HomeMy WebLinkAbout14-3878 � 7
t
Supreme Court:c>~fPennsylvania
�,�" ,X
Coure6f Coinrnon_ Tleas For Protlwnotmy use only:
C Vil'00_Ve'.Sheet Docket No:
CUMBRLANCounty
The Information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and sen-ice ofpleadings or other pa ers as requited by lax,or rules of court.
Commencement of Action:
S 0 Complaint 0 Writ of Summons 0 Petition
Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiffs Name: Lead Defendant's Name:
CACH,LLC APRIL S BARRON
T IDollar Amount Requested: Owithin arbitration limits
I Are money damages requested? OYes 0 No (check one) []outside arbitration limits
O
N Is this a Class Aclion Suit? E3 Yes [2 No Is this an 11IDJAppeal? El Yes d No
A Name of Plaintiff/Appellant's Attorney: ALLAN C. SMITH,ESQ.
0 Check Dere if you have no attorney(are a Self-Represented (Pro Se]Litigant)
Nature of the Case: Place an"1'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.iudgments) CIVIL APPEALS
El Intentional [I Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution 0 Debt Collection:Credit Card 0 Board of Assessment
0 Motor Vehicle 0 Debt Collection:.Other 0 Board of Elections
]Nuisance Dept. of Transportation
Q Premises Liability 8 Statutory Appeal:Other
S Q Product Liability(does not include
❑Employment Dispute:
mass tort)
El SlanderlI.ibel/Defamation Discrimination
C 0 Other: 0 Employment Dispute: Other 0 Zoning Board
,r Other:
I 0 Other:
d MASS TORT
0 Asbestos
N E3 Tobacco
Q Toxic Tort-DES
Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
0 Toxic Waste
Other: 0 Ejectment 0 Common Law/Statutory Arbitration
B Eminent Domain/Condemnation 0 Declaratory Judgment
Ground Rent e Mandamus
Landlord/Tenant Dispute Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
0 Medical 0 Other:
0 Other Professional:
Updtded 11 2011
* Q 2 5 5 4 7 — C O M — 1 —
q t�
�tit
Law Firm of Allan C. Smith,P.0
Attorney ID 204756 i'! J1J/
1276 Veterans Highway C"I p"fE "'
Suite E-1 � < A
Bristol,PA X4 Co
(888)275-639919007S
888)275 63 90/(215)428-0666 `S�� 1 l uw Y
Attorney for Plaintiff
CACH,LLC ) COURT OF COMMON PLEAS
4340 SOUTH MONACO STREET 2ND ) CUMBERLAND COUNTY
FLOOR
DENVER,CO 80237 )
Plaintiff,
VS. ) No.: J
APRIL S BARRON )
118 LIGHTHOUSE DR )
MECHANICSBURG,PA 17050 )
COMPLAINT
To: APRIL S BARRON
118 LIGHTHOUSE DR
MECHANICSBURG,PA 17050
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 the court without further notice may enter
a judgment against you for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose 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 SOUTH BEDFORD STREET S
CARLISLE,PA 17013.
Telelphone: 249-3166 �a 63 7�I a
�6` s�
Cr `
AVISO
Le han dernandado a usted en is corte. Si usted quiere defenderse de estas demandas
expuestas en las pagins siguientes. Usted tiene veinte (20) dias de plaza al partir de la fecha de la
demanda y la notificacion. Hace falta asentar una comparencia excrita o en persons o con
abogado y entregar o sus objecciones a las demandas en contra de su persona. Se avisado que si
usted no se defiende. La corta tomara medidas y puede continuar la demada en contra suya sin
previo Avisa o notificion. Ademas la corte puede decidie a favor del demandante y requiere que
usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus
propiedas o otros derechos imporrantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO O SI NO TIENE .EL DINERO
SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSOAN O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO
PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
SERVICE DE REFERENCIA LEGAL
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013.
Telelphone: 249-3166
Plaintiff, CACH, LLC, by its attorney Allan C. Smith, Esq., by way of complaint against
Defendant APRIL S BARRON,avers the following:
1. Plaintiff, CACH, LLC, is a Colorado limited liability company doing business at 4340
South Monaco Street 2nd Floor, Denver, CO 80237.
2. Defendant, APRIL S BARRON, is an individual residing at 118 LIGHTHOUSE DR.,
MECHANICSBURG,PA 17050.
3. Plaintiff s cause of action is based upon a writing.
4. Defendant, APRIL S BARRON, was indebted to MBNA America,N.A.for a breach of
the written contract by and between them in the amount of$21,074.71 which balance was
due and unpaid as of March 30,2013,for credit card account number
5490353861746252. <Exhibit A>
5. Upon charge-off,the above account number was changed to 5490353998402209.
6. On or about April 24, 2013, FIA CARD SERVICES, N.A. sold the debt for good and
valuable consideration to plaintiff, CACH,LLC<Exhibit B>
7. The Defendant,April S Barron, last tendered a payment on 08/29/2012.
8. Pursuant to P.R.C.P Rule 1019(1), a copy of the controlling writing, the Card Member
Agreement, is not accessible to the Plaintiff at this time and is in the possession of the
third-party assignor of the debt to Plaintiff. Plaintiff has a reasonable and good faith
belief that said writing can be produced to Defendant during discovery or prior to trial.
9. Plaintiff is entitled to charge-off account finance charges of$0.00. <Exhibit A>
10. Plaintiff is entitled to pre-litigation charge-off interest of $0.0000 per day from the
default date ( 0.000% annual percentage rate x $21,074.71/365 days)or$0.0000 x 600
days = $0.00; which is accrued interest through the date of filing. <Exhibit A> Plus an
award of late fees 0.00, court costs $203.75 and reasonable attorneys fees as stated in the
Cardholder Agreement.
11. The defendant, being indebted to the plaintiff upon the account by and between them did
promise to pay said sums upon demand. Demand has been made for payment and the
defendant has failed to remit payment.
WHEREFORE, plaintiff demands judgment against the defendant for $21,278.48 which
includes interest, court costs, and a prayer to the court for reasonable attorney's fees, should this
matter be contested or go to default judgment.
Date: May 19,2014
llan C.Smith,Esq.
7
EXHIBIT A
Bankof America
APRIL S BARRON
Account Number:5490 3538 6174 6252
March 21-April 18,2012
Account Information:
www.bankofamerica.com
Mail billing inquiries to: New Balance Total...................................................................$18,467.20 Previous Balance......................$17,732.70
Bank of America Current Payment Due...............................................................:....$548.00 Payments and Other Credits....................0.00
P.O.Box 982235 Past Due Amount...........................................:..................:...........$549.00 Purchases and Adjustments................366.85
El Paso,TX 79998-2235 Fees Charged.................................................35.00
Mail payments to: Total Minimum Payment Due.......................................................$1,097.00 Interest Charged..........................................332.65
Bank of America Payment Due Date............... ..... /16/12
P.O.Box 15019 New Balance Total......................$18,467.20
Wilmington,DE 19886-5019 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 and Total Credit Line..........................$18,200.00
1.800.789.6701 your APRs may be increased up to the Penalty APR of 29.99%. Total Credit Available. .........................$0.00
Total Minimum Payment Warning:If you make only the Total Minimum Cash Credit Line...........................$5,500.00
(1.800.346.3178 TM Payment each period,you will pay more in interest and it will take you longer Portion of Credit Available for Cash........$0.00
to pay off your balance. For example: Statement Closing Date...................4/18/12
y $,, Days in Billing Cycle.....................:............29
a o a a« o a s a
Only the Total 35 years $53,034.80
Minimum Payment
If you would like information about credit counseling services,call
1-866-300-5238.
Transaction Posting Reference Account
Date Date Description Number Number Amount Total
Purchases and Adjustments
03/26 03/27 SHOE DEPT 0443 CAMP HILL PA 2664 6252 9.97
03/28 03/29 HERSHEY MED/DERMATOLOG HERSHEY PA 0158 6252 40.00
03/29 03/30 TARGET 00022020 MECHANICSBURGPA 2666 6252 44.45
04/09 04/10 WEGMANS#45 MECHANICSBURGPA 1412 625210.87
04/14 04/16 RAMADA INN LEVITTOWN LEVITTOWN PA 0100 6252 261.56
ARRIVAL DATE 4/09/12
$366.85
16 : 0184672000109700001104000005490353861746252
BANK OF AMERICA Account Number:5490 3538 6174 6252
P.O.BOX 15019
WILMINGTON,DE 19886-5019 $18,467.20
New Balance Total........................................................
Total Minimum Payment Due...............................................1,097.00
Payment Due Date ...................................................05/16/12
APRIL S BARRON Enter payment amount "$3
118 LIGHTHOUSE DR
MECHANICSBURG PA 17050-2442 '
Check here for a change of mailing address or phone numbers.
Please provide all corrections on the reverse side.
Mail this coupon along with your check payable to:Bank of America
1: 524022250,: L5883136L74625DO
X �
IMS PORTANT INFORMATION ABOUT THIS ACCOUNT USE711 Rev.06/11
CUSTOMER TIPS FOR DISPUTED ITEMS ONLINE
Manytimes disputed charges are legitimate charges that customers maynotrecognize Online Banking is available 24 hours a day,7 days a weekand
orremember.Before disputing a charge,we recommend that you verify a few things allows you to view the most recent activity onyour account.
and.make every effort to resolve the dispute with the merchant.Often the merchant can
answer your questions and easily resolve your dispute.The merchant's phone number
may be located on your receipt or billing statement. PHONE
• Has a credit posted to your account? 1.866.266.0212
Please allow up to 30 days from the date on your credit voucher or For prompt service,please have the merchant reference number(s)
acknowledgement letter for the merchant credit to post. available for the chaxge(s)in question.
• Is the charge or amount unfamiliar?
Check with other persons authorized to use the account to make sure they
did not make the charge.It is possible that the merchants'billing names ,�,�.�i
and store names are different or amounts can easily be confused with similar MAIL
charges or include tips. , Attn:Billing Inquiries PO Box 982235,E1 Paso,TX 79998
One way to check for the credits or to view transaction details is to look at your When writing,please include Your Name,Account Number,the
account statements online.If you are not enrolled in Online Banking,it is easy to Disputed Amount,Merchant Name,Transaction Date,and
reference number of the disputed item and specific details regarding
enroll usingthe web address on the front of your statement or give us a call. your dispute,including dates of contact with the merchant and the
Please remember-If you find an error on your bill,you must notifyus no later than merchant's response in each instance.Please include all supporting
60 days afterwe sent your first statement onwhich the error or problem appeared documentation,including sales and creditvouchers,contract and
to preserve your billing rights. postage return receipts as proof of any returns.
PAYING INTEREST TOTAL INTEREST CHARGE COMPUTATION
We will not charge interest on Purchases on the next statement if you pay the New Interest Charges accrue and are compounded on a daily basis.To determine the
Balance Total in full by the Payment Due Date,and you had paid in full by the previous Interest Charges we multiply each Balance Subject.to Interest Rate by its applicable Daily
Payment Due Date.We will begin charging interest on Balance Transfers and Cash Periodic Rate and that result is multiplied by the number of days in the billing cycle.To
Advances on the transaction date. determine the total.Interest Charge for the billing cycle,we add the Periodic Rate Interest
CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Charges together.A Daily Periodic Rate is calculated by dividing an Annual Percentage
Average Daily Balance Method(including new.Purchases): Rate by 365.
We calculate separate Balances Subject to an Interest Rate for Purchases and for HOW WE ALLOCATE YOUR PAYMENTS
each Introductory or Promotional Offer balance consisting of Purchases.We do this by: If your account has balances with different APRs,we will allocate the amount of
(1)calculating a daily balance for each day in the billing cycle;(2)adding all the daily your payment equal to the Total Minimum Payment Due to the lowest APR balances first
balances together;and(3)dividing the sum of the daily balances by the number of days (including transactions made after this statement).Payment amounts in excess of your
in the billing cycle. Total Minimum Payment Due will be applied to balances with higher APRs before balances
To calculate the dailybalance for each day in this statement's billing cycle,we:(1) with lower APRs.
take the beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE
multiplied by the previous day's daily balance;(3)add new Purchases,new Account Fees, When using the optional Pay-by-Phone service,you authorize us to initiate an
and new Transaction Fees;and(4)subtract applicable payments and credits.If any daily electronic payment from your account at the financial institution you designate.You must
balance is less than zero we treat it as zero. aaithorize the amount and timing of each payment.For,your protection,we will ask for
Average Balance Method(including new Balance Transfers and new Cash Advances): security information.A fee may apply for expedited service.To cancel,call us before the
Subject to an Interest Rate for Balance Transfers, scheduled payment date.Same-day payments cannot be edited or canceled.
We calculate separate Balances Sub
1 YOUR CREDIT LINES
Cash Advances,and for each Introductory or Promotional Offer balance consisting of The Total Credit Line is the amount of credit available for the account;however,only a
Balance Transfers or Cash Advances.We do this by:(1)calculating a daily balance for each portion of that is available for Bank Cash Advances.The Cash Credit Line is that amount
day in this statement's billing cycle;(2)calculating a daily balance for each day=prior to this you have available for Bank Cash Advances.Generally,Bank Cash Advances consist of
statement's billing cycle that had a"Pre-Cycle balance"—a Pre-Cycle balance is a Balance ATM Cash Advances,Over the Counter(OTC)Cash Advances,Same-Day Online Cash
Transfer or a Cash Advance with atransaction(fate prior to this statement's billing Advances,Overdraft Protection Cash Advances,Cash Equivalents,Returned Payments,
cycle but with a posting date within this statement's billing cycle;(3)adding all the daily and applicable transaction fees.
balances together;and(4)dividing the amn of the daily balances by the nutuber of days in MISCELLANEOUS
this statement's billing cycle. —Promotional Rate End Date:This date is based on a future statement closing date.
To calculate the daily balance for each day in this statement's billing cycle,we:(1) If you change your payment due date,this date could change.Transactions must meet
take the beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate offer conditions in order to qualify for the promotional rate.
multiplied by the previous day's daily balance;(3)add new Balance Transfers,new Cash For the complete terms and conditions of your account,consult your Credit Card
Advances and Transaction Fees:and(4)subtract applicable payments and credits.If any Agreement.FIA Card Services is a tradename of FIA Card Services,N.A.This account
daily balance is less than zero we treat it as zero. is issued and administered by FIA Card Services,N.A.
To calculate a daily balance for each day prior to this statement's billing cycle that
had a Pre-Cvcle balance;(1)we take the beginning balance attributable solely to Pre-Cycle
balance(which will be zero on the transaction date of the first.Pre-Cycle balance);(2)
add an amount equal to the applicable Daily Periodic Rate multiplied by the previous
(lay's daily balance;(3)and add only the applicable Pre-Cycle balances and their related
Transaction Fees.We exclude from this calculation all transactions posted in previous
billing cycles,
PAYMENTS If your billing address or contact information has changed,or if your address is
We credit mailed payments as of the date received,if the payment is:(1)received by
5 p.m.local time at the address shown on the remittance slip on the front of your monthly incorrect as it appears on this bill,please provide all corrections here.
statement;(2)paid with a check drawn in U.S.dollars on a U.S,financial institution or
a U.S.dollar money order;and(3)sent in the return envelope with only the remittance Address 1
portion of your statement accompanying it.Payments received by mail after 5 p.m.local time at the.remittance address on any day including the Payment Due Date,but that
otherwise meet the above requirements,will be credited as of the next day.Payments Address 2
made online or by phone will be credited as of the date of receipt if made by5 p.m.Central. --
Credit for any other payments may be delayed up to five days. ■
No payment shall operate as an accord and satisfaction without the prior written
approval of one of our Senior Officers. City _
We process most payment checks electronically by usingthe information found on
your check.Each check authorizes us to create a.one-time electronic funds transfer(or
process it as a check or paper draft).Funds may be withdrawn from,your account as State Zip___._, _
soon as the same clay we receive your payment.Checks are not returned to you. Area Code&
For more information or to stop the electronic funds transfers,call us at the Home Phone
number listed on the front. —
If you have authorized us to payyour credit card bill automatically from your savings Area Code&
or checking account with us,you can stop the payment on any amount.you think is Work Phone
wrong.To stop payment,your letter must reach us at least three business days before
the automatic payment is scheduled to occur.
Bankof America
5490 3538 6174 6252
March 21-April 18,2012
Page 3 of 4
rransaction Posting Reference Account
Date Date Description Number Number Amount rota/
Fees
04/16 04/16 LATE FEE FOR PAYMENT DUE 04/16 8099 35.00
TOTAL FEES FOR THIS PERIOD $35.00
Interest Charged
04/18 04/18 Interest Charged on Purchases 330.09
04/18 04/18 Interest Charged on Balance Transfers 2.56
04/18 04/18 Interest Charged on Dir Dep&Chk CashAdv 0.00
04/18 04/18 Interest Charged on Bank Cash Advances 0.00
TOTAL INTEREST FOR THIS PERIOD $332.65
Total fees charged in 2012 $70.00
Total interest charged in 2012 $1,423.69
i_ s -
Thank you for being a valued customer.We have not received your payment.Please make your payment today or if you need assistance,please contact us at
the number listed above.
Your statement balance exceeds the Total Credit Line.To ensure uninterrupted use of your account,please make a payment to bring your balance under the
Total Credit Line.There is no fee for being over your Total Credit Line.
Please review your enclosed annual"Billing Rights"and"Privacy Notice"information for your account.You can also review this information online if you have
registered your account in online banking.
OVERDRAFT PROTECTION
What You Should Know:
If your Bank of America®checking account was opened in Washington or Idaho and is linked to this credit card account for Overdraft Protection,we'll
transfer money in increments of$100-previously set at$25.For example,if the overdraft amount was$15,starting on August 18,2012,we will now transfer
$100 from this account to your Bank of America checking account to cover the overdrawn amount.
We're not changing the amount of the fee for Overdraft Protection Cash Advances.
Remember,Overdraft Protection is an optional service that you can cancel at any time through online banking,or by calling us or visiting a banking center.
Amendment to Your Credit Card Agreement:
Effective August 18,2012,the Overdraft Protection section of your agreement is amended by deleting the phrase"$25 if you opened your checking account in
Washington or Idaho;%
s
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Promotional Promotional Promotional Balance Interest
Percentage Transaction Offer ID Rate End Subject to Charges by
Rate Type Date Interest Transaction
Rate Type
Purchases 23.24%V $17,876.80 $330.09
Balance Transfers 23.24%V $ 138.66 $ 2.56
Direct Deposit and Check Cash 23.24%V $ 0.00 $ . 0.00
Advances
Bank Cash Advances 23.248V $ 0.00 $ 0.00
APR Type Definitions:Daily Interest Rate Type:V=Variable Rate(rate may vary)
ra^
w -
With Bank of America's secure Mobile Banking,you have the flexibility to bank from your smartphone or tablet anytime,anywhere.To download the free
Mobile Banking App,visit:bankofamerica.com/onthego
Discover the convenience of paperless statements:enjoy easy organization of your account statements,review your statement and transactions sooner,and
reduce your risk of mail fraud and identity theft-all while taking another step towards a greener lifestyle.Simply sign in to your online banking account at
www.bankofameriba.com and click the green leaf"go paperless"icon to get started.
■
Bankof America
APRIL S BARRON
Account Number:5490 3538 6174 6252
August 21-September 19,2012
Account Information: _
www.bankofamerica.com
p
Mail billing inquiries to: New Balance Total...................................................................$18,572.56 Previous Balance......................$17,987.96
Bank of America Current Payment Due.....................................................................$563.00 Payments and Other Credits..............—525.00
P.O.Box 982235 Past Due Amount..........................................................................$547.00 Purchases and Adjustments.................728.01
El Paso,TX 79998.2235 Fees Charged.................................................35.00
Mail payments to: Total Minimum Payment Due.......................................................$1,110.00 Interest Charged........:.................................346.59
Bank of America Payment Due Date.......................................... ...10/16/12
P.O.Box 15019 New Balance Total......................$18,572.56
Wilmington,DE 19886-5019 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 and Total Credit Line..........................$18,200.00
1.800.789.6701 your APRs may be increased up to the Penalty APR of 29.99%. Total Credit Available............................$0.00
Total Minimum Payment Warning:If you make only the Total Minimum Cash Credit Line...........................$5,500.00
(1:800.346.3178 TTY) Payment each period,you will pay more in interest and it will take you longer Portion of Credit Available for Cash........$0.00
to pay off your balance. For example: Statement Closing Date...................9/19/12
Days in Billing Cycle..................................30
s • � xa
Only the Total 35 years $53,348.38
Minimum Payment
If you would like information about credit counseling services,call
1-866-300.5238.
LEN
Transaction Posting Reference Account
Date Date Description Number Number Amount Total
Payments and Other Credits
08/29 PAY BY PHONE PAYMENT 4811 —525.00
—$525.00
Purchases and Adjustments
08/31 09/01 PLN PRICELINE.COM HTL 800-657-9168 CT 7877 6252 457.11
ARRIVAL DATE 8/31/12
09/12 09/13 WEGMANS#45 MECHANICSBURGPA 4248 6252 67.26
09/12 09/14 TURKEY HILL#280 ENOLA PA 1726 6252 97.33
09/13 09/14 MCDONALD'S F22804 MECHANICSBURGPA 9362 6252 3.92
continued on next page...
16 0185725600111000000525000005490353861746252
BANK OF AMERICA Account Number: 5490 3538 6174 6252
P.O.BOX 15019
WILMINGTON,DE 19886-5019
New Balance Total.........................................................$18,572.56
Total Minimum Payment Due..............................................1,110.00
Payment Due Date ...................................................10/16/12
APRIL S BARRON Enter payment amount $ 4 {
118 LIGHTHOUSE DR t
MECHANICSBURG PA 17050-2442 `
Check here for a change of mailing address or phone numbers.
Please provide all corrections on the reverse side.
Mail this coupon along with your check payable to:Bank of America
1: 5 240 2 2 2501: 1588386 1746 2S 2112
IMPORTANT INFORMATION ABOUT THIS ACCOUNT USE711 Rev.06/11
CUSTOMER TIPS FOR DISPUTED ITEMS
ONLINE
Many times disputed charges are legitimate charges that customers may not recognize Online Banking isavailable 24hours aday,7days aweekand
or remember.Before disputing a charge,we recommend that you verify a few things allows you to view the most recent activity on your account.
and make every effort to resolve the dispute with the merchant.Often the merchant can
answer your questions and easily resolve your dispute.The merchant's phone number
may be located on your receipt or billing statement. PHONE
• Has a credit posted to your account? 1.866.266.0212
Please allow up to 30 days from the date on your credit voucher or ( For prompt service,please have the merchant reference number(s)
acknowledgement letter for the merchant credit to post. available for the charge(s)in question.
• Is the charge or amount unfamiliar?
Check with other persons authorized to use the account to make sure they
did not make the charge.It is possible that the merchants'billing names
and store names are different or amounts can easily be confused with similar MAIL
charges or include tips. Attn:Billing Inquiries PO Box 982235,El Paso,TX 79998
One ay to check For the credits or to view transaction details is to look at your When writing,please include Your Name,Account Number,the
wayaccount statements online.If you are not enrolled in Online Banking,it is easy to ® Disputed Amount,Merchant Name,Transaction Date,and
reference number of the disputed item and specific details regarding
enroll using the web address on the front of your statement or give us a call.
your dispute,including dates of contact with the merchant and the
Please remember:If you find an error on your bill,you must notify us no later than merchant's response in each instance.Please include all supporting
60 days afterwe sentyour first statement on which the error or problem appeared documentation,including sales and credit vouchers,contract and
to preserve your billing rights. postage return receipts as proof of any returns.
PAYING INTEREST TOTAL INTEREST CHARGE COMPUTATION
We will not charge interest on Purchases on the next statement if you pay the New Interest Charges accrue and are compounded on a daily basis.To determine the
Balance Total in full by the Payment Due Date,and,you had paid in full by the previous Interest Charges we multiply each Balance Subject to Interest Rate by its applicable Daily
Payment Due Date.We will begin charging interest on Balance Transfers and Cash Periodic Rate and that result is multiplied by the number of days in the billing cycle.To
Advances on the transaction date. determine the total Interest Charge for the billing cycle,we add the Periodic Rate Interest
CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Charges together.A Daily Periodic Rate is calculated by dividing an Annual Percentage
Average Daily Balance Method(including new Purchases): Rate by 365.
We calculate separate Balances Subject to an Interest Rate for Purchases and for HOW WE ALLOCATE YOUR PAYMENTS
each Introductory or Promotional Offer balance consisting of Purchases.We do this by: If your account has balances w th different APRs,we will allocate the amount of
(1)calculating a daily balance for each day in the billing cycle;(2)adding all the daily your payment equal to the'rotal Minimum Payment Due to the lowest APR balances first
balances together;and(3)dividing the sum of the daily balances by the number of clays (including transactions made after this statement).Payment amounts in excess of your
in the billing cycle. Total Minimum Payment Due will be applied to balances with higher APRs before balances
To calculate the dailybalance for each day in this statement's billing cycle,we:(1) with lower APRs.
take the beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE
multiplied by the previous day's daily balance;(3)add new Purchases,new Account Fees, When using the optional Pay-by-Phone service,you authorize us to initiate an
and new Transaction Fees;and(4)subtract applicable payments and credits.If any daily electronic payment from your account at the financial institution you designate.You must
balance is less than zero we treat it as zero, authorize the amount and timing of each payment.For your protection,we will ask for
Average Balance Method(including new Balance Transfers and new Cash Advances): security information.A fee may apply for expedited service.To cancel,call us before the
6 g scheduled payment date.Same-day payments cannot be edited or canceled.
We calculate separate Balances Subject to an Interest Rate for Balance Transfers, YOUR CREDIT LINES
Cash Advances,and for each Introductory or Promotional Offer balance consisting of The Total Credit Line is the amount of credit available for the account;however,only a
Balance Transfers or Cash Advances.We do this by:(1)calculating a daily balance for each portion of that is available for Bank Cash Advances.The Cash Credit Line is that amount
day in this statement's billing cycle;(2)calculating a daily balance for each day prior to this you have available for Bank Cash Advances.Generally,Bank Cash Advances consist of
statement's billing cycle that had a"Pre-Cycle balance"—a Pre-Cycle balance is a Balance- ATM Cash Advances,Over the Counter(OTC)Cash Advances,Same-Day Online Cash
Transfer or a Cash Advance with a transaction date prior to this statement's billing Advances,Overdraft Protection Cash Advances,Cash Equivalents,Returned Payments,
cycle but with a posting date within this statement's billing cycle;(3)adding all the daily and applicable transaction fees.
balances together;and(4)dividing the sum of the daily balances by the number of days in MISCELLANEOUS
this statement's billing cycle. —Promotional Rate End Date:This date is based on a future statement closing date.
To calculate the dailybalance for each day in this statement's billing cycle,we:(1) If you change your payment due date,this date could change.Transactions must meet
take the beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate offer conditions in order to qualify for the promotional rate.
multiplied by the previous day's daily balance;(3)add new Balance Transfers,new Cash For the complete terms and conditions of your account,consultyour Credit Card
Advances and Transaction Fees;and(4)subtract applicable payments and credits.If any Agreement.FIA Card Services is a tradename of FIA Card Services,N.A.This account
dailybalance is less than zero we treat it as zero. is issued and administered by FLA Card Services,N.A.
To calculate a,daily balance for each day prior to this statement's billing cycle that
had a Pre-Cycle balance;(1)we take the beginning balance attributable solely to Pre-Cycle
balance(which will be zero on the transaction date of the first Pre-Cycle balance);(2)
add an amount equal to the applicable Daily Periodic Rate multiplied by the previous
clay's daily balance;(3)and add only the applicable Pre-Cycle balances and their related
Transaction Fees.We exclude from this calculation all transactions posted in previous
billing cycles,
PAYMENTS If your billing address or contact information has changed,or if your address is
We credit mailed payments as of the date received,if the payment is:(1)received by
5 p.m.local time at the address shown on the remittance slip on the front of your monthly incorrect as it appears on this bill,please provide all corrections here.
statement;(2)paid with a check drawn in U.S.dollars on a U.S.financial institution or
a U.S.dollar money order;and(3)sent in the return envelope with only the renuttance
portion of your statement accompanying it.Payments received by mail after 5 p.m.local Address 1
time at the remittance address on any day including the Payment Due Date,but that
otherwise meet the above requirements,will be credited as of the next day.Payments Address 2
made online or by phone will be credited as of the date of receipt if made by5 p.m.Central, —
Credit for any other payments may be delayed up to five days. ■
No payment shall operate as an accord and satisfaction without the prior written
approval of one of our Senior Officers. City
We process most payment checks electronically by usingthe information found on
,your check.Each check authorizes us to create a one-time electronic funds transfer(or
process it as a check or paper draft).Funds may be withdrawn from your account as State
soon as the same day we receive your payment.Checks are not returned to you. Area Code&
For more information orto stop the electronic funds transfers,can us at the Home Phone
number listed on the front.
If you have authorized us to payyour credit card bill automatically from your savings
or checking account with us,you can stop the payment on any amount you think is Area Code
wrong.To stop payment,your letter must reach us at least three business days before Work Phone
the automatic payment is scheduled to occur.
Bankof America
5490 3538 6174 6252
August 21-September 19,2012
Page 3of4
Transaction Posting Reference Account
Date Date Description Number Number Amount Tota/
Purchases and Adjustments
09/13 09/14 LITTLE CAESARS MECHANICSBURGPA 7165 6252 9.54
09/14 09/14 COMCAST OF CENTRAL PA 800-COMCAST PA 3835 6252 14.95
09/13 09/15 KOHL-MERCHANICSBURG MECHANICSBURGPA 0190 6252 17.90
09/14 09/15 EXXONMOBIL 45461498 MECHANICSBURGPA 6994 6252 60.00
$728.01
Fees
09/16 09/17 LATE FEE FOR PAYMENT DUE 09/16 8190 35.00
TOTAL FEES FOR THIS PERIOD $35.00
Interest Charged
09/19 09/19 Interest Charged on Purchases 346.59
09/19 09/19 Interest Charged on Balance Transfers 0.00
09/19 09/19 Interest Charged on Dir Dep&Chk CashAdv 0.00
09/19 09/19 Interest Charged on Bank Cash Advances 0.00
TOTAL INTEREST FOR THIS PERIOD $346.59
•vy '
Total fees charged in 2012 $234.00
Total interest charged in 2012. $3,187.12
Thank you for being a valued customer.We have not received your payment.Please make your payment today or if you need assistance,please contact us at
the number listed above.
Your statement balance exceeds the Total Credit Line.To ensure uninterrupted use of your account,please make a payment to bring your balance under the
Total Credit Line.There is no fee for being over your Total Credit Line.
BMW-
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Promotional Promotional Promotional Balance interest
Percentage Transaction Offer ID Rate End Subject to Charges by
Rate Type Date Interest Transaction
Rate Type
Purchases 23.248V $18,145.01 $346.59
Balance Transfers 23.248V $ 0.00 . $ 0.00
Direct.Deposit and Check Cash 23.24%V $ 0.00 $ 0.00
Advances
Bank Cash Advances 23.24%V $ 0.00 $ 0.00
APR Type Definitions:Daily Interest Rate Type:V=Variable Rate(rate may vary)
Want flexibility to bank on your smartp hone or tablet?Download Bank of America's free Mobile Banking App:Text APP1 to 226526.Must first enroll in Online
Banking.Supported carriers include:Alltel,AT&T,•Cellular One,T-Mobile;Virgin Mobile,US Cellular,Verizon Wireless.Wireless fees may apply.Text STOP to
cancel and HELP for help to 226526.
� � r
Discover the convenience of paperless statements:enjoy easy organization of your account statements,review your statement and transactions sooner,and
reduce your risk of mail fraud and identity theft-all while taking another step towards a greener lifestyle.Simply sign in to your online banking account at
www.bankofamerica.com and click the green leaf"go paperless"icon to get started.
■
EXHIBIT B
CERTIFICATE OF PURCHASE
1. _ PETER € �}111:31E hereby depose and state that:
1. 1 am an Authorized Agent of CACH, LLC,a Colorado Limited Liability Company.
2. As such, I am authorized to give this Certificate,and possess sufficient personal
knowledge to do so regarding:
Customer Name: APRIL S BARRON
Original Creditor: MBNA America, N.A.
Account Number: 5490353861746252
3. On or about April 24,2013 this account was sold by the creditor. CACH, LLC is the
current owner of the account and purchased 1he account for good and valuable
consideration.
Date: tl
r
>� < ,
�i
Sworn and subscribed to before
me this day of "n
NOtaly Public
r`-, �-
BankofAmericaer.
EXHIBIT C
BILL OF SALE AND A►SLG IMEN1 OF LQANS
THIS BILL OF SALE AND ASSIGNMENT OF LOANS is made and entered into between CACH, LLC
("egg")and RIA CARD SERVICES, N.A.("W'), pursuant to the Loan Sale Agreement dated April
13, 2013 (the "A&MgMW") entered into between Purchaser and Seller. Capitalized terms not defined herein.
shall have the same meaning as defined in the Agreement.
(a) In consideration of the payments made pursuant to the Agreement and such other good and valuable
consideration,the receipt and legal sufficiency of which are hereby acknowledged,Seller does hereby sell,transfer,
convey,assign and deliver to Purchaser all of Seller's right,title and interest in and to each and all of the Loans,as
included an the electronic file referenced in Schedule I of the Loan Agreement as BAC Fresh SgTwo Sale File
0413 Final.xlsx,without recourse and without representation or warranty of any type,kind,character or nature,
express or implied,except as specifically provided in the Agreement,and subject to Buyer's and Seller's repurchase
rights as set forth in the Agreement.
(b) Purchaser hereby accepts such sale,transfer,conveyance,assignment,and delivery of the Loans,including
without limitation the right to all principal.interest or other proceeds of any kind with respect to the Loans
remaining due and owing as of the Cut-Off Date applicable to such Loans.
(c) Nothing in this Bill of Sale and Assignment of Loans shall be deemed to modify,limit or amend any of the
rights or obligations of Purchaser or Seller under the Agreement. This Bill of Sale and Assignment of Loans shall
inure to the benefit of,and be binding upon,the respective,permitted successors and assigns of Seller and Purchaser
and shall be governed by and construed and interpreted in accordance with the Agreement and the laws of the State
of Delaware,without regard to such state's principles of conflicts of law.
(d) This Bill of sale and Assignment of Loans may be executed by facsimile or electronic transmission in
multiple counterparts,each of which shall be an original,but together shall constitute one and the same instrument.
IN WITNESS WHEREOF,each parry,through its duly authorized officer,has caused this Bill of Sale and
Assignment of Loans to be executed in their name this 25ib day of April,2013.
SELLER/ASSIGNOR:. BUYERIASSIGNEE:
FIA CARD SERVICES, ,A. CACH,LLC
By: By;
Name: Debra LFA licciaro Name:
Title: Vice President Title:
Nlur::91rt.4Llt 114:IN
Fresh 4/15/13 RokdAlnrrini Amart%4-a
IlN•rfO41 III,Ilii IL4v-r Hilt IWmL.N4-i L IW- t9711
AFFIDAVIT OF SALE AND CERTIFICATION OF DEBT
STATE OF NORTH CAROLINA ) i
)
CITY OF GREENSBORO )
FIA Card Services,N.A.
i
Accountholder:APRIL S BARRON Account No(s),5490353998402209,5490353861746252
The undersigned,Tracy Hopkins,being duly sworn,states and deposes as follows:
1. That Affiant is employed by FIA Card Services,N.A.in the position of Bank Officer,has personal knowledge of
the manner and method by which FIA Card Services,N.A.maintains its normal business book and records,and is
duly authorized to make this affidavit.
2. That the contents of this affidavit are believed to be true and correct based on the computerized and hard copy
books and records of FIA Card Services,N.A.,maintained in the ordinary course of business,with the entries in
them having been made at or near the time of the transaction recorded.
3. That FIA Card Services,N.A.is a wholly owned subsidiary of Bank of America Corporation and is successor in
interest to MBNA America Bank NA,Fleet'Bank(RI),and Bank of America,National Association(USA),
4. That the account records of FIA Card Services,N.A.show that:
I
a. Account number 5490353998402209,formerly account number 5490353861746252,was opened on
06/30/2003 by APRIL S BARRON.
b. Pursuant to the terms of the card member agreement with FIA Card Services,N.A,there was due and
payable 521074.71 as of the charge off date of 03/30/2013.
C. Said agreement and account was,on 04/22/2013,sold,transferred and set over unto CACH,LLC,with
full authority to do and perform all acts necessary for collection,settlement,adjustment,compromise or
satisfaction of the said claim,and as of that date,there was due and payable on this Account the sum of
$21074.71,with all just and lawful offsets,payments,and credits having been allowed.
d. There were no uncredited,payments,just counterclaims or offsets against said debt when sold.
5. That as a result of the sale of said account,CACH,LLC and/or its authorized Agent,has complete authority to
settle,adjust,compromise and satisfy same,and that FIA Card Services,N.A.has no further interest in the account
for any purpose.
6. That the original contract in this matter may not be available,or no longer accessible to Affiant.
DATED THIS____day of JAN 15 =2014
FIA Card Services,N.A.
By:
Bank Officer
Subscribed and sworn to before me this day of JAN 15 201 2014
My commission expires: �L
Notary Seal aaaaaaaa�a,fill f"'t"Io
-Nato A A,9
ci
Z,A.�oSAR1-
AUBL�G; C.
",'At lU l{ula'�a
1630—CACH,Ll_C_1/14/2014
A ) t
VERIFICATION
I, PSR °:U, 3 hereby depose and state that:
The language of the foregoing document is that of counsel and not necessarily my own;
however, I have read the foregoing document and the factual information contained therein
is true and correct to the best of my personal knowledge.
I am the Authorized Representative and a duly authorized representative of the plaintiff;
The factual allegations set forth in the foregoing pleading are true and correct to the best of
my knowledge, information and belief, and they are that APRIL S BARRON owes the
balance of $21,074.71 to CACH, LLC on previously submitted invoices, which balance is
due and unpaid as if the date of the execution of this Verification.
I am aware that if any of the foregoing is willfully false, I am subject to punishment.
I understand that false statements made herein are subject to the penalties relating to
unsworn falsification to authorities.
By: e s
F
Dated:_ ItJN 0 20-14
Authorized Representative
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ,,.` ' f
ov 01 Comber,
ok
Jody S Smith
Chief Deputy $ ` _ '
#,-'. to
Richard W Stewart ,_`MBERLA n 1 i, J .'„ .
Solicitor :,,,• .:.,gra. F.R1FC— PENNSYLVANIA
CACH, LLC
vs. Case Number
April S Barron 2014-3878
SHERIFF'S RETURN OF SERVICE
07/10/2014 07:27 PM- Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Omar Barron, Husband, who
accepted as"Adult Person in Charge"for April S Barron at 118 Lighthouse Drive, Hampden Township,
Mechanicsburg, PA 17050.
tI i f-1 f ;i Wilhfc,3
IE DIMART E, DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
K''::
July 14, 2014 RONf�R ANDERSON, SHERIFF
,., ^t to e Shoe Tck osof', f^G.
Law Firm of Allan C. Smith, P.C.
Attorney ID #204756
Bucks County Office Center
1276 Veterans Highway, Suite E-1
Bristol, PA 19007
1-888-275-6399 /1 (215) 428-0666
Attorney for Plaintiff
FLED -OFFICE
HE PROTHONOTARY
20 ',SEP -5 PH 1: 22
CUMBERLAND COUNTY
PENNSYLVANIA
CACH, LLC
vs.
APRIL S BARRON
Plaintiff,
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 14-3878
PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter a Default Judgment in favor of plaintiff, CACH, LLC, and against the
defendant(s), APRIL S BARRON, for failure to answer or otherwise respond to the Complaint
in Civil Action.
The Complaint was served upon the defendant(s) on July 10, 2014. A copy of the proof
of service is attached hereto.
A copy of the Notice of Intention to take Default mailed to defendant(s) APRIL S
BARRON by regular United States mail, postage paid, on August 1, 2014, is attached hereto.
Assess damages in the amount of $22,074.71 as follows: [a] $21,074.71 principal being
sought in the Complaint; [b] and $0.00 interest being sought in the Complaint; [c] and reasonable
attorney's fees of $1,000.00, [d] and Court Costs of $0.00, [e] and Costs of Service of $0.00.
Date: August 21, 2014
B
Ablika 4AL laWfAl
Co,
onnagel, Esq.
Co
Atto
y I.D. No. 313173
tIL.cLPWyf
CO' 191&
RA 310718
kkAt.f._, Mai litt_
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
IfItiert.
CACH, LLC
vs.
April S Barran
Case Number
2014-3878
SHERIFF'S RETURN OF SERVICE
07/10/2014 07:27 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Omar Barron, Husband, who
accepted as "Adult Person in Charge" for April S Barron at 118 Lighthouse Drive, Hampden Township,
Mechanicsburg, PA 17050.
LID
IE DIMARTCE, DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
July 14, 2014 RONNY R ANDERSON, SHERIFF
CcitireySuite Sheriff, Teosofi. mc.
Law Firm of Allan C. Smith, P.C.
Attorney ID #204756
Bucks County Office Center
1276 Veterans Highway, Suite E-1
Bristol, PA 19007
1-888-275-6399 // (215) 428-0666
Attorney for Plaintiff
CACH, LLC
vs.
APRIL S BARRON
Plaintiff,
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 14-3878
CERTIFICATE OF SERVICE OF
NOTICE OF INTENT TO FILE
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, CORRYN L. KRONNAGEL, ESQUIRE., of full age, certify that I mailed a copy of
the annexed NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY
DEFAULT upon defendant APRIL S BARRON by United States mail, postage prepaid, on
August 1, 2014 at his/her last address of:
118 LIGHTHOUSE DR
MECHANICSBURG, PA 17050
Date: August 21, 20141
yn L. Kronnagel, Esq.
y I.D. No. 313173
Law Firm of Allan C. Smith, P.C.
Attorney I.D. No. 204756
Bucks County Office Center
1276 Veterans Highway, Suite E-1
Bristol, PA 19007
1-888-275-6399 /1(215) 428-0666
Attorney for the Plaintiff
CACH, LLC
Plaintiff,
vs.
APRIL S BARRON
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No.: 14-3878
NOTICE OF INTENT TO
FILE PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO:
APRIL S BARRON
118 LIGHTHOUSE DR
MECHANICSBURG, PA 17050
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 TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) 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 NOTICE TO A 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.
Lawyer Referral Service
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013.
Telelphone: 249-3166
Dated: August 1, 2014
THIS COMMUNICATION IS FROM A DEBT COLLECTOR IN AN ATTEMPT TO COLLECT A DEBT.
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
Law Firm of Allan C. Smith, P.C.
Attorney ID #204756
Bucks County Office Center
1276 Veterans Highway, Suite E-1
Bristol, PA 19007
1-888-275-6399 /1 (215) 428-0666
Attorney for Plaintiff
CACH, LLC
vs.
APRIL S BARRON
Plaintiff,
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 14-3878
CERTIFICATION OF NON-MILITARY SERVICE
I, Corryn L. Kronnagel, Esquire, of full age, certifies as follows:
1. I am the plaintiff's attorney herein, and have sufficient knowledge of the facts and
am fully authorized to make this Certification;
2. My information is that the defendant is APRIL S BARRON.
3 Our latest information is that the defendant is employed at UNKNOWN.
4. To the best of my information and belief, the Defendant is not a member of
the military services of the United States of its allies or otherwise within the
provisions of the Soldiers' and Sailors' Relief Act of 1940, as amended, and as
stated in the attached Department of Defense Manpower Data Center reports.
5. This certification is taken subject to the penalties of 18 PaCSA 4904 relating to
unsworn falsification to authorities.
Date: August 21, 2014
Ai6fA AtAiiLkak '
$ yn L. Kronnagel, Esq.4
ey I.D. No. 313173
uerense manpower uata eenter
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: BARRON.
First Name: APRIL
Middle Name: S
Active Duty Status As Of: Aug -28-2014
Kesuits as ot Au—g-zs-zut4 r.e.00.uu IVI
SCRA 3.0
On Active Duty On A -Clive Duty Status Date -
Active Duty Start Date
' Active Duty End Date '
, f Status
Service Component
NA
NA
No
NA
This response reflects the inclividualsactive duty 'statusbased on the Active Duty Status Date
Left Active Duty tMthin 30DayotActive Duty Status Date 2 .
. Active Duty Start Date
Active Duty End Date
' . : Status
Service Component
NA
NA
No
NA
This response
. . _ ,..
reflects ,,tvharehe: individual left ietiVe aUtY'statueWithirISS.7SCieYS preceding thetkCtiVe 8Uty Status Date
•
•
The Member or HistHer Unit Was Notified of a Future Calkip to Active Duty on Active Duty Status Date
, , • Order Notification Start Date .
I Order Notification End Date .
Status '
Service Component
NA
NA
No
NA
This
. „
response reflects whether the individual or his/her..unit has received earty,notificatiori 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 (Afiiiy, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Law Firm of Allan C. Smith, P.C.
Attorney LD. #204756
Bucks County Office Center
1276 Veterans Highway, Suite E-1
Bristol, PA 19007
1-888-275-6399 // (215) 428-0666
Attorney for Plaintiff
CACH, LLC
vs.
APRIL S BARRON
Plaintiff,
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 14-3878
To: APRIL S BARRON
118 LIGHTHOUSE DR
MECHANICSBURG, PA 17050
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that
a Judgment has been entered against you in the above proceeding as indicated below:
By:
Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Verdict
If you have any questions concerning the above, please contact:
ATTORNEY: ALLAN C. SMITH, Esquire at 215-428-0666 or 1-888-275-6399
1
1.11 111 5 11 11 1111 1.111 111,1 II II
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
CACH, LLC : IN THE COURT OF COMMON PLEAS OF
4340 S. MONACO STREET, 21''D FLOOR : CUMBERLAND COUNTY, PENNSYLVANIA
DENVER, COLORADO 80237
Plaintiff's],
vs.
: Docket No.: 14-3878
APRIL S BARRON
118 LIGHTHOUSE DR
MECHANICSBURG, PA 17050
3
Defendant[s]. rn rrico
r -
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: c c
>C)
ISSUE and INDEX WRIT OF EXECUTION IN THE ABOVE MATTER, `per
-a
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania,
7,3
(2) against APRIL S BARRON Defendant(s); ANY AND ALL PERSONAL PROPERTY
TO BE LEVIED ON.
(3) and against Garnishee(s);
as a lis pendens against the real property of the defendant(s) in the name of the
S
Garnishee(s) as follows: (Specifically describe property to be levied upon by Sheriff)
(4) Amount Due $ 22,074.71
Interest from
$8.5o pA ATS
q 5 Car
103.'15
1(o.50
-4143. go- NJ ATP -1
TOTAL , plus costs.
DATE: October 20, 2014
J
it L
irk 7 ' onnagel, Esq.
#8o v*
(iori+ \SW6CI
4,a.a5Noeee
•50Lt.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
CACH, LLC.
Vs. NO 14-3878 Civil Term
CIVIL ACTION — LAW
APRIL S. BARRON
WRIT OF EXECUTION
(Pa R.C.P. 3252)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against APRIL S. BARRON, 118 Lighthouse Dr, Mechanicsburg,
PA 17050, Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
any and all personal property to be levied on.
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that
(a) an attachment has been issued;
(b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the
defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any
funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s) with a .bank or other financial institution in which funds on deposit exceed
$10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being
funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law.
(iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If
multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
1
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due $22,074.71
Interest
Attorney's Comm. %
Attorney Paid $193.70
Date: 10/27/14
(Scat)
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
David D. Buell, Prothonotary
REQUESTING PARTY:
Name : CORRYN L. KRONNAGEL, ESQUIRE
Address: LAW FIRM OF ALLAN C SMITH, PC
1276 VETERANS HIGHWAY, SUITE E-1
BRISTOL, PA 19055
Attorney for: PLAINTIFF
Telephone: 1-888-275-6399
Supreme Court ID No. 204756
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
2