HomeMy WebLinkAbout09-8647IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs. CIVIL-LAW
GLENDA M. BEAGLE, :DOCKET NO. 0 `/- SL `/ 7
Defendant
ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the
above captioned matter.
Respectfully Submitted,
THE REMIT CORPORATION
LAURINDA J. VOXCUR, ESQUIRE
Attorney No. 82706
36 W Main St
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
GLENDA M. BEAGLE,
Defendant
CIVIL-LAW
: DOCKET NO.
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
LAURINDA J. V'PELCKER, ESQUIRE
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
GLENDA M. BEAGLE, : DOCKET NO. 09- 76 V 7 C?t,? T-?..-.
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, Glenda M. Beagle, is an adult individual residing at 1710 Market
Street Apt. 19, Camp Hill, Cumberland County, Pennsylvania 17011.
3. Defendant obtained a Visa credit card on or about October 19, 2007, from
Providian National Bank, (hereinafter "original creditor"), Account number 4185 8617 0551
9266.
4. Defendant used the extended credit leaving an unpaid balance of $1,715.29 with
interest continuing to accrue at 18.00% per annum.
5. Defendant defaulted on the payments due and the last activity on this account was
on or about July 31, 2008.
6. On or about June 26, 2009, Remit Corporation purchased the account of Glenda
M. Beagle, from Riverwalk Holdings, LTD., 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 $1,378.72 and $336.57 post-charge off interest
for a total of $1,715.29.
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 her account.
10. The reasonable charges and expenses owing for the credit card purchases, cash
advances, balance transfers, fees and interest is $1,715.29.
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 $1,715.29. 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 $1,715.29 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 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 her 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 she received the same to her benefit.
18. The total reasonable value of the Defendant's use of the credit extended by
original creditor is $1,715.29.
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 $1,715.29.
WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the
amount of $1,715.29, together with interest, costs and such further and additional relief as this
Honorable Court deems just and equitable.
COUNT III
QUANTUM MERIUT/UNJUST 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 she is allowed to retain the benefit
resulting from her 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 her 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 $1,715.29.
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 $1,715.29 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 $1,715.29, together with interest, costs and such further and additional relief as this
Honorable Court deems just and equitable.
Respectfully submitted,
Laurinda J. Voe ke , Esquire
Attorney for Plaintiff
PA ID #82706
Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
VISA CLAS5ICm-
PRO VZDIA T NATIO
NAL
BANK 4. Finat[ce.charges Finance charges begin t? accrue on a debtr when is is atclwxled in
d- daily balance ("Balance
J a+a_ eoltonue' to cite uitr l the B
l
rcF
cl
ACCOUNT AGREIIENT a
ar
ia
uded
Payment or edit: The Balance is ;educed by u
payments as of the dale'{eceavt acid by a
Sara[ (exr epi for reversals of lace aver
!tort and m
li
a e
..
Your VISA Classic credit aceoune (the Credit Ed Account ) a({o
' isce
aRequs charge,) as of the d
acted. Debits other than:fuwtee'c}acy?s am Iric(uded in the Balance' as folksws cash
advances from financial ttrsntutions and from Automated 'Pellet M
chin
`
d
h
pu you to make
- purchax. by us, q yourVISA C!attic card. tha "Card`) tvherevei it u honored; and
: . 1
to'get cash advances tro a
es
,
prr
p[uc
tcsn as of the date made: other debits (accept for late over-limit Apance' acrd ,
rnwcellarieouus clta ges), as of -the dote pctsrad Finance ?
are added to
p
r
j a
c
?
'
r
ut any pariicipatmg Ill iancial institution In;cltu Agreement,
you and `your mean each person for ;whom we have o t
d
C y
?
a
,
a
h day acid arc then acted on
rhe last day , ? bn(lirg
i
cy
cle
To. figure the daily finance
start W
a
a
redit
y aril
Account "We Pene
Our "ours, and.-"usmean.Pcovidian Nananal Bank (fonneri First
De
o
N E Your Previousday s B nce
d b
a ubtra
-1 ala ado all
current, day
}u f?r the
Cas explained in the paragraph
bCve) and
thtn r[iulti
l
?
p
sit
ational Bank) o
r eta usegner Any use of. this GedirCard Acc6unr
coiutitutes acceptance of chi Agreement The Credit:.Can3 Accoun
b .
am
p
y
t
cosr -S. Y fhe daiANNUALly'penadicPERCE1t1tare The daily .
per; ac ca rd it 0060296'
iod (il dlrtg to an .TAGE BATE
of 119996}- if your Accaint is not in
ood
i
d
t rnay,
e:uxd
only fI personal farntly.houuhold , qr r}ctrirableo '.
utpace{, and not for smY busine.s
Of commrctal
d
Y
g
sta
i
in be yore baudnot arierr6e
tctmsr nhi greemeni, the dai[y cause
'penodic rate it be increised to 0065796
feat di co an A W
L B E
A
In rea
ed
_putp
we.
qu and we agree as follow, - .-
1
Se
l ,&
RCEIVTAGE R
TE
r
at )Hop ever ,
after your Account has been in good staridntg fox anx months
Your requ
ei
a
.
curity
nterar in $a
-P Account If you.ppen aavi
Sngs:Acrounryou gram us
a securiry interest in the Savings Account-to th
full e ,
r
est we m
y
nstate the lower rate: The fMnce i ha
Balarue Dye, vest a credit ba * ra.Ml to, grid included. in, that clay,
da
it £or an
'
e
xrent of the balance in that`
xcouitt (the."Pledged Balance) Pledged Balar" farads will
Femain yours as long
' as your Credle.Carti Account u In good
d
a y
y of to
We determine rF?e finance
rJia
Rfs on balances fvr'the:brlling.cya by adding together the Fu atue chrge"fw
each day within the billing tycie. T
d
a3
i
e
;tan
i
nd
The xcurity'interesr will searre die - YOU comply. With t{in'?rerineitt
all of rh payment oaEl yuur.o6ltgatwns uixjei,: aril your
crnnplmnce with
v a
eterr
cin
the average daily balanct . _
o . ,
your statement add eaclt.day'i Balaned (Inclirdin dail f[nance.chs
cycle and di, d
h
n
b
)
,
pm
isions.uF-this Agreement In case of deilautr, we niay,
without notice, apply ill 'or any..portioni of your Pledged $alance,agdins[ any
outstanding balance dui oil
C t
e
um
er :of days in the billing cycle. You'cart
`mu p ydiis
average daily balance by the numbecof days in, the billing cyclc.arid by'ch
periodic rare to
q 'daily
determine r
ine th
a
oi
n
youf
redni..Card Act cunt. You wilC not'be able m
rhdraw funds, from the Pledged Balance unless we nq longei`requue you to maintain a
Savings Account or you do
-
u
C m
e
nt
j
t of your finance charges.gn.balartces fo
r [liar _
Ill
billing cycle. iitig finatice:.chargerr in..dtuata,enc will Lie made, f_r any:
transaction or meat
h
o
Pay
ld
se
yo
r
redo Card Account Provided.
A
ount has bee YCredit Card
n
the paid iii hell you will be able tb wtthdnwali retnaini (ands (tom
Pledged Balance t
e
i
fi .
t
at w
u
have affected the finance ch . cal .
a' culaii . in`a
cc
prior, billing cycle had it been posted in that. cycle lfa:cash advatace"
or credrr line.
inerea
e f
d
a
?
t
w
r
ry-
ve (25) drys after You notify ua:tneuriting i
you t chat
Wish
..
to duseyoiR Credit Card. Augmr, you destroy ymrr Caryl sti? we have verified d to our
satisfaction that
all fiu
d
h
' .
s
ee
s ch
rged, (see Fees, .seccion`6);.thar imou
n
,
'alsb a
isno
inance charge. There nod 'wtehin wh ich credit extend
ed may be repaid
wndtour incurrin .. a fin
n
haz
.;
n
s.yuu
ave sent wa aie
valtd, Yai will also have to -
additional charges that arc. pay any
pared to. your Creda card Accoutre after is leas been closed.
2. Promise to Pay.
You
promise t
h a
ce e
f
- g ge - - ,. `
The balanceamdun[s shown on your statement
d
t Y may rffa from the Balances rued in
trig finance cha a
?
.
pay
o cis w
en dire all amounts bor.mu Q when you
or itimcone else uses Your Credit :Card Accginnt (even if the amou
t
h
d
n ony Late, river irmi4:or
neoiu charge. that anc
utcluded matlte balancotshou
wn'
x
Yourpen
n
c
arge
excacis
iashin);allntherttanvcnonsandchar
collection costs we incur; include but riot limited rb ea k?t%tnAeY gild
n8a
c
urt
If
.
Your
tu
pt`..'
Si .Changes: We may change an
re
qu
iremeno after notice as requited by lap !fuels Agreement of add or remove
t
o
costs. (
seasonable aitorncYsue 's fo%s4 w collet[ the debt`and you ,vin the curt, We will pay your
we 3ndcourc coats ) tton ,4; the ne w finance
ch
arge
latlatron' will. aI "g I
eRective date of the changi y ro Your thole Credit Grd Account balance.frvm.the
3. Payments. You will" receive a monthly statement showi your outstan
ding
balance. . You will pay ru in U.S. dollari
(checks
m
s
b
' Cre and d Accobefou' he chanet.dareatid whether or not
You tontmue tti use
the Credit Card Account.
e ar
.
,
u
t
a US. office of the
bank. the click is drawn dttJ at least the payabk
the payinent due date in' accordance' w hYment.due as shown on yarn statement by
pa
ment i
u 6.: $eea The followingfees will be charged m -
Your Credit Card Aaounq An gnaw{:
fee of $59 every 12 months; f
ea
h b l
y
nstr
statement. The
ctions. on your monthly
peymenr'due will be: 3964 the 'new balance showrron Y
plod die'utxisritt of any pasi due Your statement
! enr
'Alt*- nce arrwonnt by w
cb or
c
li
rag cycle within wlttcli yuirr Credo Card
. '
Account is delinquent (late fee); $ZS, for each billing :cycle withrn'whrth'yotir, ;
balalice exceeds your credit line (over
li
t le
_
he
exceeds
the ixw balance
yourcredit line, plus fees for cetta m optional services However; 'the
due will not be leis, dun 415 (tole,, your niiv bal
n
ua
h
15 iiin -
mi
eX25 forcaah advance,: a ttarisaction'
fee thae is the grratei of S3 of596 of tfie'caa}t ,adyance amount f
that. a
.
return
ed to us
ip
id
b
i
a
p
ce is less than 515, in wl
c
the Paymco due will di
case
mr of rite new balance . if your
the
t _ than
WTI be o eared as a si
l
tlU
i
n
e
pa
e
on
a
(
olineed:.check) $20 each ri me
the item ix retu
un
a
id
; for a
m
se
id
Card i$ired on your Account : pn a dditional S25 annual lee for
thatCard for
C
rd
e
ng
e PaYrneitt and Wane of r
future
l
m
n
be Applied to. '
P
Y
is due
a
s
a
s s
nt through an etcpns atatI.strvwce we ma
Card you ask:tt to replace, we may ch Y ehaiBe:$22 for each:
31 acid f
'
When we receive your pay
cherlc, u e may at our discretion kee the
P check and .
presrnr it ?kA to the financial Inatrtutuin ore nhi
h
h
d
he
k or ooAfea
of back eacxno thai'
were first 3c t to you more dean three
nwotidna cachet; we rest ch?fEe $3 fbEor each COPY
Your Credo Card Account will f
rma
'
O
e
t
e
c
o so, we will provide c
is ctnum. If we
you wadi a copy of the check at,your request
ifyousendismoney wtrh
i
f
If i
Y be
tevievted for an unsecured' credit line
increase every
try six months. Fach ricrac we Increase your credit,-Ime as a result of this .. '
review, we
may char
e
le
of
o
rt
ying whether a ss a deposit to your Savings Acewnt
a payment on speci
t your Credit Card Acciiurit we will detetniine, at our d5
A
or . matey wil attion, which `
ccount(,) he l be appliedm::. We i ns urs
" Y pt
re o
l .
g
a
e
up to 512:.'
(!n addition
you paid cone-ante enrollmen
t fee in order to open . the Grader Card
Account The amount of
chat fee
was d
l
.
r partia
payments marked
payments, or
ltd m fuU° or marked with o[fxr reatricriotts, without losin
right I. wllecc
(I
'
m
u .
,
isc
osed in the solicitation niatenal yo
received.)
u.'..
a
g arc
a
aw
s ow . .
u+8 Milder this Agreemrnt .:
.i
EXHIBIT
A
7, Credit Line. Your credit line is specified from;ntne to time in a separate notice. We
may increase of decrease., your creditline based on infottnation we obtain from you or
your credit `eccx. & Your available credit; is no m?lly chi difference between your uedit.:
line and your,C[edreC3rdAccoimt'balance (PnClWingiruuacdogs'madeor autsoriied:
but not yet posted) [f you send us a `largt pa.Ytment r, liec ..k; we may limit, your available'
credit whsle we atnfrcin. that the cfieck.will clear For. certain transactions, available
credit may be less You will not use your Credit Card Account for and we may refluetb'
horror any transaaton ibsec would rasne you to eiiceed your a'va table credo
S.,Foreign EAt hange/Currency Conveniori if,you use your Card-for transactions in
a currency other than U,S. dollars, the transactions will be converted to U.S. dollars,
gciierally, using either il..M government mandated rate or .(ii) wfiolesale market race
in'effecr the day before the transaction processing date,:inciewe'd by one percent
(I%) ifa.creditis'subsetjueir[ly'given for a rr.anaactson,'it will"be;decreased by one,
peiicrnt (1%). ifthe uedit has a diffeccnc processing dace; :then the exchange rate of:.
the credit can` lx gre'atetlless`than that. of the original transaction. The Currencyfore: -the transaction.-processing date .ntay differ „from
the rate in'effect it the time of the rransiciion of -on°the date -the transaction is.'
posted to yoirr;CredirCard Account. You agree co aepithe converted amount in
U,$ dollars
9. Merchant 13elations :We will not be liable if an_y person or Automaced.Tdler.:
Machine refuses to Honor the:Card or fails to'tetiun the Card.to you. We have no'
respottslbili.ry-for goods and services purchased with the Card except as required by
law., (Sec special Rule below )
10.714 Card;.Qtncellatrun You, will renun'the bird to us 't our request Thc Card
eipires,at,the, end •0f the'. month.shown on' It.- We have the right not co renew the
Card At any iime afterai least 30 days notice ioyou, or without notice if permitted
by law, we may'cincel the; Card and your credit privileges.'If your. Card is "cancelled or
not renewed, finance: charges and 'other Pecs will continue to be assessed, payment
wilt continue to :be dui,. and At Ether applicable provisions of this Agreement will.'
remain: effect You inay cancel your'credit privileges by`notifying us in writing,
destmying the dar slid paying your entire statement balance by the date indicated
on the staterrient Alai includes your 'fmal purchases, cash advances, charges; and fees.
Your credit privileges. will be cancelled. You will still bd responsible for paying any
accrued finance clwges; and additional charges:
11.-Personal Infarmanorn Documents. Ypu.svill give us'at least 10 days notice if ynu
change your rrpw bome,a marring address:. telephone numbers,.income, or job. You
wilPprrnnpelyigive u:;i;lkimaROn about yourfinancial affairs if we ask for it. We may.
get; such informanon 66ai others; in cluditig.credit reporting agencies, and provide. .
your address and mfomtation about your Credit Card Account to others. We may also`.
- share infornid toil wi 7i a ?r affiliates Hew Ve; vac ` tray write to d
Inatnrcttnv not toss redit 'n(aem [ion'ab c yo- and vngCAccount v k
ws'affdtata• 1f you fail to fulfill any of your.obligaiions under this Agreement, 'a .
neganve credit report reflecting on your credit record may be submitted to. credit
reportng aeenciec _ ;
17: CtrStarner Seevue; Unauthorized Use, Loss; or 77ieft of the Card. Each Card '
must be sigr(,ed on:receipt You will safegoard the Card. and your Personal
Identibcatiorr Numbet MN), which provides iccats to Automated Teller -
Mai.chines f wit theft. You will keep your.-PIN separate from your;Card. lf'you
d'e:covet or suspect that,the'Card. is ipsr-oi stolen, or that there may bean,
unauthorised ttaneaenori Air your Credit Cana Account; you. will notify us promptly,
by telephoning, 1413QO-356.0011. You will phone, even though.you may not us in
writing so'we can act quickly toaimii losses and liability. Your.liability,for
unauthorted tic. occurring before you notify us is limired to 550. 1t you report;or we .:
suspect unauthorized use of your `Credit Card Account, we may suspend'your credit
privileges, until.we resolye the problem to our satisfaction or issue you a new Card.-
To improve cusrorn service and security, you agree, that your calls. may be
monitored or recorded
3
1'3i.Standard of Care. Transactions in Your Credit Card Account will be processed
plechanicallywidtouc our necessarily reviewing every item: Our processing system
will call out attenr5on to certain items that we will examine. We will examine all
asinsactioru when you report that your Card has been lost or stolen- We.do not
intend ordinarily to examine all items; and we.will not be negligent if we do not do
so.-This rule. establishes the standard of ordinary care rhat.we in good faith will
exercise in administering your:Credit Card Account. Because of our limited review;
and because your Card transscrion slips, will not6 returned to you. with the
monthly statement, yuu shoidd be careful to keep a record of them. You should save
Your cash :advance and pufchase slips..You agree to check' your monthly statement
against your record and to notify AS promptly of any unauthoracd,transactions or
'- errors. -
14. Default You will be in defaultd if you wete not eligible for the Credit Card
Account at the time it was`opened- if you fail to pay any amount due to us or to any
other' creditor, if you fail io comply with any part of this Agreement or the atnched
Savings Accaunt Rules if any informati on you gave us proves to be incomplete or
faLa upon your death, bankruptcy, or insolVency; if a bankruptcy petition is filed by
o; agairut you; or if we believe in good faith that you may not pay of pericirm.your
obligatioru under this Agreement.On,your default, we may; without further demand
or notice, cancel your credit privileges, declare your Credit Card Account balance
'immediatelydue and payable; and invoke any remedy we may have. In the evciic of
your default, the outstanding balance on your Credit Card Account shaH continue'
,to accrue interest at the'Annual Percentage Rate(;) 'disclosed in the Finance
Charges section of this Agreement, even if we have sued you to collect the iinount
you owe
]$. Waiver of Certain Rights. We may delay or waive enforcement of any
provision of this Agreement without losing ouvright to enforce it or any other`
provision later. You waive: theright to presentment, demand, protest, or notice of
dishonor; any applicable statute of limitations; and any right you may Kaye to
require us to proceed against anyone before we sue you. •
16. -Applicable Law;' Severabiiityi, Assignment. No matter where you live, this
Agreement and your Credit. Card Account are governed by federal law and by New
Hampshire law. This Agreement is a final expression of the agreement between you
and its and may not be contradicted by evidence of any :alleged oral agreement. At
any time. after, we determine in good faith that any proposed or enacted legislation,
regulatory action, or, judicial decision has tendered or may tender. any material
provision of this. Agreement invalid or unenforceable; or impose any increased tax;:
reporting requirement, or other burden in connection with any such provision tot its
enforcement, we may, after at least 30 days notice to you, or without notice if
permitted by law, cancel the Cana and your credit privileges and declare your Credit
Card. Account balance. immediarely.dueand payable: lfany provisiop of this
Agreement is held to be invalid'or unenforceable, you and we will.consOer that
provision modified to conform to applicable law, and the rest of the provisions in
the Agreement will still be'enforceable,. but we will have the right to cancel.your
Credit Card Account and declare your balance immediately due, as provided in the,
preceding' sentence: We may transfer or assign our right to all or some of your
payments. If state law requires that You receive notice of such an event to protect
the purchaser or assignee, we may. give you such notice by filing a financing '
statcmerit with the states Secretary of State.
17 Notices, Other norices.to you shad be effective when deposited in the mail'
addressed to you at the address shown on our records, unless a longer notice period is
specified in this Agreement or by law,.which period shall start upon mailing: Notice;
to us shall be ritaiied to our address for Customer Service on your statement (or.:
other addresses we may specify) and shall be effective when we receive it.
Your Billirsg Rights-Keep This Notice for Future Use
This notice contains important information about your rights and our
responsibilities colder the Fair Credit Billing Act. .
4
Notify Us in Case of Errors br Q.. stwna About Your Bill
dl wna
1(y° think Pour b is ng, or-1f you need mom informar, about an entry on daily balance
method to calcu ace the interest ori, your Savings Account. This
merhod app) od
ia a periic
tare t
h
v
v xu bill write i+s on a
separate sheet at out address for Customer Service listed
on Your jsill: WnR tows oa soon as posnble.,We must tieatfrom you no ht
'd
a ,
o t
e a
erage daily .balittr a for the
av
t flail balance ytiod .The
a+E . g if calculated by adding d,r pr(i,c,pal tn;dse Saves Account
for eaclCday of the;
ertod
di
'
nd d
f
er
t
n
60 days after We sent You the fist bill t which `the error of roblem a
:can cele P ppeared.:You
phone us butdoing it, wail not
r p
ivi
ng
that
a
ikpre the number of
nod ` PZ E Y depezsd. ' days die',
Pe stitetesr rate. afid'annual mots a leki css the amount of
p
eserve.your ri?rrs.
In your,
lecrer,
give us the following: .
your fialarsee on the last day''of each statetnentpertad latetest ucntes;
and. is.
c
ompqunded monthly tnte
ar
d
-Your name and Cowin Card Account numbs u cR
re
ired to Your $avsngs Account at Elie end of
each monthly statement period and Wheri.todi Sivii* Adcouni is doted : .
-The do11u'aitwunt of the creel
suspe
error '
Depostnng Money Weanay rcquirE a mmrmum balance,ot you
to o
en
-13aatbc;he error and explain tf you ran wh'r- You 6elteve there is an error If
ou .
p
the s?aYlltg5 Account, if so ti1E minimum'
o!g deposit amoui4t will be'shown
y
need mote i,karnatfon descrsbe'the item you ate not sure about :..
Your Rights'and bur'Res
on
ibili i Af an a
?? diseksure To inalte a deposit you rt?y ifnd money, orders or'checks
d?+`?R-on U.S. fiiianctal tnstitutsotis in
U.S. ollars to p Q . B6
a Til
p
s
mr;We Recave Your Written Notice
- We must acktiowledge_ your lecmr,wirhm'30 days unlesl we ?taye corrected the
;
e
b
h
r _
x
ton,
?' Ha psb{n 43276-0800: Such a deposit !vi girtieammg jnt,,66 6.?bu?ss.
day aket;dx date tecuved
If
you smd;us rndtey wttlsiiut s
etlf
in
h
i
i'
.
or
y t
r
eta: Within 90 days we. must either i orrect. the error or'ezpI a, whywe -
believe the bill was correct Akec:we receive' your letter; we cannot try to:collect
.
n p
y
g w
et}
a;i
s a
rm
Acco
depostrmyauSavutgat:orapaymcntonyo' ( d'[1 a Aaosini,.wewill
detetmtn e. aii
d tWn to
which Accamt(s} the
wilt f
'
a
pamountyou quesu6ri
? report you as delsrigiient We ?n continue to bill you
for:tkie amount
ou
u
s
i
n
l
if
n
' •
,
>e a Ifed:_We
^Y PP
to
may not adept for depomr any item
thou ismade txu Qo a
'
y
e
t
q
o
uit
u
i
g
nairicrel,aeges We can apply any unpaid
amount agaaur your credit line you do not have to any,
Pay. quest oned amiwnt
while we are'{rivest tui b
ll You 6t to
.us We may a,dorie and depaa i items (o( m
;-ive yoeSsar rive '
wher, we tecetve your dick for
de it
ay ataui dircretion keep the dteck
ut
E you pre ah
obligated to paY Elie parts of your bill
that
are not in questwn': Arid present it t tothe
fmanc;al irienN[tot# on which the It
drawn.
if we dui so we will prov de you with a copy of the check ai
uE
re
i
s
If we irid than we made a mistake on ur bill you will.not hav : e',ro pay any
Yo
fm'siwrehaEge related to an
ues
fa
d
m
' y
¢
quest+W
re
tive
the right to tefisse deposits For any reason :We reserpq;the'righi to limit the total
balance m, your Savi
A
c
u
y q
[
ne
a
ount. If we didn
t male a mismke, you
rosy have. to pay finance clfarges,: and you will have to make up the missed' ngs
c
o
nt to $5,000 If we Reeive a deposit slur causes
your balance to exceed $5;000 weay at'oiir:option,,return the funds
F
payments on the questioned amouni; In either i:ase we will
scud you a smtenient
of the amoiinryou owe arxf
he da
e
h -
ro
you
` •
p
t
t
, t
at ire due. If youfail to pay the ainpiint wt
think you owe,'we re
may
- Port You as delinquent Howevtt, if Drat exp3anation d
e
ledg Balance Restrrcted Withdrawal. At the' rot yvu open the Savi -
- cc9unrou gent to us a
tunry interes[
A
ll
f
h
o
s -
not satisfy
youstud write to us„within 10 days teliing a th at you still refuse to
ay,, we must tell anyone ire reportyou to that you question your . bill: And RYe
[
rus tRll
h
" .
to a
; o
t
utg.balance in: t th
e x9m
e
&M
not LOCOUn
stud
rl any3u -9uent deposits we act iiis nor,witfidraw '
You'
any fus from Chu Savings Account-except as described in these
Savi
rg
A
' ;
Your t
e nott
of anyc+nrwe reported you ua; We must. fell anyone-we
tcpOn you .to that
the matter has been settled between us when it finally is. If we
don't follow these rules
' We
c
ll ,
s
a
ccount
Rules-Th$ Savings: Areoutit balance lus been led b
ob[, ariotss on a yoat-
E your C
redit CardAccount, as set kserh its die Credit Ct rd Account
;
.
tan c
o
ect tlte:finrt j50 of,ihe questioned amount,;.
eL
en ifyour bill was correct., , .
grcernent n case of defaul t we may; without notice; gpp1Y your ple dged Sa
Account balance against your
Credit Card Accou
b
l
i
Species! Rule for Credit Caid Purebases
' .
nt .
a
ar
ce You may with w
the Pledged Balance ":the Savttigs Aceunr 25 clays esker liavtng notified us
If you have a problem
-wit h else qualtry. of the goods or services that y6, purcfused • , .
with ouucreds[ card and y6 u have
tritd m
1 °°d faa
to c
ti
h
th ish d
or Y(,- w tO c l m Credit Caul Account yai have destroyed your Card,
all-amounts due lrave'b yourem paid m full, and we have verified'm'oui satisfa
ti
n
,
g
ect t
e oblgni with -
the inerchaP?y
you may not have to the remaining amount due on the rods
T
r
i c
o
[ha[ all funds you have sent us are valid. In add,aon under fe8enl regulations; we
'
o
serv
ces Then are two lima aeons on char right, (a) You.musr hive made the
Purchase in your home state or r<not w
hi
o must reserve the rght
to require seven days notice before you igirhdraw stay money .:
from. the Savings Account
it
n y
ur Mme state; within ]00 rode: of
grnir cuumr mailing address and (b) the purd,ase price.miisr have been more.:. , `-
than $50.- Lmitatioru Jo not'apply ifne own
at
he
4 Statcjnectts We;willsend you a monthlysratemenrihowii the interest carri ed '.
during dse
perrod; up to the stateme
t d
:
t
h
n
f
or oper
e t
merchant or iF: -
We mailed You -the adv kistinent for the prope - -
• rty nor ser* s••' .
n
e;
a
t
e a
nua
, percentage yield,eamed, =.
and all transactions ielaied to the Sayings Account. - ` -
SAVINGS ACCOUNT RULES 5 Errots.:Y6U i4:noti[y us within. days esker you receive a statement if any„
truisacnonahown omit is incorrect
The f°IION"rtR s if y hour a Sosingr Aeaount 44th Rvi drat NaEiannl AmJ 6 Fees.-TI;te fpllowing fees may be assessed against your Savings' Acc«mt: For `
.
l tieie Savings Aecqunt Rules
Acca,nt) fives the pledged Savings Account (the "Savings:
opet!ed I- You .with Isrovidian National Bank
jf
i
l payment of outatahdfng Credit. Card Account balance .a $25 processing fee if ,
we mustlY any fibids ftun5,yout Savings AccounC'to pay any p onion of the
.
or
ner
y First Depaslt
^lanonal Bank) in connection with your Credit ('.aid Amount. In these Savings
Account Rules "you and
ttteaa each person for whwn
ha
o
e outstandihe balance' on Your, Credit Card Account; for deposited item returned t
on
-
unpaid. $20'each:tio,e an item is returned unpa
id; fb? extra copies
of sateinenrs:
we
ve
p
ned a
Savings Accouiu: "We .out ou
ra and us mean Providian National Bank'or ;.
to assi
ne .
$3 each for
1
. p• $25 if.we must .i omply with a legal Order related. to-the
Savings Account oriel (or S
i
3 A
g
r avtt
g
ccount re ottctletnent j3 2 per
1 :
Interest said BalancmComputatron Method. Your deposit begins earning
intent the tininess day after the d
l
d ? Federal Depoaf?,lnanranee: Funds on deposit-in the Sovings.Account are
nsured by the
Federal 19eppsif; Insurance Ca itio
a
e regesve
. The initial interest rates and
annual percentage Yields we Paytxi [Iris Sik m`gs Ac'cotinr are shown on a
rate
d
ldd accounts,:rlie 'tat ofall deposits you have with?is n'su d up to. 00 001' , al
`
,
ise
uR. Your interest dates and annual percentage yields may cha
nge. discretion we may Change the interest rites ii oken is daily: We use the suet A ?iulosnre of
Actount InfoimatEOn:'At out duuetlcm we inaysclose_
information about the Savurgs Actt 5p our affiLaia .Qn
? regisest of another,
.
financial itistftution wK may relatp,our experience-with :
You Savitlga At count.
7o the a:tent regifited by law
"wewdl re
r
h
O
,
port ear
ungs
e 5avings:Account to
r. t
s A6116 , s '
the appropriate. iax;authori;ies We may give Information about the Sayings,
Account others as ess
in wilting by you. We may also be required
subpoena or or
by
h
l If we decide that there was no error we will send Sou a written
explanacton within'
h
b
, t
,
ot
er
egal l process, to provide ?nforma[ion about ynur Savings Account
or to hold or delixer funds 6 the Savings Account :'.. t
ree
usiness days after we finish our invatigacton. You r[uy ask for copies. of the
documents we used .in our investigation.
9 limits of Lability. You will tttdtmnify and hold us harmless from any loan caused
by otir•acting to aci orance. with these Savings Account Rule3 i
li
n Our Ltabil;ry for Failure to Make Transfers. it we do noe compktt a transfer to of
f Y°irr Sayings Account
ti
n re
a
ce tin my
e?mrn°ur°a a authorization You give us We are: not liable for the accuracy of
any iaf, rnnatiori'you give tows O
` on
me or in the correct aioount, we will be liable for
'
fir Itztses
ijatitages.: However, there are some exceptions. We will NOT be liabl
ur
responsibility.is limire to the exercise of
ott3irtaty care.. - c
e
if, forinacane:
10. No; Warranties We: make no wattettc:u or representations wirh'reapeec to
processing under these Savi
rigs Account Rules or the accuracy of an
re
or
o
h
f • thruugh`no fault of ours, you do not have enough money in the Savings Account to
rake the transfer,
y
p
t or
t
er
orm famished under These Savings Accoaint Rules. We will not be liable for our
failure to act if the failure is due to your action or in
c
i
f
il
e •,carcumsnnces beyond our control (such as. ire or flood
c6pire ) prevent the transfer, `
reasonable precautions that
h
e t
a
t
on,
a
ur
of our equipmenr,.
acu of God government ;ggulattoru, tabor disputes, mechanical or electrical
breakdowns western conditions
or
ther e
b
we
av
aken
• • '-
There Y other exi?puons not specs cally mentioned here (for
l
f
,
o
vents
eyond our control
11. 'Applicable Law;
Change, of . eras. This Savin Account is
bj
c
o N examp
e, i
a
payment is not made diidro the limitations of a payee or financial institution).
D
s
su
e
t t
ew
Hampshire law, applicable federal laws and regulations and our procedures f
cco Busiaesc
ay
. Our business days are Monday through Friday; excluding bank kolidays.
or
a
unts of this type. We may change these Savings Account Rules but will
give
you any prior notice required.by
taw at'the address you have
iv
n
' '
" :Disclosure of Account lnformation to 1?ird Parties. We will disclose information
a
the circumanncu described in
ur S
i
A
ou
g
e
us.
12.
Closing Accouru We in close the Savings Account a[ shy time by written
notice. Then we will send yni; the b
l
inte 25 d yo
av
ng
cc
nt Rules section 8. .
Unauthorized
'T'ransfers: :You must tell us at once if someone has transferred or ma
r
f
'
o
a
ays after the surrender or cancella
r. of Your Card after paying offany unpaid balance on the.Credir Card A
i
Y y
t
ans
er money from your Saving
s Account without your permission. Telephoning in
is.the best way to kee
possibl
l
s
cwun
..
ou may close the Savings Account tidy pursuant eoaecnon 3
above.
13
A
i
n
s p
e
osse
down. Call I-800.3556011 or write to P.O.
x 800,
Tilton
, New Hainpahire 03276-0$00.
.
ss
ment
g
Because you have pledged this Savings Account to us as security
for your obligations on Your Credit Card Acco
t, if your statement shrnvselectronic transfers that you d d not make
tell us at onc
If
un
you may not pledge or assign dais
Savings Account co any third party. If you-attempt to do so, we will dose both your
Savings Account aril your Credit Ca
d A
c ,
e.
you do not. tell us within 60 days 'after. the statcmetit was mailed to you, you may'
not,gec back any money you lost after the 60 days if we can rove we
ld
a
r
c
ount
Electronic Fund
Transfers Disclos cou
ve
h
cropped someone from taking the money if you had told us "in:time. I( a good reason
(such as along trip or ahospital stay) kept you from telling us
we will e
d
h
ure Statement
You may arrange for an orgahizatiori (fair example
d
overn
n ,
xten
t
e
time period.
,
g
ment age
cy or
ftnanc..I instItution) td make electronic deposits to your Savings Account:
Electronic departs dear
re cr
dit
d
r
a
e
e
to you
Savings Account will be described in
Your monthly stateriient You may also ca11.1,800-356.001 i to find out wh
th For naymen s to your Credit Card Account,
or to make d
i
e
er
or not an electronic
deposit has been made. wm
t into your Savings Aecouni
In Case of Errors or Questions About Electronic Transfers. You should telephone
us it 1-800-35&436i I
w
O to increase your credit line
send cheek or money order to:
of
rite to us at P.
' Box 800, Tilton, New Hampshire
03276-0800 as s6on'as possible if
ou thi
k '
"
'
y
n
your statement is wrong
or if you need
more information about i transfer ltsti? on your statement. We must hear from'you .
W later than' 60 days after e
h Provtdian T'roce$sing Services
P.O. Box 9553
ve sent t
e FIRST statement on which the problem or
!er'[orappeared Yquthnuld- •, .,. .. :... ,?.._, .
... :.; Manchester,NH:03108-9553:. .
,
11) tell cis your name and savings Account number
,
(2) describe the error or tlx transfer in
u
io
p
e
For Customer Serv ice for, your Credit Card Accou
q
est
n and ei
l
in clearly why it may be
an error or why you need snore information, .. nt
or Savings Account, to report lost. or "stolen '.
(3) tell is the dollar amount of the suspected error, Credit Cards, "
if you tell us orally, we may require you to send the complaint or question in writing
within 10 business da
s or for other questions, please call us col)-free:
y
.
We will tell you chq results of our investigation within 10 busineu days after hearing
front you and wt will
correct any error
rom
tl
If
n
m
1-800-356.Oo 11
{
p
p
y.
we
eed
ore t ime, however; we
inaY take up to 45 days to mvesi[gate the cortiplain( or question if we decide to do
this, we will recredit your Savings Account. within 10 business da
f
h
o
.
P' `OV I DIAN '
ys
or t
e am
unt
you think ia.in error so that you will have theuseof the morsey during the time it
takes us to tompleee our
invp
i
: National Bank
.
r
guion
Uwe ask you'to put the complaint or
'question in writing and we do not receive It within 10
business da
w
,
ys,
e In not
`recredit yourSavings;Account.
1/98
'. 66116
:
a
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 4.,tra&usser, III, 't Corporation
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
: CIVIL-LAW
GLENDA M. BEAGLE, 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.
Dated this/ day of lLaurinda J. Vo 1 er, Esquire
Attorney For Remit Corporation
Attorney ID 82706
36 West Main Street
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
Request .for "VIi1; tarn Status
Department of Defense Manpower Data Center
4
Military Status Report
Pursuant to the Service Members Civil Relief Act
Pagel of 2
Dec-08-2009 10:37:28
`?a asst First/Middle Begin Date Active Duty Status [Active Duty End Date Service
d t
BEAGLE GLENDA Agency -
Based on the information you have furnished, the DMDC does not possess
M 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).
14. AWJ _ *
In 44FI14.
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://ww v.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 12/08/2009
Request for MiFtarv Status
Page 2 of 2
More in formation 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 RDAs. 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:D07NB9AQPO
https://www.dmdc.osd.miI/appj/scra/popreport.do 12/08/2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
: CIVIL-LAW
GLENDA M. BEAGLE, 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: Glenda M. Beagle
1710 Market Street, Apt. 19
Camp Hill, PA 17011
Respectfully submitted,
Laurinda J. Voel er, Esquire
Attorney for P intiff
PA ID #82706
Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Phone: 570-387-1873
Fax: 570-387-6474
r
r., ?.. ` '' r
'J v J f.+ a.. V
c. k- / i.7 10
?Cet . j 6 5`/U Z
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
FILI:U-'-•„ ? U?
CO
Remit Corporation
vs.
Glenda M. Beagle
Case Number
2009-8647
SHERIFF'S RETURN OF SERVICE
12/17/2009 07:56 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Decembei
17, 2009 at 1956 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Glenda M. Beagle, by making known unto herself personally, at 1710 Market Street, Apt
19, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $41.50
December 18, 2009
SO ANSWERS,
'00rage.e..- we 6
r
R THOMAS KLINE, SHERIFF
e uty Sheriff
{c Coun ySuite Shenff. Teleosott. Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
GLENDA M. BEAGLE,
Defendant
CIVIL-LAW
DOCKET NO. 09-8647 CIVIL TERM
PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment against Defendant in the above captioned matter as follows:
Real debt $ 1,715.29
Interest from Dec. 16, 2009 $ 8.58
Total:
$ 1,723.87
Kindly assess damages against Defendant in the sum of $ 1,723.87 plus continuing interest at the
statutory rate of 6%.
BY:
Laurinda J. oelcker, Esquire
Attorne or Plaintiff
C=a
r., ?r
i2 a3L7s7.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
GLENDA M. BEAGLE, DOCKET NO. 09-8647 CIVIL TERM
Defendant
CERTIFICATION OF TEN (10) DAY NOTICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
I, LAURINDA J. VOELCKER, ESQUIRE, hereby swear and certify that I served a copy of the
Ten (10) Day Notice by regular mail to Defendant on January 8, 2010.
BY: 4z)
Laurinda J. a cker, Esq.
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
GLENDA M. BEAGLE,
Defendant
CIVIL-LAW
DOCKET NO. 09-8647 CIVIL TERM
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
TO: Glenda M. Beagle
1710 Market Street, Apt. 19
Camp Hill, PA 17011
DATE OF NOTICE: January 8, 2010
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Pennsylvania Lawyer Referral Service
100 South Street, PO Box 186
Harrisburg, PA 17108
800-692-7375
717-238-6807
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
RE tckerr, ON Mailed to:
Glenda M. Beagle
Launnda .
' Esquire e 1710 Market Street, Apt. 19
570-387- 73 Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
GLENDA M. BEAGLE, DOCKET NO. 09-8647 CIVIL TERM
Defendant
AFFIDAVIT OF NON-AHLITARY 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.
Va-' ?'?
Dated th' , day 9q n ? , 2010
Laurinda J. Voelcker, squire
Attorney For Remi orporatic
Attorney ID 82706
36 West Main Street
Bloomsburg, PA 17815
Telephone: (570) 387-1873
Fax: (570) 387-6474
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Jan-19-2010 07:44:52
st First/Middle Begin Date Active Duty Status Active Duty End Date Service
Nam
GLENDA Based on the information you have furnished, the DMDC does not possess
BEAGLE M 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).
A41 14. 11411j4j,
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/fag/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 01/19/2010
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:MUIN04TNHM
https://www.dmdc.osd.mil/appj/scra/popreport.do 01/19/2010
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
GLENDA M. BEAGLE, DOCKET NO. 09-8647 CIVIL TERM
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: Glenda M. Beagle
1710 Market Street, Apt. 19
Camp Hill, PA 17011
Laurinda J. Voekke , Esquire
Attorney for Plaintiff
PA ID #82706
Remit Corporation
36 West Main Street
Bloomsburg, PA 17815
Telephone: (570) 387-1873
Fax: (570) 387-6474
Respectfully submitted,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
REMIT CORPORATION,
Plaintiff
vs.
CIVIL-LAW
GLENDA M. BEAGLE, DOCKET NO. 09-8647 CIVIL TERM
Defendant
TO: Glenda M. Beagle
1710 Market Street, Apt. 19
Camp Hill, PA 17011
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
_X Judgment by Default
Money Judgment
Judgment in Replevin
Judgment of Possession
Judgment on Award on Arbitration
Judgment on Verdict
Judgment on Court findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY: LAURINDA J. VOELCKER, ESQUIRE
AT THIS TELEPHONE NUMBER: 570-387-1873
Ila /I