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HomeMy WebLinkAbout13-5281 Supreme Cou - 66IF F - Pennsylvania COUrA �- For Prothonotary Use Orr1J7: CIVi1 �+> b6- Sh } eet :., Docket No: Q , t , County 1 The information collected on this form is used solely court udministratlon purposes. .This fior•m does not supplement or replace the and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S [9 Complaint 0 Writ of Summons [� Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: L cad'Defendant's Name: T REMIT CORPORATION, ASSIGNEE OF UNIFUND CCR, LLC JONATHAN C. FORD Dollar Amount Requested: within arbitration limits I Are money damages requested? M Yes 0 No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? Yes (E No A Name of Plaintiff /Appellant Attorney: RAY W. KESSLER, ESQUIRE Q Chech 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 daitn, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional El Buyer Plaintiff Administrative Agencies E] Malicious Prosecution © Debt Collection: Credit Card E] Board of Assessment Motor Vehicle Q Debt Collection: Other Q Board of Elections n Nuisance _ Dept. of Transportation Premises Liability Statutory Appeal: Other S E] Product Liability (does not include E mass tort) E] Employment Dispute: El Slander/Libel/ Defamation Discrimination C El Other: M Employment Dispute: Other El Zoning Board � Other: , I lQQ Other: O MASS TORT _ F1 Asbestos N 0 Tobacco Q Toxic Tort - DES E] Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS [' Toxic Waste Other: 0 Ejectment Q Common Law /Statutory Arbitration B D Eminent Domain /Condemnation E] Declaratory Judgment El Ground Rent E] Mandamus 0 Landlord /Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ] Mortgage Foreclosure: Commercial Q Quo Warranto El Dental 0 Partition Replevin Legal ® Quiet Title Other: .Medical 0 Other: rj Other Professional: Updated 1/112011 IN THE:COURT OF COMMON PLEAS OF CUMBERLAND:COUNTT` `7Y COMMONWEALTH OF PENNSYLVANIA ,;-?„1 f%0, '''e d I REMIT CORPORATION, � U;�'tr LI P. Assignee of Unifund CCR, LLC, t) -S �r'(� Plaintiff � `,;�S YL. k/4 j/i'l " vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL 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 $ 6,371.45 Court Costs $ 222.40 Default Judgment $ 16.50 Interest from Sept. 9, 2013 $ 280.69 Total: $ 6,891.04 Kindly assess damages against Defendant in the sum of $6,891.04 plus continuing interest at the statutory rate of 6%. BY: Ra rnd W. Kessler, Esquire �Ib.SD� GZn'r? � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL 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 May 28, 2014. BY: Ra nd 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 JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant TO: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 DATE OF NOTICE: May 28, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 717-238-6807 Raym.' W. Kessler, Esquire 570-387-1873 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Mailed to: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant TO: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Award on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: :RAYMOND W. KESSLER, ESQUIRE AT THIS TELEPHONE NUMBER: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL 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 t C1 day of TUh % , 2014 Raym d W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 Department of Defense Manpower Data Center Results as of : Jun -04-2014 01:42:59 PM SCRA 3.0 StatusReport Pursuant to Servicc :embers. Civil. Relief Ad Last Name: FORD First Name: JONATHAN Middle Name: C Active Duty Status As Of: Jun -04-2014 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 Das 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/tier 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 0910,1`-‘ 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: EAC4JC25S01 BS20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL 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: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 Respectfully submitted, Ra '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 JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant CERTIFICATE OF SERVICE I declare that on �C b, 2 I 70 (L( I, Raymond W. Kessler, placed a true and correct copy of the Plaintiff's Reinstated Complaint, filed in the above referenced matter, in the US mail, FIRST CLASS mail and Certified mail, postage prepaid to the following addresses: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 The Certified mail was returned marked "unclaimed"; the First Class mail was not returned to my office. The Sheriff also posted a copy of the Civil Complaint at the defendant's residence of 210 W. Main Street, Mechanicsburg, PA 17055. Respectfully submitted, Raymon. 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 vs. JONATHAN C. FORD, Defendant : CIVIL -LAW : DOCKET NO. 13 -5281 -CIVIL NOTICE OF ENTRY OF JUDGMENT ( ) Notice is hereby given that a � _rVierrt ( in the above -captioned matter has been entered against you in the amount of $6,891.04 on Noe, ,20 '� ) A copy of all documents filed with the Proth judgment ;is/are enclosed. 1 If you have any questions regarding this Notice, please contact the filing party: NAME: Raymond W. Kessler, Esquire otary in support of the within Prothonotary Civil Div. By: 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: Jonathan C. Ford 21Q W. Main Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA c:) REMIT CORPORATION, , C__ Assignee of Unifund CCR, LLC, Mr" r-n � Plaintiff, �`" ° c� r =-*, VS. :CIVIL -LAW JONATHAN C. FORD, DOCKET NO. Defendant' r ' 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 RAY ND W. KESSLER, ESQUIRE s a 4 , - P" , eL# Aga ,OfagSHort\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL -LAW JONATHAN C. FORD, 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, Jonathan C. Ford, is an adult individual residing at 210 W. Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant obtained a Citibank MasterCard credit card on or about March 8, 2007, from Citibank (South Dakota) National Association, (hereinafter "original creditor "), Account number 5424 1805 8043 2240. 4. Unifund CCR, LLC has been assigned the account of the Defendant by Unifund CCR Partners. 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. Unifund CCR Partners has been assigned the account of the Defendant by Pilot Receivables Management, LLC. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. 6. Pilot Receivables Management, LLC purchased the account of the Defendant from Citibank (South Dakota) National Association. Pursuant to Pa.R.C.P. No. 1019(1), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit D. 7. Defendant used the extended credit leaving an unpaid balance of $5,547.14 with interest continuing to accrue at 6.00% per annum. 8. Defendant defaulted on the payments due. 9. The last payment was made on this account on or about July 1, 2010. 10. The balance on the charge -off is $5,547.14 and post- charge off interest has accrued in the amount of $824.31 to date for a total remaining balance due of $6,371.45. 11. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his/her account. 12. 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. 13. 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. 14. Defendant's failure to pay is a breach of the implied contract between the Defendant and original creditor. 15. 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. 16. 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. 17. The total reasonable value of the Defendant's use of the credit extended by original creditor is $6,371.45. 18. 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. 19. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 20. By virtue of Plaintiff's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $6,371.45. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $6,371.45, 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: Jonathan C. Ford # 823286 5424180580432240 for the sum of $6,371.45 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 5A day of _,2013. Authorized Signature Unifund CCR, LLC EXHIBIT a ASSIGNMENT THIS ASSIGNMENT is effective as of July 1, 2013 between UNIFUND CCR PARTNERS, a Now York Partnership ("Assignor") and UNIFUND CCR, LLC, an Ohio limited liability company ("Assignee"). I.Mless otherwise defined herein, terms used herein shall have the meanings specified in the Serviciag Agreement between Assignor and Assignee (the "Agreement Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. UNIFUND CCR PARTNERS By: ". . morg n * Sin th Vice side of Ueration UNIFUND CCR, LLC By: Aktumn Hopkins Manager of Legal Operations EXHIBIT ASSIGNMENT THIS ASSIGNMENT is effective as of July 1, 2013 between PILOT RE CEIVABLES MANAGEMENT, LLC an Ohio limited liability company ("Assignor") and UNIFUND CCR PARTNERS, a New York Partnership ("Assignee"). u nless Aless otherwise defined herein, terms used herein shall. have the ineanings specified in the Servicing Agreement between. Assignor and Assignee (the "Agreement"). Assignor, for value received and in. connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. PILOT RECEIVABLES MANAGEMENT, LLC B y: Morga in th Vice P siden of O ation UNIFUND CCR PARTNERS By: Autumn Holi iign� p Manager of Legal Operations EXHIBIT Contract ID: UNIMUMXBO32513 Document ID: 032013UNIMUIXBBI Document ID: 032013UNIMUMB1 Document ID: 032013UN1MU4XBB1 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated March 25, 2013, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank ") to Pilot Receivables Management, LLC, organized under the laws of the Ohio, with its headquarters /principal place of business at 10625 Techwoods Circle, Cincinnati, OH 45242 ( "Buyer "). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated March 25, 2013, between Buyer and the Bank (the "Agreement "), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 and the final electronic file. Citibank, N.A. By. `._. . (Signature) Name: Patricia Hall Title: Financial Account Manager EXHIBIT Pilot 032513 Es 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. Harry A. S ausser, III 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 JONATHAN C. FORD, DOCKET NO. Defendant AFFIDAVIT OF NON - MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, and has not been in such service within thirty days hereof. Dated this) day of s����-'� , 2013 Raymddd W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570 -387 -1873 Fax: 570- 387 -6474 Department of Defense Manpower Data Center Results as of: Sep -04- 201303:29:00 SCRA 3.0 +,� Status Report `, # Pursuant to Scrviccmemben Civil Relief Act. Last Name: FORD First Name: JONATHAN Middle Name: Active Duty Status As Of: Sep -04 -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 N o 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 Cali -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. 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 1D: R4819146EODAJEO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL -LAW JONATHAN C. FORD, :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: Jonathan C. Ford 210 W. Main Street Mechanicsburg, PA 17055 Respectfully submitted, Raym nd W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570- 387 -1873 Fax: 570- 387 -6474 ca IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY -_ COMMONWEALTH OF PENNSYLVANIA rn rn REMIT CORPORATION, Assignee of Unifund CCR, LLC, : C Plaintiff vs. CIVIL -LAW JONATHAN C. FORD, DOCKET NO. Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, RAYMOND 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 1 , Sheriff w of 1tiribrr ow Jody S Smith Chief Deputy is Pt t 3 rs r-!, Richard W Stewart U;�'iBEI L ��a! 7 �ta. -T Solicitor + Remit Corporation Case Number vs. 2013-5281 Jonathan C. Ford SHERIFF'S RETURN OF SERVICE 10/10/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jonathan C. Ford, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Served"at 210 W Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. several attempts at service were made but deputies were unable to make contact with anyone at the residence to effectuate service and the Complaint has since expired. SHERIFF COST: $61.60 SO ANSWERS, October 10, 2013 RONNW R ANDERSON, SHERIFF E ieeoscf;. • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT COMMONWEALTH OF PENNSYLVANIA -v p �-•• r 4" S"r�Cam ' r. �i. REMIT CORPORATION, i yw -r,, Assignee of Unifund CCR, LLC, • r- � L Plaintiff �a a �. vs. : CIVIL-LAW JONATHAN C. FORD, : DOCKET NO. 2013-5281 Defendant MOTION FOR ALTERNATIVE SERVICE OF ORIGINAL PROCESS COMES NOW the Plaintiff, by and through its attorney, Raymond W. Kessler, Esquire and files this Motion for Alternative Service of Original Process and in support thereof says: 1. On September 9, 2013, Plaintiff filed a civil complaint with the Prothonotary of CUMBERLAND COUNTY. 2. Pursuant to Pa.R.C.P. 400 and 402 Plaintiff requested the Sheriff of CUMBERLAND COUNTY to serve the complaint. 3. The CUMBERLAND COUNTY Sheriff's Department attempted to serve this complaint at the Defendant's residence on multiple dates. 4. The Sheriff's Department was unable to serve the complaint noting: "Several attempts at service were made but deputies were unable to make contact with anyone at the residence to effectuate service."A copy of said Return of Service form is attached hereto, made a part hereof and labeled as Exhibit «A„ 5. The above service attempt was made at Defendant's residence at 210 West Main Street, Mechanicsburg, PA 17055. 6. Plaintiff avers that the address of 210 West Main Street, Mechanicsburg, PA 17055 is the current and correct address of the Defendant. A copy of a Postmaster request showing Defendant's physical address as current is attached hereto, made a part hereof and labeled as Exhibit`B". 7. Plaintiff avers that the Defendant is actively avoiding service of process in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to order that service of Original Process in this matter be made by alternative means. Respectfully submitted, Raymond W. Kessler, Esquire PA 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 : • vs. : CIVIL-LAW JONATHAN C. FORD, : DOCKET NO. 2013-5281 Defendant . AFFIDAVIT PURSUANT TO Pa.R.C.P. 430(a) Pursuant to Pa.R.C.P. 430(a), I have taken the following actions to verify that the correct address of the Defendant is 210 West Main Street, Mechanicsburg, PA 17055. 1. I submitted a request for verification of address to the United States Post Office in Mechanicsburg, PA. This document was returned to me by the Post Office marked the above address is correct. A Copy of this document is attached as Exhibit B. 2. I searched the website"411.com"which is an electronic version of Directory Assistance. It listed Defendant's address as 210 West Main Street, Mechanicsburg, PA 17055. A copy of the document is attached as Exhibit C. 3. I searched Voter registration records through the Pennsylvania Department of State website. However it does not provide any information whether Defendant is registered or not. Resp ctfully submitted, /411,/ Valerie Chevere Paralegal Sworn to and subscribed before me colvIlvloNWE TF? °F sYr vAxin thisaL ay of o 0!3. r7it)1 :ii; ;> At Janine ; a x. ' otaryPubhc Bloor shsr.?'o; r, olumbia County My camnris ?nx iresMa 11,2014 Notary Public 56i UJP • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of Llnufitrr1iirk Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF TPE sHERIrr Remit Corporation vs. Case Number Jonathan C. Ford 2013-5281 SHERIFF'S RETURN OF SERVICE 10/10/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jonathan C. Ford, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint& Notice as"Not Served"at 210 W Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. several attempts at service were made but deputies were unable to make contact with anyone at the residence to effectuate service and the Complaint has since expired. SHERIFF COST: $61.60 SO ANSWERS, October 10, 2013 RONR ANDERSON, SHERIFF EXHIBIT (c)CountySuite Sheriff,Teleosoft Inc. (� OV47,fh41,S1 Cie Postmaster Date 10/16/2013 MECHANICSBURG,PA 17055 City, State, ZIP Code REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address(if a boxholder)for the following: Name: JONATHAN C.FORD Address: 210 WEST MAIN STREET.MECHANICSBURG.PA 17055 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(4Xii). There is no fee for providing boxholder or change of address information. 1. Capacity of requester(e.g., process server, attorney, party representing self): Remit Corporation 2. Statute or regulation that empowers me to serve process(not required when requester is an attorney or a party acting pro se-except a corporation acting pro se must cite statute): PA Act 219 of 1990 Section 2, Title 18 Section 7311 3. The names of all known parties to the litigation: Remit Corporation 4. The court in which the case has been or will be heard: Depends on Jurisdiction 5. The docket or other identifying number if one has been issued: N/A 6. The capacity in which this individual is to be served(e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS,OR BOTH(TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal proc ss' conjunction with actual or prospective litigation. Remit Corporation PO Box 7 Signature Address VALERIE CHEVERE Bloomsburg, PA 17815 Printed Name City, State, ZIP Code POST OFFICE USE ONLY No change of address order on file. NEW ADDRESS OR BOXHOLDER'S NAME POSTMARK Moved, left no forwarding address. AND STREET ADDRESS No such address. The above address is correct 7055 Gs 9 DEC 1 4 2013 1 j EXHIBIT Free People Search I 411.com Page 1 of 2 411.com t .y S f Bloomsburg, PA'S NEW RULE New[December 20131 rule in Bloomsburg. PA leaves drivers furious and shocked... Read More» t bsv pp,, k C:: Cat :44ft • • • qa Alarming Brain Trend [December 20131 This 1 scary trick is used by major companies to teach their employees a new language... Read More» AM ry FACEBOOK BANNED THIS [December 20131 This looming scandal could ruin the 44th President and disrupt the entire country... Read More » Or search: • Last name only Jonathan Ford 210 W Main St Mechanicsburg, PA 17055-6227 Age: 30-34 Associated: Jeffrey M Busier 0 � 4 F EXHIBIT f r http://www.411.com/name/Jonathan-Ford/Mechanicsburg-PA/a4x5g58 12/19/2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, • Assignee of Unifund CCR, LLC, • Plaintiff • vs. : CIVIL-LAW JONATHAN C. FORD, • DOCKET NO. 2013-5281 Defendant CERTIFICATE OF SERVICE I declare that on_ / / 6/4 y I, Raymond W. Kessler, Esquire, placed a true and correct copy of the Plaintiff's MOTION FOR ALTERNATIVE SERVICE OF ORIGINAL PROCESS, filed in the above referenced matter, in the US mail, FIRST CLASS mail, postage prepaid to the Defendant at the following addresses: Jonathan C. Ford 210 West Main Street Mechanicsburg, PA 17055 Respectfully submitted, Raymo a W. Kessler, Esquire Attorney ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 REMIT CORPORATION, IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF UNIFUND CCR, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. JONATHAN C. FORD DEFENDANT 13-5281 CIVIL ORDER OF COURT AND NOW, this 14th day of January, 2014, upon consideration of the Plaintiff's Motion for Alternative Service of Original Process; IT IS HEREBY ORDERED AND DIRECTED that the Motion for Alternative Service of Original Process is GRANTED. IT IS FURTHER ORDERED AND DIRECTED that: 1. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's last known address at 210 West Main Street, Mechanicsburg, PA 17055; 2. That the Sheriff and/or Plaintiff is directed to serve the Complaint upon the Defendant, Jonathan C. Ford, by posting a copy of the Complaint upon the premises at 210 West Main Street, Mechanicsburg, PA 17055; 3. All future service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address. By the Court, M. L. Ebert, Jr., J, ✓ Raymond W. Kessler, Esquire 36 West Main Street Bloomsburg, PA 17815 bas rrtt�a r leg 41 � `a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL-LAW JONATHAN C. FORD, DOCKET NO. 13-5281-CIVIL e Defendant ::o V C:� .YC PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Civil Complaint filed in the above matter. Respectfully Submitted, RAY ND W. KESSLER, ESQUIRE Attorney ID 309802 36 W Main Street PO Box 7 Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 �11.�� a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff O T '' Jody S Smith Chief Deputy ?114 MAID -t+ AM in: 38 Richard W Stewart CUMBERLAND COUNTY Solicitor " ` v,„� PENNSYLVANIA Remit Corporation Case Number vs. Jonathan C. Ford 2013-5281 SHERIFF'S RETURN OF SERVICE 02/21/2014 02:04 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Complaint& Notice upon the within named Defendant, to wit: Jonathan C. Ford, pursuant to Order of Court by "Posting”the premises located at 210 W Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and correct copy according to law. NOAH CLINE, DEPUTY SHERIFF COST: $45.30 SO ANSWERS, February 25, 2014 RONNTY R ANDERSON, SHERIFF ,� 0f' ,-... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, n } Assignee of Unifund CCR, LLC,rN Plaintiff tc) cp —. (c y Z r� Z G c..? J � VS. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant VS. METRO BANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) (2) (3) directed to the Sheriff of Cumberland County, Pennsylvania against JONATHAN C. FORD, defendant; and Against Metro Bank, Garnishee; (4) and index this Writ in the judgment index and (a) against JONATHAN C. FORD, defendant(s), and (b) against Metro Bank, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: Interest from 6/10/2014 Credits Costs to be added: Clerks Fee: Sheriff: Total: ett `°e i -5-")r IC 11 u [t r! t�1 1".L Ac r . S) 13wc- $ 6,891.04 $ 111.01 $ 0.00 $ 29.00 $ 150.00 $ 7,181.05 Dated t s a2. day of SepFewhel—, 2014 Raymolfd W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 ['Ur E/l'gck•Pcl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant vs. METRO BANK, Garnishee 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, nor has been in such service within thirty days hereof. Dated thisa2- day of Ser iera<c2014 RaymW. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 Department of Defense Manpower Data Center Status Report. Pursuant to Ser iccmembets: Civil Relief, Last Name: FORD First Name: JONATHAN Middle Name: C Active Duty Status As Of: Sep -12-2014 Results as of : Sep -12-2014 09:26:41 AM SCRA 3.0 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 Das 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. 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: UDYEBCF5T080050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant vs. METRO BANK, Garnishee CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation Assignee of Unifund CCR, LLC 36 West Main Street Bloomsburg, PA 17815 Defendant: Jonathan C. Ford 20 Round Hill Road Apartment 2 Camphill, PA 17011 Garnishee Metro Bank 65 Ashland Avenue Carlisle, PA 17013 Respectfully Submitted, Ra ind W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax (570)387-6474 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net Remit Corporation, Assignee of Unifund CCR, LLC Vs. NO 13-5281 Civil Term CIVIL ACTION — LAW Jonathan C. Ford WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Jonathan C. Ford, 20 Round Hill Road, Apt, 2, Camp Hill, PA 17011 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of Metro Bank, 65 Ashland Avenue, Carlisle, PA 17013GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $6,891.04 Interest from 06/10/2014 - $111.01 Attorney's Comm. Attorney Paid $267.90 Date: 09/1/14 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs -haR.LieL Leie David D. Buell, Prothonotary REQUESTING PARTY: Name : Raymond W. Kessler, Esq. Address: 36 West Main Street, Bloomsburg, PA 17815 Attorney for: Plaintiff Telephone: 570-387-1873 Supreme Court ID No. 309802 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF Ti " St!EFiFF: r_` �- i . _ n µ. F ILEO O'r '10E ii THE PROTHONOTARI Z 1s OCT -11 P14 2t 51 CUMBER`LANU COUNTY PENNSYLVANIA Remit Corporation vs. Jonathan C. Ford Case Number 2013-5281 SHERIFF'S RETURN OF SERVICE 10/07/2014 12:04 PM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Suzzanne Yingling, Senior Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 8, 2014 to Jonathan C. Ford at 210 W Main Street, Mechanicsburg, PA 17055. October 08, 2014 (c) CountySuiie Sheriff, "teleosoft, Inc. A onal.Q TO\I IE DIMARTILE, DEPUTY SO ANSWERS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO: 13 -5281 -CIVIL Defendant VS. METRO BANK, Garnishee PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly discontinue the Writ of Execution against METRO BANK. SUBMITTED BY: Raymo i W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main St. Bloomsburg, PA 17815 Tel. (570)387-1873 Fax (570)387-6474 ,supdt Eft V,4 /go 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA. C REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff vs. : CIVIL -LAW JONATHAN C. FORD, : DOCKET NO. 13 -5281 -CIVIL Defendant vs. METRO BANK, Garnishee Ansoto INTERROGATORIES TO GARNISHEE TO: Metro Bank 65 Ashland Avenue Carlisle, PA 17013 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has account xxxxxx9447 held jointly with Erika M Ward. Account has a balance of $10,737.03 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? see answer, to question 1 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? no 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? no 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or. consent and if so what was the consideration thereof? no 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? no 7. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. no 8. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. no 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as may be relevant to this attachment. COMPLETED BY: Interrogatories submitted to garnishee by: Raym.nd W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist (Title) of Metro Bank, garnishee herein, (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.