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HomeMy WebLinkAbout08-0338IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. LINDA A. FALLA, Defendant TO THE DEFENDANT: : CIVIL-LAW DOCKET NO. l NOTICE TO 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 ?WA4 14 4 LLAMNI) A J. V0 CKER, ESQ RE 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 LINDA A. FALLA, DOCKET NO. 0 F - 31 p &L,4 -re,- 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, Linda A. Falla, is an adult individual residing at 601 State Street Apt 1, Enola, Cumberland County, Pennsylvania 17025. 3. Defendant obtained a Citibank credit card on or about September 3, 2003, from Citibank (South Dakota) National Association, (hereinafter "original creditor"), Account number 5424 1808 2292 3931. 4. Unifund CCR Partners purchased the account of Linda A. Falla from Capital Financial Credit, LLC. 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 $2,215.17 with interest continuing to accrue at 6.00% per annum. 6. Defendant's last payment on this account was made on or about June 8, 2004. 7. To date the balance is $1,887.55 principal and $327.62 interest for a total of $2,215.17. 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 $2,215.17. 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 $2,215.17. 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 $2,215.17 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IWLIED 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 $2,215.17. 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 $2,215.17. 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: FALLA, LINDA A # 435901 5424180822923931 for the sum of $2,215.17 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. Autho ' gnature: Jos z 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 LINDA AFALLA, Account Number 5424180822923931, the amount of $2215.17. This account was issued under the name of CITIBANK and acquired from Capital Financial Credit LLC. 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. DATED this 08/27/2007 By: Kim 10625 Techwoods Circle, Cincinnati, OH 45242 Address I hereby certify that on 08/27/2007, before me, the subscriber, a Notary Public for the State/County aforesaid, personally appeared the above-stated afflant, and made oath in due form of law. Notary Public My commission Expires 634 EXHIBIT 8HARATI i.ENGADE t"10 ARY PUBLIC S'A TE 1i F O H l O C-L)m. Expires k'IQY 14, 2012 -f ! -J''r.r 'alt CIT IBANK CARD AGREEMENT This Agreement and the folder containing the card are your Citibank Card Agreement. The folder contains importa t account information. including the annual percentage rate and the amount of any membership fee. Please read and keep the folder and this Agreement for your records. To simplify the rest of this Agreement for you, the folioving definitions will apply. The words you. your. and yours mean the person responsible for this Agreement, to whom we direct the billing statement. The word card means one or more cards which we have issued with your account number. The words we, us, and ourmean Citibank (South Dakota), INLA. The words Citibank checks mean one or more checks that ,/e may provide to access your Citibank card account. This Agreement is binding on you unless you cancel your account within 30 days after recsi4g the card and you have not used or authorized use of your account. Using Your Account and Your Credit Line: The card must be signed to be used. Your initial credit line appears on the folder containing the card. A portion of your credit line, called the cash advance limit, is available for cash advances. At our discretion and at any time, we may change your credit line or cash advance limit. We will notify you if we do, either by mail or through a billing statement sent either before or after the change takes effect. You may request a change to your credit line or cash advance limit by contacting Customer Service by telephone or mail. The full amount of your credit line is available to btiv or lease goods or services wherever the card is honored. Your cash advance limit is available for cash through any bank or automated teller machir:e that accepts the card or by using Citibank checks. The total amount charged on your account, including purchases, balance transfers, cash advances, finance charges, fees, or other charges, must always remain below your credit line. However, if that total amount exceeds your credit line you must still pay us. Additional Cards: You may request additional cards on your account for yourself or others and you may permit another person to have access to the card or account number. However, if you do, you must pay us for all charges made by those persons, including charges for which you may not have intended to be responsible. You musi notify us to revoke permission for any person you previously authorized to use your account. If you tell us to revoke another persor's use of your account, we may close the account and issue anew card or cards luith a different account number:. You are responsible for the use of each card issued on your account according to the terms of this Agreement. .,. Membership Fee: The folder containing the card indicates whether your account is subject io a membership fee. if It is, the fee is added to the purchase balance and is non- refundable unless you notify us to cancel your account within 30 days from the mailing date of the billingg statement on which the fee is billed. EXHIBIT r E :i S r 1 y. P. . r- ?Ll O =),p U J N 0 -, - C N> y y r O O E N Y N Q? r _ C.- X WZ5 N n`? c? y r R 7:1 w C-) ?h a y N a .= Q ._ C R y U p cn N v .ra m U W O C _- asc•am?7 -off=rs c: C v :J c.v _ .: aJ'. a y O ^J CJ C U O r - '- O J C T T7 ,O C1 V C . L PS alC 43 J C R U N t7 N rc 3 - r ^ > C CC. a? _R = .= c o ari = ^ C7 = Q O C r C= O N G Q xd O y V? E NC SRS an d O_?.C C-3 C-3 iE O V G Y w U V C7 y .- _ N - C OS 7 O C) _ cm i... 45: - 23 J C-3-? Q. tO.) C ? O U LL. m TL cy, cCi C C N p 0 ?' T^ R ?^ _ y N - NAY Cs za 52 r y O C V V` ;i - .J _ = 6 O ? O_ c: Cs O V a: ? C 3 G ?;C O m r E a Q m m C C = U _ es ? ^ •? r U y y J C5 ' O E aJ G Q a) r .. c cz •c c.? 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U CJ O r L _? r - ^ .- " v?+ - - = U ^ _ J C _ R .7 _ _ 7 p J C J _ C _ O -_ -5.2 U _U r / I- p O -_ T J ^ ; N H J J _ U- .- _ ^ ST, 52 V ^ - = 3: 7S v > rz C^ ? ? .. r _ 7F; - U V c) - _ _ 1. .J - = _ '- _ U *U cS O O ( ,? - c v) c') ?. - - C LZ ^ v CJ 'J.: - - - ... - :J US •- - - C L _ _ _ - _ -? j, = - w`, V Jy V]:JCi- G-. JU CJ V ? - 4/ _ l--? -- - v. -- - .- _O n_. - J^ .-^r - O = - V: W - J -_ .- r r C:.' • C.i . - - f. O cr. - ; 3: ti5 r - -7E > IS Q- 5P CV- • 77, _ J .. L= O J / .J U l _ U co -5 ?12 cr. Citibank Checks: Citibank ;hm k.s may be used to purChas2 goods and ser/i.RS Cr '..:btalr Cast uD to the amourt of your available cash MUM Ilmii uniess that amount vAll cause the balance to exceed youF credit line. Wfe vAil treat Citibank checks as 3 cash advance and charge them against your cash advance limil. Each Citibank rheel: mfai lie ::n the form ive have issu?d and must be us2d according M .n% instructions vJe glee you. Citibank checks may oa used ;ni'; by the pef5rin, `id Cs2 ;carne is prin;;r: or, them. Citibank checks may nct to usciS to pay :if % ^I%ou t ovred to !is ender this or any ether Citibank Card Agreement.We 'viil not sera any Citibank cher.'r.s, nor will we return paid Cifitank checks. Returned Citibank Check Fee: ",/e will add a S29 fee io the cash advance bal=rice if kys a=--Cline 'c ^oror _ Citibank We may decline 10 honor a Citibank chec'.•; if. i_r ample. the cli!1?•:.::. :Jr :lit ., ... . ..? _ or credit iine, if you default, if you did not compli tgith our Instructions regarding the check, if vo-,r account has been closed. Cr if the ccrd has expired. Stop Payment Fee: We will add a S29 fee to the cash advance balance when payment of a Citibank check is stopped at your request. You may stop payment on a Citibank check by notifying us in writing at P.O. Box 6500, Sioux Falls, South Dakota 57117 or by calling us at the te:•ephone number listed on th-, billing statement. If you call, you must confirm the call in writing within 14 days. A written: stop payment order will remain in effect for six months unless renewed in writing. Once a charge is made through the use of the card or account number we cannot "stop payment" on the charge. If there is a dispute involving a charge on t,!,ur -,cc.*)uht. please refer to the section entitled "What To Do If There's An Error in Your Bill". Lost or Stolen Cards, Account Numbers or Citibank Checks: If any card. account number or Citibank check is lost or stolen or if you think used or may use them without your permission, notify us at once by tl:e telephone number shown on the billing statement or the number ,;!M-MeJ CallinL' toll-tree or local Directory Assistance. We may require you to prc?ide certain inforrnation in writing to help us find outshat happened. Don't use the card or the Citibank checks after we've been notified. even if they are found or returned. You may be liable for unauthorized use of the card, but not for more ihan S:,O. You vvon't be liable for unauthorized purchases or rash advances made after we've been notified of the loss or the theft, however, you must identify for us the charges on the billing statement that were not made by you, or someone authorized by you, and from which you received no benefit. Default: You default under this Agreement if you tail to pay tha minimum payment listed on each billing statement when due, fail to make a payment to _ny other creditor ,A/hen due, file for bankruptcy, exceed your credit line without permission. pay by a check or similar instrument that is not honored or that we must return because it cannot be processed, pay by automatic debit that is returned unpaid, or default on any other Citibank Card Agreement. If you default, -we may close your account and demand it^mdiate payment of cite full balance. If you have given us a security interest in a certificate of Jeposit or a savings account, we may use the deposit amount to pay any 3mrouni you o'.ve. 6 -le U o y "- n h° a' v C. - E m u ?' v y_ ^0 3 .°i ti= o a CO 11 Ln C3 > Lo o F - a MC r ? v t° W a 3 cr r, 3 '^ r' o v t- •`_? ?` '- E _°^,' : o cn Co W or L)._ O O p N S U N a' "- W 3 o E W = O G r O" N "' C CL) o a, C. >,C •C co M) = Q,Cm rm3= c n cm "C-0 a o,N.U a?cUa=°o n.Ecvd=a`? _ N p ?'• - t C:1 . fC ? ° L 3 C1 = E ^ O , U M C= _0 N > r CL 156 N ? r J N M O •S 2 U ^ G.? v N 3 ?. O C C1 •= c N 7 C CD T M > c >. O LT 41 S .O O 3 N y f0 •- ?. tl _ C C in O 'C y° c? C t; co O W r " c C." y C a. ^? ^ .? C p y.•- C3 r j 3 O v 1 C..) Q N •.??. 'V :? tCd j r w O v e, = _? r o G o =- 3 °- 3 m M M Ta ee -_ ccu'_ G ° d ctl c °' cti o c ?N c?.= o _i o o - >= N crNS•'- a °'Jcp 3 E a>- N in a Oi ?; ai a ° r = as J o s?o N 5 - ?s - v o C, O J C 'Z' j r 22 > T O .? --5 p r •? •? U N ea `•• >, N `'T T O? V O ?.. `' tl 0 3 e R a? 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C v? as V _ V C? - E:= -C OO 3 .n a aa> C, O is = en h - _ - ?o f E _ CL EL ME In q W O C C T Cc co CL 3 i o c ti =a' vi ° 3 a av d T r E a; r y i _ _ E 29E y C4 0 e s m ° > Cm Lc? L O = as ` O 75 O ti •r r h 72; - y CO E! _C _ C-l IS C=) 0 LL Ca 0, ts 3 CD 3 cc C-3 1,3 -:5 >c CZ 0 c) - • - In - ? ' O .2 L- 0 4) 'D a: ' c c aa _ a c a .-? L - ? C, ?2 ? -N - r O Z 4! ! w ai E5 y CJ C C N fn r? a Cl ^ Q 1 ^ Ci ? a: U _ _ ? CL O> a L r C t -25 C ` >. •p y _ - es \ . . O - _ O c: C . = c ?• -_ ". __ - 73 7,:j CL 7? 21 C?: 25 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. Harry A. Stra er, III., Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. : CIVIL-LAW LINDA A. FALLA, 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. d Xrof dM , 2007 Dated this Laurinda J. Voelc a 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 NOW Page 1 of 1 NOV-16-2007 10:25:19 Last Name First/Middle Begin Date Active Duty Status Service/Agency FALLA Linda A. Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 41 0 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.di„fenselink.mil/faa/pis/PG09S_LDR 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: WADRPHKYDT https://www.dmdc.osd.mil/scra/owa/scra.prq_Select 11/16/2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. LINDA A. FALLA, 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: Linda A, Falla 601 State Street Apt 1 Enola, PA 170215' Respectfully submitted, Laurinda J. Voelck , Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-6470 a w N w W C v r-, n., 2, `., L> s CJ " I 0 I - _ `? t -G; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. CIVIL-LAW LINDA A. FALLA, DOCKET NO. dS -3 Ct u c ?, G Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION AURINDA J. V ELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsburg, PA 17815 (570) 387-1873 ? ?? ?? ,.? r C _ ----1 ? -:? t1 - G'? `M? _ ._ ? -; r ?. ?l ::1? C::. ,. SHERIFF'S RETURN - REGULAR CASE NO: 2008-00338 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REMIT CORPORATION VS FALLA LINDA A JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sw rn according to law, says, the within COMPLAINT & NOTICE was so ved upon FALLA LINDA A the DEFENDANT at 1907:00 HOURS, on the 24th d of January , 2008 at 601 STATE STREET APT 1 ENOLA, PA 17025 by hand?n to LISA HELMAN, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to th contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 14.40 .N: Affidavit .00 Surcharge 10.00 R. Thomas Kline' .00 Ilaq,/p8- LJ ? 42.40 01/25/2008 REMIT CORPORATION, Sworn and Subscibed to By: before me this day e Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. LINDA A. FALLA, Defendant CIVIL,-LAW DOCKET NO. 08-00338 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO TIRE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt Attorney Fees Costs Defaaltjudgmeat Interest from Jan 16, 2008 Total: $2,215.17 $ 471.89 $ 120.90 X14:06-- $ 22.15 $2,ab-. iZ= 193 0, 11 2Rao. I I Kindly assess damages against Defendant in the sun of*2,*4 -.+l plus continuing interest at the statutory rate of 6%. BY: " fA4???_ Laurinda . Voelcker, Esquire Attorney for Plaintiff N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. LINDA A. FALLA, Defendant CIVIL-LAW DOCKET NO. 08-00338 TO: Linda A. Falla 601 State Street, Apt. 1 Enola, PA 17025 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on 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. CIVIL-LAW LINDA A. FALLA, DOCKET NO. 08-00338 Defendant 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 mail to Defendant on February 19, 2008. BY: JjAA1AA'd 041 -.? vLtq, Laurinda J. lcker, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. LINDA A. FALLA, : CIVIL-LAW : DOCKET NO. 08-00338 Defendant NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Linda A. Falla DATE OF NOTICE: February 19, 2008 601 State Street, Apt. 1 Enola, PA 17025 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 REMBI, CO O aurin. Voel er, Esquire da J Remit Corporation PO Box 7 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Mailed to: Linda A. Falla 601 State Street, Apt. 1 Enola, PA 17025 Bloomsburg, PA 17815 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifimd CCR, Plaintiff VS. : CIVIL-LAW LINDA A. FALLA, DOCKET NO. 08-00338 Defendant AMDAVIT OF NON-M LITARY 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 this /r day of 141Q ?_6,A '2008 Laurinda J. Voorcker, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 (570) 387-1873 (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 I MAR-05-2008 07:08:53 E Last Name First/Middle Begin Date Active Duty Status Service/Agency FALLA Linda A Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 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.defensel.ink.mil/fag/yis/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: CXOABGYBOU h4s://www.dmde.osd.mil/scra/owa/scra.prc_Select 03/05/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. LINDA A. FALLA, Defendant CIVIL-LAW DOCKET NO. 08-00338 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: Linda A. Fa11a 601 State Street, Apt. 1 Enola, PA 17025 Respectfully submitted, Laurinda J. V cker, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 570-387-6474 l+: r? n?Fn A rC :l by" ? c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR Plaintiff vs. CIVIL-LAW LINDA A. FALLA DOCKET NO. 08-00338 Defendant PRAECIPE FOR WRIT OF EXECUTION Personal Property Levy To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against LINDA A. FALLA, defendant (3) against N/A, garnishee; (4) and enter this writ in the judgment index a. against LINDA A. FALLA, defendant, and b. against N/A, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) T .. ,3 T A. A0 - of Amount Due: AJ& fi8• so- K tt /Y• vv - !r so r( Interest from 03/13/2008 Other: Credits: Costs to be added: Clerks Fee: Sheriff: Total: $ 284 i 1 ??8.3Q l $ 312.85 $ 0.00 $ 0.00 Dated ttjs, C?Zd# gfjJany_ary, 2010 $ -24-60- ? $ 1-56.06 _, $ 3,330.96 Laurinda J. Voelckzr, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 7.?-00 ? 17. SC, eK;fL /.x;z4? '? ,,A_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR Plaintiff vs. CIVIL-LAW LINDA A. FALLA DOCKET NO. 08-00338 Defendant WAIVER OF WATCHMAN Any deputy sheriff levying upon or attaching any property under within may leave same without a watchmen, in custody of whoever is found in possession, after notifying such person of such levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any such property before sheriff's sale thereof. LINDA A. FALLA 601 State Street Apt I Enola, PA 17025 Laura J. Voelcker, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR Plaintiff VS. : CIVIL-LAW LINDA A. FALLA DOCKET NO.08-00338 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, nor has been in such service within thirty days hereof. Dated thin; day of January, 2010 Lauri&a J. V( elcker / Attorney for Plaintiff` Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Tel. (570) 387-1873 Fax (570)387-6474 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jan-25-2010 13:07:36 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency FALLA LINDA 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). Amy A Audl.A- V- 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 htti)://www.defenselink.mil/W/Xis/PC09SLDR.html. 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. https://www.dmde.osd.mil/appj/scra/popreport.do 01/25/2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR Plaintiff vs. CIVIL-LAW LINDA A. FALLA DOCKET NO. 08-00338 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: LINDA A. FALLA 601 State Street Apt 1 Enola, PA 17025 Respectfully Submitted, Laurinda J. elcker, Esquire Attorney for Plaintiff PA ID# 82706 36 West Main Street Bloomsburg, PA 17815 Tel.(570)387-1873 Fax (570)387-6474 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-338 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due REMIT CORPORATION, Plaintiff (s) From LINDA A. FALLA, 601 STATE STREET, APT. 1, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANY AND ALL PERSONAL PROPERTY IN DEFENANT'S POSSESSION, INCLUDING BUT NOT LIMITED TO: VEHICLES, ATV'S, BOATS, SNOW BLOWERS, GUNS, OTHER SPORTING GOODS AND EQUIPMENT, COMPUTERS & EQUIPMENT, ELECTRONICS, COLLECTIONS (COINS/FIGURINES), JEWELRY, RIDING TRACTORS, HOUSEHOLD GOODS & FURNISHINGS. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 $2,830.11 L.L. $.50 Interest FROM 3/13/2008 - $312.85 Atty's Comm % Due Prothy $2.00 Atty Paid $161.40 Other Costs Plaintiff Paid Date: JANUARY 28, 2010 J. David D. Buell, PrQ (Seal) By: REQUESTING PARTY: Name LAURINDA J. VOELCKER, EQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 82706 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-C)- tic Sheriff F TH` p,"`X Q' P;g,TA. ?aa?xtr of ?':Irtpbt•r r?6 qY Jody S Smith Chief Deputy H,? -S p '12: 3 7 s { ; 0„ ??.. Edward L Schorpp ?jI, Solicitor OFFtC;6 OF THE S?-E€zIFF cuts ? - , ??.?.r'` Remit Corporation Case Number S. 2008-338 Linda A Falla SHERIFF'S RETURN OF SERVICE 02/24/2010 02:10 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 24, 2010 at 1410 hours a true copy of the within writ of execution was attempted to be served upon the defendant, to wit: Linda A. Falla, 1919 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. At that time it was learned from the current tenant that the defendant has moved to Grand Forks, North Dakota. 03/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $76,45 March 05, 2010 013 I I .Z d Z- q] 3 G?07 ,, C' ', 1 ..' - SO ANSWERS, RON R ANDERSON, SHERIFF By Sharon R. Lant l 7?G -2 / 33 q3 G (c) CountySW6 Sheriff. Teleosoft, Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-338 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due REMIT CORPORATION, Plaintiff (s) From LINDA A. FALLA, 601 STATE STREET, APT. 1, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANY AND ALL PERSONAL PROPERTY IN DEFENANT'S POSSESSION, INCLUDING BUT NOT LIMITED TO: VEHICLES, ATV'S, BOATS, SNOW BLOWERS, GUNS, OTHER SPORTING GOODS AND EQUIPMENT, COMPUTERS & EQUIPMENT, ELECTRONICS, COLLECTIONS (COINS/FIGURINES), JEWELRY, RIDING TRACTORS, HOUSEHOLD GOODS & FURNISHINGS. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 $2,830.11 Interest FROM 3/13/2008 - $312.85 Atty's Comm % Atty Paid $161.40 Plaintiff Paid Date: JANUARY 28, 2010 (Seal) L. L. $.50 Due Prothy $2.00 Other Costs David D. Buell, Prot onotary By: Deputy REQUESTING PARTY: Name LAURINDA J. VOELCKER, EQUIRE 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 REMIT CORPORATION Plaintiff CIVIL ACTION -LAW o == VS. -? NO. 08-00338 - LINDA A. FALLA = A Defendant ASSIGNMENT OF JUDGMENT 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 "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 08-00338 against Defendant, LINDA A. FALLA, for the sum of $2,350.07 which constitutes damages and costs of suit, plus interest at 6.00% annum from 03/13/2008, together with all the benefits and advantages that may be obtained thereby, and full power to enforce and recover the Judgment to Unif end'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. #8.0o Pa Am/ iasgq ?' 015q (021 IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporation, has executed this Assignment this day of , 2010. Laurinda J. V&,.,.". General Counsel Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. LINDA A. FALLA Defendant : CIVIL ACTION -LAW NO. 08-00338 PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), LINDA A. FALLA, 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: _Z? 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), LINDA A. FALLA, 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, c.: Plaintiff : ::j e CIVIL-LAW vs. A °?- r- -? -r r v jl ? Knee ?? pA ! ? ?? I > --- DOCKET NO. 08-00338 + LINDA A. FALLA, X919 (7pA? c -, Defendant c? vs. 5- cz r\) a 705 MEMBERS 1ST FCU, 050M Lovi, 1 : Mee Garnishee PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotarv=: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, Pennsylvania (2) against Linda A. Falla, defendant; and (3) Against Members 1st FCU, Garnishee; (4) and index this Writ in the judgment index and (a) against Linda A. Falla, defendant(s), and (b) against Members 1 st FCU, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: $ 2,830.11 Interest from 03/13/2008 $ 706.21 Other $ 105.95 Credits $ 0.00 Costs to be added: Clerks Fee: $ 10 Sheriff- $ 4619 - 00 Pa AT7q Total: 401. Lio CAF 7b. q 5 " `18.50 i4. oo 8. oo " a7a .35 - P4 AM $a.as OueCd Data"j--liffy of W 01 2012 Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 & f71a4 ?# a?sno I1 ?r f? A urn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. CIVIL-LAW LINDA A. FALLA, DOCKET NO. 08-00338 Defendant vs. MEMBERS 1 ST FCU, Garnishee 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 day of I y Aq , 2012 Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 Department of Defense Manpower Data Center SuMs Report F uxg to Sez-vicemeffibers Civil Relief Act Last Name: falla First Name: linda Active Duty Status Date Apr-30-2012 Results as of : Apr-30-2012 02:49:13 SCRA 2.1 Active Duty End Date status Service Component On Active Duty. On Active Duty Status Date NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HielHer UnH Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. rte. A ,c?.?,-?-. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual leftActive Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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 (NOAH Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: DKQDMPAB3L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. CIVIL-LAW LINDA A. FALLA, DOCKET NO. 08-00338 Defendant vs. MEMBERS I ST FCU, 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 Defendant: Linda A. Falla 1919 Princeton Avenue Camp Hill, PA 17011 Garnishee Members 1 st FCU 5000 Louise Drive Mechanicsburg, PA 17055 Respectfully Submitted, Angela L. Mattis, PA ID #309229 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 08-338 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION, Plaintiff (s) From LINDA A. FALLA, 1919 Princeton Avenue, Camp Hill, PA 17011 (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: MEMBERS 1sT FCU, 5000 Louise Drive, Mechanicsburg, PA 17055 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 $2,830.11 Interest from 3/13/08 -- $706.21 L.L. $ Atty's Comm % Atty Paid $272.35 Plaintiff Paid Date: 5/11/12 (Seal) Due Prothy $2.25 Other Costs: $105.95 Deputy REQUESTING PARTY: Name ANGELA L. MATTIS, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 309229 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~!12 MAY 18 PM 1: 11 Richard W Stewart Solicitor s IJMBERLAND t;OLIN IFY PENNSYLVANIA Remit Corporation vs. Linda A Falla SHERIFF'S RETURN OF SERVICE Case Number 2008-338 05/17/2012 02:24 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2012 at 1424 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Linda A. Falla, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 321 York Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Jamie Smith, Assistant 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 May 18, 2012 to Linda A. Falla at 1919 Princeton Avenue, Camp Hill, PA 17011. SO ANSWERS, May 18, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy