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HomeMy WebLinkAbout10-2067IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC PO Box 2036 CIVIL ACTION Warren, MI 48090 Plaintiff VS. NO: 1b - ao(0 MARK REESE 339 REGENT ST CAMP HILL PA 17011 Defendant nR.G.N- F 70F THE nrr'r 'nNO?Auv 2010 MAR 24 Pal 1 ? !Z Term NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice to Defend are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 G #Q1,00 PO ATry &-p wu-s e# aag oo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC PO Box 2036 CIVIL ACTION Warren, MI 48090 Plaintiff VS. NO: MARK REESE 339 REGENT ST CAMP HILL PA 17011 Defendant COMPLAINT Plaintiff, ASSET ACCEPTANCE LLC, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, ASSET ACCEPTANCE LLC, (hereinafter "Plaintiff") is a Michigan corporation with a principal place of business located at PO Box 2036 Warren, MI 48090. 2. The Defendant MARK REESE (hereinafter "Defendant") is an adult individual residing at 339 REGENT ST CAMP HILL PA 17011. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by CHASE BANK with the account number 5418228000632390. 5. The within account was sold by CHASE BANK to ASSET ACCEPTANCE, LLC for valuable consideration and all rights under said accounts were assigned to ASSET ACCEPTANCE, LLC. 6. Use of the CHASE BANK credit card was subject to the terms of the Cardmember Agreement, a copy of which was sent to the Defendant along with the credit card. (See, Credit Card Agreement attached hereto as Exhibit "A") 7. Defendant used the CHASE BANK credit card account number5418228000632390, for purchases, cash advances and/or balance transfers. 8. The Defendant was mailed account statements relative to the Defendant's use of the subject credit card. 9. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 10. The account became delinquent May 12, 2008. 11. The principal amount was $8,050.84 at the time it was received by Plaintiff. 12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate of 9. 13. The total amount due and owing the Plaintiff including interest, is $8,914.37. 14. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $8,914.37 plus costs of suit and any other relief as the Court deems just and appropriate. Edwin A. Abr arxen & Assoc. /Michael F. atchford, Esquire Heather Woodruff, Esquire Attorne D. Nos.: 86285/207805 120 N h Keyser Ave. Scrant n. PA 18504 mratchford@eaa-law.com hwoodruff@eaa-law.com VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, ASSET ACCEPTANCE LLC, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. Cardmember Agreement 1. ACCEPTANCE OF THIS AGREEMENT This agreement governs your credit card account with us referenced on the card carrier containing the card for this account. Any use of your account is covered by this agreement Please read the entire agreement and keep it for your records. The entire agreement may be in separate parts, including this document and a "Rates and Fees table that is expressly made a part of this agreement. You authorize us to pay for and charge your account for all transactions made on you account. You promise to pay us for all transactions made on your account, as well as any fees or finance charges. If this is a joint account, each of you, together and individually, is responsible for paying all amounts awed, even if the account is used by only one of you. Please sign the back of your credit card when you receive it You will be bound by this agreement I you or anyone authored by you use your account for any purpose, even if you dont sign your card. Whether you use your account or not, you will be bound by this agreement unless you cancel your accent within 30 days after receiving your card and you have not used your account for arty purpose. Throughout this agreement the words "we*, "us and "our" mean Chase Manhattan Bank USA, NA., the issuer of your credit card and account The words "you", "your" and "yaws" mean all persons responsible fa complying with this agreement, including the person who applied for the account and the person to whom we address bitfug statements, as well as any person who agrees to be liable on the account. The word "card" means one or more cards or other access devices, such as account numbers, that we have issued to permit you to obtain credit under this agreement. 2. USING YOUR ACCOUNT Your account is a consumer account and should be used only for personal, family or household purposes. Unless we agree or it is required by law, we will not be responsible for merchandise or services purchased or leased through use of your account. You promise to use your account only for valid and lawful transactions. For example, internet gambling may be illegal in some places. It is not our responsibility to make sure that you use your account only for permissible transactions, and you will remain responsible for paying for a transaction event it is not permissible. Types of Transactions: • Purchases: You may use your card to pay for goods or services. • Checks: We may provide you cash advance checks or balance transfer checks as a way to use your amount We also refer to them in this agreernert as a check or checks. You may use a check to pay for goods or services, to transfer balances to your account, or for other uses we allow. But you may rat use these checks to transfer balances to this account from other accounts with us or any of our related c ompanfes. Only the person whose name is printed on the check may sign the check. Cash advance checks may also be referred to as convenience checks. • Balance Transfers: You may tionsim balances from other accounts or loans with other credit card issuers or adw lenders to this account, or other balance transfers we allow. But you may not transfer balances to this account from other accounts with us or any ol our related cornpanfes. If a portion of a requested balance transfer will exceed your available credit fine, we may process a partial balance trar>ster up to your available credit fine. • Cash Advances: You may use yon card to get cash from automatic teller machines, or from financial iinsUeutions accepting the card; or to obtain travelers checks, foreign cuunrwy, money orders, wee transfers or similar cash-like charges; or to obtain lottery tickets, casino gaming chips, race track wagers or for similar betting transactions. You may also use a third party service to make a payment on you behalf and bill the payment to this account Cash Advances may also be referred to as Advances. • Neirritait Advances. H you have an eligible checking account with one of our related banks, you may link this acccint to your checking account with our related bank to cover an overdraft on that checking account under the terms of this agreement and your checking arcwunt agreement Billing Cycle: In order to manage your account, we divide time into periods called "billing cycles." Each billing cycle is agproxarrately one maM in length. For each calendar month, your account will have a billing cycle that ends in that month. Your account will have a billing cycle ending in each calendar month whether x t o, . . . . ?, W < . m G ?j< CC Q rmS S -3 t'+ ' iy m? 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CL 7 nnm c -0 3 d to c 0 C, W mna- zr ?G3a 7' S H y j O? ?=r O' X .T' .Z•' L ? m Ql ? 8- , o? ?gm<mc?m SWISH 'am°n'Dm3 °mH3°mmudN,mny=°o*3tcc,?a Dcl) <m.=Nmxn?o>c? m og-w co" .o n .m c. ??m? ym• m..?`?in?c3ap=m= ?p n m o 0wm a m a ??-`<?Et. si??dm?y w IC Q 090 4D.-C<50 cl? myym 0Ci aDt?i Mpjm..DZ W k m _ C'f ci n q < n U--.- 1- aci O S iD .. B. 7 9, - Z7 C n-- ? -c? C-) -4'9`0 c F1 0 Ft- p v ?a m 3o " 3 e °^ me r mm o a g m `,gymm. cp T m Z?.? C 5 AL C2 =8 - C.) M ?m pp?rY ?,o° g° n om n m B'? OR z sm w ?.' m m e ?_+. •' •' .. n.? m m 'l P3 m ?. c' 5.50. 5 o529nncc -0- 9 .? O CA vi-T;MC2":? .:-m, Col. IlD `gym ? m? ?p+s3? o f'° ' 3 ?""m7 {Q¢(p 3 e? y+ m ' W' r w _:'w`G0 7 C m m.?r ??°•.. r?'G . iC•N .Oi??O mGM=I"< too GI oAa $ 94 10 . 10 C" m.m T?3 c3?.' ?,m ? m - -C o m " fl? ? ,,$y?m ow2•? s ;s Cad s`P m ?O?pp m m m y° c w O m O ??^ 'Y CL. co . U.5 aw to ca m 9Rog? _a g'?ya? c r? 00:g to pa 33 O m ^. w m n ^ so = .CL Ot S°mNmv+c: m m 2 . a ?° $?ao r y o} to mo. ?< m m? o aQ 3 o cg'oory 7 fpT6? ? m m o'<¢ pamc'I C . m Z ?1•I IC m d< y ??p m ?C' y ?m ? " g< m n 00 fC y 7. y Ol d m O a5 w 3 m? O c m m iT 5 C- D at3 5.6? '.',cm 7 3c c3 <m 5W 0Sco, -.1 q o0O _CD Fr. m n 3 p ,d. -. O .?- m y c FL m m§ -I ms o a mm?K gm' mc.g Q m ??d n. p m? a:. Cf j ' 7. ; m p•w F 7 ?O' low's W 5_ i3l 11. o:n 7 NdCC o < „ O IE. g m ° m m m ?m C" RL o 82 0i CW to NO- 0' waO Z -cop •m m o 4. j. go c' m n W.2 tRp T- oocm3ogc_: /i ?[?D n.r, d MCI &C Cm-•- om m m o j4i o o m _ m .G ?•zg _. O •'? ? ? a?3?Soe Qmai?o sm m 0' m w yog?8 2 m N o 3 o 0 <@m cc n C3" ° g- S OR OR .,, .=°. 10lmYa ?ow 00.Gm 0 3 C. pS-'- m >>-1 m to o S: 7° m 00 your account for others, we may report account information in your name as well as in the names of those other people. If you think we have reported inaccurate information to a credit bureau, you may write to us at the Cardmember Service address listed on your billing statement Please include your name, address, account number, telephone number and a brief description of the problem. If available, please provide a copy of the credit bureau report in question. We will promptly investigate the matter and, if our investigation shows that you are right, we will contact each credit bureau to which we reported the information and will request they correct the report If we disagree with you after our investigation, we will tell you in writing or by telephone. We will also notify the credit bureau that you dispute the infomation unless you let us know that you no longer dispute the information. 11. NOTICE$/CHANGE OF PERSONAL INFORMATION We will send cards, billing statements and other notices to you at the address shown in our files. Or, if this is a joint account, we can send billing statements and notices to any joint account holder. Notice to one of you will be considered notice to all of you and all of you will remain obligated on the account. If you change your name, address, or home or business telephone number or email address (if you elect to receive billing statements or other notices on line), you must notify us immediately in writing at the address shown on the back of your billing statement We may, at our option, accept mailing address corrections from the United States Postal Service. 12. TELEPHONE MONITORING AND RECORDING We, and if applicable, our agents, may listen to and record your telephone calls with us. You agree that we, and if applicable, our agents, may do so, whether you or we initiate the telephone call `13 11:L111i01? C?1?ii)IIMEMBEftSE IN?ORNi1?TI0NSNAt31NCr Our Privacy Policy, which you have received, describes our unfomu"orf sharing Re'ttices and gives directions on how to opt out, or drect us •to (' the sharing of personal ittlbumatiorr about you with compames or organizations outside of our femilly of companies. Illinois law provides that we may.not shire infori mabon about you with companies or other organizations outside of our family of companies`unless you authorize the ds@osure .or unless the disclosure fags under another exception iri the law (such as sharing information taprocess your transactions or in.response to a subpoena). You hereby agrei that, 4 you. choose riot to exerese the opt out described in our Privacy Policy, .you A be deemed to have authorized us to share personal information we have about yI uJncludiing infoapation related to any of the products or services you may vel nth any .ot our companies) with companies or other organizations outside ifour family of cotnpaplnas , 14. ENFORCING THIS AGREEMENT We can delay enforcing or not enforce any of our rights under this agreement without losing our right to enforce them in the future. If any of the terms of this agreement are found to be unenforceable, all other terms will remain in full force. 15. ASSIGNMENT We may assign your account, any amounts you owe us, or any of our rights and obligations under this agreement to a third party. The person to whom we make the assignment wig be entitled to any of our rights that we assign to that person. 16. GOVERNING LAW THE TERMS AND ENFORCEMENT OF THIS AGREEMENT AND YOUR ACCOUNT SHALL BE GOVERNED AND INTERPRETED IN ACCORDANCE WITH FEDERAL LAW AND, TO THE EXTENT STATE LAW APPLIES, THE LAW OF DELAWARE, WITHOUT REGARD TO CONFLICT-OF-LAW PRINCIPLES. THE LAW OF DELAWARE, WHERE WE AND YOUR ACCOUNT ARE LOCATED, WILL APPLY NO MATTER WHERE YOU LIVE OR USE THE ACCOUNT. 17. FOR INFORMATION Please call the Cardmember Service telephone number on your card or billing statement if you have any questions about your account or this agreement 18. YOUR BILLING RIGHTS Keep This Notice for Future Use This notice contains important information about your rights and our responsibilities under the Fair Credt Big Act Notify Us In Case Of Errors Or Onestions About Your BRI If you think your big is wrong, or if you need more iiforration about a transaction on your big, write us on a separate sheet at the Cerdmember Service address shown on your billing statement Write to us as soon as possible. Vie must hear from you no later than 60 days after we sent you the first big 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, 'f you cam why you believe there is an error. If you need more information, describe the item you are not sure abouL If you have authorized us to pay your credit card bill automatically from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us at least three business days before the automatic payment is scheduled to occur. Your Rights!And Our ResponsibiR6es After We Receive Your Written Notice We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must eiUuer correct the error or explain why we believe the big was correct After we receive your letter, we cam try to collect any amount you question, or report you a? delinquent We can cnn*w to big 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 big that are not in question. 0 we find that we made a mistake on your big, you will not have to pay any finance charges related to any questioned amount. If we didnt 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 thk* you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within 10 days telling us that you stg ruse to purr, 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 bleep settled between us when it finally is. If we don't fallow these rules, we cant collect the first $50.00 of the questioned amount, even 'd your big was coned Special Rules for Credit Card Purchases If you have a problem with the quality of property or services that you purchased with a credit icard, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remutirw?g ammint due on the property or services. This right does not apply to check transactions. There are two limitations on this right:. (a) You must have made the purchase in your tome state or, if not within your home state, within 100 miles of vow current mailing address, and (b) The purchase price must have been more than $50.00. These limitat?o ns do not apply R we man or operate the merchant, or R we mailed you the advertisement for the property or services. Copyright 02004 JPMorgan Chase It Co. AN rights reserved. ADV2042 10/04 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff1 ?g???.tr of ??irril•?? Ito- t`.' ??-r ??t l?r ?'?Os???"'i Jody S Smith Chief Deputy Edward L Schorpp Solicitor N, i? Asset Acceptance LLC vs. Mark Reese Case Number 2010-2067 SHERIFF'S RETURN OF SERVICE 03/29/2010 08:47 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2010 at 2047 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark Reese, by making known unto Carolyn Geyer, Mother of defendant at 339 Regent Street, 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. 4 /l . MICHA L BARRIC DEPUTY SHERIFF COST: $41.50 March 30, 2010 SO ANSWERS, (;" x 2?2 RONtrY R ANDERSON, SHERIFF ? ae;?yS t SrPrr ?E ?r a,::. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC Plaintiff vs. MARK REESE Defendant CIVIL DIVISION NO: 10-2067 c-> r~ 0 i t ~ ~, ~. ~ c ~:~= _ ~i r- W ~ c..w f.. , 4~ . _. _- ~.::~ W Tr _~+ ;~; ~, PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE CLERK OF JUDICIAL RECORDS: Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the amount of $8,914.37. Notice of the intent to file a default judgment was served upon the Defendant on May 18, 2010. A copy of the Notice of Intent to Take Default Judgment is attached hereto and marked Exhibit "A." Edwin A. Abrahamsen & ~Vli~hael F. R~,ltcliford, Esquire Attorney I.D. No.: 86285 Attorney for Plaintiff JUDGMENT AND NOW, this ~_ day of ~, 20f0 ,Judgment is hereby entered in favor of the Plaintiff, ASSET ACCEPTANCE LLC and'a ainst the Defen g dant, MARK REESE m the amount of $8,914.37 for failure to respond to Plaintiff's Complaint. CLERK OF JUDICIAL RECORDS J. ~I~.00 ~PQ A77'~ ef4oro~{ ~a~~q5~ Nofie~ l~t.Cac~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC Plaintiff : CIVIL DIVISION vs. NO: 10-2067 MARK REESE Defendant : CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served a copy of the Praecipe for Entry of Default Judgment in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: MARK REESE 339 REGENT ST CAMP HILL PA 17011 Edwin A. Abrahamsen & Associates, P.C. Date: July 8, 2010 1~ylichael F. Ratchford, Esquire Attorney I.D. No.: 86285 120 N. Keyser Avenue Scranton, PA 18504 (570) 558-5510 ASSET ACCEPTANCE LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division MARK REESE vs. NO: ] 0-2067 AFFIDAVIT UNDER SOLDIERS AND SAILORS Defendant RELIEF CfVIL RELIEF ACT OF 1940 AS AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): MARK REESE is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): MARK REESE is(are) older than eighteen years of age; That the employment status of the defendant(s): MARK REESE is(are) unknown. Lee Per°ricone, Notary Public NOTARIAL SEAL LEE PERRICONE Notary Public SCRANTON CITY, LACKAWANNA COUNTY My Commission Expires Apr 2, 2014 Subscribed before me this ~~r day of ~ _„ , ~_~ EGNJIPJ A, ,4ER4HAhASEM MICHAEL F. RATLHFORG HEATHER I:. YIOOURUFF" A.lSO A MEMBER OF Fl BAR MARK REESE 339 REGENT ST CAMP HILL PA 1701 1 171 Il ~~~ THE I.AW OFFICE OF laD>,tiIN:~. aBR.~H.~RLEN S :1SSOCL~ITES, PG WWW.EAA-LAW.COM May 18, 2010 Re: ASSET ACCEPTANCE LLC v. MARK REESE CUMBERLAND County Civil Action No.:10-2067 Our file No.: AA 100897/MF Dear MARK REESE: Enclosed please find the Ten Day Notice of Tntent to Take Default in regard to the above- noted matter. Please act accordingly. If you have any questions or wish to discuss your outstanding account, please contact me at (570) 558-5510. Edwin A. Abrahamsen & Associates, Kevin J. Cummings, Esquire Enclosure This is a communication from a debt collector in an attempt to collect a debt. Any information will be used for that purpose. ~• 1Y0 N KEYSER AVE SfRANiON, PA 18504 ~ (P) 570.558.5510 (F) 510.558.5511 .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC CIVIL ACTION Plaintiff vs. MARK REESE NO: ] 0-2067 Defendant ti TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: MARK REESE 339 REGENT ST CAMP HILL PA 1701 I Date of Notice: May 18. 2010 IMPORTANT NOTICE PURSUANT TO PA.R.C.P. 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN 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. r :,: 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. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC CIVIL ACTION Plaintiff : vs. MARK REESE NO: 10-2067 Defendant CERIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on May 18, 2010 I served a copy of the Ten Day Notice of Intent to Take Default in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: MARK REESE 339 REGENT ST CAMP HILL PA 1701 1 Edwin A. Abrahamsen & Associates, P.C. BY: Michael F. Ratchford, Esquire Attorney I.D. No.: 86285 Kevin J. Cummings, Esquire Attorney I.D. No.: 209660 120 N Keyser Avenue Scranton, PA 18504 (570) 558-5510 '.';: Request fot-Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act https://www.dmdc.osd.mil/appj/scra/popreport.do Jul-29-2010 11:52:50 m~"C Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency REESE MARK 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). 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.miUfaq/uis/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. 1 of 2 7/29/2010 2:51 PM Request fot Military Status https://www.dmdc.osd.mi I/appj/scra/popreport.do 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 autharized 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:4N7SG76UFC 2 of 2 7/29/2010 2:51 PM ASSET ACCEPTANCE LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division vs. MARK REESE NO: 10-2067 Defendant NOTICE OF FILING JUDGMENT Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the amount of $~j, Ql~, ~7 4t„~~o on - ~~. By: ~- If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 120 N. Keyser Avenue Scranton, PA 18504 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)