HomeMy WebLinkAbout13-5192 30160153 C A Pit SJS
Supreme C ,,,, o ��`` urt o �P ns��lvania w�vR #
CouA_ f Comm on�'
Clv'CoVer. Sheet
For P� oUeoiwrary Use Only
C UMBERLAND; County Docket No:
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The in
formation collected on this form is used solely for court administration pirfposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S 13 Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Q Declaration of Takin
C DISCOVER BANK
Lead Plaintiff's Name: Lead Defendant's Name:
T PAIGE TIPPET
I
0 Are money damages requested? (l Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? ❑ Yes 12 No Is this an MDJ Appeal? 13 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 Se] 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 J11 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 13 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
Cl Medical
❑ Other Professional:
Updated 1 /1/2011
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2013 SE1'
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P ENNSyLVAN UNT
IA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK / 9 � A/;
Plaintiff No: :S
l�
vs.
COMPLAINT IN CIVIL ACTION
PAIGE TIPPET
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
30160153 C A Pit SJS
wo, l3Sy
��agSl°Il�
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
PAIGE TIPPET
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249 -3166
COMPLAINT
1. Plaintiff, Discover Bank, is a banking institution organized under
the laws of the State of Delaware and maintains a business address of
12 Reads Way, New Castle, DE 19720.
2. DB Servicing Corporation is the servicing affiliate for Discover
Bank, f /k /a Greenwood Trust Company, an FDIC - insured Delaware State
bank. As the servicing affiliate, DB Servicing Corporation performs a
variety of services for Discover Bank including, business management
services in support of Discover Bank business lines, including, among
other things, credit cards, deposits, personal loans and student
loans, customer service, collections, credit risk, collection of
delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the account to the
attorneys and /or collection agencies for collection and to file suit
on Discover Bank's behalf.
3. At all times pertinent hereto, DB Servicing Corporation is the
servicing affiliate for Discover Bank, in reference to Defendant
account, which is the subject of this litigation.
4. Defendant is adult individual(s) residing at 48 REGENCY WOODS N
CARLISLE, PA 17.015
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX1600.
6. Defendant made use of said credit card and has a current balance
due of $1557.98. A copy of Plaintiff's STATEMENT is attached hereto,
marked as Exhibit "1".
7. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and /or refused to pay the balance due the Plaintiff.
WHEREFORE, Plaintiff prays for Judgment in its favor and against
Defendant, PAIGE TIPPET, INDIVIDUALLY, in the amount of $1557.98 with
interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
William T. MolczarV47437
WELTMAN, WEINBERG REIS CO., L.P.A.
436 Seventh Aven e, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30160153 C A Pit SJS
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
DISCO Discover More Card
Account number ending in 1600
Open Date: May 1, 2013- Close Date: May 22, 2013
Cardmember Since 2012
Page 1 of 4
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $1,557.98 New Balance $ 1 , 557.98
Payments and Credits — $0.00 Minimum Payment Due $1,557.98
Purchases + $0.00 Payment Due Date June 17, 2013
Balance Transfers + $0.00 s Includes past due amount of: $373.00
Cash Advances + $0.00
Fees Charged + $0.00 Late Payment Warning: If we do not receive your minimum payment by the
Interest Charged + $0.00 date listed above, you may have to pay a late fee of up to $35.00 and your
New Balance $1,557.98 purchase and balance transfer APRs for new transactions may be increased up to
the Penalty APR of 24.99% variable.
See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each
Transactions section for detailed APR information period, you will pay more in interest and it will take you longer to pay off your
Credit Line $0 balance. For example:
Credit Line Available $ 0IfJ�irioet�Y�d +iJthonc41c1Sprges Yati✓allpyoFFtha� Anc�ounllent�up
ustngl�tis d�r�'artd eoc(,�nonlh �' bsxlanag shown on 1{as }sayang on esitmat�c� tofiat �'
Cash Advance Credit Line $0 {yPc?Yr, atat6mebftn q}S�yf, o r ,�
VV
Cash Advance Credit Line Available $0 Onl the minimum a menl 4 years $1,558
You may be able to avoid interest on Purchases. If you would like information about credit counseling services, call 1-800-347-112 1.
See reverse for details.
REWARDS
Contact Us Discover.com Cashback Bonus® Anniversary Month
1- 800 - 347 -2683 August
Opening Balance $ 0.00
New Cashback Bonus This Period + $ 0.00
Redeemed This Period — S 0.00
Cashback Bonus Balance $ 0.00
To learn more, log in at Discover.com
Make Check payable to Discover. NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below, detach and return with your payment.
Mt 4y yh, Nt 4urstf 5, ^'"� 3 5K 5+ t3 pk SR
Account number ending in 1600
'lead Hoot kY1d d tsr stq fe l7t�tver Lorin t 1 `800 34 26$3'
,�_�, ��, „� ,;� �' �sv.��;�... „�...� .,�e-.a. �vry ,.+ :�,•> -.�k��
" Minimum Payment Due $1,557.98
nlli uillllllill'll�l�l���l'� I�Ilnll "I �III�I'I'�III'I�I New Balance $1,557.98
Payment Due Date June 17, 2013
PAIGE TIPPET
48 REGENCY WOODS N; Amount enclosed $
CARLISLE PA 17015 -9063
PO BOX 6103
CAROL STREAM IL 60197 -6103
.301 661 51 Internet payments must be received by 5 PM ET to be credited as of the some day.
Address, e-mail or telephone changed? Note changes on reverse side.
EXHIBIT
000001986458870268923015579800550730155798
PAIGE TIPPET Account number ending in 1600 Open Date: May 1, 2013 - Close Date: May 22, 2013 Page 2 of 4
Important Information You must ensure that sufficient funds are available in your bank account, and
all transactions must comply with U.S. law.
See your Cardmember Agreement. Your Cordmember Agreement
contains oil the terms of your Account. You con set automatic payments for: (i) statement New Balance, (ii) statement
Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed
Lost or stolen cards. Report immediatelyl Call 1- 800 - 347 -2683. dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar
What To Do If You Think You Find A Mistake On Your Statement amount" payment is not enough to cover the Minimum Payment Due as listed
If you think there is an error on your statement, write to us at: Discover, PO on your monthly billing statement, your scheduled payment for that month
Box 30421, Solt Lake City, UT 84130 -0421. You must write to us within 60 will be increased to cover the Minimum Payment Due. If the scheduled
days offer the error appeared on your statement. You may coil us, but if you payment is greater than the Minimum Payment Due, any excess will be
do we ore not required to investigate any potential errors, and you may have applied in accordance with your Cardmember Agreement. If your scheduled
to pay the amount in question. The Billing Rights Notice further explains your payment is greater than the New Balance on your billing statement, that
rights. Please see your Cardmember Agreement or visit payment will be processed only for the amount of your New Balance. Your
htips :Hdiscover.com/billingrights for a copy of this notice. automatic payment amount may be less than the amount indicated on the
billing statement based on credits or payments after the Close Date.
Payments. You may pay all or part of your Account bolancg at an time. If you enroll by phone in our automatic payment service, please fill -in the
However, you must pay of least the Minimum Payment Due by the Payment followin blanks below and retain the authorization for our records.
Due Date. Send only our payment and the bottom portion qt this statement 9 Y
in the envelope prow ed. D9 not send cash. If you p by 4heck, yo � Amount: Full Pa ❑Min Pa ❑Min Pa + $
authorize us to use in ormation on your check to make an .l �tronic fund Y Y Y
transfer tram yyour account at the financial institution indicated on your check 0 Other Amount$ Bank Routing #:
or to proce t he payment pps a check trp nsaction. If a payment is processed
as on electronic fund,transfer, the transfer will be for the amount of the Bank Account #
check. When we use information from your check to make an electronic fund
transfer, funds may be withdrawn from your account as soon as the some Monthly on the [I Payment Due Date 0 Close Date
day we receive your payment, and you will not receive your check back from
your financial institution. 0 Day of month (insert date)
The processing of your payment may be delayed if you send cash, Credit Reporting. We may report information about your Account to credit
correspondence or other items with your payment, if you send the payment to bureaus. Late payments, missed payments, or other defaults on your Account
any other address or if you use an envelope other than the one provided. may be reflected in your credit report. We normally report the status and
Payments received in proper form at our processing facility by 5PM local time pent history of your Account to credit reporting agencies each month_ If
on any day will be credited to your Account as of that day. Payments received you believe that our report is inaccurate or incomplete, please write us at the
at our processing facility after 5PM local time will be credited to your Account following address: Discover, PO Box 15316, Wilmington, DE 19850-5316.
as of the next day. If you have misplaced your envelope, send your payment Please include your name, address, home telephone number and Account
to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10 number.
days for delivery. If your payment is returned unpaid, we reserve the right to
resubmit it as an electronic debit. Payments made online or by phone will be Paying Interest. Your due date is at least 25 days after the close of each
credited as of the day of receipt if made by 5 PM Eastern time. billing period at least 23 dos for billin ( y g periods that begin in February). We
You con pay your monthly Minimum Payment Due, or a greater amount that will not charge you any interest on Purchases if you pay your entire balance
does not exceed your current Account balance, over the telephone or you can by the due date each month. We will begin charging interest on Cash
setup automatic payments through a customer service representative by Advances and Balance Transfers as of the later of the Transaction Date or the
calling 1- 800 - 347 -2683. Automatic payments for the billing period shown first day of the billing period in which the transaction posted to your Account.
on your statement will be deducted on the Payment Due Date shown on that How We Calculate Interest Charges. We Use the Daily Balance Method
statement, or the next automatic payment date referred to on your statement,
unless you request a recurring pa ment date (e.g., the 15'" day of the month) (including current transactions) to calculate the Balance Subject to Interest
that occurs before your Payment Due Date or Close Date. If your scheduled Rate. For more information, please call us at 1- 800 - 347 -2683.
payment dote falls on a weekend or bank holiday, your payment will be Balance Subject to Interest Rafe. Your statement shows o Balance Subject
processed the business day prior le the weekend will need this statement and bank holiday. In order to to Interest Rate. It shows this for each transaction category. The Balance
schedule monthly payments by telephone, you will
your bank account information. You will be asked to provide the lost four (4) Subject to Interest Rate is the average of the daily balances during the billing digits of the social security number of the primary borrower. By providing period.
those numbers as your electronic signature, you will be agreeing to this Credit Balances. If your Account has a credit balance, the amount is shown
authorization to allow us and your Bonk to deduct each payment you on the front of your billing statement. A credit balance is money that is owed
authorize, s the amount selected by you, from your bank account. You also to you. You may make charges against this amount if your Account is open.
authorize ,
to initiate debit or credit entries to your bank account, We will send you a refund of any remaining balance of $1.00 or more after
applicable, correct an error in the processing of such payment. You can 6 months, or as otherwise required by applicable low, or upon request made
cancel a scheduled payment by phone of LIT or moil of to the address in the Contact Us section on page 3 of your billing statement.
receive notice of least t three business days in advance of the schedul) ed d must
Discover, PO Box 30 Solt Lake City, 844130 -130 - 04421; 21; however Discover may monitor and /or record telephone calls between you and
rn
payment. If your payments may vary in amount, we will tell you on each Discover representatives for quality assurance purposes.
monthly billing statement when your payment will be made and how much it The Discover® card is issued by Discover Bank, Member FDIC. TL23N
will be.
CHANGE OF ADDRESS
If correct on front, do not use. Please print clearly in blue or black ink, in the space provided.
Street Address Home Phone
Work Phone
City Email
38'166153
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
DISCOVER Discover More Card
Account number ending in 1600
Open Date: May 1, 2013 - Close Date: May 22, 2013
Page 3of4
CONTACT US
0 Web ® Mobile O Phone ® Inquiry 0 Discover ayments
Access your account securely ■ accou anytime, (1-800-347-2683) P Box 30943 PO Box 6103
at Discover.com anywhere at TDD 1- 800 - 347 -7449 Salt Lake City Carol Stream
m.Discover.com LIT 84130 IL 60197 -6103
Transactions
Trans. Date Post Date
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2013 Totals Year -to -Date
TOTAL FEES CHARGED IN 2013 $ 140.00
TOTAL INTEREST CHARGED IN 2013 $ 104.10
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 22 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 19.99% V $0.00 $0.00
Cash Advances 24.99% V $0.00 $0.00
V= Vorioble Rote
Information For You
For more information about how interest charges ore calculated see your Cardmember Agreement or go to www .discover.com /inieresicharges
30160153
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
' PAIGE TIPPET Account number ending in 1600 Open Date: May 1, 2013 - Close Date: May 22, 2013 Page 4 of 4
30160153
A
VERIFICATION r �1
(Name) (Title)
of DB Servicing Corporation, servicing affiliate of Discover Bank does hereby verify, under penalty of
perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities
states, that he /she is a duly authorized representative of plaintiff herein. Additionally, he /she verifies that
Discover Bank, f /k/a Greenwood Trust Company, which is an FDIC - insured Delaware state bank, lacks
sufficient knowledge or information to verify this complaint. He /she verifies that he /she is authorized to
make this verification. As an employee of DB Servicing Corporation, he /she has sufficient knowledge
and information to make this verification, and consequently verifies that the facts set forth in the
foregoing complaint are true and correct to the best of his/her knowledge and information and that he /she
is personally familiar with the account and the relationship between Discover Bank and DB Servicing
Corporation.
It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the
Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for
Discover Bank, including business management services in support of Discover Bank business lines,
including, among other things, credit cards, deposits, personal loans and student loans, customer service,
collections, credit risk, collection of delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for
collection and to file suit'on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank
are wholly owned subsidiaries of Discover Financial Services.
Date
i na
DB Servicing Corporation servicing affiliate
For Discover Bank
PO Box 3025
New Albany, OH 43054
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff - r : IiiW '
Jody S Smith `
Chief Deputy 2 3 OCT " AM I: }
Richard W Stewart
` r, r. C
Solicitor U T i
. :. O�I M B E i L A r;
PENNSYLVANIA
Discover Bank
vs.
Case Number
Paige Tippet 2013-5192
SHERIFF'S RETURN OF SERVICE
09/17/2013 06:51 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Paige Tippet at 48 Regency Woods North, Middlesex, Carlisle, PA 1701
='4=Wrol 'UTSHALL, ! •.
SHERIFF COST: $34.78 SO ANSWERS,
September 20, 2013 RONR ANDERSON, SHERIFF
ci CCU^tr Suao h2rf'.Tc'eosoft 'nc.
t ter°f 'Fii;E
$:_ Tti P 1TNONOTARY
IN THE COURT OF COMMON PLEAS 1013 DEC 16 PM 3: 24
CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNTY
CIVIL DIVISION
PENNSYLVANIA
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5192 CIVIL
PAIGE TIPPET
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant PAIGE TIPPET above named, in
the default of an Answer, in the amount of $1557 . 98 computed as follows :
Amount claimed in Complaint $1557 . 98
Less payments / adjustments made $0 . 00
Attorney' s fees $0 . 00
TOTAL $1557 . 98
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: 1./
William T. Molczan 47437
30160153 C A Pit SJS
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 :
PAIGE TIPPET
48 REGENCY WOODS N
CARLISLE, PA 17015
atikt a
(y-14 11uoan
NO-fra aqq yg�
fl1aJ
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
Case No. 13-5192 CIVIL
vs.
PAIGE TIPPET
Defendant
IMPORTANT NOTICE
TO:
PAIGE TIPPET
48 REGENCY WOODS N
CARLISLE, PA 17015t-9063
Date of Notice: `' 1
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA.17013
(717)249-3166 •
WELTMAN,WEINBERG & REIS CO., L.P.A.
By:
Matthew Urban
P.A.I.D.#90963
WELTMAN,WEINBERG& REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412)434-7955
(412)338-7130
30160153 A PIT H4N
•
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5192 CIVIL
NON-MILITARY AFFIDAVIT
PAIGE TIPPET
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, PAIGE TIPPET 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:
PAIGE TIPPET
48 REGENCY WOODS N
CARLISLE, PA 17015
Affiant further states that the averments contained herein are true and
correct to the best of Affiant ' s knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C.S .A. Section
4904 relating to unsworn falsification to authorities .
AFFIANT
.. t�.m._sp.,sma.�.-..w...-r_F. -'.!l..rys.'S ,., .�.�`4.... 'tom•4 .a...- ..'1V:�v .. .At#'a2a,`4`. _. .. .a __ ,. <�, -v.,
• Results as of:Dec-05-2013 11:46:05
Department of Defense Manpower Data Center
SCRA 3.0
Status Report
Pursuant to Sery cemembers Civil Relief Act
•
Last Name: TIPPET
First Name: PAIGE
Middle Name:
Active Duty Status As Of: Dec-05-2013
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.
Yhadtlyr '
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: A63EVA00F059X20
*
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5192 CIVIL
PAIGE TIPPET
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the f flowing Order of Judgment
was entered against you on a�) 40111
(xx) Assumpsit Judgment in the amount of $1557 . 98 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
07).Prothonotary
By:
PROTHONOTAR ' DEPUTY)
PAIGE TIPPET
48 REGENCY WOODS N
CARLISLE, PA 17015
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