HomeMy WebLinkAbout14-3883. 1
Supreme Couxf�af,.Pennsylvania
Court of=.Common leas ForProthonotay UseOitxy:
I
Civil Cover,Shut
. � ;�,► ' t";
iDocketNo:y
CUMBERLANDs County
..:,
The information collected.on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling acrd service. ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S Complaint 0 Writ of Summons Petition
Transfer from Another Jurisdiction Q Declaration of Taking
E
C Lead Plaintiffs Name: Lead Defendant's Name:
CACH,LLC LYSONN PIERRELOUIS
T Dollar Amount Requested: Qwithin arbitration limits
I Are money damages requested? 13 Yes EJ No
(check one) outside arbitration limits
O
N Is tills a Class Action Suit? [I Yes [2 No, Is this an I11DJAppeal? [ Yes [A No
A Name of Plaintiff/Appellant's Attorney: ALLAN C. SMITH,ESQ.
El Check here if you have no attorney(area Self-Represented (Pro Se]IA tigant)
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 Moss Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
Q Intentional Q Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution Debt Collection:Credit Card Board of Assessment
0 Motor Vehicle Q Debt Collection:Other 0 Board of Elections
Nuisance Dept. of Transportation
S 0 Premises Liability l 8 Statutory Appeal:Other
Product Liability(does not include
mass torp �Employment Dispute:
er/Libel/Defamation Discrimination
0 SSlandtand: Q Employment Dispute:Other Zoning Board
,r Other:
I 0 Other:
Q MASS TORT f
Q Asbestos
N Q Tobacco
0 Toxic Tort-DES
0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic.Waste
Q Ejectment Q Common Law/Statutory Arbitration
B Other: 0 Eminent Domain/Condemnation 0 Declaratory Judgment
El Ground Rent Mandamus
Q Landlord/Tenant Disputee.Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY Q Mortgage Foreclosure:Commercial Quo Warranto
0 Dental Q Partition [ Replevin
0 Legal Quiet Title El Other:
Q Medical Other:
Other Professional:
Up"ed 1/112011
* Q 2 6 5 3 9 - C O M - 1 -
Law Firm of Allan C. Smith,P.0
Attorney ID: 204756 JUL ,m
1276 Veterans Highway c �, �i �' u
Suite E-1 J' � Et � ^ n
Bristol,PA 19007 SEN' S} 'A ��, Y
(888)275-6399/(215)428-0666 A
Attorney for Plaintiff
CACH,LLC ) COURT OF COMMON PLEAS
4340 SOUTH MONACO STREET 2ND ) CUMBERLAND COUNTY
FLOOR
DENVER,CO 80237 )
Plaintiff,
VS. ) No..
LYSONN PIERRELOUIS )
2242 OLD HOLLOW RD )
MECHANICSBURG,PA 17055 )
EVENS VIELLE )
2242 OLD HOLLOW RD )
MECHANICSBURG,PA 17055 )
COMPLAINT
To: LYSONN PIERRELOUIS
2242 OLD HOLLOW RD
MECHANICSBURG,PA 17055
and
EVENS VIELLE
2242 OLD HOLLOW RD
MECHANICSBURG,PA 17055
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 �Q
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013. /
Telelphone: 249-3166 �it / L
;2-,4 3b-) 9(4
� a
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
x ..
Plaintiff, CACH, LLC, by its attorney Allan C. Smith, Esq., by way of complaint against
Defendants LYSONN PIERRELOUIS AND EVENS VIELLE, 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, LYSONN PIERRELOUIS, is an individual residing at 2242 OLD HOLLOW
RD , MECHANICSBURG, PA 17055 and Defendant, EVENS VIELLE is an individual
residing at 2242 OLD HOLLOW RD ,MECHANICSBURG,PA 17055.
3. Plaintiff's cause of action is based upon a writing.
4. Defendants, LYSONN PIERRELOUIS AND EVENS VIELLE, was indebted to GE
MONEY RETAIL BANK for a breach of the written contract by and between them in
the amount of$5,096.43 which balance was due and unpaid as of April 10,2013,for
credit card account number 6019193601702037. <Exhibit A>
5. On or about May 28,2013, sold the debt for good and valuable consideration to plaintiff,
CACH,LLC<Exhibit B>
6. The Defendants, Lysonn Pierrelouis And Evens Vielle, last tendered a payment on
12/26/2012.
7. Pursuant to P.R.C.P Rule 1019(i), 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.
8. Plaintiff is entitled to charge-off account finance charges of$0.00. <Exhibit A>
9. Plaintiff is entitled to pre-litigation charge-off interest of $0.0000 per day from the
default date ( 0.000% annual percentage rate x $5,096.43/ 365 days) or $0.0000 x 509
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.
10. 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
defendants have failed to remit payment.
WHEREFORE, plaintiff demands judgment against the defendants for $5,300.18 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
A lan C.Smith,Esq.
XHIBIT
ASIAZY FURNI'll'RE, CIt,,JlI(,),-AcrNtm7.w: LYS0NNPlcRREL0UjS
S-ond.x Nartx,: ENTNS VFFUX
GE Capital Retail Bank WHY7013
..........
i,mi
T
tud Mininum N5,mm Env IL273A)i
Nyt-g% Paysiont Dw,Dsty, 0462010,
f. Cmiitn Set!,&Atijit,ftnenk(.1)
PA YME-.N7 D UT BY P.M.L,,STL-R-N ON THE-DUE VA TI--
chwrgo frwt I we may w1mr4 pmr Payment dew,sw
Xm B.'awemen-Alt.
Omen UtTli: WIWAX) i
Lxe PaymMf wanting., IT w,do,-nes t--eive 3m Total
Wolmurn iinpwml Ow by di.Aty
DyY,in HiMm Mw fitiaal.[vw
17
fuAy f-up w$3'5:(14;
Pay OnEw fors face m:gqtiwlxmn
Fr,f(T RIIWIDUA cuwmrimrlcc 6f to fitpm,
your cad Jostor stotam cull 1•81741,994)72L
nottt fitrtes to call tne wedwWav-r-03VI
.............. ........................- .............-..........................................................................-....................................................... ........................- ...........
TAOMMLUMM
- !
I'm,,Ml, i Poz-t Daw Rt,,.Imt—Ntnivr
(Wt(,,'20l3
OVIW2013 F9(PttCJ4fW,)999f) C,H A R GE OFF ACCOU 14 4 RN ANCE' $l;929A7(.R
I-ATFIEF W,001
TOTAL FOk PHLS'PER 10 1) 'o-"m
lNTfz9t-,ST tMARGED
44.11tV2013, (WI(112613+ INT]IREST CHARd;EON N;Rcm-A.3rs 1XI.001
lUrANTME�T FORMS PPRIOD so.w
mg
"M
Total Imest ChugW in 2013
ToW ltiwmsc P.M in 20 B $0.0,1
Mtriffiff
m'}—MEW 24
Dino, A,.,,Wi finom,itchaflm
Tyjv Balame
Pi—uum Intw1wi Ram
Rxe 4P
$11,00
................ ...... ......... ...... ..............
aNOTICE:
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Paym-ro EMMA: NOOSE on
.N',.Wdl inail? Ftjvnw.At,lu.nducl,,.a S 0A)fwfduc,Pleaw.Pity Ilk twa,fueam nal PROMMLY.
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LYSONN PIERRELOUTS
EVENSVIEUE
-15H011.0w xr) NIa4xPaymmtlw GECAPMALLRETAILBANK
MECHAMCSHURG PA i 7055,WT,' 110 BOX 90)(16 1
ORLANDO.Ff. 0061
DTA.,MtATD17DFFFI'An)AAATDI)IT�A.DM,,II)AFrf,-.FAI-,aA,"TDFATAI.,n.-rAM- DDIND'A
00000000012200 00006,000000. 00PO 000601919 36'01702 03762
i
Customer Service/Questions:For account information,please ca II the tol I free number on the front of this stotoment.Unless
your name is listed on this statement,your access to information on the account maybe limited.You may also mail questions
Ibut not payments)to:P.O.Box 91 Orlando,FL 32896.5033.Please include your account number on any correspondence
you send to us.
E Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www.
gogecapital.com.
Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekiva Springs
Road,Longwood,FL 32779.
Notice:See below for your Billing Rights and other important information.Telephoning about billing errors will not preserve
yovi rights under federal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando,
FL 3Z896-5035.
Purchases,returns and payments made Just prior to billing date may not appear until next moat statement.When
you provide a check as payment,you authorize us either to use information from your check to make a one-time electronic
fund transferfrom your account or to Process the paymentas a check transaction.When we use information from your check
to make an electronic fund transfer,funds may be withdrawn from your account as soon as the some day we receive your
payment and you will not receive your check back tram your financial institution.You may choose not to hove your payment
collected electronically by sending your payment(with the remittance coupici in your own envelope-not the endosed
remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address.
What To Do I(You Think You Find A Mistake On Your Statement
If you think there is an error on your statement,write to us at:
GE Capital Retail Bank.P.O.Box 965035,Orlando,FL 32896-5035.
In your lettergive us the following information:
•Account information:Your name and account number
•Dollar amount The dollar amount of the suspected error
•Description of problem:If you think there is an error on your bili,describe what you believe is wrong and why you be-
lieve it is a mistake.
You must contact us within 60 days after the error appeared an your statement.
You must notify,us of any potential errors in writing,You may call us,but if you do we are not required to investigate any
potential errors and you may have to pay the amount in question.
While we investigate whether or not there has been an error,the following are true:
•We cannot try to collect the amount in question or report you as delinquent on that amount.
•The charge in question may remain on your statement and we may continue to charge you interest on that amount.
But,if we determine that we made a mistake,you will not have to pay the amount in question crony interest or other fees
Mated to that amount.
•While you do not have to pay the amount in question,you are responsible for the remainder of your balance.
•We can apply any unpaid amount against your credit limit.
Information About Payments:You may at anytime pay,in whole or in part,the total unpaid balance without any additional
charge for prepayment. Payments received after 5:00 PM IET)on any day will be credited as of the next day.Credit to your
account maybe delayed up to five days if payment(a)is not received at the payment address,ilii is not made in U.S.dollars
dravm on a U.S.financial institution located in the U.S.,Icl is not accompanied by the remittance coupon attached to your
statement.(dl contains more than one payment or remittance coupon,(e)is not received in the remittance envelope provided
or(f)includes staples,paper clips,tape,a folded check or correspondence of any type.Conditional Payments:All written
communications concerning disputed amounts,including any check or other payment instrument that(i)indicates that the
payment constitutes"payment in full'or is tendered as full satisfaction of a disputed amount,or(ii)is tendered with other
conditions or limitations("Disputed Payments"),must be mailed or delivered to us at P.O.Box 965035,Orlando,PL 32896-5035.
Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits
will be applied toyour previous balance immediately upon receipt,butwill not satisfyony required payment that maybe due,
Credit Reports and Account information:Hyou believe that we may have reported inaccurate information about you to a
consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the
inaccurate information and tell us whyyou believe it is incorrect.lfyou have a copy of the credit report that includes the inac-
curate information,please include a copy of that report.We may report information about your account to credit bureaus.
Late Payments,missed payments,or other defaults on your account may be reflected in your credit report.
How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily bal-
ance"of your account for each day in the billing cycle. We then odd the interest to the daily balance. To get the"daily bal-
ance"we take the beginning balance of your account each day 1which includes unpaid interest),add any new charges,and
applicable fees,and subtract arty payments or credits.This gives us the doily balance.Any daily balance of less than zero will
be treated os zero.A separate daily balance will be colculated foreach balance type on your account.The balances)shown
in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by
the number of days in the billing cycle.
Bankruptcy Notice:Ifyou file bankruptcy you must send us notice,including account number and all information related to
the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell.GA 30076.
Your account is awned and serviced by GE Capital Retail Bank.
Hearing Impaired:TDD users call 1-877-448-8512
Use of Information About You and Your Account:Our Pnvacy Policy describes our collection and disclosure of information
about you and your Account.If you would like another copy ofthe Privacy Policy,please call us atthe customer service tele-
phone number indicated on the front of this statement.
This is an attemptto collect a debt and any Information obtained will be used for that purpose.
31-:5322-12 03/06/12
By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of
your account contacting you aboutyour account,including using anycontact information or cell phone numbers you provide.
and you consent to the use of any automatic telephone diol ing system and/or an artificial or rerecorded voice when contact-
ing you,even ifyou are charged for the call underyour phone plan.
Forchanges ofaddressor phone number,please check the box and print the changes below. Retail EN-OIEJ5302
Name
Street Address
City State Zip Code
Home Phone# Business Phone# Cell#or other phone#we can use to contact you Email Address
Remember,you can update the above information as well as your e-mail address online at www.gagecapital.com
ASOLEY FURN rTTJRr'HOMESTO?EStZM
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22-42 01.0 HOLLOW RD'.. GECAPIT.41,,RETAILHANK
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00625000012400 006250000359479 000601919 3L0,1702 03762
Customer Service/Questions:For account mfannation,please call the toll free number on the front of this statement.Unless
your name is listed on this statement,your access to information on the account maybe limited.You may also mail questions
(but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account number on any correspondence
you send to us.
Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www.
gogecapital.cam.
Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekwo Springs
Road,Longwood,FL 32779.
Notice:See below foryour Billing Rights and other important information.Telephoning about billing errors will not preserve
your rights under federal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando.
FL 32896-5035.
Purchases,returns and payments made just prior to billing date may net appear until next month's statement.When
you provide a check as payment,you authorize us either to use information from your check to make a one-time electronic
fund tra nsfer from your account or to process the poymentos a check transaction.When we use i nformotion from your check
to make an electronic fund transfer,funds may be withdrawn from your account as soon as the some day we receive your
payment and you will not receive your check back from your financial institution.You may choose not to haveyour payment
collected electronically by sending your poyment)with the remittance coupon),in your own envelope-not the enclosed
remittance envelope,addressed to:PO Box 530960,Atlanto,GA 30353-0960 and not the payment address.
What To Do If You Think You Find A Mistake On Your Statement:
If you think there is on error on your statement,write to us at
GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035.
In your letter give us the following information:
•Account information:Your name and account number -
•Dolfor amount:The dollar amount of the suspected error
•Description of probll If you think there is an error on your bill,describe what you believe is wrong and why you be-
lieve it is a mistake.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing,You may call us,but if you do we are not required to investigate any
potential errors and you may have to pay the amount in question.
While we investigate whether or not there has been an error,the following ore true:
•We cannot try to tolled the amount in question or report you as delinquent on that amount.
•The charge in question may remain on your statement and vie may continue to charge you interest on that amount.
But,if we determine that we made a mistake,you will not have to pay the amount in question or any interest or other fees
related to that amount.
•While you do not have to pay the amount in question,you are responsible for the remainder of your balance.
•We can apply any unpaid amount against your credit limit.
Information About Payments:You may at any time pay,in whole or in part,the total unpaid balance without any additional
charge for prepayment. Payments received after 5:00 PM(ET)ort any day will be credited as of the next day.Credit to your
account may be delayed up to five days if payment lal is not received at the payment address.Ibl is not made in U.S.dollars
drawn on a U.S.financial institution located in the U.S.,(c)is not accompanied by the remittance coupon attached to your
statement,(d)contains more than one payment or remittance coupon,(e)is not received in the remittance envelope provided
or IFI includes staples,paper clips,tape,a folded check or correspondence of any type.Conditional Payments:All written
communications concerning disputed amounts,including any check or other payment instrument that:VI indicates that the
payment constitutes"payment in full"or is tendered as full satisfaction of a disputed amount,or(ii)is tendered with other
conditions or limitations("Disputed Poyments 1,must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896-5035.
Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits
will be applied to your previous balance immediately upon receipt,but wil I not satisfy any required payment that may be due.
Credit Reports and Account Information:If you believe that we may have reported inaccurate information about you to a
consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the
inaccurate information and tell us whyyou believe it is incorrect.If you have a copy of the credit reportthat includes the inac-
curote information,please include a copy of that report.We may report information about your account to credit bureaus.
Late payments,missed payments,or other defaults on your account may be reflected in your credit report.
How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily bol-
once'of your account for each day in the billing cycle.We then add the interest to the daily balance. To get the"daily bal-
ance"we take the beginning balance ofyour account each day(which includes unpaid interest),add any new charges.and
applk be fees,and subtract any payments or credits.This gives us the daily balance.Any daily balance of less than zero will
be treated as zero.A separate doily balance will be calculated for each balance type on your account.The bola nce(a}shown
in the Interest Charges section of this statement is the sum of the daily boldnces for etch day in the billing cycle divided by
the numberof days in the billing cycle.
Bankruptcy Notice:If ou file bankruptcy you must send us notice,including account number and all information related to
the proceeding to the fallowing address:GE Capital Retail Bank,Atm:Bankruptcy Dept.,P.O.Box 103106,Roswell,GA 30076.
Your account Is owned and serviced by GE Capital Retail Bank
Hearing Impaired:TDD users call 1-877-448-1 12
Use of Information About You and Your Amount Our Privacy Policy describes our collection and disclosure of information
about you and your Account.If you would like another copy ofthe Privacy Policy,please call us at the customer service tele-
phone number Indicated an the front of this statement.
This is an attemptto coflect a debt and any information obtained will be used for that purpose.
CiEJ5302-i2-03/OS/12
By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of
your account contacting you about your account,including using any contact information or cell phone numbers you provide,
and you consent to the use of any automatic telephone dialing system and/or on artificial or rerecorded voice when contact-
ing you,even if you are charged for the call under your phone plan.
For changes of address or phone number,please check the boxand print the changes below. Retail EN-CIEJ5302
Name
Street Address
City State Zip Code
Home Phone# Business Phone# Cell#or other phone#we can use to contact you Email Address
Remember,you can update the above information as well as your e-mail address online at www.gogecapital-com
Canhokler Name:- LYSONN PIE RRELOUtS Account Number 0019-19360170 2037
ecoadiryName; EVENSVIMLE RalementClosing Date:12/1410.12
ildnh +t!}#ttti+lt+tl+it+tt+tt+t+t!ttt!ttt!ttfiftttt#lttttfilt+tt
Tnn Date Post Date Reference Nuanber MFoription. Arnotnt
127.16/2012 llIW2012 R07300P8000Z 1347 ADfOb"rMENT•PAYMENTS $124.00:
M612012 -12WZ01285348u2P5FT<6GX46 PAY.1IENr-THANK YOU $124.6061{
.. .. FEES"
12AWN12. .12AW2012LAT£.FEE 535.00
TOTAL FEES FOR.THIS PERIOA 535100
INTEREST CHARCM
12/142012 -101412012' 1NTERE Sr CIMME ON PURCJLASE 9 $7.19
TOTAL INTEREST 7C1R THISPERIOD $7.19
lttt+ttt+ttttttfclAstfF.f=1r:47hhtlt tti+ttlt
�1'orelFcesL.Largedin 2012 $:il I.tTI
Tntul lrierast Chari iu2012 530.83
ITotil Interest Paid in 2012. 5&76
}i#i#i}+#i}iti#i}i#i}iiiti#i}i}t#i}i#i#4#i}iMi#i#i#i+i
Espiration Date Annual BilanceUrcrt'o IraemstCharge
Type.of l3alnnce perontale Iukrest Rate
-Rate{APR}.
Ptcchases NA 29.99% 5282.145 $7.19
Ceferredinterest/No Interest lfPaidln Fall 01/1V11013 29.99%. S3,17631 $0.00
DeferredintemWINt Interest lfNidt"Full: 01//472013 29.99% 1458.43 50.00
Defertedlmerest/No Interest lfPaid Cn Full 02/1 IMI3 29.99 5717.90 $0.00
* #i#i}i#iii+i#i}i#itiii#i#t+it+}!#i}i#i#t#iiiii+i#i#i
we urui:rstand the impnct of naturahimsters can be difficult and se hope you and your loved ones are safe.ityoutwed.
epecW awstance uith ymc account,our representatives are wallaNe to assist You by calting thea rnter on this statement:
YOUR ACC'OVINT REXIAINSPASr DUE.PRCYrFcr YOLK
CREDIT BY SENDINGTHE:AMOUNT DUE-TODAY:OR
CALL I-SM-399-5166 .
;302 Cain 1 7 11 !21214 EX PAGE 2 of 3 9071 3600 XM30, oillis302
S302 CXH
1 7 11 121210
CX PAck 3 cf 3
9073 3600 XI930 CR615302
EXHIBIT B
1 u
CERTIFICATE OF PURCHASE
I, PETER HUSER hereby depose and state that:
1, l 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 Names: LYSONN PIERRELOUIS and EVENS VIELLE
Original Creditor: GE MONEY RETAIL BANK
Account Number: 6019193601702037
3. On or about May 28,2013 this account was sold by the creditor. CACH, LLC is the
current owner of the account and purchased the account for good and valuable
consideration.
Date: i 9 14
k
Sworn and subscribed to before
me this day of UN' 2014.
Notary Public ,�.;T ,. :`c L c,;M'10
3
GE Capital
BILL of SALE
CACH PSCC Fresh-May 2013
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated
as of this 110' day of January, 2013 by and between General Electric Capital
Corporation,GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services,
L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and
CACH, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement),delivered by Seller to Buyer on May 20,2013, and as further
described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
B y: 'J'ta'�-moi By:' /--, _.
Glenn Marino Glenn Marino
Title: EVP Title: President
Date: Ln-LA 1'� Date:
General Electric Capital Corporation RFS Holding,L.L.0
By: �,•.,��---- By: .
Glenn Marino Joseph Ressa
Title:_Vice President Title:_CFO
Date: ( a - 4 ~ 1 3 Date:
GEMB Lending,Inc. GEM Holding,L.L.0
By: By:
Stephen Motta Joseph Ressa
Title:_Director Title:_CFO
Date: Date:
GE Capita!
BILL of SALE
CACH PSCC Fresh—May 2013
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated
as of this I Vh day of January, 2013 by and between General Electric Capital
Corporation,GE Capital Retail Bank, GEMS Lending,Inc., Monogram Credit Services,
L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively -seller") and
CACH, LLC ("Buyer'l, Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement),delivered by Seller to Buyer on May 20,2013,and as further
described in the Agreement.
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: By:
Glenn Marino Glenn Marino
Title: EVP Title:_President
Date: Date:
General Electric Capital Corporation RFS Holding,L.L.0
By: By:
Glenn Marino Joseph Ressa
Title: Vice President Title: CFO
Date: Date:
GEMB Lending,Inc. GEM Holding,L.L.0
By: C By:
Stephen Mona Joseph Ressa
Title: Director Title: CFO
Date: &A4 j 13 Date:
I /
i GE Capital
BILL of SALE
CACH PSCC Fresh—May 2013
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated
as of this 11'" day of January, 2013 by and between General Electric Capital
Corporation, GE Capital Retail Bank, GEMS Lending, Inc., Monogram Credit Services,
L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and
CACH, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns,without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement),delivered by Seller to Buyer on May 20, 2013,and as further
described in the Agreement.
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: By:
Glenn Marino Glenn Marino
Title: EVP Title: President
Date: Date:
General Electric Capital Corporation RFS Holding,L.L.0
By: By.
Glenn Marino Joseph Re a
Title:_Vice President Title:_CFO
Date: Date:
GEMS Lending, Inc. GEM,Holding,L.L.0
By: By:
Stephen Motta Joseph
Title: Director Title: CFO
Date: Date:
i j t 5►
I
AFFIDAVIT OF SALE
STATE OF: Minnesota
: SS
COUNTY OF: Ramsey
BEFORE ME,on the day and date set forth below,the undersigned Notary,being qualified and
commissioned in and for the county and state aforesaid,personally carne and appeared Lisa
Anderson,who being duly sworn,did depose and say:-
Affiant is a Collections Operations Representative at GE Capital Retail Bank,issuer of the
relevant consumer transaction/credit card. I have reviewed the information below regarding the
debt 6019193601'701037(the"Account")made by LYSONN PIERRELOUIS(the"Debtor'
made payable to GE Capital Retail Bank and:subsequently sold to CACH,LLC..
The amount owed on the account on 5/19/2013,$5096.43 was sold.to CACH,LLC and is
reflected in the system of GE Capital Retail Bank.
The following statement pertains if the debtor referenced above is a state of California,resident: I
certify under the penalty of perjury under the laws of the state.of California that the�foregoing is
true and correct.
Executed this 14th day of March,2014
Lisa Anderson
Collections Operations Representative
Sworn to and Subscribed before me this 14th day of March,2014
C
s
TAJESHA LSHAViss
Notary Public Notary Public(
State of Minnesota
My Commission Expires
Januory,31,_2018
My commission expires: 1 3L 7i01
Version:1.0.1 A0S 06_06 2412-Sl.Paul
VERIFICATION
I,
PETER HUSER 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 LYSONN PIERRELOUIS AND
EVENS VIELLE owe the balance of $5,096.43 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,
Authorized Representative
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff t :r,faL ? H is t'RO i HOI, Ui
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFF I Or THE „.MEr it
2O=4 AUG 12 PM 2: 22
CUMBERLAND COUNTY
PENNSYLVANIA
CACH, LLC
vs.
Lysonn Pierrelouis (et al.)
Case Number
2014-3883
SHERIFF'S RETURN OF SERVICE
08/01/2014 05:22 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Evens Vielle, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at
2242 Old Hollow Road, Upper Allen, Mechanicsburg, PA 17055. Seven attempts at service were made
but deputies were unable to make contact with anyone to effectuate service and the Complaint has since
expired.
08/01/2014 05:22 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Lysonn Pierrelouis, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not
Served" at 2242 Old Hollow Road, Upper Allen, Mechanicsburg, PA 17055. Seven attempts at service
were made but deputies were unable to make contact with anyone to effectuate service and the
Complaint has since expired.
SHERIFF COST: $77.90 SO ANSWERS,
August 07, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft, Inc.
Law Firm of Allan C. Smith, P.C.
Attorney I.D. 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
4340 S. MONACO STREET, 2ND FLOOR
DENVER, COLORADO 80237
Plaintiff(s),
vs.
LYSONN PIERRELOUIS
2242 OLD HOLLOW RD; E402
MECHANICSBURG, PA 17055
Defendant(s).
'h• - -
0 THOI 1-1:4 icy
2811/OCT -8
464'11 : 23
'P'1E3P-io
YLVA NIA"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No: 2014-03883
PRAECIPE TO REINSTATE
TO THE CLERK OF COURTS OF CUMBERLAND COUNTY:
REINSTATE the Complaint in the above captioned matter.
GI REISSUE the Writ of
C3 OTHER:
DATE: October 01, 2014
in the above captioned matter.
Kronnage , Esqui
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
``E V
` nm
u� \ ``
Y�U4u`
o^` ' \ �A '1'
Pkti0 V1;6
[ \yMn`r
1
*=ICE OF,�EHERIFp
CACH, LLC
vs.
LyuonnHonaouiu(et ai)
Case Numbe
2014-3883
SHERIFF'S RETURN OF SERVICE
11/03/2014 08:41 PM - Deputy Shawn Gutshall, being duly sworn accoring to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Evens Vielle, Roommate, who
accepted as "Adult Person in Charge" for Lysonn Pierrelouis at 2242 Old Hollow Road E402, Upper Allen
Township, Mechanicsbur, PA 17055.
^r,"f
GUTSHALL, DEPUTY
u,SHERIFF COST: 3G1.QU SO ANSWERS,
November 05, 2014 RONNYRANDERSON, SHERIFF
(c,) CountySuite Sheriff, Telhosoft,
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 ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff )
vs. ) NO: 2014-03883
LYSONN PIERRELOUIS ) PRAECIPE TO ENTER
) JUDGMENT BY DEFAULT
Defendant(s)
TO THE PROTHONOTARY:
Please enter a Default Judgment in favor of plaintiff, CACH, LLC, and against the
defendant(s), LYSONN PIERRELOUIS, for failure to answer or otherwise respond to the
Complaint in Civil Action.
The Complaint was served upon the defendant(s) on November 03, 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) LYSONN
PIERRELOUIS by regular United States mail, postage paid, on December 1, 2014, is attached
hereto.
Giving Defendant, LYSONN PIERRELOUIS credit for any payments and refunds
received since the filing of the complaint. Assess damages for the outstanding balance listed
herein $6,096.43 as follows: [a] $5,096.43 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: December 22, 2014
By:
tv:4ft
Michelle L. San niti, Es
Attorney I.D. No. 311248 r
6
IL* faac,1-1
Ronny R Anderson
Sheriff
Jody S Smith
CChrf: t f`,Vuty
W
S(ir/cftci
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
CACH, LLC
vs.
Lysonn PierreLouis (et al.)
Case Number
2014-3883
SHERIFFS RETURN OF SERVICE
- : , Lputy Sttawn GutSt a,,, being duly sworn according iaw, served the req
ues
ted Complaint &
Notice by nanding a true copy to a person representing themselves to be Evens ie:le, Roommate,
who
accepted as "Adult Person in Charge" for Lysonn Pierrelouis at 2242 Old Hollow Road E402, Upper Allen
Township-, Mechanicsburg, PA 17055.
SHERIFF COST: $61.90
GUTSHALL, DEPUTY
SO ANSWERS,
November 05, 2014 RbNNY R ANDERSON, SHERIFF
iIIIfINIIIIIIhuuii ;1111111
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
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff
vs.
NO: 2014-03883
LYSONN PIERRELOUIS
Defendant(s)
CERTIFICATE OF SERVICE OF
NOTICE OF INTENT TO FILE
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, MICHELLE L. SANGINITI, 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 LYSONN PIERRELOUIS by United States mail, postage prepaid, on
December 1, 2014 at his/her last address of:
2242 Old Hollow Rd # E402
Mechanicsburg, PA 17055
Date: December 22, 2014
B y:11,e��li(iit Q`
ichelle L.angii Esq.
Attorney I.D. No. 311248
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.
LYSONN PIERRELOUIS
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No.: 2014-03883
NOTICE OF INTENT TO
FILE PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO:
LYSONN PIERRELOUIS
2242 Old Hollow Rd # E402
Mechanicsburg, PA 17055
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: December 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.
CALLS TO AND FROM THE LAW FIRM OF ALLAN C. SMITH, P.C. MAY BE MONITORED AND/OR
RECORDED FOR COMPLIANCE PURPOSES.
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
Plaintiff
vs.
LYSONN PIERRELOUIS
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-03883
CERTIFICATION OF NON-MILITARY SERVICE
I, Michelle L. Sanginiti, Esquire, of full age, certifies as follows:
1. I am the plaintiffs 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 LYSONN PIERRELOUIS.
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: December 22, 2014
By
//
ichelle L. anginiti
Attorney I.D. No. 311248
Department of Defense Manpower Data Center
Status Report
Pursuant to Servccrmbers Civil Relief Act
Last Name: PIERRELOUIS
First Name: LYSONN
Middle Name:
Active Duty Status As Of: Dec -18-2014
Results as of : Dec -18-2014 11:55:40 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
- - No
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Vdihin 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
_ NA _
_- No"
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Law Firm of Allan C. Smith, P.C.
Attorney I.D. #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
Plaintiff
vs.
LYSONN PIERRELOUIS
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-03883
PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
To: LYSONN PIERRELOUIS
2242 Old Hollow Rd # E402
Mechanicsburg, PA 17055
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notify, that
a Judgment has been entered against you in the above proceeding as'' dicat e1ow:
By:
X
Clerk
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
11111 1111111 1111111111 11 HI 1 1111