Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
11-7735
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. TODD A. BAUSERMAN, Defendant TO THE DEFENDANT: r- -ryK? ? •?r W CIVIL-LAW DOCKET NO.-113 S aV? ( y NOTICE TO DEFENDANT =-?s N c? o ?- ?-t YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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, 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. Pennsylvania Lawyer Referral Service Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800-692-7375 717-249-3166 717-238-6807 LAURIND J. VOELCKER, ESQUIRE Attorney for Plaintiff S a.M? igfl OD Pd C" iiaq ss($ Qy. Al IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. CIVIL-LAW TODD A. BAUSERMAN, DOCKET NO. Defendant COMPLAINT The Plaintiff, Remit Corporation, by and through its attorney Laurinda J. Voelcker, Esquire, hereby files this Complaint of which the following is a statement: 1. The Plaintiff, the Remit Corporation is a Pennsylvania Corporation doing business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania 17815. 2. The Defendant, Todd A. Bauserman, is an adult individual residing at 402 N. Earl Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Defendant obtained an Orchard MasterCard credit card on or about May 11, 2006, from Household Bank SB N.A., (hereinafter "original creditor"), Account number 5155 9300 0169 6699. 4. Remit Corporation purchased the account of Todd A. Bauserman from National American Credit Corporation. A copy of the Bill of Sale is attached hereto and labeled as Exhibit A. 5. National American Credit Corporation purchased the account of Todd A. Bauserman from HSBC Card Services, Inc.. A copy of the Bill of Sale is attached hereto and labeled as Exhibit B. 6. Household Bank SB N.A. was acquired by HSBC Finance Corporation, through a merger and acquisition. 7. Defendant used the extended credit leaving an unpaid balance at charge-off of $1,241.45. 8. Defendant defaulted on the payments due and the last activity on this account was on or about November 30, 2007. 9. No interest has been added to the account since it was charged-off. 10. To date the charge-off balance is $1,241.45. COUNTI BREACH OF EXPRESS CONTRACT 11. The above paragraphs are incorporated herein as though more fully set forth at length. 12. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his/her account. 13. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $1,241.45. 14. Defendant accepted the extension of credit and utilized the credit card without complaint, objection or dispute as to credit services provided, the prices charged for the same or the costs incurred. 15. Defendant is indebted to the Plaintiff in the amount of $1,241.45. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. 16. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), a copy of this writing is attached hereto, incorporated herein and referred to hereafter as Exhibit C. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $1,241.45 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 17. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 18. It is averred, in the alternative, in the paragraphs set forth above, if an express contract between original creditor and Defendant did not exist, that a contract implied by fact or implied by law exists. 19. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to him/her and that the original creditor expected to be paid for the Defendant's use of this credit. 20. Defendant used the credit card to purchase items, and/or transfer balances, and/or obtain cash advances and he/she received the same to his/her benefit. 21. The total reasonable value of the Defendant's use of the credit extended by original creditor is $1,241.45. 22. In breach of the implied contract, Defendant has failed and refused to pay the outstanding sum for the credit card use and the same is now due and owing. 23. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 24. By virtue of Plaintiff s purchase of this account and the assignment of all rights to the Plaintiff, Defendant is indebted to the Plaintiff in the amount of $1,241.45. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $1,241.45, together with interest, costs and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERIMUNJUST ENRICHMENT 25. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 26. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, cash advances, balance transfers, fees and interest. 27. The credit extended by original creditor benefited Defendant. 28. The Defendant will be unjustly enriched if he/she is allowed to retain the benefit resulting from his/her use of the credit card provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 29. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon his/her use of the credit card. 30. The reasonable value of the Defendant's use of the credit card including purchases, balances transfers, cash advances, fees and interest is $1,241.45. 31. By virtue of the Plaintiff's purchase of this account along with the assignment of all relevant rights thereto, Plaintiff, Remit Corporation is entitled to $1,241.45 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $1,241.45, together with interest, costs and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, Laurinda J. Vo cker Esquire Attorney for aintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 EXHIBIT A BILL OF SALE FOR VALUE RECEIVED, and pursuant to the terms and conditions of the purchase and sale agreement between National American Credit Corp. ("Seller") and Remit Corporation. ("Purchaser') (the "Agreement"), Seller does hereby sell, assign and convey to Purchaser, its successors and assigns, all right, title and interest of Seller in and to those certain accounts described below (the "Accounts"). This Bill of Sale is executed without recourse, warranty or representation of any kind, expressed or implied, including, without limitation, any warranty or representation as to the collectability of the Accounts, except as specifically provided in the Agreement. Product/State Purchased- PA HSBC Executed this l 6th day of November, 2009. SELLER By: Name: (V?are \o k,?,L_ Title: CEO EXHIBIT BILL O SAL FfStW CARD SERVICES 1111) I NC t 'Srfler"t. tier 4alue rec;eiled and pursuant to the ),ruts and ca nditions of the Receivables Purchase _ ' rcenknt ('•A, em nt") dated :August i. -1 re _MO hemeen Seller and National American Credit Corp.. t 1 ennsykania (wporation "Purchaser'., sloes hereby tick!, assign and convey to Purchaser, its wuccessur and assis;ns. 11 riht, title and interest of Seller in and to those certain purchased receivables listed on the Sale He Mated (K-tuber 19. 007 without recourse and without representation of. or warranty of, collectihility, or othervvice. except to the extent provided for within the Agreement. E`CECI'TED this b'h clay of November. 2mT I ISHC CARD S?t ES t tl ' Name:._....)Llarcelo Aita----- - EXHIBIT /3 SPECIAL RULES FOR CREW CARD PURCHASES 11 p? have a,?blem with the quality of property or services yo "MTn a credit card, and you have tried to good taRh tou correct the problem with the merchant, you may have the right not to rt?re a- the remainmg amount due on the property or se vices two hrmlahons on this right: (a) You rr1'r have made the purchase in your home state or ,t riot, within 100 miles of your current mailing address. (b1 The Purchase Price must have been more than $50_ These limitations do not apply if we own or operate the merchant, or it we mailed you the adverticsement for the property or services. HSBC Gard Services in. andlor HSBC Card Services (11}} Inc. provide P?ocessino sere Ces for HSBC Bank Nevada, N A. You may write to us at the address shown on our billing statement or HSBC Bank Nevada, N n.. 1 1 Town Center Drive. Las Vedas. Nevada 89144 Thomas M. Kimble HSBC Bank Nevada, N A February 1. 2006 Visa is a registered mark of Visa International and VIs tI S A IMntasternaterCard ic is a registered mark of MasterCard nai Incorporated. "-'?006 HSBC Bank Nevada, N A_ CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT AG2505 (OZ%i This document and accompanying Additional Dmcbsrne Statement make up your Cardmember Agreement and throughout this docxmient are referred to as Cardmember The Additional Disclosure Statement Ag contain ns ? r+mpt r % int. " ant Malian including your. Annual Percert amount of any fees, P " Rates P'A'R s! and nY tease take the time to famiiranzp vorrrrr ?,?,tt, your 4grprment and retain it for future reference. Thank you for betnq an HSBC Cardm m e ber We aPnrerrat? your bU5lneSS. TABLE OF CONTENTS Agreement to Terms and Definitions Us+nq Your Account t Your Credit t Payment t lnterest Rates and F rnance Charges 2 Account Fees 4 Foreign Transactions Account Renewal. Closure Anil Terminahnn 8 Credit Card Fraud R Personal lnformatjon i Add0ional Terms ,n!n R I nn 4atn s AUKILLMENT TAO TERMS AND DEFINITIONS oovam the ard"10"It a dfre Ot nt and any amendments (Ageentent) ?:?unt °yT and credit we have established for you (Your Account or are contr yoia"refer to all persons who applied for the us and our" fifer to FfSB Bank Utrough any other means. 1Ne,° i e:;.t arils Or o her Nevada. N.A 'Cart!" means any i t'?rrMOrk m access devices issued under thie Agreement. eans V ernationai MasterCard rxorated. Ctrsaover Fina ard International isa i !°i1-.' Cdri`. nervark as ancoPServices LLC or other governing ou 'I'd we are bound b this Agreement of ta''e rcv rccewa it or Zorn th6 date o hp iron, fitherst earlier transact ct the nchx,in j, rti.rhout limitation, the lacemenion, Awitial *ee or f'ertodiG Members Pp Fee on o Account. posting t. any may 'i' Se your Account before usit?g it if Without You ''Inc'h%if rile. or Periodic Membersh? F hout 1b46 to any Account when you call us within 90 days Of you?Ac nog date at the customer service number on the back of your card USING YOUR ACCOUNT Account Use Restrictions vnt: agree to use your Account only for personal. famlty househ old, ,x charitable purposes you agree not to use ur Account to make payments to us or to any of our affiliates. Yo 4cr:cunt on ly for vattd and latvhui your t:sPd tnr any other Purposes and that if your Account n;7y hr re(JUI ect to r bUrseUSand thepoNehvark far 311 use and 71r` -u,,tS wid eKnenses. esuRing Types of Account Transactions `%ot; can access your Account using your Card or by other means 1pOf0ved by us to make purchases or receive cash advances. ?%e -ray iirnit the dollar amount andror frequency of any type of !'Ar?ia'::i r_ ?l K'Ithptrt notice to you YOUR CREDIT Credit Limit tNf- 'x 0l advise, you of the total credit limit on your Account. All or a Pct"gun of Your total credit limit is available for cash advances. Jr C'-flat credit limd and cash advance limit m change nip ;,) t•me. We will notify you of any such changes thro h fyrom bill.nq Statement of by sendin?gq Yyou a separte notice If rio sepa at amsh ad l nce limit rs,ed on your billing statement, h"n of your s V'ur total rr-rilt limit - dit Ir Jed available for cash advances . 19r" not If) allow your unpaid balance (inc_luding Finance Charges and other charges) to exceed your total coedit limit We may not extend credit if you have exceeded your total credit limit or , ! I r ar Hunt requested would cause you to exceed your total as ;hat excesso amoun?mmed totalcredit available to pay `-esn,adt'ancr a^xrunt may not reflect your payments for up 10 If you have a credit card with a no preset snendfng limit fe.q MasterCard' WorldCard Disclosure Statement please sn? the Adrift oriel . Credit Authorizations Some transactions will require our prior authorization and you ma be asked by the merchant to provide identification. if any part of the authorization systems not working, we may not be able to authorize a transaction. ever, if you have suffiaent available credit, We will not be liable to you if any of these events happen. We may refuse to authorize any transactions at our sole discretion including. without limitation. it we fraudulentyor suspicious tsuch activity on authorization ? Account. may are result not responsible for refusal or failure to authorize any transaction or refusal by any merchant to accept or honor your Card. Promise to pay You promise to pay according to the terms of this Agreement for alt, (a) credit we extend on your Account; (bj Finance Charges, late charges, overtimrl charges and administrative charges (e.g. for research, returned checks, overdraft Protection, i< applicable. etc.) provided in this Agreement; and (c) collection costs and attorneys' fees to the extent permitted DY applicable taw. If your Account is a ?' int Account. each joint Accountholder is ointly and ind r ivid aually responsible for all amounts due undgear cee ingS or ag eement© hat d ay` affect eliabi6t l liable for you- If any joint Accountholder requests to not be p future transactions, , we may close your Account. If we do. You must continue to pay according to the terms of this Agreement, but you will not be able to make r, your Account e w charge3 on Payment Each statement you receive from will identity a Minimum Payment and Current Payment Dueus Afln/mum Payment The Minimum Payment is calculated as follows (?) If your New Balance is Min not more than $t S. your Minimum Payment is the New Balance (2) If your New Balance is more than $15 , your Minimum Payment is the greater of (a) 1% of the New Balance shown on your statement Pius the following any periodic Finance Charges ' any Mond* Maintenance Fee Finance Charge or an amount equal to 1'12 of the Annual Fee. if any additional amounts disclosed in the Adrftiirrnat Disckisore Stalk-menr, or (h1 31S Gurvenr Payment Due Tr,e (:rrr•en,. Payment D.te ,s the oreater of f t) your Mirnmtrm Pay-r, aril plus ary 3m+3 rR! oast ^ rs• f,r (21 the greater of tai , % of the New Balancp chnw•l on v-,;n eta?n -.,..e nfus the foltowrnq. any periodic Finance Charges any Monthly Maintenance Fee Finance Charr.p y an amount equal to 111, 2 of rile Atrnral Fee. i applk aMr. and any amount over your crWN km:t. nr (b) S15 plus any 3mount over your credit Ir tr Your Minimum Payment and Current Payment Due wd' be rounded up to the nearest dollar. unless do-Q sc: Will t'acrsQ t'ie resulting value to exceed the New Balance. Timing and Form of Payments You must pay at least the Current Payment Due in time to be credited to your Account by the Payment Due Date. and failure 00 do so constitutes a default of this Agreement. Instructions for making Payments are on your billing statement. For a Payment to be Credited to your Account as of a particular day, we must receive 1f payrnent by the date and time and in the manner specift in those instructions. N your Account is t, ou can avoid an additional overfimit fee by p ,,Ting at least the Current Pa ment Due uPon delivery your biffing statement. If y definqucn you can avoid an additional late feee you- by pint at past tChheer inimum Payment plus any past due amount yytthe aytnent Die Dale. however, if you cannot pay this amount. yot? crest pay at least the Minimum Payment by the Payment Due Date to avoid progressing to the next stage ct delinquency. You may pay note than the Current Payment Due and may pay the entire New Balance at any rmP. All Payments nest be in U.S. dollars. Fxcept for disputed Payments if you pay by mail the payment must be sent to the address f>c'j ied on your billing statement. it ypu pav by be negoifilible strument such as a money order or check. it 'mist that is fable to us and nest be drawn on a U S. financial institution. Any check, mone?'rIorder or other Itrstrtiirnptf landered as an ae:OOrd In stall . includes a condMon, or which statement to ft t~or that ?ee?eeFppvppe endorsement or any shall conoftoo ppaa ls?a?=of such instru nent undisputed debt (collsctlvr n of a must disputed be sent or the address for written ' a ' s Co^dloon shown ") on your sent to rconspi oh Your trifling >?tarrrent. You must note conspicuously on the tau, of ttW payment instrument that it is tendnrwd for this reserve the rOght to refuse to accept any that is u pec! to a Conditiori. If the comply rtt that t5 st>fe g and we PaYrrient does not comply with the as Process i, we will not be bound by the Condi 13y anus a cfteck for ppaayy?nienn on your Account, you us to k ttate an eNctronic funds transfer from your bank terms or tt?ier financial institution account according to the is means t convertpd to an electronic ttransactionh n and ooorcheck will be will not he retpr,e., to y i Ongmal checi, wdt be desMeyed Your checking or other financial inslitutfon account may be debited the same day we roceive your check It vnu do nnf want your checks to be converted to an nl?rtronrr filnt!s transfer, p ase calf cttsinm+ar servK.e at the D''+>r>P ntrmher on the back o` ynrtr card Application of Payments At our discretion, payments are generally applied to interest, t oweees+ and then principal balances. We apply your payments to APR balances before higher APR balant?s. The xt? ?i of payments is subject to change at any tim@ INTEREST RATES AND FINANCE CHARGES interest Rates The APRs on your Account are either a fixed or variable rate, Vanable rates are determined by addi a specified ! Suread"i to an Index (described below amount } The APR is divided ay 365 arid rounded to the next highest hundred thousandth o rcentage?'aint to determine your Deily Periodic Rate. The atit Per c: Rate is used to determine the amount of Pere."jr -nance Charge (see Finance Charges). Index For Varlable Rate Accounts Please see the Additional Disclosure Statement for the Irnrtn,r paragraph below that IS applicable to your Account. t' ti ?nShly n x For each bitlinj cycle, me Index is (Ietarmme in he month prior to he month in which the billing cycle ands. In that prior month, the highest domestic 'Prime Rate'published in the Money Rates table Index hasacthangedJ the new varableedra(the tes will take effect with tht? hillingg cycle that ends on or affPr the first riay of tare uv)nth following the fndex change. cQV gVN_t(j1Sm The Index for the current and each quarter is the highest da?nesffc 'Prime Rate nuhkshed in the Money Rates table of The Wait Streat -`+wma, on the first business day of the preceding calendar quarter. If the Index has chin the new variable rates will take et'. with the billing that begins in July or October foflowing the Index cnge, January. Atxit, 0' VN. LRde. Please see your Additional f5+rclosurc Statement. Air increase in the Index WIN increase your applicable Daily Periodic Rates which may increase the Finance Charge due on - any or Account. Each time any APR changes we will apply it trilri,id story APR batsncas, excluding any t5romotionat or rY R hal may aPPh'. Purchase APR or credit card purchases, the Spread (for variable rates), APR end Sp oncin A..ttr'innal fJrscfasure S atemenPeriodic Rate are disclosed it the Cash APR For cash advances the Spread (for vanable rates). AuR and Corresponding Daily Periodic Rate are disclosed in the Adddionai Disclosure Statemenl. Default APR If Your Account has a Default APR provision the Default APR and conditions that may cause a Default AOR io take effect as well as the Spread (for variable rates), APR and corresponding Daily Periodic Rate are disclosed in the Additional Disclosure Statement. Promotional or Introductory APR At our discretion, we may offer you a Promotional or Introductory APR for any type of transaction. The Promotional or Introductg APR. corresponding Daily Periodic Rate, period of time Tor which the Promotional or Introductory APR applies, and the be shortened are dsclosed which he o4 f" Certain l Period may Offers maY or may not be sutr?ect to Cash pfotloinal P Advance FFeeses ramotionel or Inttoduct APR offer will be subject to the terms of the offer and this Agreement. Finance Charges Finance Charges are the total of the greater of (a) Minimum Finance Charge or (b) Periodic Finance Charges and anS applicable (c) Cash Advance Fee Finance Charc?es dj Foreign Transaction Fee Finance Charge. (e) Credit Limi Increase Fee Finance Charges, (f) Monthly Maintenance Fee Finance Char es, (g) Overdraft Fee Finance Charges, and (h) any other Fnance Charge(s). Please see the Additional Disclosure Statement for applicability and amount of the following Finance Charges. (a) Minimum Finance Charge. A Finance Charge that is arse F? Callao of Penodc a less Fipe?ic Finance Charge rn any bi inG Hance Charge is payable. (b) PerfoaYc Finance Charges. Periodic Finance Charges are computed muffip ing ttx? Average D iy Balance for each ca of >rarrsacboru shown on the Dating state (e pcat" ea, balance translim. cash advances the Da Periodic Rate acrd then the by To result := of the toe ,g_ the number D, Balerim, take begins q talienoe for each the ca tegory y of tr i we ar>e each day add arty new hansect ions Y prevous 's periodic Finance 6harges, any assessed fees am chargesday abeginntng of a b aedrtsbut tl? the the ?gmrxng of pilot to be 0-7-1eed loo include the transaction amount d amount ays periodic Finance Charges for each day thetrtransection ing b&V was 17?jor eeactrans?n tegmo9rvof the curt" cyda t therceand a? the ftDiae?iwnber of 4 divide the bola! by Balance for ea ? rnsact on Category. This is the Aver Uai1v (t) Periodic Finance harries begin to ac+?ve or t e date o e bA?SaCt!Cn ant! r,,.,i n;_K, to accrue until payment in hull is creg1ed to there is a Grace Period on your, Account. However. -eam. if the New PeBabncp riod shown Credit card That Paid In full by the payment Due Dale rd tftat stmt is Periodic Finance Ct+arges will not be anpnsed on now creo:t Card Purchases, provided the New b" cycle is pad in full by the P in ? ? curren for t billing cycle. If however, the New =its not by the 9 ayrnent bi a Date for the paid in AM cycle, periodic Finance Charget wi card purchases ((i.e., purchases Meann the current le? 1rrm the date o t? the *V trine in If 9 ?mstY bit but un } artsar?on a d Carr r><. first day of the current cyclKe, rxrtrfit cant arrrftagps from the (2) Q 21??t? (including balance transfer and credit car c ec s . anodic Finance Charges begin to accrue on the date of the transaction and continue to accrue until payment in fuU is credited to the AcCnunt There is no Grace Period on cash advances Periodic Finance Charges will be calculated using the (,a•Iv Periodic Rafe in effect on the statement ctostng date. You may request a change to your b" cycle date no more than once a year. You agree that chin request may shorten any Grace Period you may on voor ave increase the lime period Tor vrhtch ppn.:Mr- F rnanC,. Char tc?5 may accrue. Any fee Finance Charge m exceed the nominal APR a cause the APR on the brllrnq Statement on which the f?einanre r_tiarge Frei appears '.^ . (c) Cash Advance Fee Finance Charges. Cash advances include all advances to get cash over the counter througgh an ava labletj n or Uoth ar m`cfif ashVlikeblPtransacr?tonsd Schec uch s as purchasing a money order travelers check, Casino or bettirq chip or a Mary ticket) as determined by us. A Finance Change will be computed on the arnoun,! nark ::a5r <?;'vanr .1>; +-' date of the transaction. (d) Fordgn Transoebon Fee Finance Charge. A Foreign I ransaction Fee Finance Charge is assessed on transactxms made in a foreign Currency. Your billing statement transactions separately from the Foreign Transaction Fee Finance Charge will tilt the . (e) Credit Limit Increase Fee Finance Charges. If vor+ reg-rPSt and are approved for a credit limit increase t,CLI,). a 4!_l f=ee Finance Charge may be assessed to your Account. (f) Monthly Maintenance Fee Finance Charges. A FinancA Charge that is assessed to the Account for each b4nq cyrl? whenever that Account s Closed with a debit tiatanre 19) Overdraft Fee Finance Charges. iApplicable only to desggna3 eed HSBC Bank USA Nprovidi ,A e de ositdaac ?r is c iVno_ V v_ reouested ovr+rlraf prrvitegs+a we V- P 1-rid Al cover any overdraft due to designated deposit account, We insufficient will transfer to !ands the on the deposit collar. account We the will amount of ihn nve,drall rounded to the next full not make a transfer ,f you do not have sufficient unused credit available or are delinquent h. In that overcase,draft the be aoverldto„raft wdi be subject to th ereunder e usual deposit account rules and fees . Under no C,rcumslances shall any such to exceed your available credit limit. You understand that we have the right to cancel this Account or your overdraft loan Pnvileges at any time, We may add an Overdraft Fee Finance Charge to yyour Account wifas your Account is utilized to cover any ovedraft on your mated deposit account. An Overdraft Fee Finance Charge computed on the amount of each overdraft transaction ht See Additional Disclosure Statement for any additional inance Charges that may be applicable to your Account ACCOUNT FEES Please see the Additional Disclosure Statement for apobcability aryl ammint of the following fees Annual Fee/Perbdlc Membership Fee if your Account is subject to an Annual Fes; or periodic Membership Fee, you agree to pay this fee each year (or other ppanodic assessment if indicated on the Additional Disclosure Twemen!) your Account is open. or closed with a balance Vou agree tha, this lee will he charged to your Account. If you close your Account within the first 90 da? is open, the Annual Fee/Periodic Mem i Your Account refundable $o asyou have not used n,P Fee(s. are The Annual Feet PeiiodiC Ntembership Fee compensates nHS C Bank Nevada, N.A. in part, for cardmember services provided or made ava$abie to you throughout the membership year Late Payment Fee A Late Payment Fee is assessed for each billing cycle in which at least the Minimum Payment, and any amount ast due, is not paid in time to be credited to the Account by tee Payment Due Date. Overlirrit Fee An Overtimit Fee is assessed i+ the Account balance exceeds aPWic the aWe credit limit at any time dunnq a billing cycle. We may impose this fee ever. if we authorize or impose any charges that cause your balance to exceed the credit limit. Other Fees and Charges Returned Payment Fee A Returned Payment Fee is assessed to the Account each time a payment check, automatic payment deduction, or other Yment method is not honored or is returned unsatisfied by e bank or other financial institution. Any payment retumed unsatisfied for any reason may be reposted to any type of transauection (r _P, cash advance, purchases, etc ! 8nd Fe.?FTr,Cf Charles may be reinstated ba(k to the payment dale at the inq ch arged for that rransaction. RAPR eturned Check Fee a Returned Check Fee is assessed to the Account each time cod crOMC ?? check, balance tram check (if available satisfied other Account access device is returns eI by * for any reason. Check By Phone Fee A Check By Phone Fee is assessed to the Account each time a payment is made by telephone, even J the payment is made by someone other than you. Stop Payrrrent Fee A Stop Payment Fee is added to the cash advance balance when a. Payment of a credit card check is stopped at your r Payment may be stopped on a credit card check no us In writing or by calling us at the telephone such Nsted on the Account billing statement, so long as check has not already been Processed A Stop Day mert request must include the check number, payee, amount. and da!eepeof the credit card check on which payment is to be must be conflirm payment is requested tr telephone, the call rtned in writs within 14 das. payment will remain in effect for six months unlesttte^ w9cl in writstg. The address to send a stop y, t d,sckWsed ,n the Additional Disclosure Statement t re u(.si rc Research Fee A Research Fee is assessed to the Account for each sales slip copy, statement copy and apclication copy requested. R+pAelment Fee A Replacement Fee is assessed to the Account if we rePlam a Card that is lost, stolen, or dam" or i` we issue a replacement Personal Identification Number (PIN) to facwIli to access to Automated Teller Machines. If a replacement card is requested on a rush basis, we will charge our current fee for this service. Reinstatement Fee reopen t ceme t or blocked is assessed whenever a ren,;nst tc docked Account is approved. Addftlonal Fees See the Additional D,sclosurn Statamnnr ..., that may be applicable to your Account. FOREIGN TRANSACTIONS you make a transaction in a foreign currency, the transaction wit be converted by the Network, into a U.S. dollar accordance with its =t rati r I amount in ?edures in itttect at time ? attons or conversion ? "ansaction is processed. these Addibonat d dosm9ure Statemeen°Ct eThe Ns shown in e e rwork may change the procedures, from time to time. at its own discretion. ACCOUNT RENEWAL, CLOSURE AND TERMINATION Card Renewal t_wo,; are 'SSUe:7 with an expiration date We have the right not !a rrinPw Your Card for »nY reason Closing Your Account `ciu can close your Account by writing to us. Your Account Dalane ! es a dwwlill emsnesub?ecctrto all the terms Charges cand onditions (If !his Agreement. You also agree to destroy your Card(s) and any unused credit card checks. We wilt not honor any cr dil and after au written on your Account or authorize any Account is closed. The address to send your request tocio". your Additional Disclosure Statement Account is disclosed in the Account Closure We may close your Account, suspend your credit privileges, or reduce our credit limit at any time and for any reason. subject to the requirements of applicable law. In any of these events our Account balance will continue to accrue r'o"arr_h!^c!P Xharges and fees until paid in full, and will remain s ;n all the terms and conditions of this Agreement. If ,ve 'fuse your Account, you agree to destroy your Card(s) a''"i ,in) Un.arri credit card checks. It your Account has tee.. closed. or your credit privileges are suspended you '• not use Your Cad or credit Card cher:ks Default cu uaill be in defaull under this AAp?r? n ?kc. cit Ir±ast the Current Payment"Due in time time be credited Ic v:rir Account by the Payment Due Date: (b) y e; ou O violate .Iny olhrr provision Of this Agreement; (C) you til d ?CCO?Tte subfect to bankruptcy or insoivenc You ynu supply us with misleadingfalse. Incom Pee o dinrcor'rect information; (11 we ' P receive information from third parties, including credit reporting agencies, which indicate a serious delinquency or charge-off with other creditors; ( ) Provide us a physical address; (h) you ex you fail to ceed your payment is returned unsahsfled b Your credit other financial institution for any reason by your bank or check is re turned Vnpaid by us. U 0) any credit card the to close our i Y Upon default, we have the credit DrrvIeges under this to terminate or suspend your rchange the terms of your Account and this Agreement do 10 Your entire Account balance inciudi equire ybou to pay cn,rUr.S immediately. and to sue you Torlwhatryou owe Uif you iii "(1 : ct pay us, your Account balance will continue to ac F'n•?i'^'c t.hargges and fees until paid :r hill ain and will crue rem h;r-ri t, all the terms and ronddi(r s Of this Agreement. If xr• c:P ?.,, , nr q wP r ,a this' bai;err,t ?•au Ndt pay our court cos s.! reasonableuatto e?yyst yes and other collection costs related to the default to the extent permitted by law In the state in which you reside and :.r r4,11 aP%ly your Payments firs, to attorneys fees and other rusts and ihrn 1,1 principal and unpa-d Finance Charges. Security interest AccriuntL have wP are not eXtcompl ndi g YCAJ at, unsecurAed in Agreement to Our if YOU se4ave cured completed an application and Security Agreement within this red account. the terms and conditions contained Yyour performance u paragraph fh so our Account. As Security for ftmiled to there reernent, including but not Account and an noel of alt credit extended under this assign. y red =rent secured credit card account, you pledge, rant to us a first priori security interest in all money now and hereafter in the Cfepps; account with the bank disclosed in the 'Additional Disclosure Statement". You authorize us to restrict withdrawals from y until such time our Deposit Account as this Account is closed and all your indebtedness is fully satisfied or until this Account is otherwise modified by us. If you exceed your credit limit, or otherwise default under the terms of r Agreement, or if this Agreement is cancelled by you or us for any reason. we may at any time thereafter and without advance notice to you. apply all or part and a1 amounts owed under thiss Count and any replacer?t securedcredit perrn?ittedd or otherw sedavailable tto us if the aYt ount in your Deposit Account is not sufficient to retire all obligations incurred related to your Account. yo owed to us u agree fo pay the amount irnmediatety. CREDIT CARD FRAUD Lost or Stolen Credit Card or Account Checks You agree to notify us immediately it your Credit card or credit card checks are lost or stolen. You mayy notify us by calling us at the phone number disclosed :n the Additional Disclosure SWernent. LlobNity for Unauthorized Use You should retain copies of all charge slips until you receive your statement, at which time you should venty that the charge true and the amounts unaltered, You may be It" Tors a0ree unauthorized use of your credit card. You will not be liable for of authorized use that zurs after yyou notify us of Possible unauthonzed use. NOV,Ou #on must be the g loss, a homer boysswrtdnp us immediately upon learning of the loss, theft or Pst red iie rthonzed use or Calif 71 us at the telephone number unauthorized usbe?p o r statement. u will not be liable for any by Your credit card Account when you notify us phone or in writing. In any rase. your liability for unaufhonzed use of your credit card 2;. not exceed $0. The address to notify us of unauthorized use of your credit card is disclosed in the Additional Disclosure Statement, You may also -11 us at the tr'Ipptione number li;tr_d On war t illino siatP als PERSONAL INFORMATION Chill" W of Name, Address, Telephone Number pit"ment You agree a give us prompt notice of any change In your re"n, "u"*+g address. telephone number or place of employment 10 -'on Financial and Other Informatlon Upon request, You agree to promptly g us accurate erf Other nlrrmaabout yourself. Cfinredoancial sReporting ive if you fait to fulfill the terms of your credit obligation a negatrva report reflecting you credit record may be submilted to a credit reporting agen if any specific mtormation related to your Account transactions or credit exoenence with us is Inaccurate- You m notify us to correct the inaccurate information (after cormirmation of the a t, Las credit reporting agency by wribnq to fifig at P errorl 0, reported to z gP.OE. Vegas. Nb 84193. &o Certain Privacy Practices You agree that from "me to time wit may receive credit oonceming you from others as stores other i nforma'on eenders, and creditrep ng agencies. and te such at we may use thus mto?iaton to arrlend,ucancel or suspend under this Ag default reement even if your credit p us '?es agree that the you are not in with us. you t of residence adrrdderrsess tous. . nshould itobecome nsecess cry to locate y re !Phone ou' You agree that our calls between supervisory personnel may listen and order to evaluate the??a You and our representative>s :n Caromembers. FOr! of our sour ce to you and to ether practices. Please reaMdai,ional information reaadinq u,i r t -.y OUr P^wacy Stalentpnl- ADDiTIONAL TERMS Change of Terms (Including Finance Charges) WE MAY CHANGE OR TERMINATE ALL OR ANY PART OF THIS AGREEMENT OR ADO NEW TERMS AT ANY TIME, INCLUDING WITHOUT LIM TION Annuirs r.n INC*FAA1wr_ L GUST OF HISTORY, I OR AN WITH US WILL BE PLICABLE APPLY TO Arb**Ion Please see the Additional Disclosure applicability to your Account. Statement for This atbitrayon provision, shell ro Claim against us. and to each of our parents, ",:=to u rewards feature In oonJutiction r Ua n officers, directoes, a fiend 1111311111P3. and each of their dispute, or controversy (wife top nagresoentarnyt;aowrt• intentional or o#wwwtse. constitution; sratWe: "14W,. or ?iaF and owhelther ff, matsk^9 PMWMt or k uremj. _ - ? daimq. crvasdahls and Oft wh from ich whom to ? Agreement or the this e enbroeability or this arb&ftb 'ndnrdirv Mle vaboy or 0 Ere Agreement ("Cia m•), *4 be ea thersot or the you Of us, Won 00 411111101on Provision and tf by biro ppursuant to thits ?n?ba>+at<a?pr orgrs at the tme t? a of go arbiyalk>n Is Sod. one ofhrL#* arbl?n proosOd?Y sinM harsve the to M)Tor e °x ? arbitrater?W *w ,?! p w agree t ob ? court or s M*4d*twi rut" ? n ?"' is in ? " S Of 11,110 °'Wn at the bad by wrRkg to to" . is Inca_ oP. ? ? P??ort 1i3* ?? for My t as Vegas. NV 89193-6740. services in rife dry n P." arbitration hearing lMl ya+ spend n? W. ptiscit is bmom, or at such o?tr Magon M e s tai dpa?bict 'refitt wee you wq f f ft of g pay ft fit q b;. PW your remainder of IN administrative Or itearf administrator on arty Clsit g IN" dW"d by theand po Y maxim i Of $1 500, Kypt,f submitted by arbitr= to ation In atbilrarptl ti e Lom to the arbltratlori ^s9t?lled to pity any by you sdrttknietatpr ,va we an of, apart y of +h• aQdlionel is ;oonsih der aIN not be you an award. If arbibuittr m ? ft arbitrator' Penile 8*11001n to" 11rd In your the arm ad for any i1eee Paid or pt, r vtte would he" been d Ef P b to arnount of the 1?sea to to ft amount of the ac4ial awastd in Kff Claim had been for ft f pense otheir The steep hear Provided bXIIWW , Nr a ste°'1e All te70p oveo YOU admirwwat& tiese f*" Paid ???, hwq*L if mobs" in any In v? ie ? twv You w4 ? be t?MQulrad tto 8oi' adrnMfiatrafor or Acfor wtyrh vie are ==:& to trte rhrs arbitration agreement is rnade Federal Arbitration pursuant to a transaction FIvotwng interstate comrnprce, and shah be governed by the on Act, 9 U S.C. Sections 1.16 (the FAA-) e Q FAA shad ov'Y applicab'e substantive law consistet w,th th (ttn FAA and provide written reasoned findings of fact and u.lus+ons ()flaw. The arbitrator's award shalt not be sub)ect 3Pt' »I r'xc?pt as Permitted by the FAA. This parties agree !i.,, ?Aard shall be kew cnnfirf nt,at rr , r -!_r" in an awn, ftrnsdictrcn T RIGHT HE PARTIES ACKNOWLEDGE THAT THEY HAVE A TO LITIG BEFORE A JUDGEAOR JURY, BUT WIRpNOT HA VE THAT RIGHT IF EITHER PARTY ELECTS ARBITRATION. THE 12 SEES HERESY KNOWINGLY AND VOLUNTARILY COURT OEFM R B D" OLiRJUJURY UPOq ELECTION OF ARBITRATION BY EITHER PARTY. CLAM= IN You may contact, obtain the OWntion rules of, Or ttte a Clairn with N AAA a JAMS as rotloivs: mestoriall P.O. Box SOd 9atlon Forum MN 554% wwwtf 45 r New York Y p erg Code of Procedure . 10005 Fw adr.corn ine'ricillf Services Arbitration RuW$ and Procedures American 1150 Connecticut Association Aw NW r . DC 20036.41 d4 cry p for C onsumer __ s (( ? C'?m?l Arblh rR ?) ntbn lee (ant other deima). Assign rt ten of Account o may anpoi on Uessign Of transfer MF a Your Agreement and Aunt assign transfer notice to you. You may not W. n or your Account, waiver Wernay eundar this ? rain enforcing certain wittatiorm or waive a of our rights rlDFtta. tPwe w ,of txr rtotns w ty° ?^ ` Y right In oew situationst we do not thereby weivIi the •saolh6r me K any provision of this or unit 'a rOn t' a rule or to be void proofs under er?y law, rub or regutatiorL all other Agreement laWO remain valid and enrorcisable. APPIleable Law and Neyada and ? Ne ? gorarne I by t Or rxit or not yft I" r thth his semen senteredd into i Accountn used all rxe?dn extended from Nevada. YOUR BILLING RIGHTS What To Do If There's An Error in Your Bill YOUR BRING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE This notice contains,imporlantInformation about our rpspp your rights and nsibii:trp; dd X our Credit Bitfino 13 N07'FY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR BILL k your by is ar Yov ?? more . IffboyOt`irt a in Y?,X VgrWMK*m Imc at the addrOft listed on wtNs fo us (on a motion 1111alleirnard. us as poaslbls. We must hex from you as soon ova sent YOU the first trig on which fis e n ` ep after eirrair or appestrad You can telephone us but d0114 so will not pr>fserye y,?,,,r rights. naccount "Ie f?owirtg iMOrmation In your rafter Your The doiler an+ount of thnumber and e suspected deerrop.ems ` Describe the error and explain, there is an error i<You can, why you believe , If you need more Inftrntapon, diescr" the Item sure about, N?y?o?tmhave suthorked us b You are not ?sck^r9 arcatrn your bill stop the Payment Your s wrings Nor on a o WMN. I stop tbhe0 P the nt. yo atlle? nutst re'd,? tthrse business can payment is schaduled to occur. YOUR RIGHTS AND OURRE3POWjMLffWS AFTER WE RECEIVE YOUR WRITTEN NOTICE: We not ? yOUr blAer mf rreect motor explein !Min- Wllltirt 90 days. we muust eithWeer explain why we believe the big was correct Aft, we " Your brier, we or report you as ?? fry We ? any art to big You bq' Cott, whou el Ln tt Ftntrtas tO we can apoy arty do not have to pay airy que?yo your Credit Limt you v? ad bnl;ofb tWr? you are tst# a to ? amount whi s we are question. the Parts of It we rind that We to Pay all F'xtanoe Chea n1ktMaOed bar ?• You will not have if we didn't make n mts YOU a gvesborwd amount rpas. and you will have to m I ma ake up any peY the Finance atatamen4ve is of 4MOunt. In anther case, we wit Payments on ft send you a amount you owe and the date it is due. if you tail to tale arttoUnt we think you owe, we may report you and you wrlis 10 us wMiln ton we f YOU you. We anyqiIia d" b us go =% We report e ,Host teN 10 pa about your big And, w you have a question roPorted you to. Upon setllenterlt You ttlhe name of anyone we everyone we report you to that the matter e dispute. must has been seettleed. tell If we quest don't f? ?e tubs. we cant cotfeo the first $50 of the mount. even if your to was correct, VERIFICATION The undersigned verifies that the statements made in the foregoing Complaint are true and correct based to the best of his/her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. i -4 .&aa - /"-? HarryA. Str sser III President, Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. : CIVIL-LAW TODD A. BAUSERMAN, DOCKET NO. Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof. Dated this /day of 2011 Laurinda J. V eker, Es uire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 . 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 Oct-04-2011 08:14:03 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency BAUSERMAN TODD A 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, NOAH, Public Health, and Coast Guard). n1a 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. https://www.dmdc.osd.mil/appj/scra/popreport.do 10/04/2011 . 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) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:L9ULOTT9F9 https://www.dmdc.osd.mil/appj/scra/popreport.do 10/04/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff vs. TODD A. BAUSERMAN, Defendant CIVIL-LAW DOCKET NO. CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Todd A. Bauserman 402 N. Earl Street Shippensburg, PA 17257 Respectfully submitted, '0000 A9f Laurinda J. Voe er, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff VS. CIVIL-LAW TODD A. BAUSERMAN, DOCKET NO. 11 ,-jg 5 C 1 k Defendant : ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION LAURINDA J. OELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 r'i G7' _ 7•?Y C • ry C7 a ` ..,, -; 1 C) ° C7 Om� Trothonotag Office of � f�^ /�~`��~7lOh7y�/ -~k-.-—'-o`—~Q Soricitor 3,5 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE — THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCEWITH PARl�P.Z3O.Z. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0Juitx10DCarlisfe, TA 0 Thono7J7240-6295 0 Ta�717240-6I73