HomeMy WebLinkAbout11-9413FILED-OFFICE
<<F THE PROTHONOTARY
M I DEC 27 PM I : 38
CUMBERLAND COUNTY
PENNSYLVANIA
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CIVIL DIVISION
Discover Bank,
Through Its Servicing) Agent,
DB Servicing Corporation
Plaintiff
vs
KEVIN A REESE
Defendant
No: // - 9YI3 clot ?COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
09432985 C A Pit SJS
Q?)
$4a vd?r?.???
CK? 16?853a2?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff _ \\
KEVIN A REESE
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been su d 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 d fenses 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 HIS 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 banking institution organized under
the laws of the State of Delaware and maintains a business address of
12 Reads Way, New Castle, DE 19720.
2. DB Servicing Corporation is the servicing affiliate for Discover
Bank, f/k/a Greenwood Trust Company, an FDIC-insured Delaware State
bank. As the servicing affiliate, DB Servicing Corporation performs a
variety of services for Discover Bank including, among other things,
the collection of delinquent accounts, marketing, application
approval, transaction approval, customer service, and billing. The
collection of delinquent accounts includes the right to forward the
account to the attorneys and/or collection agencies for collection and
to file suit on Discover Bank's behalf.
3. At all times pertinent hereto, DB Servicing Corporation is the
servicing affiliate for Discover Bank, in reference to Defendant
account, which is the subject of this litigation.
4. Defendant is adult individual(s) residing at 310 CRANES GAP RD
CARLISLE, PA 17013
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX4004 .
6. Defendant made use of said credit card and has a current balance
due of $6178.66 , as 'of October 31, 2011
7. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
8. Plaintiff is entitled to the addition of interest at the rate of
29.9906 per annum on 'the unpaid balance from October 31, 2011 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1".
9. Although repeately requested to do so by Plaintiff, Defendant has
willfully failed and/gar refused to pay the balance due the Plaintiff.
WHEREFORE, Plaintiff prays for Judgment in its favor and against
Defendant, KEVIN A REESE INDIVIDUALLY , in the amount of $6178.66
with interest at the rate of 29.990% per annum from October 31, 2011
until date of judgment and costs.
James C. ro t,42524
WELTMAN, WE NBERG & REIS CO., L.P.A.
436 Sev t Avenue, Suite 1400
Pittsbu gh PA 15219
(412) 4- 955
FAX: 4 2 38-7130
WWR# 9 2985 C A Pit SJS
This law firm is a dekt collector attempting to collect this debt for
our client and any in ormation obtained will be used for that purpose.
New Balance Minimum Payment Due
DISCOVER $0.00 $1,339.00
Payment Due Date
November 26, 2011
31 SDSN6A01 00107[2
KEVIN REESE
310 CRANES GAP RD
CARLISLE PA 17013-9637
Account Number ending in 4004
Enter Amount Enclosed Below
Access and manage your account at
www.Discaver.com or visit m.discover.com
on your mobile phone.
PO BOX 6103 111111111 is to
CAROL STREAM IL 60147-6103
Address, e-mail or telephone hange?
Go to www.Discover.corn or int change in space above. EXHIBIT
000001986458?36289816000000000000000133800
Date: October 3; 2011 Closing Date: October 31, 2011
Discover More Card /Account Summary
Account number ending in
Previous Balance $6,178.66
Payments And Credits 6,178.66
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Fees Charged + 0.00
Interest Charged + 0.00
New Balance X0.00
See Interest Charge Calculati n section following
transactions for detailed APR nformation
Credit Line $4,900.00
Credit Line Available $0.00
Cash Advance Credit Line I $2,486.00
Cash Advance Credit Line Avdilable $0.00
Page 1 of 2
Payment Information
New Balance $0.00
Minimum Payment Due $1,338.00
Payment Due Date November 26, 2011
IoM Payment Warning: If we do not receive your minimum
payment by the date listed above, you may have to pay a kite
fee of up to $35.00 and your purchase and balance transfer
APRs for new transactions may be increased up to the Penalty
APR of 29.99% variable.
Manage Your Account Online at www.Discover.com
• Securely access statements and free online tools, pay bills
online and frock 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
Cashback BonuSe I Access your account securely at www.Discover.com
Anniversary Month
2. Call 1-800-DISCOVER11-800.347-268
January Please have your Discovere card available.
Opening Cashback Bonus Ba??o?nce $ 0,00 3. Write to us at Discover, PO Box 30943,
Salt Lake City, UT 84130 (Not a payment address)
New Cashback Bonus This Perrod
-? + 000
For payments, please send to address on remittance or
Cashback Bonus Balance $ 0.00 Discover, PO Box 6103, Carol Stream, IL 60197-6103
T. 6- more, log in or www.D' r.com For TDD (Telecommunications Device for the Deal)
assistance, please call 1-800-347-7449.
Transactions
ns. Post
he Date
Payments and Credits ct 31 Oct 31 INTERNAL CHARGE-OFF $ -6,178.66
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD S 0.00
2011 Totals
9432985
TOTAL FEES CHARGED IN 2011
TOTAL INTEREST CHARGED IN 2011
$ 280.00
1,349.54
NOTICE: SEE REVERSE SIDE F 78R INFORMATION fMSC*VER
DISCOVER It pays to KEVIN REESE
DISC ?SCVVER Account number ending in 4004
page 2 of 2
Interest Charge Cakulation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current BR1ing Period: 29 da?s
TYPE OF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
RATE (APR) BVTEREST RATE
Purchases 29.99% V $0 $0
Cash Advances 29.99% V $0 $0
V = Variable Rate
Additional Important Infonna n
See your Cardmember Ag nt. Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report irdmedioielyl Cog 1-800-347-2683.
What To Do If You Think IiYou Find A Mistake On Your Statement
if you think there is an error o statement, write to us at: Discover. PO Box 30421 Salt Lake City, UT 84 1 30-042 1
In your letter, give us the folio iyong iurnformation:
Account information: our name and account number
Dollar amount: The cl lar amount of the suspected error
Descri lion of Problem If you think there is an error on your bill, describe what you believe is wrong and why you believe
it is o mist e.
You must contact us withi 60 days after the error appeared on your statement.
You must notify us of any ptentiol errors in wrin .You may call us, but if you do we are not required to investigate any
potential errors and you ay have to pay the amount in question.
While we investigate wh er or not there has been an error, the following are true:
We cannot tryto colt t the amount in question, or report you as delinquent on that amount.
The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if
we determine that we ode 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, you are responsible for the remainder of your balance.
We can apply any unpaid amount against your credit limit.
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 a following must be true:
1 The purchase must h e been made in your home state or within 100 miles of your current mailing address, and
the purchase price m st have been more than $50. (Note: Neither of these are necessary if your purchase was
based on an advertis ment we mailed to you or if we own the company that sold you the goods or services.)
2. You must have used ur credit card for the purchase. Purchases made with cash advances from an ATM or with a
check that accesses ur credit card account do not qualify.
3 You most not yet hav fully paid for the purchase.
if all of the criteria a ve are met and you arestill dissatisfied with the purchase, contact us in writing at:
Discover PO Box 3 45, Salt Lake City, UT 84 1 3 0-094 5
While we investigate the same rules apply to the disputed amount as discussed above. Aker 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 d inquent.
Payments. You may pa y oll or of your Account balance at any time. However, you must pay at least the Minimum
Payment Due by the Payment Date. Send only your payment and the top portion of this statement in the envelope
provided. Do not send cash. B sending your check as described above, you authorize us to use information on your check
to make an electronic Fund Ira r from your account at the financial institution indicated on your check or to process the
payment as a check transaction If payment is processed as an electronic fund transfer, the transfer will be for the amount of
the check. When we use inform ion from your check to make an electronic fund transfer, funds may be withdrawn from your
account as soon as the same da we receive your payment, and you will not receive your check back from your financial
institution.
The processing of your payment may be delayed if you send cash, correspondence or other items with your payment, if you
send the payment to an other a dress or if you use an envelope other than the one provided. Paymen received in proper
form at our processing facility 6 5PM local time on any day will be credited to your Account as of that day. Payments
received at our processing facili after 5PM local time will be credited to your Account as of the next day. If you have
misplaced your envelope, send our payment to Discover PO Box 6103, Carol Stream, IL 60 1 9 7-6 1 03. Please allow 7-10
days for delivery. If your paym is returned unpaid, we reserve the right to resubmit it as an electronic debit.
You can pay your scheduled m thly payment or a granter amount that does not exceed your current Account balance over
the telephone or you can setup atic ayments through a customer service representative by calling 1-800-347-2683.
Automatic payments will be dad cted on the Payment Due Date unless you request a payment date that occurs before your
Payment Due Date. If your sc led payment date falls on a weekend or bank holiday, your Pa entwill be processed the
business day prior to the weeks or bank holiday. In order to schedule monthly pa ants by telephone, you will need this
statement or>d your bank occoun inFormation_ You will be asked to provide the last Cr (4) digits of the social security
number of the primary borrower By providdeding those numbers as your electronic signature, you will be agreeing to this
authorization to allow us and y r bank to uct each payment you authorize, in the amount selected by you, from your
bank account. You also authori us to initiate debit or credit entries to your bank account, as applicable, to correct an error
in the processing of such paym t. You can cancel a scheduled payment by phone at 1-800-3,4 7-2683 or by mail at
Discover PO Box 30421, ii f ke City, UT 84130-0421, however we must receive notice at least three business days in
advance of the scheduled payme t. If your payments may vary in amount, we will tell you on each monthly statement when
ur ??nr,??will be made and ow much it will be. You must ensure that sufficient funds are available in your bank
itdScN transactions mu comply with U.S. low. If your scheduled payment is not enough to cover the Minimum
Payment Due as listed on your in thy billing statement, you will be responsible for paying the difference. If the scheduled
payment is greater than the Mini um Payment Due any excess will be applied in accordance with your Cardmember
Agreement. Your automatic P. ant amount may 6e less than the amount indicated on the periodic statement based on
credits or payments aher the Clos ng Date.
if you enroll by phone in our auto atic payment service, please fiff-in the following blanks below and retain the authorization
for your records.
Amount: ? full Pay Min Pay ? Min Pay + $
Bank Routing #:i_ -,Bank Account #: Frequency:
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER
Credit Reporting. We may r rt information about your Account to credit bureaus. Late payments, missed payments, or
other defaults on your Accov may be reflected in your credit report. We normally report the status and payment history of
your Account to credit reporfi agencies each month. I_ f you believe that our report is inaccurate or incomplete, please write
vs at the following address: iscover. PO Box 15316, Wilmington, DE 19850-5316. Please indicate your rune, address,
home telephone number and ccount number
Paying Interest We in to mpose interest charges on a transaction, fee or interest charge from the d%=d d it to the
daily balance. We continue impose interest charges until you pay the total amount you owe us. You paying
interest on Purchases as descr below. However, you cannot avoid paying interest on Balance Transfers or Cash
Advances.
Y,-01.1.t pat t Fie ew a once n your previous i ing statement by the Payment Due Date shown on that billing statement, we
wiimpose interest charg on new Purchases or an portion of a new Purchase, paid by the Payment Due Date on your
current billing statement. No Purchases are Purchases that first appear on the current billing statement.
How We Apply Payments Mo Impact Your Grace Period
yoc o not Puy your ew nte in eac mont ten, depending on the balance to which we apply your payment,
you may not get a grace pert aon new Purchases.
How We Calculate Inlsrost Ch rges Daily Balance Me" (including current transactions): We calculate interest charges
each billing period by First fig ring tfre'dody balance" For each Transaction Category. Transaction Gatagvies include
standard Purchases, standard ash Advances and different promotional balances, such as Balance Transfers.
How We Figure the Daily Ball a for Each Transaction Category
We start with the i ning balance for each day. The beginning balance for the first day of the billing period is
your balance on the day of your previous billing period
We add any interest c urges accrued on the previous day's daily balance and any new transactions and fees. We
add any new transact' ns or fees as of the later of the Transaction Date or the first day of the billing period in
which the transaction r fee posted to your Account.
We subtract any new redits and payments.
We make other adjust ents (including those adjustments required in the "Paying Interest" section).
Now We Figure Your Total In st Charges
We multiply the daily lance for each Transaction Category by its daily periodic rate. We do this for each day in
the billing period. This gives us the interest charges for each Transaction Category. To get a daily periodic rate,
we divide the APR that pplies to the Transaction Category by 365.
We add up all the daily interest charges. The sum is the total interest charge for the billing period.
flow We Include Fees
We add Balance Transfer Fees to the applicable Balance Transfer Transaction Category. We add Cash Advance
Fees to the applicable Cash Atnce Transaction Category. We add all other fees to the standard Purchase
Transaction Category.
Balance Subject to Interest Rain. Your statement shows a Balance Subject to Interest Rote. It shows this for each
transaction category. The Bala`ice Subject to Interest Rate is the average of the daily balances during the billing
period.
Credit Balances. If your Acco t has a credit balance, the amount is shown on the front of your billing statement.
A credit balance is money that s owed to you. You may make charges against this amount if your Account is
open. We will send you a refs d of any remaining balance of $1.00 or more after 6 months, or as otherwise
required by applicable law.
For TDD (Telecommunications vice for the Deaf) assistance, please cal 1-800.3147-7449.
Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance
purposes.
The Discoverocard is issued by Discover Bank, Member FDIC
9432985
RZNFE001
QU@stlons? Visit www Discover.com or DISCOVER
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
unworn falsifications to authorities, that she is Natasha SzcUXiel. Legal Placement Account Manager,
(Name) (Title)
of DB Servicing Corporation 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.
WWR# 9432985
Kevin A. Reese
6011002630554004
-
SHERIFF'S OFFICE OF CUMBERLANI.qp,. 141TY
Ronny R Anderson !f, p n
Sheriff
JA
! tl P?
Jody S Smith
Chief Deputy CUMBERLAND Ct u INT%-,
Richard W Stewart PENNSvL1'ANIA
Solicitor ` Tr.
Discover Bank
vs.
Kevin A. Reese
Case Number
2011-9413
SHERIFF'S RETURN OF SERVICE
01/03/2012 02:54 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January
3, 2012 at 1454 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kevin A. Reese, by making known unto Kirsti Reese, Daughter of Defendant at 310
Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to her personally the said true and correct copy of the same.
1 ^
A TSH , DEPUTY
SHERIFF COST: $34.00
January 05, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c Cou"ySuite Sheri. Tele so`t, Ir.c.
w
IN THE COURT OF COMMON PLEAS
i:''
CUMBERLAND COUNTY, PENNSYLVANIA
??: Dot
CIVIL DIVISION -3
Discover Bank, Through Its Servicing Agent,
DB Servicing Corporation i ti,LAdD CDUHTY
E ? SYINANIA
Plaintiff
vs. Civil Action No. 11-9413
KEVIN A REESE
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant KEVIN A REESE above named,
in the default of an Answer, in the amount of $6796.15 computed as follows:
Amount claimed in Complaint
Less payments / adjustments made
Interest on the remaining principa
from October 31, 2011 to March 01,
@ the interest rate of 29.9900
Attorney's fees
TOTAL
$6178.66
$0.00
1 balance
2012
per annum $617.49
$0.00
$6796.15
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 : z 1, /. / //-, -/FA, lo4, - -
Wil lam . Mo cza 47437
09432985 C A Pit SJS
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219
And that the last known address of the Defendant is
KEVIN A REESE
310 CRANES GAP RD
CARLISLE, PA 17013
0P4
f1*I11.SD1-)d ally
e" jo -39
?# ?-7a 1yg
11. ?_i. . Mn. 'I_r
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank, Through Its Servicing Agent DB
Servicing Corporation
Plaintiff
vs
KEVIN A REESE
Defendant
Case No. 11-9413
IMPORTANT NOTICE
TO:
KEVIN A REESE
310 CRANES GAP RD
CARLISLE, PA 17013
Date of Notice: 1011
v?
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.
try:
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
9432985 A PIT B41
'r•
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
vs.
KEVIN A REESE
Civil Action No. 11-9413
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 , KEVIN A REESE is not in military service.
Affiant further states that this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC), which states that
the DMDC does not possess any information indicating that the below
individual is in the military service:
KEVIN A REESE
310 CRANES GAP RD
CARLISLE, PA 17013
Affiant further states that the averments contained herein are true and
correct to the best of Affiant's knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C.S.A. Section
4904 relating to unsworn falsification to authorities.
AFF ANT -
Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Pagel of 2
Mar-02-2012 10:11:02
< Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
REESE KEVIN Based on the information you have furnished, the DMDC does not possess any information
MAE 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).
ohk? 14 4A4-4?m_
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.m i P URL http:Hwww.defenselink.niil/faq;pis/PC09SI.,DR.litinl. 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 3/2/2012
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 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:T11048S673
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/2/2012
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank, Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
vs. Civil Action No. 11-9413
KEVIN A REESE
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the o lowing Order of Judgment
was entered against you on 3 rll? (4},
(xx) Assumpsit Judgment in the amount of $6796.15 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 and
Prothonotary
By : j?
KEVIN A REESE
310 CRANES GAP RD
CARLISLE, PA 1.7013
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
VS. NO. 2011-9413
KEVIN A REESE
PRAECIPE FOR APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance for DISCOVER BANK
in the above case.
Date: December 18, 2014
Stephen Selinger
Print Name
Eltman, Eltman & Cooper, PC
Firm
140 Broadway, 26th Fl
Address
New York, NY 10005