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Home My WebLink About14-0426 Supreme Cod, nnsylvania COuP tco mo leas For Prothonotary Use On ly: Sht trr Q `�� Docket No: J! •S j County ?he in%rinadon collected on this forni is used solely fi)r court administration purposes. This forni does not supplement or replace the fithkq and sei of pleadings or other papers as required by law or rifles of court. Commencement of Action: S ! Complaint Q Writ of Summons ll Petition E] Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: L,cad Defendant's Namc: T , REMIT CORPORATION, ASSIGNEE OF UNIFUND CCR, LLC MARK S. HENRY Dollar Amount Requested: Qwithin arbitration limits I Are money damages requested? Yes No O (check one) 0outside arbitration limits N Is this a Class Action Suit? 0 Yes R No Is this an AIDJ Appeal? El Yes 0 No A Name of Plaintiff /Appellant Attorney: RAYMOND W. KESSLER, ESQUIRE 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 inchide Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional n Buyer Plaintiff Administrative Agencies Malicious Prosecution ® Debt Collection: Credit Card 0 Board of Assessment Q Motor Vehicle 0 Debt Collection: Other [] Board of Elections Nuisance Q Dept. of Transportation Premises Liability ll Statutory Appeal: Other S Product Liability (does not inchide E mass tort) Employment Dispute: Slander/Libel/ Defamation Discrimination Employment Dispute: Other Zoning C � Other: g Board T El Other: I Other: 0 MASS TORT D Asbestos N ® Tobacco Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Q Toxic Waste Other: 11 Ejectment [] Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation l3 Declaratory Judgment 0 Ground Rent l7 Mandamus r--1 Landlord /Tenant :Dispute Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial Quo Warranto El Dental 0 Partition 0 Replevin rl Legal 1] Quiet Title 13 Other: Medical 0 Other: 0 Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNfJT �- - COMMONWEALTH OF PENNSYLVANIA r° REMIT CORPORATION Assignee of Unifund CCR, LLC, Plaintiff , VS. CIVIL -LAW MARK S. HENRY, DOCKET NO. Defendant NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Lawyer Referral Service Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800 - 692 -7375 (717) 249 -3166 717 - 238 -6807 RAY ND W. KESSLER, ESQUIRE S C a� Psy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL -LAW MARK S. HENRY, 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, Mark S. Henry, is an adult individual residing at 30 Allison Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Defendant obtained a Citibank MasterCard credit card on or about March 20, 2008, from Citibank (South Dakota) National Association, (hereinafter "original creditor "), Account number 5424 1806 7000 3257. 4. Unifund CCR, LLC has been assigned the account of the Defendant by Distressesd Asset Portfolio IV, LLC. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit B. 5. Distressesd Asset Portfolio IV, LLC purchased the account of the Defendant from 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 Assocation. 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 D. 7. Defendant used the extended credit leaving an unpaid balance of $4,240.81 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 15, 2010. 10. The balance on the charge -off is $4,240.81 and post- charge off interest has accrued in the amount of $733.37 to date for a total remaining balance due of $4,974.18. 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 $4,974.18. 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 $4,974.18. WHEREFORE, Plaintiff, Remit Corporation, demands judgment against Defendant in the amount of $4,974.18, together with interest, costs, and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, Raymo d 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: Mark S. Henry # 832655 5424180670003257 for the principal sum of $4,240.81 arising from unpaid credit card services with interest accruing at 6.00% per annum for total interest of $733.37 as calculated from the charge off date of 01/10/2011. The total balance assigned to assignee is $4,974.18. 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 20' day of December, 2013. auc Jes ica Bergholz, Legal 'Liaison nifixnd CCR, LLC EXHIBIT ASSIGNMENT THIS ASSIGNMENT is effective as of June 27, 2013 between DISTRESSED ASSET PORTFOLIO IV, LLC, an Ohio limited liability company ( "Assignor "), and UNIFUND CCR, LLC, an Ohio limited liability company ( " Assignee "). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement "). Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectibility, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. [DISTRESSED ASSET PORTFOLIO IV, LLC] By: w Morgan J. Smith Vice President of Operations [ UNIFUND CCR, LLC] By: Autumn Bloom Manager of Legal Operations EXHIBIT D D BILL OF SALE THIS BILL OF SALE is effective as of June 27, 2013 between PILOT RECEIVABLES MANAGEMENT, LLC, an Ohio limited liability company ("Assignor"), and DISTRESSED ASSET PORTFOLIO IV, LLC, an Ohio limited liability company ("Assignee"). Assignor, for value receive transfers, sells, convey, grants and delivers to Assignee free, clear and unencumbered title to the Accounts described on Attachment A and all of Assignor's rights thereto effective as of June 27, 2013. The sale is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of the information, and applicability of any statute of limitations) except as stated herein. [PILOT RECEIVABLES MANAGEMENT, LLC] By:� Name: Mo i(JJS pith Title : Vice President EXHIBIT r Contract ID: UNIBAMXBO62513 Document ID: 061913LTNIBAIXBB 1 Document ID: 061913UN1BA2XBB1 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated June 27, 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 State of 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 June 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. i Citibank, N. . By: (Signatur Name: Doualas Morrison Title: Dire EXHIBIT Pilot 062513B.doc a 8 i 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. Atrausser, 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 MARK S. HENRY, 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 I7 day of 2014 Raymond 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 Results as of: Jan -07- 201407:40:46 Center SCRA 3.0 St8tm Report Fl to Servicemembers Civil Relief Act. Last Name: HENRY First Name: MARK Middle Name: S Active Duty Status As Of: Jan -07 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA t 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 Oate Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects where the individual left active duty staluswithin 367 days preceding the Active Duty Status Date t . The Member or HislHer 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 I Service Component NA NA No -o' I NA This response reflects whether the individual or histher unit has received early notification to report for active du 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. ' w 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 at 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.htm]. 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: Y6Y32B78X097C10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. CIVIL -LAW MARK S. HENRY, 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: Mark S. Henry 30 Allison Lane Shippensburg, PA 17257 Respectfully submitted, Raymon W. Kessler, Esquire Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570- 387 -1873 Fax: 570- 387 -6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, `= Assignee of Unifund CCR, LLC, Plaintiff MCC VS. CIVIL -LAW "'� zv, MARK S. HENRY, DOCKET NO. (P � Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, RAYM ND W. KESSLER, ESQUIRE Attorney ID 309802 36 W Main Street Bloomsburg, PA 17815 Phone: 570- 387 -1873 Fax: 570-387-6474 � r • REMIT CORPORATION, : IN THE COURT OF COMMON PLEAS OF Assignee of Unifund CCR, LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION-LAW -, : NO: 14-426 rn rh rn F i cn r — co- MARK S. HENRY • -t --- Defendant • r-- � ? � . rvi,r ti ANSWER TO COMPLAINT AND NOW, comes Mark S. Henry by and through his counsel, Karl E. Rominger, Esquire and in support of his Answer to Complaint avers as follows: 1. Admitted as to who plaintiff is, but from reviewing the attached documents, it is impossible to say if Plaintiff is an assignee, and the same is denied, and strict proof of the same is demanded at trial. 2. Admitted. 3. Admitted. 4. Denied. From reviewing the attached documents, it is impossible to say if Plaintiff is an assignee, and the same is denied, and strict proof of the same is demanded at trial. 5. Denied. From reviewing the attached documents, it is impossible to say if Plaintiff is an assignee, and the same is denied, and strict proof of the same is demanded at trial. _ _ _ 6. Denied. From reviewing the attached documents, it is impossible to say if Plaintiff is an assignee, and the same is denied, and strict proof of the same is demanded at trial. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. Strict proof of the same is demanded. 11. Admitted, as to the issuer of the credit card. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted. 16. Admitted. 17. Admitted. 18. Breach is a legal conclusion and no answer is required. 19. Admitted. 20. Admitted as to creditor,but not plaintiff. WHEREFORE Defendant request judgment in his favor. NEW MATTER 21. Plaintiff was not in privety with Defendant. 22. Plaintiff lacks capacity to sue. 23. WHEREFORE Defendant request judgment in his favor. Date: February 11, 2014 Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant REMIT CORPORATION, : IN THE COURT OF COMMON PLEAS OF Assignee of Unifund CCR, LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : vs. : CIVIL ACTION—LAW : NO: 14-426 MARK S. HENRY • Defendant • CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Answer to Complaint upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, and Facsimile, addressed as follows: Raymond W. Kessler, Esquire 36 West Main Street Bloomsburg, PA 17815 Fax: 570-387-6474 Date: February 11, 2014 Respectfully submitted, ROMINGER & ASSOCIATES arl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ..°, ' - Jr I-.''.'.`. Sheriff 1 r?E P?O T OHO i 3i,, ,�',„;r of Czorit,ezt Jody S Smith t' 20I4 FEB I I PH 3: 14 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Remit Corporation Assignee of Unifund CCR LLC vs. Case Number Mark S Henry 2014-426 SHERIFF'S RETURN OF SERVICE 01/23/2014 03:22 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Alice Christine Kutz, Sister, who accepted as"Adult Person in Charge”for Mark S Henry at 30 Allison Lane, South Newton, Shippensburg, PA 17257. ;, gatir i GUTSH L, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, January 27, 2014 RONR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. : CIVIL-LAW MARK S. HENRY, : DOCKET NO. 14-426 Defendant PLAINTIFF'S RESPONSE TO NEW MATTER ..--.. CD COMES NOW, the Plaintiff, by and through its attorney, Raymond W. Kesg*, Esquire and submits the following Response to New Matter: RESPONSE TO NEW MATTER 21. Paragraph 21 states all legal conclusions to which no response is required. 22. Paragraph 22 states all legal conclusions to which no response is required. 23. No response is required to Paragraph 23. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in this matter in favor of the Plaintiff and against the Defendant. Respectfully submitted, Raym W. Kessler, Esquire PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Attorney for Plaintiff • II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, LLC, Plaintiff VS. : CIVIL-LAW MARK S. HENRY, : DOCKET NO. 14-426 Defendant CERTIFICATE OF SERVICE I, Raymond W. Kessler, Esquire, do hereby certify that on ft a 3, ,)2t I served a true and correct copy of Plaintiff's Response to New Matter by U.S. mail, first class, postage pre-paid, to Defendant's Attorney, being: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Raymo ¶W. Kessler, Esquire Attorney I.D. No.: 309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873