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HomeMy WebLinkAbout10-4209,10 s OF ??c P Oi H NOTAPY 231, 0 J 1,111-4 23 PN 3: 1 I II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. GEORGE STOJKOVICH Defendant No - 10 - 4(a09 CiV a l E'E.1'CYt COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.AI. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. Civil Action No GEORGE STOJKOVICH Defendant COMPLAINT AND NOTICE TO DEFEND 11 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 enterng a written appearance personally or by an attorney and filing in writi'g 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 b the court without further notice for any money claimed in the complaint o for any other claim or relief requested by the plaintiff. You may lo?e money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO' 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 ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 -fta.00 Papal C? 4loa'?i' 5? e,? ayy 14? !? COMPLAINT 1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at 3700 WISEMAN BLVD. SAN ANTONIO , TX 78251 . 2. Defendant , is adult individual(s) residing at the address listed below: GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX6973 . 4. Defendant made use of said credit card and has a current balance due of $21081.82 . 5. Defendant is in default of the terms of the Cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, and accrued interest or any part thereof to Plaintiff. Wherefore, the Plaintiff prays for judgment against Defendant GEORGE STOJKOVICH , INDIVIDUALLY , the amount of $21081.82 with continuing interest thereon at the statutory rate of 6.000% per annum! from June 04, 2010 , plus attorneys fees of $300.00 and costs. ames 436 S 08364520 C J Pit SJS Pitt (412 FAX This law firm is a debt collector atte pt our client and any information obtain w F ro ,42524 ERG & REIS CO., L.P1A. enue, Suite 1400 15219 130 ng to collect this debt for 11 be used for that purpose.! II Payment Due Date New Balance Ainimum Payment 03/22!10 S27,081.82 5421.00 8842.00 Account number: 6973 ih WA 7 Make your check payable to: Chase Card Services. Please write amount enclosed. New address or e-mail? Print on back. 69730008420002108182000000000000003 24799 BEX 9 05610C GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG PA 17257-9628 1-111rolllllrllllllllllllll0111111IIlllllll111lllill...doll [ACCOUNT SUMMARY Account Number: 4100000MM6973 Previous Balance 521,081.60 Payment, Credits -$107.00 Fees Charged +$39.00 Interest Charged -$68.22 New Balance $21,081 82 Opening/Closing Date 01/26/10 - 02125/10 Total Credit Line 521,500 Available Credit $418 Cash Access Line $4,300 Available for Cash $0 1: 5000 160 281: 69 7 3 1116 ®Manage your account online: Additional contact information vereuoraoMUl4s www.chase.com/disnev conveniently located on reverse side 8364520 PAYMENT INFORMATION New Bale 521,081.82 Payment Due Date 03/22/10 Minimum Payment Due 5842.00 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay up to a $39.00 late fee and your APRs will be subject to increase to a maximum Penalty APR of 27.99%. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no You will pay off the And you will end up additional charges balance shown on paying an estimated using this card and this statement in total of... each month you about... pay,.. Only the minimum 37 years $43,470 payment $708 3 years $25,493 (Savings=S17,977) IT you would like information about credit counseling services, call 1-866-797-2885. DISNEY DREAM REWARD DOLLill Balance from last statement 49 Please call 800-300.8575 to redeem your Reward dollars earned from net purchases -1 Disney Rewards@ or if you have any questions Reward dollars transferred to Rewards Card 0 about the Disney RewardsO Program. Remaining balance 48 41 Reward dollars that will expire 12/2014 7 Reward dollars that will expire 01/2015 Cardmember ID: 15656975 Use your Cardmember ID for special limited-time promotions such as Refer A Friend. 1111111110111111111101111111111rl llllllllll 111 ll llolllllllllrl CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 Your account Is past due, therefore rewards earned this period have not been posted to your account. Please make the minimum payment due immediately to avoid forfeiture of rewards. TOTAL FEES FOR THIS PERIOD IA1Te" CNAReft u2l"1S PURCHASE INTEREST CHARGE 02/25 PROMOTION INTEREST CHARGE TOTAL INTEREST FOR THIS PERIOD ACCOUNT ACTIVITY Date of Transaction Merchant Name or Transaction Description 5 Amount u2/0`L Clipl_TL1r SCEN7P_ LJ07 ?r1 _HEEKTCWAGA Nr ..•.?1 LET- SEE 0000001 F1533336 C 4 000 V 9 25 10/02125 Page 1 of 2 J( 0044INS14496 REWARD VWCAW 940M CUM sa ;tit 9 00 54.63 13 59 $68.22 06272 MA MA 24799 05610000040002479901 EXHIBIT I Statement Date: 01/26/10 - 0212:, - Account Number: 4266 9020 2582 6973 Page 2 of 2 . 2O1(F'Tota *.YW4o-bate Total fees charged in 2010 539.00 Total interest charged in 2010 568.22 Year-to-dale totals reflect all charges minus any refunds applied to your account on or after January 31, 2010. INTEREST CHARGES Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Balance Accrued Balance Percentage Rate (APR) Subject To Interest Interest' Type 31 Days In Cycle Interest Rate Charges Charges Purchases 13.24% (v) $4,858.91 554.63 $0 00 Cash Advances 19.24% (v) $0.00 80.00 . $0 00 Promotion 0.99% $16,178.37 513.59 . 50.00 (v) = Variable Rate Please see Information About Your Account section for the Calculation of Balance Subject to Interest Rate, Annual Renewal Notice How to Avoid Interest on Purchases, and other important Information, as applicable. 8364520 X 0000001 FIS33336 C 4 000 v 9 25 1002/25 Page 2 oft 06272 MA MA 24799 05610000040002479902 Cardmember Agreement CMA12762 ACCEPTANCE OFTHIS 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. You authorize us to pay for and charge your account for all transactions made on your account. You promise to pay us for alltransactions made on your account, as well as anyfees or finance charges. 11 this is a joint account, each of you, together and individually, is responsible for paying all amounts owed, even if the account is used by only one of you. We may require that you pay the full amount owed without first asking the other person(s) to pay. Please sign the back ofyour cardwhen you receive it. Youwill be bound by this agreement if you or anyone authorized by you use your account for any purpose, even if you don't sign your card. Whetheryou use your arcount or not, you will be bound by this agreement unless you cancel your account within 30 days after receiving your card and you have not used your account for any purpose. Throughout this agreement; the words "we", "us" and'our mean Chase Bank USA, N.A., the issuer of your credit card and account. The words "you", 'your and "yours" mean all persons responsible for complying with this agreement, including the person who applied for the account and the person to whom we address billing statements, as well as any person who agrees to be liable an the account. The word "card" means one ormore cards or other access devices, such as account numbers, that we have issued to permit you to obtain credit under this agreement. USING YOUR ACCOUNT Your account is a consumer account and shall 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. 11 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 even if it is not permissible or contemplated under this agreement 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 wayto use youraccount. We also refer to them in this agreementas 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 not use these checks to transfer balances to this account from other accounts with us or any of our related companies. Only the person whose name is printed on the check may sign the chock. Cash advance checks are treated as cash advances and balance transfer checks are treated as balance transfers except as noted in this agreement or any offer we make to you. We may treat checks that we call convenience checks as balance transfer checks. However, checks that we call convenience checks and that we indicated to you are subject to the terms for cash advances, may be treated as cash advances and assessed cash advance rates and fees. • Balance Transfers: You may transfer balances from other accounts or loans with other credit card issuers or otherlenders to this account, or other balance transferswe allow. But you may not transfer balances to this account from other accounts with us or any of our related companies. If a portion of a requested balance transferwill exceed your available credit line, we may process a partial balance transfer up to your available credit line. • Cash Advances: You may use your card to get cash from automatic teller machines, or from financial institutions accepting the card; or to obtain travelers checks, foreign currency, money orders,wire transfers or similar cash-like charges; or to obtain lottery tickets, casino gaming chips, race track wagers or for similar belting transactions. You may also use a third partyservice to make a payment on yourbehalf and bill the payment to this account. • Overdraft Advances: It you have an eligible checking account with one of our related banks, you may link this account 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 account agreement. Billing Cycle: In order to manage your account, we divide time into periods called"billing cycles Each billing cycle is approximately one month in length. For each calendarmonth, 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 or Pot there is a billing statement for that billing cycle. Authorized Users: If you allow someone to use your account, that person will be an authorized user. You may request an additional card for use by an authorized user on your account. If you do so, this account may appearon the credit report of that authorized user. You should think carefully before allowing anyone to become an authorized user because you are allowing that person to use thu account as you can. You will remain responsible for the use of your account and each card issued on your account according to the terms of this agreement. This includes your responsibility for paying all charges on your account made by an authorized user. You must notify us to terminate an authorized user's permission to use your account. If you notify us, we may close the account and/or issue a new card or cards with a different account number. You should also recover and destroy any cards, checks or any other means of access to your account from that authorized user. Credit Line: Your credit line appears on your billing statements. We may also refer to the credit line as a credit limit. Your billing statement may also show that only a portion of your credit line may be used for cash advances. Cash advances, including cash advance checks, are charged against the cash advance portion of your credit fine, anti all other transactions are charged against your credit line. You are responsible for keeping track Page 1 of 6 of your account balance, including any fees and finance charges, and making sure it remains below your credit line. If your account balance is over your credit line for any reason, we may charge you an overlimit fee as described in this agreement We may, but are not required to, authorize charges that go over your credit line. You must pay shy amount over your credit line, and you must pay us immediately if we ask you to. This agreement applies to any balance on your account, including any balance over your credit line. At our discretion, we may increase, reduce, or cancel your credit line, or the cash advance portion of your credit line, at any time. However, it you have asked us not to do so, We will notincrease your credit line. A change to your credit line wig not affect your obligation to pay us. International Transactions: International transactions include any transaction that YOU make in a foreign currency orthat you stake outside ofthe United States ofAmerica eve n if it is made in U.S. dollars. If you make a transaction in a foreign currency, Visa International or MasterCard International, Inc., will convert the transaction into U. . dollars by using its respective currency conversion procedures. The exchange rate each entity uses to convert currency is a rate that it selects either from the range of rates available in the wholesale currency markets for the applicable processing date (whic rate may vary from the rate the respective entity itself receives), or the government-mandated rate in effect on the applicable processing date. The rate in ofle t on the applicable processing date may differ train tire rate on the date you used your car or account. We reserve the right to charge you an additional 3% of the U.S. dollar amott t of any international transaction, whether that transaction was originally made in U. S, dollars or was made in another currency and converted to U.S. dollars by Visa or MasterCard. In either case, the 3% will be calculated on the U.S. dollar amount provide to us by that entity. The same process and charges may apply if any international transaction is reversed. Refusal to Authorize Transactions: We may, but are not required to, decline a transaction on your account for any of the following reasons: • because of operational considerations, • because your account is in default, • if we suspect fraudulent or unlawful activity or, • in our discretion, for any other reason. We are not responsible for any losses if a transaction on your account is declined to? any reason, either by us or a third party, even if you have sufficient credit available. I For online transactions, we may require that you register your account with a? authorization system that we select. We will notify you if we want you to register. if yo do not register, we may decline your online transactions. Refusal to Pay Checks: Each check you write is your request for funds. When we receive a check for payment, we may review your account to decide whether to authorize that check. We may, but are not required to, reject and return unpaid a check for any reason, including the following examples: • We or one of our related companies is the payee on the check. • Your credit line or cash advance portion of your credit line has been exceeded, orwould be exceeded if we paid the check. • The check is post-dated. If a post-dated check is paid, resulting in another check being returned or not paid, we are not responsible. • You have used the check after the date specified on it. • You are in default or would be if we paid the check. Lost OF Stolen Cards, Checks or Account Numbers: If any card, check, account number or other means to access your account is lost or stolen, or you think someone used or may use them without your permission, you must notify its at once by calling the Cardmember Service telephone number shown on your card or billing statement. Do not use your account after you notify us, even if your card, check, account number or other means to access your account is found or returned. We may terminate or suspend your credit privileges when you notify us of any loss, theft or unauthorized use related to your account. You may be liable if there is unauthorized use of your account from which you receive no benefit, but you will not be liable for more than 550.00 of such transactions, and you will not be liable for any such transactions made after you notify us of the loss, theft or unauthorized use. However, you must identity for us the unauthorized charges from which you received no benefit. We may require you to provide us information in writing to help us find out what happened. We may also require you to comply with certain procedures in connection with our investigation. PAYMENTS Payment Instructions: Your billing statement and accompanying envelope include I!i instructions you must follow for making payments and sets forth the date and time by li which we must receive the payment. You agree to pay us amounts you owe in U.S. dollars drawn on funds on deposit in a U.S. financial institution or the U.S. branch of a foreign financial institution using a payment check, moneyorder or alltDMatic debitthat will be processed or honored byyour financial ! institution. We will not accept cash payments. Your total available credit may not be restored for up to 15 days after we receive your payment. Any payment check or other form of payment which you send to us for less than the full balance that is marked *paid in full"or with a similar notation orthat you otherwise tender in full satisfaction of a disputed amount (conditional payments), must be sent to us atthe conditional payments address listed on your monthly statement. We reserve all our rights regarding such payments. For example, if it is determined there is no valid dispute or if any such payment is received at any other address, we may accept the payment and you will still owe any remaining balance. We may refuse to accept any such payment by returning it to you, not cashing it or by destroying it. All other payments that Vol) make should be sent to the regular payment address shown on your monthly statements. EXHIBIT 2 We reserve the right to electronically collect your eligible payment checks, at first presentment and any representment, from the bank account on which the check is drawn. Our receipt of your payment checks is your authorization for us to collect the amount of the check electronically, or, if needed, by a draft drawn against the bank account. Payment checks will be collected electronically by sending the check amount along with the check, routing and account numbers to your bank. Your bank account may be debited as early as the same day we receive your payment The original payment check will be destroyed and an image will be maintained in our records. Minimum Payment: You agree to pay at least the minimum payment due, as shown on your billing statement, so that we receive it by the date and time paymentis due. You may pay more than the minimum payment due and may pay the full amount you owe us at any time. If you have a balance that is subject to finance charges, the sooneryou pay us, the less you will pay in finance charges because finance charges accrue on your balance each day. Your billing statement shows your beginning balance and your ending balance (the "New Balance" on your billing statement). If the New Balance is S1D.DO or less, your minimum payment due will be the New Balarico. Otherwise, it will be the largest of the following: S10.00; 2% of the New Balance; or the sum of 1% of the New Balance, total billed periodic rate finance charges, and any billed late and overfimit fees. As part of the minimum payment due, we also add any amount past due and any amount over your credit line. Payment Allocation: You agree that we are authorized to allocate your payments and credits in a way that is most favorable to or convenient for us. For example, you authorize us to apply your payments and credits to balances with lower APRs (such as promotional APRs) before balances with higher APRs. Credit Balances: You may request a refund of a credit balance at any time. We may reduce the amount of any credit balance by the amount of new charges or fees billed to your account. Automatic Charges: You may authorize a third party to automatically charge your account for repeat transactions Ifor example, monthly utility charges, memberships and insurance premiums). If automatic charges are stopped for any reason (including because your account is closed or suspended for any reason) or your account number changes, you are responsible for notifying the billerand paying these charges directly. If your account number changes, we may, but are not required to, pay from your new account number chargesthatyou authorized to be billedto yourold account number. Promotions: From time to time we may offer special terms for your account If we do, we will notifyyou about the terms of the offer and how long theywill be in effect. Any promotion is subject to the terns of this agreement, as modified by the promotional offer. FINANCE CHARGES Daily Periodic Rates and Annual Percentage Rates: Your annual percentage rates ("APRs) and the corresponding daily periodic rates are listed on the Rates and Fees Table that is at the end of this document or provided separately. To get the daily periodic rate we divide the APR by 365, and in effect always round up at the fifth place to the right of the decimal point. Variable Rates: One or more APRsthat applytoyour account mayvarywith changes to the Prime Rate. When you have an APR that varies with changes to the Prime Rate, we calculate the APR by adding a margin to the Prime Rate published in The Wall Street Journaltwo business days before the Closing Date shown on your billing statement. The "Prime Rate" is the highest (U.S.) Prime Rate published in the Money Rates section of The Wall SrreetJournal. If The Wall SrreetJourna/stops publishing the Prime Rate, we will select a similar reference rate and inform you on yourbilling statement or through a separate notice. A "margin" is the percentage we add to the Prime Rate to calculate the APR. A "business day" is any day that is not a weekend or federal holiday. The Rates and Fees Table shows which rates, if any, are variable rates. It also lists the margin for each variable rate and any minimum daily periodic rate and corresponding APR. Two business days before the Closing Date shown on your billing statement; we see what the Prime Rate is. We then add the applicable margin to that Prime Rate to get the APR. The daily periodic rate is calculated as described above. If our calculation results in a change to a daily periodic rate from the previous billing cycle because the Prime Rate has changed, the new rate will apply as of the first day of your billing cycle that ends in the calendar month in which we made the calculation. If the daily periodic rate increases, you will have to pay a higherperiodic finance charge and may have to pay a higher minimum payment. Default Rates: Your APRs also may vary if you are in default under this agreement or any other agreement you have with us or any of our related companies for any of the following reasons: • We do not receive, for any payment that is owed on this account or any other account or loan with us, at least the minimum payment due by the date and time due. • You exceed your credit line on this account. • You make a payment to us that is not honored byyour bank. If any of these events occurs, we may increase the APRs (including any promotional APR) on all balances lexcluding overdraft advances) up to a maximum of the default rate stated in the Rates and Fees Table. We may consider the following factors to determine your default rate: the length of time your account has been open, the existence, seriousness and timing of the defaults on your account; other indications of your account usage and performance; information aboutyour other relationships with us or any of our related companies; and information we obtain from consumer credit reports obtained from credit bureaus. The default rage will take effect as of the first day of the billing cycle in which the default occurs. If we decide not to increase your APR even though there is a defaulter if we do not increase your APR up to the maximum default rate stated in the Rates and Fees Table, we reserve our right to increase your APR in the event of any future default. We may in our discretion determine to charge reduced default rates or reinstate standard rates for all or selected balances on your account Finance Charge Calculation - Average Daily Balance Method (Including New Transactions). We calculate periodic finance charges separately for each balance associated with a different category of Ira nsactions (for example, purchases, balance transfers, balance transfer checks, cash advances, cash advance checks, overdraft advances, and each promotion). These calculations may combine different categories with the same daily periodic rates. This is how it works: We calculate periodic finance charges for purchases, balance transfers, balance transfer checks, cash advances, cash advance checks, and overdraft advances by multiplying the daily balance for each of those categories by the daily periodic rate for each of those categories, each day. You may have overdraft advances only if you have linked this account to a checking account with one of our related banks. We calculate the periodic finance charges for purchases, balance transfers, balance transfer checks, cash advances, and cash advance checks subjectto a promotional rate the same way, but we use the promotional rate. To get the daily balance for each day for each category: • We take the beginning balance for that day. • We add to that balance any new transactions, fees, other charges, and debit adjustments that apply to that category. We add a new purchase, cash advance, balance transfer or overdraft advance, if applicable, to the daily balance as of the transaction date, or a later date of our choice. We add a new cash advance check or balance transfer check to the daily balance as of the date the cash advance check or balance transfer check is deposited by a payee, or a later date of our choice. • We subtract from that balance any payments, credits, or credit adjustments that apply to that category and that are credited as of that day. • We treat a credit balance as a balance of zero. To get the beginning balance for each category for the next day, we add the daily periodic finance charge to the daily balance. If more than one daily periodic rate could apply to a category because tite rate for the category may vary based on the amount of its average daily balance, we will use the daily periodic rate that applies for the average daily balance amount at the end of the billing cycle to calculate the daily periodic finance charge each day. This agreement provides for daily compounding of finance charges. To get the total periodic finance charge for the billing cycle, we add all of the daily periodic finance charges for each category for each day during that billing cycle. However, if any periodic finance charge is due, we will charge you at least the minimum periodic finance charge stated in the Rates and Fees Table. If it is necessary to add an additional amount to reach the minimum finance charge, we add that amount to the balance for purchases made during the billing cycle. The total finance charge on your account for a billing cycle will be the sum of the periodic finance charges plus any transaction fee finance charges. F )r each categorywe calculate an average daily balance (including new transactions) for the billing cycle by adding all your daily balances and dividing that amount by the number of days in the billing cycle. If you multiply the average daily balance for a category bythe applicable daily periodic rate, and multiply the result bythe number of days in the billing cycle, the total will equal the periodic finance chargus for that balance attributable to that billing cycle, except for minorvariations due to rounding. Grace Period and Accrual of Finance Charges: We accrue periodic finance charges on a transaction, fee, or finance charge from the date it is added to your daily balance until payment in full is received on your account. However, we do not charge periodic finance charges on new purchases billed during a billing cycle if we receive payment of your New Balance by the date and time your minimum payment is due and we received payment of your New Balance on your previous billing statement by the date and time your payment was due. This exception or "grace period" applies only to purchases and does not applyto balance transfers, balance transfer checks, cash advances, cash advance checks or overdraft advances, if applicable. Transaction Fees for Cash Advances: We may charge you a cash advance fee in the amount stated in the Rates and Fees Table for cash advance checks and cash advances. In addition, it you use a third party service to make a payment on your behalf and the service charges the payment to this account, we may charge a transaction fee for the payment. These transaction fees are finance charges. We add the fee to the balance for the related category as of the transaction date of the cash advance. For example, a transaction fee for a cash advance would be added to your cash advance balance. Transaction Fees for Balance Transfers: Wu may charge you a balance transfer lee in the amount stated in the Rates and Foes Table for balance transfer checks and balance transfers. These transaction fees are finance charges. We add the fee to the balance for the related category as of the transaction date of the balance transfer. For example, a transaction fee for a balance transfer would be added to your balance transfer balance. OTHER FEES AND CHARGES We maycharge the following fees. The amounts ofthese fees are listed in the Oates and Fees Table. These fees will be added to the balance for purchases made during the billing cycle. Annual Membership Fee: If your account has an annual membership fee, it will be billed each year or in monthly installments (as staled in the Rates and Fees Table), whether or not you use your account, and you agree to pay it when billed. The annual Page 2 of 6 CMA12762 membership fee is non-refundable unless you notify us that you wish to close your a ccoun within 30 days of the date we mail your billing statement on which the annual membership fee is charged and at the same time, you pay your outstanding balance in full. Your payment of the annual membership fee does not affect our right to close your account orlimit your right to make transactions on your account. If your account is closed by you or us, we will continue to charge the annual membership fee until you payyour outstanding balance in full and terminate your account relationship. Late Fee: If we do not receive at least the required minimum payment by the date and time it is due as shown on your billing statement for any billing cycle, we may chargu the late fee shown in the Rates and Fees Table. If the fate fee is based on a balance, we calculate the late fee using the Previous Balance on the current month's statement that shows the late fee. This balance is the same as the New Balance shown on the prior month's statement for which we did not receive at least the required minimum payment by the date and time it was due. Overlimit Fee: If your account balance is over your creditline at any time during a billing cycle, even if only for a day, we may charge an overlimit fee. We may charge this fee even if your balance is overthe credit line because Ole finance charge orfeewe imposed or a transaction we authorized. We will not charge more than one overlimit fee for any billing cycle. But we may charge an overlimit fee in subsequent billing cycles, even if no new transactions are made on your account, if your account balance still is over your credit line at any time during the subsequent billing cycles. Return Payment Fee: If (a) your payment check or similar instrument is not honored, (b) an automatic debit or other electronic payment is returned unpaid, or (c) we must return a payment check because it is not signed or cannot be processed, we may charge a return payment fee. Return Check Fee: If (a) we stop payment on a cash advance check or balance transfer check atyour request, or (b) we refuse to pay a cash advance chock or balance transfer check, we may charge a return check fee. Administrative Fees: If you request a copy of a billing statement, sales draft or other record of your account or it you request two or more cards or any special services (for example, obtaining cards on an expedited basis), we may charge you for these services. However, we will not charge you for copies of billing statements, sales drafts or similar documents thatyou requestfor a billing disputeyou may assertagainstus under applicable law. We may charge, for any services listed above and other services we provide, the fees from time to time in effect when we offer the service. DEFAULT/COLLECTION We may consider you to be in default if any of these occurs: • We do not receive at least the minimum amount due by the date and time due as shown on your billing statement. • You exceed your credit line. • You fail to comply with the terms of this agreement or any agreement with one of our related companies. • We obtain information that causes us to believe that you may be unwilling or unable to pay your debts to us or to others on time. • You file for bankruptcy. • You become incapacitated or in the event of your death. If we consider your account to be in default, we may close your account without notice and require you to pay your unpaid bahrncu immediately. We also may require you to pay interest at the rate of two percent (2%) a month on the unpaid balance when we deem your account to be six or more billing cycles past due. To the extent permitted by law, if you are in default because you have failed to pay us, you will pay our collection costs, attorneys' fees, court costs, and all other expenses of enforcing our rights under this agreement. CLOSING YOUR ACCOUNT You may close your account at any time. If you call us to close your account, we may require that you confirm your request in writing. We may close your account at any time or suspend your credit privileges at any time for any reason without prior notice except as required by applicable law. If we close your account, we will not be liable to you for any consequences resulting from closing your account or suspending your credit privileges. If you or we close your account, you and any authorized users must immediately stop using your account and destroy all cards, checks or other means to access your account or return them to us upon request. You will continue to be responsible for charges to your account, even if they are made or processed after your account is closed and you will be required to pay the outstanding balance on your account according to the terms of this agreement. In addition, to the extent allowed by law, we may require you to pay the outstanding balance immediately or at any time after your account is closed. ARBITRATION AGREEMENT PLEASE READ THIS AGREEMENT CAREFULLY. IT PROVIDES THAT ANY DISPUTE MAY BE RESOLVED BY BINDING ARBITRATION. ARBITRATION REPLACES THE RIGHT TO GO TO COURT. YOU WILL NOT BE ABLE TO BRING A CLASS ACTION OR OTHER REPRESENTATIVE ACTION IN COURT SUCH AS THAT IN THE FORM OF A PRIVATE ATTORNEY GENERAL ACTION, NOR WILL YOU BE ABLE TO BRING ANY CLAIM IN ARBITRATION AS A CLASS ACTION OR OTHER REPRESENTATIVE ACTION. YOU WILL NOT BEAGLE TO BE PART DFANY CLASS ACTION OR OTHER REPRESENTATIVE ACTION BROUGHT BY ANYONE ELSE, OR BE REPRESENTED IN A CLASS ACTION OR OTHER REPRESENTATIVE ACTION. IN THEABSENCE OF THIS ARBITRATION AGREEMENT, YOU AND WE MAY OTHERWISE HAVE HAD A RIGHT OR OPPORTUNITY TO BRING CLAIMS INA COURT, BEFOREA JUDGE OR JURY,AND/OR TO PARTICIPATE OR BE REPRESENTED IN A CASE FILED IN COURT BY OTHERS (INCLUDING CLASS ACTIONS AND OTHER REPRESENTATIVE ACTIONS). OTHER RIGHTS THAT YOU WOULD HAVE IF YOU WENT TO A COURT, SUCH AS DISCOVERY OR THE RIGHT TO APPEAL THE DECISION MAY BE MORELIMITEO. EXCEPTAS OTHERWISE PROVIDED BELOW,THOSE RIGHTS ARE WAIVED. t Binding Arbitration. This Arbitration Aoreementismade pursuanttoatransactioninvolving interstate commerce, and shall be governed by and be enforceable under the Federal Arbitration Act (the "FAA'), 9 U.S.C. 41-16 as it may be amended. This Arbitration Agreement sets forth the circumstances and procedures under which claims (as defined below) may be resolved by arbitration instead of being litigated in court. Parties Covered. For the purposes of this Arbitration Agreement, "we , "us , and "our also includes our parent, subsidiaries, affiliates, licensees, predecessors, successors, assigns, any purchaser of your Account, and all of their officers, directors, employees, agents, and assigns or any and allot them. Additionally,'we","us"and"our shall include anyythirtd party providing benefits, services, orpruducts in connection with the Account (Inc ludi g but not limited to credit bureaus, merchants that accept any credit device issued under the Account, rewards programs and enrollment services, credit insurance companie , debt collectors, and all of their officers, directors, employees, agents and representatives) if, and only if, such a third party is named by you as a co-defendant in any Claim you asse against us. Claims Covered. Either you or we may, without the other's consent, elect mandator, , binding arbitration of any claim, dispute or controversy by either you or us against th other, or againstthe employees, parents, subsidiaries, affiliates, beneficiaries, agents Pr assigns of the other, arising from or relating in any way to the Cardmember Agreeman any prior Cardmember Agreement, your credit card Account or the advertising, applicatio or approval of your Account ('Claim"). This Arbitration Agreement governs all Claim whether such Claims are based on law, statute, contract, regulation, ordinance, to common law, constitutional provision, or any legal theory of law such as respondea superior, orany other legal or equitable ground andwhether such Claims seek as remedie money damages, penalties, injunctions, or declaratory or equitable relief. Claims subjec to this Arbitration Agreement include Claims regarding the applicability of this Arbitratio Agreement orthe validity afthe entire Cardmember Agreement or any prior Cardmembe Agreement. This Arbitration Agreement includes Claims that arose in the past, or ails in the present or the future. As used in this Arbitration Agreement, the term Claim is t be given the broadest possible meaning. Claims subjectto arbitration include Claims that are made as counterclaims, cross claims, third party claims, interpleaders or otherwise, and a party who initiates a proceeding in court may elect arbitration with respect to any such Claims advanced in the lawsuit by any party or parties. As an exception to this Arbitration Agreement, you retain the right to pursue in a small) claims court any Claim that is within that court's jurisdiction and proceeds on an individual basis. If a party elects to arbitrate a Claim, the arbitration will be conducted as an individual action. Neither you nor we agree to any arbitration on a class or representative basis, and the. arbitrator shall have no authority to proceed on such basis. This means that even it a class action lawsuit or other representative action, such as that in the form of a private attorney general action, is filed, any Claim between us related to the issues raised in such lawsuits will be subject to an individual arbitration claim if either you or we so elect. No arbitration will be consolidated with any other arbitration proceeding without the consent of all parties. The only Claims that may be joined in an individual action under this Arbitration Agreement are (1) those brought by us against you and any co-applicant, joint cardmember, or authorized user of your Account, or your heirs or your trustee in bankruptcy or (2) those brought by you and any Co-applicant, joint cardmember, or authorized user of your Account, or your heirs or your trustee in bankruptcy against us. Initiation of Arbitration. The parry filing a Claim in arbitration must choose one of the following two arbitration administrators: American Arbitration Association; or National Arbitration Forum. These administrators are independent from us. The administrator does not conduct the arbitration. Arbitration is conducted under the rules of the selected arbitration administrator by an impartial third party chosen in accordance with the rules of the selected arbitration administrator and as may be provided in this Arbitration Agreement. Any arbitration hearing that you attend shall be held at a place chosen by the arbitrator or arbitration administrator within the federal judicial district in which you reside at the time the Claim is filed, or at some other place to which you and we agree in writing. You may obtain copies of the current rules of each of the two arbitration administrators, information about arbitration and arbitration fees, and instructions for initiating arbitration by contacting the arbitration administrators as follows: American Arbitration Association, 335 Madison Avenue, Floor 10, New York, NY 1D017-4605, Web site: www.adr.org, 800-778-7879; or National Arbitration Forum, P.O. Box 50191, Minneapolis, MN 55405, Web site: www.arbitration-forum.com, BOD-474.237E Procedures and law applicable in arbitration. A single, neutral arbitrator will resolve Claims. The arbitrator will eitherbe a lawyer with at least ton years experience or a retired or former judge. The arbitration will be conducted under the applicable procedures and rules of the arbitration administrator that are in effect on the date the arbitration is filed unless those procedures and rules are inconsistent with this Arbitration Agreement, in which case this Agreement will prevail. These procedures and rules may limit the amount of discovery available to you or us. Thu arbitrator will apply applicable substantive law consistent with the FAA and applicable statutes of limitations, and will honor claims of privilege recognized at law. You may choose to have a hearing and be represented by counsel. The arbitrator will take reasonable steps to protect customer Account information and other confidential information, including the use of protective orders to prohibit disclosure outside the arbitration, it requested to do so by you or us. The arbitrator will have the power to award to a party any damages or other relief provided for under applicable law, and will not have the power to award relief to, against, or for the benefit of any person who is not a party to the proceeding. If the law authorizes such relief, the arbitrator may award punitive damages or attorney fees. The arbitrator will make any award inwriting but need notprovide a statement of reasons unless requested by a parry. Upon a request by you or us, the arbitrator will provide a brief statement of the reasons for the award. Costs. We will reimburse you for the initial arbitration filing fee paid by you up to the amount of $500 upon receipt of proof of payment. Additionally, if there is a hearing, we Page 3 of 6 CMA12762 will pay ahy fees of the arbitrator and arbitration administrator for the first two day of that hearing. The payment of any such hearing fees by us will be made directly to the arbitration administrator selected by you or us pursuant to this Arbitratio Agreement All otherfees will be allocated in keeping with the rules of the arbitration administrator and applicable law. However, we will advance or reimburse filing fees and other fees if the arbitration administrator or arbitrator determines there is good reason for requiring us to do so or you ask us and we determine there is good cause for doing so. Each party will bear the expense of the fees and costs of that party's attorneys, experts, witnesses, documents and other expenses, regardless of which party prevails, for arbitration and any appeal (as permitted below), except that the arbitrator shall apply any applicable law in determining whether a party should recover any or all fees and costs from another party. Enforcement finality, appeals. Failure or any delay in enforcing this Arbitration Agreement at anytime, orin connection with any particular Claims, will notconstitute a waiver of any rights to require arbitration at a latertime or in connection with any other Claims. Any decision rendered in such arbitration proceeding will be final and binding on the parties, unless a party appeals in writing to the arbitration organization within 30 days of issuance of the award. The appeal must request a new arbitration before a panel of three neutral arbitrators designated by the saute arbitration organization. The panel will reconsider all factual and legal issues anew, follow the same rules that apply to a proceeding using a single arbitrator, and make decisions based on the vote of the majority. Each party will bear their own fees, costs and expenses for any appeal, but a party may recover any or all tees, costs and expenses from another party, if the majority of the panel of arbitrators, applying applicable law, so determines. An award in arbitration will be enforceable as provided by tite FAA or other applicable law by any court having jurisdiction. Severability, survival. This Arbitration Agreement shall survive: (1) termination or changes in the Cardmember Agreement, the Account and the relationship between you and us concerning the Account, such as the issuing of a new account number or the transferring of the balance in thu Account to another account; (ii) the bankruptcy of any party or any similar proceeding initiated by you or on your buhalf; and (iii) payment of the debt in full by you or by a third party. If any portion of this Arbitration Agreement is deemed invalid or unenforceable, the remaining portions shall nevertheless remain in force. CHANGES TO THIS AGREEMENT We can change this agreement at any time, regardless of whether you have access to your account, by adding, deleting, or modifying any provision. Our right to add, delete, or modify provisions includes financial terms, such as the APRs and fees, and other terms such as the nature, extent, and enforcement of the rights and obligations you or we may have relating tothis agreement Modifications, additions, or deletions are called "Changes" or a "Change". We will notify you of any Change if required by applicable law. These Changes may be effective with notice only, at the time stated in our notice, in accordance with applicable law. Unless we state otherwise, any Change will apply to the unpaid balances on your account and to new transactions. The notice will describe any rights you may have with respect to any Change, and the consequences if you do or do not exercise those rights. For example, the notice may state that you may notify us in writing by a specified date if you do not want to accept certain Changes we are making. It you notify us in writing that you do not accept the Changes; your account may be closed (if it is not already closed) and you will be obligated to pay your outstanding balance under the applicable terms of the agreement. If you do not notify us in writing bythe date stated in the notice, orif you notify us but then use your account after the date stated in the notice, you will be deemed to accept all Changes in the notice and to accept and confirm all terms of your agreement and all Changes in prior notices we have sent you regardless of whether you have access to your account. CREDIT INFORMATION We may periodically review your credit history by obtaining information from credit bureaus and others. We may report information about you and your account to credit bureaus, including your failure to pay us on time. If you request additional cards on 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 oil your billing statement. Please include your name, address, account number, telephonu number and a brief description of the problem. It 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 withyou after our investigation, we will tell you in writing or by telephone. We will also notify the credit bureau that you dispute the information unless you let us know that you no longer dispute the information. NOTICES/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, cellular or business telephone number or email address (if ydu elect to receive billing statements or other notices online), you must notify us immediately in writing at the address shown on your billing statement. We may, at out option, accept mailing address corrections from the United States Postal Service. We may contact you about your account, including for customer service or collection, at any address or telephone number as well as any cellular telephone number you provide us. s TELEPHONE MONITORING AND RECORDING Y We, and if applicable, out agents, may listen to and record yourtelephone calls with n us. You agree that we, and if applicable, our agents, may do so, whether you or we n initiate the telephone call. d INFORMATION SHARING You authorize us to share certain information about you and your accuuntwithin our family of companies, and with others outside our family of companies including any company or organization whose name or mark may appear on the cards, as permitted by law. Our Privacy Policy, which is provided to you when you first receive an agreemantand atloastonce each calendar yea r thereafter, describes ourinformation sharing practices and the choices you have and directions you may give us about our sharing of information about you and your account with companies or organizations within and outside of our family of companies. ILLINOIS CARDMEMBERS Illinois law provides that we may not share information about you With companies or other organizations outside of our family of companies unless you authorize the disclosure or unless the disclosure falls under another exception in the law (such as sharing information to process your transactions Orin response to a subpoena). You hereby agree that, if you choose not to exercise the applicable opt outdescribed in our Privacy Policy, you will be deemed to have authorized us. to share personal information we have about you (including information related to any of the products or services you may have with any of our companies) with companies or other organizations outside of our family of companies. ENFORCING THIS AGREEMENT We can delay enforcing ornot enforce any of our rights under this ogroementwithout 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. 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 will be entitled to any of our rights that we assign to that person. 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, WILLAPPLY NO MATTER WHERE YOU LIVE OR USE THEACCDUNT. 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. YOUR BILLING RIGHTS Keep This Notice For Future Use This notice contains important information aboutyourrights 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 Cardmomber Service address shown on your billing statement 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. • Describn 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. If you have authorized us to pay your credit card bill automatically from your savings or checki-)g 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 Responsibilities 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 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 continua to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit line. 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 ;hat 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 1D days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question aboutyour bill. And, we rnusttell you the name of anyone we reported you to. We musttell anyone we report you to thatthe matter has been settled between us when it finally is. _ If we don't inflow these rules, we can't collect the first S50.00 of the questioned amount, even-if your bill was correct. Special Rules for Credit Card Purchases Page 4 of 6 CMA12762 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. This right does not apply to check transactions. There are two limitations an this right: (a) You must have made the purchase in your home state or, if notwithin your home state, within 100 miles of your current mailing addfess; and (b) The purchase price must have been more than 850.00. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. Copyright 02007 JPMorgen Chase & Co. All rights reserved Page 5 of 6 CMA12762 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating to unsworn falsifications to authorities, that he is Ruben A Alcaraz Assistant Treasurer (Title) plaintiff herein, that maintains t. by plaintiff and he is duly author the foregoing Complaint in Civ information and belief. (Name) of Chase Bankcard Services Inc. , a subsidiary of the (Company ie records for and services the credit cards accounts o ned •ized to make this Verification, and that the facts set forth in 1 Action are true and correct to the best of his knowledge, I (Signature) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOIICItOr ~~~plr Ot t IrtH~rr~~~~ QF~iCE ~ ~ '~E S~ERIFE ~i.i~ . - '~r T} _ 'Y ,~i~ ,,;, ,~,_ Jug ~ PI~t. 3••3,3 r, 7t ~''e Chase Bank USA, N.A. vs. George Stojkovich Case Number 2010-4209 SHERIFF'S RETURN OF SERVICE 07/22/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 22, 2010 at 1400 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: George Stojkovich. After several attempts the Complaint and Notice has expired. SHERIFF COST: $64.00 SO ANSWERS, -"'"-` July 22, 2010 RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft. Inc. 1a FILED-OFFICE OF THE PROTHONOTARY 2010 NOV 23 AM 10: 32 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. GEORGE STOJKOVICH Defendant No. 10-4209 CIVIL TERM MOTION FOR ALTERNATE SERVICE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #08364520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No. 104209 CIVIL TERM VS. GEORGE STOJKOVICH Defendant PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendant, George Stojkovich, by certified U.S. Mail and Certificate of Mailing, addressed to 10 Cabin Lane, Shippensburg, Pa 17257, averring in support thereof the following: 1. On or about June 23, 2010, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $21081.82. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 3. Upon receipt of the Sheriffs return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #08364520 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 10 Cabin Lane, Shippensburg, Pa 17257, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was able to confirm a current address for Defendant of 10 Cabin Lane, Shippensburg, Pa 17257. A true and correct copy of the search results is attached hereto, marked as Exhibit "3", and made a part hereof. 6. Plaintiff searched the Cumberland County Tax Assessment website which confirmed the Defendant as being the registered owner of 10 Cabin Lane, Shippensburg, PA 17257. A true and correct copy of the search results is attached hereto, marked as Exhibit "4", and made a part hereof. 7. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the Accurint Total Research System to confirm the physical address of the Defendant. 8. Pursuant to Plaintiff's request for information, Accurint Total Research System could not confirm Defendant's physical address of 10 Cabin Lane, Shippensburg, PA 17257. 9. No judge has previously ruled upon any other issue in this matter or any other related matter in Cumberland County. 10. Because the Defendant in the above matter is represented pro-se, concurrence cannot be obtained. WWR #08364520 11. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (10 Cabin Lane, Shippensburg, Pa 17257) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. (n/? / William T. Molczan, Esquire U PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #08364520 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the ` day of Lisa m d , 2010, by first class, U.S. Mail, postage-prepaid, addressed as follows: George Stojkovich 10 Cabin Lane Shippensburg, Pa 17257 Attorney for Plaintiff WWR #08364520 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard Al Stewart Solicitor ?QStntr pfa+rrlT'rs OFFIGS OF TKE SW RIFF Chase Bank USA, N.A. Case Number vs. George Stojkovich 2010-4209 SHERIFF'S RETURN OF SERVICE 07/22/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that on July 22, 2010 at 1400 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: George Stojkovich. After several attempts the Complaint and Notice has expired. SHERIFF COST: $64.00 SO ANSWERS, July 22, 2010 RONW R ANDERSON, SHERIFF tXHIBIi {c; Gou i'Suile Sher9. Te[eoso!_ Inc. Postmaster S111PPENSBURG, PA 17257 Date: Alleusi 9. 'tilt) R[ QtJ[is'r FOIL CI-IANG1: 01' ADDRESS OR BOXIIOL,DI:R INFORMATION NEEDED FOR SI:RVI(T OF I .FGA 'SS Please furnish the new address or the name and street address (if a buNholdcr) for the following: Name: G13ORGL-' S"rO.IKOVICI-I 10 CABIN LN Address: SI-IIPPENSBIJRG, PA 17257 Note: Only one request may be made her completed form. The name and last known address are required for change of address information. The name, if known, and Post Office box address are required for boxholder information. Tile iollowin inl'onnilliun is provided in accordance with 39 CTR 265.6(d)(5)(ii). I-here is no fee for pro\ i,Gn!_ boxhokler or chilm-'e (1l' addr.Ss information. I C :urtcit,. of rcquc>a r (c procrs s !'vcr. at1L)rnr?', p8rlV represewinit self): ATTC;UNE t); 111 l lill!oil :hal`tillipU\V;:ri nie to ?t:r 1'e f`rU:`Ctiti (1'ihl :'ellitlfell \\'hell re'i(itl'S•_e!' is an i11101'T1L') 1Y11'1y i1cling nrO S! .. eN::ept a Corr)o"Itioll actlllg pro NU Ii1tIst -iie SIanile) il.(SItC'I; S"rOIKOVI(71l. C'1IASI: BANK IIS;\. N...%,. EXHIBIT h.: n !nlcs of all known pl!t-ties to the litigation: I. !'he c,)or! in which the case has been or ;vill be heard: 13IMHIONOTARY f't!M131 ItI.AND C >. 'I-h_ docket or other identify iog number is or h must be filled -out): F _ :I. ;Mcktrt or other idenoifling number: '110-4209 CIVIL TIJZh4 h. Docket or other identifying number has not been issued 6. 1-!1c capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER ThIAN THE SERVICE OR LEGAL PROCESS IN CONNECTION WITH ACTUAL 0[2 PROSPECrIVE LITIGATION COULD RESULT IN CREMIN >.L PE.NA L I•IF,S INCLUliINC A IriiNE OF UP-1'O 510,000 OR fill PAISONMEN 1 Oil- NOT MORE THAN s t'E.llti, OR t;U'l it t 1 :'rl.f: i% U.S.C. SECTION 1001). I certifv thin the above nformation is lnie and that fhc address information is needed and will be used su!cl\ !ui non ice uf'lc ;d p,uccs, in u ).jL. io!1 with ac 1r ;r pc ire litigation. Sil?alurc ?? WI:I.'I-MAN_ WFIN!IFRG K RIi1S CO.. i-P.A. 'Killi;ut) 1 .:\4olcian. i'sr)uirt:. PA lDll 17:117 136 Seventh Avcnuc. 1400 Kopl)crs BUildin Pillsburgh. PA 15219 J Printed. Name ri W\•1R [:if-,- No. S36-lilt) r:scr- SP Ira FU!t POST OITIC liUsi O(?L'i Nu chat; e u! odc!;ess or.l r on lilt: Moved, left no forword:mz address: - _ ' No >.ttch address: A - I N11-W ADIA IL SS OR BOXI IO::DEWS NAMI POS rMA1ZK `' _..... ,% AN 1) STREET ADi)RESS /` 1 } ?ree People Search I WhitePages NhitePages )r search: Last name only _ Metro area Page 1 of sy answering this simple yes or no question, you can help improve search results for you and everyone that uses rhitepages.com. s this the person you were looking for? George P Stojkovich Jr Is this you? Edit 0 Cabin Ln ;hippensburg, PA 17257-9628 age: 45-49 j E iousehold: Cindy A Cramer, Ruth Stojkovich, Ashley B Stojkovich, :now me? Ask me to update my listing. ame popularity and name meaning for first name George and last name Stoikovich. tt--//tiananaT uihitar?aaPC rnm/tiir/17')57/cYnikrn?irh/aPnraP i i ii ni11ni i FaxDB Result Details Page I of detailed Results for Parcel 39-14-0165-029B in the 2004 Tax Assessment Database DistrictNo 39 Parcel ID 39-14-0165-029B MapSuffix HouseNo 10 Direction Street CABIN LANE Ownerl STOJKOVICH, GEORGE P JR C/O PropType R PropDesc LivArea 1680 CurLandVal 31580 CurImpVal 94660 Cu rTotVa 1 126240 CurPrefVal Acreage 1.86 C1GrnStat TaxEx 1 SaleAmt 1 SaleMo 12 SaleDa 19 SaleCe 20 SaleYr 05 DeedBkPage 00272-01929 YearBlt 1988 HF File Date 11/03/2004 HF Approval_Status A EX IV ttn•//tA'vdh rrna nPt/di-tailc acn?id='19_14-n1 Fi5-(179R.eirlhcPlPrt=1 1 1 /1 n/,)nI i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. NO. 10-4209 CIVIL TERM Plaintiff vs. GEORGE STOJKOVICH Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendant as being 10 Cabin Lane, Shippensburg, Pa 17257. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff conducted an online what pages search that confirmed the Defendant's address to be 10 Cabin Lane, Shippensburg, PA 17257. A true and correct copy is attached hereto and marked as Exhibit "3." C. Plaintiff requested current address information from the Accurint Total Research System, which request for information could not confirmed the current address for Defendant as being 10 Cabin Lane, Shippensburg, PA 17257. WWR #08364520 d. Plaintiff searched the Cumberland County Tax Assessment website which confirmed the Defendant as being the registered owner of 10 Cabin Lane, Shippensburg, PA 17257. Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, George Stojkovich, is 10 Cabin Lane, Shippensburg, Pa 17257. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan, Esquire U PA I.D. #47437 ?? WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this 15? day of November, 10 Notary COMMONI,NEAL TH OF PENNSYLVANIA Notarial Seal Sheila G. Bevan, Notary Public Ross 1'wp., Aileyheny County i I My Commission E5pires Nov. 15, 2010 w_ fv,.m,giber. Fennsvlvanla Association of Not&-[ WWR #08364520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No. 10-4209 CIVIL TERM VS. GEORGE STOJKOVICH ORDER OF COURT AND NOW, to-wit, this day of G? 201Q, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, George Stojkovich, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 10 Cabin Lane, Shippensburg, Pa 17257 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: DISTRIBUTION: 'ej William T Molczan 436 Seventh Avenue Koppers Building Suite 1400 Pittsburgh, PA 15219 Cop; ,,s m:, l W 1 l Aar 11 b C") c rr1w 0 ? rn- zo -c `om :0 CAI ? C7 =-n n G q M George Stojkovich - C T> < 10 Cabin Lane Shippensburg, PA 17257 WWR #08364520 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A Plaintiff vs. GEORGE STOJKOVICH Defendant(s) Civil Action No. 10-4209 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. o r rn ?;. a m :C3 ' _. _ C 7 o, 7, C :)-n a M -< o WELTMAN, WEINBERG & REIS CO., L.P.A. By. Benjam' ler, Esquire PA ID 9 WELT , WEINBERG & REIS CO., L.P.A. 1400 Koppers Buidling 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #8364520 ?p cs ?P?y? Uc?go$3 ?q3 ?,? X53 FILED-OF rlt F THIE PPOTHONOTAF0 2011 FEB 24 PM 1: 69 CUMBERLAND ANI?A TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. GEORGE STOJKOVICH Defendant No. 10-4209 CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#083654520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff No. 10-4209 CIVIL TERM vs. GEORGE STOJKOVICH Defendant AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared William T Molczan, Esquire, who, being duly sworn according to law, deposes and says that on January 28, 2011, he did cause to be sent to Defendant, George Stojkovich, Plaintiff's Complaint by Certificate of Mailing Postal Form 3817 and on January 28, 2011, he did cause to be sent to Defendant, George Stojkovich, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at his last known address of 10 Cabin Lane, Shippensburg, PA 17257. True and correct copy of Plaintiff's Certificate of Mailing PS Form 3817 is attached hereto, marked as Exhibit 1" and made a part hereof. Furthermore, true and correct copy of Plaintiff's Receipt for Certified Mail is attached hereto, marked as Exhibit "2" and made a part hereof. As the Order of Court states, service is deemed to be perfected as of January 28, 2011, the date of mailing. WELTMAN, WEINBERG & REIS CO., L.P.A. By: !??.; William T. Motczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#083654520 Sworn to and subscr d before rae this day of 2011. ARY PUBLIC T lSwl _ Notxrlal Seal Sheila G. ftvan, Notary Public Ross Twp., Allegheny County M., r?mmlacden mires Nov. 15, 2( Marlin AOST/? L SERVICE aenled b USPS® for mailing TtJs CerllUede of MaUlnp ptorddu avldatru Urat moo hae besn pre This forth may be used for domestic and InlamaUanal maU. From: Weltman W 1400 KO rs Bid • 436 7th Ave. . s urn . PA 15219 To,. i S ll" Postal CERTIFIED M AIL, REC EIPT Ir (Domestic Mail Only: No Insurance C overage Provided) M • -13 C) AL r? u' Postage $ Certified Fee O r. Postmark C3 Return Receipt Fee Here O (Endorsement Required) O Restricted Delivery Fee C3 (Endorsement Required) CO Total Postage & Fees r-q O Sent To /?• - \ ('? ? -•°1.1.1.11 .L.eIJ Y.)...?r!-- ------.-•-•.-----.-• C3 Street, A 0.; or PD Box No. ' ---------------- - Cily Sate, Z%P+ 17V erse foi Instructions R PS Form :3300. August 20C;& ev See PS Form 3817, April 2007 PS1J 7530-02-000-9065 CHASE BANK USA, N.A. Plaintiff vs. GEORGE STOJKOVICH TO THE PROTHONTARY: s IN THE COURT OF COMMON PLEAS--".- CUMBERLAND COUNTY, PENNSYLVANIA''' w` CIVIL DIVISION r,a 1 ? :f 21 a r, 3a Civil Action No. 10-4209 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant GEORGE STOJKOVICH above named, in the default of an Answer, in the amount of $22348.69 computed as follows: Amount claimed in Complaint $21081.82 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $21081.82 from June 04, 2010 to March 10, 2011 @ the interest rate of 6.000% per annum $966.87 Attorney's fees $300.00 TOTAL $22348.69 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. 08364520 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgr And that the last known address of the D f GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG, PA 17257 mbrodt,4 Pit SJS 15219 nt is IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff Case No. 10-4209 CIVIL TERM vs. GEORGE STOJKOVICH Defendant IMPORTANT NOTICE TO: GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG, PA 17257 Date of 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: 4 -====== - ----- Matthew Urban P.A.I. D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 8364520 J PIT 134S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 10-4209 CIVIL TERM GEORGE STOJKOVICH NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant , GEORGE STOJKOVICH is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG, PA 17257 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. tequest for Military Status Department of Defense Manpower Data Center Page 1 of Mar-14-2011 07:06:30 Military Status Report Pursuant to the Service Members Civil Relief Act NEW Last Name iFirst/Middlel Begin Date Active Duty Status Active Duty End Date Service A venev STOJKOVICH GEORGE (Based on the information you have furnished, the DMDC does not possess any information indicatinp- the individual status. Jpon searching the information data banks of the Department of Defense Manpower Data Center, based on the nformation that you provided, the above is the current status of the individual as to all branches of the Uniformed )ervices (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Aa, ,a- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 Che 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. Che DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as upended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds >f thousands of "does not possess any information indicating that the individual is currently on active duty" responses, ind has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or epresentative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the >CRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's >ervice via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the Jerson is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may )e invoked against you. See 50 USC App. §521(c). f 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. Chis response reflects active duty status including date the individual was last on active duty, if it was within the )receding 367 days. For historical information, please contact the Service SCRA points-of-contact. (lore information on "Active Duty Status" kctive duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more han 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 § i02(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All kctive Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they ;upport. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Jniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the ittps://www.dmdc.osd.mil/appj/scra/popreport.do 3/14/201 Zequest for Military Status Page 2 of Jational Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 :onsecutive days. overage Under the SCRA is Broader in Some Cases overage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes >f the SCRA who would not be reported as on Active Duty under this certificate. dany 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 lave not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend o persons who have received orders to report for active duty or to be inducted, but who have not actually begun active luty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protection >f SCRA extend beyond the last dates of active duty. Fhose who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to iervice members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous lame or SSN will cause an erroneous certificate to be provided. Zeport ID:E49ALONIAB ittps://www.dmdc.osd.mil/appj/scra/popreport.do 31141201 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 10-4209 CIVIL TERM GEORGE STOJKOVICH NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following order of Judgment was entered against you on rl jaj?( h of l (xx) Assumpsit Judgment in the amount of $22348.69 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( } If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of { ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: GEORGE STOJKOVICH 10 CABIN LN SHIPPENSBURG, PA 17257 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955