HomeMy WebLinkAbout12-0478
. FILED-OFFICE
F THE PROTHONOTAR ,,'
2012 JAN 30 AM 11: 53 COUN GU PENNSYLVAN A TY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff No: `?_(?'? 0 C?VI
vs.
KRISTIE L TORRES
COMPLAINT IN CIVIL ACTION
Defendant 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
09433016 C A Pit SJS
Q ?Ib3.?s ?d o
?- lb D
20 02 70 197 -7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
VS. Civil Action No
KRISTIE L TORRES
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, 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 532 N PITT ST
CARLISLE, PA 17013
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX7957 .
6. Defendant made use of said credit card and has a current balance
due of $1689.76 , 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
Plaintiff.
8. Plaintiff is entitled to the addition of interest at the rate of
26.9906 per annum on the unpaid balance from October 31, 2011 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111".
9. Although repeately requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due the Plaintiff.
WHEREFORE, Plaintiff prays for Judgment in its favor and against
Defendant, KRISTIE L TORRES INDIVIDUALLY , in the amount of $1689.76
with interest at the rate of 26.9906 per annum from October 31, 2011
until date of judgment and costs.
WELTM
436 S
Pitts
(412)
FAX:
WWR#
This law firm is a debt collector attem
our client and any information obtained
ar ro 1E,42524
WEINBERG & REIS CO., L.P.A.
th Avenue, Suite 1400
h, PA 15219
-7955
-338-7130
33016 C A Pit SJS
to collect this debt for
be used for that purpose.
New Balance [=5100 mum Payment Due Account Number ending in 7957
DISCOVER Enter Amount Enclosed Below
Payment Due Date
Noverriter 26, 2011
31 SDSN6A010010733
KRISTIE TORRES
PO BOX 504
CARLISLE PA 17013-0504
EXHIBIT
I
PO BOX 6103 Illusllnn.ullunllrllnl
STREAM IL 601F97-6103 i
Address, e-mail or telephone change? CAROL Irllll lllr 1111 ll lll1111III1111r11tIIII111111111111t?1I111111)I
Go to www•Discover.com or print change in space above.
000001986458861281752000000000000000045300
)pening Dale: October 18, 2011 - Closing Hole: Oct
Discover Motiva Card Account Summary Account number ending in 7957
Previous Balance $1,689.76
Payments And Credits 1,689.76
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Fees Charged + 000
Interest Charged +
- 000
New Balance
-- $0.00
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $1 100.00
Credit Line Available $0.00
Cash Advance Credit Line $60000
Cash Advance Credit Line Available $0,00
,her -,11 9(11 1
1 N L
Payment Information
New Balance $0.00
Minimum Payment Due $453.00
Payment Due Dote November 26, 2011
Lab Payment Warning: If we do not receive your minimum
payment by the date listed above, you may have to pay a late
fee of up to $35.00 and your purchase and balance transfer
APRs for new transactions may be increased up to the Penalty
APR of 29.99% variable.
Manage Your Account Online at www.Discmer.com
• Securely access statements and Free online tools, pay bills
online and track and view all transactions simply and easily
• Make your money worth moresm -find easy ways to earn
and redeem cash rewards
• NEWT Access your account securely through your
mobile phone
&m us* Easy Ways to Contact Us
Ca5116aC1c t7W rU$° Anniversary Month 1 'a'ccess your account securely at wwwj)iscover com
February 2. Call 1-800-DISCOVER (1-800-347-2683)
hY Please have your Discovere card availableOpening Cashback Bonus Balance $ 0.00 3. Write to us at Discover, PO Box 30943,
New Cashback Bonus This Period + 000 Salt Lake City, UT 84130 (Not a payment address)
Cashback Bonus Balance - - -- For payments, please send to address on remittance or
$ 0.00 Discover PO Box 6103, Card Stream, IL 60 1 97-6 1 03
To learn more, log in at www.Disoover.com For TDD (Telecommunications Device for the Deal)
assistance, please call 1-8003 4 7-7449.
Transactions
Trans. Post
Dale Dab
Payments and Credits Oct 31 Oct 31 INTERNAL CHARGE-OFF $ 1,689.76
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2011 Totals Year-to-Date
9433016
TOTAL FEES CHARGED IN 2011
TOTAL INTEREST CHARGED IN 2011
$ 215.00
353.28
rvvm-t: 5tt KtVERSE SIDE FOR IMPORTANT INFORMATION
DISCOVER
h t ro KRISTIE TORRES
C'VEK Account number ending in 7957
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Curtw* Bang Pried 14 days
TYPE OF BALANCE
Purchases
Past Purchases
Cash Advances
V = Variable Rate
Additional Important Information
See yous.Cordmember Agreement.
ANN
RATEUAL PERCENTAGE
26.99%
29.99%
29.99%
BALANCE SUBJECT TO
INTEREST RATE
$0
$0
$0
MEREST CHARGE
$0
so
so
Your Cordmember Agreement contains alt the terms of your Account.
Lost or stolen cards. Report immediately! Call 1-800-347-2683.
What To Do if You Think You Find A !Mistake On Your Statement
If you think there is an error on your statement, write to us at: Discover PO Box 30421 Salt Lake City, UT 8413"421
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
ff is a mistue
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in wniting. You may call us, but if you do we are not required to investigate any
potential errors and you may have to pay iha amount in question.
While we investigate whether or not there has been an error. the following are true:
We cannot try to collect 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 drat amount. But, if
we determine that we made a mistake, you will not have to pay t6 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.
Your Riohts N You Are Dissatisfied With Your Credit Card 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 made with cash advances from an ATM or with a
check that accesses your credit card accounf do not qualify.
3. You must 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 same 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. You may ppaay all or part of your Account balance at any time. However, you must pay at least the Minimum
Payment Due by the Payment Due Date. Send only your payment and the top portion of this statement in the envelope
provided. Do mat send cash. Byy sending your check as descnbed above, you authorize us to use information on your check
fo make on electronic Fund hamster from your account at the financial institution indicated on your check or to process the
payment as a check tronsaction. if payment is processed as an electronic fund transfer, the transfer will be for the amount of
the check. When we use information from your check to make an electronic fund transfer funds may be withdrawn from your
account as soon as the same day 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 address or if you use an envelope other than the one provided. Payments received in proper
ion an
form at our processing facility by SPM lo
y daed at our essty offer M ll time will mplayour , ur pant to DiscoverPddelivery If yor payment is reed unpaid, we reserve the rig?it to resubmit it as an electronic debit.
You can pay your scheduled monthly payment or a greater amount that does not exceed your current Account balance over
the telephone or you can setup automata payments Through a customer service representative by calling 1-800-347-2683.
Automatic Pa errt will be deducted on a Payment Due Date unless you request a payment date that occurs before your
Payment Due Date. If your scheduled payment date falls on a weekend or bank holiday, your pa ment will be processed the
business day prior to the weekend or bank holiday. In order to schedule monthly payments by telephone, you wig need this
statement and your bank account information. You will be asked to provide the last four (Al digits of the social security
number of the primary borrower By providing those numbers as your electronic signature, you will be agreeing to this
authorization to allow us and your bank to deduct each payment you authorize, in the amount selected by you, from your
bank account. You also authorize us to initiate debit or credit entries to your bank account, as a plicable, to correct an error
in the processing of such payment. You can cancel a scheduled payment by phone at 1-800347-2683 or by mail at
Discover PO Box 30421, Salt Lake City, UT 84 1 30-042 1 however we must receive notice of least three business days in
F scheduled payment. If your payments may vary in amount, we wig tell you on each monthly statement when
?rfDwiff be made and how much it will be. You must ensure that sufficient funds are available in your bank
account, and all transactions must comply with U.S. law. If your scheduled paymentis not enough to cover the Minimum
Payment Due as listed on your monthly billing statement, you will be responsible for paying the difference. If the scheduled
payment is greater than the Minimum Payment Due any excess will be applied in accordance with your Cardmember
Agreement. Your automatic payment amount may lie less than the amount indicated on the periodic statement based on
credits or payments after the Closing Date.
9 you enroll by phone in our automatic payment service, please fill-in the following blanks below and retain the authorization
for your records.
Amount: ? Full Pay ? Min Pay ? Min Pay + S
Bank Routing #: , Bank Account
Frequency: .
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC VEK
Credit Reporting. We
your may report information about your Account to credit bureaus. fate payments, missed paymenh, or
otherAdefauhs on your Account may be reflected in your credit re rt. We normally report the status and payment history of
ccount tocredit reporting agencies each month. If believe that our reppoorrtt is inaccurate or incompkafe, please write
us at the Following address: Discover. PO Box 15316, Wilco n9fon, DE 1985Q5316. Please indicate your name, address,
home ph.... mber and Account number
Peeing hrterost Wee be8in to impose interest charges on a transaction fee or interest charge from the day we add B to the
daily balance. W continue to impose interest charges until you pay tfie total amount you owe us. You can avoidpayi
ng
interest on Purchases as described baba. However, you cannot avoid paying interest on Balance Transfers
Advances. or Cash
How to Avoid Paying Interest on Purchases "Grace Period"
you pan the New balance on your previous boiling statement by the Payment Due Date shown on that billing statement, we
wilt not im
ose i
t
t
h
P
h
p
n
eres
c
arges on new
urc
ases or an1910f, ion of a new Purchase, paid by the Payment Due Date on your
current billing statement. New Purchases are Purc6ses irst appear on the current billing statement.
How We A 1 Pa ments Ma Im ct Your Grace Period
TI you o not pay your ew a once in eac. mont , on, depending on the balance to which we apply your payment
,
you may not get a grace period on new Purchases.
How We Calculate Interest Charges Daily Balance Method (including current transactions): We cakulate interest char
ges
each billing period by first figuring the "daily balance" for each Transaction Category. Transaction Catogvies include
standard Purchases, standard Cash Advances and different promotional balances, such as Balance Transfers.
Hew We Figure the Daily Balance for Each Transaction Category
We start with the beginning balance For each day. The beginning balance for the first day of the billing period is
your balance on the last day of your previous billing period.
We add any interest charges accrued on the previous day's daily balance and any new transactions and fees. We
add any new transactions or fees as of the later of the Transaction Date or the first day of the billing period in
which the transaction or fee
osted to
our Ac
t m
n
r°
p
y
coun
.
We subtract any new credits and payments. z
n
We make other adjustments (including those adjustments required in the "Paying Interest" section).
How We Figure Your Total Interest Charges 0
g
We multiply the daily balance for each Transaction Category by its daily periodic rate. We do this for each day in
the billing period. W. gives us the interest charges for each Transaction C
t
T
d
l
a
egory.
o get a
ai
y periodic rode,
we divide the APR that applies to the Transaction Category by 365. N
We add up all the daily interest charges. The sum is the total interest charge for the billing period.
How We bxlude Fees
We add Balance Transfer Fees to the applicable Balance Transfer Transaction Category. We add Cash Advance
Fees to the applicable Cash Advance Transaction Category. We add all other Fees to the standard Purchase
Transaction Category.
Balance Subject to Interest Rate. Your statement shows a Balance Subject to Interest Rate. It shows this for each
transaction category. The Balance Subject to Interest Rate is the average of the daily balances during the billin
g
period.
Credit Balances. If your Account has a credit balance, the amount is shown on the front of your billing statement.
A credit balance is money that is owed to you. You may make charges against this amount if your Account is
open. We will send you a refund of any remaining balance of $1.00 or more after 6 months, or as otherwise
required by applicable law.
For MD (Telecommunications Device for dw Dealt assistance, please cafl 1-800-347-7449.
Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance
purposes.
The Discovermcard is issued by Discover Bank, Member FDIC
9433016
RZNFEOOI
Uueshons? Visit wwwr Discover.com cir
call 1-800-DISCOVER (1 -800-347-2683). DISC*VER
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 Szczygiel Legal Placement Account Manager
(Name) (Title)
of DB Servicing Corporation successor to DFS Services LLC servicing went 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# 9433016
Kristie L. Torres
6011002777257957
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
-FILED-OFFICE
t,in 4t u,nbr?f,jr0 0F THE PROTHONOTARY
.. 2017 FEB 17 AM 10: 45
CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank
vs.
Kristie L. Torres
Case Number
2012-478
SHERIFF'S RETURN OF SERVICE
02/10/2012 03:15 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
10, 2012 at 1515 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kristie L. Torres, by making known unto herself personally, at The Cumberland County
Prison, 1101 Claremont 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.
TIM LA K, DEPUTY
SHERIFF COST: $40.00
February 14, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
. ?nw ante S? ? ? :...., •.. ?.,_;.
IN THE COURT OF COMMON PLEAS cam "'
CUMBERLAND COUNTY, PENNSYLVANIA ter'`? Y;.
CIVIL DIVISION cnr-_ -
Discover Bank, Through Its Servicing Agent, -? _
DB Servicing Corporation>
Plaintiff
VS. Civil Action No. 2012-478 CIVIL
KRISTIE L TORRES
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant KRISTIE L TORRES above
named, in the default of an Answer, in the amount of $1865.35 computed as
follows:
Amount claimed in Complaint
Less payments / adjustments made
Interest on the remaining principa
from October 31, 2011 to March 20,
Q the interest rate of 26.990%
Attorney's fees
TOTAL
$1689.76
$0.00
1 balance
2012
per annum $175.59
$0.00
$1865.35
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.
B
Y:
William T. Molcian,474
+1(,.5o Po A11/
c? ?o?la3sa8
No?tce I?lailec?
09433016 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
KRISTIE L TORRES
CUMBERL CO PRISON UN
CARLISLE, PA 17015
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank, Through Its Servicing Agent DB
Servicing Corporation
Plaintiff
vs.
KRISTIE L TORRES
Defendant
Case No. 2012-478 CIVIL
IMPORTANT NOTICE
TO:
KRISTIE L TORRES
CUMBERL CO PRISON UNIT L 1101 CLAREMONT RD
CARLISLE, PA 17015?(Ql
....
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: Z'?'
Matth w A 551F
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
9433016 A PIT H4N
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. 2012-478 CIVIL
NON-MILITARY AFFIDAVIT
KRISTIE L TORRES
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 , KRISTIE L TORRES 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:
KRISTIE L TORRES
CUMBERL CO PRISON UN
CARLISLE, PA 17015
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.
(r
AFFIANT
• Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page] of 2
Mar-26-2012 06:16:26
'K Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
TORRES KRISTIE 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).
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/fag/12is/PC09Sl.,DR.htini. 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 3/26/2012
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:JAHLPQN3UI
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/26/2012
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. 2012-478 CIVIL
KRISTIE L TORRES
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following Order of Judgment
was entered against you on ?a?la
(xx) Assumpsit Judgment in the amount of $1865.35 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
Prothonotary
By:
PROTHONOTARY
KRISTIE L TORRES
CUMBERL CO PRISON UN
CARLISLE, PA 17015
Plaintiff's address is:
and
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955