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HomeMy WebLinkAbout07-2402IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. :CIVIL-LAW JII_,L A KULIG :DOCKET NO. Q 7 ~ a~~a C~ Defendant NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IlV COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty {20j days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for arty money claimed in the Complaint or for arty 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 WFIERE YOU CAN GET LEGAL HELP. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 Cumberland County Bar Association 2 Lberty Avenue Carlisle; PA 17013 717-249-3166 717-238-6807 LAURINDA J_ VO CKER, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR Plaintiff vs. CIVIL-LAW JILL A KULIG :DOCKET NO. D 9- ~ ~D z. ~! ~,[.tvw- Defendant COMPLAINT The Plaintiff, Remit Corporation, by and through its attorney Laurinda J. Voelcker, Esquire, hereby files this Complaint of which the following is a statement: The Plaintiff The Remit Corporation is a Pennsylvania Corporation doing business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania 17815 and is the assignee of Unifund CCR Partners. Copies of the documents assigning all relevant rights with reference to the present action to the Remit Corporation are attached hereto, incorporated herein and referred to hereafter as Exhibits A and B. 2. The Defendant, Jill A Kulig, is an adult individual residing at 3 Crooked Drive, Enola, Cumberland County, Pennsylvania 17025. Defendant obtained a First USA Bank Mastercard credit card on or about March 10, 1998, from Chase Manhattan Bank USA National Association (hereinafter "original creditor"), Account number 5422 7020 3700 9826. 4. Unifund CCR Partners purchased the account of Till A Kulig from Chase Manhattan Bank USA National Association. A copy of the Affidavit of Indebtedness is attached hereto and labeled as Exhibit B. 5. Defendant used the extended credit leaving an unpaid balance of $19,181.36 with interest continuing to accrue at 23.24% per annum. 6. Defendant's last payment on this account was made on or about May of 2003. 7. To date the balance is $10,167.93 principal and $9,013.43 interest for a total of $19,181.36. COUNT 1 BREACH OF EXPRESS CONTRACT 8. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 9. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his account. 10. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $19,181.36. 11. Defendant accepted the extension of credit and utilized the credit card without complaint, objection or dispute as to credit services provided, the prices charged for the same or the costs incurred. 12. Defendant is indebted to the Plaintiff in the amount of $19,181.36. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. 13. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(1), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against the Defendant in the amount of $19,181.36 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 14. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 15. It is averred, in the alternative, in the paragraphs set forth above, if an express contract between original creditor and Defendant did not exist, that a contrail implied by fact or implied within the law exists. 16. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to her and that the original creditor expected to be paid for the Defendant's use of this credit. 17. Defendant used the credit card to purchase items, and/or transfer balances, and/or obtain cash advances and she received the same to her benefit. 18. The total reasonable value of the Defendant's use of the credit extended by original creditor is $19,181.36. 19. In breach of the implied contract, Defendant has failed and refused to pay the outstanding sum for the credit card use and the same is now due and owing. 20. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 21. By virtue of Plaintiil's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $19,181.36. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against the Defendant in the amount of $19,181.36, together with interest, costs, ASSIGNMENT OF CLAIM PURSUANT TO PENNSYLVANIA ACT 219 OF 1990 For value received, the undersigned: Unifund CCR Partners assigns to: The Remit Corporation doing business at: 36 W Main Street PO Box 7 Bloomsburg, PA 17815 a debt due to the undersigned from: Jill A Kulig # 418476 5422702037009826 for the sum of $19,181.36 arising from unpaid credit card services with interest accruing at 23.24% per annum. The said sum is justly due to the undersigned without offset or defense. The undersigned neither transfers to The Remit Corporation, nor expects The Remit Corporation to assume, any obligation or any liability of the assignor to the said debt. The undersigned has done nothing and will do nothing to discharge the debt or hinder its collection and hereby grants to The Remit Corporation the full power and authority, to bill and collect the aforesaid claim, in accordance with Pennsylvania Act 219 of 1990, Section 2, as it amends Title 18 regarding Section 7311, including to sue for, (in its own name, through a licensed attorney) and discharge the assigned debt or to sell and assign it again. The Remit Corporation specifically agrees to comply with the Pennsylvania Act of December 17, 1968, P.L. 1224, No. 387 (known as the Unfair Trade Practices and Consumer Protection Law), and with the regulations promulgated under that Act pursuant to this assignment. Dated this 22nd day of February, 2007. Jo Unifund CCR Partners EXHIBIT AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton) ss. Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and the statements and representations herein are within her personal knowledge. The defendant is not in any branch of the military. There is due and payable from JILL A KULIGS Account Number 5422702037009826, the amount of $19181.36 (principal balance in the amount of $10167.93 plus interest up through 01/26/2007 in the amount of $9013.43). By the terms of the agreement between the defendant and the original creditor, . interest is accruing from the aforesaid date at the rate of 23.24 percent per annum. This balance reflects any payments, credits or ofrsets made since the account was charged off. Chase Manhattan Bank USA NA's account-was issued under the name of FIRST USA BANK. Unifund CCR Partners purchased this account from Chase Manhattan Bank USA NA. Said account has been referred to REMIT Corporation .with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said. claim. DATED t ' January 26, 2007 CCR PARTNERS By: Kim Kenney Media Supervisor 10625 Techwoods C_ ir_ cle Cincinnati, OH 45242 . ~ Address Subscribed and sworn to before me this 26 day of January 2007 Year ~- ~~, Notary Public My commission Expires Client # 634 . , .,,,,, ~ ~N 4 .••' KAREN WILLIAMS NOTARY PUBLIC STATE OF OHfC) Cd''n~- Expires Duty 19, 2010 EXHIBIT .~~~ ~~ ~~ ~~ ~ ~~ m ~.~Q ~ ~~~ ~ ~~~ ~ ~ ~ a ~ ~_ ~~ ~~P ~~ ~ ~ ~~ ' ~ ~~ ~~ ~ Z A m o~ S~ ~° N ~O ~~ r~ r N ~ ~ ~ ~T ~ ~.~~ w~. ~~~ a ~a ~~ .~g~ .~ ~~ ~ . p. a' ~~~ ~~ ~ ~ .~ a a ~ ~ ~ ~~ ~~ ~~~ ~~~ ~ ~~g~ .~ ~~ ~ ~ g ~- ~~~ s d g ~ ~ • ~. ~~ a =. ~ ~ ~ ~ ~ 'a ~ ~ ~~~ ~ ~ ~~~ ~~~ ~ ~ ~~~ ~ a ~ .~~ ~a~~~ ~~ ~ ~~ ~~ Q ~ ~ o ~ ~~~ ~ ~ ~~~ ~ ~~ ~~~~ " ,~, Q fa '$ ~ D ~ ~ ~ c ~ SC ~ ~ N ~ ~ of ' ~ 3 - _ '" ~ '7 -_~~~-- ~~~~_~~~ ~ _~4~~-~~~""-~~~ dig ~ ma K ~ ~ ~~~ ~~~.ry~ ~_ ~~ '~~,~~ua$ ~._ ~3~ '~ _ ~ EXHIBIT' T ^~ 7 ~ N W ~ O N 7 ~ S~, ~ ~ d Q to ~ ~ ~ ~ ~ ~ ~ ~ y~ sj• 'tr$3 ~Q{~ q f0 ~ {yT~ CI CN7 W 6 ~~22 1\./. O' ~ W Pri ~ .o ~ 75 ~ ~ S ~ _ C a a ~ ~ C ~ ~ ~ ~ ~ ~ F S"c ~ ~ G ~ Q. ~ ~ ~ ~ ~ . 9 ~gN ~~Q ~~ fi=g ~ ~~a~ ~,~ ~-+ ~4.3ga N ,~ ~ y - ~ d ~' g am ~~~ g ~S~g a~~ ~.F~a~ ~~ _~~ ~. _ ~' ~ -+ asap ~~ ~ Q ~ ~ ~~ ~~ a~~ Q g ~ ~ ~ ~~ ~"~~ ~a~ .~ ~ ~~~ ~~ S ~ 3~ ~ ~. .~~ ~ a ~ ~~~ ~ ~ ~m ~ °~ ~~ ~ ~Q ~> ~- ~ g~ A ~- ~ ~ g ~.~. ~~ ~ ~ ~~ ~ ~ ~~ ~~ s R ~~ ~~ ~~~~~~ ~ ~~ ~p s ~ ~ ~a s~~~ ~~ ~~~~ ~ ~~~~. ~ ~ y ~ ~~ ~ ~ ~ ~~. ~~ ~m~~~ ~~~~ ~~ ~~~~ ~~~~ ~~~~~ ~~~~~Y~ °~ ~ ~,~ as ~ $ S ~~ ~.~~ ~ ~ ~~~ ~~~~ ~~ ~ ~ ~ ~ ~~ s ~ ~~ . ~ ~ g ' -i ~~ a ~'~ . ~~ ~~~Q ~~, ,~ ~ 9~ ~aS~ ~ .~ ~ ~~~ $ ~~ ~ ~~ ~~$~ ~ ~~ ~ ~ _~,~ s ~ ~ ~~ ~ ~ ~ ~ ~ ~ ~ ~ ~~ ~s ~ ~ ~ ~ ~ ~ ~w ~ ~3.~ M~~~~f~ e~t• ~~Q~~~~p g 1~ s or ~ ~~ ~ ~~ 9 ~ a ~Y ~~ fT N~~ ~ ~ J ~s~ ~~ ~ .d S ~ $ 'g d' s +~ ~ 4. Q~ S S w ~ ~~ ~ ~ ~. ~ >_ g ~. ~ g ~ ~ ~ a ~ a 3~ ~~ ~ ~ ~ v ~. d ~ ~ ~~~~~ W ~ L ~ ~ N . ~ ~~ . ~' ~ N ~ ~ ~ s ~ ~.~ ~~ ~ ~ ~ 3 ~~ ~a ~ ~ ~ ~ ~ ~ ~' ~.~~ ~~ ~ ~ g ~ ~ d ~~ ~~ ~ y ~l ro .. roe a ~ ~~ ~~ ~ ~ ~ . $ ~ ~ ~ ~~ `~ ~ ~ 3 gad r? ~° 5 ~. ~ ~ ~ ~ ~_ ~ ~ ~~. ~~ ~ ~ ~ ~ ~ ~ ~ .~~ ~ ~ . ~~ .~~ ~ ~ ~~ ~ ~ .~.~ .~ ~ g ~ ~ p~ a ~~~ ~~. ~~ g~,~s~ ~ ~ ~ .~ A . ~ ~ ~ ~ a ~' . ~ ~ ~ ~ ~ ~ -~ g~ ~ ~~ ~ ' ~ ~~~~~ ~~ c~ g ~~ a ~ ~~ ~~~ ~~~ -~ Q a• ~ ~~~ . a ~~ ~ ~++ a .~ ~ ~ ~ ~ ~~~ ~~m~Y~ ' ~-~ ~~ ~~o ~ ~~. "~~ ~~~ ~ ~~ ~~~ ,. ~ m ~~~ ~~~~g~~~~~~ .~ i ; VERIFICATION I verify that the statements made in the foregoing Civil Complaint are true and correct upon my personal knowledge or information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Lari M. Reed, mit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, : Assignee of Unifund CCR, Plaintiff vs. :CIVIL-LAW JII.,L A KULIG :DOCKET NO. Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof. /~CF Dated this (~ day of , 2007 Laurinda J. Voelc er, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 (570) 387-1873 Request for Mlitary Status Department of Defense Manpower Data Center .~ Military Status Report ~' x Pursuant to the Servicemembers Civil Relief Act ,' Page 1 of 2 MAR-19-2007 09:06:12 Last Name FirstlMiddle Begin Date Active Duty Status Service/Agency KULIG JILL A Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~ ~,-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional 1Vrlitary Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http //www.defenselink.n~il/fad/pis/PC09SLDR,html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 03/19/2007 Req~iest for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report III: CBFAUGXhPWD https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 03/19/2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. :CIVIL-LAW JILL A KULIG :DOCKET NO. Defendant : CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) aze as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Jill A Kulig 3 Crooked Drive Enola, PA 17025 Respectfully submitted, ,,. Laurinda J. Voel er, Esquire Attorney for Plaintiff PAID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 \.J d g..J C'? ~r c:-, .' s-"~ ~: -r `_ f~..? ~.~ ra c~ ~., ~,. ~~ ra cry ~,. v°~ O -n ~~ c7 t-? c~ ~ .{_-~, - ? r, T~ ;:-., -n. -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. JILL A KULIG , Defendant CIVII,-LAW DOCKET NO. ~7- ~~foa c'cW./ ENTRY OF APPT:ARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION LAURINDA J. JVOELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsbwg, PA 17815 (570) 387-1873 ~ -- -ca ~• F ... 1 ~ gyp. .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. JILL A KULIG, Defendant CIVIL-LAW DOCKET NO. 07-2402 CIVII. PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $19,181.36 Attorney Fees $ 2,541.98 Interest from Apr 26, 200? $ 95.91 Total: $21,819.25 Kindly assess damages against Defendant in the sum of $21,$19.25 plus continuing interest at the statutory rate of 6%. BY: _ Laurinda J. V lcker, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff . vs. :CIVIL-LAW JILL A KULIG, Defendant DOCKET NO. 07-2402 CIVIL TO: Jill A. Kulig 3 Crooked Drive Enola, PA 17025 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Awazd on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: LAURINDA J. VOELCKER, ESQUIRE AT THIS TELEPHONE NUMBER: 570-3$7-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW JILL A KULIG, : DOCKET NO. 07-2402 CIVIL Defendant CERTIFICATION OF TEN (101 DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, LAUIZINDA J. VOELCKER, ESQUIRE, hereby swear and certify that I served a copy of the Ten (10) Day Notice by regular mail to Defendant on May 21, 2007. /~ BY; Laurinda J. oeIcker, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW JILL A KULIG, :DOCKET NO. 07-2402 CIVIL Defendant NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Jill A. Kulig DATE OF NOTICE: May 21, 2007 3 Crooked Drive Enola, PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII,ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THI5 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. Pennsylvania Lawyer Referral Service _ Cumberland County Bar Association 100 South Street, PO Box 186 ~ 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800-692-7375 717-249-3166 717-238-6807 REMIT CORPORATION ! (/ Mailed to: Laurinda J. V Icker, Esquire Jill A. KuIig Remit Corporation 3 Crooked Drive PO Box 7 Enola, PA 17025 Bloomsburg, PA 17815 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. JILL A KULIG, Defendant CNIL-LAW DOCKET NO. 07-2402 CNIL AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof. t' Dated,,t~hi day of ~ Y , 2007 Laurinda J. Volcker, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 (570) 387-1873 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-23-2007 l 2:33 :03 rC Last Name First/Middle Begin Date Active Duty Status Service/Agency KULIG Jill A Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~~. ~r-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselirilc.mil/facLp/ is/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.miUscra/owa/scra.prc_Select 05/23/2007 Request for Military Status Page 2 oaf 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BVTFXRHlZQC https:llwww.dmdc.osd.miUscra/owalscra.prc_Select 05/23/2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW JILL A KULIG, :DOCKET NO. 07-2402 CIVIL Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Jill A. Kulig 3 Crooked Drive Enola, PA 17425 Respectfully submitted, Laurinda J. Voe ker, Esquire Attorney for Plaintiff PAID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 • .,$;y `~ ., ~. ..r 7~ C..,. a -- Y _ ~ ~ ~ ~7 ' ~; . ;~ ...-1 ' ~,-~i i~~~ - r" S`~~ ~i~' -: "~ h~• 9\ SHERIFF'S RETURN - REGULAR CASE N0: 2007- 2402 P COMMONWEALTH O PENNSYLVANIA: COUNTY OF CUMB RLAND REMIT CORPORATION KULIG JILL A VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland Cou ty,Pennsylvania, who being duly sworn according to law, says, the with~n COMPLAINT & NOTICE was served upon T7T TT T/'~ TTT T T the DEFENDANT at 1920:00 HOURS, on the 27th day of April 2007 at 3 CROOKED D IVE ENOLA, PA 1702 by handing to JILL A KULIG a true and att sted copy of COMPLAINT & NOTICE together with and at the sam time directing Her attention to the contents thereof. Sheriff's Cost So Answers: .~ Docketing 18.00 ~t Service 14.40 Affidavit .00 f Surcharge 10.00 R. Thomas Kline .00 5~~4~e~ ~ 42.40 04/30/2007 REMIT CORPORATION Sworn and Subs ibed to By: _ before me this day Deputy Sheriff of A.D.