HomeMy WebLinkAbout10-1552_N
IN THE COURT OF COMMON PLEAS OF CUMBERLA # a
COUNTY, R?
PENNSYLVANIA
!?-s cn
C7 rte
CACH. LLC.
VS. NO: Ott).
L
JANET BRYANT
NOTICE TO DEFEND
You have been sued in Court. If you wish to defendant against the claims set fourth in
the following pages, you must take action within (20) days after the Complaint and notice
are served, by entering a written appearance personally or by an attorney and filing in
writing with the Court, your defenses or objections to the claims set fourth 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 of any money
claims or 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 THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET HELP. 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.
LAWYER REFERRAL SERVICE
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013. S
(717) 240-6200
#Qa .o0 1 ?.a,
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Harrison Ross Byck, Esq., P.C.
229 Plaza Boulevard
Suite 112
Morrisville, Pennsylvania 19067
1-888-275-6399/(215) 428-0666
Attorney for Plaintiff
#61511
CACH, LLC.
4340 S. MONACO STREET
DENVER, CO 80237
Plaintiff,
VS.
JANET BRYANT
212 EDENDERRY WAY
ENOLA, PA 17025
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.:
COMPLAINT
To: JANET BRYANT
212 EDENDERRY WAY
ENOLA, PA 17025
NOTICE
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 the court without further notice may enter a judgment against you for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose 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.
LAWYER REFERRAL SERVICE
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
AVISO
Le han dernandado a usted en is corte. Si usted quiere defenderse de estas demandas expuestas
en las pagins siguientes. Usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia excrita o en persons o con abogado y entregar o sus
objecciones a las demandas en contra de su persona. Se avisado que si usted no se defiende. La corta
tomara medidas y puede continuar la demada en contra suya sin previo Avisa o notificion. Ademas la
corte puede decidie a favor del demandante y requiere que usted compla con todas las provisions de esta
demanda. Usted puede perder dinero o sus propiedas o otros derechos imporrantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO O SI NO TIENE EL DINERO SUMCIENTE DE
PAGAR TAL SERVICIO, VAYA EN PERSOAN O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
SERVICE DE REFERENCIA LEGAL
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
Plaintiff, CACH, LLC., by its attorney Harrison Ross Byck, by way of complaint against Defendant
JANET BRYANT, avers the following:
1. Plaintiff, CACH, LLC., is a Colorado limited liability company doing business at 4340 S.
Monaco Street, DENVER, CO 80237.
2. Defendant, JANET BRYANT, is an individual residing at 212 EDENDERRY WAY, ENOLA,
PA 17025.
3. Defendant, JANET BRYANT, is indebted to GE MONEY BANK on an account stated by and
between them in the amount of $1,677.47 which balance was due and unpaid as of March 11,
2008, for credit card account number 6020521401639933. <Exhibit A>
4. On or about April 1, 2008, GE MONEY BANK sold the debt for good and valuable
consideration to plaintiff, CACH, LLC. <Exhibit B>
5. The Defendant, Janet Bryant, last tendered a payment on October 18, 2007.
6. A copy of the credit card agreement is attached hereto. <Exhibit C>
7. Plaintiff is entitled to charge-off account finance charges of $0.00. <Exhibit A>
8. Plaintiff is entitled to pre-litigation charge-off interest of $1.2864 per day from the default date
27.990% annual percentage rate x $1,677.47 / 365 days) or $1.2864 x 600 days = $771.82; which
is accrued interest through the date of filing. <Exhibit A> Plus an award of late fees 0.00, court
costs $192.00 and reasonable attorneys fees of $300.00 as stated in the Cardholder Agreement
attached hereto as <Exhibit C>.
9. The defendant, being indebted to the plaintiff in the sum of $2,941.29 upon the account stated by
and between them did promise to pay said sums upon demand. Demand has been made for
payment of $2,941.29 and the defendant has failed to remit payment.
WHEREFORE, plaintiff demands judgment against the defendant for $2,941.29 together with
other interest and costs of suit.
Date: February 27, 2010
EXHIBIT A
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CAwsMIMirMaM
pl96 et1a1810 sn lrek
JANET WANT
b0T910010y!!I7! 20 EDENDERRY VAkY
MW P%-Wft sx GE MDHEY RAW E"OLA PA 17DR54414
p0 HOI pepper 11702 534141201
ORLANDO. FL 3259MI b1
13289600616281
00945610007400 009456100160361 000602052 1401639 93362
s twUow Mww.PMnMwvW*Jmnr I I ON Mw?.Nrw~%*E WANIN Mr1 ft0-wwr.AA.
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F& Qmmw Smft" A 6mw r
0101"NAM Ow
PIP mu Dw an
MinftM POymsIM This P., lad 367.00
Amwa PaI Ow $285.00
TOW mwmmSRP"MWO Dw $312.00
OwkQI A"w%" $000.81
Suppesm Psymm $915.61
DeP T108 PF A00 31
PAYMENT DUE BY 6 P.M. ON THB DUE DATE
Wsm yw""AYawPNR? Im6 an 9Uet1s61$ 04m,
sss 9PI9r6 gas.
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0. FINANCE CHARGE/ $31
ImmoG0on FMS 110Q
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1WNML PORMNYA" RAZE Ardmn 27.110% TWO Pw%Og F0M M CHARGE Salk
IN ORDER TO PROTECT YOUR ACCOUNT PRIVACY, YVE ARE UNABLE TO PROVIDE ACCOUNT INFORMATION TO
ANYONE OTHER THAN THE CAW4OI.0WS)CR AM WTNORILED PN1TY. IF YOU VW T4 PEN01IT US TO SPEAK
TO ANY AUTHORIZED PARTY SUCH A$ A SPOUSE ABOUT YOUR ACCOUNT, PLM3E SEND MrTEN
AUTHORIZATION TO THE GENERAL CORRESPONDENCE ADDRESS.
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Y01M PERIODIC RATE AA10 ANNUAL PERCENTAGE RATE MAY VARY.
IMMEDIATE PAYMENT ARRANGEMENTS MUST BE MADE
TODAY ON YOUR ACCOUNT. CALL 1800.78 e"a
• NOTICE: ON Mam Qr 8110 60o9i9R91 pSOa p"se wp.w , wwnre:e MR&OW47wr 60-6
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13289600616181
00283000001400 002850000152769 000602057 1401639 93362
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S A K MENSWEAFUGEMe GE Money
FOI Cwlmrt Sw1c91w r *** s
SMIMINAt ow 011108000
Payment ow Oats 020VAN
kirdwAa Paymara TM Period $54.00
AROM Past Ow $231,00
TW&IMin 1aa11PrpW*0ua $3$690
0miffiT AmOYtt $527.811
tAr pUW Por" d im-00
Data Thin Pedod 31
PAYMENT OVA •Y 4 PJA ON THE ON DATE
VIr ant WwmM pw 1rIboM YI. r.t.sarcadd.
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W ORDER TO PROTECT YOURAC00UNT PRIVACY. WE ARE UNABLE TO PROVIDE ACCOUNT INFORMATION TO
ANYONE OTHER'I WA THE CAR0110LDERM OR AN AUTHORITED PARTY, IF YOU WIM1 TO PERMR US TO SPEAK
TO ANY AUTHORI2E0 PARTY SUCH AS A SPOUSE ABOUT YOUR ACCOUNT, PLEASE SEND WRITTEN
AUTHORIZATION TO THE GENERAL CORRESPONDENCE AODRESS.
YOUR PERIODIC RATE AND ANNUAL PERCENTAGE RATE MAY VARY.
YOUR ACCOUNT t8 SERIOUSLY PAST OUE. R IS
CRITICAL THAT YOU CONTACT US TODAY AT
141(11)4 .5188
NOTICE: 9«rhar..a...n1.a.0i..r..s..p..t0 a. tw«wMrn¦.r.wwway r..¦wrr
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sm"Wa Dato 021,164001
Payment No Date 0X01110005
MWVR l PSYtlwa TIm P¦tied :67.011
AIRNM Pal OW 5766.00
TMd Mirmrw m P"ffm* Dui SM.00
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PAYh1551T ONE BY a ?JYL ON THE DUE DATE
ft "W asnv¦t yo¦t la?msnt kto ¦n marrosk Aiat.
4" favom 1W.
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•l. FBMINCECMARNI Sm.52
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IN ORDSR TO PROTECT YOUR ACCOUNT PRIVACY, VA ARE UNABLE TO PROVIDE ACCOUNT WORMATION TO
JWYO* OTHER TW11N THE CAM40LOERIS) OR AN AUTHMIZED PARTY. IFYOU 1NISH TO PERIMT US TO SPEAK
TOANY AUTHORIZED PARTY SUCH AS A SPOUSE ABOUT YOUR ACCOUNT, PLEASE SEND 1A411PTEN
AUTHORIZATION TO THE GENERAL CORRESPONDENCE ADDRESS.
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Ra4wnid Chock Fee to SFFtii 04M pamp wr is not hwtwadbT Your bw* SATI RlVpsi to 1174.
YOUR PERIODIC RATE AND ANNUAL PERCENTAGE RATE MAY VARY,
l IMWATE PAYMENT ARRAMINMENTS MUST BE MADE
T00AV ON YnLW ACYYNJVT. CALL1 MM •'^° "MI
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sytrr" ft)M4, $1.071.47
Dtyt 7tit Paw 39
PAYMLW DUS BY s P.M. M THE Due DATE .
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EXHIBIT B
CERTIFICATE OF PURCHASE
I, PFIER HI ER , hereby depose and state that:
I am an Authorized Agent of CACH, LLC, a Colorado Limited Liability Company.
As such, I am authorized to give this Certificate, and possess sufficient personal
knowledge to do so regarding:
Customer Name:
Original Creditor:
Account Number:
BRYANT, JANET
GE MONEY BANK
6020521401639933
On or about April 1. 2008 this account was sold by the original creditor. CACH, LLC is
the current owner of the account and purchased the account for good and valuable
consideration.
Date: FEB 11 2010 By. J I/
Sworn and subscribed to before me this day of F'EB 11 2019, 2010.
Notary Public
011
t; r
C) 0
PIv Commission Expire's 0319/20' 'el
(PA-NJ SWEEP Jan 2010)
EXHIBIT C
Terms and Conditions
Page 1 of 9
THE KEY CREDIT TERMS OF THE GE MONEY CREDIT CARD AGREEMENT ARE
AS FOLLOWS:
Ci?'1Clrl5': •.•.iRYXSC'r-L9.!dU. iA/e ?T.Jp.'9R .K ?w'??NYYYiM1CF ?.JS.M1 .... ...se.Y..^-....?1MSi
Annual Percentage Rate (APR) for Purchases and Cash Advances
24.99%
Delinquency Rate APR*
29.99%
Grace Period for Repayment of the Balance for Purchases
23 days if no previous balance and full payment is made; otherwise none.
Method of Computing the Balance for Purchases
One Cycle Average Daily Balance (Including New Purchases)
wx Minimum Finance Charge
$2.00
CT..SF"-.'15??_^'•tiaw-._.?L.:.-.9if.MVn_:?LiG?6M1]IUC?Z??p•`•••?•-?'--•••Tw.ti.x M.J1a.?i6M FUw.uu? ,T13?•n"?•.r.......L-?
Late Payment Fee: $29.99 if the Balance is $249.99 or less and $39.99 if the Balance is
$250.00 or more. (Balance is Account balance on date fee is applied.)
-,....,,,?.?.-.•..,.rrrw.._,.?.?..?,. Over Limit Fee: $38.99
Returned Check Fee: $39.99
urOt-....;_..;.r::..??:::s':`.t__•?s::.txk.?I.+'4':'?'Y.W_.f_...:_.vCXaL•1t.0.2N....._.?_?a_efti..-:....:. u'aY•?:.??_?-vw.?' ???:x!.?.. ...iv?::.....Y3:]
Transaction Fee for Cash Advances: 4% of the amount of each cash advance, but not
less than $5.
Transaction Fee for Balance Transfers: 4% of the amount of each balance transfer,
but not less than $5.
* If you do not make your required Minimum Payment by the Payment Due Date, you
make a payment that is not honored by your bank or you exceed your credit limit, the
Delinquency Rate, or at our discretion a lower rate (rather than the Standard Rate), may
apply to all existing balances on your Account and all new transactions beginning with
the first day of the billing period in which your missed or returned payment was due or in
which you exceeded your credit limit.
The information about the costs of the Account described herein is accurate as of July 1,
2009. This information may have changed after that date. To find out what may have
changed, write us at GEMB, P.O. Box 981439, El Paso, TX 79998-1439. We may, at any
time and for any reason, change, add or delete provisions of the governing credit card
agreement, including increasing rates or fees. These changes may affect existing
balances as well as future transactions. We will send you notice of any change as
required by applicable law.
Consent to Electronic Communications
1. Categories of Communications.
You understand and agree that GE Money Bank, the issuer of the GE Money Bank C' GE
Money") Credit Card, our assignees, or other holders of your GE Money Credit Card account
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("we" or "us") may provide to you by electronic means the following categories of information
with respect to applying for and obtaining a GE Money Credit Card account CAccount"),
which may include disclosures required by applicable federal or state law (collectively,
"Communications"):
• The GE Money Credit Card Agreement ("Agreement"), including, without limitation,
any Truth in Lending Act disclosures;
• Other federal and state law disclosures, notices and communications in connection
with the application for an Account or opening an Account; and
• Our Privacy Policy for the GE Money Credit Card Program.
2. Manner of Consent.
You acknowledge that by agreeing to the Consent to Electronic Communications through this
website, you demonstrate that you can access information that we would provide to you by
posting electronic Communications on our website.
3. How to Withdraw Consent.
You may withdraw your consent to receive electronic Communications by not submitting your
online application. However, you may not apply online unless you consent to receive
electronic Communications.
4. Hardware and Software Requirements.
In order to access and retain Communications, you must have:
• An Internet Browser which supports HTML 4.0 and SSL-encryption, such as Netscape
4.0 or later and Microsoft Internet Explorer 4.0 or later.
• A means to print or store notices and information through your browser software.
• A personal computer or equivalent device capable of connecting to the Internet via
dial-up, DSL, Cable Modem, Wireless Access Protocol, or equivalent, and that
supports the foregoing requirements.
5. Paper Copies of Communications.
Upon your request, we will send you a paper copy of the Agreement, our Privacy Policy for
the GE Money Credit Card Program and/or other material provided pursuant to the Consent
to Electronic Communication. If you would like a paper copy of any of this material please
write to us at GE Card Services, Application Processing, OH3-4250, P.O. Box 8817, Dayton,
OH 45482-9940 or call us at 1-877-794-8400. There will be no charge for a paper copy of
this material.
6. Communications in Writing.
All Communications in either electronic or paper format from us to you will be considered "in
writing." You should print or download a copy of this Consent to Electronic Communication,
the Agreement, our Privacy Policy for the GE Money Credit Card Program, your application
and any other Communication that is important to you for your records.
7. Electronic Signatures.
You acknowledge that by clicking on the "I Agree" or similar button at the GE Money Credit
Card application, you are indicating your intent to sign the relevant document or record and
that this shall constitute your signature.
8. Federal Law.
You acknowledge and agree that your consent to electronic Communications is being
provided in connection with a transaction affecting interstate commerce that is subject to the
federal Electronic Signatures in Global and National Commerce Act, and that you and we
both intend that the Act apply to the fullest extent possible to validate our ability to conduct
business with you by electronic means.
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INITIAL DISCLOSURE STATEMENT
Page 3 of 9
The following is an initial disclosure statement. If you are approved for a GE Money credit
card, a complete credit card agreement ("Agreement') governing your GE Money credit card
account ("Account') will be sent to you along with your credit card. The GE Money credit card
is issued by GE Money Bank ("Bank"), In this disclosure statement, 'we", "us", and "our"
means the Bank; "you" and "your" means all persons who we approve to use the Account;
and "Card" means your GE Money credit card. You may use your Account (i) to purchase
goods and services ("Purchases"), (ii) to obtain cash advances ("Cash Advances") by writing
convenience checks ("Convenience Checks") we may provide to you from time to time or by
other means we may make available, or (iii) to transfer balances from other credit card
accounts to this Account ("Balance Transfers") by means (including balance transfer checks)
we may make available from time to time, in each case up to any credit limit we may
establish for your Account ("Credit Limit'). Except as otherwise provided in this Agreement or
in any applicable offer, Balance Transfers will be treated as Purchases. You may not initiate
Balance Transfers to this Account from other accounts with us or any of our affiliates. We
may limit your Cash Advances to a portion of your Credit Limit (your "Cash Limit') and if we
do so, you agree not to take Cash Advances in excess of your Cash Limit. We may decline to
authorize any Purchase, Balance Transfer or Cash Advance or change your Credit Limit at
any time. You may use your Account only for personal, family or household purposes.
PERIODIC FINANCE CHARGES.
A. We calculate the periodic Finance Charge separately for Purchases and Cash Advances.
The Annual Percentage Rate may sometimes be referred to as "APR". For each billing period
in which a periodic Finance Charge is imposed, the amount of the Finance Charge is the total
of the amount of the periodic Finance Charge calculated during that billing period. The
periodic Finance Charge for each billing period is calculated by applying the applicable daily
periodic rate ("Periodic Rate") in effect during that billing period to the balance subject to
periodic Finance Charges for each day in the billing period, and adding together all of those
daily Finance Charge amounts. A minimum FINANCE CHARGE of up to $2.00 will be
imposed for each billing period in which your Account is subject to a Finance Charge.
B. The periodic Finance Charges will be determined separately for charges incurred under
any Special Payment Plan in accordance with the terms established for such Special
Payment Plan. You understand and acknowledge that this Account provides for the daily
compounding of periodic Finance Charges.
PERIODIC RATES
A. The Periodic Rate for your Purchase Balance is the Purchase Standard Rate, unless the
Delinquency Rate applies as described below. The Purchase Standard Rate for a billing
period is a rate of .06846% (APR 24.99X).
B. The Periodic Rate for your Cash Advance Balance is the Cash Standard Rate, unless the
Delinquency Rate applies as described below. The Cash Standard Rate for a billing period is
a rate of .06846% (APR 24.99%).
C. The Periodic Rates and corresponding APRs for all Account balances (including any
promotional rates) may be increased if you fail to make a required Minimum Payment by the
Payment Due Date, you make a payment to us that is not honored by your bank or you
exceed your Credit Limit. If we increase your Periodic Rates, the new Periodic Rates will be
equal to the Delinquency Rate, or at our discretion a lower rate. Our decision may be based
on factors such as the timing or seriousness of any default, your payment and purchase
history and other performance on this Account. The increased Periodic Rates will apply to
your existing balances and future transactions and will take effect as of the first day of the
billing period in which your missed or returned payment was due or in which you exceeded
your Credit Limit. We also may change rates or other terms as provided in the
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Termination/Change In Terms Section of this Agreement. The Delinquency Rate is a rate
of .08216% (APR 29.99%).
BALANCE SUBJECT TO PERIODIC FINANCE CHARGES. The balance subject to a
periodic Finance Charge is calculated seperatly for Purchases and Cash Advances.
A. The Purchase Balance subject to a periodic Finance Charge is the Purchase Daily
Balance of the Account. To determine the Purchase Daily Balance, we take the prior day's
Purchase Balance of your Account, which includes unpaid periodic Finance Charges on your
Purchase Balance and add any new Purchases, including any Balance Transfers that are
treated as Purchases, and other debits charged to your Account that day, and subtract any
payments and other credits applied to your Purchase Balance that day. Each day we also
add any periodic Finance Charges on your Purchase Balance and other Finance Charges
and fees (other than Transaction Fees for Cash Advances), including any debt cancellation
fees, assessed that day on your Account. This gives us the Purchase Daily Balance of the
Account. Any Purchase Daily Balance of less than zero will be treated as zero.
B. The Cash Advance Balance subject to a periodic Finance Charge is the Cash Advance
Daily Balance of the Account. To determine the Cash Advance Daily Balance, we take the
prior day's Cash Advance Balance of your Account, which includes any unpaid periodic
Finance Charges on your Cash Advance Balance, and add any new Cash Advances,
including any Balance Transfers that are treated as Cash Advances, Transaction Fees for
Cash Advances and periodic Finance Charges on your Cash Advance Balance for that day
and subtract payments and other credits applied to your Cash Advance Balance that day.
This gives us the Cash Advance Daily Balance of the Account. Any Cash Advance Daily
Balance of less than zero will be treated as zero.
WHEN PERIODIC FINANCE CHARGES BEGIN TO ACCRUE. Purchases and Cash
Advances begin to accrue periodic Finance Charges from the date of the transaction (or, at
our option, from the date they are posted to your Account) and continue to accrue Finance
Charges until the charge is paid in full. However, you can avoid periodic Finance Charges on
new Purchases if for each billing period you pay your New Balance, including any Cash
Advance Balance and any balance of Purchases made under any Special Payment Plan, in
full on or before the Payment Due Date for such billing period. There is no period within
which you can avoid periodic Finance Charges on Cash Advances or Transaction Fees for
Cash Advances.
PAYMENTS. You must pay at least the Minimum Payment on your Statement by the
Payment Due Date shown on the Statement. You may pay more than the Minimum Payment
at any time. If you have a balance subject to Finance Charges, earlier payment may reduce
the amount of Finance Charges you will pay. Any time the APR applicable to your Account is
25.0% or less, your Minimum Payment initially will be (i) the greater of $15.00 or 3.1% of your
New Balance (excluding any balance attributable to any Special Payment Plan that involves
delayed or special payments), rounded to the next highest dollar, plus (ii) any past due
amounts, plus (iii) any payment due under any Special Payment Plan. Any time the APR
applicable to your Account is greater than 25.0%, your Minimum Payment initially will be (i)
the greater of $15.00 or 3.5% of your New Balance (excluding any balance attributable to
any Special Payment Plan that involves delayed or special payments) rounded to the next
highest dollar, plus (11) any past due amounts, plus (iii) any payment due under any Special
Payment Plan. However, if during any four month period immediately following a billing
period in which a Late Payment and/or Over Limit Fee is assessed, you pay at least the
Minimum Payment each month but the total of your payments does not at least equal the
sum of the Finance Charges billed on your Statement each month, plus 1 % of your New
Balance each month, plus the particular Late Payment and/or Over Limit Fee that was
assessed in the billing period before the four month period, your Minimum Payment will be
changed for future months to the greater of the Minimum Payment calculation stated above,
or the sum of 1% of your New Balance plus Finance Charges, Late Payment Fees and Over
Limit Fees billed on your Statement. In each case, your Minimum Payment also will include
any past due amounts and any payment due under any Special Payment Plan. The Minimum
Payment will be the New Balance if the New Balance is less than $15.00.
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You agree that, if allowed, any payments on your Account delivered to a retailer store are
handled by such retailer as a convenience for you and are not received or accepted by us
until physically delivered to us.
We reserve the right to select the method by which payments and credits are allocated to
your Account in our sole discretion. The payment allocation method that we use may result in
higher Finance Charges on your Account, depending on the types of transactions you make
(such as promotional or non-promotional Purchases), and the timing and amount of your
payments. For example, on promotions requiring a Minimum Payment, payments over the
minimum will usually be applied to those promotional balances before non-promotional and
other balances. If you have a non-promotional balance, this may reduce the benefit from the
promotion. If you want to change this allocation, please call customer service.
FEES. You agree to pay the following fees.
A. A Late Payment Fee, if we have not received your Minimum Payment by the Payment
Due Date shown on your Statement. The amount of the Late Payment Fee will be based on
your Account balance on the date the Late Payment Fee is applied to your Account. The
Late Payment Fee will be $29.99 for a balance of $249.99 or less; and $39.99 for a balance
of $250.00 or more.
B. A Returned Check Fee of $39.99 if any check or other instrument sent to us, or any
electronic payment authorization you provide us in payment on your Account, is not honored
upon first presentment, even if the check, instrument or electronic authorization is later
honored.
C. An Over Limit Fee of $39.99 for each billing period in which your New Balance as shown
on your Statement exceeds your Credit Limit We may assess an Over Limit Fee even if we
authorize the transactions on your Account that caused you to exceed your Credit Limit or if
you exceed your Credit Limit as a result of unpaid Finance Charges, the billing of deferred
accrued Finance Charges or other fees.
D. A Transaction Fee for each Cash Advance that posts to your Account, including any
Balance Transfer treated as a Cash Advance. This fee will be a FINANCE CHARGE equal to
4% of the amount of the Cash Advance, with a minimum of $5.
E. A Returned Loan Check Fee of $39.99 in the event any Convenience Check on your
Account is not honored by us because (1) the portion of your Credit Limit available for
Convenience Checks is insufficient to cover the amount of the Convenience Check, (ii) you
have filed a petition in bankruptcy, (iii) the Convenience Check has expired, or (iv) your
Account has been closed.
F. A Stop Payment Fee of $39.99 if we stop payment on any Convenience Check at your
request.
G. A Transaction Fee for each Balance Transfer treated as a Purchase that posts to your
Account. This fee will be a FINANCE CHARGE equal to 4% of the amount of the Balance
Transfer, with a minimum of $5.
SECURITY INTEREST. You grant us a purchase money security interest in each item of
merchandise purchased on your Account to secure its unpaid purchase price until such
merchandise is paid in full. Solely for the purpose of determining the extent of our purchase
money security interest in each such item of merchandise, your payments will be allocated
first to Finance Charges on the Account, and then to pay off each Purchase on the Account
in the order in which the Purchase was made (if more than one item was purchased on the
same day, your payments will be allocated to pay off the lowest priced item first). If you made
a Purchase pursuant to a credit promotion, the balance with respect to the promotional
Purchase may be shown on Statements during the promotional period and may reflect a
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different payment allocation method. In no event will we assert a security interest in the
promotional Purchase for an amount greater than the lowest balance shown on a Statement
for that promotional Purchase. We agree that no security interest is or will be retained or
acquired under this Agreement in any real property, which is used or is expected to be used
as your dwelling. Should we feel it is necessary, you authorize us to sign and file financing
statements regarding any Vehicle purchased.
If the item of merchandise purchased is a Vehicle (including the vehicle, parts and
accessories) and if you default under this Agreement we may, as permitted by applicable
law, repossess the Vehicle and any personal property of yours in or attached to the Vehicle
that is not subject to our security interest may be held by us without liability. Unless you make
written demand on us for the return of such personal property within 10 days (or any longer
period required by applicable law) of repossession, you will lose any right to reclaim it from
us, except as applicable law otherwise provides. After we repossess the Vehicle, it may be
sold at public or private sale, as provided for by applicable law, and the proceeds received
from the sale will be applied to your balance after deducting expenses allowed by law. We
will pay you any surplus resulting from a resale of the repossessed Vehicle, and you will pay
us any deficiency when and as permitted by applicable law.
For some individual Purchases under your Account, we may require you to maintain
property/casualty insurance on the Purchase as a condition of granting you credit. You will
be informed of any property/casualty insurance requirement at the time you make the
Purchase.
CHANGE IN TERMS. We may, at any time and subject to applicable law, change, add or
delete provisions of the Agreement ('Terms Change°) or terminate your Account. Unless
prohibited by applicable law, we may apply any Terms Change to any outstanding or future
balances of your Account.
ARBITRATION. The Agreement contains an arbitration provision that may substantially limit
your rights in the event of a dispute, including your right to litigate in court or have a jury trial,
discovery and appeal rights, and the right to participate as a representative or member of a
class action. You have a right to reject the arbitration provision, by following the instructions
in the arbitration provision. If you reject arbitration, it will have no effect on any other terms of
the Agreement.
Notice: The following is important information regarding your right to dispute billing errors.
YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about your rights and our responsibilities under the
Fair Credit Billing Act.
Notify Us in Case of Errors or Questions About Your Bill.
If you think your bill is wrong, or if you need more information about a transaction on your bill,
write us on a separate sheet at the address shown on your Statement under billing inquiries.
Write to us as soon as possible. We must hear from you no later than 60 days after we sent
you the first bill on which the error or problem appeared. You can telephone us, but doing so
will not preserve your rights.
In your letter, give us the following information:
• Your name and Account number
• The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is an error. If you
need more information, describe the item you are not sure about.
Your Rights and Our Responsibilities After We Receive Your Written Notice
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We must acknowledge your letter within 30 days, unless we have corrected the error by then.
Within 90 days, we must either correct the error or explain why we believe the bill 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 finance
charges, and we can apply any unpaid amount against your credit limit. You do not have to
pay any questioned amount while we are investigating, 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 have to pay any finance charges
related to any questioned amount. If we didn't make a mistake, you may have to pay finance
charges, and you will have to make up any 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.
If you fail to pay the amount that we think you owe, we may report you as delinquent.
However, if our explanation does not satisfy you and you write to us within ten days telling us
that you still refuse to pay, we must tell anyone we report you to that you have a question
about 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 rules, we can't collect the first $50 of the questioned amount, even if
your bill was correct.
Special Rule for Credit Card Purchases
If you have a problem with the quality of property or services that you purchased with a credit
card, and you have tried in good faith to correct the problem with the merchant, you may
have the right not to pay the remaining amount due on the property or services. There are
two limitations on this right:
(a) You must have made the purchase in your home state or, if not within your home
state, within 100 miles of your current mailing address; and
(b) The purchase price must have been more than $50.
These limitations do not apply If we own or operate the merchant, or if we mailed you the
advertisement for the property or services.
PRIVACY POLICY
This Privacy Policy describes our information collection and sharing practices. Please
read it carefully and retain with your records for this Account. The Policy applies only to
current and former customers and applicants in their relationships with us relating to this
consumer credit card Account of GE Money Bank (GEMS, `we", "us" or "our").
Information We Collect -We collect personally identifiable information about you, (such
as your address, phone number, social security number, mother's maiden name, and
transaction information about items purchased, payments and payment method), for
identification, account management, servicing and marketing purposes. We obtain
information about you directly from you (such as on application forms), through your use
of our products and services, and in some cases, from third parties (such as credit
bureaus and demographic firms). Occasionally, we may also collect information about
you online using "cookies" (small pieces of data stored by your Internet browser on your
computer) or other technology that may be used to remember passwords for you, to track
your website usage with us, and to provide you with customized content, among other
things.
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Information We Share with Others -We may use and share all of the information we
collect, subject to applicable law, with the following (these examples are not intended to
be all-inclusive):
Page 8 of 9
The Retailer/Merchant/Dealsr associated with this credit program and its
affiliates and program sponsors (as applicable), for use in connection with this
consumer credit program and as otherwise permitted by law. They may use this
information to update their records, to provide you with notices of special
promotions and other tailored offerings, to answer questions about this Account
and perform other credit program functions or for other purposes permitted by law.
They may use their affiliates, licensees, sponsors or third-party service providers
(such as modeling and database companies) to assist them in any of these
activities.
Service Providers and program sponsors, (including our affiliates) to assist us
in servicing Accounts, like preparing billing statements and promotional materials,
and responding to customer inquiries. We also may use marketing firms, such as
modeling companies, to assist us in our own marketing efforts.
Financial Institutions with whom we jointly offer financial products, such as
loan products or credit insurance. If your billing address is in Vermont, this
information will be limited to your name and contact information, and transaction
and experience information on this Account.
GEMB's affiliates, who are other companies in the General Electric Company
corporate family ("GEMB affiliates") for servicing or marketing purposes, subject
to your right to opt out of sharing of credit eligibility information, such as certain
information from credit bureaus and your application, as provided in the H's Your
Choice section below. Subject to your right to opt out, GEMB Affiliates also may
use information from us concerning your credit eligibility, and your transactions
and experience with us, to send you marketing solicitations about products and
services.
Third Parties, who are interested in offering special products or services to
you, subject to your right to opt out as provided in the H's Your Choice section. For
example, we disclose information, either directly or through the
Retailer/Merchant/Dealer and its affiliates and program sponsors (as applicable) to
financial services providers offering products such as insurance, mortgages or
loans, and non-financial companies offering consumer products and services. We
may disclose name, address and telephone numbers, as well as Account
purchase and performance history.
Others:We report Account information, such as credit limit, balances and payment
information, to credit bureaus. In addition, we may buy and sell assets, lines of
business and/or Accounts. When this occurs, customer information generally is
disclosed to bidders and is one of the transferred business assets. We also
disclose infomnation about you to third parties in certain other circumstances, as
permitted by law.
It's Your Choice -You have the right to opt out of certain uses we may make of
credit eligibility information and our sharing of information with certain third
parties as described below. To opt out please call us toll-free at 1-877-905-2097, or
write to us at P.O. Box 981439, El Paso, TX 79998.1439. If you have previously
informed us of your preference, you do not need to do so again.
you opt out, you will be directing us as follows:
Do not share information about me with companies other than with GEMS
Affiliates, and with the Retailer/MerohantiDealer and its affiliates and program
sponsors (as applicable) for use in connection with this credit program and as
otherwise permitted by law. Do not share with GEMS Affiliates information used to
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determine my eligibility for credit. Do not allow GEMB Affiliates to solicit me for
products and services based on transaction, experience or credit eligibility
information they receive from GEMB.
Notes About Your Choice
• Please understand that, even if you opt out as described above, we will continue to
share information with the Retailer/Merchant/Dealer and its afflr fates and program
sponsors (as applicable) associated with this Account, joint marketing partners and
service providers as described in this policy, and as otherwise permitted by law.
And we will continue to share information that identifies you, and about your
transactions and experiences with us, with GEMB Affiliates.
. if you have a joint account, a request by one party will apply to all parties on the
account.
. We will process your request promptly. However, it may take us several weeks to
ensure that all records are updated with your preference. In the Interim, you may
continue to be included in programs as described above. Also, after your request
is processed, you may still be contacted by GEMB Affiliates and/or other
companies based on their own information.
. Even if you opt out, we will continue to provide you with billing inserts and mail
notices of special offers and new benefits. We will also continue to use your
information (including credit eligibility information) to offer you special benefits,
features and/or services on your Account.
. Vermont Residents: if (and while) your billing address is in Vermont, we will treat
your Account as if you had exercised the opt out choice described above and you
do not need to contact us in order to opt out. If you move away from Vermont and
you wish to restrict us from sharing information about you as provided in this
Policy, you must then contact us to exercise the opt-out choice described above.
Our Security Procedures - We maintain physical, electronic, and procedural safeguards
that comply with federal standards to guard nonpublic personal information about you.
We limit access to personal and Account information to those employees and agents who
assist us in providing products and services to you. We also require third parties to whom
we disclose nonpublic personal information to adhere to this Privacy Policy and to
establish information security procedures.
Your Access to Information - We provide you access to information about your Account
by sending you monthly billing statements outlining your transactions, finance charges,
and other Account information, and by providing customer service representatives to
answer your questions.
r This Policy Applies to You - The examples contained in this Privacy Policy are
rations only, and are not intended to be all-inclusive. If you decide to close your
aunt or become an inactive customer, or if we close or suspend your Account, we will
inue to adhere to the privacy policies and practices described in this notice to the
nt we retain information about you. We may amend this Privacy Policy at any time,
we will inform you of changes as required by law. You may have other privacy
actions under state laws and we will comply with applicable state laws when we
lose information about you. This Privacy Policy applies only to this consumer credit
)unt with GE Money Bank and does not apply to any other accounts you may have
us, and replaces our previous disclosures to you about our information practices.
Print Close
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VERIFICATION
I, PETER HUBEH , hereby depose and state that:
The language of the foregoing document is that of counsel and not necessarily my own:
however, I have read the foregoing document and the factual information contained
therein is true and correct to the best of my personal knowledge.
I am the Authorized Representative and a duly authorized representative of the plaintiff;
The factual allegations set forth in the foregoing pleading are true and correct to the best
of my knowledge, information and belief, and they are that BRYANT, JANET owes the
balance of $1,677.4 7 to CACH, LLC on previously submitted invoices, which balance is
due and unpaid as of the date of the execution of this Verification.
I am aware that if any of the foregoing is willfully false, I am subject to punishment.
I understand that false statements made herein are subject to the penalties relating to
unsworn falsification to authorities.
By: -- -
Authorized Representative
Dated: FEB 11 2010
(PA-NJ SWEEP Jan 2010)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith
Chief Deputy
Edward L Schorpp
SOiICItOr
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Cach, LLC
vs.
Janet Bryant
Case Number
2010-1552
SHERIFF'S RETURN OF SERVICE
03/22/2010 Jason Vioral, Sergeant, who being duly sworn according to law, states that on March 22, 2010 at 1445
hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit:
Janet Bryant, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1
Courthouse Square Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the
same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $41.50
March 22, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
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JASON IO L, SERGEANT
~d!. Cru~si Suite SFE:r'(. ie'.^cs:;ft Inc.
Harrison Ross Byck, Esq., P.C.
Attorney I.D. 61511
229 Plaza Blvd.
Suite 112
Morrisville, PA 19067
1-888-275-6399 // (215) 428-0666
Attorney for Plaintiff
CACH, LLC.
vs.
Plaintiff,
JANET BRYANT
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: -~A-i~32 civil term
l0-1550?
To: JANET BRYANT
212 EDENDERRY WAY
ENOLA, PA 17025
NOTICE
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:
By:
~~~~~rv
X Judgment by Default
_ Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Verdict
If you have any questions concerning the above, please contact:
ATTORNEY: HARRISON ROSS BYCK, Esquire at 215-428-0666 or 1-888-275-6399
Harrison Ross Byck, Esq., P.C.
Attorney I.D. No. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399// (215) 428-0666
CACH, LLC.
Plaintiff(s),
vs.
JANET BRYANT
~c
r "" ( ,~r~ ~'l~
. T. _.... .. .. _.
2~Jt0 x i~~i ~ 7 i~`i ~ x:23
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 10-1522 civil term
PRAECIPE TO ENTER
Defendant(s). ) JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter a Default Judgment in favor of plaintiff, CACH, LLC., and against the defendant(s),
JANET BRYANT, for failure to answer or otherwise respond to the Complaint in Civil Action.
The Complaint was served upon the defendant(s) on MARCH 22, 2010. A copy of the proof of
service is attached hereto as Exhibit "A".
A copy of the Notice of Intention to take Default mailed to defendant(s) JANET BRYANT by
regular United States mail, postage paid, on APRIL 22, 2010, is attached hereto as Exhibit "B".
Assess damages in the amount of $ 2749.29 as follows: [a] $ 1677.47 principal being sought in the
Complaint; [b] and $ 771.82 interest being sought in the Complaint; [c] and reasonable attorney's fees of
$ 300.00, or $ 150.00 per hour, [d] and Court Costs of $ 0.00, [e] and Costs of Service of $0.00.
Date: May 05, 2010
__
By. - _-_.,.,.
Allan C. Smith, Esq.
Attorney I.D. No. 204756
$~~. oo P a A'rr/
~~a~~~1
~~ a~raa~~
~(a~tee, ~~.~
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith ~~~tititi11' ~t v~ rarf~i,~y~~~~~4
Chief Deputy ~, , : ~; ,,,
Edward L Schorpp
Solicitor ~FFi~:~;r rr~E..,~,~,~~
Cach, LLC
vs.
Janet Bryant
Case Number
2010-1552
SHERIFF'S RETURN OF SERVICE
03/22/2010 Jason Vioral, Sergeant; who being duly sworn according to law, states that on March 22, 2010 at 1445
hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit:
Janet Bryant, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1
Courthouse Square Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the
same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $41.50
March 22, 2010
SO ANSWERS,
~~~.
RON y R ANDERSON, SHERIFF
~, ~~/~~
JASON IO L, SERGEANT
(r.) GourtySulto Sheriff. TelF~sofl, Irtc.
Harrison Ross Byck, Esq., P.C.
Attorney I.D. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399//(215)428-0666
Attorney for Plaintiff
CACH, LLC. ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff, )
NO: 10-1522 civil term
vs. )
JANET BRYANT
Defendant(s)
CERTIFICATE OF SERVICE OF
NOTICE OF INTENT TO FILE
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, ALLAN C. SMITH, ESQ., of full age, certify that I mailed a copy of the annexed NOTICE OF
INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT upon defendant JANET
BRYANT by United States mail, postage prepaid and certified mail, on APRIL 22, 2010 at his/her last
address of:
212 EDENDERRY WAY
ENOLA, PA 17025
Date: May 05, 2010
Allan C. Smith, Esq.
Attorney I.D. No. 204756
Harrison R. Byck, Esq., P.C.
Attorney LD. No. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399 // (215) 428-0666
Attorney for the Plaintiff
CACH, LLC.
Plaintiff,
vs.
JANET BRYANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-1522 CIVIL TERM
NOTICE OF INTENT TO
FILE PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO:
JANET BRYANT
212 EDENDERRY WAY
ENOLA, PA 17025
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 TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
Dated: Apri122, 2010
Harrison Ross Byck, Esq., P.C.
Attorney I.D. No. 61511
229 Plaza Blvd.
Suite 112
Morrisville, PA 19067
1-888-275-6399 // (215) 428-0666
Attorney for Plaintiff
CACH, LLC. ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff, )
NO: 10-1522 civil term
vs. )
JANET BRYANT
Defendant(s).
CERTIFICATION OF NON-MILITARY SERVICE
I, ALLAN C. SMITH, ESQ. of full age, certifies as follows:
I am the plaintiff s attorney herein, and have sufficient knowledge of the facts and am
fully authorized to make this Certification;
My information is that the defendant is JANET BRYANT.
3. Our latest information is that the defendant is employed at UNKNOWN.
3. To the best of my information and belief, the Defendant is not a member of the
military services of the United States of its allies or otherwise within the provisions of the
Soldiers' and Sailors' Relief Act of 1940, as amended, and as stated in the attached
Department of Defense Manpower Data Center reports.
5. This certification is taken subject to the penalties of 18 PaCSA 4904 relating to unsworn
falsification to authorities.
Date: May 05, 2010
By
Allan C. Smith, Esq.
Attorney I.D. No. 204756
Request for Military Status
Department of Defense Manpower Data Center
~' > ~' .
~~`~" Military Status Report
Pursuant to the Service Members Civil Relief Act
~r
Page 1 of 2
May-OS-2010 10:07:55
'~ Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
BRYANT JANET Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
~~_ ~i-~-
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink mil/faq/pis/PC09SLDR.htm1. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA maybe 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.miUappj/scra/popreport.do 5/5/2010
of
?Cunt?Pr??
RONNY R. ANDERSON
Sheriff
JODY S. SMITH
Chief Deputy
To Whom It May Concern:
RICHARD W. STEWART
Solicitor
OFFICE OF THE SHERIFF
One Courthouse Square, Room 303 3
Carlisle, Pennsylvania 17013 Mc
z rn-
U) 1
July 17, 2011 .
j
CACH, LLC yZ-, ?? Im
vs
Janet Bryant
<
Writ No. 2010-1552
Property Claim Determi nation
Reference is made to Property Claim dated June 27, 2011, entered by Troy W.
Soctt, III, Writ of Execution No. 2010-1552 Civil Term, CACH, LLC vs. Janet Bryant
Ronny R. Anderson, Sheriff, has determined that the claimant, Troy W. Scott, III,
in the above mentioned property claim, is the owner of the property set forth in the claim.
So Answers:
cc
Allan C. Smith, Atty for Plaintiff
Janet Bryant, Defendant
Troy W. Scott, III, Claimant
Ronny R. Ander on, Sheriff
B
NOTICE OF PROPERTY CLAIM
In The Court of Common Pleas of
.......... CACH...... LLC .......................................................... Cumberland County, Pennsylvania
VS.
.-.----. Janet....Brxant ............................. No...?9.1.0.-..1.5.5..2
.................. Term
Writ of Execution
TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST:
You are hereby notified that a property claim, a copy of which is attached hereto has been filed by
Troy. W. Scott, III . , , ... , , claiming property listed therein. Unless an appraisal of the prop-
erty is requested within (10) days from the date of this notice, the sheriff without making an appraisal will accept the
value of the property set forth in the claim.
Date: June . 2.7., ..201.1...._...... .
Ronny. R,. Anderson
Sheriff of Cumberland County
Q? ......
PROPERTY CLAIM
L?CA uL
VS
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA
In the Court of Common Pleas of
Cumberland County, Pennsylvania
`'
Writ No. G - /! -
The property listed below and levied upon in this case is not the property of the defendant, but is the property of the
undersigned. A list of the claimed property and the values thereof are:
LIST OF PROPERTY VALUE
C1 o4),) 5,o,4 f 1 Go
1 Z-A 6d
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ry?Gn? wit G 4m -s ? 6 -
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1 bAt,4 P1, i GAS 4Jv(?' 4 6. W
THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS:
Ado- I-
i bR-` t o G 5-d-C
Date C /,
State of Pennsylvania:
County of Cumberland
Claimant :)?dv ? !w 5 < -17` d
T'?0 7+ w .S<CTft *j:t- being ly sworn according to law, deposes and says that the
above list in the property claim are correct and true.
Sword and9ubscr. e to before e a
Claimant
Thi$'L t d o NOTARIAL SEAL
Notary Public %JUUT l
SM1TH, NOTARY PUBLIC '2(1 c'v? l p?
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
_ ? CLCt1 C??'iC
,. THE FP;C 1 FfI N
2011 JUL 19 PM 3: AS a
Richard W Stewart
Solicitor
CUMBERLAND COUNTY
PENNSYLVANIA
Cach, LLC
vs.
Janet Bryant
Case Number
2010-1552
SHERIFF'S RETURN OF SERVICE
06/22/2011 09:12 PM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Writ of
Execution and Claim for Exemption Form to a person representing themselves to be TROY SCOTT-
HUSBAND, who accepted as "Adult Person in Charge" for the within named Defendant, to wit: Janet
Bryant at 212 Edenderry Way, East Pennsboro Township, Enola, PA 17025, informed person of contents
of same and levied upon personal property as directed.
Postcard and copy of levy mailed to attorney and letter mailed to defendant on 06-23-2011.
06/27/2011 On June 27, 2011, at 1000 hours, a property claim was filed by Troy W. Scott, III. All parties notified by
mail this date.
07/19/2011 No objections to property claim filed in this case. Refunding $25.00 on this date to claimant Troy Scott III.
07/19/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is
returned STAYED per Pennsylvania Rules of Court 3206(c).
SHERIFF COST: $97.64 SO ANSWERS,
°-
July 19, 2011 RON R ANDERSON, SHERIFF
All
-ountvSIM0 Sheriff, Te eosoft. trn;.