Loading...
HomeMy WebLinkAbout12-1407 ?p 3 iTt--_ `cars IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff No : /a- 14-07 ewr-grw vs. COMPLAINT IN CIVIL ACTION JASON J HARING Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 09460891 C A Pit SJS 0 .x os. ,?5 PO A17Y L'? lo3'I9g53 a 918176 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Barak, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. Civil Action No JASON J HARING 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 257 SUSQUEHANNA AVE ENOLA, PA 17025 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2093 . 6. Defendant made use of said credit card and has a current balance due of $3753.79 , 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 28.990% per annum on the unpaid balance from October 31, 2011 . A copy of Plaintiff's STAETMENT 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, JASON J HARING INDIVIDUALLY , in the amount of $3753.79 with interest at the rate of 28.990% per annum from October 31, 2011 until date of judgment and costs. William T. Molczan '7437 WELTMAN, WEINBERG REIS CO., L.P.A. 436 Seventh Avenu , Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 09460891 C A Pit SJS This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. DISCOVER $375g79ce 22 SDSN6A01 0008214 JASON HARING 257 SUSQUEHANNA AVE ENOLA PA 17025-2425 Minimum Payment Due Account Number ending in 2093 $3,753.79 Enter Amount Enclosed Below Payment Due Date $ r December 17, 2011 l Please make check payable to Discover Card. Minimum yment due includes a past due amount of $827.00. Phone and internet payments must be made by 5:00pm ET for same day Access and manage your account at wwwDiscover.com or visit m.discover.com on your mobile phone. PO BOX 6103 111111111,1111111111 CAROL STREAM IL 60197 -6103 EXHIBIT 6ctos_ w?muscovefephone change 11liuilnnnf(111fJI.Ji11nni1111nn i? ? 101-tllnjui? 'o in ww.Dixover.com or print change in space above. 000001986458809162007037537900000000375379 Opening Date: November 1, 2011 - dosing Date: November 22, 2011 Discover Motiva Card Account Summary Account number ending in 2093 Previous Balance $3,753.79 Payments And Credits 0.00 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged + 0.00 New Balance $3,753.79 See Interest Charge Calculation section follow ing transactions for detailed APR information Credit Line $3,000.00 Credit Line Available $0.00 Cash Advance Credit Line $0.00 Cash Advance Credit Line Available $0.00 Cashback Banuse Anniversary Month February Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 To learn more, log in of www.Discover.com 3 Easy Ways to Contact Us 1 Access your account securely at www.Discover.com 2. Call 1-800-DISCOVER (1-800-347-2683) Please have your Discovers card available 3. Write to us at Discover, PO Box 30943, Salt Lake City, UT 8,4130 (Not a payment address) For payments, please send to address on remittance or Discover PO Box 6103, Card Stream, It. 60 1 97-6 1 03 For TDD frelecommunications Device for the Deaf) assistance, please call 1-800-347-7449 page 1 of 2 Payment Information New Balance $3,753.79 Minimum Payment Due' $3,753.79 Payment Due Date December 17 2011 'Includes past due amount of $827.00 tote 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 Penally APR of 29.99% variable. Minimum Payment Warning: IF you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance- For example: F you make no You will pay off the And you will end additional charges b6orxe shown on up pa" an using this card and this statement in estimated tatalof, cfi month you pay:: about. Only the minimum 10 years $3,754 payment If you would like information about credit counseling services, call 1-800-347.1 121 Manage Your Account Online at www.Discover.com • Access free online tools like Paydown Planner to create a plan to ray down your balance, securely access statements, pay bil s online and easily track all transactions • Make your money worth morel -find easy ways to earn and redeem cash rewards • NEW! Access your account securely through your mobile phone Transactions 9460891 T?Dates Plate Fees TOTAL FEES FOR THttS PERIOD $ 0,00 Interest Charged TOTAL INTEREST FOR THIS PERIOD - $ 0,00 2011 Totals ear-to-Date TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 235.00 764.06 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER DISCOVER i - ? It Pays to I JASON HARING Dj?'(`r Account number ending in 2093 page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account Current Billing Period: 22 days TYPE OF BALANCE ??U'ERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE INTEREST RATE Purchases 28.99% $0 $0 Cash Advances 28.99% $0 $0 V = Variable Rate Additional Important Information See your Cardmember Agreement. Your Cordmamber Agraameer nrrcirs oil the arms or jour 1ccoum asr x :toien :;arcs. ;<epcr-. ?mme(ncteN; Calf 1-800-347-2683. What To Do If You Think You Find A Mistoke 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 841 340421 In your letter give us the following information' 'Account information: Your name and account number Dollar amount: The dollar amount of the suspected error Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared an your statement. You must notify us of any potential errors in writiri You may call us, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error the following are true We 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 that amount. But, if +ve determine that we made a mistake, you will not have to pay the amount in question or any interest or other Fees related to that amount. While you do not have to pay the amount in question, you are responsible for the remainder of your balance. We can apply any unpaid amount against your credit limit. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the ids or services that you have purchased with your credit card, and you have hied in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount clue on the purchase. To use this right, all of the following must be true- I 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 account 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, Saft Lake City, UT 84130-0945 While we investigate, the some rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Payments. You may all or part of your Account balance at any time. However you must pay at least the Minimum Payment Due by the f yment Due Date. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as described above, you authorize us to use information on your check to make an electronic Fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If pa ment is processed as an electronic fund transfer, the transfer will be for the amount of the check. When we use information ham 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, you en the payment o any other address or if you use an envelope other than the one provided. Payments received in proper form at our processing facility by 5PM local time on any do will be credited to your Account as of that day_ Payments received at our processing facility after 5PM local time will Ise credited to your Account as of the next day. If you have misplaced your envelope, send your payment to Discover. PO Box 6103, Carol Stream, IL 60197 6103. Please allow 7-10 days for delivery. If your payment is returned unpaid, we reserve the right to resubmit it. s 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 automatic payments Through a customer service representative by calling 1-800-347-2683. Automatic payments will be deducted on the 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 payment will be processed the business day prior to the weekend or bank holiday. In order to schedule monthly payments b telephone, you will need this statement and your bank account information. You will be asked to provide the last four (4) 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 applicable, to correct an error in the processing of such payment. You can cancel a scheduled payment by phone at 1-800-347-2683 or by mail at Discover, PO Box 30421 Salt Lake City, UT 84130-0421 however we must receive notice at least three business days in advance of the -scheduled payment If your payments may vary in amount, we will tell you on each monthly statement when o VII be made and how much it will be. You must ensure that sufficient Funds are available in your bank acee?fl transactions must comply with U.S. law. If your scheduled pa ment is not enough to cover the Minimum Payment Due as listed on your monthlybilling 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 be less than the amount indicated on the periodic statement based on credits or payments after the Closing Date. If you enroll by phone in our automatic payment service, please fill-in the following blank! below and retain the authorization for your records. Amount ? Full Pay ? Min Pay ? Min Pay + $_ Bank Routing #: -, Bank Account #: , Frequency:___ NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected in your credit report. We normally report the status and payment history of your Account to credit reporting agencies each month. If you believe that our report is inaccurate or incomplete, please write us at the following address: Discover, PO Box 15316, Wilmington, DE 19850-5316. Please indicate your name, address, home telephone number and Account number P Interest: We begin to impose interest charges on o transaction, fee or interest charge from the day we add it to the daJ?lance. We continue to impose interest charges until you pay the total amount you owe us. You can avoid paying interest on Purchases as described below. However, you cannot avoid paying interest on Balance Transfers or trash Advances. How to .ovoid Paving Interest on Purchases I"Grace Period" yT) ou paw t e Paw a nce on your previous billing statement by the Payment Due Date shown on that billing statement, we will not impose interest charges on new Purchases or any portion of a new Purchase, paid by the Payment Due Date on your current billing statement. New Purchases are Purc)aee ,that first appear on the current billing statement. How cr ?_vmeris_'lav'moact'rour Graca'ariod ff you o not pay your Naw Balance m tuach mcnih,$en, depenaing on the oaicnca .'o v icn -a apply ?.0111 pcvmanr you moy not get a grace period on new Purchases How We Calculate Interest Charges Daffy Balance Method (including current transactions(: We calculate interest charges each billing period by first figuring the "daily balance" for each Transaction Category. Transaction Cato ores include standard Purchases, standard Cash Advances and different promotional balances, such as Balance Tronsters. How We Figure the Daily Balance for Each Transaction Category We stort with the beginning balance for each dc ;y. The beginning baance for the first day of the billing period is ,your balance on the last day of your previous billing period 'No add any interest charges accrued on the previous day's daily balance and any new transactions and fees. We rn 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 posted to your Account. az We subtract any new credits and payments. D 0 We make other adjustments (including those adjustments required in the "Paying Interest" section). o0 How Woo Figure Your Total Interest Charges °wN Ne multiply the daily balance for each Transaction Category by its daily periodic rate. We do this for each day in A the billing period, This gives us the interest charges for each Transaction Category. To get a daily periodic rate, N we divide fhe APR that applies to the Transaction Category by 365. X We add up all the daily interest charges. The sum is the total interest charge for the billing period. How We Irrdudo 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 billing 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 TDD (Telecommunications Device for the Deaf) assistance, please call 1-800-347-7449. Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance purposes. The Discover ("card is issued by Discover Bank, Member FDIC R[Ni' EOOI 9460891 Questions? 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 unsworn falsifications to authorities, that she is Natasha Szczygiel, 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# 9460891 Jason J. Haring 6011002715912093 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Opp 2012 MAR 16 PM 3: 35 >UMERLAND COUN1 Y PENNSYLVANIA Discover Bank Case Number vs. Jason J. Haring 2012-1407 SHERIFF'S RETURN OF SERVICE 03/08/2012 04:51 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 8, 2012 at 1651 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jason J. Haring, by making known unto himself personally, at 157 N. Enola Drive, Enola Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURG, D SHERIFF COST: $58.00 March 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA -..?;CIVIL DIVISION -? Ptl I: 9 Discover Bank, Through Its Servicing Agent, C?,;_,:? COUNTY DB Servicing Corporation C j Plaintiff vs. Civil Action No. 12-1407 CIVIL TERM JASON J HARING PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant JASON J HARING above named, in the default of an Answer, in the amount of $4259.06 computed as follows: Amount claimed in Complaint Less payments / adjustments made $3753.79 $0.00 Interest on the remaining principal balance from October 31, 2011 to April 18, 2012 @ the interest rate of 28.990% per annum $505.27 Attorney's fees TOTAL $0.00 $4259.06 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: William T. Mo czan 7437 09460891 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 JASON J HARING 157 N ENOLA DR ENOLA, PA 17025 r>.? %N 6 . Sb ('d alb& Cyl-& 104-) t $8 S ?-W 9?-71i3y9 NnA('.A 1?Ukw IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover-Bank, Through Its Servicing Agent DB Servicing Corporation Plaintiff VS. JASON J HARING Defendant Case No. 12-1407 CIVIL TERM IMPORTANT NOTICE TO: JASON J HARING 157 N ENOLA DR ENOLA, PA 17025 Date of Notice: 2?. 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: Matthew Urban P.A.1,134 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 (412) 338-7130 9460891 A PIT 641 \v•L IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. JASON J HARING Civil Action No. 12-1407 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA.), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant , JASON J HARING 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: JASON J HARING 157 N ENOLA DR ENOLA, PA 17025 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. AFFI T Department of Defense Manpower Data Center Results as of: Apr-23-201207:11:34 40 Status Rep art F'ursuantto the Servicemembers Chit Rehef Act Last Name: HARING First Name: JASON Date Of Interest: Apr-2.3-20.12 Active Duty End Date Statue Service Component On Active Duty On Date of Interest No NA This response reflects the individual's active duty status based on the Date of Interest. L Left Active Duty Within 367 Days of Date Of Interest No NA This response reflects whether the individual left active duty status within 367 days preceding the Date of Interest. The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Date of Interest No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty upon searcning the oata banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the date of interest as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NCAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. yha Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the date of interest, 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.htmi. If you have evidence the person was on active duty for the date of interest 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., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Date of Interest (2) Whether the individual left Active Duty status within 367 days preceding the Date of Interest (3) Whether the individual or his/her unit received early notification to report for active duty on the Date of Interest. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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),. 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN, and date of interest provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: null t r 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. 12-1407 CIVIL TERM JASON J HARING NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the fo?lowing order of Judgment was entered against you on y la7 12- (xx) Assumpsit Judgment in the amount of $4259.06 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 ( ) Arbitrati Aw rd Prothonotary By: PROTHONOT O U JASON J HARING * 157 N ENOLA DR ENOLA, PA 17025 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 CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff VS. JASON J HARING Defendant(s) SOVEREIGN BANK Garnishee(s) No. 12-1407 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9460891 0 -- . 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. 12-1407 CIVIL TERM JASON J HARING - 15'1 N• ?NOU? OQ , £11p10. PA 17023- Defendant(s) SOVEREIGN BANK - I? W • Wqb C'a tl isk? PA 1-M I3 Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against JASON J HARING , Defendant 3. against SOVEREIGN BANK... Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): 0 .$aQ.00 PQ AVY 58. oo C.SF ID3.15 d 1(1.50 11 ?ap9. 7s - Po AT Y #a,a.S INva So U. C* IOSS7 WO e>t a77ti?1 .. $ $4,259.06 $ $0.00 $ $13.30 $ 4,272.36 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9460891 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-1407 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, through its servicing agent, DB SERVICING CORPORATION, Plaintiff (s) From JASON J HARING, 157 N. Enola Drive, Enola, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SOVEREIGN BANK, 17 W. High Street, Carlisle, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,259.06 Interest -- $13.30 Atty's Comm % Atty Paid $209.75 Plaintiff Paid L.L. $.50 Due Prothy $2.25 Other Costs Date: 6/22/12 (Seal) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS B,4UILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 SHERIFF'S. OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff m THE PRO THONO U),i ' Jody S Smith Chief Deputy Richard W Stewart Solicitor 2012 JUN 29 PM 3 34 GUMNE Atit COUNTY PENN YLVANIA Discover Bank vs. Case Number Jason J. Haring 2012-1407 SHERIFF'S RETURN OF SERVICE 06/28/2012 01:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2012 at 1300 hours, he attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jason J. Haring, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 29, 2012 to Jason J. Haring, 157 N EnolE Drive, Enolal, PA 17025. SO ANSWERS, June 29, 2012 RON R ANDERSON, SHERIFF 4i 4ia ine, eputy WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9460891 Attorney for Plaintiff(s) OF THE PRO 2012 JUL 13 PM 2: 24 CUMM701 A k1 , DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION vs. JASON J HARING, CUMBERLAND County Court of Common Pleas NO. 12-1407 CIVIL TERM and SOVEREIGN BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), SOVEREIGN BANK,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By 41iam. Molczan, uire Attorney for Plainti QI tt Ck-bf ID a 0. S9(n? 97a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ate.r .,nny RAnderson FILED-OFFICE Sheriff iQF THE PROTHONOTARI' �atcy�tp at�a�Lrxr��� Jody S Smith ' Chief Deputy fi 1013 MAR is AN 4= 54 Richard W Stewart af CUMBERLAND COUNTY Solicitor OrFfcE OF THE s'��`�'rF PENW5 YLVANI A Discover Bank Case Number vs. Jason J. Haring 2012-1407 SHERIFF'S RETURN OF SERVICE 06/28/2012 01:00 PM-William Cline, Deputy Sheriff,who being duly sworn according to law,states that on June 28, 2012 at 1300 hours, he attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Jason J. Haring, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, qlarlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers,Teller, personally three cos of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 29,20 I to Jason J. Haring, 157 N Enola Drive, Enolal, PA 17025. 03/14/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.93 SO ANSWERS, March 14, 2013 RON R ANDERSON, SHERIFF as (c)CountySuite Shenff,Teleosoft,Inc.