HomeMy WebLinkAbout13-5084 Supreme Cou>E t.o: Penns3'lvania wWx # 09862570 C A Pit ABR
Court of Common Pleas
:Civil Cover Sheet For Prothommy U-se Only:
s
CUMBERLAND County Docket No:
7.
The information collected on this fibrin is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by lain or rules of court.
Commencement of Action:
S 13 Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
C Lead Plaintiff's Name: Lead Defendant's Name:
T MIDLAND FUNDING LLC WAYNE MORRIS
I
O Are money damages requested? El Yes ❑ No Dollar Amount Requested: El within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? 13 Yes 13 No Is this an MDJ Appeal? E3 Yes W No
Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437
❑ Check here if you have no attorney (are a Self - Represented [Pro Sel 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
❑ Intentional ❑ Buyer Protection Administrative Agencies
• Malicious Prosecution Debt Collection: Credit Card ❑ Board of Assessment
• Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Statutory Appeal: Other
E
[3 Product Liability (does not include [3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
I ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - DES ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Toxic Tort — Implant ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Toxic Waste ❑ Ground Rent ❑ Mandamus
❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Retraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
NDNOTARY
2013 AUG 28 pH 2; U
CUMBERLAND C OUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff No:
vs.
COMPLAINT IN CIVIL ACTION
WAYNE MORRIS
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219 -1827
(412) 434 -7955
FAX: 412- 338 -7130
09862570 C A Pit ABR
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
VS. Civil Action No
WAYNE MORRIS
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
i
CIVIL ACTION
1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875
Aero Drive, Suite - 200, San Diego, CA 92123.
2. MCM+ records show that the Defendant(s) WAYNE MORRIS is/ are individual(s)
residing at 483.3 BRIAN RD, MECHANICSBURG, PA 17050.
3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a
credit agreement entered into between Defendant(s) and the original credit grantor.
4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was
assigned all the rights, title. and interest to Defendant§ CITIBANK (SOUTH DAKOTA), N.A.
account XKXKXXXXXXXX9084 (hereinafter "the account "), Midland Credit Management,
Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff.
5. MCM� records state that this action is based upon a credit agreement entered into
between defendant(s) and the original credit grantor. MM records further state that
. defendant(s) used or authorized the use of the credit account but failed to make the payments
due pursuant to the agreement.
6. MCM� records show -that the defendant(§) owed a balance of $1247.44 as of
20.12- 04 -16.
7. Attached Hereto are records regarding the account and/or payment(s) received.
WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff
and against Defendant(s) in the amount of $1247.44, togeth with interest and costs.
By
Weltman, Weinberg eis, Co., LPA
Attorney for Plainti
9862570 Page - 1
INN 1®1®0®1111®1
8543340874 AFFINDEBTMEDIA 09862570
Account Statement
send Notice of Mr4 Errors aid Cualcum service kv** as to
0 Customer Service: HOME DEPOT CREDIT SERVICES
myhomedepotaecount com PO BOX 869000, DALLAS TX 762663000
® Account Inquiries
1- 866 -458 -7683
.Malted payments must be received by 6:00 PM st the
Summa of Account AcNvf Payment lnformatlon address for payments by the payment dUe
Previous Balance $1,376.80 New Balance $1,447.44
Payments -$0.00 Minimum Payment Due $622.00
Other Credits 40.00 Payment Due Date January 04, 2011
Purchases +$0,00 Late Payment Wanting: It we do not recelve your minimum payment by the
Fees Charged +$35.00 data listed above, you may have to pay a late tee up to $35,00.
Interest Charged +$35:64, Minimum Payment Waming: It you make only the minimum payment each
New.Balance $1,447.44 period, you will pay more In Interest and it will take you longer to pay off your
Past Due Amount $536.00 balance, Forsxample:
�s
Credit Limit $0.00' -
Available-Credit $0.00 Only ft minimum payment 12 years $2,967
Statement Closing Date 12/08/2010 $61 3 years $2,212
Next Statement Closing Date 01107/2011 (Savlrlps -8745)
Days in Billing Cycle 31 It y ou would like blformelkrmabW cradil counsellIQ SWIM, cal 1-877 337-8168.
Your minimum payment due is $622.00. To avoid Interest charges, pay your V�Ie SAVE STAMPS, Register now for Paperless
revolving balance of $1,447.44, plus any promotions expiring this period, try 11,E $) TIME... Statements and. more at
January 4, 2011 (residual interest may apply). '@r AM TREES! rayhpmedepptaCcount.cmm
Z TRANSACTIONS
Z Trans Date Description Reference 0 Amount
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12104 LATE FEE $ 95.00
Z TOTAL FEES FOR THIS PERIOD $ 35.00
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NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account Is Issued by Citibank (South Dakota), N.A.
------------------------------------------------------------------------------------------------- ----- ----- -- --- ---- ---- -- - - --
't' Please detach this portion and return with your paymem to insure proper credit. Retain tipper portion Ioryour records. 't'
I Make Chucks Payable to: HOME DEPOT CREDIT SERVICES
S t Past Dee Amount is included in the Minimum Payment Due.
Payment Due Date New Balance Past Due Amountt I Minimum Payment Due Amount Enclosed
�.` January 4, 2011 $1,447.44 $696.00 $622.00 $
r Register to receive a year -end Summary of tax eligib purchases' at homedepot.com/taxcreft.f
But hurryl Tax Credit ends Dwmber 31, 2010.
KBAVHD 2 1216x10 OA
HOME DEPOT CREDIT SERVICES
OD
III�II. IIIt�tlll�llll�+ Itt. Irtl�l�llll�ll '�Ill�llttt�ll _III PROCESSING CENTER
N WAYNE MORRIS DES MOINES, IA 50364.05M
4833 BRIAN RD Ihu�p�t�tll�Illlllpl�h��I�II�II 'I�IIItIlllul���ullnllt�.��
MECHANICSBURG, PA 17050.3014
Print address changes above in blue or black Ink.
Infonnat tan About Your Account I]
How to Avoid Paying Interest on'Purcheses.Your payment due date Wut'o go it You Think You Find a Mistalm on Your�temsnt
is at toast 25 days after the close of each billing cycle. We will not If you think there is an error on your statement, writs to us at the
charge you any Interest on purchases If you pay your New Balance by Customer Service address shown on the front.
the payment due date each month..This is called a grace period on In you Matter,give.us the following Information:
purchases. If you do not.pay the New Balance ih full by the payment • 8ocaunt Your name and account mrmbae
due date,you will not get a grace period an purchases until you pay • Dollar amwrrC The dollar amount of the suspected error.
the Now Balance In full for two billing cycles in a.row. . M you think there is an•error on your bill.
If you have a balance subject-to•a deferred interest,0%APR or Equal' de�ri a at you elie is wrong and:why you oelim R•le a mistake.
Payment Pion promotion and that promotion expires before the You must contact us Wlthln 60 days after the error appeared on your
payment due date,that balance(the'excluded promotional balance") statement.You must notify us of any potential errors in wMino.You may
is excluded from the amount you must pay frrfull to get a grace period. call us,but If you do we are not required 10 Investigate any potential
However, you must still pay any'seperately required payment on the errors and you may have to pay,theamount in-question.
excluded promotional balance.In billing cycles in which payments.are While we investigate whether or not there has been an error, the
allocated to deferred Interest balances first. the deferred Interest following are true:
balance will be reduced before any other balance on the account. • We cannot try to collect the amount in question, or report you as
However,you will continue to get a.grace period on purchases so long delinquent on that amount•
as you pay the New Balance lass any excluded pmmotlonal balances ° The charge in question may remain on your statement,and we may..
in full by the payment due date each billing cycle. We may refer to cominue.todwrge you interest.on that amount Bul.it we detemrine'that
deferred interest promotions as No Interest remotions. we hoe a mistake.you will not have to pay the amount-In question or
p any interest or other fees-related to that amount.
In addition.certain promotlon9t offers may takeaway the grace period •While you do not have to pay the amount In question, you are
responsible for-the remainder purchases.Other promotional offers not described above may also malnder of your balance,
allow you to have a grace period on purchases without having to pay We'ean apply any unpald arraum-against your credit ItrMt.
all or a portion of the promotlonal.balance by the payment due date.If Your RIgMe U You Are Dissetlsfled With Your Credit Card Purchases
either is the case,the promotional offer will describe what happens, If you are dissatisfied with the goods or services that you have
purchased with your credit card, and you have tried in good Talth to
Now We Calculate Your Balance Sub)edt to Interest ReW.For each correct the problem with1 he merchant,you may have the right notto pay
ba!afte,the letter following the Annual Percentage Rate In the Interest the:remalning amount due on the purchase.
Charge Calculation section on the front of the statement indicates the To use this right,all of the following must be true:
method we use to calculate interest charges.For Methods C.H and M, 1.The purchase must have been made in your home•state or within 100
we use a dally balance method(including current transactions) to miles of your current mailing address,and the purchase.price must
calculate interest charges. For Methods i end,L,we use an average have been more than$50.(Note:Neither of these are necessary If
daily balance method (Including current transactions) to calculate your purchase was based on an advertisement wo%mailed to you,.or
interest charges. For Method K, we use an average daily balance if we oven the company that sold you the goods or servloes.)
method(excluding current transactions)to calculate Interest charges. 2.You must have used your-credit card.for the purchase. Purchases
To find out more Information about the balance computation method made with cash advances from an.ATM or with a check that accesses
that applies to your account and how the resulting interest charges /Your credit card account do not.quality.
were determined,contact us of the Customer Service number shown 3.You must not yet have fully paid for the,purchose.
on the front. If all of the criteria above are met and you are stilt diesatisfied with the
Credit Reporting Disputes. It you think we reported inaccurate purchase,contact us in vAlfing at.the•Customer Ssrvlce address shown
Information to a credit bureau write us at the Customer Service address on the frorit.
shown on the front While we investigate,the same rules apply to the disputed amount as
discussed above.After we finish our investigation.we will tell you our
Reporta Last or Stolen Card Immediately.Call the Customer Service decision,At that point,'it wa think you owe.an amount and you do not pay
number shown on the front. we may report you as delinquent.
KEY CREDIT TERNS-NO INTEREST IF PAiD IN FULL WITHIN B MoNTNB'.$298 Minimum Purchase Reeqquuired.Mlaimum.Paymente Required.
Interest will be charged to your account from the purchase date N the purchase balance(Includi g.premlume for optional credh insurance)Is
not paid In full within 6 months;or It you.make a late payment
'With credR•approval for gqUsti in9 purchases made on The Horne Depot or EXPO Design Center Consumer'Credit.Card,17,.99%-26:89%APR.
Minimum INTEREST CHARG :t .See card-agreement for details including.APR applicable to you.Offer Is only valid for consumer accounts
and Is subject to change without notice.
tmportent Payment Instructions. Payment Options Other Than Regular lllail.
Cradiiing t'aymsrds.if we receive your rrreiied paymert in proper torm.atair *Online Paytmnts.Visit myhom� awrt.com and sign up tor.free
processing f8clltyr by 5 p m.local tune there,it wig 4eaedited as of that d*A online payments,Erndimenl may take a few days.if we receive your request to
payment recelved4 form after that time will be credited as of-the makeAn online payer by 5 m,Eastern time,we w9•credit your payment as
next day..Allow 5 to T days ror is by regular mail to reach.us.There may ofthat4ay acrd Itf col I post wNhh three business days 11 we reoelve y J r request
ba a delay at up to 6 days in cred �g a we receive that is not in proper to make an onllne�ppaayment after that it me we wII1 credit yourp, as at the
form or iii not sera to the correct edt�eas dcorreat address for tar rrtai next day and it will post within three bunt days For secu rea8pn9,you
is iho address drr file r1oM.of the�ayment coupon.Allayment mado bh-store is may be unable to pay your enllre.Naw Balance with yew first ne paymerri.
not sent to!h6 correct address.ire correct address for courier or onxess nisi •Pay by Phone S wide. You may use this service any time to rreke a
ls•tfhe Express Payments Address shown below, payment by.Vm� if.yohn acoouni fe:eligible.You will-be charged$14.96 to use
P Form Fora paymerht sent by Mall or cants'b be In proper lam,you musk p. taste. ti representative o have your of ours helps�orpe�its your payment Coil by 5
Proper p.m.Eastern time to have ychx payment credited ev of that day and posted
• lir dose s valid check or money order made payable to Home DWI within tisee business If you call altar that lime,your psymerg will be
Credit Services.Pro cash,slit cards.or foreign cu plase. credited as of the nod end meted within nee buakreaa days.We may
• Mdude•your name and account number on the rrionl of your check or ply�u psi r renicelly after we veWy your Identity.
massy order.. •Express Pa msnts,You can Bond payment by cr2urler or rQsa m to the
If you send an eligible duck with tale cys t coupon, authorttte.us E Payr�iergs Adorers. This address is: tome► sr,
!o 61:rleto cur pay by efactronrc debit If we the choWng A :Payment Mail Opening, 1500 BoWrflald St.,Columbus,CH.
eacourrt wN cur amount an the check We may do this as payment must to racerved in ppraper form at-the proper address by 5 p.m
soon as the day ire rem the checL Also,Un check trip u destroyed. Pacific time to be credited as.Aftt day:All received in proper farm
Cop yy Fee.We.chargo.SEi for each cc�o�ppyy of.s btrmg etaterrhent thew dates back 3 at the proper address attar that Ornowlll be cre of the next day
morhths or roue.We add the fee.to.a balerhee of our chooaing.We reserve.the right Th Stare Dd*4 ts.For Yyaamadded converPaOTji,payments can store or
to add this fee to balances subject a�phar annual rate.VVe waive The Horne Depose g ties with no service foe: our o oo mach o the staa prior
the fee.if r request far the b � � e the store closing bj a will be posted to xis.account as of that day but
you re9 spy relates ablfing error or disputed purchase. hbreilabi6ty may be subject to verKrcctlon aA funds.
HD1EX DEMO
X E 1(/01/0795 113.0 H17P-02Rar10 E P 7 8 8188 0400 0002
Page 2 of 4
Account: '«"*'"* *'*'9084
Page 4 of 4
Account: •"•""""" ••`"9084
TRANSACTIONS(cont.)
Trans Date Descrlptlon Reference 11 Amount
INTEREST CHARGED
12M Interest Charge on Purchases $ 35.64
TOTAL INTEREST FOR THIS PERIOD 111 35.84
Total Fees Charged in 2010 $442.00
Total Interest Charged in 2010 $351.98
INTEREST CHARGE CALCULATION Your.Annuat Percents 10.Rate(APR)to the annual Interest rate on your account.
PURCHASES
Revolving Balance 29.99% IM Sf 399.55 $35.84
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Page 3 of 4
Verification
Paula Fruth,being duly sworn(or affirmed)according to law deposes and says that
I am employed as a Legal Specialist for Midland Credit Management,Inc. ("MCM"),
servicer of this account on behalf of plaintiff. I am a competent person over eighteen
years of age,and make these statements herein based upon personal knowledge of
those account records maintained on plaintiffs behalf. I am authorized to make this-verification
on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct.
The undersigned understands that the statements therein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
JUN 18 2013
Date 1
Paula Fruth Y
OH 14
Weltman,Weinberg&Reis. Co.,LTA
Page-.2
854334Q874 AFFMEBTMEDIA 09962570
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
��"ILL�I-OFD ICE
Sheriff li;I- .f, E PR0TH0N i Tip IR
�ai�ai�r+lre���pxFC
Jody S Smith r
Chief Deputy :Y 2013 SEP —9 AM 10: 06
Richard W Stewart CUMBERLAND COUNTY
Solicitor 0MCE FTHESYERIFr PENNSYLVANIA
Midland Funding LLC
Case Number
vs.
Wayne Morris 2013-5084
SHERIFF'S RETURN OF SERVICE
08/30/2013 11:14 AM- Deputy Noah Cline, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Maria Morris-mother, who
accepted as"Adult Person in Charge"for Wayne Morris at 4833 Brian Road, Hampden Township,
Mechanicsburg, PA 17050.
i
NOAH CLINE, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS, j
September 04, 2013 RbNW R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Te!eosoff,Inc.
2L113 OCT 21 PH 3: 52
CUMOERI_AND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff No: 13 5084 CIVIL
vs .
PRAECIPE FOR DEFAULT JUDGMENT
WAYNE MORRIS
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, 47437
WELTMAN, WEINBERG & REIS CO. , L. P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219-1827
(412) 434-7955
FAX: 412-338-7130
09862570 C A Pit DKB
Judgment Amount $1247 .44
a I tv.sa
CI1 '3J ? 2
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No. 13 5084 CIVIL
WAYNE MORRIS
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant WAYNE MORRIS above named, in
the default of an Answer, in the amount of $1247 . 44 computed as follows :
Amount claimed in Complaint $1247 . 44
Less payments / adjustments made $0 . 00
Attorney' s fees $0 . 00
TOTAL $1247 .44
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. Molcza , 47437
09862570 C A Pi DKB
Plaintiff ' s address is :
c/o WELTMAN, WEINBERG & REIS CO. , L. P.A. ,
436 7th Ave Ste 1400 Pittsburgh PA 15219-1827
And that the last known address of the Defendant is :
WAYNE MORRIS
4833 BRIAN RD
MECHANICSBURG, PA 17050
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No. 13 5084 CIVIL
NON-MILITARY AFFIDAVIT
WAYNE MORRIS
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, WAYNE MORRIS 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 :
WAYNE MORRIS
4833 BRIAN RD
MECHANICSBURG, PA 17050
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 .
i/n
AFFIANT
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
Case No. 13 5084 CIVIL
vs.
WAYNE MORRIS
Defendant
IMPORTANT NOTICE
TO:
WAYNE MORRIS
4833 BRIAN RD
MECHANICSBURG, PA 17050 i2
Date of Notice: 912(Q 13
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: 4.1/14#7---
1v�
William T. Molczan
P.A.I.D.#47437
WELTMAN,WEINBERG liEIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412)434-7955
(412)338-7130
9862570 A PIT A4S
Results as of:Oct-11-2013 08:18:28
Department of Defense Manpower Data Center
SCRA 3.0
State Report
.E Pursuant to Servicem.embers Civil Relief Act
Last Name: MORRIS
First Name: WAYNE
Middle Name:
Active Duty Status As Of: Oct-11-2013
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 Notified 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 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.
AirtAy, F
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.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: 35M9J8F0P0B1 K30
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No . 13 5084 CIVIL
WAYNE MORRIS
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the foil wing Order of Judgment
was entered against you on 1019•1 1.3
(xx) Assumpsit Judgment in the amount of $1247 . 44 plus costs .
( ) Trespass Judgment in the amount of $ plus costs .
( ) If not satisfied within sixty (60) days, your motor vehicle
operator' s license and/or registration will be suspended
by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration Award
tot
Prothonotary elk
By:PROTHONOTARY (OR DEPUTY)
WAYNE MORRIS
4833 BRIAN RD
MECHANICSBURG, PA 17050
Plaintiff ' s address is:
c/o WELTMAN, WEINBERG & REIS CO. , L. P.A. ,
436 7th Ave Ste 1400
Pittsburgh PA 15219-1827
(412) 434-7955
WELTMAN, WEINBERG & REIS,CO., L.P.A.
BY: William T. Molczan,47437
I.D. No. 47437
436 7th Ave Ste 2500
Pittsburgh PA 15219-1842
(412) 434-7955
FAX: 412-338-7130
File # 09862570 C A Pit SJS
Attorney for Plaintiff(s)
MIDLAND FUNDING LLC
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
vs.
WAYNE MORRIS
C)
CASE NO. 13 5084 CIVIL
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PRAECIPE TO SATISFY 1>c)
TO THE PROTHONTARY:
Kindly mark the case and judgment entered against Defendant WAYNE
MORRIS as satisfied.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
William T. MLlczan
Attorney for Plai iff
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