Loading...
HomeMy WebLinkAbout12-1618IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, c, r.,, .14 Plaintiff CIVIL-LAW VS rn . X -Iq - 1 YO A. LE, DOCKET NO. 1 8 Defendant 0?? g, .. 5 M NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT. A REDUCED FEE OR NO FEE. Pennsylvania Lawyer Referral Service Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800-692-7375 717-249-3166 717-238-6807 ANGELA L. MATTTS, ESQUIRE io3._7 Sfl J ) AI'LL 1631 ?a?a3yS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW YO A. LE, DOCKET NO. Defendant COMPLAINT The Plaintiff, Unifund Corporation, by and through its attorney Angela L. Mattis, Esquire, hereby files this Complaint of which the following is a statement: 1. The Plaintiff, Unifund Corporation is a Corporation doing business at 10625 Techwoods Circle, Cincinnati, Hamilton County, Ohio 45242. 2. The Defendant, Yo A. Le, is an adult individual residing at 903 Apple Drive, Mechanicsburg, Cumberland County, PA 17055. 3. Defendant obtained a MasterCard credit card on or about September 25, 2008, from Citibank (South Dakota) N.A., (hereinafter "original creditor"), Account number 5256 5024 0407 4424. 4. Unifund Corporation has been assigned the account of the Defendant by Unifund CCR Partners. Pursuant to Pa.R.C.P. No. 1019(1), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit A. 5. Unifund CCR Partners has been assigned the account of the Defendant by Pilot Receivables Management, LLC. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit B. 6. Pilot Receivables Managament, LLC purchased the account of the Defendant from Citibank (South Dakota) N.A. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. 7. Defendant used the extended credit leaving an unpaid balance of $3,716.45 with interest continuing to accrue at 6.00% per annum. 8. Defendant defaulted on the payments due and the last payment on this account was on or about October 15, 2010. 9. The balance on the charge-off is $3,716.45 and post-charge off interest has accrued in the amount of $218.22 to date for a total remaining balance due of $3,934.67. COUNTI BREACH OF EXPRESS CONTRACT 10. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 11. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his/her account. 12. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $3,934.67. 13. Defendant accepted the extension of credit and utilized the credit card without complaint, objection or dispute as to credit services provided, the prices charged for the same or the costs incurred. 14. Defendant is indebted to the Plaintiff in the amount of $3,934.67. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. 15. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(1), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit D. WHEREFORE, Plaintiff, Unifund Corporation, demands judgment against the Defendant in the amount of $3,934.67 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 16. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 17. It is averred, in the alternative, in the paragraphs set forth above, if an express contract between original creditor and Defendant did not exist, that a contract implied by fact or implied within the law exists. 18. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to Defendant and that the original creditor expected to be paid for the Defendant's use of this credit. 19. Defendant used the credit card to purchase items, and/or transfer balances, and/or obtain cash advances and he/she received the same to Defendant's benefit. 20. The total reasonable value of the Defendant's use of the credit extended by original creditor is $3,934.67. 21. In breach of the implied contract, Defendant has failed and refused to pay the outstanding sum for the credit card use and the same is now due and owing. 22. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 23. By virtue of Plaintiff's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $3,934.67. WHEREFORE, Plaintiff, Unifund Corporation, demands judgment against Defendant in the amount of $3,934.67, together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERUIT/UNJUST ENRICHMENT 24. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 25. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, cash advances, balance transfers, fees and interest. 26. The credit extended by original creditor benefited Defendant. 27. The Defendant will be unjustly enriched if Defendant is allowed to retain the benefit resulting from Defendant's use of the credit card provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 28. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon Defendant's use of the credit card. 29. The reasonable value of the Defendant's use of the credit card including purchases, balances transfers, cash advances, fees and interest is $3,934.67. 30. Plaintiff is entitled to $3,934.67 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff Unifund Corporation demands judgment against the Defendant in the amount of $3,934.67 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, T- AngVa L. Mattis, Esquire PA ID #309229 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 ASSIGNMENT THIS ASSIGNMENT is effective as of January 1, 2012 between UNIFUND CCR PARTNERS a New York partnership ("Assignor") and UNIFUND CORPORATION, an Ohio Corporation ("Assignee"). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement"). Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. UNI D CCR PARTNERS 'By. rudy Weiss- rail/ g Vice Presiders UNIFUND CORPORATION By: UYC _ --- Morg . S itl Vice Pr id nt o erations EXHIBIT ASSIGNMENT THIS ASSIGNMENT is effective as of January 1, 2012 between PILOT RECEIVABLES MANAGEMENT, LLC an Ohio limited liability company ("Assignor") and UNIFUND CCR PARTNERS, a New York Partnership ("Assignee"). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement"). Assignor, foryalue received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. PILOT RECEIVABLES MANAGEMENT, LLC ?f By: ! ? r 5 ?i Trudy Weiss Craig Vice Preside t UNIFUND CCR PARTNERS C-- By: Mor J. Smit Vice a dent Operations EXHU31T Contract ID: UN1MUTAB112111 Document ID: 111611 UNIASISBBI Document ID: 111611UN1FXITBB 1. Document ID: 111611 UN 1 PM 1 PBB 1 BILL OF SALE THIS BILL OF SALE, dated November 21, 2011, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank") to Pilot Receivables Management, LLC, organized under the laws of the state of Ohio, with its headquarters/principal place of business at 10625 Techwoods Circle, Cincinnati, OH 45242 ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated November 21, 2011, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 and the final electronic file. Citibank, N.A. By:_. (Signature) Name: Patricia Hall Title: Financial Account Manager Pilot CBNA 112111 CITIB NK CARD AGREEMENT his Agreement and the 1Oi(;?„er containing -a Citibank Caa j ith le hard t; ailsyour i;itirri Agreement. The ;older contains ..!,oorta t account, information, lnr„uding 'lie annual perceriiage rate ano Chic • mnount of an,., mernibersmD fee. ?lease ear' and keep the ?alder and this Agreement for year rec ts. To simpliN the rest of this Agreement for you, the 'Ollortrng definitions will aptly. The no-ras you, your. and lours mean the person responsible for this Agreement; tJ'./hCm we direct ^e billing statemeni. The word 1,01.rd means one or more cam's which; we have issued with vour account number. The words we. us. and our mear; Citibank (South i)akota). The words Citibank c^eo-rs mean one or more checks 'tat ,ie may provide to access your Citibank card account. This ;agreement is binding on you unless you cancel your account within days after receiving tine r-ard and you have not used or authorized use of your account. Usina Your Account and Your Credit Line: The card must be signed to be used. Your initial credit line appears on the Colder containing the card. A portion of your credit line, called the cash advance limit, is available for cash advances. At our discretion and at anv time, we may change your credit line or cash advance limit. We will notify you if we do, either by mail or through a billing statement sent either before or after the charge takes effect' Y may request a change to your credit line or cash advance limit by contacting Customer Service by telephone or mail. The full amount of your credit 11Re is available to buy or lease goods or services wherever the card is honored. Your cash advance limit is available for cash through any bank or automated teller machine that accepts the card or by using Citibank checks. The total amount charged on your account; including purchases, balance transfers, case; advances, finance charges, fees, or other charges, must always remain below your credit line. However, if that total amount exceeds your credit line you must still pay us. Additional Carus: You may request additional cards on your account for yourself or others and you may permit another person to have access to the card or account number. However, if you do, you must pay us for ail Charges made by those persons, including charges for which you may not have intended to be responsible. You must ncfify us to revoke permission for any person you previously authorized to use your account. if you tell us to revoke another persons use of your account, we may close the account and issue a new card or cards with a different account number. You arm. responsible for the use of each card Issued on your account according to the terms of this Agreement. .,. Membership Fee: The folder containing the card indicates whether your account is subject to a membership fee. if it is, the tee is added to the purchase balance and is non- refundable unless you notihj us to cancel your account within 30 days from the mailing date of the billing statement on which the fee is billed. F EL 2. 5t - C _ 'n n - - •r, - to cD T _ r < i = - in _ = C+ - Z 75 (D _2 no -4 n C_ C, cm 7,- GI CD Si ZZ - =-r - _ t"3 o -- o J ',i-' `? _ .... cn ?• : CCI :' ;a `' - O c r-• -'='. cs G ? -- cu - _ ,'s_ c_? c? ' _1 :? `? .^.3 C O = =J-•G CD f::t. CD cz. m < car = JS - c - Y - :ten ?? c? - ?? cs N O r?? _ V . C C N C < ?w C. C ?. -•, CC:7-j--,-i ` =. SSS y r? =J O ?; -' ^ ca C, 1['I C S - fc, J ti .•. Can Co G3 ..,? =iC N -? '.-. ^ _ ?, tu^ = w '.11 .{ CJ •.r• :/: ? C] c7 -_ D F, to :.^ n CD S? Y, L,' .^-J V= C y iv CCU mD :- C4 y'7 Cns N C :n ? ti '?Q G ? _ - - .:+ = i?9'? ?• ? ? ? G G G y ^? ? c? ? .,C ,? •G y ?- O c- N :7z m +? ,,? C? 3 = ?` an :v M CD J C ?''_ t=J D_ c c N ^?? ?- c cn {? - cn. c_ c z - ? Co c O c .? - - O S G CG W P Q T . c'1 c C t ?'? -" . C n C _? y- C- f- 'n• _ .-. tif., y CTJ G D_ -..G`? r CD ccD D C, =r 7J ?Ow< ? ??.•. <`? O ' csOr?i< =?CCC?m?o JdW_ ^J ?c ° cGr_s. J a o ? n ?_ ^ ? r co ' ` cD " ? O r3 cc ? ? • 0 Cc ic= ND a =' c "-i O c n' a CS ??' •"' ?' _ c,J O C ° - -?+ N = - x < .? ?• c 5z. ?. :L7 w C •< ^ - '? C C? co D 5T -cu C eOniJ co Yr?-;' ? ????cca cJ c' n ?c _a=J w m ^: ?_? 0 c^>?Z2 = ?'-ra ? w ? O J n c ? n ` CO _? - .? C, y D m o? N Yc?T O co 0 o C'3 -'co C- c=D C, CD =r cn r n _ c? a t^- Z ___a0 0 c. - N = ? v .n• O' c' ^ ?', - C-a 1; .• O cct) -- ? G eD Q•^ = C , :L S cJ -_ - - . a y J C d _• w? O CD " - CD fj n CD o c^ .L n C _. 2) Er. ? d_ --i C T =..? CL C`j W d C m n o o = _ o ? c.? CD C,, _= _--1 c c ? " o `u m _ " c ro c - ^' cam'-, 5 CD n C.) C6 CD _W w ? ? J - DU- ?. O CD ? CD Z E n C. ` m :? ? N J CD ?- 0 CD O d C `< N C I C7 = C? ('1 J CD = W O - (D CD O _? - - C.. -CIC .- CD co C1 co ..... (-] .- _ C C jJ = - CA -, -um N .-. CD :,; n '_ ..., O ....- d r W ti - C• Z; C d ( •-? - , L1J f? Zr CA, D N Cv CD O y co WSJ fn ''? --. W ,.-. ? ` CD -c-? CD W C W C7 CD W G• < d Cn W ?_ - `?C O C O t< C, cD 0 Cj - CD ':E CD ;D -Vt Ji < V: C'") 07 -' Ca C'7 ca Q ?J C^• W N CD 7 d ?-< CT CD CZ wYl CD Y, n w - ??'?G ^ ?CCC 2 v J ;? a'-d CD ccnC= y cQ ?t3O ^ F O S -_ m C -•r; ?, :-' _ c „? G ?. cc %? - :C -? CD C C "S r. _ ?. ' = d C r7 c .-, CD d co N ?C:- cg :E G. c co --+ c... -D 7 C.-` D :E - C J - ' ^ O `C : 7 G 27 y .?'. Cs. CJ c? O y .d p^.' =G„. C C ? c cs n -- ° o o? _ _ _ cD a?---? rcn o ?c y Sr?? Tc =%? r? J a c v n ?. n -D Co Cn j 25' - d CO J =! - C? y - BSI d W .?; co ?.$. ~ cm :J cn .? 2.3 =J as = CO c - r n m .c C - cn co cn c w _ T. O- C7 N W G - •^r CD ^ ?" O _..< - _ '•' N L'D `< r "' ^_ t< U C5 n O C _ _ :L ;n _ c!? ..,C _- E;T CL x . O u-. -" '." O LJ C? = j d CD ??< cD CC CD ...+ y .-+• O C-J Lo CO fn AJ cb 2 W d O C cm = - r G M CC,, T O j O, C CD C -. Cr, n -? ?. c d N y _. C -F o* n =-c -< < Cs `-,. = p r = [D UJ N _ r- .1J n .< .- n N O 0.7 . y CC C'f = X - CD O `< CD O CD '-- Cc d `2 D.. n LD +-?- C C-i7 ED O• `' S h CD CC w C7 O -'• C O n _.DJ -`-+ - •-' Co CD O N e ' D ^ u cD N C/J cr C t0 CD CD W< , t' 7.1 =t - r C O G < ^^.7 Li ?• CD CD ^. `n L= ?2 CU J " Cp W m en y co C '" n - co = Tom. 'D C J. u c r? c; ° _• m _ tom' c? c? c_;c N CD r M = r°n - 'mac o m _^? ? = c? co c 3 c? ° ? CD Q CD n y c? 'd G y ° v> rOn =_ n C = C ?' < = . c c'J cc D ° :n °• O CD y. _N m • _?- -' -• 7::j a V) ^ C'7• cm-, U :_J t-? 'u x .C/J O_ Q d J V CD _ w :.J 2 u. O C.^ 'C = "? y ?< C` cV y- n - p L` ?, Y c' rJ O ,-`C r ? J cQ _ . en J F U.) d O CD W N ti'. C co CA N^..J CL co ED M W CD Z=' o y co C n ?.. d 'J m cD t ca =? O o N _ d O cs y •? •c ?. :D . CD N y -'s`- - G •_- CO =• d y ?. CJ O t. C7 d O ^. y ^= ? y O C J -"? C ^ ?•C CD G _• _ - !G - _ '< .. O CC C ?'- N CD f'7' cJ c=;' O C D :? - - C O n D+ co CJ to ' -. CD ran cD = ," D c: G CD _ `- c".+ ? yo cn m -?Q 7, 7?i iF -D I-j Ch c-, (A - j p _ i.•, D C', C' j "?.."- ~ O =? ccj : V:_ " fi T C. = ' C 'Y,'• -' L ^; ^ C i O - - _ L !-C -:, m .v - /maryy =P "_ C cr, C ;•: o' (? n _" ? C C C =C = ?? =- c = z z to = - c•`? ? c . O I c : •:C . -• _ = O .-.• C? - ? C O-?? n v cn :? - 'n •G ?GJ = ?' _ " ..e ? cc C.w ' • Cb - FM - - x j O = c n ?? c= v c ?_ n . d C ti Gnu . c..• _•.,,= z O CD L c? " G _ < = T C O _ ^. O ,n ` = - : _.57 C n ?. O _ :D C •, C: - a ?i'cri CCD ?c ==Zj = -^'??m c vac LO . cn m rn ? ^ ," = _ _ O c'r ¢ ; _ - C T ,- •.- C7=? -r n D^ =? iT7 G ^ o- D occ? = , ?; _ C - o - C,G- C j (n C7 q ci-J `C n G S ;T ,= c _ C, = " _ C rn cD C: c , ' U7 Q ' =^ co En 'n ? < C. ti C 43 •'D i 62 , O - CD - C •--. C 1 C G D* O ^ -< O - ^ _W _ ---I C `n ? cu C Cn O :n Cp - cn G w (4 _ -D CD r -. C - `? - '- ? C ? c: C O . r - C p ? CD in c7 ' C. C ^ ^' ? .? C ,.,, -' ?- ?' = O C '- •"' U :., =' ^' s C O C ;, O _ G ZT CD G . 1, Ul -? ? ?7°*? ?ccr 2 a 'C) -?-^= = T ?Q-0 t < C O RiY -•," 4 - -.. v : C?J _ cn c O O m CD =i O O `- rz q?.0 v ?cti c=" cn °`C - ?' ?z•.,?'cD-o J tv coo=_ «+ T-CDCCO a' -' , -1 n 2 v, °- CD O ^- = _, C_ - C CE, G O =? C CD CC, •? ^ CJ.7 = Cn `r ?• - _ L.' cv?D °-' R' "* -co cn". 0_ n n o ? co ^G ? o co coS D - =to ?`na . U, <v,? (D o c'tiG o %n?_, - s - In tD p m to o_ co .c R2 =- - C, r. - - CD s cR - t", - d CDC cu ? cr_' _ ° c a1 e' ° vci O (79 X .69 O ti tcDn 4-5 Cb cNn CO .-^..• r O O { - c? G7 Z rn _ C :D - c?D O cD - = c? O J CD N N n N\ J ti, y > N y C., C n ^ 4 ._-'G CO co c:D y Z Cn J C .-. O O G: ?• C O EIL .O^.? CD T J =_ v ;.'< v, -` __ D Cl) - ;p o G m ca cD c? < CD m - < Cn rte, C cn CO CL (D Ln - -= ro c o 7C j< n O ?`C _'.? CD CC ?O,C N n v- .N-. G y O C-• to C C) x COD CD O 4 O m c "i C. EF 0 Er C-- co L" -D c. C6 C?w O =. C C_t•`• C J CJOb C'? 0 {n C]. G `G CO D.: i?j C7 C n, U .?.1 O CD n O N G cl, < 02 'o N -. C CD „y, CL r CD O Cn O -' ?-,' C) VJ C'1 - co W r, - :.1 CD ._._ CJ - y r1. N < co Cc.,^' ^ p TJ ,? a a y p : ?C y y p ;7 V; C ? = a, cn' C• Cp ^ p _ C ro u; y a2 CD --o - ?_' .O^.. A tU C e•) n- C ,-, O r _ ..) CD 2-10 C C r, Cn C z. C Cfs O" Cn '_` - = W c T O C, CD N CA c i'? En v :3 cn CD cn `D - o ?CC? .'n c ins c-_ aai c - {D ° co m o L- C N.? - cn ?? cD=? o=-. CD -- cn p°'oW? ow o Q? ?.3=- _c c_ m G o a D- r ce co w- - 2 Q?c ? o :J = ]i ?' G _• 'ri h `•' d O Cn C .r'. %? _o .il N CD ,.. =? CC-) •-? " .? O E cn" Cl) :Y co N (D Z7 G 7 :7 CD ._ : C =? D O ,_ C= .?' O G `• CD .? O r [_D cn C y N, C7 N (7 p cD m O ?_ A ? C C _ , C r" - :J 4^•. ?{ C7 a co O c T .^ O Cn v CD Q C v m .? T CD O .-- = G G!R C 7c• to ?_ G CD cL CD ?_ L ^ "•' .?•J ^yu -x 1 Cn .^'] Co `G -'-•. r O cGJ (G Cn v w C? < y 'D C: Z? ,r ^- C: C: `C = ?. 1 :? 2 -?•' : , O"? ?_ O y Cc h V, CC/7 Cn a L' `) C•, un, ^ a C C _ C -C ca ` ?{ - cD O C; C CD O cf) ci C" 'D ?.... t_.. = O CD O tD `oK O CD j4• y ". C7 G CD J - C CD Co CD - V,. - ? j G 7 [D .n "1 .r. • O n U C^ :J a, N O :D M W 'C3 CCD C O r r C C) CD r S y-0 G C GC•) O C G 00 ra -' O x -• T.C cD s OC T CD C ro y c? r O o v ?•` cr g- O Co j CD <`D C`j == CD O _' ,fl _ cD ^^ Co :^ to O CL x ,-. n c - o -- ? ^ ca = Cam -o n c ol< - - -"0 a' = C. CD y C/) Cj ^ w CD J c9 CJ'' `C O Citibank Checks: l,.`10 i.n i MCC m :'J b u 60 .,r.`urchr"A go a.: d 1 : or !p .;'a mc r of ; .ur .v..ll<"air rash 30Jc c i1rUt '1 r_5 that n OL t'l:!! cause the dal, .ce o e ceed you; CreV lire tie will Ve t G fbdi.:. rECC` k a . . _ ;d'd 'r 7 li^si. a Ci, !,Il a 11 . cash advcrr- no -"arge ; i7m 19i3k $t your cash +'i h ck. r^':$t n 'hE 'G-, M we h"a e iSS d anG ? ust le us -d . ci di nQ !o y auks may _- use; F?j rre Us: s ?? ;,''J - illst uc , n e tifu. IC ?I'tu ,? n - ".3 ^6'c r i r ?r t!1 `l itiban. cl .Ck IT :C[ ce o -:n a/ .;''i r c?u"t owe--f to us ;n Vie: this or an, other C tibark r 'd g °eme t `'; ,Jill . ?t , rif any C Man! .hec;l,s, nor uill we return paid C :':".ank cnerkS. Returned Citibank Check n=ee: .. j?1: -f:•? S[? _r r h,. -Coch advance 1, '1C° if rNr r' IirC n -P w C1 IK h 14e r , ie line Ono t , ank cheC,, A 1? e or credit Ilne, it you a fau t, if loll did not Co viv it h aU. f G.r$ r yar(]liy the check, t'.iGUr aCCu!?nt has "eEn closed. or ,< • i" Care has . as rri. Stop Payment Fee: We ':Jill and a $29 fee to tie cash advance balance ?r,hen pa, merit o; Cititan'lk payment on e CIt:bagk ci:eCk by check is --topped your request. You may stop I r,ped at yo U notifying us in writing at P.O. Box 6500. Sioux Fails. South Dakota 57117 or by calling us a* the telephone number listed on the billing statertem. If you cal, you must confirm the call in writing'.vlthin 11 days. A written stop ua'/m?nt order will remain, in, e act for six months unless renewed in writing. Once a 'harge is made through the use of the card or account number-ne cannot 'stop payment' on the charge. If there is a dispute involving a ct arge on 'r cCC?::^t: please refer to the section entitled `Mlrat to Do If 'here's Art Crmr iii ` Cur Bill!", Lost or Stolen Cards, Account Numbers or Citibank Checks: Ill n.a card. account number or Citibank check is lost or stolen or if you think s; reoi,e us d or flay use them without your permission, r:ctify us at once by .O-Iling the telephone number shown on the billing statement or the number ;,ht;;rni:?-;' callirl,' tCil-free or local Directory nSsistance. We may require you. to, pfcyide certain lrt'--rnlation In writing to help us fired out what ha,pered. Dona use the card or the Citibank checks after we've been notified. e:reil if they are found or returned. You may be liable for unauthorized use of the card. but not for more than S50. You won't be'iable for unauthorized purchases or cash advances made after we've been notified of the loss or the theft: however, you must identify for us the charges on the billing statement that v-ere not made by you, or someone authorized by you, and from which you received no benefit. Default: You default under -,his Acreement if you fail to pay the I ,inimum payment iistea on each billing statement when due, fail 'to make a payment to any other creditor when due, file for bankruptcy, exceed your credt'line without dermissioni. pay by a check or similar instrument that !s not honored or that we must return, because it cannot be processed, pay by automatic debit that is returned unpaid, or default on any other Citibank Card Agreement. If you default, we may close your account and demand imr-nediate payment of tine full balance. If you have given us a security interest in a certificate of deposit or a savings account, we may use the deposit amount to pay any amounr `Jou mve. - L [?J X C7 Cr ??p C T ^L^-O a CD OCnD G C _ _ r+ ^ C y w 'C .- c c C7 C - T J r--- _ O y - : O =•'"? _ .n C CJ C n - - m z- `es< CD == C_ _'.:? 1• O =•' ti N _ " r _' -C - . y :' T5 - Z.^ Cn G C S y O C " O ?' ?• CJ r `' f .`± ° G cn = G r oo--t- _-..^u vp ' =.- D ..-" 57 a-i U) 2.2 Q _ z 3 [y m - o C :D M in .•1' u C '??- C _ C cD R '< -' _ •? Cf ON 1 G O fn ?. ? Q n 1` Q r C C %> •? y CL -- Cn O O [?Ti CJ ti O_' -n+ -+ C O C. C? C ?? : J C J r C t O .t O_ y C9 ` :° [7 C C tD c su y c l ?_-' `` °_ '_ cO?i7 o c" - ?c Co c cn co N„ o n aoi =+ p :n --- " " rd = J o "' ,r''»• °_ '' _ .c» ?? ° °' CD c' o ^ - = `.°. 3 c '.'n... t? c L-- = =' = c * ='.?'? _c cc ° _ < c Ca c7 _ ?? < °- cc ?? cc ° c`> m o G "-c' 0 0 _ ^- Q ^.'? -- " 7 r7 ti -- ^ •? O CJ O - G C O CD rp ! ti G _- N G^ C ^-. $ -- C C CD N C9 (/? G - v O ^J C-. '? ._. CD ..7 N CJ C C-, C r 7 ,., :T ^ -C•t C'D ^ C3 ... -,,. < 3• T CD w =CD ~ .?.? C J N y ^ '^-' ,N-a• O ,^:> G C G C r ^- < ??. C'v y• c '"' V'' s' 7` ^ M J C N V1 ^. CD C [n . O --N= N j c O O- ... Q _ .? O Co c= '? C_ _ .? " -• :J ?G y c5 a ^ ^ f'7 _ N G . :5 v y N y N ? pr? •7 y C W N 0 C-, -- C E w = O C C_• C ° C!7 ? Cn C G ? -3 -? O G CD n ? C y ? . C O O x 'COD y r °. Z16 O -= ?...• C co = -C° = c C°C 4 .c "' . °-' CD t Ri O '? ° b o'-• rG - y CD `-" Cb LO ?, O: ? ° C •L^ N C6, S? = 11 = 02 CD ?_ V7 ??` - o o n °-Gm - rs m m cu cKro 3 m «uv'i m O=0 c+?.c -c o cD -a °_ o cam co ??•• p7 4 C :E flJ7 n C f Ca CII`"L,< .< A 'O AJ CCD CZ) - CD .--..• y V7 C - ca GD C `C y •C'P cL N.C =_CGV C,•Oy:EIe y?< m O QC ° ?_? °`C C CN C 5 'CO', in o N ° n. y?•? ; ?C C•?? p ?.Q- ? c.p N =N..{ C ?'?' C Gm O v G O O Cp c to ^ O =c AO p N co - CD Co Cm - -c 3 0 co p =2 _ •?- G O fj CD w= _ ° - y c - cc ?• p'..? A C' C -A•? A i+- O 9J C y r' y. _ N O ?S • CA O A N e_S ^ (n O w C@n O ° O CD * a G .•+• O to C, O ^ ,y~.• ° A C rnp m q ca=m ccpcri a3Ap na m=L' ._P7"0C N? -? n -r `;C O -' F'. A O in .^. y Cv co C• _ ••, .n-« _ n O c1 n _? ^„ G n n CII r N J - .-. .-«^- Y J. C^'.7 -. E3, O -• A •O • O = in O -tp L'7 N ^A., ° .? = O C '? O CD -Oi Sy In C`?7 -cz ED ? y C G G n G c C O n r+ -t N y .Cn N m N < O b O Q CD 4 W^ C cJ O J C ro' co CD 'm 0 CD c, .-.- Cn . O O N T O N .•. O 5p . C C ° ^ '? = N G C K C c- cD y G Crt FF C9 G7 { C n A `G F.% .ry `>`C -G / 'O y. = W W CJ) n --.. ?..0.• p O y O C 7 ?+ 51 -0.., p - G a A: `i i O < .iJ n Cp O O • , C11 ?, ; j O ,C C R) = .. Ai a y` O - C C = 3 C C' -ys O mem { o Qcae?o7z?' (D cr?m.c O aco a,, _c_ Q 3 moo o mc?3mo1m3 co ?w pa cl C. cr Cl- ? C ? ? c m N mom °- ••". N J CD n - ? m m CD p 3 o °7• ?. ci Op n -' CJ cQ p1 - c^ o ` o (G m ? °c_ -0 ::E co w' ° o .?•r. co C y c = 3 a' (n`c _ C., p . O c C? ?• - c Ca s= Cc a ` o `9 n ' vii r' < = = n cc co o =L 23 <3 - -? co CD m mos?Da7-y ct2 (? 'm p, mo ro(R f - o x CCi7 ' m < ° r ?' -. .•. c CO o G .+• ,, 0 3 0 o C c _? J aco ca m =3'?C A Eel co U-5 co A` ?C 4 - ? G = G N •G 3 .? _o ?mnnnn co CL ?o`N? ?ccn'o3c=(D r' ? CD 71- - C, n?O ymC ?o= A y-c - =. s °co Ica D ?'????T°C?'f7 ?oyCno °3. aN• -c °3 y° m gym A CD Ga CD CA CD O ? ? C (? C C N 'C O N ? C CD *- O J _ 'O ? N ?Cc ??a R co °oa7 'Go?c?-acaao c '- 23, ° ?cm?°mo O Tim Z- - (Q o y _c ao c ?C°n n? CM Ccc C C° ro m w m °.^GO 3 z;; < c rci oa?-7 a '? mC°n??CO- c ?: gLQ °= co c o oa^.c - < c-(7 'mom co v ?n - = a o n c, - -y :-« co rn ..m < cD ?c co c ? m v n U8 ° o Vw `--' CD coo o? `? c o a w = . - M? CD (n C n g o -n nCd' c a7 3 c cG 3 n c< n ca = ?? c iEr 3 co a, c CD = o (D G Cu ^ .. ?-p n n ` O C'f `. n J ti ^n:.c? .C Cn '?, C s -`< ?' C ^ N O E- - o n'^ cc ?. Y mn CDC co- Q a? O •? oC' ]? ° y y oc J mroan?_ `?G O .. _ ".3 co n `G rJ (Gj y O CM) P. CO CD ^ y.? n 2 N C, O co c=c?-?m•ocN?=c No- <-c =?_ _'{ i7 3 ° cc?ncn= n-C'° _xCD °= 3 3 y? n O O ?2 y .c c9 C-°•?_ -`< °_ ??.M O m -?, 3 - Ln .? CA Cn O U7 A N r N C -9 AI '••• n N CI C 2517 J f9 CD in CD C7)C-. O m ° o ' n C C CL? a--C-7' @ Cam- =- n. v7 y .-- O C p r y C p `? - ca C d v cD ?' O c-- [O ..• C w o sn c `? : c < y_C-mc° < t- OCM. -co _cps 3• °,C? .» CC Cn07=?cp .00 Oo =r CD 8 0 r- C-1o c?7 33 _ ^, ?•n ?N c ,v m ro .co o c c CCt 2 o c ?a 'v cvc _ mOc,- ?_ co co 'D N C.'1 p w 'C C' cs°'o C/Ci C C,• =? C C J ^_ ?. C :O' ?'? - "p ?O O O c?o ^ O r^L-• ?. co c_° 'O Q rn ^ y ? C" n, CA ni° Cn 0 5?. 'T, CD E; C9 N O <'? ?, Si G O A N A ? tD C-°• ? ?_ ^J CO n , . p y ar o cNi.c•m c s`?n cc ?,• ccn ° CD ui 3 m $? y <a C o c C47 oo m N Cl, CD co CO CO =L 50 co CD 1= En Aj ?< -• co O - am --, N V :D 0 77 ? . .. -, r y-_ z C C V- C 52 -c: 7CD ? - c cD - " ?.C? a %, cz ` n ? Bo -c o $ C- 1 7 _. t `C ?. - 0.- ,n CD O O m y n n c J { c ct u-- O O C [p O Cj _ b cD ?. to O .? G O -. < ' cD o C° T r m Q c? c-j m ?. . = O G = y b /S cr.. - cb , C - y cD to '? G O CA co 1 C-) 2 c-b CD a -75 cm) CD ?77 !D z? c.) <? C: gT =t EL CD 5 ,CR 72 5 "n CD r-L cp nq•C? .... c c0=^. y cb ' - w `? CD `acs tD c c x y = O co Q .r ? ?. q c O q .-. C C x Vol 2 C CD C n cr, C-1 TS pO m CCD _ ymco u= y < G (n cA y O CD C c = c ? _ C-- D CD - ^ c = CD - b t J C ^? -ii n d r C CT n O h O . t? Ct -= `-• .y- - CA 10 ?. y y N CD CJ ? V <D y c a nQ c'DOC? Sir C n' - . C co Q ?J CJ CD a CD Q 7 0. CD co m pyc z- r^ h C9? O. cr, ' _' y 21 O ' % =.: CD C: CD Cn U) ro J G C T CD O •0. ' 5I C y ? , n q Cj ct - 0 ED C.) C - C C C co Z' =) p 2 co N ? to cv O to n" ,? Cc Cn ca n ZI ? O ?{ C ;D C v c0 CD C) Cn CD rJ CD [7 CD CD CD CD w -- v, CD tn 5. O `G G^ • G • X LSD 9 C [n A7 =co cr 03 ,< c- C%J r Q- ,:; .. J I CD C n d CD y :? .O -o O , O O? D C 0. ?C d ?O -al = ? "-D m ?`G 1 m? i-•O `D c_D O a c - w i m co `C -Ci C O _`C `G cv CS n ? 1 Q cn n•C = = C J n C1 .- fl - ••« O. Q = CD cD ` cD c ° IM ° p fv y'`'am' O O = * - r y - - C am.- (r) ra c, . cm -< c) C C co en l< to cribOy O^' n>C ? iOc b ,8 1.0 -ba 4 'C C - X Co w' C1 n cP h sw =r CD N ^ ' rJ y CD `C `C c" 7r - A = cD `C C _ o_ o a= CD = c`e' C, cR y C ro•C ° C --. ?. c' b -?C c^Cj nd - y C -+ 77 C7 n „' ^e co c Er 'D G CD `c O n ^ q y O _ CO tn C-1 cn -it =L ta CD cu O cJ N CD O w cm 0 onDac'd w=N°'=' :fib--c" m m o o G ^? Q O ti _G C n ro 0 O c0-, ro y Co a C- aa=:z c„o o cv c c= O C O - a? m '?. p " c C C X ct b co CD --m N ^^ ? = `t ? cD cD ?m ?.n o c o co VERIFICATION OF COMPLAINT AGAINST YO A. LE The undersigned verifies that the statements made in the foregoing Complaint are true and correct based to the best of his/her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Unifund Corporation Chris Blanton Authorized Representative for Unifund Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. YO A. LE, : CIVIL-LAW : DOCKET NO. Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, and has not been in such service within thirty days hereof. Dated this?day of , 2012 /0-- Angglat attis, Esquire Attorney ID # 309229 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 Request for Military Status Department of Defense Manpower Data Center 46 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-22-2012 09:51:19 Last First/Middle Name Begin Date Active Duty Status Active Duty End Date Service Agency Based on the information you have furnished, the DMDC does not possess LE YO A . 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//vis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are 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:HIMDKHUHEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW YO A. LE, DOCKET NO. Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Unifund Corporation 10625 Techwoods Circle Cincinnati, OH 45242 Defendant: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 Respectfully submitted, Ange a L. attis, Esquire PA ID #309229 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW C YO A. LE DOCKET NO. got a' ? ?) 8 " 1 va ?; Defendant ,ate rn F;j tl d > C !z v c- -o : = £-; x o ... ENTRY OF APPEARANCE' Kindly enter my appearance on behalf of Unifund Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, AN LA L. ATTIS, ESQUIRE Attorney ID #309229 36 W Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor t?! -i Et i4,.rlr L' 4 0 r: Unifund Corporation vs. Yo A. Le Case Number 2012-1618 SHERIFF'S RETURN OF SERVICE 04/04/2012 02:32 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2012 at 1432 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Yo A. Le, by making known unto himself personally, at 903 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.00 April 09, 2012 MICHELLE GUT LL, DEPUTY SO ANSWERS, 22 ° --?? RON Y R ANDERSON, SHERIFF •i IN THE COURT OF CON&M PLEAS OF CUMBERLAND C66A I"' ROTH 0N0 TAR"t COMMONWEALTH OF PENNSYLVANIA 17 AM 11: 514 UNiFUND CORPORATION, Plaintiff YO A. LE, vs. Defendant (,'!MOERLAND COUNTY PENNSYLVANIA CIVIL-LAW : DOCKET NO. 2012-1618 CIVIL PRAM FOR JjJDGAT AND ASKS T OF TO TW P8017HONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $ 3,934.67 Interest from March 13, 2012 $ 39.35 Total: $ 3,974.02 Kindly assess damages against Defendant in the sum of $ 3,974.02 plus continuing interest at the rtory rate of 6®/0. BY: 4i2?? Angela L. Mattis, Esquire Attorney for Plaintiff s4sb do e ?1'7i53a? llohee (1?Gu?e? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. YO A. LE, Defendant TO: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 CIVIL-LAW : DOCKET NO. 2012-1618 CIVIL Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Award on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: ANGELA L. MATTIS, ESQUIRE AT THIS TELEPHONE NUMBER: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNWUND CORPORATION, Plaintiff vs. YO A. LE, CIVIL-LAW DOCKET NO. 2012-1618 CIVIL Defendant COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, ANGELA L. MAIMS, ESQUIRE, hereby swear and certify that a copy of the Ten (10) Day Notice was served on Defendant by regular mail on May 2, 2012. BY: Angela L. Mattis, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. YO A. LE, Defendant TO: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 CIVIL-LAW DOCKET NO. 2012-1618 CIVIL DATE OF NOTICE: May 2, 2012 IMPORTANT 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. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 717-238-6807 RE RATION Angela L. Mattis, Esquire 570-387-1873 Mailed to: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. YO A. LE, CIVIL-LAW : DOCKET NO. 2012-1618 CIVIL Defendant The Defewimt is not now in the Miiitary Service, as defined is the Saber's and Saver's Civic Reef Act of 1910 with asseadeaents, and has not been in so& service within thirty days heveof day of 1 ,2012 Angela L. 's, EsWire Attorney For Retnit Corporation Attorney ID 309229 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 Department of Defense Manpmer Data Center a.arr e. or: May -14 20i2 »:se:se SCRA 2.1 Rli?tl?t Pik to Ifet's Qvff R*W Act Last Name: LE First Name: YO Active Duty Status Date May-14-2012 ow A?at,pon ?drsaorra?wpar NA w MA Th:n.P?..rWc+..d:?.YC.W.M,,.r.a...donw.,ltli?»o?Yar..©.b ua?ewr+.*?rwr?arr ai?>4?.awyiw.aar.' MA No The fefimb r?-to:,a,:"Mar" my.r...r m3$7d wa«o+an,h.hA cy,awso.r 7m wrew or moo wr"uss ftfteer+PAWO*W*Awr 0ift- 41'» aww ?r??sM? MA No NA nftw.p.a..wla,rwrsr"w"arnawuMtimmc*md " 10 baw.ay upon am d" the data banks of the DopaMte M of Da*mw Manpower Dais Cen . bawd an dw Ntorandon that you powldad. Ilea above is Ow states of the ktdivi W on tlta acbm dtAy at" date ae to A brandm of the UnHtxrn W Servtoee (And/. NaW, Mm *w Corps. Air Faros, N00A Pwft Hamm, and Coast Guard). This ams WckWes hbffradw on a SerAcerneatber or hWW omit reooMM notMmVon of fuWre orders to report far Active Duty. • Abl A Mary M. SrawveV-DWn. Director Dep wbrmt of Detenee - Manpower Dan Conn aW Me* Canter Drive, Suft 04M Arington, VA 22360 The Ddsnse Many ww Doh Center (oMDC) is an orgsnkadon of the Department of Debase (oco) that makolns the Daiaree Enrolment and Eligibility Reporting Sysfem (DEERS) dotebase which is the oflclei source of data on eligibility for mNflary medical cans and odor e" My systems. The WD Maongiy upporfa the enforcement of the Servioenron*ers ChM Relief Act (50 USC App. § 501 at seq. as amended) (SCRA) (former iaown as the sdm and Salsa' Civil Ramef Ad of 1940). DMDC has issued hundreds of thousands of does not possess any kdornmllom indloaft that the ku li idual is a mvw* on a*A duflr response, and has aaperienced only a ama$ error rata. In the ewer[ the individual reiaranoed above, or any fm* member. Mend, or repreeasidi a asserts in any mwvw that the Individual was on aaxmw duty for the active duty at" dale, or is aManrles wdfred to the pews-, d the SCRA, your are sioro* enoougnged to otehin tarter vsdlicefian efthe parson's sb" by eoelacllag tat person's Sarvhoe vla the ' .ml" UM: iftJlwwwAdWW lrhlc.mlMacilplrlPC098t.W h%* M you have arklence to person wee on solive duty for the **A duty status daft and you tallto obtain this additional SeMce verMicaton, punii1 a provisions of to SCRA maybe Invoked agsiret you- See Std GSC App. § 52f (c). if you obtain addMonsf tnf r aeon about the person (e.g.. a SSN, First Name), you can submit your request again at tit Web alb and we wit provide a new ceritticale for that query This response ratecft the following Information: (1) The IdNkhuars Active Duty states on the Active Duty SN" Dele (2) Whadw to kv*AK at left AdMe Duty dd s within 367 days preosdlhg to Active Duty Slebus Dale (3) Whether the Individual or hfefier unit received early notlaton to repot for active duty on the Active Duty Shlue Dale. More, information on "Acfve Duty Status" Active duty etams as reported in this cadMcafe is delned in accordance wimp 10 USC § 101(d) (1). Prfo b 2010 onlysome of the salve duty periods less tian 30 coascumw days inieng% were nvailobb. in the case d a mnnba tithe [stational Guard, this includes service under a eel to active service autnotaed by to Preektent or the Som*wy of Dobme tndw 32 USC § 5020 for purposes d -11 it size wN Proeldent and auppOrlad by Pastoral [funds. Al Active Guard R sterve (AM) members mast be assigned aiii I l an autlarlaed mno11lraa1 poaW into unittrey support. This Includes Navy Training and MMniatamon d t e Reserves (TAR*), Marine Carps Ac M Reserve (ARM) and Coed Guard Reserve Program AdatnlWM or (RPAs? Acmes Duly status also apples to a Uniformed Service member who ban active duly co maissidod allow d the U.S. Pubk Fbamh Service or the National Oceanic and Atmospheric Administration (NGAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is boo Oder in acts cases and includes; some categories of patrbrr on aloe duty for purposes of the SCM who would not be reported soon Actor Duty under [iris cartlcxh. SCRA proacdon are for Time 10 and Thins 14 active duly records for al the Unikhrtrred SWAM periods. Throe 32 periods of Active Duty are not covered by SCRA, as detlned in accordance with 10 USC § 101(dxi ). Many times orders are amended lo extend the period of active duty, which would wM nd SCRA proleotbn. Persons seating lorsiy on tut webake ceeilkaMon should Check to crake sure the orders an which SCRA proteclions are based haw not been amended to extend the butualve dabs of service. Furthermore, some probdfone of ill SCRA may adend to persons who have reodved arlsea to report for acmes daily or to be Idutilad, but whw hive not actually begun adlye duty or acluamy reported far Induall m. The Lad Dab on Acmes Duty entry is important because a number of p rotsdio s of the SCRA Mond beyond the lad dales of active duty. Those who could rely on this came are urged to seek quaMbd legal coaxed to ensure that am rhghis guarambed to Service members under the SCRA are profxftd WARNt4G: This cwtlaae was provided based on a last name. SSN, and active duty status die provided by the requester. Providing erroneous kdormaton wit calms an erroneous eereksts fo be prankled. Report ID: TBOLAIMBB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. : CIVIL-LAW YO A. LE, DOCKET NO. 2012-1618 CIVIL Defendant CYJU 1LP'iCATIQN_QF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Unifund Corporation 10625 Techwoods Circle Cincinnati, OH 45242 Defendant: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 Respectfully submitted, Angela L. Mattis, Esquire Attorney for Plaintiff PA ID #309229 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIF UND CORPORATION, Plaintiff vs. YO A. LE, Defendant : CIVIL-LAW DOCKET NO. 2012-1618 CIVIL N4TiCE OF ENVY Of JUD AI ) Notice is hereby given that a in the above-captioned matter has been entered against you in the amount of $3,974.02 on Jv , 20 c? A copy of all documents filed with the Prothonotary in the withi'll judgment is/are enclosed. w Prothonotary Civil Div. By: If you have any questions regarding this Notice, please contact the filing party: NAME: Remit orjygr ion ADDRESS: 36 West Main Street B ,SPA 17815 TELEPHONE NO: 570-387-1873 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: NAME: Yo A. Le 903 Apple Drive Mechanicsburg, PA 17055 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 2012-1618 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION Plaintiff (s) From YO A. LE, 903 APPLE DRIVE, MECHANICSBURG, PA 17055 (I )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: MEMBERS 1sT FCU, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 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$3,974.02 Interest FROM 5/17/12 - $47.69 Atty's Comm Atty Paid $189.75 Plaintiff Paid Date: AUGUST 3, 2012 (Seal) L.L. $$.50 Due Prothy $2.25 Other Costs a k ? David D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name : ANGELA L. MATTIS, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 309229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND 0 ROTHONO COMMONWEALTH OF PENNSYLVANIA ., UNIFUND CORPORATION, Plaintiff vs. pp ?? o? YO A. LE, C107 Defendant vs. 2012 AUG -3 PH cUM ERLAND G PENNSYLVA CIVIL-LAW DOCKET NO. 2012-1618 MEMBERS 1 ST FCU, SOW LUJ Garnishee o PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, Pennsylvania (2) against Yo A. Le, defendant; and (3) Against Members 1 st FCU, Garnishee; (4) and index this Writ in the judgment index and (a) against Yo A. Le, defendant(s), and (b) against Members 1 st FCU, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: $ 3,974.02 Interest from 5/17/2012 $ 47.69 Other $ 0.00 Credits $ 0.00 Costs to be added: Clerks Fee: $ Sheriff. $ C ? Total: $ CL Dat d s da of 12012 Q ?er- I D Q?, "? 5 u « Ang a L. Mattis, PA ID #309229 so Attorney for Plaintiff a Sa%j 36 West Main Street S Q Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 a?8Fs9 0 ?rr?' r ??? I -13su AR 11 32 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. YO A. LE, vs. Defendant CIVIL-LAW AUG 0920 2 -? 3 N tT1 t?T'i __? t,- cnr _ MEMBERS I ST FCU, DOCKET NO. 2012-1618 Garnishee ?1't5weca ?o INTERROGATORIES TO GARNISHEE TO: Members 1 st FCU 5000 Louise Drive Mechanicsburg, PA 17055 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? 6 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? 00 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? No 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 1J0 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? No (. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? g6 7. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. , I N? 8. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. No 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as may be relevant to this attachment. *7gy,&7 in checL, accf. emirs amoud -:-m C U ;3.c-S -1' 11XI ejVo?r(j owg?koq, . COMPLETED BY: Sigqature - liAj C Titlel Iq rcU Interrogatories submitted to garnishee by: 4?)r Ang a L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 /?(A/ z 4, ?// Name (p nt) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~ttr of ~a+r+Gr,~~~j~~ ,,~;;? r. .1. . £s~F,cc ~,~ ..,. "4ERif=F r1 ~~: s KCI`i~~l~~~a 'w". , . y~C2At1G I3 PM ~~ 2C 'Ei~~dS`fLV~~I Unifund Corporation vs. Yo A. Le Case Number 2012-1618 SHERIFF'S RETURN OF SERVICE 08!08/2012 03:19 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 8, 2012 at 1522 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mon es of the within named defendant, to wit: Yo A. Le, in the hands, possession, or control of the within nam d garnishee, Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, Cumberland Coun , Pennsylvania 17050, by handing to Kelty Hall, Deposit Operation Analyst, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the Conte is there of known to her. The writ of execution and notice to defendant was mailed on 08-13-12 to Yo A. Le at 903 Apple Drive, Mechanicsburg, PA 17055. SO ANSWERS, August 13, 2012 R ANDERSON, SHERIFF iam Cline, Deputy ici Ccun!ySuita Sheri K; Tel=osoft, Inr, IN THE COURT OF COMMON PLEAS OF CUMBERLAND CQ . r' ~- ~ ~ - ~ ~ ~ ~ ~ COMMONWEALTH OF PENNSYLVANIA `~ ~~~~~~~ ~'~~ t UNIFUND CORPORATION, 2012 AUG ! 6 AM I 1 ~ 05 Plaintiff r~ tea°~m~ n un r , ~urv vs. YO A. LE, CIVIL-LAW DOCKET N0.2012-1618 Defendant vs. MEMBERS 1ST FCU, Garnishee PRAECIPE TO DISCONTINUE ATTACHMENT TO THE CLERK: Kindly discontinue the attachment of the Defendant's bank account(s) or other assets with Members 1 S` FCU. SUB1oiITTED BY: Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 an~~ ~9. so j G~~~~ ~~~~~ ^~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,ay RAnderson PII_EO-OFFICE ieriff OF THE PROTHONOTAF1 Jody s Smith Chief Deputy 2013 4AR 15 AN 9-. 54 Richard w Stewart CUMBALAND COUNTY Solicitor Of F ICE OF THE SHERIFF PENNSYLVANIA Unifund Corporation p Case Number vs. 2012-1618 Yo A. Le SHERIFF'S RETURN OF SERVICE 08/08/2012 03:19 PM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on August 8, 2012 at 1522 hours, attached as herein commanded all goods, chattels, rights, debts, credits,and monies of the within named defendant,to wit: Yo A. Le, in the hands, possession, or control of the within named garnishee, Members list Federal Credit Union, 5000 Louise Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Kelly Hall, Deposit Operation Analyst, personally three copies of interrogatories together with three true and attested copies of tie writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 08-13-12 to Yo A. Le at 903 Apple Drive, Mechanicsburg, PA 17055. 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: $82.28 SO ANSWERS, March 14, 2013 RON R ANDERSON, SHERIFF Ply 4 I (cj i-ountySuite Sheriff..Teleosoff Inc.