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Home My WebLink About11-1040.r e1LED-OFFICE OF THE PROTHIONO TRY 2311 JAN 31 AM 11:17 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. ELIZABETH DERENZO Defendant ?j 11 No : I- 0/6 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08804080 C J Pit SJS film ?Vkm lgyoH ??: LIS& 5-/-71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No ELIZABETH DERENZO Defendant COMPLAINT AND 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 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 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 COMPLAINT 1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at 200 WHITE CLAY CENTER DR, NEWARK, DE 19711. 2. Defendant is an adult individual(s) residing at the address listed below: ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 5184450030186237. 4. Defendant made use of said credit card and has currently a balance due of $5002.09. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default by having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the 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 Plain-?iff. WHEREFORE, Plaintiff prays for judgment against Defendant, ELIZABETH DERENZO individually, in the amount of $5002.09 with continuing interest thereon at the statutory rate of 6% per annum from November 26, 2010, plus attorneys' fees of $300.00 and costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. 436 Seve Pittsbur Fax (4WWR#:8 r mnrocit, 42524 (412) Y10 Avenue, Suite 1400 PA 15219 955 38-71.30 0 THIS IS AN ATTEMPT TO COLLECT A SHALL BE USED FOR THAT PURPOSE. AND ANY INFORMATION OBTAINED Payment Due Date New Balance Past Due Amount Minimum Payment I 09/05/10 55.902.09 S519.00 $732.00 Account number: 5184 4500 3018 6237 Make your check payable to: Chase Card Services. Please write amount enclosed. New address or e-mail? Print on back. 51844500301862370007320000500209000000000000005 -2315 BEX 2 22010 J ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE PA 17013-8527 I,.,III,,,Ill,,,,, rll„II,I,J,J,L,JJL,,Lr rll,,,ll rl„II I,,,III, I„I„i, I, r lr, 1 1„, I,I„„Il r l,l,r, 1 1„I,I,,, 11, r ll„I CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 1:S0001.0281: 40800 30 186 2 3 7611• slate- ® Manage your account online: Additional contact inormation fiem CHASED www.chase-mm/cmdikards conveniently located on reverse side ACCOUNT SUMMARY Account Number: 5184 4500 3018 6237 Previous Balance S4,838.20 Fees Charged +S39.00 Interest Charged +$124.89 New Balance $5,002.09 Opening/Closing Date 07/09/10 - 08/08/10 Total Credit Line S6,000 Available Credit 5997 Cash Access Line $6,000 Available for Cash SO PAYMENT INFORMATION New Balance 55,002.09 Payment Due Date 09/05110 Minimum Payment Due S732.00 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 29.99%. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will lake 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 29 years $17,125 payment $213 3 years $7,680 (Savings=59,445) If you would like information about credit counseling services, rail 1-866-797-2885. You haven't made the required payments and your credit card account is 90 days past due. As a result, your credit bureau may be updated with a negative rating. Please send your payment immediately or call us at 1-800-955-8030 (collect 1-302-594-8200) today. This account is closed and not available for new transactions. If there is a balance please continue to make payments by the due date ACCOUNT ACTIVITY Dale of Transaction Merchant Name or Transaction Description S Amount FEES CHARGED 08/n5 I FEE 39.00 TOTAL LEES FOR THIS PERIOD 53900 INrrERW CHARGED 08IG8 PURCHASE iNTEkcS f CHARGE 1 14 08108 CASH ADVANCE INTEREST CHARGE 1 41 C8108 BALANCE TRANSFER INTEREST CHARGE 122.34 TOTAL INTEREST FOR THIS PERIOD S124.89 2010:Totals Yeer4ta-Dab Total fees charged in 2010 578.00 Total interest charged in 2010 S241.82 Year-to-dale totals reflect all charges minus any refunds applied to your account on or after January 31. 2010. 8804080 This Statement is a Facsimile - Not an original 0000001 FIS33333 D 13 000 N Z 08 10,08;08 Page 1 of2 06598 MAMA 12315 220'0000130001231501 x EXHIBIT Address Change Request Please provide information below only if the address information on front is incorrect. Street Address: _ __________________ City State: Home Phone. Zip - Work Phone: __- ___ ____ E-mail Address: _____________________________ To service and manage any of your account(s), we. our representatives. JPMorgan Chase representatives, and/or affiliates, may contact you at any telephone number you provide to us. Please refer to your Cardmember Agreement for additional details about the use of your personal information L and/or visit our website shown below to provide us with additional contact information. 8804080 To contact us regarding your account: By Telephone: 7 2 ® In U.S. 1-800-945.2000 V"y ?IV`i Espanol 1-888-946-3308 TDD 1$170-955-8060 Send Inquiries to: Mail Payments to: Visit Our WobsHe: Pay by phonel-800.436-7958 P.O. t30x 15298 P.O. Box 15153 wsvw chase com/cr di r s Outside U.S. call collect Wilmington, DE 19850-5298 Wilmington, DE 19886-5153 l 1-302-594-8200 Inlermellen Ako61 Your A oul Cleddin8 at Prymelb: Ycu may :eke payments by any It The options listed below. The amount al your payment ahaid Nat West your minimum payment due. payable in U S. dollars old drawn a payable throcgh a U.S. filial Pane an or me US. branch of a Iemugn flnandal Irma:nlm. YOU may .make Payments by regular U.S. mail. Send your payment to the Payments adores& shown an Ilia statement. Yar payments by mail most comply w m the instructions on this samwiL Do Pal send .ash. Write your Account number an yar check nr mmeY Order Pavntemt must he acmmparMrt M the Payment anpon 1n the owilape provide l wan Our address Wside Reagan am envelope window; Ilea envelope Canmt contain mere than One paylneni or Coulon; and there can be he staples. paper c fps, tape or conespoldence mclacN with your payment In your Payment is in a=dance wan 00, payment ustNCnOns and is made migiiwo to is un ally day by 5:00 p.m, Ideal hme dal Payments address In ails stgdmenn, m.11 vedI Me payment to your Account a Of that day R Your payment Is In accordance ,ill our Payment insthietio s, but is made -Wk to Us alter 5.00 p.m. local time at ten Payments address On it's Sfrtnefi t, we will made! I to your Account as of me next ralem an day. YOU may malls payments electronically through Our webathe Shown, on fit& Settlement 11 we acme yugl completed Ieq Uesl on air weasae by 5 am. Eastern I lme, we will c ad I your Aii as at that day. If we receive your requal altar 5 p_m Fasten Time, WC wi'I credit Your oapsnt AS of the a= calendar day. If you epacity, a total, data '..n yaf mgLP.S wR WWII crdn yowl Pay'Irherd aS 01 that day fur all chin paymerls or [or sly Adymen: type Abeve for which you do Pat '01 OW our payment institutional chi IN of your payments may be deuyed for up to 5 days Almll IatermW an Reprted is CMdR IMIUM Wo try report infuriation aCOUI your Account to creaft bureaus. Late payments, missed payments or Cthx defaults on your Account may as reflected in your credit report It you think we have reported marmarte iM-C-atice it a c-eda bureau, you may Write to us gt he InabPries address shown an a113 stemor it. To Service led Mirage Any of Ya1rAgcm*s): We, our reCmmnWWS, JPMlxgan Chase Paromserativea, andla afilates, may caad yea at any telephone ^.umwr yoc p'orde to is. Plans refer ea your Cardmember Aphament far addi'ional details saol the use of YOUR personal Pitimphoram. WIS. Abdul 2l.dr k Chad Cosawr61ou: When you pay by deck. you auth rlee us ether it use Punce-tim from Wen cheek to mete a one-firs eemmno told 'ror.fer from your aocognt or m process Ms payment as a CneCk kanactipn. When we Use ulkinatim from Year CI*Ck to nfgle an eastruric fad transfer. Ions may be withdrawn from your account As span AS the arse clay we recewe vow payment, are You will Rol Receive your check back tram your financial irmilunion. Ca I the Gas-'.1 Service number on his s-akrsrd IT you nave questions about dectonic cheat cul!xtaw cr do sl want Yar payments cA." eledrem may. AU.'10en61 Payrouts: Any Payment Check et otlsr form If payment that you send us'cr less than If. fufi beiake due mat le ma'ked'paid In full" m Prams a RUI& mushon, or 'hat you olherense tsnder in fan satistacUcn of A disputed ahrual, must oe sent to card Services, P0, Box 15049, Wilmington, CE 19850-5049 . We reserve all at rights mga•ding these payments a g.. it its a te-mme, rare is he valid dispute or f any such coed is received at Any other address, we my apcgll to check as you WIII still awe Any himaIn" below). We may refuse to accept ally such paymert by rearlene A to you, not ashNg it a deslmying it, All other payments that you make should be sent 1o the regular Payment address shown On :his Material Maul Renewal Rages: If your Account Agreement has M annual membership fee anion s radar cna'ge to sax-nom or availaulrty at your acemunl. i- will be bided each year or in readily or quarely insta:nWft. This boor o' Charge are end wtU'l or nut you use your ACCanL aid Wu agree to hey then what b Did. The annual fee as charge are non-refundable enless you slily us dal you w sh a close your account main 30 days a one ailing eye,* (whkaevel is ass) still we P-it a the spemsel on which the annual In a charge is billed and at the same ame, you pay you outstanding balance in hall. If yek do this, far a charge b Tied more often than annually such as a monthy service charge, you wi8 not owe the big It km charge: huswver, prim billed Barges are flea-tedlundable All must be paid as part o:' paying your Ounrtanaing Telerate In fit 1. Your Claymont of me anneal tae a, charge does its anect our rights to dose your Account and to find your ni ed :o make nasxdors en yet IAmount It Your Account :s closed by yea or us, we will Conforms to impose it. llug fed A'hd'a Chatua Until YOU Pay yow Outstanding balance it) full aid laminate y'a'r Amount nl3llcnsl Calculation at 861819- Settled to Ynen61 Rate: in figure your her rthe inblrest charges for each hi INS cycle Whsn a daily pa-'OdiC o l apple,. M use the daily balance method (iiuluding CUrfeal tiasudlors). To l l your pwNdlc il'l,'25l charges nor cacti phling cycle when a monmly peracb mk(51 applies. ww Use the ave'a9e daily aalance method (emlua'.ng closed 11Alsxh011&l. Por an exparod or at Mrd- method. o' questions about a Particular inlsest cndrge, cakuletion on Your .sttement. pease all IS al :he toll free castomer sets. phone amber listed above. We calcu ate periodic mail charges. Long the 3PPIable pehodk rates shown ur ill S seedura l separately fa exit lealu,t balance Transfer chocks and Cash advance checks ('deck tralsedory ), purchases, balance trensters, cash advances, Nomatloral baleses or Overdraft advances). These =Ulaoom may combine different Caegones witr the same penkdk rates. Variable rates will vary with is mallet based a the Prime Realtar such index desLyicd in your Account Ageeel 1. There its himum interiorcharge o!5150(breach amountooscnbed in yml Aaourd Agreement) it any biill'q cycle in which YOU um arty periodic "honest Charges, and a transaction -as for said, :glance Ranter, an advance, Or check I-Kbw, ha the amoutlts stated in your Axuuat AgreamenL as d may be amended. There Is a lorelpn 1-cU ctbn fee 01 3% of the U.S. dh tar amount of any foreign transaction (or such amount desenced Pn your Acaunl Agreement). Now to Avoid Paying (merest an Purchases: We begin assessing periodic interest charges On a ta!sata0n, lee, or Interest charge item the ante Rig added to youraally .Arcs All your Account is paid in fun, as described in your Amount Agreement. Your due dale will be a minimum 0 21 days following Uw close of eaea Will Cycle. You can awed pCnpClc (merest charges On new ardlaees when they we arse effort to a statement AS awarded below, but this don flat apply 10 balance hansfers, cash advemaks a overdraft advances. If you raeehe a CU at Mom" statement that includes now purchall and make a payment[ that wa receive Oy the date and time the Minimum Payment is due for that statements As will not Charge periodic interest on any action at those now purchases Met we alioMe such payment to, se long as 1) your current statement also snows that we received pa-vii of the ar ntg balance far you previous month a statement by the age and fims us lAmmum payment was due OR 2) oat Ile ending balance la your Nevem; "mm's state, was of if You have a UPPase other flan a mlchM balm- old it bumna lards or a higher periodic interest rate, you may not be able to same perica m lnkrm# charges on new purchases d you do not pay Your balance in full each month, because we generally alloale payments hid a the IaWnce w,ah me rtgnem permute lntarest rate. Wkm To Oe 11 Yea Think Ym Rod A WSW 08 Yea Steted61 :.I y011 Ihatk there is an error on your sateisnl, wee to US on a separate sail at Customer Service, P 0. Box 15299 yAkmingtral DE 19850-529gr n your letter, gets us Yw following intonation: • Account "tareabon: Your came and Account amount. • Unllar amoum: I to dollar Amount pl me suspected coon. • Dew pfion of Problem: If you mink Persia an ens on your bill, deCnbe what you thal is wrong and why you belleve it is a mtslike, YOU most contact as w thin 60 days after the error appeared on year statement YOU must noun is Of airy potential e'mm In wr:bng. YOII may ref 1e, oar it you do we a'$ not required -0 inveSth" any potential OPOIS and Ya tray have 11 pay the amoum In quical a vil le we Nteatlgdk whether a not them has bete an error, tie f asomng a: a true: • We darted try to called the amoumh queerlo0, an pecrunyou as de inidm on Ilal anmenL • Tre charge In quest an may remain or your statement, and ws may conllnue to Charge you interest , on that amount. But. -:` we eaterne is that Yee made a mistake. You will not have I, pay de amount in question or any merest or cltw, lees (stated Ill Datapoint • While you do hat have to pay the amount In quewon, you are rnwside to too repaimer of your balance. • We an apply any unpaid amount agavhst your crepit limit Year R19M If You Are Olaoutie8ed tWth year Credit Card Purdrue It you are dissatisfied with the goods or seewcds the. you have purchased with your credit .,it. and ycu,aw teed in pond but, to correct the problem whh ire merchant, you may have the right no: to Pay the to thing arrant due on 7e purchase. To use this Ogrr, all It the folinviing mtu be true' 1. The purchase must have been trade in Year home state or within 100 miles of your cLrar,t mailing address, and :he Dumb- prim rust -ave been more OUR, S50. (NOM '. Naitter d these era Tw eswy B your evaliasa was based on an 3CwrtiSerlMt we marled to you , Or a we Over, mthe company flat solo you lire goods or survices.) 2. the must have usetl your credit and faith.purchase. Purchases mad. with cash abacus from an ATM or wait a chedl Ihg aGal year clead -d Account do not qualify. 3. you mus: nut yet have fully acid fer v tw purchase. If al 01 h'0 C"Oula above am ma and you are Still ntssaasted wwm No pu'cnase, Cut us in writing at Customer Serves. P.O. Box 15299 liRalph, DE 19850-52% While are Invesligak, rte saw riles appy to the 9sputed amount as dirceana above. After 'A IiRism Ou' iOWStigatme, we wA) Ill you our Cnasion. At me paint. e ,. thllk you owe an amount and you do not pay we may report you as deiluma 1. MA0192010 Statement Date' 07109/10 - 08!08!10 • Account Number: 5184 4500 3018 6237 Page 2 of 2 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 29.99%(v) S44.65 $1.14 S000 Cash Advances 29.99% (v) 555.26 $1.41 S0.00 Balance transfer 29.99% (v) S4,803.41 5122.34 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. 8804080 This Statement is a Facsimile - Not an original K 0000001 FI533338 D 13 000 N Z 08 10,0&08 Page 2 of 2 08598 MAMA 12315 2010000130001231502 VERIFICATION The undersigned is an Officer of Chase Bankcard Services, Inc., which is a subsidiary and agent of the Plaintiff that maintains the records and services the credit card accounts owned by the Plaintiff. The undersigned is authorized to make this verification for and on behalf of the Plaintiff and is familiar with Plaintiff's account in this matter. Based upon my review of the Plaintiff's books and records of Defendant's account(s), I have personal knowledge of the facts set forth in the attached pleading. Records such as these are kept in the regular course of the Plaintiff's business and it is the regular course of Plaintiff's business to maintain these records. These records and the entries thereon are made at or near the occurrence in question by, or from information transmitted by, a person with knowledge of the account. This verification is made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. (Signature) J 7{. WWR#8804080 Client Account #5184450030186237 Name ELIZABETH DERENZO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-0FFICF" THE ROTHONOT'l Is ?? Jody S Smith Chief Deputy C 11 FEB -9 AM g: D 1 Richard W Stewart Solicitor ' NNS`t'L.V4it1 Chase Bank USA, N.A. Case Number vs. 2011-1040 Elizabeth Derenzo SHERIFF'S RETURN OF SERVICE 02/01/2011 06:00 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that, on February 1, 2011 at 1800 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Elizabeth Derenzo, by making known unto Francis Derenzo, Father of defendant at 711 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. ROBE BI ER, DEPUTY SHERIFF COST: $33.40 February 03, 2011 SO ANSWERS, 22 RON R ANDERSON, SHERIFF • CHASE BANK USA, N.A. Plaintiff VS. ELIZABETH DERENZO TO THE PROTHONTARY: OF THE PROTHONOTARY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2011 MAR Zg pH 3:C5 CIVIL DIVISION CUMBERLAND COUNTY PENNSYLVANIA Civil Action No. 11-1040 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant ELIZABETH DERENZO above named, in the default of an Answer, in the amount of $5390.89 computed as follows: Amount claimed in Complaint $5002.09 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $5002.09 from November 26, 2010 to March 14, 2011 @ the interest rate of 6.000% per annum $88.80 Attorney's fees $300.00 TOTAL $5390.89 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. rmbrodt,42524 08804080 /C IJ Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh /)A 15219 And that the last known address of the Defendant is ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 K J7 Al --Tf 40 1<V# --25_71d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff Case No. 11-1040 CIVIL vs ELIZABETH DERENZO Defendant IMPORTANT NOTICE TO: ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 O'l. 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. t5y: 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 8804080 J PIT A4J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. ELIZABETH DERENZO Civil Action No. 11-1040 CIVIL 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 , ELIZABETH DERENZO 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: ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 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. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Pagel of 2 Mar-16-2011 07:10:39 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service S Agency DERENZO ELIZABETH 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). IA. 4bk? f ri Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.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. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the https://www.dmdc.osd.mil/appj/scra/popreport.do 3/16/2011 Request for Military Status Page 2 of 2 N tional 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:ERNEPI6J713 https://www.dmdc.osd.mil/appj/scra/popreport.do 3/16/2011 10 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. Civil Action No. 11-1040 CIVIL ELIZABETH DERENZO 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 31d _-Itl (xx) Assumpsit Judgment in the amount of $5390.89 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: PROTHONOTARY -( 8R BEPUT ELIZABETH DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955