Loading...
HomeMy WebLinkAbout13-6910 Supreme Co tiofl,Pennsylvania Court,4 Pleas For Prothonotary Use Only: C�iwiY Cove "r�Sheet _,- D ` = Docket No: CUMBER R LAN' " ��° County The information collected on this form is used solely for court administration purposes. This fibrin 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 Complaint El Writ of Summons 0 Petition Q E Transfer from Another Jurisdiction J Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T FIA CARD SERVICES, N.A. JACQUELINE M LACEY I Are money damages requested? Ix' Yes NO Dollar Amount Requested: fix; within arbitration limits (check one) Ooutside arbitration limits O N Is this a Class Action Suit? F-1 Yes El No Is this an MDJAppeal? El Yes X No A Name of Plaintiff /Appellant's Attorney: FREDERIC I WEINBERG C Check here if you have no attorney (are a Self- Represented JPro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional 3 Buyer Plaintiff Administrative Agencies El Malicious Prosecution Debt Collection: Credit Card Q Board of Assessment E] Motor Vehicle Debt Collection: Other Q Board of Elections 0 Nuisance Dept. of Transportation Premises Liability El Statutory Appeal: Other S Lai Product Liability (does not include E mass tort) CI Employment Dispute: 0 Slander/Libel/ Defamation Discrimination C !J Other: [3 Employment Dispute: Other CI Zoning Board , 0 Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco Toxic Tort -DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 7l Toxic Waste fi J ectment Ejectment Other: � Q Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation !_+ Declaratory Judgment ©E— Ground Rent Mandamus 0 Landlord/Tenant Dispute r- Non- Domestic Relations Q Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY f=J Mortgage Foreclosure: Commercial E Quo Warranto J Dental ❑ Partition(] Replevin Legal LJ Quiet Title Other: 0 Medical O Other: E] Other Professional: Updated 1/1/2011 2131437 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS 655 PAPERMILL ROAD CUMBERLAND COUNTY NEWARK, DE 19711 V` VS. DOCKET N0. JACQUELINE M LACEY+ -� 6252 BILLINGSGATE - t; MECHANICSBURG PA 17050 t) CD c.) CD D ' 5> u NOTICE 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 Ot O CJI/ a 5a� FIA Card Services, N.A., ) Plaintiff, ) V. ) JACQUELINE M LACEY, ) Defendant, ) COMPLAINT IN A CIVIL ACTION 1. At all times relevant hereto, the Defendant(s) was the holder of a credit card or other consumer finance account (hereinafter "the account "), which at the request of the Defendant(s) was issued to the Defendant(s) by the Plaintiff or a predecessor in interest of the Plaintiff, under the terms of which the Plaintiff or its predecessor agreed to extend to Defendant(s) the use of its credit facilities. 2. Defendant(s) accepted and used the account so issued and by so doing agreed to perform the terms and conditions prescribed by the Plaintiff for the use of the account. 3. The Defendant(s) received and accepted goods and merchandise and/or accepted services or cash advances through the use of the account issued by the Plaintiff. A true and correct copy of the Charge -Off Statement is attached hereto as Exhibit "A ". 4. All the credits to which the Defendant(s) is entitled have been applied and there remains a balance due in the amount of $19232.47. 5. Plaintiff has made demand upon the Defendant(s), who is in default, for payment of the balance due but the Defendant(s) has failed and refused, and still refuses, to pay the same or any part thereof. 6. Defendant's last payment on account was made on 06/02/2011. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $19232.47 plus applicable court costs. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff PBOA.1 s , FIA. Card Services; N.A., j ) Plaintiff, ) ) V. ) JACQUELINE M LACEY, Defendant, ) VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he is an authorized agent of FIA Card Services, N.A., the Plaintiff herein, and that he is duly authorized to make this Verification, and that the facts set forth in the Complaint in this civil action are true and correct to the best of his knowledge, information and belief. Dated: OCT 10 2013 Affiant Name (Printed): Sherri Griffin Affiant Name (Signature): & 2' VU 2131437 Reference No EXHIBIT "A" BankofAmerica � JACQUELINE M LACEY Account Number: 4888 93615910 8152 April 3 -May 2, 2011 Account Information: www.bankofamerica.com trim Mail billing inquiries to: New Balance Total ............... ............................... .....................$19,272.47 Previous Balance.. .................... $19,121.29 BankofAmerica Current Payment Due ............. ............................... ........................$381.00 Payments and Other Credits ... , .............. 40.00 P.O. Box 75026 Past Due Amount .................. ............................... ......................$2,363.00 Purchases and Adjustments ......... .... ....... 0.00 Wil mington, DE 19850.5026 Fees Charged ........................ .................... ... 35.00 Mail payments to: Total Minimum Payment Due .. ............................... ......................$2,744.00 Interest Charged ..................... ..................... 156.18 BankofAmerica Payment Due Date............ 6/1/11 .............................. ............................... . P.O. Box 15019 New Balance Total . .....................$19,272.47 Wilmington, DE 18986-5019 Late Payment Warning. If we do not receive your Total Minimum Payment by Customer Service: the date listed above, you may have to pay a late fee of up to $35.00. Credit Line ............. .....................$18,900.00 1800.789.6701 Total Minimum Payment Warning: If you make only the Total Minimum Statement Closing Date .....................5 /2/11 Payment each period, you will pay more in interest and it will take you longer Days in Billing Cycle ..... .............................30 (1.800.W31318 TM Payment pay off your balance. For example: • . will P l ayoff ad ditional charges the balance up r each 111 011111 You abo Only the Total 32 years $32,967.74 Minimum Payment If you would like information about credit counseling services, call 1- 866300.5238. Transaction Pasting Reference Account Date Date Description Number Number Amount Toter Payments and Other Credits 04/29 BA ELECT RONIC PAYMENT -40.00 •- $40.00 Fees 05/01 05/02 LATE FEE FOR PAYMENT DUE 05/01 9081 35.00 TOTAL FEES FOR THIS PERIOD $35.00 Interest Charged 05/02 05/02 Interest Charged on Balance Transfers 0.00 05/02 05/02 Interest Charged on Cash Advances 0.00 continued on next peat 03 0192724700274400000040000004888936159108152 BANK OF AMERICA Account Number: 4888 93615910 8152 P.O. BOX 15019 WILMINGTON, DE 19886 -5019 New Balance Total ............. .......$19,272.47 Total Minimum Payment Due ....................... .......................2,744.00 Payment Due Date ...................... .............................06 /01/11 JACQUELINE M LACEY Enter payment amount $. 6252 BILLINGSGATE MECHANICSBURG PA 17050 -5224 :>:,,...,...>........ eN.:..:.......> .....;::.:, .....:..::...:..:3 =. Check here for a change of matting address or phone numbers. Please proHde arr corrections on the remrse side. Mail this coupon along with your check payable to: Bank of Artrerica 1:5 240 2 2 2 501: 128 76 15 9 1081520 [ MPORTANT INF AB THIS ACCOU NT_, — _ - �,� ^� _ _,_^ USE6 Re O. 1101 CUSTOMER TIPS FOR DISPUTED ITEMS ^ OIVI,TNE Nlanyt. ine_ s disputed charges are legitimatechm drat h.atcustomersmayrotreeognize i Online Bankingisav' ailrble24hoursadxy ,7dayaaweekand a r• rememher. Before ciispnt. ingatharge, wP few tbmgs I all owsyoutoaiewtbe most recentactivityonyouraccount. and make every effort to resohe the dispute with the merchant. Often ille merchant can answcryourquestionsantieasilyresolveyourdiapute .Themercliant`sphonenumber may be located on your receipt or billing statement. PHONE • flag a credit posted toyouraccoant? 1 L86(L266,0212 Please aliowup to 30 days from the date on year credit voucher or For prompt service, please have the merchant reference an mber(s) acknowledgententletter for the merchant credit topost. 1 availab (e for the charge(e)inquestion. • Is the charge or amount unfamiliar? f Check with other persons authorized to use the account to make sure they did not make the charge. It is possible that the merchants' hillingnamec and store names are different oramounts can easily be contused with similar hfATL chargvsorinciudetips. AttmBilling Inquiries POBox16026,WAm1n9ton,DEM5 -6026 One x77 to check for the credits or tosiew tram u-tion details is to look at your ® When writing, please include Your Name, Account Number, the account statements online. Ifyou are not enrolled in Online Banking, it is eagytu enroll reference number of the disputed item and specific details regarding yourdispu te ,includingdalesofcontactwiththe usingthowebaddressonthefrontofyourstatementorgiveusacall. ludealnt.andthe merchant's response in each instance. Please include all supporting ( Please remember: ( Tnceyou receive your statement vyithatransactinn .ynn doc: wnentation, including sales and credit vouchers, contract and vviahto � � dispute, you onlyhace 60 daya to dispute the charge. postage return receipts as proof ofany returns. GRACE PERIODIPAYING INTEREST "Gram Period" meanstbeperiodoftimeduringa billing cycle whenyouwillnot less than zero we treat it asze.ro. accrue interest an certain transactions orbal . toms. There is no Grace Period for Balance t' tre include the fees for credit card debt-cancellation or credit insurance. .purchased Transfers or Cash Advances: w• e begin chatginginterestonBalanco Transfers and Cash through us in calculating the beginning balance for the first day of the billing cycle after Advances on the transaction date. We will notcharde interest on Purchases on the next the billing cycle in which suchfees are billed. statement ifyou pay the New Balance Total in full by the Payment Due Date, arid you had TOTAL INTEREST CHARGE COMPUTATION paid in hill by the previousPaymeutDue Date. interest Charges accrue and are compounded on 9, daily basis, To determine the CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Inters at Charges we multiply each Balance Subjectt to InterestBnteby its applicable Daily Menage Balance Method (including new Balance Transfers and new C.-tsh Advances): Periodic Rate and that result by the number of days in the billing cycle. To determine PTe calculate at ywaratr. B2lsaie ra Subject tri an Interest Rate for Balanc e'f ransfers, the total Interest Charge for the billing cyale,we add the Periodic Rate Interest Charges Cash Advances, and for each Promotional Offer balance consistingofBalauce' Transfers together. ADaai ly Periodic Rate, is calculated by dividing an Annual PercentAgeRate or CushAdvaiioc Wedothisby:( 1.) cal culatingidailybalanceforeachdayinthis by 36.5. s tatementsbilfitgcycle;( 2) calculatingadai�yba lanceforeachdiypriortothis HOW WE ALLOCATE YOUR PAYMENTS statement' sbillingcycie that had a" Pro-Cyciohalance "- aPre- Cyclo balance isaBalance lfyouratxounthas balances with differentAPRs ,wewill all cuatetheamntm'tof Transfer or aOash Advance witha transaction date prior to ' this statemenfsbilling your pavment equal totheTotal'M inimum Payment Due to the lowest APR balancesfirst cvcle but with a posting date vrithin this statement's bab ng cycle; (3) adding a 0 the daity flnuluding transactions made after this statement). Payukentamounto ill excess Qfyour b alances together; and M dividing the sum ofthe rLaily-balancess by the number ofda in Total Minimu in Payment Due will1o, applied t4o balances with hi.-berA.PR,-. before balances this statement's billing cycle, with lower APRs. To raticul.tte the daily balance for each day in this statement's billing cycle, we take the IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE beginningbalance, add an amount equal to the applicable Daily Periodic Rate multiplied When usingthe optional Pay -by- Phone service, Sou authorize us to initiate an bythe previous (IV's dai'I,vbalance, add new Balance Transfers, new Cash Advances i.nd ele`ttronic payment from your account at the financial institutionyou designate. You mast Transaction Fees, avdsubtractapplicablepaym. ont5 and credits. lfany daily balance is authorize, the amount and timin9ofe- wA Payment. Foryoitrprotxction,we5vitlaskim less than zero we treat it as zero. security information. A fee may appu-for expedited service. To cancel, (all us before the To calculate a daily balance for each day prior to this statement's biltingcy had scheduled paymentdate. Same-day Iiaymeats cannot he edited or canceled. aFre- Cycle balance, we take the beginning balance attributable sololy to Pre -Cycle INA-knee MISCELLANEOUS ( whichvvil lb e zero on the transaction date of tile fustPre-Cycle balance), add anariount F( w the complete terms and covditionsofyour account, consuit-yoorGlediiCard equal tntheapplica bleDailyPeriodicRatemultipliedbythepreviousday 'sdru'lybalance, Agreement. PIA Card Servicesisntradename ofFl A Card Services, N.A.This account is mrdaddonly the applicable Fre- clebalances ,uidtheirmlateiTransaction Fees. life issuedand adminiateredbyFUatilServices,NA exclude from this calculation all transactions posted in previous billin; cycles. Average Daily Balance Method (including new Parr-bases)! We calculate separate Balances Subject to an Interest Rata for Purchases and for each Promotional Offer ba) ancx consisting of Purchases. Wedo this by! Wcalculatinga daily balance far each day in the billing cycle; (2) adding all the dailybalanees together; and (3) dividing the eu m of the daily balances by the number,)( days in the billing cycle-. To calculate the daily balinvee'for each day in this statement's billing cycle, we Make the beginning balanco, add an amount equal to applicable Daily Periodic Rate multi plied by the previous day's daily balance, add new Purchases, new :Account Fees, and now Transaction Fces, and trubtract applicable piyments and credits. If any dally balance is PAYMENTS Ifyourbilling address or contact information has changed, or if your address is V %e r.,rerlit..mailed payments as of the date received, if tin pa }'newt is: (1) rereic'erl by incorrect as it appears on this bill,please provide all corrections here, 5 p.m. local time atibc address shown on the remittance slip on the front ofyour monthly statement; (2) paid with a check drawm in U.S. dollars on a U.S. financial institution or a U.S. dollar money ordenand (3) sent in the return envelope with only thL remittance Address portion ofyoursiatement accompanying it. Payments received hymailafter6p.m.local time at the remittance address on any day including thePVmcnt DucDate, but that otherwieem. oettheaboveregniremcnts, willbecredite(itteofthencet•rlay. Pagtnents Add made made online or. by phone wilibe credited as of the date of receipt if madeby 5 p.m. Central .... _.. .............. ._.................. ..._.....................___.._._...._......-....-..._...... ................_...- -.-- -_.._. time C reditfor any otherivavanents may bedelayerluptnfivedays. ■ Nopaymentshalloperateasanaecordandse4afaclionwithaitthepriorwritten City approval. of one of our Senior Officers. We process mostMynicatchecks electronicidly by usingthe information found on yourcheck. Each check authorizes tie to create a one-time electronic funds transfer (or State _ Zip — process itas a check or paper draft). Fmidsmaybewithdrawnfromyouraccountassoon -- — as the same day we re.ceiveyour pigment. Chccks are not returned to you. Por tnom Area Cale & information or to stop the electronic funds trall gfors, call its at the number listed on gomr-Phone the front _..... _. -.... _ -- _._....._. Ifyou have authorized us to payyourcredit card bill automatically from your savings Area Code& or checking account with as, you can stop the payment on any ammmt -you think is {C /ork Phone wrong. To stop payment, you rletler must reach us at least three business days before the automatic payment is scheduled to occur. BankofAmeriea �w 4888 9361 5910 8152 April 3 - May 2. 2011 Page 3 of 4 s . � Trensactron Poslirg Reference Account Date Date Descriptlon Number Number Amount Total Interest Charged 05/02 05/02 Interest Charged on Purchases 156.18 TOTAL INTEREST FOR THIS PERIOD 5 166 . 18 2 011 Tot als • i Total fees charged in 2011 $175.00 Total interest charged in 2011 $773.34 .. Your balance exceeds the credit limit Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Promotional Promotional Balance Interest Percentage Transaction Offer ID Subject to Charges by Rate Type Interest Transaction Rate Type Balance Transfers 9.90$ $ 0.00 $ 0.00 Cash Advances 19.24$V $ 0.00 $ 0.00 Purchases 9.908 $19,193.68 $156.18 APR Type Definitions: Daily Interest Rate Type: V- Variable Rate (rate may vary) Department of Defense Manpower Data Center Results as of: Nov -07.2013 07:34:213 SCRA 3.0 Status Deport Pursuant to Servicernemben Civil Relief Act Last Name: LACEY First Name: JACQUELINE Middle Name: M Active Duty Status As Of: Nov -07 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duly End Date Status Service Component NA NA No NA This response reflects the individuals' active duly status based on the Active Duty Status Dale Left Active Duty Within 387 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 387 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 Dale Order Notification Start Date Order Notification End Date Status Service Component NA I 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. A LI Vff� Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Dala'Ceht& (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp://www.defenselink .mil /faq /pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH 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: X578H248Q0338E0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r i !i Jody S Smith �o ,- 4 , Chief Deputy r i_t 3 EC -2 p I O S Richard W Stewart CUHSERLAND COUNT Y Solicitor ;E PENNSYLVANIA FIA Card Services, N.A. vs. Case Number Jacqueline M Lacey 2013-6910 SHERIFF'S RETURN OF SERVICE 11/25/2013 05:52 PM - Deputy Ryan Burgett, 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: Jacqueline M Lacey at 6252 Billingsgate Court, Hampden Court, Mechanicsburg, PA 17050. RYAN BURGETT, DEPUTY ' SHERIFF COST: $39.30 SO ANSWERS, November 26, 2013 RONNY R ANDERSON, SHERIFF ,-.1 a d a r1L. .. 1,ofi-ioNjtA12131437 GORDON & WEINBERG, P. C. 2014 JA S 13 Pf' 2: 35 BY: FREDERIC I . WEINBERG, ESQUIRE('UHB.R,�D ��UN�� Identification No. : 41360 PENN5YLVANrA =_- JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 MNIMM ggE FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 13-6910 CIVIL zmz JACQUELINE M LACEY PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant JACQUELINE M LACEY only and assess damages certified to be calculable as a sum certain from the complaint, as follows : Principal $19, 232 . 47 Costs (Complaint & Service) $143 . 05 Less : Payment on Account ( $ . 00) Total : $19,375 .52 Understanding the false statements made herein are subject to penalty under 18 Pa. C. S .A. §4904, Unsworn Falsification to Authorities, I verify that : 1 . The last known addresses of the defendant, JACQUELINE M LACEY, is 6252 BILLINGSGATE, MECHANICSBURG PA 17050 . 2 . The annexed notice of intention to file this praecipe was mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days 04•,1 prior to the date of filing of this praecipe. 0"Y ) ,SD etA. 91° 16 21:1- 300v6.21 1.)ohc� 3 . The said defendant is not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is over 18 years of age . AND NOW, this 11 day of , 20 / (Judgment is entered in favor of the plaintif and against defendant default for want of an answer and damages ass sse t um of 9, 375. 52 as per the above certification. / Prothonotary GORDON & WEINBER P.C. BY: FREDERI . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2131437 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 13-6910 CIVIL JACQUELINE M LACEY 6252 BILLINGSGATE MECHANICSBURG PA 17050 NOTICE Pursuant to Pa. R. Civ. P. 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 $19,375.52 / / Money Judgment $ / / Judgment on Award of Arbitrators$ / / Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS : FREDERIC I . WEINBERG OR JOEL FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 ° A. ! ifr 4,o PROTHONOTATY 1)1 //'i' CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. 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:/lwww.defenselink.mil/faq/pis/PCO9SLDR.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: H600958780ADF30 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:llwww.defenselink.millfaglpis/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: H600958780ADF30