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Home My WebLink About08-0336IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. TAE H. KIM, CIVIL-LAW Defendant DOCKET NO. Oe 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 Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 800-692-7375 717-238-6807 Carlisle, PA 17013 717-249-3166 LAURINDA J. OELCKER, 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 TAE H. KIM, DOCKET NO. ?- 3 3 G1? 7i- 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, Tae H. Kim, is an adult individual residing at 134 Sholly Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant obtained a Chase credit card on or about May 12, 2004, from Chase Manhattan Bank USA, National Association, (hereinafter "original creditor"), Account number 5490 9133 2900 2430. 4. Unifund CCR Partners purchased the account of Tae H. Kim 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 $9,385.22 with interest continuing to accrue at 6.00% per annum. 6. Defendant's last payment on this account was made on or about August 3, 2005. 7. To date the balance is $8,042.89 principal and $1,342.33 interest for a total of $9,385.22. 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 $9,385.22. 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 $9,385.22. 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), 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 $9,385.22 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT U 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 $9,385.22. 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 $9,385.22. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against Defendant in the amount of $9,385.22, together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERIMUNJUST 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 $9,385.22. 28. By virtue of the Plaintiff s assignment of this account, Plaintiff, Remit Corporation is entitled to $9,385.22 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 $9,385.22 together with interest, costs, attorney fees and such further and additional relief, as this Honorable Court deems just and equitable. Respectfully submitted, Laurinda 7. Voelcker, 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: KIM, TAE H # 446444 5490913329002430 for the sum of $9,385.22 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 EXHIBIT Unifund CCR Partners IQ 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 TAE H KIM, Account Number 54909 133332900243 )0, the amount of $9368.05. This account was issued under the name of CHASE MANHATTAN BANK USA NA 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. ATED this 10/07/2007 FUND CCR PARTNERS By: Kim Kenney Authorized Representative Title 10625 Techwoods Circle Cincinnati OH 45242 Address I hereby certify that on 10/07/2007, before me, the subscriber, a Notary Public for the State/County aforesaid, personally appeared the above-stated affiant, and made oath in due form of law. iiifl% m ! c:E IR N Notary Public My commission Expires Jras July 4, 2012 634 E EXHIBIT MIR ? M m? ? a• SL J. sit[ film all p S 21 § I If I .1 el Z m AQ o ?i S? N ?o m? g. -4 R 19 _? _ aga a Lf?a4? i? zs at 51 a a ya ass A air $ oil 'a I _5 Q?9 R I cr sec mmz ?y 3 ?T?, Q _ N m O L'• ? fem. ?j Q• ? ? N 9 N ? G ? i[' ? ? ? ? N •"C ? ? µ d ? O ? /n Ln' c 171 {N ??' yT f?? ?3 3 g r V Orr >c . rnrn m n m m < EXHIBIT m? ,z D 45 4 ar °i ?i g y ? Q g a 7S & ?. g s s?3 ?a a? $ g s --rill ` 1, IT gl larl I ML I a ? U u ? s Kill H ?. 11,11gli: - g 13 1 21 w Ir If rig If. fig, m I troar g go A r N lip ? ?r trig P1 a-+ or a s still 1 if I I I ? a ?s 5T cr at 3 11 HIT °? ? j -sr a' 41 m 3' ^ loll A ?? ??? •? Q s+? A ?3: fli, fit MIST Rle ??•? g gist. m RL 4; CIA fill H a ,. a 3. ?{ «, fir.-I -§- its 1011 ?mR 1 9 -? R m?q m a???•- ??s ? ? gam A. ?? cr 4 7y.? `T 4{ M s Q 3 ? FF V a sr L1 Cr ulex a Hat 111W1.1111 a Eia? a FQ .?SQ m $ a Qg i?o Ulf 4?. Er Jil a3 a g Q ?. If I SL I a J v I i" I I ?Jlffj wjjjfg?l 91.3 F1 -_q a f j 1111 1 'it laiifn 3m" ? " Q a ?N ig -a J1 - it I SL a& al f lit tits ID 17 f if 41 if a a flt , 8 g It g a, 01 7 d R 12 11 # cr 1. 941 9 Z I It s3 l O a tit- $ ;t S era ? 3? c!' ? 141111jil 1 W 'A a s P. a s3 g JI V99 Wit 3 cr if all J.11 MISS ja ?n IS. Tufam 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 unsworn falsification to authorities. II f?o? 14, Harry A. S sser, III, Rermt Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. TAE H. KIM, CIVIL,-LAW DOCKET NO. Defendant AFFIDAVIT OF NON-MII.ITARY 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. Dated thisGTday of IVeV" , 2007 Laurinda J. Voelcke squire y 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 NOV-07-2007 07:28:17 * Last Name First/Middle Begin Date Active Duty Status Service/Agency KIM TAE H 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. % 14. AWJ. * ut lot 40?01?- 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/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 11/07/2007 Request 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 ID:BDGOYNAXL UY https://www.dmde.osd.mil/scra/owa/scra.prc_Select 11/07/2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. TAE H. KIM, Defendant CIVIL,-LAW DOCKET NO. 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: Tae H. Kim 134 Sholly Drive Mechanicsburg, PA 17055 Respectfully submitted, Laurinda J. Voelc r, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 SI REMIT CORPORATION coe?? ?? ?a ?? co, ? AM 10110 A 36 West Main Street • Bloomsburg, PA 17815-1703 Cumberland County SheriTs Office RE: Remit Corporation vs. Tae H. Kim Dear SherflFs Department: Please serve the enclosed Civil Complaint upon the Defendant, Tae H. Kim, at the address of 134 Sholly Drive Mechanicsburg, PA 17055 I have enclosed the Civil Complaint and our check in the amount of $100.00 representing the service fee. If service is not effectuated, please note the reason as well as any suggestions as far as service by posting or certified mail service. If you have any questions, please contact me at 570-387-1873. Sincerely, Laurinda J. Voelcker, Esquire General Counsel LVJ/glm Enclosures 570-387-6470 • 800-326-9962 • Fax 570-387-6474 • clientservices@remitcorp.com • www.remitcorp.com CAJ a 1 _ 771 f?l ? .,l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. : CIVIL-LAW TAE H. KIM, DOCKET NO. 6$ - 3-74 Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION LAURINDA J. ELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsburg, PA 17815 (570) 387-1873 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00336 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REMIT CORPORATION VS KIM TAE H TIMOTHY REMTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VTM TaP u the DEFENDANT , at 1128:00 HOURS, on the 17th day of January , 2008 at 134 SHOLLY DRIVE MECHANICSBURG, PA 17055 KWANG KIM, DAUGHTER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.52 .00 10.00 .00 3.52 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/17/2008 REMIT CORPORATION By utt neriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. TAE H. KIM, Defendant CIVIL-LAW : DOCKET NO. 08-00336 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $9,385.22 Attorney Fees $2,010.72 Costs $ 118.02 Default judgment $ 14.00 Interest from Jan 16, 2008 $ 46.93 Total: $11,574.89 Kindly assess damages against Defendant in the sum of $11,574.89 plus continuing interest at the statutory rate of 6%. BY: ';?/" Laurinda J. Voelcker, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. TAE H. KIM, Defendant TO: Tae H. Kim 134 Sholly Drive Mechanicsburg, PA 17055 CIVIL-LAW DOCKET NO. 08-00336 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 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. TAE H. KIM, Defendant : CIVIL-LAW : DOCKET NO. 08-00336 CERTIFICATION OF TEN [10) DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, LAURINDA J. VOELCKER, ESQUIRE, hereby swear and certify that I served a copy of the Ten (10) Day Notice by regular snail to Defendant on February 7, 2008. BY: Laurinda J. V elcker, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. TAE H. KIM, CIVIL-LAW DOCKET NO. 08-00336 Defendant NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Tae H. Kim 134 Sholly Drive Mechanicsburg, PA 17055 DATE OF NOTICE: February 7, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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, 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 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 REMff CO Laurinda J. Voblcker, Esquire Remit Corporation PO Box 7 Bloomsburg, PA 17815 570-387-1873 Mailed to: Tae H. Kim 134 Sholly Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. TAE H. KIM, : CIVIL-LAW : DOCKET NO. 08-00336 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. 4r Dated 4s?Iday of ka"41 , 2008 Laurinda J. Vodckei, 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 1 FEB-20-2008 10:51:25 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency KIM Tae H 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. n1l) 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: htttp://www.defenselink.mil/fa_?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:BKOEDMYHIPZ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 02/20/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. TAE H. KIM, Defendant CIVIL-LAW DOCKET NO. 08-00336 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: Tae H. Kim 134 Sholly Drive Mechanicsburg, PA 17055 Respectfully submitted, Laurinda J. Voe ker, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 R V" \ w 4 ? 4x \ V7 t. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. TAE H. KIM Defendant CIVIL ACTION -LAW NO. 08-00336 c? ? q 1_T x rl7 0 ASSIGNMENT OF JUDGMENT_ l1` 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 T ,- - > l "Unifund"), 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 08-00336 against Defendant, TAE H. KIM, for the sum of $9,517.24 which constitutes damages and costs of suit, plus interest at 6.00% annum from 02/29/2008, 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. 4'8. CO PO AIW M, is-55l P.# A81 W3 IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporation, as executed this Assignment this Rday of F 04 , 2010. Laurinda J. Voel er General Couns Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff CIVIL ACTION -LAW VS. : NO. 08-00336 TAE H. KIM Defendant PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), TAE H. KIM, 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: --2/a3 BY: Laurinda J. Vo er, 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), TAE H. KIM, is hereby marked to and for the use of Unifund Corporation. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. CIVIL-LAW TAE H. KIM, DOCKET NO. 08-00336 Defendant vs. PENNSYLVANIA STATE EMPLOYEES CU, Garnishee _ PRAECIPE FOR WRIT OF EXECUTION W (MONEY JUDGMENT) 1:' -o To the Prothonotary: U.:. te o Issue a Writ of Execution in the above matter, r .. (1) directed to the Sheriff of Cumberland County, Pennsylvania J _ C to `-> defendant; and 13FI Sholly Dry Meeh, PA (2) against Tae H. Kim . 1'705? -- , (3) Against Pennsylvania State Employees CU, Garnishee; !C redo- Uhion Plaee Nbq PA 17110 (4) and index this Writ in the judgment index and (a) against Tae H. Kim, defendant(s), and (b) against Pennsylvania State Employees CU, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: Interest from 02/29/2008 Other Credits Costs to be added: Clerks Fee: Sheriff: $ 11,574.89 $ 1,354.45 $ 0.00 $ 0.00 Total: 3q. = CBF IN So " !4.oo " 8.00 a.50 167.0a --Pp ATTq $1.00 QveOo •5o LL cftu8(v 0 a146C* 6 LOrif 455, 3au, d $ ?? Dated this daylgf __ , 2010, La&inda J"VoelWer, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, : Plaintiff VS. CIVIL-LAW TAE H. KIM, DOCKET NO. 08-00336 Defendant vs. PENNSYLVANIA STATE EMPLOYEES CU, Garnishee Y' ' r rn J r 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, nor has been in such service within thirty days hereof. Dated this Qdi y of A14 , 2010 Laurinda J. YgAcker, PA ID# 82706 Attorney for laintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 ,bequest for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-11-2010 07:30:25 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service S Agency KIM TAE Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fag/pis/PC09SLDR.httnl. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. ,.Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:34LOL7JTPT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW TAE H. KIM, DOCKET NO. 08-00336 Defendant vs. PENNSYLVANIA STATE EMPLOYEES CU, Garnishee CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Unifund Corporation 10625 Techwoods Circle Cincinnati, OH 45242 t? v Defendant: Tae H. Kim f-b - 134 Sholly Drive C). Mechanicsburg, PA 17055 -o z"= J Garnishee Pennsylvania State Employees CU S> C I Credit Union Place 0 Harrisburg, PA 17110 Respectfully Submitted, Laurinda J.y6elcker, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax (570)387-6474 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-336 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION, Plaintiff (s) From TAE H. KIM, 134 Sholly Drive, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PENNSYLVANIA STATE EMPLOYEES CU, 1 Credit Union Place, Harrisburg, PA 17110 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,574.89 L.L.$.50 Interest from 2/29/08 -- $1,354.45 Atty's Comm % Due Prothy $2.00 Atty Paid $167.02 Other Costs Plaintiff Paid Date: 9/10/10 t . uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LAURINDA J. VOELCKER, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 82706 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. TAE H. KIM, Defendant vs. PSECU, Garnishee CIVIL - LAW DOCKET NO. 08-00336 PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: w ?f y Kindly Discontinue the Attachment of the Defendant's bank account with Pennsylvania State Employees Credit Union. SUBMITTED BY: Laurinda Voelcker, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: (570)387-187'3 Fax: (570)387-6474 Tee., '' - to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. TAE H. KIM, Defendant VS. MEMBERS 1sT FCU, Garnishee CIVIL - LAW DOCKET NO. 08-00336 PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: rnM ?? .. ter, ? ?4?. Kindly Discontinue the Attachment of the Defendant's bank account with Members 1St Attorney f4r Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: (570)387-1873 Fax: (570)387-6474 ,? I FCU. SUBMITTED BY: WRIT OF EXECL!TION and/or ATTACHMENT CO ViMONWEALTH OF PENNSYLV.IN[A) Ct~UN"1'Y OF CL"MBFRLAND) NO 08-336 Civil CIVIL ACTION L,A1,b 1'C) "[ HL tiHL:R1FF OF }~Quhh~n :;OUNTY: "C'o satisfy the debt, interest ana cons due UNIFUND CORPORATION Plaintiff (s) From TAE H. KIM, 134 SHOLLY DRIVE, MECHANICSBURG, PA 17055 (1)You are directed to levy upon the property of the defendant (s)and to sell (21 You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISI~IEE(S) as follows: PENNSYLVANIA STATE EMPL01'EES CU, 1 CREDIT UNION PLACF,, HARRISBURG, PA 1"110 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishees I is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s} or otherwise disposing thereof; (~ } [f property of the defendant(s) not levied upon an subject to attachment is found in the possession oa anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,574.89 L.L. $ Interest FROM 2/29/2008 - $3,152.81 Attr~'s Comm Att~~ Paid $415.64 Plaintiff Paid Due Prothy X2.25 Other Costs Date: OCTOBER 16, 2012 (Seai) RGQJES'rING PARTY: Name : AN~;ELA L. MATTIS, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorne~~ tor: PLAINTIFF Telephone: 570-387-1873 ~~~ ,-__ David D. Buell, Prothonotary Deputy Supreme. Court ID No. 309229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, : Plaintiff : ~ _ ~~ . ~ '> vs. r ,~A ~~ ~~~: CIVIL-LAW .;_ TAE H. KIM, 13y S~no,~y ~ ~~ps S :DOCKET N0.08-00336 _. r ., Defendant ~~~ M ~. w ~. `S. .. ~ ~.. . .... ... PENNSYLVANIA STATE EMPLOYEES CU, 1 ~~~}. (~i6V~ Garnishee '~,~4CQ, ~~ ~1P ~ it ~ ~ ~ PRAECIP'E FOR WRIT OF EXECUTION ~ (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (l) directed to the Sheriff of Dauphin County, Pennsylvania (2) against Tae H. Kim, defendant; and (3) Against Pennsylvania Pennsylvania State Employees CU, Garnishee; (4) and index this Writ in the judgment index and (a) against Tae H. Kim, defendant(s), and (b) against Pennsylvania State Employees CU, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: NiA (5) Amount Due: $ 11,574.89 Interest from 02/29/2008 $ 3,152.81 Other $ 0.00 Credits $ 0.00 Costs to be added: Clerks Fee: $ _.._\ Sheriff: $ Total: $ l~ ` ~ ~ r_'~ .~~r ~~~ ~ ~ ~~~ ~ d ~ D ~ is ~ ` day of _O l " ~~ Angela L. Mattis, PA ID #309229 d ` ~~ a ~ • ~~ ~ A-~ Attorney for Plaintiff t i u ~~ ~ 36 West Main Street ~c~ ,1 g~~~j . Bloomsburg, PA 17815 `1 ~' s Phone: (570) 387-1873 (~ ~~ ~ { ~ _ Fax: (570) 387-6474 1 "I. °' t ~ ~ , ~ ~a~a~~ ~. a`~ 5~,. ~ ~u~a ~ ~ 6" ~ K-~, .,, . a u . sv ° .. jL-E~aBa~J.o ~ ~~ i~ ~F ~k ~sS'~e~