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Home My WebLink About14-1229 Supreme Cot;o 7 P.ennsylvania WWR0 30260291 C A Pit SJS O!f rT - - Court Common Pleas 0 it�COVersSheet ForPmthommy UseOaljt: C UMBERLAN c ,� County Docket No: The information collected on this form is used solely for court administration prlrposes. This form does not supplement or replace the filing and sett. ice of'pleadings or other papers as required b law or rules of coin Commencement of Action: S QI Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction 13 eclaration of Takin C DISCOVER BANK Lead Plaintiff's Name: Lead Defendant's Name: T CHRISTINA WHITE I 0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits N (check one) ❑ outside arbitration limits A Is this a Class Action Suit? 13 Yes 13 No Is this an MDJ Appeal? (3 Yes IB No Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437 ❑ Check here if you have no attorney (are a Self - Represented [Pro Se) Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Protection Administrative Agencies ❑ Malicious Prosecution Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E (3 Product Liability (does not include (3 Employment Dispute Mass tort) Discrimination C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: I ❑ Other: O N MASS TORT ❑ Asbestos B Cl Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Ejectment ❑ Common Law /Statutory Arbitration • Toxic Tort — Implant ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment • Toxic Waste ❑ Ground Rent ❑ Mandamus ❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Retraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Irnti0 +a.1 1 /1 Mn11 -0 F I_,.I�.. i- p CUMBERLAND COUNTY PE NNSYLVANIA F IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK �j c ut Plaintiff No: VS. COMPLAINT IN CIVIL ACTION CHRISTINA WHITE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: I William T. Molczan,4 WELTMAN, WEINBERG & CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412 - 338 -7130 30260291 C A Pit SJS. 1 i aWk4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No CHRISTINA WHITE Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 COMPLAINT_ 1. Plaintiff, Discover Bank, is a banking institution organized under the laws of the State of Delaware and maintains a business address of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Discover Bank, f /k /a Greenwood Trust Company, an FDIC - insured Delaware State bank. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the account to the attorneys and /or collection agencies for collection and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is the servicing affiliate for Discover Bank, in reference to Defendant's account, which is the subject of this litigation. 4. Defendant is an.adul.t individual(s) residing at 1020 BRIDGE ST APT B NEW- CUMBERLND, PA 17070 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3553. 6. Defendant made use of said credit card and has a current balance due of $2096.84. A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11 1". 7. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and /or refused to pay the balance due the Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, CHRISTINA WHITE, INDIVIDUALLY, in the amount of $2096.84 and costs. William T. Molczan, 437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412- 338 -7130 WWR# 302602.9.1...O.A_Pit:SJS PIK YER : Discover More Card Account number ending in 3553 Open Datec Oct 17 2013- Close Dote: Nov 16,'2013 Cordmember Since 2007 ACCOUNT SUMMARY PAYMENT INFORMATION Page 1 of 4 Previous Balance $2,025.32 ,I New Balance $2,09 Payments and Credits $0.00 Purchases t Minimum Payment Due' $660.00 $0.00 I Payment Due Date December 11, 2013 Balance Transfers $0.00 j Cash Advances + $0.00 " Includes past due amount of: $568.00 Fees Charged + $35.00 ! Late Payment Warning: If we do not receive your minimum payment by the Interest Charged + $36.52 date listed above, you may have to pay a late fee of up to $35.00 and your New Balance purchase and balance transfer APRs for new transactions may be increased u to $2,096.84 Y up to I the Penalty APR of 28.99% variable. See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each rana _Tsctions section for detailed APR information _ period, you will pay more in interest and it will take you longer to pay off your I Credit Line $1,500 balance. For example: j Credit Line Available $0 If ytip tnokc ttorrdWONdAd cftttrt)ryS Yak Will 1 ay4l4 Attdlrts[rwtlleetd u Cash Advance Credit Line W 5800 n.964ittirdand, hmontlt baiar es1toyrrtorstFtfis �rayir;ttrrrresfi 5 }atenl040rr abOLC'. of:,. Cash Advance Credit Line Available $0 Only the minimum payment b years $3,180 You may be able to avoid interest on Purchases. � See reverse for details. If you would like information about credit counseling services, call 1 -800 -347 -1 121. j � . REWARDS Contact Discover.com r .....—.........__........—........._ ............._................._............._._ ----- —......__.......... __......._.....__------ .._. -._. CashbuCk BCYI(/$® n Anniversary Month 1- 800 -347 -2683 I uly Opening Balance $ 0.00 Please make check payab!e to Discover. You are overlimii. New Cashback Bonus This Period + $ 0.00 Pay the sum of the Minimum Payment Due plus the remaining i Redeemed This Period — $ 0.00 overlimit amount of $596.84. Cashback Bonus Balance $ 0.00 To learn more, log in at Discover.com Make Check payable to Discover Please fold on the perforation below, detach and return with your payment NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION !} s4 of �01Jj3 n !� Puy 000 � 1 C1j/ }!y/ Phone. Account number ending in 3553 1 °f0as4 dew tat fold-, :cite Or', sfzr�le (ieover cam 1(}0 34��a83 Minimum Payment Due $660,00 I'i � I i ;n) ilill illii !I I l ilil "III lit iilill New Balance $2,096.84 Payment Due Date December 11, 2013 .................................._ ........__._......- ............ CHRISTINA WHITE _............- - - 1256 SUMMITVIEW CT Amount enclosed S NEW CUMBERLND PA 17070 -2200 . .. ............. . . ... _._._...__.........---....._- ...... -- ........... ----- .........._ . ........ . ...... _ ............. � PO BOX 71084 CHARLOTTE NC 28272 -1084 LI'II.I�ai irl i��lill.11l� ill; I ! d I 3026029rld Internet payments must be received by 5PM ET to' be credited as of the some day Address, e-mail or telephone changed ?.Note changes on reverse side 000001986458117213344020968400040000066000 CHRISTINA Account number ending in 3553 Open Dote: Oct 17, 2013 - Close Date: Nov 16, 2013 Page 2 of 4 . ... . .... . .... ........ . .... . ......... . ..... . ........ . . . . ...... . .............. . .. . ... ...... . ...... ............... Important Information You must ensure that sufficient funds are available in your bank account, and See your Cardmember Agreement. Your Cardmember Agreement all transactions must comply with U.S. low. contains oil the terms of your Account. You can set automatic payments for: (i) statement New Balance, (5) statement Lost or stolen cards. Report imme&atelyl Call 1 -800- 34'7-4683. Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed dollar amount, or (1v) Other dollar amount. If your scheduled "Other dollar What To Do If You Think You Find A Mistake On Your Statement amount" payment is not enough to cover the Minimum Payment Due as listed If you think there is an error on your statement, write to us at; Discover, PO on your monthly billing statement, your scheduled payment for that month Box 30421, Salt Lake City, UT 84130-0421. You must write to us within 60 will be increased to cover the Minimum Payment Due. If the scheduled days after the error appeared on your statement. You may call Z but if payment is greater than the Minimum Payment Due, any excess will be do we are not required to investigate any potential errors, and yo may ve heduled to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Cardmember Agreement. If your sc payment is greater than the New Balance on your billing statement, that rights- Please see your Cardmember Agreement or visit payment will be processed only for the amount of your New Balance. Your htips://discover.com/billingdghts for a copy of this notice. automatic payment amount may be less than the amount indicated on the Payments. You may pay all or part of your Account balance at anytime. billing statement based on credits or payments after the Close Date. However, you must pay at least the Minimum Payment Due by the Payment, If you enroll by phone in our automatic payment service, please fill-in the Due Date. Send only your payment and the bottom portion of this statement ]'allowing blanks below and retain the authorization for your records. in the envelope provided after affixing postage. Payments sent without proper postage will be returned to the sender. Do not send cash. If you pay by Amount: D ruii Pay_[] Min Pay _0 Min Pay+ check, you authorize us to use information on your check to make on electronic fund transfer from your account at the financial institution indicated 0 Other Amount$ Bank Routing #: on your check or to rocess the payment as a check transaction. If a payment is processed as on electronic fund transfer, the transfer will be for the amount Bonk Account # of the check. When we use information from your check to make an Monthly on the [I Payment Due Date L0 Close Date electronic: fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your Day of month (insert date) check back from your finandol institution. The processing of your payment may be delayed if you send cash, corres- Credit Reporting. We may report information about your Account to credit pondence or other items with your payments, if you send the payment to any bureaus. Late payments, missed payments, or other defaults on your Account other address, or if you use an envelope other than the one provided. may be reflected in your credit report. We normally report the status and Payments received in proper form at our processing facility by 5PM local time payment history of your Account to credit reporting agencies each month. If on any day will be credited to your Account as of that day. Payments received you believe that our report is inaccurate or incomplete, please write us at this at Our processing facility after 5PM local time will be credited to your Account address: Discover, PO Box 15316, Wilmington, DE 19850-5316. Please as of the next day. If you hove misplaced your envelope, send your payment include your name, address, home telephone number and Account number. to Discover, PO Box 6103, Carol Stream, IL 60197-6103. Please allow 7.10 days for delivery. If your payment is returned unpaid, we reserve the right to Paying Interest. Your due date is at least 25 days after the close of each resubmit it as an electronic debit. Payments made online or by phone will be billing period (at least 23 days for billing periods that begin in February). We credited as of the day of receipt if made by 5 PM Eastern time. will not charge you any interest on Purchases if you pay your entire balance by the due date each month. We will begin charging interest on Cash You can pay your monthly Minimum Payment Due, or a greater amount that Advances and Balance Transfers as of the later of the Transaction Date or the does not exceed your current Account balance, over the telephone or you can first day of the billing period in which the transaction posted to your Account. setup automatic payments through a customer service representative by calling 1-800-347-2683. Automatic payments for the billing period shown How We Calculate Interest Charges. We Use the Daily Balance Method on your statement will be deducted on the Payment Due Date shown on that (including current transactions) to calculate the Balance Subject to Interest statement, or the next automatic payment date referred to on your statement, Rate. For more information, please call us at 1-800-347-2683. unless you request a recurring payment date (e.g., the 15" day of the month) that occurs before your Payment Due Date or Close Dote. If your scheduled Balance Subject to Interest Rate. Your statement shows a Balance Subject payment date falls on a weekend or bank holiday, your payment will be to Interest Rafe. It shows this for each transaction category. The Balance Siulqject to Interest Rote is the average of the daily balances during the billing processed the business day prior to the weekend or bank holiday. In order to period. schedule monthly payments by telephone, you will need this statement and your bank account information. You will be asked to provide the lost four (4) Credit Balances. If your Account has a credit balance, the amount is shown digits of the social security number of the primary borrower. By providing on the front of your billing statement. A credit balance is money that is owed those numbers as your electronic signature, you will be agreeing to this to you. You may make charges against this amount if your Account is open. authorization to allow us and your bank to deduct each payment you We will send you a refund of any remaining balance of $ 1.00 or more after authorize, in the amount selected by you, from your bank account. You also 6 months, or as otherwise required by applicable low, or upon request made authorize us to initiate debit or credit entries to your bank account, as to the address in the Contact Us section on page 3 of your billing statement. applicable, to correct an error in the processing of such payment. You can cancel a scheduled payment by phone at 1-800-347.2683 or by mail at Balance Transfers. Balance Transfers are offered at our discretion and Discover, PO Box 30421, Salt Lake City, LIT 84130 -0421; however, we must accrue interest at the standard purchase rate unless we tell you otherwise. receive notice at least three business days in advance of the scheduled Discover may monitor and/or record telephone calls between you and payment. If your payments may vary in amount, we will tell you on each Discover representatives for quality assurance purposes. monthly billing statement when your payment will be made and how much it will be. The Discover@ card is issued by Discover Bank, Member FDIC. TL23N CHANGE OF ADDRESS If correct on front, do not use. Please print clearly in blue or black 'ink, in the space provided. Street Address I Home Phone .. . .......................................... . .......... .. . ........... . . .. . ........ . ...... Work Phone ....................... . ......... . . ....... . ............................. . . . .... . . . ................. . .............. .................... ........ . ............. . ........... . - ............ ............... . . . . ..... . . . ...... . . . . .............. City Email To make changes to your address, email or telephone number, visit Discover.com Continued on next page Discover More Card DISCVER Account number ending in 3553 Open Date: Oct 17, 2013 - Close Date: Nov 16, 2013 Page 3 of 4 CONTACT US . ......... . ......... . ......... - - ----------- - ---- - - - - - Web Mobile Phone Inquiry Mail Payments Access your Discover Manage your 1-800-DISCOVER Discover 10 171 Q 0 0 account securely account anytime, (1-800-347-2683) PO Box 3 0943 PO Box 6103 at Discover.com anywhere at TDD 1-800-347-7449 Salt Lake City Carol Stream m.Discover.com LIT 84130 IL 60197-6103_-------,/ Transactions Trans. Date Post Date Fees Nov 11 Nov 11 LATE FEE 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Charged INTEREST CHARGE ON PURCHASES $ 36,52 INTEREST CHARGE ON CASH ADVANCES 0.00 INTEREST CHARGE ON BALANCE TRANSFERS 0.00 TOTAL INTEREST FOR THIS PERIOD 36.52 2013 Totals Year -to -Date TOTAL FEES CHARGED IN 2013 S 256.34 TOTAL INTEREST CHARGED IN 2013 S 342.18 . . ... . ........ . . ......... . . ..... .... . ........... . ............ . . ..... . . ......... . . . ....... ....... . . . ..... . . ...... ... . . ........ . ....... . . . .......................... .... . .............. . .. - ....... . ........... ___ . . ..... I ... . .......... . .......... . . .... . . . ............ . ...... . ............. . ... . . ............ ........... Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Billing Period: 31 days ANNUAL PERCENTAGE•RATE BALANCE SUBJECT TO TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE Purchases 23-99% $1,229.78 $25.07 Expired Promotional Purchases Promotional APR 23,99% $562.27 $11.45 Cash Advances 28.99% WOO $0.00 V=Voriable Rate ..... . .. . ...... I ..... . ............... . .... ...... . ......... — ........... . . ...... . ...... . . ........ . .. . ............... . ........................... . ....... . . ...... . . .......... ....... ...... . ...... __ ......................... ...................... . ...... . - ------ . ........ — — ------------ _ . . . ...... . ............... . ........ . ............. . ....... . . . .......... Information For You For more information about how interest charges are calculated see your Cardmember Agreement or go to Yrww.discover.com/interestcharges ....................................... . . ......... . . . .............. . .... ... . . ....... .. . ............... . .......................... . .. . ................ . ........ . . ........... . ........................... .. . ..... . ............................... . ............... . ................ . — ....... . .......... . . . ..... .. . . ............... . ......... . . ................. .......... . ............... . . .... ... . . .......................... . ..................... . . . . ....... 30260291%r NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION ' CHRISTINA WHITE Account number ending_ in 3553 Oeen Date: Oct 17, 2013 -Close Date: Nov 16, 2013 Page 4 of 4 30260291' VERIFICATION (Name) (Title) of DB Servicing Corporation, servicing affiliate of Discover Bank does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities states, that he /she is a duly authorized representative of plaintiff herein. Additionally, he /she verifies that Discover Bank, fVa Greenwood Trust Company, which is an FDIC - insured Delaware state bank, lacks sufficient knowledge or information to verify this complaint. He /she verifies that he /she is authorized to make this verification. As an employee of DB Servicing Corporation, he /she has sufficient knowledge and information to make this verification, and consequently verifies that the facts set forth in the foregoing complaint are true and correct to the best of his/her knowledge and information and that he /she is personally familiar with the account and the relationship between Discover Bank and DB Servicing Corporation. It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank, including business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. _A� Date I� (Signat e DB Servicing Corporation servicing affiliate For Discover Bank Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY =, cit.T.,-Iiiiltit (Pr— ... c.. ..? .-,, ‘7, -0) ., .0..4 f") .w. r- --- 7- -T, < -0 3H = CO C:). i--1 --<.. OFtOFTF Discover Bank vs. Christina White Case Number 2014-1229 SHERIFFS RETURN OF SERVICE 03/04/2014 07:24 PM - Deputy Dawn Kell, 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: Christina White at 1020 Bridge Street, Apt, B, New Cumberland Borough, New Cumberland, PA 17070. v� DAWN KELL, DEPUTY SHERIFF COST: $47.21 SO ANSWERS, March 05, 2014 RONNJV R ANDERSON, SHERIFF (c) CcuntySuite Sheriff, Teleoseft, inc.. DISCOVER BANK Plaintiff VS. CHRISTINA WHITE TO THE PROTHONTARY: FILL:0-01:1'1U: OF THE PROTHONOTARY IN THE COURT OF COMMON PLEAS 2014APR 28 PM 1:52 CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CUMBERLAND COUNTY PENNSYLVANIA Civil Action No. 14-1229 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant CHRISTINA WHITE above named, in the default of an Answer, in the amount of $2096.84 computed as follows: Amount claimed in Complaint Less payments / adjustments made Attorney's fees TOTAL $2096.84 $0.00 $0.00 $2096.84 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. M�1czan4f7437 30260291 C A Pit S S Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 And that the last known address of the Defendant is : CHRISTINA WHITE 1020 BRIDGE ST APT B NEW CUMBERLND, PA 17070 (O. /9716 079 //s799‘/ Alt so &-.0 7s- kio A 4.00/ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTINA WHITE Defendant TO: CHRISTINA WHITE 1020 BRIDGE ST APT B NEW CUMBERLND, PA 17070 -1632 Date of Notice: Case No. 14 -1229 CIVIL 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249 -3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W. mbrodt P.A.I.D.# 4 `24 WELTMA EINBERG & REIS CO., L.P.A. 436 7th Ste 1400 Pittsbur.h PA 15219 Phone: 2) 434 -7955 (412) 7130 30260 91 A PIT M4Z DISCOVER BANK Plaintiff VS. CHRISTINA WHITE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 14-1229 CIVIL NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent.and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, CHRISTINA WHITE is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center. (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: CHRISTINA WHITE 1020 BRIDGE ST APT B NEW CUMBERLND, PA 17070 Affiant further states that the averments contained herein are true and correct to the best'of Affiant's knowledge, information and belief and that these averments are'made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. 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 /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: D9EBX9B070E3160 DISCOVER BANK Plaintiff VS. CHRISTINA WHITE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 14-1229 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee was entered against you on You are hereby notified that the fo wi/2yder of Judgment 11 I' (xx) Assumpsit Judgment in the amount of $2096.84 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary CHRISTINA WHITE 1020 BRIDGE ST APT B NEW CUMBERLND, PA 17070 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955