HomeMy WebLinkAbout09-2803IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs. CIVIL-LAW
VICTOR A. LEMUS, SR., : DOCKET NO.
Defendant
ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the
above captioned matter.
Respectfully Submitted,
THE REMIT CORPORATION
LAURIND J OELCKER, ESQUIRE
Attorney No. 82706
36 W Main St
Bloomsburg, PA 17815
Phone: (570) 387-1873
Fax: 570-387-6474
FILED-
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
DOCKET NO. D 9
a k a .3 CtL4 'Ll
VICTOR A. LEMUS, SR.,
Defendant
NOTICE TO DEFENDANT
TO THE DEFENDANT:
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Pennsylvania Lawyer Referral Service
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
,4 J.
4AURINDADA J. V ELCKER
, ESQUIRE
E
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
VICTOR A. LEMUS, SR., DOCKET NO. 0 9 - -2 90 3
Defendant
COMPLAINT
The Plaintiff, Remit Corporation, by and through its attorney Laurinda J. Voelcker,
Esquire, hereby files this Complaint of which the following is a statement:
1. The Plaintiff, the Remit Corporation is a Pennsylvania Corporation doing
business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania
17815.
2. The Defendant, Victor A. Lemus, Sr., is an adult individual residing at 97 Autumn
Lane, Enola, Cumberland County, Pennsylvania 17025.
3. Defendant obtained a Washington Mutual Visa credit card on or about May 10,
2000, from Washington Mutual Finance, (hereinafter "original creditor"), Account number 4465
6892 2523 2768.
4. Defendant used the extended credit leaving an unpaid balance of $24,601.77 with
interest continuing to accrue at 23.991/o per annum.
5. Defendant defaulted on the payments due and the last payment on this account
was made on or about June 29, 2007.
6. On or about December 29, 2008, Remit Corporation purchased the account of
Victor A. Lemus, Sr., from CreditMax Recoveries, LLC, the previous owner of this account.
The sale includes the transfer of all right, title, and interest in the account to Remit Corporation.
7. To date the charge-off balance is $19,220.32 and $5,381.45 post-charge off
interest for a total of $24,601.77.
COUNTI
BREACH OF EXPRESS CONTRACT
8. The above paragraphs are incorporated herein as though more fully set forth at
length.
9. In consideration of the extension of credit provided by original creditor through a
credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash
advances, fees and interest on his account.
10. The reasonable charges and expenses owing for the credit card purchases, cash
advances, balance transfers, fees and interest is $24,601.77.
11. Defendant accepted the extension of credit and utilized the credit card without
complaint, objection or dispute as to credit services provided, the prices charged for the same or
the costs incurred.
12. Defendant is indebted to the Plaintiff in the amount of $24,601.77. Defendant has
failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is
now due and owing.
13. Defendant's failure to pay is a breach of the express written agreement between
the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), a copy of this writing is
attached hereto, incorporated herein and referred to hereafter as Exhibit A.
WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the
amount of $24,601.77 together with interest, costs, attorney fees and such further and additional
relief as this Honorable Court deems just and equitable.
COUNT U
BREACH OF IMPLIED CONTRACT
14. The preceding paragraphs are incorporated herein by reference and made a part
thereof as if fully set forth herein.
15. It is averred, in the alternative, in the paragraphs set forth above, if an express
contract between original creditor and Defendant did not exist, that a contract implied by fact or
implied by law exists.
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 credit card to purchase items, and/or transfer balances, and/or
obtain cash advances 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 $24,601.77.
19. In breach of the implied contract, Defendant has failed and refused to pay the
outstanding sum for the credit card use and the same is now due and owing.
20. The Defendant has failed and refused to pay the aforementioned sum despite
frequent demand to do so.
21. By virtue of Plaintiff's purchase of this account and the assignment of all rights to
the Plaintiff, Defendant is indebted to the plaintiff in the amount of $24,601.77.
WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the
amount of $24,601.77, together with interest, costs and such further and additional relief as this
Honorable Court deems just and equitable.
COUNT IH
QUANTUM MERIMUNJUST ENRICHMENT
22. The preceding paragraphs are incorporated herein by reference and made a part
thereof as if fully set forth herein.
23. Original creditor provided the extension of credit as set forth above with the
expectation of receiving payment for all use of this credit including, but not limited to,
purchases, cash advances, balance transfers, fees and interest.
24. The credit extended by original creditor benefited Defendant.
25. The Defendant will be unjustly enriched if he is allowed to retain the benefit
resulting from his use of the credit card provided by original creditor without having to make
reasonable payment for the value of the benefits received from the original creditor's provision
of credit.
26. The original creditor was not a volunteer in providing the credit services set forth
above and the Defendant understood that original creditor was entitled to compensation based
upon his use of the credit card.
27. The reasonable value of the Defendant's use of the credit card including
purchases, balances transfers, cash advances, fees and interest is $24,601.77.
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 $24,601.77 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 $24,601.77, together with interest, costs and such further and additional relief as this
Honorable Court deems just and equitable.
PA ID #82706
Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
Respectfully submitted,
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EXHIBIT
A
were not eligible for the Account at the time it was opened; (2) you fall to pay
any amount due to us under this Agreement or any other agreement; (3) any
payment item Is returned unpaid; (4) you fail to comply with any part of
this Agreement; (S) any information you give us proves to be incomplete or
false; (6) your death, bankruptcy, or Insolvency or legal incompetence; (7) a
bankruptcy petition is filed by or against you; or (8) we believe in good faith
that you may not pry or perform your obligations under this Agreement N
you default, we may (urd prohibited Inv), without further demand or
notice: (1) cancel your credit privileges;by2) declare your Account balance
immediately due and payable; (3) charge you for our reasonable collection
coats; and (4) pursue any available legal remedy. In addition, in the event of
certain Aowwt defaults (for example, late payments), your APRo may
increase automatically up to the Default APR (see section 4). If you deta
the unpaid Account balance will continue to seen* Interest and other fees and
charges as provided in this Agreement, even f we have sued you to collect the
amount you owe. i we sue you or you am us for breach of this Agreemon, or for
any other claim arising out of this Agreemorrt, the prevailing aide may recover
reasonable sttorneyys fees and court costs to the extent not prohibited by law,
including attorney's lees and court costa In any action or proosecfing to enforce
a judgment based on a claim arising out of this Agreement If either you or we
sucoeaef* assert a setoff, oourtercla im, or partial defense to a aunt, the court
may vetiMold from the prevailing party all or any portion of the attorney's fees
that the court considers equitable.
17. Hots This Agreement Applies. This Agreement is the complete and
entire statement of the contract between you and us and will not be affected
by any oral agreement. We may delay or wane enforcement of any
provision of UYa Apiearnent without losing our right to enforce It
or any other provialott IIW You waive the right to presentment, demand,
protest, or notice of dishonor, any statute of imitations; and any right you may
have to mom us to proceed against anyone before we attempt to recover
from you. If any term in this Agreement is made unenforceable through law,
regulation, or court deaieion, all other provisions will remain in effect
18. Aesigaurearit We may transfer or assign our rights and duties under this
Agreement to a third party. If state law requires that you receive notice of such
an assignment to protect the purchaser or assignee, we may notify you by filing
a financing statement with the state's Secretary of State. You may not assign
your rights and duties under this Agreemenrt.
1B. AppNuwbM t,aw. No matter where you ihra, this Agrearne it and
your Account an governed
Ion of the, Unhod States arid,
to the extent not prompted y fe fedentl am; We Side of Nmdds.
This Alipaim nd takes effect when we aawpt it In Nevada. Wb
extend credit to you from Nevada regardless of where you ilve or
use your Aoeow&
20. Telephone Nionitaing and Recortift We treat all customer calla
confidentially. Your telephone oonveraetions with our representatives may be
monitored and/or recorded for quality aeeuranoe purposes, unless, at the
beginning of each telephone ooruersadion, you tell us notlion onitor or record the cal.
21. Telephone Conununicadons. You authorize is to call you or send a
teat massage to you at any number you provide or at any number at which we
reasonably believe we can contact you, including cafe to mobile, cellular, or
similar devices, and including cake using automatic telephone dialing systems
and/or premoorded messages, for any lawful purpose, including but not
mated to: (1) suspected fraud or identity theft; (2) obtaining information
necessary or desirable; (3) your account transactions or servicing; and (4)
Ong on your Account Numbers you provide include numbers you give us
and/or numbers from which you cd us You agree to pay any fee(s) or
charge(s) that you may incur for incoming coils from us, andfor outgoing calls
to us, to or from any such number, without reimbursement from us.
MARYLAND RESIDENTS: You have the right to receive an answer to a
written inquiry concerning the statue of your Account
NEW JERSEY RESIDENTS: Applicable law does not limit our rights under
this Agreement, except that we must send you prior notice of any increase in
the finance dirge.
NEW YORK RESIDENTS: This Agreement begins on the first day we extend
credit to you on your Account, as evidenced by a signed sales slip,
memorandum, or otherwise,
OHIO RESIDENTS: The Ohio law against discrimination requires that at
creditors make credit equally available to all creditworthy customers and the
credit reporting agerndes maintain separate credit histories on each wi ividual
upon request The Ohio Civil Rights Commission administers compliance with
this law.
Your BNNng Rbhts-
Keep This Notice for Future Use
This notice contains important information about your rights and our
responsibilities under the Fair Credit Billing Act
Notify Lis In Can of Errors or Omestlons About Ybur Bill
If you think your bill is wrong, or if you need more information about an entry on
your bill, write us, on a separate sheet, at our address for billing disputes listed
on your bill. Write to us as soon as possible. We must hear from you no Wer
than 60 days after we sent you the first bill on which the error or problem
appeared. You can telephone us, but doing so will not preserve your rights
In your letter, give us the following:
- Your name and Account number.
- The dollar amount of the suspected error.
- Describe the error and explain, to the extent you can, why you believe there
is an error. M you need more irfonnstkm, describe the item you are not sure
about.
If you have authorized us to pay your credal card bill automatically from your
dreokirtg account, you can stop the payment an any amount you think is
wrong. To stop the payment, your letter must reach us three business days
before the automatic payment is scheduled to occur.
Mail your letter to us at the address for bang disputes shown on your billing
statement.
Your Rights and Our Responsibilities
After We ROOM" Your 1M Itto Notice
We must acknowledge your letter withnin 30 days, unless we have corrected
the error by thin Within 90 days, we must either correct the enor or explain
why we belays the bilk was correct After we receive your letter, we cannot try
to collect any amount you question or report you as delinquent We can
continue to bill you for the amount you question, including faanoe charges. We
can apply any unpaid amount against your Credit Una. You do not have to pay
any questioned amount while we are irvaedgatlng but you are still obligated to
pay the parts of your bill that are not in question.
If we find that we made a mistake on your bill, you will not hays to pay any
finance charge related to any questioned amount If we didn't malty a mistake,
you may have to pay finance charges, and you will have to make up the missed
payments on the questioned amount. In either case, we will send you a
statement of the amount you owe and the date that it is due. I you fail to pay
the amount we think you owe, we may report you as delinquent However, if
our explanation does not satisfy you and you write to us within 10 days isQng
us that you still refuse to pay, we must tell anyone we report you to that you
question your bill. And we must tell you the name of anyone we reported you
to. We must tell anyone we report you to that the matter has been settled
between us when it finally is, If we don't follow these rides, we cant collect the
fast $50 of the questioned amount, even hf your bill was correct.
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Administrator's Rules. You can select the Administrator if you give us written
notice of your selection with your notice that you are electing to arbitrate any
Claim or within 20 days after we give you notice that we are electing to
arbitrate any Claim. If you do not select the Administrator on time, we will
select one. K for any reason the Administrator you or we select is unable or
unwilling to am or continue to serve as Administrator, or implements or
maintains a poky that refuses to wrloroe any part of this Provision, you will
have 20 days to select a difierant Administrator.
Startling an Adkil9m: You or we can give wren notice of an intention to
begin arbitration of a Clain or Claims or to require arbitration of the other
parly's Claim or Claims This notice can be given by one party even if the other
party has begun a lawaA K such a notice is given, any Claim will be resolved
by arbitration under this Provision and the Administrator's Ruin that are in
effect at the time the Claim is Ned with the Administrator. The arbitrator must
be a lawyer with more than 10 years' experience or a retired judge. A copy of
the Claim form may be obtained from the Admtniwator or from us. A party who
has asserted a Clain in a lawsuit may still elect arbitration with moped to any
Claim that is later asserted in the same lawsuit by any other party. AN doubts
about whether lo arbitrate a Claim shall be resolved in favor of arbitration. We
will not elect to arbitrate an individual Claim that you bring against us in 'seal
claims" court. However, we may elect to arbitrate a "small claims" court Claim
that is later removock sent, or appealed to any dii ferent court.
t00@
IF YOU OR WE ELECT TO ARBITRATE A CLAIM, YOU WILL NOT HAVE
THE RIGHT TO PURSUE THAT CLAIM IN COURT OR HAVE A JURY
DECIDE THE CLAIM. ALSO, YOUR ABILITY TO OBTAIN INFORMATION
FROM US AND TO APPEAL IS MORE LIMITED IN AN ARBITRATION
THAN IN A LAWSUIT OTHER RIGHTS THAT YOU WOULD HAVE IF YOU
WENT TO COURT MAY ALSO NOT BE AVAILABLE IN ARBITRATION.
THE FEES CHARGED BY THE ADMINISTRATOR MAY BE HIGHER THAN
THE FEES CHARGED BY A COURT. THE SAME LIMITATIONS ALSO
APPLY TO US. IN ADDITION, IF YOU OR WE ELECT TO ARBITRATE A
CLAIM: (1) NEITHER, YOU NOR ANYONE ELSE ON YOUR BEHALF CAN
PURSUE THAT CLAIM IN COURT IN A CLASS OR REPRESENTATIVE
ACTION (SUCH AS A PRIVATE ATTORNEY GENERAL ACTION);
(2) NEITHER YOU NOR ANYONE ELSE ON YOUR BEHALF CAN
PURSUE THAT CLAIM IN THE ARBITRATION ON A CLASS-WIDE OR
REPRESENTATIVE (SUCH AS A PRIVATE ATTORNEY GENERAL) BASIS;
AND (3) CLAIMS BROUGHT BY OR AGAINST ONE ACCOUNT HOLDER
(OR JOINT ACCOUNT HOLDERS) MAY NOT BE JOINED TOGETHER
WITH CLAIMS BROUGHT BY OR AGAINST ANY OTHER ACCOUNT
HOLDER THESE THREE LIMITATIONS ARE HEREINAFTER REFERRED
TO AS THE'CLASS ACTION WAIVER'
: Any arbitration hearing that you attend will take
place at a location reasonably convenient to where you live. If you carrot
afford to pay the fees charged by the Administrator and the arbitrator or If you
beiave that such fees are too high, we will consider in good faith any
reasonable written request by you for us to pay the fees. We will pay any fees
or experaes we are required to pay by law. You will never be required to pay us
any fees we have previously paid to the Administrator and the arbitrator. Each
party met bear the expeme of that pariy'e attorneys, experts, and witnesses,
regaddess of who wine the arbitration, except to the extent that applicable law
or the Administrator's Rules provide otherwise.
?IW-L- This Agreement involves interstate commerce and this
Provision is governed by the Federal Arbitration Act ('FMI, United States
Code, Tdle 9, Sections 1 and the following. The arbitrator must follow: (1) the
FAA; (2) the substantive law, consistent with the FAA, related to any Claim;
(3) statutes of imitations; and (4) claims of privilege rsoognbed at lawn. Upon
the finely request of either party, the arbitrator must provide a brief wrillm
explanation of the basis for the award The arbitrator will determine the rules of
procedure and evidence to apply, consistent with the FAA, the Administrator's
Rules, and ;tin Provision. The arbitrator shat not apply federal, state, or local
rules of procedure and evidence or state or local laws concerning arbitration
0b1910 m Information: After an arbitration has been started, in addition to a
party's right to obtain information from the other party under the
Administrator's Rules, either party may request the arbitrator in writing to allow
that party to obtain more information from the other party. A copy of such
request must be provided to the other party. That party will then have the
chance to object in writing within 30 days. The objection must be sent to the
arbitrator and the other "The arbitrator will decide the issue, in his or her
sole discretion, within 20 days after any objection to providing expanded
information is submitted.
Effect of Arb,ihellion Award: Any appropriate court may enter judgment upon
the arbitrator's award. The arbhrabr's decision will be final and binding, except
for any appeal right under this FAA and eooept for Claims involving more then
$100,000. For these large Claims, any party may appeal the award to a three.
arbitrator panel appointed by the Ad m nistrator. That panel will consider all
over again any part of the initial award that any party asserts was incorrectly
decided. The decision of the panel will be by majority vote and will be final and
binding, eudoopt for any appeal rigid under the FAA. Unless appic:able law
provides otherwise, the fees charged by the Administrator and the whiitratore
for euoh an appeal will be paid by the appealing party, regardless of who wins
the appeal However, we will consider it good faith any re iawbie wrban
request by you for us to pay such fees. AN other provisions of this Provision
shop apply to any appeal to a thre&arbitrator parcel, and any reference in this
Provision to a single arbitrator shall apply to the t vwwbkmtor panel.
Cwtinued Effect of Arbitration Provision: This Provision will remain in force no
matter what happens to you or your Account. For example, it will remain in
farce even if: (1) your credit privileges we carded or put on hold; (2) you close
your Account; (3) you repay your entire Aocouni balance; (4) we begin a
lawsuit to collect amounts we think you owe; or (6) you beoome bankrupt or
insolvent or a bankruplcy or insolveroy proceeoCrrg is begun, to the extent
corWoW t with applicable bardwploy law. K any portion of this Provision
(swept for the Gees Action Waiver) cannot be orrioroed for any reason, the
rest of this Provision will continue to apply. If the Class Action Waiver cannot
be enforced for any mean in a Claim between you unit us, then the errtae
Provision shah be null and void for purposse of that Claim. 04owever, this does
rapreclude cl party from fromt appealing g to a court whether the class Action
any owftt or inconsistency between
this Provision, on the one hand, and the Adminishabor's Rules or other
provisions of this Agreement, on the other hind, this Provision will govern. This
Provision will supedcede and replace any other Arbitration Provision between
you and us.
Please rote: This Arbitration Provision does not apply to your Account If you
have previously opted out
If you have a question about the arbitration companies who may serve as
Administrator, would like to obtain a copy of their arbitration rules or fee
schedules, or would ice a Claim form, you can contact them as follows:
National Arbitration Forum, P.O. Bar 60191, Minneapolis, MN 66406,
www.a1646nim.cam; American Arbitration Association, 336 Madison Avenue,
New York, NY 10017, www.s&.orp. You may also obtain copies of the runes
and Clain forma of the Ackninistrators by contacting Customer Sevtca.
7109
02ow Wt"" MuhA Ira. NMA0200
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. Str sser, III, Remit Corporation
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs. : CIVIL-LAW
VICTOR A. LEMUS, SR., DOCKET NO.
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
The Defendant is not now in the Military Service, as defined in the Soldier's and
Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within
thirty days hereof.
y)q,ld
Dated this ay of
/f (I j '2009
44 Alm 9 01 zle
Laurinda J. Voe c squire
Attorney For Re t Corporation
Attorney ID 82706
36 West Main Street
Bloomsburg, PA 17815
Phone: (570) 387-1873
Fax: 570-387-6474
12equest for )Military Status
Department of 'Defense Manpower Data Center
Military Status Report
Punmant to the Servicemembers Civil Relief Act
Page 1 of 1
APR-30-2009 05:10:16
,< Last Name :First/Middle Begin Date Active Doty States ScrviWAVacy
LEMUS, SR. VICTOR A Based on the information you have furnished, the D o[DC 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.
A
IV,?
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
LISCS 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/faa/Dis/PC-09SL.DR.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: BIVIEMFAUTBE
https://www.dmde.osd.mil/scra/owa/scra.prc_Select 04/30/2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
: CIVIL-LAW
VICTOR A. LEMUS, SR., DOCKET NO.
Defendant
CERTIFICATION OF ADDRESSES
I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows:
Plaintiff: Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Defendant: Victor A. Lemus, Sr.
97 Autumn Lane
Enola, PA 17025
Respectfully submitted,
Laurinda J. Voelck squire
Attorney for Plaintiff
PA ID #82706
Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
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P, 2.?y4LY
Sheriffs Office of Cumberland County
R Thomas Kline b.°ow .at Gam4mvt''o Edward L Schorpp
Sheri r Solicitor
Ronny R Anderson` Jody S Smith
Chief Deputy QFFCE OF THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/28/2009 12:07 PM - R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a
diligent search and inquiry for the within named defendant to wit: Victor A. Lemus, Sr., but was unable to
locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the
defendant Victor A. Lemus, Sr. The Enola Postmaster has advised the defendants new address is P.O.
BOX 354 Hollidaysburg, PA 16648. An exact address is not available.
SHERIFF COST: $46.50
May 29, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
2009-2803
Remit Corporation
V
Victor A. Lemus, Sr.
C-.- -n
M