENT PAST DUE 66 0000 3/15 3/15 2NGNTOF* WM SUPERCEHTER SE2 MECHANICSBURG PA 61 A5411US 1065 3/17 3/17 CG4T3C2G LensCrafters 10004950 CAMP HILL PA 61 A8043US 1019 3/16 3/18 VMFPGJOO AIG LIFE - TERM INS 301300075620 DE 61 N5969USA 2019 4/12 PURCHASES*FINANCE CHARGE•PERIODIC RATE 84 0000 * CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 240.69 Earned this Month 4.98 Redeemed/Expired 0.00 Current Balance 245.67 Citi Driver's Edge Charter member rebates expire 3 y4ors after they are earned. Expired rebates will be deducted from your rebate account. 35.76 rebates will expire on DECEMBER 31. 2004 The Annual Percentage Rate on your account has been increased due to one of the following reasons stated in your Card Agreement with us: you failed to wake a payment to as or any other creditor when due. you exceeded your credit line or you made a payment to us that was not honored by your bank. Additionally. Your ability to redeem or earn Citi Driver's Edge Card rebates may have been suspended. Please call our toil-free number above to learn about special yment options. Call Monday through Frtda1:7:8a 0 a.m. to 9:00 p.m. or Saturday 8:00 a.m. to 00 p.m. CST. Our records show home phone 717-761-8236 and business phone 717-238-6715. Please update coupon if incorrect. 8.42 0000000000 35.00 0000000000 126.25 71483824076 64.00 70410194077 58.79 75414914076 326.90 0000000000 EXHIBIT /0 } LOUISE M LAMOREAUX Sob Date Pact ab mtm.n 1MmMr Adirft $Mce Led $t•t~ Affmat Accowt Strnmmry PURCHASES ADVANCES $12,949.10 $2 2.46 00 $0 00 ;326.90 $13 5 8 46 TOTAL . 0.00 00 $12,949.10 :2 2.46 100.00 , . 10. =36.90 A $13,56 8 Rate Summary • nee e to Periodic Da This BaM Perfo& 32 omins eae,u ? rrr Finance Charge Rate ANNUAL APR arnr-vi rae a n.n Parch $13,322.61 0.07668%(D) 27.990% 27.990% Adv $0.00 0.07668%(D) 27.990% 27.990% 06/04/04 $13079.51 $314.72 SITE:KC-CL TM:CO-5000 ACID:KC85076 ---------- L. 12/09105 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVEROON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citi Driver's Edge' Pla inum Select Card-Charter Rbts 5424 1800 3531 6168 0=M?W iota! Credlt UM AvaigbM CredN t.lae $11920 Cast, Adraaae Llfnlt $5600 Available Cash t,1mn $5600 $25000 BOX 6500 FALLS, ? tstatement! b% i Amfeaat Over 0 0 00 call + 314 72 a7 i ?l 05/1M + 0 _ i 4/19 ` 44407414 5/10 162898369 4/20 5/12 5/12 4/20 VRG71NOO 5/12 CIT, 0 Now "Macy $13079.51 Mdnwn+ Watt Due 1314 .72 PP>?YMEIiTTHANK Y011 I Adjustments 70 000 0000 TONOOOONANK YOU 0000 Standard Purch CREDIOSOHOIOELO PREMIUM LATE FEE - APR PAYMENT PAST DUE 66 AIG 5? TERM INS 201901300075620 DE 61 969USA PURCNASES•FINANCE CHARGE-PERIODIC RATE 84 0000 0 CITI DRIVER'S EDGE CHARTER MEMBER REBATES 2 5767 Last Month's Balance 1.18 Earned this Month 0 18 Redeemed/Expired 246.85 Current alance Please note that payments must be received by 1:00 p.m., local time, on a bank business day at the payment processing facility :bat handles your payments, in order to be credited to your account as of that day, and payments must conform to the payment instructions set forth on the reverse ssido. All conforming ppaayments received at the beyacreditedcassofgthe followingebankabusinessill day. Notice of Change in Driver's Edge Rebate Program Terms. You will have 90 days from your vehicle Yur lhase Redemption a date nto complete and return the ehicle Notice of Change in Driver's Edge Rebate Program Terms. we pay change Program rules, restrictions or benefits. in whole or in part, with 30 days prior written notice. We way also terminate the Program or portions thereof with 30 days prior written notice. Want to receive your billing statement in Spanish? Prefiere recibir su estado de cuenta en espanol? Llamenos al 1.800-947-9100 Para elegir recibir su estado de cuenta y las cartas de Servicio al Cliente ea el idioms espanol. -300.00 -601.00 8.54 0000000000 00000000005.00 58.79 75414914111 309.72 0000000000 EXHIBIT LOWSE M LAMOREAUX etaaissnt AAw?Ad Bob Deto post not* uslwomm w4mber Amoy Slaps LW Axcow* Sianmary Previous + ure ases .Payments di (MINANICE CHARGE m New @alanee & Advances & Cre ts Balance PURCHASES CES 613,5 p.46 $1$02.33 5?1.00 $3 .72 00 $13,079.51 TOTAL $13 568.46 $102.33 $900 00 $309.72 019.51 $13 , , Da This 8M Perlod• 30 ' Rah Summary • nce Su-blect to en a ammo ANNUAL Finance Charge Rate APR P ERCENTAGE ATE 5d Purch $13,463.59 0.07666%(D) 27.990% 27.990% rd Adv $0.00 0.07668%(D) 27.990% 27.990% 07/05/04 $13631.07 $302.01 SITE:KC-CL TM:CO-5000 ACID:KC65076 12/09/05 18:52:55: - MENE CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE OT606-8108 CAMP HILL PA 17011-1850000 Citl* Driver's Edge' Platinum Select Card-Charter Rbts CI vl+ Aosataa WNW 5424 1800 3531 8168 Custorow Satr 1= 1-800-967-8500 total credit Line AYSsabte eredk Lin. Cash Aevaaw UmH $25000 $11368. $5600 Box 6500 stdoa ti Amaont over SIOUX FALLS, SO ct n Date 0 nOtLine M 57117 06/1 004 10.00 + OO $0.00 + Awnabte Cast, Limn H" aia.a $5600 $13631.07 .O1 a $302.01 nts Cradits E Adjustaents Pagqtr 6/01 42084663 ? PAAYME NTT ANK YOU -320.00 O 0000 70 Standard Parch 6/10 5/19 5/19 80211YJ00 01300075620 DE G LIFE - TERM INS .79 9 2019 61 75414414140 5/28 5/28 M331WPJN ALAND RENT-A-CAR WARWICK RI 171.67 61 A338TUS 1065 78453264150 6/01 6/D1 ZLS'TYN3 ROYAL PLAZA HOTEL MIDDLETOWN RI 335.64 61 A7011US 1065 78547534154 6/10 PURCHASES•FINANCE CHARGE;PERIODIC RATE 297.01 84 0000 0000000000 e CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 246.65 Earned this Month 11.32 Redeeteed Expired 0.00 Current alance 258.17 Kant to receive your billing statesrents in Spanish? Prefiere recibir ss estado de cuenta en espanol? Llamenes al 1-800-947-9100 pare elegir recibir su estado de cuenta ]as cartas de Servicio al Client0 an el idiy om espanol. Account Summary Previous 541mce (+ Purchases A Advances - Payments & Cr*dls + CHARGE Now Balance PURCHASES ADVANCES $13.0 9.51 0 00 $574.55 $0 00 $3 0.00 50 00 =297.01 00 $13.6 1.07 TOTAL . $13.0 9.51 . $574.55 . $320.00 . $2107.01 0.00 $13,631.OT Days Thb 8a Permd: 29 Rate Stanntary Be kame Subject Finance Charg to e Periodic Rate Nominal ANNUAL APR pERCENTAGE RATE Purch $13,356.62 0.07668%(D) 27.990% 27.990% Adv $0.00 0.07668%(D) 27.990% 27.990% EXHIBIT o? 08/06/04 $13761.52 $357.92 SITE:KC-CL TM:CO-5000 ACID:KCB5076 NINOW 12/09/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citr Driver's Edge" /1a ati Pla i,,,,num Select Card-Charter Rbts ACCOURt 5424 1800 3531 8168 Customer Service: 1-800-967-8500 Tetal CredltLine Arailahle Credit Line Cash Advance Unit AvaRa ble cash Limit New Balance $25000 $11238 $5600 $5600 $13761.52 agx 6500 Sbtemeat/ Amount W. . post Dee SIOUX FALLS, SD Cbair? Date W PaF04Ade uMnww Due MMlmual t Due 57117 07/13 /2004 10.00 + $0.00 + OO 337.92 = 357.92 Sall ode Post Date Refs voce Num lar AeUeay Since Let Statement at PBrrsiettts Credits i Adjustments E T O 00 -325 7/12 61525347 U AYM N N NK Y ? . O 0000 Standard Purch 7/13 ELD PREMIUM C REDIT?I 8.74 O 74 ?00??0 T/13 LATE FEE - JUN PAYMENT PAST DUE 3 5.00 0000 000 0000000 6/21 6/21 BYHXJL00 AIG LIFE - TERM INS 301300075620 DE 58.79 61 R5969USA 2019 75414914173 7/13 RCNA5 8 •FINANCE CHARGE'PERIOOIC RATE 0 .92 0 4 0 0000000 0 * CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 258.17 Earned this Month 1.18 Redeemed/Expired 0.00 Current 9Balance 259.35 Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates wilt be deducted from your rebate account. 35.76 rebates will expire on DECEMBER 31, 2004 Please see the enclosed privacy notice for important information. Fast Online Card Payments with Click-to-Pay Pay your Citi card bill online anytime, day or night Payments received by 1 p.m; EST will post that same business day: Sign-on to citicards.com and choose the Make a Payment menu. Aced Summary Previous Bal +1 Purchases A Adv (- Payments dit & C [+) FINANCE (=) Now CKARGE ance ances re s Balance PURCHASES ADVANCES $13,611 .07 0 00 $1p2.53 $0 00 $325.00 0 00 2 .92 $13,7 1.52 $3 0 TOTAL , 07 631 $13 . 53 $102 . $315 00 1 .00 $0.00 $3 2 92 , . . . . $13,761.52 Days This 81111in Period: 33 Rate Summary Balance Subject Fi Ch er ie t om na ANNUAL arg nance e Ra e APR PERCENTAGE RATE rVRLnRaCa Standard Purch $13,822.79 0.07737%(D) 28.240% 28.240% ADVANCES Standard Adv $0.00 0EXHIBIT l .07737%(D) 28.240% 28.240% 09/06/04 $14188.28 $687.05 SITE:KC-CL TM:CO-5000 ACID:KC85076 w it/09/03 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK, NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Cltl' Drivers Edge0 Platinum inum Select Card Charter Rbts NU~ 5424 1800 3531 8168 Custonwr Swvloe: 1-800-967-8500 Toth CrodltUna Avall" Credk Llna Cash Advanu Limit Awallabee Cash Link BOX 6500 $25000 $1081p1? $5600 $5600 SIOUX FALLS, SD C D N A 4n /M Line Past two A 57117 08/12/204 10.00 + $357.92 + 329.13 a ab New Meow $14188.28 amt Due 687.05 8/12 CREDITSHIELD ePREMIUM 74 GOOD 8112 LATE 0000 AL PAYMENT PAST DUE 7/20 7/20 GY03RHOO AIG LIFE - TERM INS 301300075620 DE 61 U5969USA 2019 8/12 PURCMAS?ES*FINAMCE CHARGE*PERIODIC RATE 64 • CITI DRIVER'S EDGE CHARTER MEMBER REBATES *TOTAL Last Month's Balance 259.35 Earned this Month 1.18 Redeemed/Expired 0.00 Current Balance 260.53 Want to receive your billingy statements in Spanish? Pretiere recibir su estado de cuenta en espalol7 Llamnos al 1-800-947-9100 pare elegir recibr su estado de cuenta y las cartes de Servicio al Cliente.en el idioms espanol. 8.84 0000000000 35.00 0000000000 58.79 75414914202 00000000004.13 Accoutt Summary revious t Balance 6 Purchases Payments Advances 8 Credits + CHARGE = Now Balance PURCHASES 313,7¢1.5Z $1 2.63 0.00 $3 4.13 $14,188.28 ADVANCES 10.00 0.00 0.00 1 0.00 1 $0.00 TOTAL $13,761.52 $ 2.63 0.00 $3 4.13 314,1b8.28 Dr Thhi 8 Parlat 30 Rate Summary Be ones Subject to Wi is Nominal ANNUAL Finance Charge Rate APR pERCENTAGE RATE PURCHASES Standard Purch $13,964.48 0.07737%(D) 26.240% 28.240% ADVANCES Standard Adv $0.00 0.07737%(D) 28.240% 28.240% EXHIBIT 10/OT/04 $13918.00 $354.13 SITE:KC-CL T12/09/OSO ACID:18g52?55: I CITI CARDS P.O. BOX 8108 LOUISE M LAMOR£AUX S HACKENSACK, NJ 850 VVERDON DRIVE 07606-8108 CAMP HILL PA 11011-1850000 ' Clt! s Edg Driver Citi , Rbts Platinum Select Card-Charter 5424 1800 3531 8158 T*t*I Credit Una Aralle0k Credit Una Cash Aewnca itmlt Arallaele Cest+ UisR 1C-M. -n r967-8500 Services $25000 $11082 $5600 $5600 New ealeece =13918.00 BOX 6500 statemati A,must Over SIOUX FALLS, SO t:lgat Dow 4r+slt Una Pset ae 00 + + $0 2 1?WAM¦N 13 1354 Mkdrwm n1O? 13 = 354 . 04 10.00 57117 09/13/ . . sob Doh Meet Data RNenwo RLmYer Activity dace L=t statomest Amaret Par?rslents Credits i Adjustetents HANK YOU W T -687,05 8/25 43426017 70Y 0000 00 00 Standard Purch 9/13 CREDITSHIELD PREMIUM 8.85 74 0000 0000000000 On 8/18 F9VSRG00 AIG LIFE - TERM INS 301300075620 DE S969USA 2019 1 58.79 75414914231 I 6 9113 PU AS 0 •FINANCE CHARGE*PERIODIC RATE 349.13 84 000 ?? ***Driver's Edge Charter Member Rebate Sumwary*** Previous Statement Rebates Total 260.53 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.15 Total Rebates Available 261.71 Lifetime Rebates Earned 395.42 Bonus Rebates may take one to two billing cycles to alpptar on your statement. Please refer to the spec c terms and conditions pertaining to the promotion for further details- IMPORTANT INFORMATION ABOUT CREDIT REPORTING: WE MAY REPORT INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS MISSED PAYMENTS OR OTHERCDEFAULTS REPORTON "UR ACCOUR MAY BE REFLECTE6 IN YOUR . FREE SERVICES FOR CITI CARDMEMBERS Manage your Citi Card account online securely, c bal see t t k h your e, ec an o c anytime-whether you wan if a payment was received or pay your bill. Register now at www.citicards.com Account Summary rwLous + Purchased; eym (+) FINAW-E Balance & Advances .& Credits CHARGE ¦ Now Balance PURCHASES ES $14,188.28 $67.64 $687.05 $349.13 00 $0 00 00 $0 00 $0 $0 $13,916.00 $0.00 ADVANC TOTAL . . . . $14,188.28 $67.64 $687.05 $349.13 $13,918.00 Rats Surnmary Purch $13,978.78 0.07805%(D) 28.490% 28.490% ` Adv $0.00 D.07805%(D) 28.490% 28.490% EXHIBIT 11/04/04 $13651.09 $328.99 SITE:KC-CL TM:CO-5000 ACID:KC95076 No-ow "rA , .? 12/09/05 18:52:55: CITI CARDS P.O. 80X 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 C it i' driver's Edge` Pla inum Select Card-Charter Rbts 5424 1800 3531 8168 Servica: ideffl rnr 8500 800 i^ --96967- Total credit Une Maltabk Credit line Cash Advance Umlt $288 $5600 $13940 6 BOX SIOUX FALLS, stateme" d e Amourd K + OsR o f 0 00 + 57117 10/13 4 / D sale ante F=d Deb aelereece Ilme ber Aadeef awe Lwt statement Psyytaents Credits E ANK YOU Adjustmmnts 9/15 43224659 POY 0 0000 19/08 42153139 AYME??HANK YOU 7 0000 Standard Purch 10/13 CREDITSHIELD PREMIUM O 9/20 9/20 9SP26MOO - TERM INS AIG LIIFFE 301300075620 DE 61 K5969USA 2019 9/29 9/29 FGP1T800 BARNES & NOBLE.COM 800-843-2665 NJ 61 A5192US 2222 9/30 9/30 LTN05C6S BOOK CLEARINGHOUSE INC HARRISON NY 6 05942US 2222 10/05 10/05 SBF5CM00 BARNES & NOBLE.COM 800-843-2665 NJ 61 A5192US 2222 10/09 10/09 YQ53TXOO BARNES&NOBLE BOOKQU EST 866-257-7723 NJ 61 A5192US 2222 10/13 PURCHASES*FINANCE CHARGE+PERIODIC RA TE 84 0000 ***Driver's Edge Charter Member Rebate Summary*** Previous Statement Rebates Total 261.71 Base Rebates Earned 2.61 Total Rebates Earned This Period 2.61 Total Rebates Available 264.32 Lifetime Rebates Earned 396.03 Bonus Rebates may take one to two billing cycles to apppear on your statement. Please refer to the speclfic terms and conditions pertaining to the promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 willsbeafter deducted from yourdrebate account. 35.76 rebates will expire an DECEMBER 31, 2004 Our records show home phone 717-761-8236 and business phone 717-238-6715. Please update coupon if incorrect. dtl' Amiable Ceeh WnR $288 New Calance $13651.09 per., 99 = 328 ?u_3a2'8 0 1328.99 . Annual; -375.00 -355.00 8.69 00000000058.79 75414914264 18.69 78432864273 21.45 85505944275 22.74 55432864279 8.74 55432864283 323.99 0000000000 EXHIBIT 16 LOUISE M LAMOREAUX s210 Dab Pat Dab LLNa?a aembar Aet WY Sian Left Statamant Aagaat Account Summary PrevkKn +) Purchases - Payments 01 FlMWF P) ew Balance b Advances b Credits CHARGE Balance PURCHASES $13,918.00 39.10 $1 $730.00 $3 3.99 $13 651 09 ADVANCES 00 :13,918.00 $s $139.10 00 $710.00 $323.99 , . $13,651.09 Da TW O11 PerW 30 Rata Summary y Balance asuWact to cl......? f-1- .? Periodic ._L_ amna ANNUAL Purch $13.715.64 0.07874%(D) 28.740% 28.740% Adv $0.00 0.07874%(D) 28.740% 28.740% 12/06/04 $13941.93 $314.46 SITE:KC-CL TMI:CO-5000 ACID:KC05076 WOMM Mona RAVOW 12109/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citr Driver's Edge' e CI Pla inum Select Card-Charter Rbts 5424 1800 3531 8168 tlRtotbK Service: 1-500-967-6500 Total Cre011 Lbea Avaiable Cred1t Live Cash Advance Umlt Available Cash L" Now Balance $13940 $0 $5600 s0 $13941.93 SOX 6500 SIOUX FALLS. SD MW o Am40°I,l IV,i, Pat Dw I pw Due 57117 11/10/2004 11.93 + s0.00 + 312.5 3 = 314.46 Sala Dub Pot Date RatwRix= Mah er ActWity 61.ea Led swat Aamant 11/08 62743505 Payyments credits it Adjustments PAYMENT THANK YOU -340.00 TO 0000 0000 Standard Parch 11/10 HO LD PREMIUM C REDIO 8.83 S 74 0000000000 11/10 A TE Fes- OCT PAYMENT PAST DUE L 339.00 A L ???? 10/21 10121 3GFVRHMB RIANDE CONTINENTAL MIA MIAMI FL 77.97 61 B7011US 2222 55499674297 10/21 10/21 PMBPGP00 AIG LIFE - TERM INS 301300075620 DE 58.79 61 M5969USA 2019 75414914295 10/25 10/25 YR4B•Y30 IMAGINATION SAIL i SIG MIAMI FL 138.72 61 E4411US 2222 55541864300 11/10 PURCHASES•FINANCE CHARGE•PERIODIC RATE 307.53 84 0000 0000000000 ***Driver's Edge Charter Member Rebate Summary* Previous Statement Rebates Total 264.32 Base Rebates Earned 5.51 Total Rebates Earned This Period 5.51 Total Rebates Available 269.83 Lifetime Rebates Earned 403.54 Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Your late fee was based on your account balance as of the payment due date (11/04/04). which was $13,926.57. COMPLIMENTARY TIRE CHANGE. Don't be stranded on the road with a flat! Call 1-800-670-6406 to request a wallet card for a tire change --at no cost to you. Don't target you can redeem your rebates toward the purchase or lease of a new or used car.. EXHIBIT /7 LOUISE M LAMOREAUX salt Data Pest Dab nmwvww *mmr Adtra/ flee Lot StMs ent Amood Account summary previous {+) c sa symen t FINANCE = New Baianee Advaacee S Credits CHARGE Balance PURCHASES $13.611.09 $323.31 $340.00 $307.53 $13 941.93 ADVANCES TOTAL 0.00 0.00 1 $0.00 , $0.00 $D.00 $13,651.09 $3 3.31 $340.00 $301.53 $13,941.93 Days This BDIt Period 28 Rabe Summary Balance Subject to Finance Charee Periodic Rate Nominal ANNUAL APR eenerru-rA -e• e.t. Purch $13,944.87 0.07874%(D) 28.740% 28.740% Adv $0.00 0.07874%(D) 28.740% 28.740% Y 01/06/05 $14069.67 $505.70 SITE:KC-CL TM:CO-5000 ACID:KCB5076 r oc? H ,, ... 12/09/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 17011-1850000 Citie' Drivers Edge' ati? PlAcc„a inum Select Card-Charter Rbts "Wow 5424 1800 3531 8168 M1kMer S6mft C _ 1-600-967-8500 16tH Credit Una Avalhble Clod Line Cash Advance Umlt Avama ble Cash Lbnn Now Balance $13940 s0 $5600 t0 $14069.67 BOX 6500 statanane/ Amovat Ow SIOUX FALLS. SD C1gs?y Date Crodlt Une Past Dw Pa A;1.,, tfMhtam Mlntaeem Dee at Dw 5T117 12/13/20 04 6129.67 + $0.00 + 5376.03 : 505.70 Sub Deb Peat Data Referents Number Activity Slag Last Statement Aanuat PayYments Credits E Adjustments 12/13 61881623 P riENNTTHANK YOU -350.00 O 0000 E P E E 12/13 RSNI DEC 04-MOY 05 B FE M 0.00 T4 0000 0000000000 12/13 ELD PREMIUM CRREDITTS H I .92 O O O 0000000000 12/13 LATE FEE - NOV PAYMENT PAST DUE 39.00 0 0000 00000 11/18 11/18 3GRXSM00 AIG LIFFEE - TERM INS 301300075620 DE 58.79 61 N5969USA 2019 75414914323 12/13 PURCHASES+FINANCE CHARGE'PERIODIC RATE 371.03 84 0000 0000000000 ***Driver's Edge Charter Member Rebate Sumfm;iry«ss Previous Statement Rebates Total 269.83 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Available 271.01 Lifetime Rebates Earned 404.72 Bonus Rebates nay take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Your late fee was based on our account balance as of the payment due date (12/06/04). which was $14.000.72. HAPPY HOLIDAYS FROM ALL OF US AT CITI! We'd like to take a moment to thank you for being a Citi Card member and let you know that we appreciate your business. warmest wishes for the upcoming year. EXHIBIT ?? LOUISE M LAMOREAUX s k into Wet Dab aelena a ".. a r Adhar:lee Let stebiasat AlesYMt A«?? Summary rvvous t) Balance S Purchases Advances Payments & Credits (+) FIKANCE CHARGE a) New Balance PURCHASES $13,941.93 00 $0 $1 6.71 00 10 $350.00 $0 00 $3 1.03 0 00 $14,069.67 0 ADVANCES TOTAL . $13.941.93 . $106.71 . $350.00 1 . $371.03 $0.0 $14r069.67 Da This BMan Perladt 33 Rate Summary Balance ec er c mnna ANNUAL Finance Charge Rate APR PERCENTAGE RATE Punch $14,156.73 0.07942%(D) 28-990% 28.990% Adv $0.00 0.07942%(D) 28.990% 28.990% t h 02/04/05 :14554.47 $1338.89 SITE:KC-CL T12/09/050 ACID•18B52755: CITI CARDS P-0. BOX 8108 LOUISE M LAMOREAUX S HACKENSACK. NJ 850 YVERDON DRIVE OT606-8108 CAMP HILL PA 17011-1850000 ' ' i a' ?\a atl s Ede ver Dr Citi Platinum Select' Card-Charter Rbts 5424 1800 3531 8168 Castolnar Swvlea: 1-000-967-8500 Total Credn Llna 40 Av*Mab* C-* Line cash Advance Unit $0 $5600 Available Cash Umit $0 New aalanee $14554.4T $139 BOX a50o tt6st?isg1nnone/ K.;OU; FALLS. SD 01/12/21805 Amount Over $6114.47 t+ $376 t03 VareMAdv + 13413.09 Minlmam $13315.59 Standard Parch 92 8 1/12 74EDIOO? LD PREMIUM . 0000000000 1/12 LATE FEE - DEC PAYMENT PAST DUE 39.00 O 0000000000 12/23 12/23 G5.lOX800 - TERM INS 301300075620 DE AIG LIFE 61 M5969USA 2019 58.79 754149143 1/12 DIT LIMIT FEE E OVER C R 35.00 OO O O 0000000000 1/12 •FINANCE CHARGE;PERIODIC RATE SEES RC 343.09 O 84 O ? X ***Driver's Edge Charter member Rebate Summary** * Previous Statement Rebates Total 271.01 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Expired 35.76 Total. Rebates Available 236.43 Bonus Rebates may take one to two billing cycles to appppeear on your statement. Please refer to the on and conditions pertaining to the specific , promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 35.76 rebates expired on DECEMBER 31 2004 5 R 3 2 1, 00 106.26 rebates will expire on DECEMBE Your late fee was based on your account balance s of the payment due date (01/06/05), which was 114,128.46. Your account is past due and your balance is over the credit line. To ensure you continue to receive the many benefits of Your cardmembership, please send the inimum Amount Due shown. If you have already sent us this payment, thank you. We are pleased to inform you that the current base benefits on your MasterCard(R) have been extended through September 1, 2005. For further information on the benefits you can access as a cardholder, please call 1-600-MC-ASSIST. EXHIBIT r LOUISE M LAMOREAUX lab Date Post Mb PAWSaoe NumMr AetMtr New Last Stdomat Amamt Rack up your rebates! Use your Drivers Edge Card for all purehases and watch your rebates quickly add up. Your rebates can be redeemed toward the purchase or lease of a new or used qualifying vehicle. FREE SERVICES FOR CITI CARDMEMBERS Manage your Citi Card account online securely, anytime - whether you want to check your balance, see it a payment was received or pay your bill. Register now at citicards.com Save Time. Save Paper. Sign up for All Electronic. Yau'il have instant access to your statement online, without that pile of paper. Get an a-rail notice when your statement is ready. Register or sign-on to citicards.com and choose Manage My Account. Rant to receive your billing statement in Spanish? Prefiere recibir su estado de cuenta en Espanol? Llamenos al 1-800-947-9100, o elija su idiom de ppreferencia en www.tarjetsciti.com, modificando su Perfil Personal en )a section Administrar all Cuenta. Fast Online Card Payments with Click-t*-Pay Pay your Citi Card bill online anytime day or night. Payments received by Ipm EST will post that same business day! Sign-on to citicards_com and choose the Make a Payment menu. Aeeolat Summary r•vious +) Balance & ur ases ayme s Advances .6 Credits + FININCE CHARGE (7-) Now Balance PURCHASES $14.069.67 $141.71 $0.00 $343.09 $14,554.47 ALCES 0 9 61 1 71 fl 00 43 0 4 5 TOT $14, 6 . . . $14 $3 . 9 5 . $14, Da TMs BS11 Period: 30 Rate Summary c• Subject o Finance Charge Periodic Rate Nominal APR PERC ANNUAL ENTAGE RATE PURCHASES Standard Purch $14,275.82 0.08011%(D) 29.240% 29.240% ADVANCES Standard Adv 0.00 0.08011%(D) 29.240% 29.240% F0 03/07/05 $14536.06 $1165.06 SITE:KC-CL TM:CO-5000 ACID:KCB5076 t 12109/05 18:52:55: CITI CARDS P.O. BOX 8108 LOUISE M LAMOREAUX 5 HACKENSACK, NJ 850 YVERDON DRIVE 07606-8108 CAMP HILL PA 1TOIl-1850000 Citr Driver's Edoeo Platinum Select Card-Charter Rbts A=OW* 141011W 5424 1800 3531 8168 Gustemer serreue: 1-800-967-8500 Toth Credit Una Available Cramp Line Ceah Advisee Limit $13940 $0 $5600 ROX 6500 statam"t/ Amaest pwr I t D P SIOUX FALLS. SD c?I ate 2 CrNit l na an ue 571f.7 05 02/10/ $596.06 + $216.42 + Debt 1/19 at1e Available Cash Limn Now Balance so $14536.06 50.58 = $ Payments, Credits i Adjustments 2/10 61616365 PAYMENNO ANK YOU 0000 Standard Purch 2/10 CREDITSNIELD PREMIUM 74 0000 2/10 LATE FEE- JAN PAYMENT PAST DUE 00 1/19 JY9PK500 AIG LIFE - TERM INS 301300075620 DE 61 H5969USA 2019 2/10 OVER CREDIT LIMIT FEE 62 0000 2/10 S FINANCE CHARGE*PERIODIC RATE RCHA 8 4 0 000 -Driver's Edge Charter Member Rebate Sunanaryee Previous Statement Rebates Total 236.43 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Available 237.61 Bonus Rebates may take one to two billing cycles to appppeear on your statement. Please refer to the spec: ific terms and conditions pertaining to the promotion for further details. Your late fee was based on your account balance as of the payment due date (02/04/05), which was $14,613.26. Your ccount is past due and your balance is over a the credit line. To ensure you continue to receive the many benefits of your cardmembership, please send the Minimum Amount Due shown. If you have already sent us this payment, thank you. Please see the enclosed Notice of Change in Terms to Your Card Agreement for important information regarding changes to your Card Agreement. -505.70 8.92 0000000000 39.00 0000000000 58.79 75414915019 35.00 0000000000 345.58 0000000000 EXHIBIT C LOUISE M LAMOREAUX Sale tab Pad Date IINiraap tMAa,ler AdMt?slap Last Statenast /laairt Account Summary Previous Balance + ure ses & Advances Payments & C edits (4) F11MCE CHARGE = Now Balance PURCHASES $14,554.47 $141.71 $505.70 $345.58 $14. 36.06 CES A 5 5 5 3 0 TOT I $14.554.47 $1 41.71 0 $ 70 45 58 $ $14,536. 6 Dan This ellum Perloa 29 Rate Summery Purch $14,749.90 0.08079%(D) 29.490% 29.490% Rdv f0.00 0.08079%(D) 29.490% 29.490% 04/05/05 $15023.27 $2002.77 SITE:KC-CL TM:CO-5000 ACID:KC05076 ..?IN 12/09/05 18:52:55: gow CITI CARDS PO BOX 183058 LOUISE M LAMOREAUX COLUMBUS. OH 650 YVERDON DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Citi` Driver's Edge' • CI IT, Plainum Select Card -Charter Rbts 5424 1800 3531 8168 CrntottNr S"I" 1-800-967-8500 Total Credk Llaa $13940 Awaabk Credit Line Case Advano Limit 0 $5600 $ Available Cash Lbnk $0 lkw aalance $15023.27 BOX 6500 SIOUX FALLS. SO ceseg?ta to 57117 03/!1/2105 p FA C?rediit L Past Ow $1083.27 + $569.00 Pore W Da. + 1350.50 = Amovat dpi $2002.77 Standard Parch 3/11 74EDITS ELD PREMIUM .92 00 0000000000 3/11 TE FEE FEB PAYMENT PAST DUE LA 9.00 66 DOW 0000000000 2/18 2/18 VOZX7600 AIG LIFE - TERM INS 301300075620 DE 58.79 61 N5969USA a r 75414915049 3111 OVER CREDIT LIMIT FEE 35.00 0?0 3/11 PURCHASES*FIKANCE CHARGE*PERIODIC RATE 345.50 B4 0000 0000000000 ***Driver's Edge Charter Member Rebate Summary*** Previous Statement Rebates Total 237.61 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Available 238.79 Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Your late fee was based an our account balance as of the paylaent due date (03/07105), which was $14.594.85. Your account is past due and your balance is aver the credit line. To ensure you continue to receive the many benefits of your cardmembership, please send the Minimum Amount Due shown.- If you have already sent us this payment, thank you. Important information: Please see the enclosed Notice of Change in Rebate Terms and Conditions for changes to the Driver's Edge Charter Member Rebate Program. EXHIBIT LOUISE M LAMOREAUX sar Dea Pmt Deb Ralmsm NaeMr Admty Since Last gateau t AnwUnt Account Summary revwus t Balance 6 urc aces - Advances & Payments Credks (4) FINIMEE = Now CHARGE B3 ante PURCHASES $14,5 6.06 10 00 $141.71 $0 00 0.00 0 00 $345.50 $15.0,?3 27 00 0.00 $0 ADVANCES TOTAL . $14,536.06 . $141.71 . 0.00 . 6 $345.50 $15,023.27 Days This Billing PKW 29 Rata Summary Balance • o Finance Charge Periodic Rate Nominal ANNUAL APR_ PERCENTAGE RATE d Purch $14,746.65 0.08079%(D) 29.490% 29.490% d Ady $0.00 0.08079%(D) 29.490% 29.490% 05/05/05 $14183.88 $680.37 SITE:KC-CL TM:CO-5 0050 ACID:18852T55: CITI CARDS PO Bolt 183058 LOUISE M LAMOREAUX COLUMBUS. OM 850 YYERDON DRIVE 43218-3058 CAMP HILL PA ITOII-1850000 Citl' Driver's Edge' Platinum inum Select Card Charter Rbts NUMber 5424 1800 3531 8168 CuSbww sert4tMc 2-600-W-8500 Total Credit Line AVOW* Lfedk Line Cash Advance Unit Available Cash Limit 8oX 6500 $13940 $0 $5600 $0 IsttssaIttieg?ment! Amos "t over t? ?arch/Adv SIOUX 57117 FALLS. SD 04/12/ I?2005e $243.88 + F^s.00 + 1436 49 sat: Dab Peat Gabe Rdaraaes btamber Aetivky NOW Last 90661000t /"?41 ati ew eaaaee $14183.88 bunlaan = 6Amount Do* 80.37 It Pil ya>tnts Credits it Adjustments AYtMFVa RK YOU 4108 43174415 -1,338.59 70 0000 Standard Parch REDIO?ELD PREMIUM 4112 8.92 T4 0 0?? 4/12 LATE FEE - MAR PAYMENT PAST DUE 39.00 0000 0000000000 3/18 3/18 ZTW44000 AIG LIFE TERM INS 301300075620 DE 58.79 61 N5969USA o r 75414915077 RC ASES*FINANCE CHARGE•PERIODIC RATE 4/12 33992.49 84 0000 ???? 00 ***Driver's Edge Charter Member Rebate Summarye• Previous Statement Rebates Total 238.79 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Available 239.97 Bonus Rebates may take one to two billing cycles to appear on your statement. Please refer to the t in to th i iti g e ons per a n specific terms and cond promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 106.26 rebates will expire on DECEMBER 31. 2005 Your late fee was based on your account balance Is of the payment due date (04105/05), which was 15.082.06. Our records show home phone 717-761-8236 and business phone 717-238-6715. Please update coupon if incorrect. EXHIBIT LOUISE M LAMOREAUX s.r mm.ta Pont oet. rAlw*aca l4tmbw AethAty Wm Lot Stat w mt Aeoret Account Summary rewaus Balance + ure aces 1G Advances aymen .& Credhs +IFINAWE CHAR3E (a New Balance PURCHASES ;15,0 3.27 $196.71 0 0 $1,338.59 $0 00 $392.49 00 $0 $14,163.88 0 00 ADVANCES 0.00 .0 $ . . . TOTAL $15,0 3.27 $106.71 ;1,338.59 $392.49 $14,1 3.88 Rate Sumnnnry Purch $15,053.32 0.08148%(D) 29.740% 29.740% Adv $0.00 0.08148%(D) 29.740% 29.740% 06/06/05 $14633.55 $1517.06 SITE:KC-CL TM:CO-5000 ACID:KC55016 : ,.. 12/09/05 18:52:55: CITI CARDS PO BOX 183058 LOUISE M LAMOREAUX COLUMBUS, OH 850 YVERDOli DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Driver's Edged' Citi' CTa , Pia inum Select Card Charter Rbts 5424 1800 3531 8168 Custanwr Service: 1-800-967-8500 Tetal Credit Une Avenaalo Cm* Lim Cash Advance Clink AvaVable Cash LYnk New Balance $13940 $0 $5600 $0 $14633.58 dOX 6500 SIOUX FALLS, $D clIqq..ww??yy Dattee A Crash Over Past Dw INIWAM l1 n?Dw A*euat fte 57117 05/11/Z0 05 $693.58 t $436.49 t 1386.99 = $1517.06 Sala Dote Past Bete Reweave Maai sr Acttft Sines Lot Statement M?aunt I EL 5/11 CRED TSKI E LD PREMIUM ? .92 O ? 5/11 LA TE FEE APR PAYMENT PAST DUE X9.00 A 6 0000 O0QW 4/19 4/19 K3D33000 AIG LIFE - TERM INS 301300075620 DE 58.79 61 M5969USA o r 75414915109 5/11 4RCN?ES*FINANCE CHARGE*PERIODIC RATE P 3442.99 B ??? ***Driver's Edge Charter Member Rebate Summary*** Previous Statement Rebates Total 239.97 Base Rebates Earned 1.18 Total Rebates Earned This Period 1.18 Total Rebates Available 241.15 bonus Rebates may take one to two billing cycles to a ppeear on your statement. Please refer to the specTlic terms and conditions pertaining to the promotion for further details. Please note that payments must be received by 1:00 p.m., local time, on a bank business day at the payment processing facility that handles your payments, in order to be credited to your account as of that day, and payments must conform to the payment instructions set forth on the reverse side. All conforming payments received at the ppayment processing facility after that time will be credited as of the following bank business day. Your late fee was based on your account balance D1s4of the payment due date (05/05/05), which was Your account is pa*t due. In order to redeem or continue earning Csti Driver's Edge Card rebates, pplease send the Minimum Amount Due shown. If you have already sent your payment, thank you. Save Time. Save Paper. Sign up for All Electronic. You'll have instant access to your statement online, without that pile of paper. Get an e-mail notice when your statement is ready. Register or sign-on to citicards.com and choose Manage My Account. EXHIBIT d3 LOUISE M LAMOREAUX Sub Dats Pant beta aalnesm Nwsher AdMtr Owe I st Stab~ Aemwet FREE SERVICES FOR CITI CARDMEMBERS. Manage your Citi card account online securely, anytime - whether you rant to check your balance, see if a payment was received or pay your bill. Register now at www.citicards.con Account summary revious BsIlglCe + Purchases & Advances Payments & Credits (+ FINANCE CHARGE M New Balance PURCHASES $14,183.88 $1Qb.71 ,2 $342.99 $14,633.58 ADVANCES X 0. 00 1000 10 0 $0.00 $0.00 TOTAL 33 . :14,18188 5106.71 0.00 $342.99 $14.633.58 Rate Sumateuy oaunce auopect TO Finance Charge vernocic Rate namnai ANNUAL APR PEgrEWAGE RATI >URCHASES Standard Porch IDVANCES $14.395.29 0.08216%(0) 29.990% 29.990% Standard Adv $0.00 0.08216%(D) 29.990% 29.990% OT/07/05 $15143.58 $24T4.35 SITE:KC-CL TM:CO-5000 ACID:KCB5076 12/09/D5 18:52:55: CITI CARDS PO BOX 183058 LOUISE M LAMOREAUX COLUMBUS, ON 850 YVERDON DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Citi' Driver's Edge' Platinum Select Card-Charter Rbts 5424 1600 3531 8168 Cusbomw SarWkW 1-800-398-2200 Tettt Cr"It Line AvelhWe CreNt Line Cesb Advance UfMt Available Cash Limit Box 6500 $13940 $0 $5600 50 SIOUX FALLS, SD e e Date A creed L?1 a lest nw FAMM Due 57117 06/13/2 05 S 1 Z03.58 + $823.48 + b?I 1447.29 Cltl ew Balance $15143.58 mew* pw = $2474.35 Sob Date Past Dabs nefereae number AetWy line Last stabment Aanoaat e PREMIUM 6/13 CREDITSHIELD 8.92 74 0000 0000000000 6/13 LATE FEE - MAY PAYMENT PAST DUE 39.00 66 IFEO 0 000000000 5/19 5/19 R6Y2Ze00 AIG L - TERM INS 301300075620 DE 58.79 61 N5969USA o r 75414915139 6/13 PPURCN??•FINANCE CHARGE•PERIODIC RATE 403.29 84 000000000 DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned 1 HE uDRIVER'S/EDGQQEiREB TES 9 A - 1 Previous Balance Purchase Rebates Earned 241 PREVIOUS DRIVER'S EDGE REBATES 241 Lifetime Activity Total Rebates Earned 302 Total Rebates Expired 151 Total Rebates Redeemed 0 Total Rebates Available 150 Bonus Rebates clay take one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Citt Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 1.12 rebates will expire on JULY 13, 2005 Your late fee was based on your account balance Is of the ppayment due date (06/06/05), which was 14,692.37. Your account is past due and your credit privileges are suspended. In order to redeem or continue earning Citi Driver's Edge Card rebates, please pay the Minimum Amount Due shown. If you have already sent us this payment, thank you. Important Information: Please see enclosed insert for discounts and offers from Hertz especially for Driver's Edge(R) Cardwembers. EXHIBIT LOUISE M LAMOREAUX aer wt. Pmt bete Refs w. Mumaw ACtftl steae Liffilt 5- Amount t Summary Aocot at Previous Bolanc + Purchases & Ad antes aym s r. CredRs + FINANCE CHARGE = Now Balance _ PURCHASES tCES f A $14,633.58 $1:06.71 0.00 $403.29 03 $15,143.58 58 1 3 L A TOT 514 ,63.58 5146.71 0.00 29 $4 4 $15, . Rate Summary ?Fieaace Charae Rate APR PERCENTAGE RATE_ rd Purch $14.874.39 0.08216%(D) 29.990% 29.990% rd Adv $0.00 0.08216%(D) 29.9901(7 29.990% 08/05/05 $15632.42 :3389.32 SITE:XC-CL TM:CO-5000 ACID:KC85OT6 ----- .---. - - .............. 1.?., Xl 12109105 15:52:55: CITI CARDS PO BOX 163058 LOUISE M LAMOREAUX COLUMBUS, OH 850 YVERDON DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Citi' Driver's Edge' Pfau inum Select Card-Charter Rbts 5424 1800 3531 8168 ontoolff sa -yom ^&an" urmt 1-600-B66-9900 Tow Credn Llne AvAnble Credit Lkw $0 can $5600 $13940 BOx 6500 SIOUX FALLS. SD X7117 Ci?11 De : O7/13/2?05 ct Aasit `m :1692.42 + Past D"' $1270.77 + C! ?1' A%Wlasie Cash Lhnn flew aalamce $0 $15632.42 i?IM . Dw A?sunt Oue 1426.13 = $3389.32 A Standard Purch 7/13 CREDITSHIELD PREMIUM 74 0 O 7/13 - JUN PAYMENT PAST DUE LATE FFEE 6/20 6/20 X1Tx5RO0 66 0000 AIG LIFE - TERM INS 301300075620 DE 7/13 61 N5969USA o r 'FINANCE CHARGE-PERIODIC RATE ES OURCHO O S 84 DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned 2 Ad ustments / Expired .1 HE DRIVER'S EDGE REBATES 0 Previous Balance Purchase Rebates Earned 150 PREVIOUS DRIVER'S EDGE REBATES 150 Lifetime Activity Total Rebates Earned 303 Total Rebates Expired 150 Total Rebates Redeemed Total Rebates Available 150 Bonus Rebates my take one to two billing cycles to a ar on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 wilisbefdeducted fronyourdrebateiaccountates 2.26 rebates wilt expire on AUGUST 11, 2005 Your late fee was based an your account balance !15 of the payment due date (07/07/05). which was .202.37. Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 an - 5 pm, Central Time. 8.92 000000000 9.00 0000000000 58.79 75414915171 382.13 0000000000 EXHIBIT '15 LOUISE It LANOREAUX so* M!a Pat Dote aNgmm Nulobw AetMtr Sims Let asomew Ammmt Accowt Stanmary rw ous +) Balance 6 Purchases Advances aym s b Credits C+) ri CHARGE = New Balance PURCUA5E5 515,143.5fl $000 S1Q6.T1 WOO JOHN, 53 2.13 0.00 515,632.42 ¢0.00 ADVANCES TOTAL :15,143.58 $106.71 0.00 53 2.13 515,632.42 Da Thlt 5 n Period: 30 ante Subjtct to Periodic Nominal ANNUAL Rate Summary Finance Cfiarpe Rate APR P ERCENTAGE RATE Purch $15.374.40 0.08285%(D) 30.240% 30.240% Ady $0.00 0.08205%(D) 30.240% 30.240% . V L BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, Id. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX : NO. 05-5791 Civil Defendant : CIVIL ACTION - LAW Affidavit of Citibank (South Dakota) N.A. in Support of Plaintiffs Summary Judgment Motion I, ERICKA SMITH , am competent and make this affidavit based upon personal knowledge and review of business records described herein. 1 am employed by Citicorp Credit Services, Inc. (USA), a servicing company for Citibank (South Dakota) N.A. ("Citibank"). I am authorized to make this affidavit on behalf of Citibank in support of its motion for summary judgment. I share custodianship and have access to all of the documents in the possession of plaintiff that are germane to this case. The following statement is true and correct to the best of my knowledge, information and belief. I understand that this statement made is subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Citibank is a national bank located at 701 East 60th Street North, Sioux Falls, South Dakota. Citibank engages in various types of banking business including consumer lending through the issuance of credit cards including the credit card issued to defendant with account number 5424180035318168. In the regular course of its business, Citibank maintains as a regular business practice accurate and running computer records of the activity on credit card accounts, including defendant's account. These records reflect the purchases made, payments received, amounts owing, and credits and debits. It was the regular practice of Citibank to send monthly billing statements to defendant. These monthly billing statements reflect the account activity including EXHIBIT -? charges for any purchases, cash advances, finance charges, late fees and over the limit fees, payments and other credits, the balance due, and the minimum payment amount. Plaintiff mailed monthly billing statements for the account each month to defendant. The monthly billing statements were sent to defendant at the address of record, beginning the month after the credit card was issued. All the charges on the monthly billing statements sent to defendant were correctly calculated. The last monthly billing statement Citibank mailed to defendant was dated July 13, 2005 and set forth a new balance due in the sum of $15,632.42. A copy of this billing statement is attached hereto as Affidavit Exhibit 1. Subsequent to the date of the Exhibit 1 statement, defendant made payments totaling $6,410.00. These payments reduced the balance due on the account to $9,222.42. As of the date of this affidavit the amount due Citibank on the account is $9,222.42. `cam Date S '-?, i O 08/05/05 $15632.42 $3389.32 SITE:KC-CL TM:CO-5000 AC1D:KCB5076 ,, Y.. 12/09/05 18:52:55: CITI CARDS PO BOX 183058 LOUISE M LAMOREAUX COLUMBUS, OH 850 YVERDON DRIVE 43218-3058 CAMP HILL PA 17011-1850000 Citi' Driver's Edge" Platinum inum Select Card-Charter Rbts 5424 1800 3531 8168 C..ftb tr Sarvkw 1-800-866-9900 Total Credit Line Available Credit Line $0 cash Advance Limit $5600 Available Cash Limit $0 $13940 BOX 6500 SIOUX 7117 FALLS, SD 5 statement/ 07/1372005a Amovnl r $1692.42a+ $1270a.77a PurlNA4V + 1426.13 C tl? Now 0alanco $15632.42 13389. Standard Purch 7/13 CREDITSHIELD PREMIUM 74 0000 7/13 LATE FEE - JUN PAYMENT PAST DUE 66 0000 6/20 6/20 X1TX5R00 AIG LIFE - TERM INS 301300075620 DE 61 W5969USA o r 7/13 PURCHASES+FINANCE CHARGE•PERIODIC RATE 84 0000 DRIVER'S EDGE REBATES SUMMARY Activity This Period Purchase Rebates Earned i Adjustments / Expired . NEW DRIVER'S EDGE REBATES 0 Previous Balance Purchase Rebates Earned 150 PREVIOUS DRIVER'S EDGE REBATES 150 Lifetime Activity Total Rebates Earned 303 Total Rebates Expired 153 Total Rebates Redeemed 0 Total Rebates Available 150 Bonus Rebates may take one to two billing cycles to apppear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. Citi Driver's Edge Charter Member rebates expire 3 years after they are earned. Expired rebates will be deducted from your rebate account. 2.26 rebates will expire on AUGUST 11, 2005 Your late fee was based on your account balance as of the payment due date (07/07/05), which was 515.202.37. Your account is seriously past due and your credit privileges have been suspended. Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am - 9 pm, or Saturday, 8 am - 5 pm, Central Time. 8.92 0000000000 39.00 0000000000 58.79 75414915171 382.13 0000000000 EXH I B IT_______t BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire, Id. No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX NO. 05-5791 Civil Defendant : CIVIL ACTION -LAW Plaintiffs Brief in Support of Summary Judgment Motion A. History of the Case Plaintiff sued defendant to recover the past due balance owed on a credit card account in the sum of $10,722.42. Defendant filed an answer with new matter to which plaintiff filed a reply thereby closing the pleadings. Subsequent to the filing of the lawsuit, defendant made payments which reduced the balance to $9,222.42. Plaintiff served defendant requests for admission which defendant failed to answer. Plaintiff filed a motion for summary judgment because there is no genuine issue of material fact. The pleadings and matters admitted from the requests for admission constitute the record for purposes of this motion. Plaintiff's motion is before the Court for disposition. B. Issue Whether there exists a genuine issue of material fact which will require a trial? C. Argument There is no genuine issue of material fact which will require a trial. This is because of two reasons: (1) defendant admitted all of the allegations in the complaint and (2) all matters in the requests for admission were admitted. The answer to the complaint admitted all the allegations either directly or because of denials which had the effect of an admission. Defendant directly admitted complaint paragraphs 1 through 4. Answer paragraphs 5 and 9 were stated "Denied. Proof is demand." A demand for proof except as set forth in Rule 1029(c) has the effect of an admission. See Pa R.C.P. 1029(b)'. Therefore, defendant admitted complaint paragraphs 5 and 9. Answer paragraph 6 also had the effect of an admission. Defendant did admit that plaintiff mailed a billing statement each month because there was no response to the allegation. The denial "any statements did not accurately reflect debits or credits" is an admission. "Although no fixed rule can be stated for determining whether a denial is specific, generally for a denial to be specific, it must deny what is averred and then must affirmatively aver what did occur in place of the facts as averred." 5 Standard Pennsylvania Practice 2d Section 26:40 and the cases cited therein. See also Acme Cotton Products Co. V. Michael McDonou h Inc., 61 Pa. D. & C.2d 608 (1972); affirmed, per curiam, 225 Pa. Super. 701, 306 A.2d 351 (1973).2 In other 'Pa. R.C. P. 1029(b) provides :Averments in a pleading to which a responsive pleading is required are admitted when not denied specifically or by necessary implication. A general denial or a demand for proof, except as provided by subdivisions (c) and (e) of this rule, shall have the effect of an admission." 2The denial was an admission also because it is in haec verba. "Any form of general denial is an admission, including a denial which merely repeats allegations almost verbatim in the negative..." 3 Goodrich - Amram 2d § 1029(b):4. The rule cited in the treatise has been the law in Pennsylvania for many years and has periodically served as the basis for grant of a motion for judgment on the pleadings. See Hoffman v. Bozitsko, 198 Pa. Super. 553, 182 words, debtor was required to aver facts which stated the reasons that the debits and credits in the statements were not accurate. Therefore, defendant admitted complaint paragraph 6. In paragraph 7 of the answer, defendant alleged objections to the statements were made periodically. For the reasons noted above and on the same grounds as in the Acme case, this is a general denial because not a single fact was alleged in support of the averment. Complaint paragraph 8 alleged defendant did not dispute, object or protest any of the billing statements to which defendant merely stated she did not assent to the correctness of the balance. Here, too, defendant alleged no facts why the balance is not correct. Although this is not a Rule 1029(c) denial, the logic of the Cercone3 case would apply. This is because defendant would be in a singular position to possess information which would enable her to respond specifically to the paragraph's allegations. She is the one who used the credit card, received the billing statements, reviewed them, made payments, had the opportunity to determine whether the statements were correct or not and as such could respond specifically. Had a notice of billing error been sent to plaintiff, she could respond specifically with the date it was sent and summarize its material facts. She did none of this. Therefore, paragraph 8 was admitted. The new matter alleged defendant made payments on the account. Plaintiff's reply and affidavit reflect defendant was given credit for all payments she made. The matters admitted in the requests establish the payments she made which left a balance due on the account in the sum of $9,222.42. Defendant did not answer the requests for admission. Pursuant to Pa R.C.P. 4014(a) and (b), each matter sought to be admitted in the requests was admitted and conclusively established for the purpose of this case. These admissions are sufficient for the Court to grant the motion4 A.2d 113 (1962); Noll v. Hamil, 72 Pa. D. & C.2d 177 (1975); Martin v. Barfield, 66 Pa. D. & C. 321 (1948); Sheppard v. Stubbs, 19 D & C 215 (1910). 3In Cercone v. Cercone, 254 Pa..Super. 381, 386 A.2d 1 (1978), the Superior Court held that a defendant may not rely upon Rule 1029(c)(1) to excuse a failure to make a specific denial of factual allegations contained in a complaint when it is clear that the defendant must know whether a particular allegation is true or false. 4The failure to answer request for admissions was the basis for summary judgment in whole or in part in the following cases: Borough of Mifflinburg v. Heim, et al., 1997 Pa. Super. LEXIS 4020, 705 A.2d 456, 466 (1997); Bvmes, Inc. v. Buss Automation, Inc., 415 Pa. Super. 549, 609 A.2d 1360 (1992); Innovate Incorporated v. United ._, : # because they confirm there is no genuine issue of material fact which will require a trial. Finally, defendant's new matter paragraph 2 raised no genuine issue of material fact. This is clear because no facts were alleged to support the bald averment. Further, there is no provision within the Fair Debt Collection Practices Act, 15 U.S.C. 1692 which would provide a defense to a creditor's action to recover a debt. D. Conclusion The judicial admissions5 in defendant's answer and the matters admitted in the requests for admission are binding and conclusive on defendant. They establish proof of plaintiff's account stated cause of action.b Because there exists no genuine issue of material fact, trial is unnecessary. Therefore, summary judgment should be entered under Pa. R.C.P. 1035.2 for plaintiff and against defendant plus the costs of this action. BURTON NEIL 8/ASSOCIATES, P.C. Attorney for Plaintiff In making this communication, we advise our firm is a debt collector. Parcel Service, Inc., 275 Pa. Super, 276, 418 A.2d 720, 723 (1980); Bamebei v. Hauf, et al. 116 Dauph. 215 (1996); Carter v. Harrisburg Motel Enterprises, Inc., 113 Dauph. 479 (1993). 5A judicial admission is an express waiver made in court or preparatory to trial by a party or his attorney, conceding for the purposes of the trial, the truth of the admission. It has the effect of a confessory pleading, in that the fact is thereafter to be taken for granted, so that the opposing party need offer no evidence to prove it and the party by whom the statement was made is not allowed to disprove it. See 9 Wigmore, Evidence Section 2588 (Chadbourne Rev. 1981). It is axiomatic that a judicial admission cannot be contradicted by the party that made it. See Tops Apparel Mfg. Co. v. Rothman, 430 Pa. 583, 244 A.2d 436 (1968). Jewelcor Jewelers & Distributors v. Corr, 373 Pa. Super 536, 542 A.2d 72 (1988) 6The Second Restatement of Contracts defines and states the legal effect of an "account stated" at Section 282 as follows "(1) An account stated is a manifestation of assent by a debtor and creditor to a stated sum as an accurate computation of an amount due the creditor. A party's retention without objection for an unreasonably long time of a statement of account rendered by the other party is a manifestation of assent."(Emphasis added) Under Pennsylvania law, "...the essence of a common law action for an account stated is an agreement, either express or implied, based upon prior transactions, between two parties as to the correctness of an amount due.." Connolly Epstein Chicco Foxman Engelmyer & Ewing v. Fanslow, 1995 WL 686045 at *5 (E.D.Pa.1995) (applying Pennsylvania law). Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff V. LOUISE M LAMOREAUX Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-5791 Civil : CIVIL ACTION - LAW Certificate of Service I, Burton Neil, Esquire do hereby certify that I served a true and correct copy of the within Plaintiff s Motion for Summary Judgment, Brief in Support, proposed Order and Praecipe for Listing Case for Argument on pro se defendant, Louise M Lamoreaux, at her address of record via first class mail, postage prepaid on the date set forth below. Burton Neil & A ociates, P.C. R Date: By: B (Lwff Ne quir Attorney for Plaintif The law firm of Burton Neil & Associates is a debt collector. C-8037 CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX NO. 05-5791 Civil Defendant : CIVIL ACTION -LAW ORDER AND NOW, this day of , 20, plaintiff s motion for summary judgment is GRANTED. Judgment is entered for plaintiff Citibank (South Dakota) N.A. and against the defendant Louise M. Lamoreaux in the sum of $9,222.42 plus record costs of $96.94 for a total judgment of $9,319.36. BY THE COURT: J. 63 _Z Wd 61 AON LOOZ 3HI Jo ?.'U?Cg4&Ij Praecipe for Listing Case for Argument (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CITIBANK (SOUTH DAKOTA) N.A. Plaintiff V. LOUISE M LAMOREAUX Defendant NO. 05-5791 Civil 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Plaintiff's Motion for Summary Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Burton Neil, Esquire c/o Burton Neil & Associates, P.C. address: 1060 Andrew Drive, Suite 170, West Chester, PA 19380 b) for defendant: Louise M Lamoreaux, Pro Se address: 850 Yverdon Drive Camp Hill PA 17011-1850 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: January 23, 2008 Attorney for the The law firm of Burton Neil & Associates is a debt collector. E'7 C ev c=a Q 7_7 1i{;: CJ -n '_ .qC T 0 0 N CITIBANK (South Dakota) N.A., IN THE COURT OF COMMON PLEAS OF PLAINITFF CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M. LAMOREAUX DEFENDANT NO. 05-5791 CIVIL IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this 25th day of January, 2008, after consideration of the Plaintiffs Motion for Summary Judgment and the Court noting that the Defendant did not file a brief in opposition to the Plaintiff's Motion nor appear for argument, IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion for Summary Judgment is GRANTED. IT IS FURTHER ORDERED AND DIRECTED that Judgment be entered in favor of the Plaintiff, Citibank (South Dakota) N.A., and against the Defendant, Louise M. Lamoreaux, in the amount of $9,222.42 plus record costs of $96.94 for a total Judgment of $9,319.36. By the Court, Burton Neil, Esquire Attorney for Plaintiff M. L. Ebert, Jr., J. 120P 1?-v rnv?LLQ Louise M. Lamoreaux, Pro Se Defendant bas f,i ..may ¢' G ] •?? 1. ai ?? d?^ Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M LAMOREAUX Defendant : NO. 05-5791 Civil : CIVIL ACTION - LAW Praecipe for Entry of Judgment on Court Order To the Prothonotary: Enter judgment on behalf of the plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and against the defendant, LOUISE M LAMOREAUX, as per the Court's Order dated January 25, 2008 and assess damages in the sum of $93fr Burton N ' & By P.C. Neil, Esquire And now, this 0(#k, day of judgment is entered on behalf of the plaintiff, CITIBANK (SOUTH DAKOTA), N.A.' and against the defendant, LOUISE M LAMOREAUX, in the sum of-S9,9 t . 9, •y? Prothonotary of Cum rland County - /Y&gwi?w - In making this communication, we advise that this office is a d 4t collector. CITIBANK (South Dakota) N.A., IN THE COURT OF COMMON PLEAS OF PLAINITFF CUMBERLAND COUNTY, PENNSYLVANIA V. LOUISE M. LAMOREAUX DEFENDANT NO. 05-5791 CIVIL IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this 25"' day of January, 2008, after consideration of the Plaintiffs Motion for Summary Judgment and the Court noting that the Defendant did not file a brief in opposition to the Plaintiff's Motion nor appear for argument, IT IS HEREBY ORDERED AND DIRECTED that the Plaintiffs Motion for Summary Judgment is GRANTED. IT IS FURTHER ORDERED AND DIRECTED that Judgment be entered in favor of the Plaintiff, Citibank (South Dakota) N.A., and against the Defendant, Louise M. Lamoreaux, in the amount of $9,222.42 plus record costs of $96.94 for a total Judgment of $9,319.36. By the Court, M. L. Ebert, Jr., - ( \ J. Burton Neil, Esquire Attorney for Plaintiff Louise M. Lamoreaux, Pro Se Defendant bas Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. LOUISE M LAMOREAUX 850 Yverdon Drive Camp Hill PA 17011-1850 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5791 Civil : CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. Burton Neil Associates, P.C. Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that this office is a debt collector. rv ? W O LA? Cam- ° -n t c -*i rT'? n1 rv ? Cf) 7jj rY C: N rn ?- ?ca r S Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS V. LOUISE M LAMOREAUX Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5791 Civil Defendant : CIVIL ACTION - LAW Rule of Civil Procedure No. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on q- aw Prothonotary of Cumberland County If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 In making this communication, we advise that this office is a debt collector.