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HomeMy WebLinkAbout13-4123 Supreme Coidd f-Pennsylvania COUr dff(COi rno A�Tleas For Prothonotary Use Only: I' Civil / r S &t Docket No: county � JCG�n� are The infirrnratiorr collected on this f()rnt is used solely f)r corn"t administration Trurposes. This fn - 111 does not supplement or replace the, filing and service of pleadings or other 1)apers as required by laiv or miles of court. Commencement of Action: S h] Complaint 0 Writ of Summons El Petition E Transfer from Another Jurisdiction ®i Declaration of Taking C Lead Plaintiff's Name: Lcad Defendant's Narne: , REMIT CORPORATION, ASSIGNEE OF UNIFUND CCR, LLC CORRIE E. SARACINA Are money damages requested? Yes No Dollar Amount Requested: [9 within arbitration limits T O ( check one ) 0outside arbitration limits N Is this a Class Action Suit? M Yes GO No Is this an MDJ Appeal? 0 Yes [i] No A Name of Plaintiff /Appellant's Attorney: RAYMOND W. KESSLER, ESQUIRE 0 Check here if you have no attorney (are a Self - Represented [Pro Sej Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS F1 intentional ® Buyer Plaintiff Administrative Agencies El Malicious Prosecution ® Debt Collection: Credit Card rl Board of Assessment [] Motor Vehicle 0 Debt Collection: Other Board of Elections n Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other S Product Liability (does not include E mass tort) 0 Employment Dispute: Slander/Libel/ Defamation Discrimination C 0 Other: IQ Employment Dispute: Other Zoning Board T 0 Other: I Q Other: O MASS TORT 0 Asbestos N 0 Tobacco Q Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Q Toxic Waste El Ejectment r_1 Common Law /Statutory Arbitration B (] Other: El Eminent Domain /Condemnation r] .Declaratory Judgment 0 Ground Rent Mandamus Landlord/Tenant Dispute Non- Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY El Mortgage Foreclosure: Commercial Quo Warranto I®. Dental rl Partition 0 Replevin Legal rl Quiet Title 0 Other: Medical 0 Other: Other Professional: U])dated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff c `c w- a� , VS. CIVIL -LAW CD CORRIE E. SARACINA, ; DOCKET NO. 1 �° < (�' -' CD Defendant 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 kAYM46f4D W. KESSLER, ESQUIRE 63 `1 S pA, a I a33 Q4f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff : VS. CIVIL -LAW CORRIE E. SARACINA, DOCKET NO. Defendant COMPLAINT The Plaintiff, Remit Corporation, by and through its attorney Raymond W. Kessler, Esquire, hereby files this Complaint of which the following is a statement: 1. The Plaintiff, The Remit Corporation is a Pennsylvania Corporation doing business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania 17815 and is the assignee of Unifund CCR, LLC. A Copy of the document assigning all relevant rights with reference to the present action to the Remit Corporation are attached hereto, incorporated herein and referred to hereafter as Exhibit A. 2. The Defendant, Corrie E. Saracina, is an adult individual residing at 15 Church Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. Defendant obtained a Visa credit card on or about October 1, 2004, from First National Bank of Omaha, (hereinafter "original creditor "), Account number 4412 9701 2440 8814. 4. Unifund CCR, LLC 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. 5. Pilot Receivables Management, LLC purchased the account of the Defendant from First National Bank of Omaha. 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. 6. Defendant used the extended credit leaving an unpaid balance of $970.88 with interest continuing to accrue at 6.00% per annum. 7. Defendant defaulted on the payments due and the last payment on this account was on or about July 27, 2010. 8. The balance on the charge -off is $970.88 and post- charge off interest has accrued in the amount of $134.70 to date for a total remaining balance due of $1,105.58. 9. 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. 10. 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. 11. It is averred that an implied contract exists based upon Defendant's use of the credit card and his/her payments made on the account to the original creditor. 12. Defendant's failure to pay is a breach of the implied contract between the Defendant and original creditor. 13. 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. 14. 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. 15. The total reasonable value of the Defendant's use of the credit extended by original creditor is $1,105.58. 16. 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. 17. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 18. By virtue of Plaintiff's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $1,105.58. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $1,105.58, together with interest, costs, and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, Raymond W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570- 387 -1873 Fax: 570 -387 -6474 ASSIGNMENT OF CLAIM PURSUANT TO PENNSYLVANIA ACT 219 OF 1990 For value received, the undersigned: Unifund CCR, LLC assigns to: The Remit Corporation doing business at: 36 W Main Street PO Box 7 Bloomsburg, PA 17815 a debt due to the undersigned from: Corrie E. Saracina 4412970124408814 #800037 for the sum of $1,105.58 arising from unpaid credit card services with interest accruing at 6.00% per annum. The said sum is justly due to the undersigned without offset or defense. The undersigned neither transfers to The Remit Corporation, nor expects The Remit Corporation to assume, any obligation or any liability of the assignor to the said debt. The undersigned has done nothing and will do nothing to discharge the debt or hinder its collection and hereby grants to The Remit Corporation the full power and authority, to bill and collect the aforesaid claim, in accordance with Pennsylvania Act 219 of 1990, Section 2, as it amends Title 18 regarding Section 7311, including to sue for, (in its own name, through a licensed attorney) and discharge the assigned debt. The Remit Corporation specifically agrees to comply with the Pennsylvania Act of December 17, 1968, P.L. 1224, No. 387 (known as the Unfair Trade Practices and Consumer Protection Law), and with the regulations promulgated under that Act pursuant to this assignment. Dated this k-0 day of May, 2013. Chris Blanton Unifund CCR, LLC EXHIBIT ASSIGNMENT THIS ASSIGNMENT is effective as of January 1, 2013 between PILOT RECEIVABLES MANAGEMENT, LLC an Ohio limited liability company ( "Assignor ") and UNIFUND CCR, LLC, an Ohio limited liability company ( "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 infonnation, and applicability of any statute of limitations), except as stated in the Agreement or herein. PILOT RECEIVABLES MANAGEMENT, LLC B �l Morga J m th Vice P ide of e ation UNIFUND CCR, LLC By. iA A tumn Hopkin Manager of Lega perations EXHIBIT BILL, OF SALE FIRST NATIONAL BANK OMAHA, (the "Seller"), has entered into a Purchase and Sale Agreement with Pilot Receivables Management, LLC (the "Buyer") dated July 30, 2012 (the "Purchase and Sale Agreement") for the sale of certain Accounts and related Receivables described in the Purchase and Sale Agreement, upon the terms and conditions set forth in the Purchase and Sale Agreement. NOW, THEREFORE, for good and valuable consideration, subject to the terms of the Agreement, Seiler hereby setls, assigns, and transfers to Buyer, its successor and assigns, all of the Seller's right, title and interest in each and every one of the Accounts and related Receivables identified in the Receivables Data File. Buyer and Seller agree that the Purchase Price for such Receivables shall be stated in the Closing Statement attached to the Agreement, In witness thereof, Seller has assigned and delivered this instrument on this 30th day of July, 2012. First Nat' nal Bank of Omaha By: III Name: A 7C) tit �V � Title: Vice President, Finance Date: `� 3u- t — First National Bank of Omaha B y . Naive: • l n•y Title: �► � Date: t EXHIBIT 9 VERIFICATION The undersigned verifies that the statements made in the foregoing Complaint are true and correct based to the best of his/her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Dwayne Heisler Vice - President, Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL -LAW CORRIE E. SARACINA, 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 ) 5 day of TV[ L 12013 Raymo d W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570 -387 -1873 Fax: 570- 387 -6474 Results as of: Jul-08 -2013 12:48:47 Department of Defense Manpower Data Center SCRA 3.0 a = � Status Report 4 Pursuant to Servicemernbers Civil Relief Act, Last Name: SARACINA First Name: CORRIE Middle Name: Active Duty Status As Of: Jul -08 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - NA - No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His /Her Unit Was Noted of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or hislher unit has received early notification to report for active duty Upon searching the data 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 active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, 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. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. a - 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 active duty status date, 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 active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. 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 /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 13X7UD2AB022RC0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff Vs. CIVIL -LAW CORRIE E. SARACINA, DOCKET NO. Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Corrie E. Saracina 15 Church Road Carlisle, PA 17015 Respectfully submitted, Raymond W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 ' Fax: 570- 387 -6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR LLC Plaintiff F r A .4-,-- 3 VS. CIVIL -LAW CORRIE E. SARACINA, :DOCKET NO. , 3.��I 3 Cv,� c ;- °F { � Defendant r ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, RAYM D W. KESSLER, ESQUIRE Attorney ID 309802 36 W Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570 -387 -6474 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -jl" _ -} `.$ Sheriff Jody S Smith Chief Deputy :fir 20 13 JUL 26 AN 10: 30 Richard W Stewart Solicitor , o: ., :r, I Ott B B L N D O O GN T Y PENNSYLVANIA Remit Corporation Case Number. vs. Corrie E. Saracina 2013-4123 SHERIFF'S RETURN OF SERVICE 07/19/2013 05:44 PM-Deputy William Cline, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Minka Saracina, Mother,who accepted as"Adult Person in Charge"for Corrie E. Saracina at 15 Church Road, Penn Township, Carlisle, PA 17015. LIAM CLINE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, July 24,2013 RONW R ANDERSON, SHERIFF (c)Count ySuite Sheriff,7eieosoft,Inc, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA c Mco REMIT CORPORATION, �rn Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL-LAW F � r' aG rrx CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES FAILURE TO FILE ANSWER TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $ 1,105.58 Court Costs $ 138.53 Default Judgment $ 16.50 Interest from July 16, 2013 $ 7.63 Total: $ 1,268.24 Kindly assess damages against Defendant in the sum of$1,268.24 plus continuing interest at the statutory rate of 6%. BY: ` RaynYond W. Kessler, Esquire rib tj LL- C - �� ags�s'1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant CERTIFICATION OF TEN (10) DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, RAYMOND W. KESSLER, ESQUIRE, hereby swear and certify that a copy of the Ten (10) Day Notice was served on Defendant by regular mail on August 14, 2013. BY: RayKond W. Kessler, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant TO: Corrie E. Saracina DATE OF NOTICE: August 14, 2013 15 Church Road Carlisle, PA 17015 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 Prothonotary of Susquehanna County 100 South Street, PO Box 186 P.O. Box 218 Harrisburg, PA 17108 Montrose, PA 18801 800-692-7375 570-278-4600 ext. 321 717-238-6807 Mailed to: Corrie E. Saracina Raymond W. Kessler, Esquire 15 Church Road 570-387-1873 Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant TO: Corrie E. Saracina 15 Church Road Carlisle, PA 17015 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 c3w Judgment on Award on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: RAYMOND W. KESSLER, ESQUIRE AT THIS TELEPHONE NUMBER: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CHESTER COUNTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 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 21'\day of A vy 2013 RaymoddW. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 ;d7:50 Department of Defense Manpower Data Center Results as of:Aug-27-2013 07 SCRA 3.0 �t . Statim Report Pursuant to Service-members Civil.Relief dot. Last Name: SARACINA First Name: CORRIE Middle Name: Active Duty Status As Of: Aug-27-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuats7 active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA NO NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Sarvioe Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data 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 active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. OhAwk jrq 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 active duty status date,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:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. 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/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 94EEH6E4F012D50 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es)of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Corrie E. Saracina 15 Church Road Carlisle, PA 17015 Respectfully submitted, Raymo d W. Kessler, Esquire PA ID #309802 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 REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL-LAW CORRIE E. SARACINA, DOCKET NO. 13-4123 Defendant NOTICE OF ENTRY OF JUDGMENT Notice is hereby given that a W A rhex�� in the above-captioned matter has been entered against you in the amount of$1,268.24 on 20 A copy of all documents filed with the ProthonWary in support of the with.-in judgment is/are enclosed. Prothonotary Civil Div. By: If you have any questions regarding this Notice,please contact the filing party: NAME: Raymond W. Kessler, Esquire ADDRESS: 36 West Main Street Bloomsburg, PA 17815 TELEPHONE NO: 570-387-1873 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: NAME: Corrie E. Saracina 15 Church Road Carlisle, PA 17015