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HomeMy WebLinkAbout08-0329IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. : CIVIL-LAW : DOCKET NO. 08 KENNETH P. BRADLEY, Defendant NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 717-238-6807 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 LAURINDA J. V ELCKER, 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 KENNETH P. BRADLEY, : DOCKET NO. O8- 3-7 9 (f u, J u µ* 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: 1. 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, Kenneth P. Bradley, is an adult individual residing at 821 Pheasant Drive N, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant obtained a Providian/Chase Mastercard credit card on or about March 12, 1999, from Chase Bank USA National Association, (hereinafter "original creditor"), Account number 5184 4500 7184 9354. 4. Unifund CCR Partners purchased the account of Kenneth P. Bradley from Chase 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 $7,861.25 with interest continuing to accrue at 6.00% per annum. 6. Defendant's last payment on this account was made on or about February 18, 2005. 7. To date the balance is $6,991.83 principal and $869.42 interest for a total of $7,861.25. 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/her account. 10. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $7,861.25. 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 $7,861.25. 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(i), copies of the written agreements are attached hereto, incorporated herein and referred to hereafter as Exhibit C and D. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against the Defendant in the amount of $7,861.25 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 contract 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 Defendant 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 he received the same to Defendant's benefit. 18. The total reasonable value of the Defendant's use of the credit extended by original creditor is $7,861.25. 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 Plaintiff's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $7,861.25. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against Defendant in the amount of $7,861.25, together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MEERIIUT/UNJUST ENRICHMENT 22. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 23. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, cash advances, balance transfers, fees and interest. 24. The credit extended by original creditor benefited Defendant. 25. The Defendant will be unjustly enriched if Defendant is allowed to retain the benefit resulting from Defendant's use of the credit card provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 26. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon Defendant's use of the credit card. 27. The reasonable value of the Defendant's use of the credit card including purchases, balances transfers, cash advances, fees and interest is $7,861.25. 28. By virtue of the Plaintiff's assignment of this account, Plaintiff, Remit Corporation is entitled to $7,861.25 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners demands judgment against the Defendant in the amount of $7,861.25 together with interest, costs, attorney fees and such further and additional relief, as this Honorable Court deems just and equitable. Respectfully submitted, JA V44 Laurinda J. Voel er, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 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: BRADLEY, KENNETH P # 446471 5184450071849354 for the sum of $7,861.25 arising from unpaid credit card services with interest accruing at 6.00% 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. 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 26th day of October, 2007. Authorized Signature: Joseph Lutz Unifund CCR Partners EXHIBIT AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. Kim Kenney, being sworn, deposes and says that she is an authorized representative of Unifund CCR Partners, servicer, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242, and that she is authorized to make the following statements and representations which are within her personal knowledge, and that she is competent to testify to the matters stated herein. To the best of her knowledge the Defendant is not now in the Military Service as defined in the Soldier's and Sailor's Civil Relief Act of 1940 and amendments thereto. There is due and payable from KENNETH P BRADLEY, Account Number 5184450071849354, the amount of $7846.30. This account was issued under the name of CHASE MANHATTAN BANK and acquired from Chase Bank USA NA. Said account has been forwarded to REMIT Corporation, as attorney for Plaintiff Unifund CCR Partners, for the purpose of the commencement of a legal suit, with full power and authority to do and perform all acts necessary for the collection, adjustment, compromise or satisfaction of said claim as permitted by law. I do solemnly declare and affirm under the penalties of perjury that the matters set forth above are true and correct to the best of my knowledge. Wwrl this 10/07/2007 FUND CCR PARTNERS By: Kim Kenney, Authorized Representative Title I hereby certify that on 10/07/2007, before me, the su State/County aforesaid, personally appeared the abov, form of law. 10625 Techwoods Circle, Cincinnati OH 45242 Address a Notary Pblic for the affiant, and ade oath in due Pu commission Expires s JENNIVER A DUNCAN 634 t?> a. S) # ?10 :s 1?U, i' 2 EXHIBIT I Fg if 0 it, 9 ? x M I 9MIN 4 PC PIT c') a a 1 131 $ z m m N .0 r? r N ?. Elf I? Ifa a $$a ? R y a ?? 56i . 1 ? Ritz Jill 9. i ? car r Jai 'T all c d oil I a -- ar #I i I 3 ?72 a? N O V, w 0 s _R g?a Q? N r ? $? ar 15 Q g i g , dQ ]7D ? K i I r rn .4 9 Red? [aiaa mD £aa'?? a ?6<4 EXHIBIT 19 0) 1 a 1.1 F{ tin ? ?a cr $ Q ?' ? ? Q a'1 ?e ?+?v o ? 01 33 ° s?9 s CT -9. a IF m IS (n ! I I s_ ?g 6L fit r fill III. fir I I m I firi A if gI I = g it cr ?? as SL $ ? a -,? Y R S cr fill Ott' ?_ . 9 ?? N? ? Q? 40 2L' lei rGL loll ffl?f, ME 'ZI a L 11 11 aM If I I -q a a a 1.111, US an s'Et s - ?. a s gg p..? g 3 .ar ? a ? g a t4 . i arf Pill- a ir 01 t 6 -§ S agQ aQ 6 'Willi H. In at 3 SL 61 ,. alr a Q Fr ?a i' Or L ? s _ SL S a$ a 'I "M 3 ?1 ,K e3 ua r, 3. 1 a, I'll 5 SL N IV, u; F 3 na -M F ? 11,71'a gild ' I`Fg lilts` QF u? 1 Mul a a? F NO fialailz a1 cr r? 9 94 q- . Z I [lip • I w ? (eaq? rF T Q?' D 333x3` 0? 11?? vo. S as j s F? a asaa -1 a 3. 3. . at' 110 cr, or . ?. a a ;a ?? ro F d a?p I.?A °` ? s $ s N 1 IV set 11 5• 1. 7 *V-PROVIDIAN Financial F01.9152-0 3058 PROViDIAN NATIONAL BANK VISA* AND MASTERCARD* ACCOUNT AGREEMENT Please review this document and keep k with your other important papers. This Account Agreement contains the terms that govem your Providfan National Bank VISA at MasterCad Account (the 'Account"). The Account allows you to make purchases by using your VISA or MasterCard credit card (the 'Card") wherever 9 is honored and to get cash advances from us or any other participating financial Istlbtiom and from Automated Teller Machines. Comenience dicks may also be provided to you as an additlaai way to use the Amount. in ilia Agreement, `you" and your mean each person for whom we have opened a credit card Account. 'ft' "our. 'ours," and W mean Providian National Bank. or its assignees, as listed on your Wing statement. The Account may be used only for MOW faft household, and charitable purposes. and not for any business or commercial purpose. Any use of this Account shall coostilift acceptance of the farms of this Agreement You and we.agmte as follows: Paymerds. You will receive a mouthy statement showing your outstanding balance. Payment an this Account is required in U.S. donors (reds must be payable at a U.S. office of the bank the deed is drawn on) for at least the payrnat due as shown an your statement by the payment dire date in accordance with payment Instructions on your monthly stafanterit The back at your monthly statement Includes the fides we blow when we post payments to your Account. Convenience cheeks and other tI e dcs we may issue to you may not be used to make payments on your Account or to make paymerts on any other account you 1121111 with us or our atrilana. The payment Clue will the: 3% of the new balance shown on your statement plus cite amount of any past due' paymentt, and may ktciude the anourt by which the new balance exceeds your credit ine. Howevat the payment due will not be kss than S15 (unilesa your new balance is iless than $15. in which case the payment due will be the ant of the new balance). If your Account is past cite Qr above ft credit One. we may require a higher minimum paymat. hF we will not y you before doing sa if your payment Is mom chart the payment due. d will be b=W as a single payment and nonce of it win be applied to future payments We may accept late or partial payments. or payments marked `pahd in hit" or narked with other restrictions. without lotting our tight to ? all amounts owing under this Agmement due. Ftnauce Lbuges. Finance charges begin to accnm an a debit wall it is included In as of your daft' balances and continue to aeaue until Hat balance is reduced by a payment or credit. Your Account has two daily balances: the Dore base which fists of padases you male with your Card and fees, other than cash adve nce transaction fees, Barged to your Account, inclrfiirp fees for g7toal services; and the Cash Advance Balance, which consists of an cash advances and rash advance transaction tees. Any payment amount we twelve that iniceeds the finance charges and fees that due win ordilarhy be applied first to the Balance whh the lowr ANWJAL PERCENTAGE RATE (APR) a nd flat Babnce is zero, and am to the remaining BakncL We reserve ft right to apply payments dffua* without further n otIoL The Purchase and Cash Advance Balioces are reduced by payments as of cite days mtaivrd, and by credits as of the date posted. Purchases am included in your Purchase Beboce as of the date made Fees am included in your Purchase Bionic as of the transaction date. Cash advances are Included in your Cash Advance Balance as hdows: cash advances from other financial institutions and through Automated Teller Machines as of the date merle; fends electranically transmitted. as of the date trdwritted; rash advance cheats made payable to you that are idd>tillail as cashier's tcecks, which we may man to you at your request, as of seven flays alter the date we print on the dedc an triter cheds. Including ow convenhou clecla, as of the daft pnw tad to us. Cash advance transaction tees are included in its Cash Advance Balance as of the transaction date. Other debits are I dueled M your Purchase or Cash Advance Balance as of the date posed. Flrante charpp am added to your Purchase and Cash Advance Baluhas well day and are then posted on the last day of the brig cycle. There is no period within which credit wended may be repaid without Mcurrkig a thole a Charge. To fgum the daily Sam charge for purchases and the daily finance Charge tar Cash advances. we start with your previous cry's Purchase Bakena and Cash Advance Sal>uce, add all debits and subtract d txedbs for the current day to the applicable Baiauce (as explained in the pamomph above). and multiply the net amort by the appjlcable cony Wb* ate (sex tonowirg paragraphs). The flrance dares for purchases is that added to and included in that day's Pumciase Balance, and the AM= darge for rash ahraoas is than added to and included la Hat days Cash Advance Balance, We treat a = 0 balance for any day as zero We determume Me WW cinema charges tm your Balances for the bMny cycle by adding mgww tie finance charge for purchases for eadt nay witftn the biting cycle and the thane dwW for cash advances for each day within the Mint qde. In calculating finance Charge, an adjuatrnent will be made for any transaction or payment that would have affected Me thane charge calculation In a prior biting cycle had it been posted in that cycle. The applicable daily periodic rate for such a transaction will be the race in effect for de current billltg cycle rather than the rate in died on the date of the transaction. . The term 'Prime Rats' as used in this Agreement means the prime rate published hi Me WW Street ?lou=f on the first business day decrease in the APR win take affect on the OM day of your ttndkg cycle and may result in sight Increase decrease h me amount t at the previous Calendar moitn Arty irKxease or yeti rhirimwm payment The ANNUAL PERCENTAGE RATE for purchases will vary and may be a4isted each bWM cycle up in %99% above Prime Rate. Using this formula, the APR for purchases in the Apra 2000 bNng cycle ' to a daily periodic rate of 0.0548%. and your APR for purchases wig not go below 19.99%. The ANNUAL PERCENTAGE RATE for ash advances will vary and maybe adpsted each biGhg cycle up to 1239% above Prime Rats. Using this formnufa, the APR for cash advances in the April 2000 tilling cycle is 21.99%, corresponding to a daily period!: rate of 0.0802%. and your APR far cash afvanc is will not go below 21.99%. To determine the average duly balance show an your smarten for purchases, add each nay's Purchase Balance (inckift daily Aran e charge) in the beNM cycle and divide by the number of days kh ft bitlg cyde. To determine the average daily balance shown on your sWerent for ash advances, add each day's Cash Advance Balance Crxdudkg daily fkance charge) in the bMM cycla and divide by the number of days in the baling cycle. You can nor" each of these average daily balances by the number of days to the billing cycle and by the applicable daily periodic rate to obtain subtotals. and then add the two subtotafs together to determine the total amto in of fiance charges on your belarices for the biting cycle. It a cash advance transaction fee. credit ins Increase fee, or Express Card pmcesskg fee is charged (sue Teas section). those amounts are also F14WCE CHARGES. Fees. A membership tea of 57.95 wig be-charged to your Account each month if you request and we tiara an Additional Card on your Account for an audadad aw. a fee of S20 for each additional Card will be charged to your Account. Tfds fee wig be charged to your Accost when the addltarl Card is issued and every 12 mitts thereafter for as kill as each addidoai Card is outstanding. H you request and uss our &prnes Card Service, a are-time nee of 519.95, which Is it FINANCE CHARGE, will be derged to yox Account. In some cases, errnress processing may not be available. We may carge your Account $29 for each Card you ask us ip reppCe; tact returned pWneok each Mack you write an your Account that we return unpaid; each stop payment order or renewal of such an order, each bfplg cycle within which your Account is delUgnat (free charge): and each NO" Cycle wh* which your babrrce exceeds your Credit We evert 0 your Account is dosed. If you request copies of billing staemdds that were fist set to you more than two monUS earlier, we may charge a bolt fee of $2 for each such copy. A Cash advance fie of 3% (minimum W. which is a FINANCE CHARGE, may be charged for seen cash advance transaction merle on your Account. For some credit fine increases you may be charged a In. which is a FINANCE CHARGE, Me amount of which wig be disclosed to you before you accept the Ile Increase offer. It you request that we make a one-time automatic payment from your personal checking account, we may Charge your Account a fee of 54.95 for each request. This fee is a FINANCE CHARGE, and i wig apply whetter or not fords are available in your personal thedcimq atxaurt to make the payment. Default. You will be in decant it any information you provided us proves to be incomplete or untrue; it you do rim campy with any part of this Agreemeri upon your death. baikrupay, or Insolvency: N you do not pay other debts when due: N a bankruptcy petition is flied by or against you; or N we believe in good faith that you may trot pay or perform your obligations ender this Agreemem. If you are in defxlt, we may, without further demand or notice, canal your credit privileges. declare your Account balance owned" due and payable, and use am remedy we may have. In the event of your deauht, the outelarift balance on your Account will continue to accrue interest at the APR(s) disclosed In the Finatea Charges section of this Agreernert, even it we have filed suit to Collect the amount you mre. Credit Line. Your credit line and can advance fine are disclosed when you open your Account and on your statement each month. Your rash advance line is limited to a portion of your credit line. We may Increase or decrease your credit fine andror your resit advance line based an Itormation we obtained from you or your credit mewas. Your available credit for purchases is normally the difference between your credit line and your Account balance (including transactions made or aumorvdl but not yet posted). Your available credit for a cash amiance is normally the diftemin between year cash advance line and your Cash Adva to Balance or the difference between your credit IIa and your Account balance, whienever is less. It you send us a large payment, we may fima your available credt whin we confirm that ire check will dear. For certain transactions, available credit may be less. You WIN not use your Account luot and we may refuse to horror, any transaction that would cause you to exceed your available credit or your available credit for rash advances. Your credit rule may be reduced it you attempt to go over your cash advance credit line. Promise to Pay. You promise to pay us when due all amounts borrowed when you or someone else uses your Account (evert 0 the amount charged exceeds your permission), all other transactors and charges to your Account, and all collection costs we incur including, but not limited to, reasonable attorney's fees and court frosts. (It you win the suit. we rill pay your reasonable attorney's fees and court costs.) Changes. After we provide you any notice required by law, we may change any part of this Agreemerit and add or remove arty terms, conditions, or requirements. It a change is made to the Finance purges section of this Agreement the now finance charge caculation will apply to your entire Account balance from me etteCtM data of the change. Changes wit apply to balances that include items posted to your Account befgmm the mate at the changg. and wlh apply whaler or not you Continue to use the Account Foreign ExchageXurrency Conversion. if you use your Cad for transactions in a currency other than U.S. dollm the transactions will be converted to U.S. dollars, generally using either a (C) government-mandated rate or (N) wholesaler market rate in effect the day before the transaction is processed, increased by 3%. If a credit is subsequently given for a tramadien. it will be decreased by the same percentage. The currency conversion rate used an the carrmrsion date may differ from the rate in effect on the date you used converted amount in U.S. dollars. EXHIBIT The Card; Cancellation. You may cancel your credit privileges at arty time by notihling us in wriffng and destroying the Card(s). Upon the Card expiration at it, we reserve the right no to renew the Card. We may cancel the Card and your credit privileges at any Hme after 30 Nays nonce to you. or wthout notice d cancelled or not renewed, finance charges and other lees will cominue to be assessed. payments will continue to be due, and all other applicable provisions effect. It you terminate your Credit privileges, or if we cancel or do not renew the Care, you may no longer write checks an your Account, and you should may have issued to you. Personal inlorrmatioq Docwanfs. You wall provide us at least 10 days notice N you change your munt home or mating address 07 wrnoeis, ernployrrhent, or income. Upon err request, you will provide us add l oral financial Information. We reserve the right to cbfafn Ydarrmio n from others, including crdbt reporting agencies, and to provide your address and inlommor about your Akxxsrt to Olhe h do not hunt your obligations Under this Agreement a negative uedn report that h may reflect on Ifyou your credit maybe subrneDed to credit raportkg agencies, MRMOW Customer Service; Unandwriasd Use. Lou. or Thep of tech a the Card. Each Card must be signed an receipt. You are responsible for safeguarding the Cab. Your Personal Identification Number (Pull), which provides access to Automated Feller Machines, and any docks issued to you from then, no for keeping Your PIN separate from Your Cud, t' you df6QQ w or suspect that the Card, PIN, or any unused checks are lost or stolen, a that 6" may be an trnaiNhOM t rancho an your Account, you va promptly WW us by calling 1-11111-211.5818. So we can Immediately act to AM loess and bbft You will phone us SM though you May also DOW rs In wreig. Your iabiity for onaunbrimd Use Occurn tq before you nottty to is flndted to no. if you spat Or we suspect waufitorfad use of your Account we may suspend your age p WWM vefi we mom this problem to our slftbcbw Or is may be You a monitored new Carhprad d. or If your recorded. Card Is lost or stolen, you WE calls rra promptly destroy all docks that may be m your pits IMOA- TO improve customer service and security, You agree that your Merchant Aelanons. We will not be labia a any perm or Automated Tarter Machine refuses to hats the Card rasporaib or accept your edllCl¢, or pis to rearm the Card to you. WW have no y for goads and service Purchased with the Card checla anpi as required by law. (Sae SPWW Role below) Certain beneMs that are available web the Aaouat are provided by third-party vendors. We are not responsible fortfte quality, availability. or results of any of to services you choose to rise. Stag Payment OWSM. If You wish 10 stop pWMW On a clack you may send us a stop payment order by writing to os at our address for Customer Service limed on your staromem. You can make a 51013 payment order aaiy by aft the number listed on your statement When YOU maker a stop payment order. You mum provide your Account number and speoft irrfo mdm about the check: the used amomt, the due on the crock, the name of the party to whom it was payable, the name d the persoe who signed k and to ladle number You will he seised to hronitrn an oral stop paymet order In hrrMrhg We may disremrd vrxr aal order H wr der mar reeeIww a +a -10- .--M6.... - W" - DOW. or i ve have not rarefied an adequate dest7ip m of the seat so dot PRIATont am be stopped. The cedar will not be effective M the dark was paid by us before "e had a reaso abie opporturtfly Iv ail on the order. VA may, wnhoUi Be^ dWegard a wrttlen stop payrret order six m a 11 after mcW unless 11 is renewed m wrW4 SbP td of Care. Baavae 06 AtxoWt Involves a MO turd and nay invoin ch edk tnermcdow to are Processed throihpA separate ratioael system before the traraaciora are cad by us, and beemse n>t every dock and Card slip will be sent to us, ttansactions in your Accout wit be processed =dwic* WWM Our ngcosserily reviewing every Ibrr, Our processing system wM all our attention to curtain ftdrta, which bee will amine We will a mft ail transactions wton you report Oat yokrr Card of any r9meris have base lost or st0lef se a du not intend Ordnariy to edmdhha an pent, and in will not be negligent N we do not der so. This rule estabiisbea ft standard of ordlimy are pat we in good UM wit env YOW Account- Beemse of our khdted review. and I)Muse neither your Milled checks nor Card transaction slips will be rekrned to you vdm the nonibly statement you should be camM to enter all clock s In your obec k register or otherwise Beep a record pf Dom, You show also an your credit and cash advancer and purchase ships. Y9y your record and IV Waterer at Co talk Rilw we may delay a 111610 eMonament at any IN00ision of this Agreement without losing our right to eMoce it or any other provision later. You waive: the right to present merit demand, protest Or notice of dishonor; any applicable sphda of &rtftations; and any right you may have m requee as m proceed against anyone before we the Soft agam st you. AppllabN Law. S- 021:111W. Agent. No matter where you i0, ft Agreement and your Account are governed by federal law and by New NinhpdWe haw. This Agreement is a flirt nRrress , of the agreement between you and us and may not be caktredMed by evidence of any alleged oral agramet. It any provision of tips Agreem«K is held to be ImnRd or Une"fOlma In goodtfoih that that provision modified to CO"1mm o applicable law. and the rest of the provisions in the Agra nvt will $9 be enlorcubie. At any time afterwe .;: my proposed or enacted le9isle0on, MMdwy adios, a JW*W decision has rendered or may render any nw rial provlsiora of to A uneaforraebie, or impose arty inaeased tot; mpadng molmmen, or otter herdeh In connection with any such provision or is rrdoit nu ul,.wgAMl, alter at least 30 days lie to y or ou. a or "flhho0t 1101108 N permitted by taw, cancel the Card 4W your credit privies. We may haualer or assign our right to all of some of Your paynotts. if state law M iras the you receiv e notice of such an event to protect the purchaser or assignee, we may give You such notice by fling a flmncimg statement with the shoes Secretary of Staas. NWk@L Other notices to you shay be Mkcdw when deposited It iN mat addressed to you at the address shown in our rr1 co He, unless a IOW node period is sped led in this n : Agmmt or by taw, wt" period shat shit upon mails(: Notlae to u s shat be mailed to our address for Crammer Service on your stahemet (or other addresses we Mity Spe61y) and shall be aflective when we receive It YOUR BILLING RIG=-KEEP THM NOTICE FOR FUTURE USE. This notice contains Important IdanatiOn about you rights and err respas a under ft Fair Credit Biing Act. XoMY01 r rte Case #1 firms ar M es onsAbow roar rte n you.think your bill k wrong, or N you need morn: inorrnatal abet any tanactipm on your burl, write us, our A Separate 9ML at our address listed in the gft Rights Summary on your bill. Wile to us as soon as possible We most bear from you no law #in E0 days after we sent you the fist bill on, which the error or piobNm appeared. You an telephone ns. but doing so will not preserve your rights, in your *W give as the tkwkW Your namhe and Account number - The dollar anphmt of the suspecled error -A descrom of the error and an ' -iU partible, of wiry you bevew tires is an error. N you need mere ihfornatlorh, describe fhe Item you are not sure about Yoarr Nift aenf ON &W=WM= Ar1a N4 Aeceft ?fear Mgfty Mod". We must acknowledge your letter wRW 30 drys, unb a we have corrected the error by then. mfr 90 days, we must• eitior coned the era or aPWn why we bellew the bill was cwsM Aver we mcd ve your WW we carmrol tryto c0iecf: any amgdnt yhw question, a report youas delinquent VA an coidll0e to bill you for the amount you guesdom iruludhkg fxmrx charges, and we can apply any unpaid anvil against 'your credt line, You do not have to questioned amourd "bile we are iav 811901 ig, tut you are mil vbigeled to pay the pets of your bM that we not a oudion, pay any If we fled 110 we made a nhistalo OR Yor bit, yor•wii not have to pay any finance charge, related to any questioned amount t we didn't make a mistake, you may have to pay Tsang charges, and YOU Will have to crake cep the missed payments an the otesdxW amount In Sher case, we will send YOU a statement of the waft you owe and the data that It is due. 9 You nil to PRY ft amount we think You owe, we may report you, as delinquent However, t our "laratlon does not aadsty you and you wile to us will! 10 days telling vs that you still refuse to pay, we rust tai anyone we report you to no you ouft your bit Md, we rmwat tell YOU to name of throne we reported you tit. We must tell anyone we report you to frhat on matter has been settled between us whm it finally is. if we don't fohow these ndes, we ant collect the last S5D Of the questkxhed amount evert It your bill was correct Spesfil Rr/e for ardlt Cad Pnrcham. it you have a problem with the quality at the property or services the you purchased with or credit card and you have fried o good faith to correct the problem with the merchant. You may not have to pay the remaining arrant due an it* prtperry or services. There are two limbo= on this right (a) you must have made the purchase fn Your hone stale. or a nor within your home state. within 100 miss at your current ma ft address: and (b) the purchase price must have been more than SM. These tin.itadehs do not apply If we own or operate the merclhart, or Itwe mailed you the advertisement or the property or ser*ft -: REWARDS PROMMi -Tie kUwi tag Temus and CedMons, along w O Me Redaraptlort Rules dkdosed fn ffb Rewrds Sradere(' '). Peopom (?Prgpam") graph b the Rawr?rde Eligibility. Peddpetfou In the Program is restricted to individuals who maintain a Ptavidtan VISA or MularCard credit card account (-Accounr) in good standing. We .eserw the right to approve. deny, or revoke membership or not allow redemption of Rewards, as defined below, to any individual for any any reason whatsoever. Earnfal of Pouts. During the lest 12 months your Accost Is open, you will am 2 points ("Points") for each S1 of Not Purc hases,Therealter, at the and of each mommy billing cycle, w You wi earn 1 Point for each $1 of Net purchases. "Net Purchases' means purchases of goods or services made by you or any authorised user of the Account mews any returns or refunds, and mocluding balance transfers, cash advances, traveler's checks, and access checks. Points do not accrue for interest charges or fees of any ldmL such as late payment tees, annual teas. ovWn* fees. and um tfwrtmd charges Changes made to the above list are at our sole discretion. Point accnal will begin upon your Enrollment oats in due Program. No retroactive Points will be awarded. The Enrollment Date means the date we approve you as a Program merrdw. Points may only be earned If your Account is open and is not gam due or above the ?t go. When your Account is current and is within its credit km, you will begin to earn Points again. There is no tens m the number of Poem that an be caned. Points do not have a ash value, cannot be purchased or exchanged for cash. and annot under any cErconstance be redeemed for cash or used as a payment for Your Account or other obligations to us. Statemet of Points. Program Poll is are updated why at the time of yor Account billing sfatemerrt Points earned during the moral[ will be posted at your billing statement dam and are not available for redemption until at least two business days after your billing statement date. Expiration of Pooh. Points Will expire We years after being ahharda Points redeemed ad expired wig be based on a first-eamed, first-spent basis Re118fulf"oo It Potts. Pouts may be redeemed or products or services (Rewards'), witch are set forth in a Brochure mailed to You from time to floe. Points may Only be redeemed if your Account lee open and IS not past due or above the credit khe All Rewards are subject to availability. We reserve the right to modify or canal any Reward at any time. Who points are redeemed or a Reward, the nember of Points required for the Reward will be subtracted from your point bapnte. You Will COnaCt the parties Iltte d in the Brochure for instructions on how to redeem your Points Tax Liabppy and Fees. You will be responsible lot any federal, sate, or local taxes due arising out of the accrual of Points or redemption of the Rewards. You will also be responsible for any fees or Other charges due in connection with the redemption of arty Reward. Changes to the Program. The Program and the benefits are offered at our sole discretion. We reserve the right to alter or change any Program feature or benefit prospectively or retroactivsy, Including, without imitation. Point accrual or redemption criteria, and to cancel or temporarily suspend the program at any time without notice. In the even you commit arty fraud or abuse your privileges relating to the accrual of Points or redemption of Rewards, we reserve time rght to cancel any accrued Points as well as cancel your Account and participation in the Program. If we cancel the Program, we will normally provide at least 30 days written notice to you at the address provided to us. However, If you violate any provision of these Terms and Conditions, you are in default under your Account, or your Account is closed, we may cancel the Program without providing you 30 days wonen notice and you wilt forfeit any unused Points. You may cancel your participation at any time. The Program is void where prohibited by federal. state, or local law. Rewards. Maritz Inc. and SRI provide administrative services for redemption of the Rewards. Man-- Inc. and Bill are hwependent contractors and are not af0liaded with us_ Neinv.. w* 6A-i+, Ir. ".,. sot ..ti..n s.., r...u? .-- `-?.•- `-- --"-- ---- - -- - - - i :5 X ri f, r r c fir :i? 1,5 J C_ n ri .- 1 i T r; n T 7 7 f v, rw v, J W C. Q, 57 :L 7:7 r; 5 - P = ra - Y .70 - - rr . 1 F ? n " V c (^7 r !rte : _ w ?Lt ? = a w 2 fl T ,T n 'Z G r u > e ) ^ rAc r. W y r - .v cy N ?. O _? TJ • ra. ? I - R• T. 1' ^ .•JRi r- r-, i r - r ?f r, j _ rx C i - rri j TJ .. i r= .rte- '_ - _ •i' n - 'f,- Ids +r„? -. 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"'I J C ._'?w [ I ? i r: rs n r N ..._ Jt L. n n n' 2 ^ r'• - • ^ ? `n . ` N =. r a•. ? J r: rn ' . It n ? = . n G ^ ?'.. ?g .NS ^ .C. = - ' - ta '' ['' `.J rr,- A) = - • G Y a^J C 9 °,- 3 . + n 0 r (y ry JC n ry - n , ?•?r C :;2 CD O (na C r .r• ti y c: N n C v. -z J Ci m Roc R n? y a G `` ^- "_ 7 g is ?:- .=* R D _.,? u, a, ~- =F p - _ m _i- m' G M m 0 .-. .. i av T{tn :r+l .+ R n •? •< rte. .r R. :P n T y - _i • r C T p T 2 r J ? n •j `. ._ ti p O .. R v. ? TA :A • .? ? n .? ? 5 GI fi rnQ - _ R 1 ? O :n <il ? m \ 3- T ? n C; N 7 J o i ?JO (C ?- 7 , C) 0 ?: r. S l T G 0 ? ,? r ? h? J 7 C: lJl r G ('1 G\ " ? O f.. = O R n C ^ _O J J t c a . VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unworn falsification to authorities. Harry A. ausser, ., R t Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff Vs. : CIVIL-LAW KENNETH P. BRADLEY, 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. , 2007 Dated this 17day of 0a0JP\-` Laurinda J. Vodcker, 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 AddOlk? Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 NOV-30-2007 10:08:05 < Last Name First/Middle Begin Date Active Duty Status Service/Agency BRADLEY Kenneth P 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. §§ 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: htt //www.defenselink.mil/faQ/pisW09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: PMSYMTWGHW https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/30/2007 a I . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. KENNETH P. BRADLEY, Defendant CIVIL-LAW DOCKET NO. CERTIFICATION OF ADDRESSES Respectfully submitted, G 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: Kenneth P. Bradley 821 Pheasant Drive N Carlisle, PA 17013 L"aurinda J. Vo?er, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 W fN-' W C- 7 7 j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. CIVIL-LAW 0, Lu'%,C_? I KENNETH P. BRADLEY, DOCKET NO. d$ ,,3,2cl Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION 00" j 411,40 LAURINDA J. OELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsburg, PA 17815 (570) 387-1873 rya G? C 77 J {in A "I ry ? k: SHERIFF'S RETURN - REGULAR CASE NO: 2008-00329 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REMIT CORPORATION VS BRADLEY KENNETH P STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RRAT)T RY KRNNRTH P the DEFENDANT , at 1745:00 HOURS, on the 15th day of February-, 2008 at 821 PHEASANT DRIVE N CARLISLE, PA 17013 by handing to KENNETH BRADLEY 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 19.20 Affidavit .00 Surcharge 10.00 .00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/19/2008 REMIT CORPORATION By: Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. KENNETH P. BRADLEY, Defendant CIVIL-LAW DOCKET NO. 08-00329 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt Attorney Fees Costs Interest from Jan 16, 2008 Total: $7,861.25 $1~,x:96- 6J<- $ 123-7-8 $ 78.61 $9443-52 y. G S 9.8x r &x.- n1 a'G? 0-." 16? q(oF7.F.L Kindly assess damages against Defendant in the sum of $9;444-52.plus continuing interest at the statutory rate of 6%. BY: Laurinda J. Voelcker, Esquire Attorney for Plaintiff 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. KENNETH P. BRADLEY, Defendant CIVIL-LAW DOCKET NO. 08-00329 TO: Kenneth P. Bradley 821 Pheasant Drive N. Carlisle, PA 17013 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Award 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: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. KENNETH P. BRADLEY, Defendant : CIVIL-LAW : DOCKET NO. 08-00329 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Kenneth P. Bradley DATE OF NOTICE: March 12, 2008 821 Pheasant Drive N. Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE INWRITING 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, 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. 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 REMEF CO ? ? Mailed to: aurinda J. V lcker, Esquire Kenneth P. Bradley Remit Corporation 821 Pheasant Drive N. PO Box 7 Carlisle, PA 17013 Bloomsburg, PA 17815 570-387-1873 dk IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. : CIVIL-LAW KENNETH P. BRADLEY, DOCKET NO. 08-00329 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. 7lq- Dated this day of 1 " l a11( '2008 Laurinda J. Voelckei, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAR-26-2008 12:42:04 ,G Last Name First/Middle Begin Date Active Duty Status Service/Agency BRADLEY Kenneth P 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. IV), 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. §§ 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.defenselink.mil/faq/is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BMXUKSLFEVP https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 03/26/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. : CIVIL-LAW KENNETH P. BRADLEY, DOCKET NO. 08-00329 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: Kenneth P. Bradley 821 Pheasant Drive N. Carlisle, PA 17013 Respectfully submitted, Laurinda J. Voel er, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 f Cep - ( G W 1 v ? ?l _i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION n e n Plaintiff J CIVIL ACTION -LAW r' VS. - rc NO. 08-00329 i' 0 KENNETH P. BRADLEY Defendant c? `. i ASSIGNMENT OF JUDGMENT CD KNOW ALL MEN BY THESE PRESENTS, that Remit Corporation in consideration of the prior contractual agreement between the parties, the receipt and sufficiency of which is acknowledged, does hereby grant, bargain, transfer, assign and make over to Unifund Corporation of 10625 Techwoods Cr, Cincinnati, Hamilton County, Ohio, 45242 (hereinafter "Unif ind"), its successors and assigns, a certain Judgment recovered by Remit Corporation of 36 West Main St, Bloomsburg, Columbia County, Pennsylvania 17815, in the Cumberland Court of Common Pleas, Cumberland County, Pennsylvania, filed to docket number 08-00329 against Defendant, KENNETH P. BRADLEY, for the sum of $8,000.95 which constitutes damages and costs of suit, plus interest at 6.00% annum from 04/03/2008, together with all the benefits and advantages that may be obtained thereby, and full power to enforce and recover the Judgment to Unifund's own use. Remit Corporation, further authorizes and Empowers the Prothonotary or any attorney on behalf of the Assignee to mark said Judgment to the Assignee's use. *8.00 PD AYH ext 1.1&q3 P_ a391o8T IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporation„ has executed this Assignment this day of , 2010. Laurinda J. V cker General Counsel Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. KENNETH P. BRADLEY Defendant : CIVIL ACTION -LAW : NO. 08-00329 PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), KENNETH P. BRADLEY, to and for the use of Unifund Corporation, Assignee, as per Assignment of Judgment, a copy of which is attached hereto and made a part hereof as Exhibit A. DATED: " BY: """> Laurinda J. Voelcker, Remit Corporation JUDGMENT MARKED TO USE OF ASSIGNEE AND NOW, to wit, this day of , the Judgment entered in the above captioned case against the Defendant (s), KENNETH P. BRADLEY, is hereby marked to and for the use of Unifund Corporation. Prothonotary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy °-' i Richard W Stewart Solicitor'" I'D 4 r Unifund Corporation Case Number vs. Kenneth Bradley 2008-329 SHERIFF'S RETURN OF SERVICE 03/11/2011 02:32 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 11, 2011 at 1432 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kenneth Bradley, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Branch Operations Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 17, 2011 to Kenneth Bradley at 821 Pheasant Drive N, Carlisle, PA 17013. SO ANSWERS, March 16, 2011 RANII)ERSON, SHERIFF ShAwn Rselfison, Deputy p?. Coon" ySutte Shentt, ielea5ofi. Inc. r ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. CIVIL-LAW KENNETH P. BRADLEY, DOCKET NO. 08-00329 Defendant VS. : SOVEREIGN BANK, Garnishee 4 aw rs f v INTERROGATORIES TO GARNISHEE TO: Sovereign Bank 269 Penrose Place Cl) C rn? zrn rz 0 =o Z N co -v N ?n c? Carlisle, PA 17013 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? NO 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? rni= rorn MC3 0 --4 to o z eC-) rn Tom' YES 1 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NO 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? NO 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? NO 7. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. NO 8. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. NO 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as may be relevant to this attachment. SEE ATTACHED Camille Neuvinger Name (print) Interrogatories submitted to garnishee by: Laurinda J. Voelck , PA ID # 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 C.O.P. Lead Specialist Title \4 (AV ?\ c^n (4'.4 ?) -ry-) _-, b- 'dVld ANSWERS TO INTERROGATORIES Account # 1691026182 Balance: $7,246.74 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $6,946.74 Account Holder: Kenneth P Bradley 821 Pheasant Dr N Carlisle, PA 17013-1226 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: ff Camille Neuwinger C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Unifund Corporation VS. Kenneth P Bradley CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Laurinda J Voelcker, Esquire 36 West Main St Bloomsburg, PA 17815 Service by certified mail addressed as follows: Kenneth P Bradley 821 Pheasant Dr N Carlisle, PA 17013-1226 Camille NedWi>ger C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 March 22, 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. KENNETH P. BRADLEY, VS. SOVEREIGN BANK, Defendant Garnishee CIVIL - LAW 2 r? -D M- M M DOCKET NO. 08-00329 `<> =° C -? -,-, `: 1 D v 1_ CD >C r C) r1a PRAECIPE SATISFY JUDGMENT AGAINST GARNISHEE AND TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly Satisfy the Judgment against the Garnishee and Discontinue the Attachment of the Defendant's bank account with Sovereign Bank. I ell's tie M,? jr14 4?-4 , PA ID# 82706 Attorney fop'Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: (570)387-1873 Fax: (570)387-6474 SUBMITTED BY: