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HomeMy WebLinkAbout08-7184IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. EDWARD B GREEN Defendant No. Ce - we y ? COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06380818 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. Civil Action No. EDWARD B GREEN Defendant You have been sued in court. L pages, you must take action within twen a written appearance personally or by objections to the claims set forth agair proceed without you and a judgment in any money claimed in the complaint or lose money or property or other rights in ,ou wish to defend against the claims set forth in the following (20) days after this complaint and notice are served, by entering attorney and filing in writing with the court your defenses or you. You are warned that if you fail to do so the case may be entered against you by the court without further notice for )r any other claim or relief requested by the plaintiff. You may ortant to you. YOU SHOULD TAKE THIS P.PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT A FORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHE E YOU CAN GET LEGAL HELP. i INFORMATION ON AGENICES THAT AT A REDUCED FEE OR NO FF.F- LA ER REFERRAL SERVICE :RL D COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET ARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation having offices in 1250 SOUTH GROVE ST, #301, BARRINGTON, IL 60010-0000. 2. Defendant is an adult individual residing at 187 CEDAR LN, CARLISLE,PA 17013. 3. On or about EDWARD GREEN Defendant duly executed a LOAN REPAYMENT AND SECURITY AGREEMENT (hereinafter the "Agreement") in favor of BENEFICIAL CONSUMER DISCOUNT COMPANY, a true and correct copy of said Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Said Contract was subsequently assigned to Plaintiff. 5. A true and correct copy of Plaintiffs Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 6. Plaintiff avers that to Plaintiff as promised, thereby 7. Plaintiff avers that a is in default of the Agreement by having not made payment ing the entire balance immediately due and payable. of $7,264.55 is due from Defendant as of JUNE 18 2008. 8. Plaintiff is entitled to inter?st at the rate of 11.99% per annum. 9. Although repeatedly requ?sted to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, inter st, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, EDWARD B GREEN, individually, in the amount of $7,264.55 with continuing interest thereon at the rate of 11.99% per annum from MAY 9, 2008, plus costs. THIS IS AN ATTEMPT TO COL ECT SHALL BE USED FOR THAT PURP SE. A DEBT AND ANY INFORMATION OBTAINED WELTI*N, WEINBERG & REIS, CO., L.P.A. MATTHEW D. URBAN, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:06380818 LOAN REPAYMENT A D SECURITY AGREEMENT (Page 1 of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPAN s 419 STONEHEDGE DRIVE y+ SUITE 2 CARLISLE PA 17013 NO BORROWERS (called "You", "Your") LOAN NO: 711715-537554 GREEN, EDWARD B SS# '0343 187 CEDAR LN CARLISLE PA 17013 11101/2002 12101/2002 EACN TOTAL OF PAYMENTS AMOUNT FINANCED S 10,009.80 7,499.85 TOTAL FINANCE CHARGE SCHEDULED INTEREST 2,509.95 2,509.95 $ LIFE INS PREMIUM DISABILITY INS PREMIUM t NONE Is NONE s DATE 111011 .00 NONE Y100 00 INS P" FILM INSURANCE PREMIUM NONE 1 166.83 YOU ARE GIVING US A SECURITY INTEREST COVERING: INSURED YEAR DESCRIPTION I Y 1975 MOBILE HOME MAKEIMODEL SCHULT SERIAL NUMBER E138124 REQUIRED INSURANCE. You must obtain insurance for term of 'loan covering security for this loan as indicated below. naming us as Loss PayIoe: Title insurance on real estate security. Fire and extended coverage insurancfion real estate security. Physical damage insurance on vehicle! listed under "Security" above if "Y" appears under "Insured". YES Physical damage insurance on other property listed under "Security" above if "Y" appears under "Insured". You may obtain any required insura a from anyone you choose. (See "Security" paragraph above for description of security to be insured.) 03-01-00 NRE 1111111111111110-111111110 11111110 11 PA875011 MG03F20E24B98CEA9000PAB750110m EN K ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for this loan, you will pay us the Total of Payments (the sum of Finance Charges plus Amount Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You may pay more at any time. You will pay us at our business address as stated on page one or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a combined amount greater than the amount owed. DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also postponed. PAYOUTS. You agree to payouts of Amount Financed as shown on Truth-In-Lending disclosure form. If payouts change because loan closing is delayed, (a) you shal pay additional amounts due at closing, or (b) your cash or check will be reduced to cover additional pay-outs, i PREPAYMENT. If you fully pay before final pay ent due date, the amount you owe will be reduced by unearned Finance Charge (but not Service Charge) determined by the "Rule of 78ths". MATURITY. After the final payment due date stated on page one you will pay interest at the rate of 18% per year. SECURITY. You agree to give us a security interest in the property identified on page one, which will secure all indebtedness, including future advances under this, Agreement. LATE CHARGE. If you don't pay any payment'' in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a f of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may d uct this charge from a monthly payment. FAILURE TO PAY. If you don't pay any paym t on time or fail to keep any required insurance in force, (a) all your payments may become due at once and without notifying you before bringing suit, we may sue for the total amount you owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable attorney fees, if the attorney is not our salaried eployee, for legal proceedings to collect this loan or realize on security. EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain rela to your Account, including but not limited to credit reports and insurance information, with any of our affilia corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to determine' if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account wiI any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such inform tion (except for the sharing of information about transactions or experiences between us and you) by sending written request which contains your full name, Social Security Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320. If you fail to fulfill the terms of your credit bligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You a that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence tress to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telepho a calls between you and our representatives in order to evaluate the quality of our service to you. INSURANCE. Optional credit insurance and any'required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any other Riders signed as part of this loan transacts are incorporated into this Agreement by reference. APPLICABLE LAW. The Pennsylvania Consu?er Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. NOTICE: THE FOLLOWING PANE CONTAINS ADDITIONAL CONTRACT TERMS. 03-01-00 NRE PA675012 1 ?®111 11¦1??II??r III?I?i?? NG03F2DE24B98CEA9000PA8750120%KGR,EN If ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. BQRROWERS- %I (SEAL) WITNESS: (SEAL) 03-01-00 NRE 11111'1®1 *G03F20E24B98MA9000PAB7 1 AL PAB75013 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is GEORGIA ANN LYCOS Name) /FS 5 £ ?'?"? 4 of fle-t o (,4AC- t-( -) JU ? plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. Gam-- ?-- _ Signature) WWR# kiWU Client Account # -1 l S(7053'*91 Name jEDMn 1. ?i Gr_ee.n ODD d v W? n f1* j ?" N cm cm 1 q 59 33 V `J SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07184 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RED ROCK LAKE FINANCIAL VS GREEN EDWARD B R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GREEN EDWARD B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 187 CEDAR LANE GREEN EDWARD B NOT FOUND , as to CARLISLE, PA 17013 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO MAKE SERVICE PRIOR TO EXPIRATION OF COMPLAINT. Sheriff's Costs: So answers -'' Docketing 18.00 Service 13.50 Not Found 5.00 R. Thomas KI-fne Surcharge 10.00 Sheriff of Cu rland County .00 46.50 WELTMAN WEINBERG REIS 01/07/2009 Sworn and Subscribed to before me this day of , A. D. A Imr, ~~ v v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL LLC Plaintiff vs. EDWARD B GREEN Defendant No. 08-7184 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-79555 WWR#06380818 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL LLC Plaintiff vs. Civil Action No. 08-7184 CIVIL TERM EDWARD B GREEN Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James CZ j tbrodt, Esquire PAID . A 5 4 WELTM , WEINBERG & REIS CO., L.P.A. 1400 K rs Building 436 Se th Avenue Pittsburgh, PA 15219 (412) 434-79555 WWR #06380818 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL,. ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. EDWARD B GREEN Defendant No. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06380818 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. Civil Action No. EDWARD B GREEN Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND 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 an 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENICES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation having offices in 1250 SOUTH GROVE ST, #301, BARRINGTON, IL 60010-0000. 2. Defendant is an adult individual residing at 187 CEDAR LN, CARLISLE,PA 17013. 3. On or about EDWARD B GREEN, Defendant duly executed a LOAN REPAYMENT AND SECURITY AGREEMENT (hereinafter the "Agreement") in favor of BENEFICIAL CONSUMER DISCOUNT COMPANY, a true and correct copy of said Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Said Contract was subsequently assigned to Plaintiff. 5. A true and correct copy of Plaintiffs Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 6. Plaintiff avers that Defendant is in default of the Agreement by having not made payment to Plaintiff as promised, thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that a balance of $7,264.55 is due from Defendant as of JUNE 18 2008. 8. Plaintiff is entitled to interest at the rate of 11.99% per annum. 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, interest, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, EDWARD B GREEN, individually, in the amount of $7,264.55 with continuing interest thereon at the rate of 11.99% per annum from MAY 9, 2008, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTNV AN, WEINBERG & REIS, CO., L.P.A. MATTHEW D. URBAN, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:06380818 LOAN REPAYMENT AND SECURITY AGREEMENT (Page t of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 419 STONEHEDGE DRIVE 9? 1 SUITE 2 CARLISLE PA 17013 40 BORROWERS (called "You", "Your") LOAN NO: 111115-537554 GREEN, EDWARD B SS# 191450343 167 CEDAR LN CARLISLE PA 17013 1110112002 12/0112002 MACK' M-CkX _ --1110112007 12 000 x TOTAL PATME S AMOUNT FINANCED 10,009.60 7,499. B5 TOTAL FINANCE CHANCE SCHEDULED INTEREST C 2,509.96 . 2,509.95 S .00 00 LIFE UIS PREMIUM OISARR.ITT INS PREMIUM 1111 PREMIUM ........ i ........ NON FILING NISIRIANCE PREMIUM L• NONE RBQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan as indicated below, naming us as Loss Payee: Title insurance on real estate security. Fire and extended coverage insurance on real estate security. Physical damage insurance on vehicle listed under "Security" above if "Y" appears under "Insured". YES Physical damage insurance on other property listed under "Security" above if "Y" appears under "Insured". You may obtain any required insurance from anyone you choose. (See "Security" paragraph above for description of security to be insured.) NOTICE: THE FOLLOWING PAGES CONTAIN ADDITIONAL CONTRACT TERMS. 03-01-00 NRE I M® O I 1 30111111111111 11111111111 PAS76011 Kti03F2OE2499$CEA9000PA67SO110"%GREEN " ORIGIIW YOU ARE GIVING US A SECURITY INTEREST COVERING: INSURED YEAR DESCRIPTION MAKEIMODEL SERIAL NUMBER Y 1975 MOBILE HOME SCHULT E138124 LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for this loan, you will pay us the Total of Payments (the sum of Finance Charges plus Amount Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You may pay more at any time. You will pay us at our business address as stated on page one or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a combined amount greater than the amount owed. DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also postponed. PAYOUTS. You agree to payouts of Amount Financed as shown on Truth-In-Lending disclosure form. If payouts change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to cover additional payouts. PREPAYMENT. If you fully pay before final payment due date, the amount you owe will be reduced by unearned Finance Charge (but not Service Charge) determined by the "Rule of 78ths". MATURITY. After the final payment due date stated on page one you will pay interest at the rate of 18% per year. SECURITY. You agree to give us a security interest in the property identified on page one, which will secure all indebtedness, including future advances under this Agreement. LATE CHARGE. If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment.. FAILURE TO PAY. If you don't pay any payment on time or fail to keep any required insurance in force, (a) all your payments may become due at once and without notifying you before bringing suit, we may am for the total amount you owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable attorney fees, if the attorney is not our salaried employee, for legal proceedings to collect this loan or realize on security. EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance information, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS, The terms of the Arbitration Agreement and any other Riders signed as part of this loan transaction are incorporated into this Agreement by reference. APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. . NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 05-01-00 NRE PAS75012 K803F2DE24898CEAH000PA8750120K"OREEW " ORIGIML LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. B ROW RS- (SEAL) (SEAL) WITNESS: (SEAL) 03-01-00 WE PA975013 189 r?? VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is GEORGIA ANN LYCOS Name) 5 s -? a w of fcO-'- &44e-- u M- , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. Signature) WWR# 0.3WU t Client Account # "3 l f `j1 Saps j(Qc! Name. x+.15 loran 0 r I v ?'v ft-CO Pa A"7Y e,T* aagoy i Sheriffs Office of Cumberland County R Thomas Kline FILED- -0'r1K-,E Sheri OF THE- PE??.".)"14 'NOTAPY ?? Ronny R Anderson Zg SEP 8 4 3 Chief Deputy Xr Jody S Smith C" IM i r Civil Process Sergeant QFFi EOF S-R(FF ` #? PE i xi MJ 1 L`'r ?til~: Edward L Schorpp Solicitor Red Rock Lake Financial, LLC Case N4Mber vs. Edward B. Green 2008-7,1184 SHERIFF'S RETURN OF SERVICE 09/09/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Edward B. Green, but was unable to locate him' in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Edward B. Green. After several attempts the complaint has expired. SHERIFF COST: $49.20 ?SO WERS, September 09, 2009 ?T WAS KLINE, SHERIFF 20° 10 Ar 13 A i . e 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, LLC Plaintiff VS. EDWARD B GREEN Defendant No. 08-7184 CIVIL TERM MOTION FOR ALTERNATE SERVICE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6380818 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, LLC Plaintiff No. 08-7184 CIVIL TERM vs. EDWARD B GREEN Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, Edward B. Green, by certified U.S. Mail and Certificate of Mailing, addressed to 187 Cedar Lane, Carlisle, Pa 17013, averring in support thereof the following: On or about December 8, 2008, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $7,264.55. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #6380818 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 187 Cedar Lane, Carlisle, Pa 17013, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was able to confirm a current address for Defendant of 187 Cedar Lane, Carlisle, Pa 17013. A true and correct copy of the search results is attached hereto as Exhibit "3" and made a part hereof. 6. Plaintiff contacted the Cumberland County Tax Assessment office, a representative from which confirmed the Defendant as being the registered owner of 187 Cedar Lane, Carlisle, PA 17013. 7. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the Accurint Total Research System to confirm the physical address of the Defendant. 8. Pursuant to Plaintiff's request for information, Accurint Total Research System confirmed Defendant's physical address of 187 Cedar Lane, Carlisle, PA 17013, a true and correct copy of the Accurint search results is attached hereto, marked as Exhibit "4", and made a part hereof. 9. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WWR #6380818 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (187 Cedar Lane, Carlisle, Pa 17013) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. IV? William T. Molcz n, uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6380818 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, LLC NO. 08-7184 CIVIL TERM Plaintiff VS. EDWARD B GREEN Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 187 Cedar Lane, Carlisle, Pa 17013. A true and correct copy of the Postal Service Return is marked Exhibit "T' attached hereto and made a part hereof b. Plaintiff conducted an online what pages search that confirmed the Defendant's address to be 187 Cedar Lane, Carlisle, PA 17013. A true and correct of the search results is attached hereto as Exhibit "3" and made a part hereof. C. Plaintiff requested current address information from the Accurint Total Research System, which request for information confirmed the current address for Defendant as being 187 Cedar Lane, Carlisle, PA 17013. A true and correct copy of the Accurint search results is marked Exhibit "4" attached hereto and made a part hereof. WWR #6380818 Plaintiff conducted an online tax-assessment search for the address of the Defendant that confirmed the Defendant as being the registered owner of 187 Cedar Lane, Carlisle, PA 17013. Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, Edward B. Green, is 187 Cedar Lane, Carlisle, Pa 17013. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczanpquire PA I.D. #47437 ?// WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this da arch, 10 Not COMMA ANIA N. V?+s ?i 91l??Y R{?Il?t pity dd '?! : ? ?Y 4;orr1rr+1t?014?' ,?Y?M1111.201Q Mom INt ?' WWR #6380818 Sheriffs Office of Cumberland County F'_ Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Red Rock Lake Financial, LLC vs. Edward B. Green ?4?ttittir a ?:?f¢n?rrl?f? QFFICE OF THs $,A-ERIFF Case Number 2008-7184 SHERIFF'S RETURN OF SERVICE 09/09/2009 R. Thomas Kline, Sheriff, who being duiy sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Edward B. Green, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Edward B. Green. After several attempts the complaint has expired. SHERIFF COST: $49.20 September 09, 2009 ;SO AN WERS, KLINE, SHERIFF EXHIBIT Postmaster CARLISLE, PA 17013 Date: October 30, 2009 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: EDWARD B GREEN 187 CEDAR LN Address: CARLISLE, PA 17013 Note: Only one request may be made per completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester (e.g., process server, attorney, party representing self): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se-except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: EDWARD B GREEN, RED ROCK LAKE FINANCIAL L 4. The court in which the case has been or will be heard: PROTHONOTARY CUMBERLAND C 5. The docket or other identifying number (a or b must be filled out): X a. Docket or other identifying number: #08-7184 CIVIL TERM b. Docket or other identifying number has not been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN S YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I cf?rfy that the above information is true and that the address information is needed and will be used solely for service of legal process in cdn aAjon with a> tuafWIrrospective litigation. rgnV= William T. Molczan, Esquire/ PA ID# 47437 Attorney Printed Name W WR File No. 6380818 User: TSW ELTMAN WEINBERG & REIS CO L P A W 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 FOR POST OFFICE USE ONLY SdSn Ln- NEW A S BO?,-liO.LDER'S NAME POSTMARK AND S T ADVII;IESSI EXHIBIT No change of address order on file: Moved, left no forwarding address: No such address: Page 1 of 1 Free People Search I WhitePages WhitePages other:,-Twitter (8) Or search: Last name only j Metro area Edward B Green Is this you? Edit 187 Cedar Ln Carlisle, PA 17015-7841 Aae: 50-54 2 © 2010 Microsoft v500 va: Listing date: Nov. 2009 EXHIBIT t9 red S. t,ttr? //.anuw whitPnaaP.c .nm/cParn}i/FinrlPPrcnn?firctnamP hPainc with=l A,firctnamP.=F.T)WART)ArnamP i/1 R19m n Page 1 of 1 Deep Skip Search ?- 187 CEDAR LN 717-766-5162 - EDT EDWARD B GREEN EDWARD GREEN CARLISLE PA 17015-7841 DOB Link ID: 988004559 Feb 96 - Feb 10 Age: 53 Seto Alert EXHIBIT httnc•//cPrnrP annnrint nnm/ann/hnc/mice 1/1 R/7(11 n CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the day of 2010, by f irst class, U. S. Mail, postage-prepaid, addressed as follows: Edward B. Green 187 Cedar Lane Carlisle, Pa 17013 __??- Attorney for Plaintiff WWR #6380818 APR 1 4 2010 V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, LLC Plaintiff No. 08-7184 CIVIL TERM N O a 4 '77 rn Ern co vs. EDWARD B GREEN ORDER OF COURT AND NOW, to-wit, this ,/115 day of d4vil s 2010, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, Edward B. Green, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 187 Cedar Lane, Carlisle, Pa 17013 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: DISTRIBUTION: 04?( J. Edward B Green 187 Cedar Lane Carlisle, PA 17013 Wi iam T. Molczan, Esq. eltman, Weinberg & Reis, .'o. LPA 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 J oa, WWR #6380818 1 .. ,,. FILE~~~1Aa'~ t~F TF':c ~',.;~ ~ ~ ~~ ~~ ~~' -8 ~ ~~~ 55 CUM~~ ~4s ~"dv Gt~Ui~Y pENivSYLVANtA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL LLC Plaintiff vs. EDWARD B GREEN Defendants} No. 08-7184 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA ID #205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6380818 TIC $lo•oo Pp ~'~ ~tgp7$ 70~ ~~ X1'7558 K ~ ~ Y ~I '4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL LLC Plaintiff vs. Civil Action No. 08-7184 CIVIL TERM EDWARD B GREEN Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Lyndsay lan ,Esquire PA ID #205 0 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #6380818 G ~ ~1L.C~"Cl~r_ It+~ Z[l I O n~T 2 7 PPS 3: 5? Ct1P~EERL~,~~a CJUPT'~' PE~WSYI..'~:'~~~I~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff vs. EDWARD B GREEN No. 08-7184 CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6380818 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff No. 08-7184 CIVIL TERM vs. EDWARD B GREEN Defendant AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared Matthew D. Urban, Esquire, who, being duly sworn according to law, deposes and says that on September 20, 2010, he did cause to be sent to Defendant, Edward B Green, Plaintiff's Complaint by Certificate of Mailing Postal Form 3817 and on September 20, 2010, he did cause to be sent to Defendant, Edward B Green, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at his last known address of 187 Cedar Ln, Carlisle, PA 17013. True and correct copy of Plaintiff's Certificate of Mailing PS Form 3817 is attached hereto, marked as Exhibit "1"and made a part hereof. Furthermore, true and correct copy of Plaintiff's Receipt for Certified Mail is attached hereto, marked as Exhibit "2" and made a part hereof. As the Order of Court states, service is deemed to be perfected as of September 20, 2010, the date of mailing. WELTMAN, WEINBERG &REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6380818 Sworn to and subscribed ~' before me thi 2~ / y day of s~ 10 / COMM NWEALTH OF PENNSYLV IA ,/ Nr,~Eefial :INI mot/ YVlyne A. )cmat, FlewrY pUblk dty df pltAYbwgh, Alfaigl~ny Caunty NO Y P I dfrnm~~lon rdt ~un~ 19 ~os~ Mamprn I~nnMVinfY Mwaitton N~trAw CI1VITiEflST/1TES .Certificate Of T'fl5T/SLSERVICE~; Maiiing Th4 CertlNcale of Malling provides evidence that maN has been presented to USPS® for maNlrg. Th(s form may be us d for dom estlc and Intsmatlonal mail ~ t ~`~ ;,(„( .,. e From: WP.IIr~Qr M Weinberg ~ ~~ r ~ ., ~~ ( ~ ;-~~ A I. ~ 400 Koppers Bldq ~°" ~~ {=~.~ 436 7th Ave ~ ~~~ . s urgh, PA 15214 `_ ~- i .,,~:, _a,, _ ~4 • ~i ~ '! 9#u~ PS Form 3817, April 2007 PSN 7530-02-000-9065 `'""' ~'`V"~'1 E.Eihlti GIU'N~It 1 -. m O Postage $ -~ sash ..• °~ Certified Fee -J _ ., ~ Retum Aeceipt Fee _ ~ e,'p~oeey~n O (Endorsement Required) ~ ~~ ~ '. ~"6~r i;.:a:~ p Restricted Delivery Fee ~~ ` ~ (Endorsement Required) c A' F` s0 ~ Total Postage & Fees ;~ ,~ < `~ ~ b15 14.' --.,.,.....--• r ~ Sent To Q Street Apt No.; - -----~---°---°----°---- R or PO Box No. --- ~~ ~ ~4:1?C~ L!V li City, State, ZIP+4 ._ ----- - LAr'LiSC_c~ •.. rr PA /7OI ~• GE TNELPROTHONOTAPY 2010 NOV 29 AM 11:23 CUMBERLAND CG(JuTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff vs. EDWARD B GREEN defendant No. o8-7184 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 140o Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 412) 434-7955 WWR#638o818 Judgment Amount $ 9,445.68 ? a 1 f ?OON ??4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. Civil Action No. o8-7184 CIVIL TERM EDWARD B GREEN Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, EDWARD B GREEN above named, in the default of an Answer, in the amount of $9,445.68 computed as follows: Amount claimed in Complaint $7,264.55 Interest from o6/09/2oo8 to 11/09/2010 at the interest rate of 11.99% per annum $2181.13 TOTAL $9,445.68 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. Wa rodt, Esquire PA I.D. #42 2 WELTMAN INBERG & REIS CO., L.P.A. 1400 Kopp rs B ilding 436 Seven Av nue (412) WWR#638o818 15219 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,14oo Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 187 CEDAR LANE, CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff EDWARD B GREEN Defendant TO: Edward B Green 187 Cedar Ln Carlisle, Pa 17013 Date of Notice: 5 0 )?a 0 W WR#:6380818 CASE#: 08-7184 CIVIL TERM IMWRTANT 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. MATTHEW D. URBAN, ESQUIRE PA I.D. #90963 __:_._WELn4AN WEINBERG & UIS CO L.P.A 1400 KOPPERS BLDG, 4366 7'H AVE. PITTSBURGH, PA 15219 (412) 434-7955 WWR #6380818 IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASSIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff VS. EDWARD B GREEN Defendant Civil Action No. 08-7184 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, EDWARD B GREEN is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: EDWARD B GREEN 187 CEDAR LANE CARLISLE, PA 17013 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Nov-22-2010 08:19:42 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency GREEN EDWARD 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/faq/pis/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.dmdc.osd.mil/appj/scra/popreport.do 11/22/2010 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:92KSAOE90V https://www.dmdc.osd.mil/appj/scra/popreport.do 11/22/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RED ROCK LAKE FINANCIAL, ASIGNEE OF BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff vs. Civil Action No. 08-7184 CIVIL TERM EDWARD B GREEN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $9445.68 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROTHONOTARY (6'R DEPUTY) EDWARD B GREEN 187 CEDAR LANE CARLISLE, PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 486 71h Avenue, Pittsburgh, PA 15219 1-888-434-0085