The URL can be used to link to this page

Home My WebLink About09-2502 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. CHRISTOPHER J. ISLEY, Defendant CIVIL-LAW : DOCKET NO. 07- NOTICE .? T?.^ TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 717-238-6807 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Attorney for ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. CIVIL-LAW CHRISTOPHER J. ISLEY, : DOCKET NO. O q- ? 5 o 2 C t!; P 7TG„„ Defendant COMPLAINT The Plaintiff, Remit Corporation, by and through its attorney Laurinda Voelcker, Esquire, hereby files this Complaint of which the following is a statement: 1. The Plaintiff, Remit Corporation, is a Pennsylvania Corporation doing business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania 17815. 2. The Defendant, Christopher J. Isley, resides at 609A Geneva Drive Apt. 30, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant is indebted to the Plaintiff in the amount of $16,392.99 for unpaid account as detailed below. 4. On or about December 2, 2008, Remit Corporation purchased the accounts of Christopher J. Isley from the original creditor. The sale included the transfer of all right, title, and interest in the account to Remit Corporation. A copy of the relevant document for this transaction is attached hereto, incorporated herein and referred to hereafter as Exhibit A. AUTOMOBILE LOAN 5. Defendant obtained a financial loan on or about July 8, 2004 from Americhoice Federal Credit Union (hereinafter "original creditor") in the amount of $17,482.37 to purchase a 1994 Saturn SDN automobile vin number 1G8ZG1577RZ334379. 6. Defendant defaulted on scheduled payments and the account was charged off on or about June 17, 2005. 7. The automobile was repossessed, or returned, and sold. After credits from the sale as well as Defendant's payments, the remaining balance is $10,596.24. 8. To date the charge-off balance is $10,596.24 and $5,796.75 post-charge off interest for a total of $16,392.99 with interest continuing to accrue at 14.49%. COUNT 1 BREACH OF EXPRESS CONTRACT 9. In consideration of the extension of credit provided by original creditor through the loan, Defendant agreed to pay for all charges for purchases, fees and interest on this account. 10. The reasonable charges and expenses owing for the loans, fees and interest is $16,392.99. 11. Defendant accepted the extension of credit and utilized the loan without complaint, objection or dispute as to services provided, the prices charged for the same or the costs incurred. 12. Defendant is indebted to the Plaintiff in the amount of $16,392.99. 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 agreements between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), copies of these writings are attached hereto, incorporated herein and referred to hereafter as Exhibits B. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $16,392.99 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 14. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 15. It is averred, in the alternative, in the paragraphs set forth above, if express contracts between original creditor and Defendant did not exist, that contracts implied by fact or implied by law exist. 16. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to him and that the original creditor expected to be paid for the Defendant's use of this credit. 17. Defendant used the loan to purchase items, and he received the same to his benefit. 18. The total reasonable value of the Defendant's use of the credit extended by original creditor is $16,392.99. 19. In breach of the implied contracts, Defendant has failed and refused to pay the outstanding sum for the loan 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 purchase of this account and the assignment of all rights to the Plaintiff, Defendant is indebted to the plaintiff in the amount of $16,392.99. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $16,392.99, together with interest, costs and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERUITIUNJUST ENRICHMENT 22. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 23. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, fees and interest. 24. The credit extended by original creditor benefited Defendant. 25. The Defendant will be unjustly enriched if he is allowed to retain the benefit resulting from his use of the loan provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 26. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon his use of the loan. 27. The reasonable value of the Defendant's use of the loan including purchases, fees and interest is $16,392.99. 28. By virtue of the Plaintiff's purchase of this account along with the assignment of all relevant rights thereto, Plaintiff, Remit Corporation is entitled to $16,392.99 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $16,392.99, together with interest, costs and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, Laurinda J. Voel r, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax: 570-387-6474 EXHIBIT C AMERICHOICE FCU 20 Sporting Green Drive Mechanicsburg, PA 17050 ASSIGNMENT AND BILL OF SALE AMERICHOICE FCU ("Seller") has entered into a Credit Card Purchase Agreement, dated,DECEMBER 2, 2008 ("Agreement") for the sale of Accounts described in Exhi it A thereof to REMIT CORPORATION ("Purchaser"), upon the terns and conditions set forth in that Agreement. NOW, THEREFORE, for good and valuable consideration, Seller hereby sells, assigns and transfers to Purchaser all of Seller's rights, 'title and interest in each and every one of the Accounts described in the Agreement, provided however such transfer is made without any representations, warranties or recourse. Purchaser and Seller agree that the Purchase Price shall be as stated in Exhibit B, attached to the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 2 day of DECEMBER 2008 SELLER By: JAMES A GLA TER EXHIBIT () m = x N n Z D 0 9 D = m m z F. N r r m Z Im tp c f1 0 3 0 03 C w rn Z I O Ph 2 O D M v v v rn m m N 9 m f') 2 D Z n W C G1 D N N V ? V = v O (? 9 4Ib m cii 2 0 000 m v ? N V O Ul to ;K V = n?i Z m ro G. d N m Z fl. o v V O m Oo N ? ?Z A D D m pN ? O ? V T D N O Z "O n x z ? D 2 M m v o ? ? m N ? A 14 T = O ? N m N ? O Z in A ? D wi r Z ,4C m r O -I A z 0 m m N m m O A m 7O AmeriChoke 20 Sporting Green Drive 9? Mechanicsburg, PA 17 FED-ERAL CREDIT UNION 717-697-3474 Building Relationships For Life 800-240-4364 OTHER EXHIBIT --6-- -arrlea Appucants: May apply for a separate account. Individual Credit: You must complete the Applicant section about yourself and the Other section about your spouse if: 1. you live in or the property pledged as collateral is located in a community property state (AK, AZ, CA, ID, LA, NM, NV, TX, WA, WI), 2. your spouse will use the account, or 3. you are relying on your spouse's income as a basis for repayment. If you are relying on income from alimony, child support, or separate maintenance, complete the Other section to the extent possible about the person on whose payments you are relying. Joint Credit: If you are applying with another person, complete the Applicant and Other sections. Guarantor: Complete the Other section if you are a guarantor on an account/loan. LOANLINER Account/Loan: cc INDIVIDUAL (/nc/uding ATM/Debit Card Access to Me if Available) r Amount Requested $ 10't 1 . , ()e,6:t?? ( L ?„ Purpose/Collateral: jq Repayment: CASH S?T?V ?- PAYMENT PROTECTION NO NO NO PPLICANT \ME ISLEY, CHRISTOPHER J 668 A BIRTH DATE HOME PHONE BUSINESS PHONE/EXT. 07/16/73 (717)645-5498 (717)599-5712 X,3i PRESENT ADDRESS 609A GENEVA DR #30 MECHAN ICSBURG, PA 17055 LENGTH AT RESIDENCE 1 YRS 4 PREVIOUS 4OPI sDR MECHANICSBURG, PA 17050 LENGT SIDENCE COMPLETE FOR JOINT CREDIT, SECURED CREDIT OR IF YOU LIVE IN A COMMUNITY YRS PROPERTY STATE: MARITAL STATUS: SEPARATED EMPLOYMENT/INCOME' $ PER 3,583.00 MONTHLY - NAME AND COUNTRY CLUB OF HBG ADDRESS OF 401 FISHING CREEK RD EMPLOYER HARRISBURG, PA 17110 TITLE/GRADE DIRECTOR OF RESTA START DATE 04-01-04 HOURS AT WORK 40 SUPERVISOR'S NAME IF SELF EMPLOYED, TYPE OF BUSINESS NOTICE: ALIMONY, CHILD SUPPORT, OR SEPARATE MAINTENANCE I E NEED NOT BE REVEALED IF YOU DO NOT CHOOSE TO HAVE IT CON ED. OTHER INCOME 9 PER -'--SOURCE ? $ PER / SOURCE / $ PER SOURCE $ "PfR SOURCE - MILITARY: IS 3 1Y STATION TRANSFER EXPECTED DURING NEXT YEAR? WHERE ENDING/SEPARATION DATE PREVIOUS EMPLOYER NAME AND ADDRESS IF EMPLOYED LESS THAN STARTING DATE FIVE YEARS 09-01-02 TUESDAY CLUB 215 PINE ST ENDING DATE HARRISBURG, PA 17110 04-01-04 REFERENCE RELATIONSHIP FATHER NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU ALLEN ISLEY HOME PHONE 404 HOPI DR (717) MECH, PA 761-5958 SINGLE CREDIT DISABILITY SINGLE CREDIT LIFE JOINT CREDIT LIFE YRS PROPERTY STATE: MARITAL STATUS: NAME AND $ PER REVEALED IF YOU DO NOT CHOOSE TO HAVE IT CONSIDERED OTHER INCOME PER SOURCE g PER SOURCE PER SOURCE PER SOURCE WHERE FIVE YEARS 1 t Application ENDING/SEPARATION DATE REFERENCE NAME AND ADDRESS OF NEAREST RELATIVE NOT LIVING WITH YOU 1-1 1-. - UMUUr, i aesu, 61, 84, 86, 89, 98, 2000, 2001 ALL RIGHTS RESERVED PAGE 1 ' Ameri(IhOiCe 20 Sporting Green Drive J Mechanicsburg, PA 17050 FEDERAL CREDIT UNIoN 717-697-3474 Building Relationships For Life 800-240-4364 LOAN AND SECURITY AGREEMENTS AND DISCLOSURE STATEMENT LOAN DATE - LOAN NUMBER ACCOUNT NUMBER GROUP POLICY NUMBER MATURITY DATE ISLEY, CHRISTOPHER J 609A GENEVA DR #30 MECHANICSBURG, PA 17055 NAME (AND ADDRESS IF DIFFERENT T IN 1 C, ,8, moorwan estimato ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is credit will cost you. provided to you or on paid after you have made your behalf. all payments as scheduled. 14.490 % $ 2, 881.57e $ 17,482.37 $ 20,363.94e which includes your downpayment of $ Your Payment Schedule Will Be: Prepayment: If you pay off early you will not have to Number of Payments Amount of Payments When Payments e ue pay a penalty. Ar 24 814 56 BEGINNI ? $ . NG 08 8 4, MONTHLY THEREAFTER. Required Deposit: The Annual Percentage Rate does 1 $ 814.50 08/08/06 not take into account your required deposit, if any. Property Insurance: You may obtain property from anyone ? Assumption: Someone buying your mobile home you cannot assume the remainder of the loan on the want that is acceptable to the credit union. If you get the insurance from us, original terms . you will payg Demand: ?This obligation has a demand feature . Late Charge: ? All disclosures are based on an assumed maturity of one year. If any portion of your payment is more than 15 days late, you will incur a $15.00 late fee. Filing Fees Non-Filing Insurance S g Security: Collateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your shares and dividends and, if any, your deposits and interest in the credit union; and the property described below: Collateral Property/Model Year I.D. Number Type Value Key Number SATURN SC2 1994 1G8ZG1577RZ334379 SDN $ 2,745.00 S S Other (Describe) Pledge of Shares $ in Account No. $ in Account No. See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the scheduled date. SIGNATURES CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security" section of the Truth in Lending Disclosure, you also agree to the terms of the Security Agreement. If you sign as "Owner of Property" you agree only to the terms of the Security Agreement. X (SEAT 08 04 X (SEAL) BORROWER DATE BORROWER 2 DATE X ? ISEAL) -?'- X (SEAL) OTHER BORROWER OWNER OF PROPERTY ITNESS DATE OTHER BORROWER ? OWNER OF PROPERTY ? WITNESS DATE A CUNA MUTUAL GROUP, 1999, 2000, ALL RIGHTS RESERVED Credit Union AMERICHOICE FEDERAL CREDIT UNION Loan No. 14440 Acct. No. 2566831 Borro'wer(s) CHRISTOPHER J ISLEY 1 SECURITY AGREEMENT I In this Agreement all references to "credit union," "we," "our" or the insurance requirements. If we add amounts for taxes, fees or "us" mean the credit union whose name appears on this document insurance to the unpaid balance of the Loan, we may increase your and anyone to whom the credit union assigns or transfers this payments to pay the amount added within the term of the insurance Agreement. All references to the "Loan" mean the loan described or term of the Loan. in the Loan Agreement that is part of this document. All references " " 7. INSURANCE NOTICE - If you do not purchase the required to you, or "your" mean any person who signs this Agreement. property insurance, the insurance we may purchase and charge you 1. THE SECURITY FOR THE LOAN - You give us what is known as for will cover only our interest in the Property. The insurance will a security interest in the property described in the "Security" not be liability insurance and will not satisfy any state financial section of the Truth in Lending Disclosure that is part of this responsibility or no fauk laws. document ("the Property"). The security interest you give includes 8. DEFAULT - You will be in default if you break any promise you all accessions. Accessions are things which are attached to or make or fail to perform any obligation you have under this installed in the Property now or in the future. The security interest Agreement. You will also be in default under this Agreement if the also includes any replacements for the Property which you buy Loan is in default. within 10 days of the Loan and any extensions, renewals or 9. WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in refinancings of the Loan. It also includes any money you receive default, we may demand immediate payment of the outstanding from selling the Property or from insurance you have on the balance of the Loan without giving you advance notice and take Property. If the value of the Property declines, you promise to give possession of the Property. You agree the Credit Union has the right us more property as security if asked to do so. to take possession of the Property without judicial process if this 2. WHAT THE SECURITY INTEREST COVERS - The Property can be done without breach of the peace. If we ask, you promise to secures the Loan and any extensions, renewals or refinancings of deliver the Property at a time and place we choose. We will not be the Loan. If the Property is not a dwelling, it also secures any other responsible for any other property not covered by this Agreement loans, including any credit card loan, you have now or receive in that you leave inside the Property or that is attached to the the future from us and any other amounts you owe us for any Property. We will try to return that property to you or make it reason now or in the future, except any loan secured by your available to you to claim. principal residence. If the Property is household goods as defined After we have possession of the Property, we can sell it and apply by the Federal Trade Commission Credit Practices Rule or your the money to any amounts you owe us. We will give you notice of principal residence, the Property will secure only this Loan and not any public sale or the date after which a private sale will be held. other loans or amounts you owe us. Our expenses for taking possession of and selling the Property will 3. OWNERSHIP OF THE PROPERTY - You promise that you own be deducted from the money received from the sale. Those costs the Property or, if this Loan is to buy the Property, you promise may include the cost of storing the Property, preparing it for sale you will use the Loan proceeds for that purpose. You promise that and attorney's fees to the extent permitted under state law or no one else has any interest in or claim against the Property that awarded under the Bankruptcy Code. The rest of the sale money you have not already told us about. You promise not to sell or will be applied to what you owe under the Loan. lease the Property or to use it as security for a loan with another If you have agreed to pay the Loan, you will also have to pay any creditor until the Loan is repaid. You promise you will allow no amount that remains unpaid after the sale money has been applied other security interest or lien to attach to the Property either by to the unpaid balance of the Loan and to what you owe under this your actions or by operation of law. Agreement. You agree to pay interest on that amount at the same 4. PROTECTING THE SECURITY INTEREST - If your state issues a rate as the Loan until that amount has been paid. title for the Property, you promise to have our security interest 10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN - shown on the title. We may have to file what is called a financing We can delay enforcing any of our rights under this Agreement any statement to protect our security interest from the claims of number of times without losing the ability to exercise our rights others. If asked to do so, you promise to sign a financing later. We can enforce this Agreement against your heirs or legal statement. You promise to do whatever else we think is necessary representatives. If we change the terms of the Loan, you agree that to protect our security interest in the Property. You also promise to this Agreement will remain in effect. pay all costs, including but not limited to any attorney fees, we 11. CONTINUED EFFECTIVENESS - If any part of this Agreement is incur in protecting our security interest and rights in the Property, determined by a court to be unenforceable the rest will remain in to the extent permitted by applicable law. , effect. 5. USE OF PROPERTY - Until the Loan has been paid off, you 12. NORTH DAKOTA NOTICE TO BORROWERS PURCHASING A promise you will: (1) Use the Property carefully and keep it in good MOTOR VEHICLE - The motor vehicle in this transaction may be repair. (2) Obtain our written permission before making major changes to the Property or changing the address where the subject to repossession. If it is repossessed and sold to someone else, and all amounts due to the secured party are not received in Property is kept. (3) Inform us in writing before changing your that sale, you may have to pay the difference. address. (4) Allow us to inspect the Property. (5) Promptly notify 13. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful us if the Property is damaged, stolen or abused. (6) Not use the for you to fail to return a motor vehicle that is subject to a security Property for any unlawful purpose. 6. PROPERTY INSURANCE, TAXES AND FEES - You promise to interest, within thirty days after you have received notice of default. The notice will be mailed to the address you gave us. It is your pay all taxes and fees (like registration fees) due on the Property responsibility to notify us if your address changes. The maximum and to keep the Property insured against loss and damage. The penalty for unlawful failure to return a motor vehicle is one year in amount and coverage of the property insurance must be provide the insurance through o y ry p prison and/or a fine of $150,000.00. a policy you already have, orr through a olicy ou get and pay for. [3 The fo/lowing notice ssppppl/ies ONLY when the box at left is marked. plies You promise to make the insurance policy payable to us and to 14. NOTICE: ANY I OF THIS CONSUMER CREDIT deliver the policy or proof of coverage to us if asked to do so. CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES If you cancel your insurance and get a refund, we have a right to WHICH THE DEBTOR COULD ASSERT AGAINST THE the refund. If the Property is lost or damaged, we can use the SELLER OF GOODS OR SERVICES OBTAINED PURSUANT insurance settlement to repair the Property or apply it towards HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY what you owe. You authorize us to endorse any draft or check HEREUNDER BY THE DEBTOR SHALL NOT EXCEED which may be payable to you in order for us to collect any refund AMOUNTS PAID BY THE DEBTOR HEREUNDER or benefits due under your insurance policy. . 15. OTHER PROVISIONS - If you do not pay the taxes or fees on the Property when due or keep it insured, we may pay these obligations, but we are not required to do so. Any money we spend for taxes, fees or insurance will be added to the unpaid balance of the Loan and you will pay interest on those amounts at the same rate you agreed to pay on the Loan. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor our loans for the purpose of determining whether you and other borrowers have complied with the insurance requirements of our loan agreements or may engage others to do so. The insurance charge added to the Loan may include (1) the insurance company's payments to us and (2) the cost of determining compliance with CI INA MI )TIIAI C;ROUP. 1999. 2000. ALL RIGHTS RESERVED myvnoi eecoo,e<n 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 r, III, Remit Corpo on IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff VS. CIVIL-LAW CHRISTOPHER J. ISLEY, 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, and has not been in such service within thirty days hereof. Dated this day of Alp (-1 2009 Laurinda J. Voelcker, Attorney for Plainti PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax: 570-387-6474 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 APR-15-2009 08:07:02 *C Last Name First/Middle Begin Date Active Duty States Service/Agency ISLEY CHRISTOPHER J 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. 4131 )4. A Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.htmi 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: EKBTRA VRDX https://www.dmdc.osd.mil/scra/owa/scm.prc Select 04/15/2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. CIVIL-LAW CHRISTOPHER J. ISLEY, Defendant : DOCKET NO. CERTIFICATION OF ADDRESSES I certify that the precise addresses of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Christopher J. Isley 609A Geneva Drive, Apt. 30 Mechanicsburg, PA 17055 Respectfully submitted, la o elc , , Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax: 570-387-6474 c ALFD- OF ?HE PP k-, 20R,'R 2 I = <' F 44 ?af . Q.•? '? 7 s, Sa C/L J) y of &w. 7 7 y 6 f S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff VS. CHRISTOPHER J. ISLEY, Defendant CIVIL-LAW DOCKET NO. Of- ?y0,2 Cc?d- '7Z- ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully submitted, I 1A Laurinda J. Voelcker squire Attorney for Plainti PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax: 570-387-6474 7 0 9 A L pigE G? Sheriffs Office of Cumberland County R Thomas Kline aat?tr at r-umber Edward L Schorpp Sheriff. Solicitor C:. Y Ronny R Anderson" Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/29/2009 01:25 PM - 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: Christopher J. Islay, 609A Geneva Drive, Apt. 30, Mechanicsburg, Cumberland County, Pennsylvania, 17055, but was unable to locate him in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Christopher J. Isley. Complex secretary advises that current resident, Joseph Pompeo has resided at this address since November 2007. SHERIFF COST: $43.80 April 30, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-2502 Remit Corp. v Christopher Isley N r -± t? c eta n -r M c? -'`2