HomeMy WebLinkAbout14-3884 r
Supreme Cour.;tf-,fennsylvania
Court of Common'Pleas For Prothonotray use Only:
Civ11 CVv r Sheet *1 Docket No: It:1`, ,'
CUM=�RLANDb W: County -� Iq
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service, of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S 0 Complaint 0 Writ of Summons Petition
0 Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
CACH,LLC MICKEY K RIEGEL
T Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? OYes 0 No (check one) Doutside arbitration limits
O
N Is this a Class Action.Suit? 0 Yes [2No Is this an MDJAppeal? O Yes El No
A Name of Plaintiff/Appellant's Attorney: ALLAN C. SMITH,ESQ.
0 Check here if you have no attorney(area Self Represented [Pro Se]Li tfgant)
Nature of the Case: Place an"x'to the left of the ONE case category that most accurately describes your
PRIAL RY 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.7udgments) CIVIL APPEALS
Intentional El Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution O Debt Collection: Credit Card 0 Board of Assessment
0 Motor Vehicle 0 Debt Collection:Other Q Board of Elections
0 Nuisance Dept. of Transportation
S 0 Premises Liability Statutory Appeal:Other
O Product Liability(does not include
mass tort) 0 Employment Dispute:
E Discrimination
O Slander/Libel/Defamation
Other:
C 0 Other: O Employment Dispute:Other D Zoning Board
T 0 Other:
I 0 Other:
Q MASS TORT
Asbestos
N E3Tobacco
Toxic Tort-DES
Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: 0 Ejectment 0 Common Law/Statutory Arbitration
B Eminent Domain/Condemnation 0 Declaratory Judgment
Ground Rent Mandamus
Landlord/Tenant Dispute 8 Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial O Quo Watranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
0 Medical Q Other:
0 Other Professional:
11111111111111111111 Updcded 11LI2011
* 4 2 5 8 4 4 - C O M - 1 - *
a
Law Firm of Allan C. Smith,P.0 {LIE`IIr 4 U 1
Attorney ID: 204756 �� �` stl
1276 Veterans Highway .It BEJ, 1111 A
4114
Suite E-1 , v Coln-} '
Bristol,PA 19007 r'� I jA
(888)275-6399/(215)428-0666
Attorney for Plaintiff
CACH,LLC ) COURT OF COMMON PLEAS
4340 SOUTH MONACO STREET 2ND ) CUMBERLAND COUNTY
FLOOR
DENVER,CO 80237 )
Plaintiff, ) �Qq
/l 1
VS. ) No.:
}
MICKEY K RIEGEL )
808 SHERWOOD RD )
NEW CUMBERLND,PA 17070 )
COMPLAINT
To: MICKEY K RIEGEL
808 SHERWOOD RD
NEW CUMBERLND,PA 17070
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 S
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013. b 3, 7S
Telelphone: 249-3166
OaJ
C Lt4
Ilk WAP3
t
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) dial 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 ALA 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
Y.
Plaintiff, CACH, LLC, by its attorney Allan C. Smith, Esq., by way of complaint against
Defendant MICKEY K RIEGEL,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, MICKEY K RIEGEL, is an individual residing at 808 SHERWOOD RD ,
NEW CUMBERLND,PA 17070.
3. Plaintiff's cause of action is based upon a writing.
4. Defendant,MICKEY K RIEGEL, was indebted to Bank of America,N.A.for a breach
of the written contract by and between them in the amount of$5,662.01 which balance
was due and unpaid as of October 30,2010, for credit card account number
4888940030422782. <Exhibit A>
5. Upon charge-off, the above account number was changed to 4888940993223342.
6. On or about September 25, 2012, FIA BANK OF AMERICA sold the debt for good
and valuable consideration to plaintiff, CACH,LLC <Exhibit B>
7. The Defendant,Mickey K Riegel, last tendered a payment on 08/07/2010.
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 $5,662.01 / 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 $5,865.76 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
117
Alan C.Smith, +sq.
EXHIBIT A
Bankof America
I
MICKEY K RIEGEL
Account Number:4888 9400 3042 2782
September 10-October 8,2010
Account Information:
www.bankofamerica.com A b ,-,
Mail billing inquiries to: New Balance Total .....................................................................$5,662.01 Previous Balance........................$5,636.20
Bank of America Current Payment Due....................................................................$150.00 Payments and Other Credits....................0.00
P.O.Box 15026 Past Due Amount..........................................................................$950.00 Purchases and Adjustments....................0.00
Wilmington,DE 19850-5026 Fees Charged....................................................0.00
Mail payments to: Total Minimum Payment Due.......................................................$1,100.00 Interest Charged............................................25.81
Bank of America Payment Due Date........................................................................11/7/10
P.O.Box 15019 New Balance Total.........................$5,662.01
Wilmington,DE 19886-5019 Total Minimum Payment Warning:If you make only the Total Minimum
Customer Service: Payment each period,you will pay more in interest and it will take you longer Credit Line....................................$7,000.00
1.800.789.6701 to pay off your balance. For example: Statement Closing Date...................10/8/10
y . as In Y Billing Cycle..................................2
n c
(1.300 346 3178TTY) � r- f • Y t' I• r y•t *
,�,�s• e= , , �: • �' ,�`•`gym-` ,��e7` %-:
Only the Total 3 years $6,073.80
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 Tota!
Interest Charged
10/08 10/08 Interest Charged on Balance Transfers 0.00
10/08 10/08 Interest Charged on Cash Advances 2.77
10/08 10/08 Interest Charged on Purchases 23.04
TOTAL INTEREST FOR THIS PERIOD $25.81
Total fees charged in 2010 $0.00
Total interest charged in 2010 $281.34
08 0056620100110000000100000004888940030422782
BANK OF AMERICA Account Number: 4888 9400 3042 2782
P.O.BOX 15019
WILMINGTON,DE 19886-5019 New Balance Total...........................................................$5,662.01
Total Minimum Payment Due..............................................1,100.00
Payment Due Date ...................................................11/07/10
MICKEY K RIEGEL Enter payment amount $-
120 W GREEN ST
MECHANICSBURG PA 17055-6251 - -
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 2 501: L 28800 30 4 2 2 78 20
1 y
IMPORTANT INFORMATION ABOUT THIS ACCOUNT USE611 Rev.08/10
CUSTOMER TIPS FOR DISPUTED ITEMS
ONLINE
Many times disputed charges are legitimate charges that customers maynot recognize Online Banki ng is available 24 hours a day,7 days a week and
or remember.Before disputing a charge,we recommend that you verify a few things lJ 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
answeryour 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? i L866.266.0212
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 15026,Wilmington,DE 19850-5026
One way to check for the credits or to view transaction details is to look atyour When writing,please include Your Name,Account Number,the
account statements on fine.If you are not enrolled in Online Banking,it is easy to enroll ® reference number of the disputed item and specific details regarding
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
merchant's response in each instance.Please include all supporting
Please remember:Once you receive your statement with a transaction you wish to documentation,including sales and credit vouchers,contract and
dispute,you only have 80 days to dispute the charge. postage return receipts as proof of any returns.
GRACE PERIOD/PAYING INTEREST
"Grace Period"means the period of time(luring a billing cycle when you will not less than zero we treat it as zero.
accrue interest on certain transactions or balances.There is no Grace Period for Balance We include the fees for credit card debt cancellation or credit insurance purchased
Transfers or Cash Advances;we begin charging interest on Balance Transfers and Cash through us in calculating the beginning balance for the first day of the billing cycle after
Advances on the transaction date.We will not charge interest on Purchases on the next the billing cycle in which such fees are billed.
statement if you pay the New Balance Total in full by the Payment Due Date,and you had TOTAL INTEREST CHARGE COMPUTATION
paid in full by the previous Payment Due Date. Interest Charges active and are compounded on a daily basis.To determine the
CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Interest Charges we multiply each Balance Subject to Interest Rate by its applicable Daily
Average Balance Method(including new Balance Transfers and new Cash Advances): Periodic Rate and that result by the number of days in the billing cycle.To determine
We calculate separate Balances Subject to an Interest Rate for Balance Transfers, the total Interest Charge for the billing cycle,we add the Periodic Rate Interest Charges
Cash Advances,and for each Promotional Offer balance consisting of Balance Transfers together.A Daily Periodic Rate is calculated by dividing an Annual Percentage Rate
or Cash Advances.We do this by:(1)calculating a daily balance for each day in this by 365.
statement's billing cycle;(2)calculating a daily balance for each day prior to this HOW WE ALLOCATE YOUR PAYMENTS
statement's billing cycle that had a"Pre-Cycle balance"-a Pre-Cycle balance is a Balance If your account has balances with different APRs,we will allocate the amount of
Transfer or a Cash Advance with a transaction date prior to this statement's billing your payment equal to the Total Minimum Payment Due to the lowest APR balances first
cycle but with a posting date within this statement's billing cycle;(3)adding all the daily (including transactions made after this statement).Payment amounts in excess of your
balances together;and(4)dividing the sum of the daily balances by the number of days in Total Minimum Pavment Due will be applied to balances with higher APRs before balances
this statement's billing cycle, with lower APRs.
To calculate the daily balance for each day in this statement's billing cycle,we take the IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE
beginning balance,add an amount equal to the applicable Daily Periodic Rate multiplied When using the optional Pay-by-Phone service,you authorize us to initiate an
by the previous day's daily balance,add new Balance Transfers,new Cash Advances and electronic payment from your account at the financial institution you designate.You must
Transaction Fees,and subtract applicable payments and credits,If any daily balance is authorize the amount and timing of each payment.For your protection,we will ask for
less than zero we treat it as zero. security information.A fee may apply for expedited service.To cancel,call us before the
To calculate a daily balance for each day prior to this statement's billing cycle that had scheduled payment date.Same-day payments cannot be edited or canceled.
a Pre-Cycle balance,we take the beginning balance attributable solely to Pre-Cycle balance MISCELLANEOUS
(which will be zero on the transaction date of the first Pre-Cycle balance),add an amount For the complete terms and conditions of your account,consult,your Credit Card
equal to the applicable Daily Periodic Rate multiplied by the previous day's daily balance, Agreement,FIA Card Services is a tradename of FIA Card Services,N.a.This account is
and add only the applicable Pre-Cycle balances,and their related Transaction Fees.We issued and administered by FIA Card Services,N.A.
exclude from this calculation all transactions posted in previous billing cycles.
Average Daily Balance Method(including new Purchases):
We calculate separate Balances Subject to an Interest Rate for Purchases and for
each Promotional Offer balance consisting of Purchases.We do this by:(1)calculating a
daily balance for each day in the billing cycle;(2)adding all the daily balances together;
and(3)dividing the sum of the daily balances by the number of days in the billing cycle.
To calculate the dailyba,lance for each day in this statement's billing cycle,we take the
beginning balance,add an amount equal to the applicable Daily Periodic Rate multiplied
by the previous day's daily balance,add new Purchases,new Account.Fees,and new
Transaction Fees,and subtract applicable payments and credits.If any daily balance is
PAYMENTS If your billing address or contact information has changed,or if your address is
We credit mailed payments as the date received,if the payment n (1)received l incorrect as it appears on this bill,please provide all corrections here.
5 p.m.local time at the address shown on the remittance slip on the front t of your monthly
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 by 5 p.m.Central -
time.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 soon State 'l.,ip______
as the same day we receive your payment.Checks are not returned to you.For more Area Code&
information or to stop the electronic funds transfers,call us at the number listed on Home Phone
the front. -- —
If you have authorized us to pay your credit card bill automatically from your savings Area Code&
or checking accountwith us,you can stop the payment on any amountyou think is Work.Phone
wrong.To stop payment,your letter must.reachusat least three business days before the —
automatic payment is scheduled to occur.
s w
Bankof America
4888 9400 3042 2782
September 10-October 8,2010
Page 3 of 4
g
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Promotional Promotional Balance Interest
Percentage Transaction Offer ID Subject to Charges by
Rate Type Interest Transaction
Rate Type
Balance Transfers 5.758 $ 0.00 $ 0.00
Cash Advances 5.758 $ 605.46 $ 2.77
Purchases 5.758 $5,043.18 $23.04
APR Type Definitions:APR Type:Temporary APR(APR for special circumstances)
n w
a,
Bankof America
MICKEY K RIEGEL
Account Number:4888 9400 3042 2782
July 11-August 9„2010
Account Information:
P'M �.� Ed
www.bankofamerica.com
Mail billing inquiries to: New Balance Total.....................................................................$5,608.75 Previous Balance....;...................$5,681.89
Bank of America Current Payment Due..............:.....................................................$150.00 Payments and Other Credits.............:-100.00
P.O.Box 15026 Past Due Amount..........................................................................$650.00 Purchases and Adjustments....................0.00
Wilmington,DE 19850-5026 Fees Charged....................................................
Mail payments to: Total Minimum Payment Due..........................................................$800.00 Interest Charged............................................26.86
Bank of America Payment Due Date...................:....:........... .....9/7/10
P.O.Box 15019 New Balance Total........................$5,608.75
Wilmington,DE 19886-5019 Minimum Payment Warning:If you make only the minimum payment each
Customer Service: period,you will pay more in interest and it will take you longer to pay off your Credit Line....................................$7,000.00
1.800.789.6701 balance.For example: Statement Closing Date.....................8/9/10
Cycle Billing n y e..................................3
Days I" � 'n C 0
(1.800.346.3178 TTY) %
sr x
Only the minimum 3 years $6,063.81
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
Payments and Other Credits
08/07 PAYMENT DIRECT DEBIT-THANK YOU 7852 —100.00
—$100.00
Interest Charged
08/09 08/09 Interest Charged on Balance Transfers 0.00
08/09 08/09 Interest Charged on Cash Advances 2.83
continued on next page...
08 0056087500080000000100000004888940030422782
BANK OF AMERICA Account Number: 4888 9400 3042 2782
P.O.BOX 15019
WILMINGTON,DE 19886-5019 „$5,608.75
New Balance Total.........................................................
Minimum Payment Due.........................................................800.00
Payment Due Date ....................................................09/07/10
MICKEY K RIEGEL Enter payment amount $
120 W GREEN ST
MECHANICSBURG PA 17055-6251 - -
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 2 501: L 28800 304 2 2 78 2 n
IMPORTANT INFORMATION ABOUT THiS ACCOUNT USE511 Rev.08/10
CUSTOMER TIPS FOR DISPUTED ITEMS ONLINE
Many times disputed charges are legitimate charges that customers may not recognize Online Barnking is available 24 hours a day,7 days a week and
or remember.Before disputing a charge,we recommend thatt 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 creditto 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
slid 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 15026,Wilmington,DE 19850.5026
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 enroll ® reference number of the disputed item and specific details regarding
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
merchant's response in each instance.Please include all supporting
Please remember:Once you receive your statement with a transaction you wish to documentation,including sales and credit vouchers,contract and
dispute,you only have 60 days to dispute the charge. postage return receipts as proof of any returns.
GRACE PERIOD/PAYING INTEREST
"Grace Period"means the period of time during a billing cycle when you will not less than zero we treat it as zero.
accrue interest on certain transactions or balances.There is no Grace Period for Balance We include the fees for credit card debt cancellation or credit insurance purchased
Transfers or Cash Advances;we begin charging interest on Balance Transfers and Cash through us in calculating the beginning balance for the first day of the billing cycle after
Advances on the transaction date.We will not charge interest on Purchases on the next the billing cycle in which such fees are billed.
statement if you pay the New Balance Total in full by the Payment Due Date,and,you had TOTAL INTEREST CHARGE COMPUTATION
paid in full by the previous Payment Due Date. Interest Charges accrue and are compounded on a daily basis.To determine the
CALCULATION OF BALANCES SUBJECT TO INTEREST RATE interest Charges we multiply each Balance Subject to Interest Rate by its applicable Daily
Average.Balance Method(including new Balance Transfers and new Cash Advances): Periodic Rate and that result by the number of days in the billing cycle.To determine
We calculate separate Balances Subject to an Interest.Rate for Balance Transfers, the total Interest Charge for the billing cycle,we acid the Periodic Rate Interest Charges
Cash Advances,and for each Promotional Offer balance consisting of Balance Transfers together.A Daily Periodic Rate is calculated by dividing an Annual Percentage Rate
or Cash Advances.We do this by:(1)calculating a daily balance for each day in this by 365.
statement's billing cycle;(2)calculating a daily balance for each day prior to this HOW WE ALLOCATE YOUR PAYMENTS
statement's billing cycle that had a"Pre-Cycle balance"-a Pre-Cycle balance is a Balance If your account has balances with different APRs,we will allocate the amount of
Transfer or a Cash Advance with a transaction daze prior to this statement's billing your payment equal to the Total Minimum Payment Due to the lowest APR balances first
cycle but with a posting date within this statement's billing cycle;('3)adding all the daily (including transactions made after this statement).Payment amounts in excess of your
balances together;and(4)dividing the sum of the daily balances by the number of days in Total Minimum Payment Due will be applied to balances with higherAPRs before balances
this statement's billing cycle. with lower APRs.
To calculate the daily balance for each day in this statement's billing cycle,we.take the IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE
beginning balance,add an amount equal to the applicable Daily Periodic Rate multiplied When using the optional Pay-by-Phone service,you authorize us to initiate an
by the previous da'y's daily balance,add new Balance Transfers,new Cash Advances and electronic payment from your account at.the financial institution you designate.You must
Transaction Fees,and subtract applicable payments and credits.If any daily balance is authorize the amount and timing of each payment.For,your protection,we will ask for
less than zero we treat it as zero: .. security information.A fee may apply for expedited service.To cancel,call us before the
To calculate a daily balance for each day prior to this statement's billing cycle that had scheduled payment date.Same-day payments cannot be edited or canceled.
a Pre-Cycle balance,we take the beginning balance attributable solely to Pre-Cycle balance MISCELLANEOUS
(which will be zero on the transaction date of the first Pre-Cycle balance),add an amount For the complete terms and conditions of your account,consultyour Credit Card
equal to the applicable Daily Periodic Rate multipliedb-ythe previous day's daily balance, Agreement.FIA Card Services is a tradename of FIA Card Services,N.A.This account is
and add only the applicable Pre-Cycle balances,and their related Transaction Fees.We issued and administered by FIA Card Services,N.A.
exclude from this calculation all transactions posted in previous billing cycles.
Average Daily Balance Method(including new Purchases):
We calculate separate Balances Subject to an Interest Rate for Purchases and for
each Promotional Offer balance consisting ofPurchases-We dothis by:(1)calculatinga
daily balance for each day in the billing cycle;(2)adding all the daily balances together;
and(3)dividing the sum of the daily balances by the number of days in the billing cycle.
To calculate the daily balance for each day in this statement's billing cycle,we take the
beginning balance,add an amount equal to the applicable Daily Periodic Rate multiplied
by the previous day's daily balance,add new Purchases,new Account Fees,and new
Transaction Fees,and subtract applicable payments and credits.If any daily balance is
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 incorrect as it appears on this bill,please provide all corrections here.
5 p.m.local time at the address shown on the remittance slip on the front of your monthly
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 clay.Payments Address 2
made online or by phone will be credited as of the(late of receipt if made by 5 p.m.Central
time.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 using the 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 maybe withdrawn homyour account as soon
State _— 7,ip,____—, _
as the same day we receive your payment.Checks are not returned to you.For more Area Code&
information or to stop the electronic funds transfers,call us az the number listed on Home Phone
the front.
.If you have authorized us to pay your credit card bill automatically from your savings Area Code&
or checking account with us,you can stop the payment on any amountyou 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
4888 9400 3042 2782
July 11-August 9,2010
Page 3 of 4
Transaction Posting Reference Account
Date Date Description Number Number Amount Total
Interest Charged
08/09 08/09 Interest Charged on Purchases 24.03
TOTAL INTEREST FOR THIS PERIOD $26.86
Total fees charged in 2010 $0.00
Total interest charged in 2010 $228.08
AUTO PAY ACTIVE-Your payment of$100.00 will be automatically deducted on September 07,2010.
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Promotional Promotional Balance Interest
Percentage Transaction. Offer ID Subject to Charges by
Rate Type Interest Transaction
Rate Type
Balance Transfers 5.75% $ 0.00 $ 0.00
Cash Advances 5.75% $ 599.73 $ 2.83
Purchases 5.75% $5,085.16 $24.03
APR Type Definitions:APR Type:Temporary APR(APR for special circumstances)
Bankof America
MICKEY K RIEGEL -
Account Number:4888 9400 3042 2782
August 10-September 9,2010
Account Information:
s.
www.bankofamerica.com x
Mail billing inquiries to: New Balance Total ........•.••.........................................................$5,636.20 Previous Balance........................$5,608.75
Bank of America Current Payment Due.....................................................................$150.00 Payments and Other Credits....................0.00
P.O.Box 15026 Past Due Amount.......:............:.........•.......................:...................$800.00 Purchases and Adjustments....................0.00
Wilmington,DE 19850-5026 Fees Charged....................................................0.00
Mail payments to: Total Minimum Payment Due.,....................:....................................$950.00 Interest Charged............................................27.45
Bank of America Payment Due Date.................... ...:....................10/7/10
New Balance Total............
P.O.Box 15019 .............$5,636.20
Wilmington,DE 19886-5019 Minimum Payment Warning:If you make only the minimum payment each
Customer Service: period,you will pay more in interest and it will take you longer to pay off your. Credit Line....................................$7,000.00
1.800.789.6701 balance. For example: Statement Closing Date.....................9/9/10
Days in Billing Cycle..................................31
(1.800.346.3178 TTY)
Only the minimum 3 years $6,068.29
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
Interest Charged
09/09 09/09 Interest Charged on Balance Transfers 0.00
09/09 09/09 Interest Charged on Cash Advances 2.94
09/09 09/09 Interest Charged on Purchases 24.51
TOTAL INTEREST FOR THIS PERIOD, $27.45
Total fees charged in 2010 $0.00
Total interest charged in 2010 $255.53
08 0056362000095000000100000004888940030422782
BANK OF AMERICA Account Number: 4888 9400 3042 2782
P.O.BOX 15019
WILMINGTON,DE 19886-5019 New Balance Total.......................... ...$5,636.20
Minimum Payment Due.........................................................950.00
Payment Due Date .........................•..••.....................10/07/10
MICKEY K RIEGEL Enter payment amount -$
120 W GREEN ST t'
MECHANICSBURG PA 17055-6251
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 2 504 12131300 304 2 2 713 20
IMPORTANT INFORMATION ABOUT THIS ACCOUNT USE611 Rev.08/10
CUSTOMER TIPS FOR DISPUTED ITEMS
ONLINE
Many times disputed charges are legitimate charges that customers may not recognize Online Banking is available 24 hours a day,7 days a week and
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? ( L866.266.0212
Please allow up to 30 days from the date on your credit voucher or I � 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 nurses are d.iferent or amounts can easily be confused with similar MAIL
charges or include tips. Attn:Billing Inquiries PO Box 15026,Wilmington,DE 19850-5026
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 enroll ® reference number of the disputed item and specific details regarding
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
merchant's response in each instance.Please include all supporting
Please remember:Once you receive your statement with a transaction you wish to documentation,including sales and credit vouchers,contract and
dispute,you only have 60 days to dispute the charge. postage return receipts as proof of any returns.
GRACE PERIOD/PAYING INTEREST
"Grace Period"means the period of time during a billing cycle when you will not less than zero we treat it as zero.
accrue interest on certain transactions or balances.There is no Grace Period for Balance We include the fees for credit card debt cancellation or credit insurance purchased
Transfers or Cash Advances;we begin charging interest on Balance Transfers and Cash through us in calculating the beginning balance for the first day of the billing cycle after
Advances on the transaction date.We will not charge interest on Purchases on the next the billing cycle in which such fees are billed.
statement if you pay the New Balance Total in full by the Payment Due Date,and you had TOTAL INTEREST CHARGE COMPUTATION
paid in full by the previous Payment Due Date. Interest Charges accrue and are compounded on a daily basis.To determine the
CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Interest Charges we multiply each Balance Subject to Interest Rate by its applicable Daily
Average Balance Method(including new Balance Transfers and new Cash Advances): Periodic Rate and that result by the number of days in the billing cycle.To determine
We calculate separate Balances Subject to an Interest Rate for Balance Transfers, the total Interest Charge for the billing cycle,we add the Periodic Rate Interest Charges
Cash Advances,and for each Promotional Offer balance consisting of Balance Transfers together.A Daily Periodic Rate is calculated by dividing an Annual Percentage Rate
or Cash Advances.We do this by:(1)calculating a daily balance for each day in this by 365.
statement's billing cycle;(2)calculating a daily balance for each day prior to this HOW WE ALLOCATE YOUR PAYMENTS
statement's billing cycle that had a"Pre-Cycle balance"-a Pre-Cycle balance is a Balance IIyour account has balances with different APRs,we will allocate the amount of
Transfer or a Cash Advance with a transaction date prior to this statement's billing ,your payment equal to the Total Minimum Payment Due to the lowest APR balances first
cycle but with a posting date within this statement's billing cycle;(3)adding all the daily (including transactions made after this statement).Payment amounts in excess of your
balances together;and(4)dividing the sum of the daily balances by the number of days in Total Minimum Payment Due will be applied to balances with higher APRs before balances
this statement's billing cycle. with lower APRs.
To calculate the daily balance for each day in this statement's billing cycle,we take the IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE
beginning balance,add an amount equalto the applicable Daily Periodic Rate multiplied When using the optional Pay-by-Phone service,you authorize us to initiate an
by the previous day's daily balance,add new Balance Transfers,new Cash Advances and .. electronic payment from your account at the financial institution you designate.You must
Transaction Fees,and subtract applicable payments and credits.if any daily balance is authorize the amount and timing of each payment.For your protection,we will ask for
less than zero we treat it as zero. security information.A fee may apply for expedited service.To cancel,call us before the
To calculate a daily balance for each day prior to this statement's billing cycle that had scheduled payment date.Same-day payments cannot be edited or canceled.
a Pre-Cycle balance,we take the beginning balance attributable solely to Pre-Cycle balance MISCELLANEOUS
(which will be zero on the transaction date of the first Pre-Cycle balance),add an amount For the complete terms and conditions of your account,consultyour Credit Card
equal to the applicable Daily Periodic Rate multiplied by the precious day's daily balance, Agreement,FIA Card Services is a tradename of FIA Card Services,N.A.This account is
and add only the applicable Pre-Cycle balances,and their related Transaction Fees.We issued and administered by FIA Card Services,N.A.
exclude from this calculation all transactions posted in previous billing cycles.
Average Daily Balance Method(including new Purchases):
We calculate separate Balances Subject to an Interest Rate for Purchases and for
each Promotional Offer balance consisting of Purchases.We do this by:(1)calculating a
daily balance for each day in the billing cycle;(2)adding all the daily balances together;
and(3)dividing the sum of the daily balances bythe number of days in the billing cycle.
To calculate the dailybalance for each day in this statement's billing cycle,we take the
beginning balance,add an amount equal to the applicable Daily Periodic Rate multiplied
by the previous day's daily balance,add new Purchases,new Account Fees,and new
Transaction Fees,and subtract applicable payments and credits.If any daily balance is
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
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(late of.receipt if made by 5 p.m.Central --
time.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 using the 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 soon State Zip____.__
as the same day we receive your payment.Checks are not returned to you.For more Area Code&
information or to stop the electronic funds transfers,call us at the number listed on Home Phone
the front. —
If you have authorized us to pay your credit card bill automatically from your savings Area Code&
or checking account with us,you can stop the payment on any amountyou think is Work Phone
wrong.To stop payment,your letter must reach us atleast three business days before the —
automatic payment is scheduled to occur.
F . 0
Bankof America
4888 9400 3042 2782
August 10-September 9, 2010
Page 3 of 4
Effective August 22,2010,we have changed the fee amount for paving late.If you do not make at least the total minimum payment by your due date,you will be
charged a Late Fee of$25.For any subsequent late payment,you will be charged a Late Fee of$35;the fee will return to$25 after you have made 6 consecutive
on-time payments.You can avoid a Late Fee by paying at least your total minimum payment amount by the due date.Complete details will be mailed to you in
November.
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Promotional Promotional Balance Interest
Percentage Transaction Offer ID Subject to Charges by
Rate Type Interest Transaction
Rate Type
Balance Transfers 5.75% $ 0.00 $ 0.00
Cash Advances 5.75% $ 602.61 $ 2.94
Purchases 5.75% $5,019.41 $24.51
APR Type Definitions:APR Type:Temporary APR(APR for special circumstances)
t �
EXHIBIT B
CERTIFICATE OF PURCHASE
i,
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: MICKEY K RIEGEL
Original Creditor: Bank of America,N.A.
Account Number: 4888940030422782
3. On or about September 25,2012 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,
JUN
F Z014
Date: -
By:._,�
s
Sworn and subscribed to before
me this day of If ilk 11 ;; = 2014,
:P
17
A,
r
Notary Pu lic
Y J w
+1
BankofAmerica_14
I
EXHIBIT C
BILL OF SALE AND ASSIGNMENT OF LOANS
THIS BILL OF SALE AND ASSIGNMENT OF LOANS is made and entered into between CACH, LLC
("Purchaser") and FIA CARD SERVICES, N.A. ("Seller"), pursuant to the Loan Sale Agreement dated
September 19,2012(the"Agreement")entered into between Purchaser and Seiler. 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 on the electronic file referenced in Schedule 1 of the Loan Agreement,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 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 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 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 party,through its duly authorized officer,has caused this Bill of Sale and
Assignment of Loans to be executed in their name this 26'"day of September,2012.
SELLER/ASSIGNOR: BUYER/ASSIGNEE:
FIA CARD SERVICES,N.A. CACH,LLC
By: By:
Name: Debra L Pellicciaro Name. 21:
Title: Vice President Title: C✓e
Fax 302.459.0438
Post Agency Bulk 9/19/12 Bank of America,Asset Salft
Deerfield Ill.655 Paper Mill Road,Newark,DE L4M
AFFIDAVIT OF SALE AND CERTIFICATION OF DEBT
STATE OF NORTH CAROLINA )
CITY OF GREENSBORO )
FIA Card Services,N.A.
Accountholder.'MICKEY K RIEGEL Account NOW,4888940993223342,4888940030422782
The undersigned,Tracy Hopkins,being duly sworn,states and deposes as follows:
I. 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:
a. Account number 4888940993223342,formerly account number 4898940030422782,was opened on
11/08/2006liy MICKEY K RIEGEL.
b. Pursuant to the terms of the card member agreement with FIA Card Services,N.A,there was due and
payable$5662.01 as of the charge off date of 10/30/2010.
C. Said agreement and account was,on 09/22/2012,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
$5662,01,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 MAR 0 5 2014,2014
FIA Card S rvices,N.A.
By: Z.
MAR,
r ank Officer
Subscribed and sworn to before me this day of MAR 0 5 2014 2014
My commission expir :
Notary Seal ,,+t++a►inrrr►rMr►�
No Pu
r � -TAy , _
A Gz.
G0'
1812 CACH,LLC 2/2 112 0 1 4
VERIFICATION
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 MICKEY K RIEGEL owes the
balance of $5,662.01 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.
0 14
Dated: 's3t`v g
Authorized Representative
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
W.:"6 PiERipc
JUL f , r.
11111EFL A ND
CACH, LLC
vs. Case Number
Mickey K. Riegel 2014-3884
SHERIFF'S RETURN OF SERVICE
07/03/2014 05:03 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Mickey K. Riegel at 808 Sherwood Road, New Cumberland Borough, New Cumberland, PA 17070.
RYAN BURGETT, DEPU
SHERIFF COST: $47.21 SO ANSWERS,
July 07, 2014
(c) CountySuite Sheriff, Teleosoft. Inc.
RONNY R ANDERSON, SHERIFF
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
7;\''l:
?Olt 3 SP'' 1' SI
O017- Y
P-;; SYI.V CA NIA
CACH, LLC
Plaintiff,
vs.
MICKEY K RIEGEL
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-3884
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), MICKEY K RIEGEL, for failure to. answer or otherwise respond to the
Complaint in Civil Action.
The Complaint was served upon the defendant(s) on July 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) MICKEY K
RIEGEL by regular United States mail, postage paid, on July 25, 2014, is attached hereto.
Assess damages in the amount of $6,865.76 as follows: [a] $5,662.01 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 $103.75, [e] and Costs of Service of
$100.00.
Date: August 12, 2014
B y. i f�l. A A[1/ !� �
��orry/ . Kronnagel, Esq.
Atto.' ey I.D. No. 313173
aV
kkalIn 0a
AVAZAk rlocicup1-1'moo 'ce \N\coeck
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
V;i011.f)47,7,
CACH, LLC
vs.
Mickey K. Riegel
Case Number
2014-3884
SHERIFF'S RETURN OF. SERVICE
07/03/2014 05:03 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Mickey K. Riegel at 808 Sherwood Road, New Cumberland Borough, New Cumberland, PA 17070.
SHERIFF COST: $47.21
RYAN BURGETT, DEPU
SO ANSWERS,
July 07, 2014 RONfJY R ANDERSON, SHERIFF
Sh,..,rill,'TrAeosoft
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.
MICKEY K RIEGEL
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-3884
)
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 MICKEY K RIEGEL by United States mail, postage prepaid, on
July 25, 2014 at his/her last address of:
808 SHERWOOD RD
NEW CUMBERLND, PA 17070
Date: August 12, 2014
B
/ /
IL. Kronnagel, Esq.
ey 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.
MICKEY K RIEGEL
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No.: 2014-3884
NOTICE OF INTENT TO
FILE PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO:
MICKEY K RIEGEL
808 SHERWOOD RD
NEW CUMBERLND, PA 17070
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: July 25, 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
Plaintiff,
vs.
MICKEY K RIEGEL
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-3884
)
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 MICKEY K RIEGEL.
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 12, 2014
By
/A i daLatil
Co rf L. Kronnagel, Esq.
At • .• - y I.D. No. 313173
uep3t u t tgr IL ut utsTETISe IiiidTipoWtt ual I,eTT2r
Status Report
Pursuant to Servieemembers Civil Relief Act
Last Name: RIEGEL
First Name: MICKEY
Middle Name: K
Active Duty Status As Of: Aug -12-2014
r!d!U to dS u . nuy c -Lu v I L.vo:ou tih
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 Within 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 theActive 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.
Y�-
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.
MICKEY K RIEGEL
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2014-3884
)
To: MICKEY K RIEGEL
808 SHERWOOD RD
NEW CUMBERLND, PA 17070
' 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 prodding s indicated below:
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
i
i
* Q 2 5 8 4 4- E D
i
F T -
1 - *