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HomeMy WebLinkAbout11-6522FILED-OFFICE OF THE PROTHONOTARY 2011 AUG 19 AM 10. 06 CU PENNSYLVANIA TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No : VS. KEVIN BEIDEL CHRISTA BEIDEL COMPLAINT IN CIVIL ACTION Defendants 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 09229374 C A Pit SJS 5 ? q2. oo pd .1-,26 3 q3q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No KEVIN BEIDEL CHRISTA BEIDEL Defendants 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, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 2. Defendants are adult individual(s) residing at the address listed below: KEVIN BEIDEL 2 N HIGH ST NEWBURG, PA 17240 CHRISTA BEIDEL 730 BLOSERVILLE RD NEWVILLE, PA 17241 3. Defendants applied for and received a credit card bearing the account number XXXXXXXXXXXX5570 . 4. Defendants made use of said credit card and has a current balance due of $5824.44 , as of May 31, 2011 . 5. Defendants are in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 28.990% per annum on the unpaid balance from May 31, 2011 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendants will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 9. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendants , KEVIN BEIDEL AND CHRISTA BEIDEL JOINTLY AND SEVERALLY , in the amount of $5824.44 with interest at the rate of 28.990% per annum from May 31, 2011 plus attorneys' fees of $125.00 , and costs. James Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 e enth Avenue, Suite 1400 Pit b rgh, PA 15219 (41 ) 34-7955 F 2-338-7130 09 2 74 C A Pit SJS This law firm is a debt collector attesting to collect this debt for our client and any information obtained will be used for that purpose. New Balance Minimum Payment Due DISCOVER' $0.00 $1.1.00 Payment Due Date June 28, 2011 31 SDSN6AO1 0000319 KEVIN BEIDEL CHRISTA BEIDEL 730 SLOSERVILLE RD NEWVILLE PA 17241-9710 Account Number ending in 5570 Enter Amount Enclosed Below $ (1 7771 Go paperless and make your account information more secure with password- statements only you can access. Learn more at discovercoMpaperless. PO BOX 6103 IllrrnllrsrsnllnnrrllrIIIII CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Ir?ln?lun,ul?((n?nnl?I?nml?Ilnnrllrllnunllnin?V ???? Go to www.Diwav*r.com or print change in space above. 'j^` 000001966458630883219000000000000000116400 10 wmm? Opening Date: May 21, 2011 Closing Date: May 31, 2011 page 1 of 2 Discover More Card Account Summary Account number ending in 5570 Previous Balance $5,824.44 Payments And Credits 5,824.44 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged .00 + 0 New Balance ,- ?V0 _00 See Interest Charge Calculation section following transactions for delailed APR information Credit line $5,800.00 Credit Line Available $0.00 Cash Advance Creldit Line $2,900.00 Cash Advance Credit Line Available $0.00 %.U3noacR Dunes Anniversary Month January Opening Cashbock Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashbock bonus Balance $ 0.00 To learn more, 69 in arwwwMiscover com Payment Information New Balance $0.00 Minimum Payment Due $1 164.00 Payment Due Date June 28, 2011 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a fate fee of up to $35.00. Manage Your Account Online at www.Discover.com • Securely access statements and free online tools, pay bills online and track and view all transactions simply and easily • Make your money worth moresm -find easy ways to earn and redeem cash rewards • NEW! Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at www.Disc&mr.com 2. Coll 1-800DISCOVER (1-800.347-2683 Please have your Discovere card available- 3. Write to us at Discover PO Box 30943, Sale Lake City, UT 841 r10 (Not a payment address( For payments, please send to address an remittance or Discover, PO Box 6103, Card Stream, IL 60 1 97-6 1 03 For TDD (Telecommunications Device for the DeaQ assistance, please call 1-800.347-7449 Transactions Trans Past Date Data Paymenh and Credits May 31 May 31 INTERNAL CHARGE-OFF $ -5,824.44 Fees TOTAL FEES FOR THIS PERIOD $ 0.00 Interest Charged TOTAL WTEREST FOR THIS PERIOD $ 0.00 2011 Totals bear-to-Date 9229374 TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 175.00 645.88 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DMX,OVER DISCOVER - -? KEVIN BEIDEL M pegs to I DISCOVER Account number ending in 5570 page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Ming Period: 11 days TYPE OF BALANCE Purchases Cash Advuxes V = Variable Rate ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE RATE (APR) INTEREST RATE 28.99% $0 $0 28.99% s0 $0 Additional Important khormation See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account. Lost or stolen cards. Report immediately! Coll 1-800-347-2683. What To Do If You Think You Find A Mistake CM Your Statement If you think there is an error on your statement, write to us of: Discover, PO Box 30421, Salt Lake City, UT 84130.0421 In your letter, give us the following information: Account information: Your name and account number Dollar amount The dollar amount of the suspected error Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing. You may call us, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error. the Following are true: We cannon try to collect the amount in question, or report you as delinquent on that amount. The charge in qquestion may remain on your statement, and we may continuo to charge you interest on that amount But, if we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. • While you do not have to pay the amount in question, rare responsible for the remainder of your balance. • We can apply any unpaid amount against your credit limit. Your Rights if Ybu Are Dissatisfied With Your Credit Cord Purchases If you are dissatisfied with the goods or services that you have purchased with your 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 purchase. To use this right, all of the following must be true. 1 The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you , or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases mode with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You musk not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at: Discover, PO Box 30945, Salt Lake City, UT 84130-0945 While we investigate, the some rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Payments. Send o?lY your payment and the top on of this statement in the envelope provided. Do not send cash. By sending your checld as described above, you au prize us to use inFormation on your check to make an ekchonic fund trornfer bear your account d the financial institution indicated on your check or to process the payment as a check transaction. It pylnent is processed as an electronic fund tronsFer, the transfer will be For the amount of the check. When we use iniwmafion from your check to make an electronic fund hansfer. funds may be withdrawn from your account as soon as the same day we receive your payment, and you will r receive your check back from your financial institution. The precessing of dour payment may be delayed if you send cash, correspondence or other items with your payment, if you send the payment to any ether address or if you use an envelope other than the one provided. Payments received m proper Form at our processing Iacility by 5PM local time on any day will be credited to your Account as of that day. Payments received at our processing facility aka 5PM local time will be credited to your Account as of the next coy. If you have misplaced your en?{elope, send your payment to Discover, PO Box 6103 Carol Stream, 11 601 97-61 03. Please allow 710 days For delivery. f your payment ns returned unpaid, we reserve the rigfnt to resubmit it as an electronic debit. You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1-800 347-2683. You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. You will be asked to provide the first 5 digits of your accourd statement ZIP code. By entering those numbers as your electronic signature, you will be aareeing to this otil orizatnorh to allow us and your bank to deduct each payment you a rize from your bank account, and to mitiate debit or credit erdri?s to your bank account, as amicable, to correct an error in the processing of such payment. You must tell us the amount aF eacF Aymara or you can select an amount such as the Minimum Payment Due or the New Balance on each statement. You can cancel a ment, however we must receive notice at least three business days in advance of the scheduled payment. You may Uru by phone at 1-800.347-2683 or by mail at the address listed in the previous paragraph. If your poymerds vary to amount, we will tell you on each monthly statement when your payment} will be made and ow, much it will be. Your automatic payment amount may be less than indicated on the monthly s}atemerd based on credits or payments applied during the billing cycle. Credh R VNe may report information about your Account to credit bureaus. Late payments, missed payments, or other nUs on ur Account may be reflected in your credit report. We normally report the status and payment history of cn dit reporting agencies each month. IF you believe that our report is inaccurate or incomplete, please write us the following Address: Discover, PO Box 15316, Wilmington, DE 19850-5316. Please indicate your name, address, home telephone number and Account number Paying Interest 1nt¢ rest Chamjes are imposed on all transactions from the date the transaction is posted to your Account until the dab you pay y¢ur entire New Balance by making === ing credits. However, if you paid the New Balance on your previous br ring statement by the Payment Due statement, and you pay the New Balance by the Payment Due Date this statement, we will not imppoossee Interest Chh?arqes on new purchases, that is, purchases first appearing on this statement. 1 Ve call this the grace period. Otherwise, you will receive a billing statement next month that includes Interest Charges on those new purchases. There is no grace period on balance transfers or cash advances. How We Calculate Interest Charges Daly Balance Method (including current transactions): We Figure Interest Charges for each billing period: To do this: NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER We calculate your Interest Charges separately for each balance subject to different terms (For example, standard purchases, standard cash advances and each purchase, balance transfer and cash advance balance subject to promotioral'terms). We refer to these balances as transaction categories. re the "daily balance" for a«h transaction category. To get the "daily balance" via take the beginning • We' d lance (or each day add any new hansactinxu and fees and any Interest Charges accrued on the previous day s aily bakmge. We then subtract any credits and poymeMs and make other ad'ustmenh. In cakulahng Iha daily balance For the first day of the bipin? period, we consider the "previous day s ?ily bakmce" to have been your balance on the lost day of your previous oiling period. This gives us the daily balance for each transaction category- We figure the Interest Charges on your Accoud by multiplying the daily balance For each transaction coh gory by its daily periodic rate, for each day in the billing period. • The total Interest Charges for the billing period are the sum of the daily Interest Charges for each transaction category for each day during that billing period. When we calculate daily balances, we add a new transaction as of the Transaction Date shown on your billing statement, unless the transaction is posted to your Account after the close of the billing period in which it occurs, in which case the transaction will be 4dded to the dally balance as of the first day of the billing period in which it is posted to your Account. All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Fees which are to the applicable cash advance transoction category and Bo once Transfer Fees which am added to the applicable boa la a transfer transaction category. Far MD (Telecarrrmunications Device fw the Deaf) oss6koKe, please cap 1-800.347-7449. Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance purposes. The Discover'card is issued by Discover Bank, Member FDIC OITSK067 N 0 m z m D o_ 0 0 0 io N X N 9229374 QUeSt1OnS? Visit www.Discover.com or DISCOVER call 1-800-DISCOVER (1-800-347-2683). Paperless statements mean less clutter, more convenience Easily access up to 24 months of downloodoble, password protected statements. • See your statement as soon as it's available rather than wait for it to arrive in your mailbox. • Get helpful payment reminders through e-mail or text messages on your mobile phone. • Print a paper copy of your statement anytime. • Sign up today at Discovercom/paperless 02o1 O Disrnvr Bank, M-Aw FDIC PAPER.0310 ur 0 N Z m D o_ 0 rw'i to N X M 9229374 QueStiOnS? Visit www.D6cvvw.com or ?$C•?R call 1-800-DISCOVER (1-800-347-2683). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Natasha Szczygiel, Legal Placement Account Manager (Name) (Title) of DB Servicing Cotporation successor to DFS Services LLC servicing agent for Discover Bank, (Company) plaintiff herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. (r 4 WWR# 9229374 Kevin Beidel 6011002501525570 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson :,, € l . j r} ?_ - Sheriff ' s y Jod S Smith y c "` " r 'l 1 SE P 26 PAR 2' 2 Chief Deputy Richard W Stewart ;?.??W?1 C+???14 F i ( 3.J Solicitor s =G -H sF PF a ? r P E t yf?SYLV>r:?q?? Discover Bank Case Number vs. 2011-6522 Kevin Beidel (et al.) SHERIFF'S RETURN OF SERVICE 08/26/2011 06:04 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 26, 2011 at 1804 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Christa Beidel, by making known unto herself personally, at 730 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. A&ai? GSqAWWGUTSWI L, DEPUTY 09/22/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 22, 2011 at 1035 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kevin Beidel. After several attempts the Complaint and Notice has expired. SHERIFF COST: $96.00 September 22, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF Vic? GoioifgSWO. ShenfC Teleosnft_ ina:. F ?T?Inii l1?i'i IN THE COURT OF COMMON PLEAS CUMBERLAND C(.MNTY P tNS LV, tNl #,± . CIVIL DIVISION DSICOVER BANK Plaintiff vs. Civil Action No. 11-6522 CIVIL TERM KEVIN BEIDEL. CHRISTA BEIDEL Defendant PRAECIPE FOR DEFAULT JUDGMENT AS TO CHRISTA BEIDEL ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, as to Christa Bc?: l Only, above named, in the default of an Answer, in the amount of $6622.74 computed as follows: Amount claimed in Complaint $5824.44 Interest from May 31, 2011 to October 24, 2011 $80.62 at the interest rate of 28.99% per annum Attornev's fees $125.00 TOTAL; $6622.74 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. ?3 i. I on the dates indicated on the Notices. WEI.:TMAN, 'A/l-1NBERG & REIS CO., L.P.A. By: W;I!ia:r. i- Molczan. Lsquire PA I.D.#47437 Weltman, Weinb,-Tv, & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Aveii!ie Pittsburgh, PA (412) 434-7955 L/ WWR%,'G9229374 Plaintiff's address is: c/o Weltman, Weinuerg & Reis Co., L.P.A.,1400 Koppers Building, 436 ""' AvcOUe, Pittsburgh, PA And that the lase known address of the Defendant is: 730 Bloserville Road, Newviiic. PA 17241 C ldt9 2&73 ?-6?99z 15219 L Cpd IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTA BEIDEL KEVIN BEIDEL Defendant Case No. 11-6522 CIVIL TERM IMPORTANT NOTICE TO: CHRISTA BEIDEL 730 BLOSERVILLE RD NEVWILLE, PA 17241 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 JAYS 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 A7 ONCE, 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 FIRE A. LAWYER, 1 HIS OFFICE MAY BE ABLE 1"0 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 & RFIS CO,, L.P.A. By. _ 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 (412) 338-7130 9229374 'A PIT BS4 IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEVIN BEIDEI, CHRISTA BEIDEL Defendant Civil Action No. 11-6522 CIVIL TERM 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, Christa Beidel only, is not in the 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: Christa Beidel 730 Bloserville Road Newville, PA 17241 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. §4904 relating to unsworn falsification to authorities. Affiant Request for Military Status Page 1 of 2 Department of Defense Manpower Data Center Oct-27-2011 07:38:38 Military Status Report Pursuant to the Service Members Civil Relief Act '. Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Name Based on the information you have furnished, the DMDC does not possess BEIDEL CH:RISTA 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). 4A4 A?(), Miry M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 222209-'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 curren*.ly 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" URI, Izttr:/hv???v.dcfr,lsel nl:.mil/fag,' is 1'{;ri i>I htinl Ifyouhave 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 U'S- App. §52" 1 i,c). It-you obtain additional information about the person (c_g., an SSNI , irr,proved accuracy of DOB, a middle name), you can submit your request agz:in at this `Vlb sire und. 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 histori.,al information, please contact the Service SCRA points-of- contact. https://www. undo..usd.mil/,tpojlscra/popteport.dc 10/27/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) member's must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH 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 aEnended to extend the period of active duty, which would ex'Lend SCRA protections. Persons se-king 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 o1'SCRA extend heyond the last dates of active duty. Those who would rely on this certificate are urged to seek quuiified 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 game or SSN will cause an erroneous certificate to be provided. Report ID:NOE7HQG8BM https://www, mdo.osd.mihappj!scraipop.?port.do 10/27/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DSICOVER BANK Plaintiff vs. Civil Action No. 1 1-6522 CIVIL TERM KEVIN BEIDEL CHRISTA BEIDEL Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J dg ent was entered against you (xx) Assumpsit Judgment in the amount of $6622.74 plus costs. ( ) Trespass Judgment in the !mount 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 Prothonotai , By: _ PRO OTARY (OR DEPUTY) Christa Beidel 730 Bloserville Road Newville, PA 17241 Plaintiff's address is: c/o Wellman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Christa Beidel ???y??Yr of ?rrrubcr???? it P. 0 TN0!'01'AP ?i 2H I DEC 16 AM 10: 09 UPENNSYLVAN A I Case Number 2011-6522 SHERIFF'S RETURN OF SERVICE 12/14/2011 10:40 AM - Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st FCU at 1166 WALNUT BOTTOM ROAD, SOUTH MIDDLETON TWP, Carlisle, PA 17015, Cumberland County, by handing to MEG BEASTON-MEMBER SERVICE REP, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 15, 2011 to Christa Beidel at 730 Bloserville Road, Newville, PA 17241. SO ANSWERS, December 15, 2011 RON R ANDERSON, SHERIFF Ryan Burget eputy (0) CountySute Sheriff- Teleosoft . Inc- WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E Ehasz, Esquire Attorney forPlainift' OAN 20 AM 11: 43 I.D. No.86469 A 436 Seventh Avenue, Suite 1400 CUMBERLAND COUNTY Pittsburgh, PA 15219 PENNSYLVANIA Phone: 412.434.7955 Fax: 412.434.7959 File # 09229374 DISCOVER BANK VS. KEVIN BEIDEL CHRISTA BEIDEL CUMBERLAND County Court of Common Pleas NO. 11-6522 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT AS TO KEVIN BEIDEL ONLY TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter as to Kevin Beidel only. WELTMAN, WEINBERG & REIS CO., L.P.A. kL ?C By. Sarah E Ehasz, Esquire Attorney for Plaintiff Qw?.?r a 11.E Ste. d Q+?, Gk? 1?3oa33s? 10311798 _ Fi . l.r 1 Iic NONDTAR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION q) FM 1' 08 "r DtrrrLAND COUNTY DISCOVER BANK ra!iT#SYLVANIA Plaintiff vs. Civil Action No. 1 1-6522 CIVIL TERM KEVIN BEIDEL CHRISTA BEIDEL Defendant PRAECIPE FOR DEFAULT JUDGMENT AS TO KEVIN BEIDEL ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, KEVIN BEIDEL ONLY, above named, in the default of an Answer, in the amount of $7236.10 computed as follows: Amount claimed in Complaint $5824.44 Interest from May 31, 2011 to March 5, 2012 $1286.66 at the legal interest rate of 28.99% per annum Attorneys" Fees $125.00 TOTAL $7236.10 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: Matthew D Urban, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#09229374 Plaintiff's address is: -7a7 ??? c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219P And that the last known address of the Defendant is: 6 SIR WILLIAM DRIVE, NEWVILLE, PA 17241 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 11-6522 CIVIL TERM vs CHRISTA BEIDEL KEVIN BEIDEL Defendant IMPORTANT NOTICE TO: KEVIN BEIDEL 6 SIR WILLIAM DRIVE NEWVILLE, PA 17241 `` 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: 14--- 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 (412) 338-7130 9229374 A PIT AJ4 IN THE COMMON PLEAS COURT OF COMMON PLEAS ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs KEVIN BEIDEL CHRISTA BEIDEL Defendant Civil Action No. 11-6522 CIVIL TERM NON-MILITARY AFFIDAVIT AS TO KEVIN BEIDEL ONLY 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, KEVIN BEIDEL is not in the 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: KEVIN BEIDEL 6 SIR WILLIAM DR NEWVILLE, PA 17241 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. §4904 relating to unsworn falsification to authorities. Affiant Request for Military Status Department of Defense Manpower Data Center 4D Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Mar-07-2012 05:23:36 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency BEIDEL KEVIN 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). ANY, r?. ,G14-A?.- 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 "defense]ink.mil" URL http://www.defen:selink.mil/faci/yis/PC09SI.,DR.litini. 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 National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases https://www.dmdc.osd.mil/appj/scra/popreport.do 3/7/2012 Request for Military Status Page 2 of 2 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 al l 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: I GNA5 IEFKL https://www.dmdc.osd.mil/appj/scra/popreport.do 3/7/2012 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-6522 CIVIL TERM KEVIN BEIDEL CHRISTA BEIDEL Defendant NOTICE OF JUDGMENT OR ORDER AS TO KEVIN BEIDEL ONLY TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or judgment was entered against you on Ise I (xx) Assumpsit Judgment in the amount of $7236.10 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 2&OAO By: W? PROTHON Y (OR DEPUTY) KEVIN BEIDEL 6 SIR WILLIAM DRIVE NEWVILLE, PA 17241 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,nderson Smith Deputy ,hard W Stewart .) icitor Discover Bank vs. Christa Beidel P 2: 14 FEN S`j? p'rLtoAN'lA 11 SHERIFF'S RETURN OF SERVICE Case Number 2011-6522 12/14/2011 10:40 AM - Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commandec all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1 st FCU at 1166 WALNUT BOTTOM ROAD, SOUTH MIDDLETON TWP, Carlisle, PA 17015, Cumberland County, by handing to MEG BEASTON-MEMBER SERVICE REP, personally three true and attested copjes of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 15, 2011 to Christa Beidel at 730 Bloserville Road, Newville, PA 17241. 06/05/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.67 SO ANSWERS, June 05, 2012 RbNWY- R ANDERSON, SHERIFF Inc.