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HomeMy WebLinkAbout09-2447IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: (1R_ a?cE7 CiVi` te-M VS. COMPLAINT IN CIVIL ACTION LEROY R DAUGHERTY III Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07303826 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs. Civil Action No LEROY R DAUGHERTY III Defendant COMPLAINT 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 ABOUT AGENCIES 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 t • COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: LEROY R DAUGHERTY III 51 SUNSET DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX0917 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of March 18, 2009 , in the amount of $3374.95 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . I #I 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , LEROY R DAUGHERTY III INDIVIDUALLY , in the amount of $3374.95 with interest at the legal rate of 6.000o per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James C. Warmbrodt,42524 WELTMAN WEINBERG & REIS CO., L.P.A. 436 Se e th Avenue, Suite 1400 Pitts r h, PA 15219 (412) 4 4-7955 FAX: 4 -338-7130 0730 6 C A Pit ABR This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. ?3`k, •d.- V 1E R, $3,374.95 , $3,374.45 I Enter Amount Enclosed Below CARD Payment Due Date $ DUE IMMEDIATELY 08 S03WA01 0005255 LEROY DAUGHERTY III 51 SUNSET DR CARLISLE PA 17013-2126 Add •ess, e-mail or tslephone change? Print change in space above, or go to Dis:over.com. Print your e-mail address to race ve important Account information and special offers. Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the same day. Visit Discover.com/payments today. PO BOX 6103 111 rrr11rr1111111rRill 11111 CAROL STREAM IL 60197-6103 {.II.rllrrrrrrillrirrlrrrlrlirrrrrliflrrrrrlirllrrrrrllrrlrril (1000019itr6458144071665033749500000000337495 Discover More Card Account Summary Closing Date: January 8, 2009 page 1 of 1 Acccuni number ending in 0917 Previous Balance $3,374.95 Payment Due Date February 7, 2009 Payments And Credits 0.00 Minimum Payment Due $3,374.95 Purchases + 0.00 Credit Limit $7,300.00 Cash Advances + 0.00 Cred t Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $3,374.95 Cashback. Bonuse Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Available to Redeem - $ - 0.00 Date: September 8 Howe Can We Help You? It's your choice - 3 ways to help Phase have your Dliscover Card available. For TDD (assistance for hearing impaired) see reverse side 1. Visit Discover.com to pay your bill for no cost, view our latest Account information, earn and redeem rewards and more 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service options or to speak with a Customer Service Account Manager 3. Write us at Discover Card, PO Box 30943, Salt Lake City, UT 84130 Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balance s Rates RATES RATES CHARGES CHARGES current billing period: 8 days Purchares $0 0.07942% 28.99% F 28.99% $0 none Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 previous billing period: 26 days Purchases $0 0.07942% 28.99% F 28.99% $0 none EXHIBIT The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Important Informatlon. If there is more than one page to this billing statement, see the back of each page for additional important information. See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account U) Lost or stolen cards. Report immediately. Call 1400-947-2683. Z rn Billing Rights Sunwiner In Case of Errors or Questions About Your Bill. K you think your bill is wrong, or if you need more information about a o transaction on your bit write to us on a separate sheet of paper at Discover Card: PO Box 30421, Salt Lake City, UT 84130-0421, as soon as possible... We must hear rom you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but 8 doing so will not preserve your rights. In your letter, give us the following information: N *Your name and Account number. N •The dollar amount of the suspected error. cn siDescribe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are unsure N about. 0 You do not have to pay any amount in question while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. While we investigate your question, we cannot report you as delinquent or take any action to collect the amount you question. Rule for Credit Card Purchases: If you have a problem with the quality of goods or services that you purchased with a credit card and u have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the gods or services. You have this protection only when the purchase price was more than S50 and the purchase was made in your home state or within 100 miles of your mailing address. (11 we own or operate the merchant, or if we mailed you the advertisement for the goods or services, all purchases are covered regardless of the amount or location of purchase.) Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as described above, you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. B payment is processed as an electronic fund transfer, the transfer will be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. The processing of your payment ma1+ be delayed 9 you send cash correspondence or other items with your payment if you send the payment to any other address or it you use an envelope other than he one provided. Payments received on or after 1 PM Monday hfouah Friday or on a weekend or bank holiday will be posted to your Account as of the next business day. If you have misplaced your envelope send your payment to Discover Bank, PO Box 6103, Carol Stream, IL 60197-6103. Please allow 7-10 days for delivery. If your payment is returned unpaid, we reserve the right to resubmit it as an electronic debit You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments Call us at 1-800.347-2683. You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. You will be asked to provide the first 5 digits of your account statement zip code. By entering those numbers as your electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct each payment you authorize from your bank account and to initiate debit or credit entries to your bank account, as applicable to correct an error in the processing of such payment You must tell us the amount of each payment, or you can select an amount such as the Minimum Payment Due or the New Balance on each statement You can cancel a payment, however we must receive notice at least three business days in advance of the scheduled payment You may notify us by phone at 1-800-347-3683 or by mail at address listed in the previous paragraph. If your payments may vary in amount?we will tell you on each monthly statement when your payment will be made and how much it will be our Automatic payment amount may lass than indicated on the monthly statement based on credits or payments applied during the billing cycle. Credit Reporting. We may report information about your account to credit bureaus. Late payments, missed pa rats, or other defaults on your account may be reflected in your credit report We normally report the status and payment history of your Account to credit reporting agencies each month. If you believe that our report is inaccurate or incomplete please write us at the following address: Discover Card, PO Box 15716, Wilmington, DE 19850-5316. Please include your name, address, home telephone number and Account number. PERIODIC FINANCE CHARGES. Periodic Finance Charges are imposed on all transactions from the date the transaction is posted to your Account until the date you pa your entire New Balance, by making payments or receiving credits. However, it you paid the New Balance on your previous billing statement by the Payment Due Date shown on that statement, and you pay Are New Balance by the Payment Due Date on your current billing statement, we will not impose Periodic Finance Charges on new purchases, that is, purchases first appearing on the current statement We call this the grace period. Otherwise,, ru will receive a.billing statement next month that includes Periodic Finance Charges on those new purchases. There is no grace period on balance ransfers or cash Advances. We sort your transactions into groups of purchases cash advances, and balance transfers and then further sort the transactions within each group by their Annual Percentage Rate. For example, purchases subject t, a promotional rate and purchases subject to a standard rate would be separate rgroups. We refer to these groups as transaction categories. At the end of each billing period, we compute balances and Periodic Finance Charges mr ::ash day of the ;,t::;;, fc: -:cch transaction ca.c5 y We us: t'.r-.nllowin^ squation to compute Periodic Finance Charges for each transaction category Average Daily Balance x number of days in the biBinfgl period x Daily Periodic Rate. You may refer to the finance charge summary on your billing statement for these amounts.) Then we'add up theYeriodic Finance Charges for each transaction Category to get the total Periodic Finance Charges for your Account The Average Daily Balance is shown as zero if, because of the grace period, no Periodic Finance Charges apply to the balance in a transaction category. We use the two-cycle daily average balance (including new transactions) metnod of calculating the balance upon which we impose Periodic Finance Charges. This means if you did not pay the New Balance shown on the billing statement you received during the previous billing period by the Payment Due Date shown on that statement we will impose Periodic Finance Charges on new purchases that first appeared on that billing statement, as well as new purchases that first appear on the current billing statement unless we already imposed Periodic Finance Charges on the purchases on your previous billing statement We compute the Average Daill Balance for each transaction categorryy by adding up all the daily balances in a billing period for a transaction Categg ry and dividing the total by the number of days in the billing cycle. We compu the dally balance for each transaction category on each day by'192 adding i e ollowing to the previous day s deli Dalance: transactions made that day, fees charged that day and Periodic Finance Charges accrued on the revious das da balanead en btracng any credand ents loaf are applied a ins. the balance of the transaction caon Nat dayIn calculating the dafbalanfor the fday of e, bllnpe, we ider evious day s balance" to nave been yor bnce for eabh tran,ction cary the Wsl day of previousDrllinperiodIf a transaction is posted to your Account after the close of the ing period in which it occs, we ill treat the trancon as having ocured on the first day of the billing period in which it is posted to your Aunt All fees Charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Transaction Fee Finance Charges which are added to the applicable cash advance transaction category and Balance Transfer Transaction Fee Finance Charges which are added to he applicable balance transfer transaction category. When a specie balance transfer rate expires we move the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee finance Charges to the standard purchase transaction category. However, if the special rate has been terminated under the Default Rate Plan, we leave the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance Charges in the applicable transaction category until the special rate would have expired. For TOO (Telecommunications Device for the Deaf) assistance, please call 1-800-947-7449. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Beth Bohac (Name) Accounts Manager of DFS Services LLC , plaintiff herein, that (Title) (Company) 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 her knowledge, information and belief. Q11 Y) LA? 1 (Signature) WWR# 7303826 Leroy R. Daugherty 16011002000360917 OF " PIS. PR0i? IIC 5OT`PY 2003 A PR i 7 Ph 2: 4 3 ( 09.*7 9,93993 Sheriffs Office of Cumberland County R Thomas Kline ?ti? tr at Oru1brEdward L Schorpp Solicitor Sheri Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF '"= SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/21/2009 04:35 PM - Jody Smith, Sergeant, who being duly sworn according to law, states that on April 21, 2009 at 1635 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Leroy R. Daugherty, III, by making known unto himself personally, defendant at 31 Sunset Drive Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. The defendant still resides at 51 Sunset Drive Carlisle, Cumberland County, Pennsylvania 17013 SHERIFF COST: $32.50 April 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-2447 Discover Bank VS Leroy R. Daughtery, III By ? Sergeant 0 , 7 t\? `? L4 CD F"n .fir Y ~r ~~~~ , i ,~Fij ? 20k0 ~.t'iy C3 i'it G' i~ CLi''" :~~~~ ::, ,:; , r`~ DISCOVER BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff No: 09-2447 CIVIL TERM vs LEROY R DAUGHERTY III PRAECIPE FOR DEFAULT JUDGMENT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07303826 C A Pit JLI Judgment Amount $3499.95 i~. DO P p AY7-f G~~` ~f953~o1$ -Jake~. ~.aP, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-2447 CIVIL TERM LEROY R DAUGHERTY III NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that th f llowing Order of Judgment was entered against you on Ala (xx) Assumpsit Judgment in the amount of $3499.95 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 Prothon~ary By: LEROY R DAUGHERTY III 51 SUNSET DR CARLISLE, PA 17013 Plaintiff's address is: OR D c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs LEROY R DAUGHERTY III Civil Action No. 09-2;447 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant LEROY R. DAUGHERTY III above named, in the default of an Answer, in the amount of $3499.95 computed as follows: Amount claimed in Complaint $3374.95 Less payments / adjustments made $0.00 Attorney's fees $125.00 TOTAL $3499.95 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. armbrodt,4 0730382 C A Pit JLI Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsbur h, A 15219 And that the last known address of the D fendant is LEROY R DAUGHERTY III 51 SUNSET DR CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LEROY R DAUGHERTY III Civil Action No. 09-2447 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first duly sworn, according tc> law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further 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 LEROY R DAUGHERTY III is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. LEROY R DAUGHERTY III 51 SUNSET DR CARLISLE, PA 17013 is not in the military service. Further Affiant sayeth naught. This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LEROY R DAUGHERTY IIl Defendant TO: LEROY R DAUGHERTY 111 51 SUNSET DR CARLISLE, PA 17013 Date of Notice: ~ ~~.. Case No. 09-2447 CIVIL TERM 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 fNFORMATION 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 WELTM N, WEINBERG &REIS CO., L.P.A. By: _. Matt ew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412} 434-7955 7303826 A PIT J4C 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 Apr-14-2010 10:52:25 `~ Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency DAUGHERTY LEROY Based on the information you have furnished, the DMDC does not III 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 ghat person's Service via the "defenselink.mil" URL http;//www.d_efenselink.mil/faq/_ps/PC09SLDR.htm1. 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 siteand 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 4/14/2010 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:IMOSBFOGO3 hops://www.dmdc.osd.mil/appj/sera/popreport.do 4/14/2010 • , ,,. ~!_ ... .- ~~1_I_ - - %~: rr ~4§ ~-~. !.. 2~1~.1~. ~.l ~ti~r• vi ~ .~ .,. s-r~r l.~~J:a~'i ~ ;~VI !~ / i' ~~. t ~ ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LEROY R DAUGHERTY Defendant(s) No. 09-2447 CNIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA LD. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7303826 DIS #8.0o P a A71`( e* ~~~~3 ~~ ~ty5(oy~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-2447 CIVIL TERM LEROY R DAUGHERTY Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WEL' By: PA I.D. # 20 20 WELTMAN, INBE 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 & REIS CO.. ~.P & REIS CO., L.P.A. W WR #7303 826 Sworn to and su befor e t 's day f July, OTARY P CAMMONWFALTH OF PENNSYLVANIA Notarlel Seal WAY ~ Ga~c, Notary Publk ar a ~, county COrtlml8slon 6~Ireg July 15, 2014 Plllnavlvanla Association of NotaNes