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Home My WebLink About14-6491 Supreme Court of Pennsylvania Court of Common +Pleas For Prothonotary Use Only: Civil Cover Sheet, �'. Docket No: Cumberland Count/ The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadinp_s or other papers as required by law or rules of court. Commencement of Action: ' ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking SLead Plaintiff's Name: Lead Defendant's Name: AVA I SHAFFER C CITIBANK;N.A. T Are move damages requested? Yes No Dollar Amount Requested: ® within arbitration limits l y g ® ❑ (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal?" ❑ Yes r ® No A Name of Plaintiff/Appellant's Attorney: Syretta Martin Frank Janello, Beth Arnold Howell, Kami S. Miller, Christoph Dr Titus ❑ Check here if you have no attorney (are a Self-Represented [Pro Se]Litigant) Nature of the Case:Place an "X" to the left.of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACTtdo not include Judgments) CIVIL APPEALS ❑ Intentional Buyer Plaintiff Administrative Agencies C1 Malicious Prosecution " Debt Collection: Credit Card "❑ Board of Assessment ❑ Motor Vehicle Debt Collection: Other ❑'Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability, ,Statutory-Appeal: Other E E] Product Liability (does not include , mass tort) ❑Employment Dispute " C ❑ Slander/Libel/Defamation' Discrimina'tiom T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board ❑ Other: f N ❑FOther: t MASS TORT , ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort-DES ❑ Toxic Tort-Implant, 'SAL PROPERTY 'MISCELLANEOUS ❑_Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑;Groupd,Rent , ❑ Mandamus i❑ Landlord/Tenant,Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Pardon ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111120_ 2955351 PPTXCPRI(07/18/2014) i 11111111 IN 1111111111110111111111111111111111111111111111111111111 IN i i Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 CITIBANK,N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. AVAISHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Defendant. COMPLAINT Plaintiff, CITIBANK,N.A., claims as follows: 1. Defendant(s), AVA I SHAFFER, , is an adult individual with last known address of 105 ARNOLD RD ENOLA PA 17025-2102 2. It is averred that Defendant(s) was indebted to CITIBANK, N.A. on 04-06-12 with account number XXXXXXXXXXXX0441 (hereafter referred to as "Account"). A copy of the Defendant(s) statement is attached hereto and collectively marked as Exhibit "A". 3. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 4. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 2955351 PPTCGDCI (08/26/2014) 111111111111 IN 11111111111111111111111111111111111111111111111111111 IN 5. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 6. Defendant(s) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 11-12-2013. 7. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $2575.61. 8. Despite reasonable demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) AVA I SHAFFER , in the amount of $2575.61, plus costs of this action and any other relief as the Court deems just and reasonable. Respectfully Submitted, Dated: - Syretta Martin, sq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 Verification iKATHY RIZOR , am employed by Citibank, N.A. (hereafter Citibank) which is successor in interest to plaintiff Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. 1 am authorized to make this verification on behalf of Citibank. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. w Sig 'aturVe s 2955351 PPTXCITI 1 VIII 1111111 III 111111 VIII 11111 VIII VIII VIII VIII 1111111111111 Exhibit " A " 2955351 PPTXEXAI ( 04/17/2014 ) Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: SEARS CREDIT CARDS 5 .4, rs C4 searscardoan sea PO Box 6282 Sioux Falls SO 57117 6282 rnj Account Inquiries: of PHOTO MasterCard' 1-800-669-8488fc .1n �11I x Fk.rid: Summary of Account Activity Payment Information Previous Balance $2,488.38 New Balance Payments -$0 00 $2,575.61 Other Credits -$0.00 Minimum Payment Due $1,380.04 Purchases +$0.00 Payment Due Date July 12,2014 Cash Advances +$0.00 Late Payment Warning:If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$52.23 Minimum Payment Warning: If you make only the minimum payment each New Balance $2,575.61 period,you will pay more in interest and it will take you longer to pay off your Past Due Amountbalance For example: $691.20 j J you mak#no addiCional You witl payoff:the And ynu well Credit Limit $0.00 charges sing tt11s.<card balance;shown an tilts end up paying an Available Credit $0.00 an9.tl each morrth you pay statement m about esltmated total flf,: Cash Advance Limit $0.00 Only the minimum payment 11 years $5,168 Available Cash Limit $0.00 $3,698 Amount Over Credit Limit $575.61 $103 3 years (Savings=$1,470) Statement Closing Date 06/15/2014 If you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 07/16/2014 Days in Billing Cycle 30 TRANSACTIONS Trans Date Description Reference# Amount FEES 06/12 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 06/15 INTEREST CHARGE ON PURCHASES S 52.23 TOTAL INTEREST FOR THIS PERIOD $ 52.23 8ME9 PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4. Page 1 of 4 This Account is Issued by Citibank,N.A. _______________+_ Please detach and return lower portion with your payment to insure proper credit Retain upper portion for your records sears® Your Account Number is 0441 PO BOX 6286 Payment Due Date July 12,2014 SIOUX FALLS,SD 57117.6286 SAVE STAMPS,TIME... New Balance $2,575.61 AND TREES! Past Due Amountt $691.20 Register now for Paperless Statements Minimum Payment Due $1,380.04 Statement Enclosed and more at { searscard.comOi1t 0 tPast Due Amount is included in the Minimum Payment Due. Please print address changes on the reverse side. Make Checks Payable tow SEARS CREDIT CARDS AVA i SHAFFER PO BOX 183082 105 ARNOLD RD COLUMBUS,OH 43218-3082 ENOLA,PA 17025-2102 0441 Information About Your Account. Proper Form.For a payment sent by mail or courier to be in proper form, How to Avoid Paying Interest on Purchases.Your payment due date is You must: at least 25 days after the close of each billing cycle.We will not charge you Enclose a valid check or money order.No cash,gift cards, any interest on purchases if you pay Your New Balance by the payment or foreign currency please- due date each month.This is called a grace period on purchases.if you do not pay the New Balance in full by the payment due date,you will not get Include your name.-�r:.d the fast four digits of your account number. a grace period on purchases until you pay the New Balance in f uli for two Payment Other Than By Mail. billing cycles in a row.We will begin charging interest on cash advances and • in-Store(Where Available).Any payment in proper form accepted in- balance transfers(if available on your account)on the transaction date, store will be credited as of that day.However,credit availability may be If you have a balance subject to a deferred interest promotion and that subject to verification of funds.Not all stores accept payments.Contact promotion does not expire before the payment due date,that balance{the your meal store to see if in-store payments are accepted at that locatior:.. "excluded promotional balance")is excluded from the amount you must Online.Go to the URL on Page t of your statement to make a payment. pay in:full to get a grace period.However,you must still pay any separately For security reasons,you may not be able to pay your entire New required payment on the excluded promotion.In billing cycles in which Balance the first time you make a payment Online.The payment cutoff payments are allocated to deferred interest balances first,the deferred time for Online Bill Payments is midnight Eastern time.This means that interest balance will be reduced before any other balance on the account, we will credit vnur account as of the calendar day,based on Eastern However,you will continue to get a grace period on purchases so long as time,that we receive your payment request. you pay the New Balance less any excluded promotional balances in full by AutoPay.Sign up at Account Online to have your payment amount the payment due date each billing cycle. automatically deducted each month from the account you choose. In addition,certain promotional offers may take away the grace period on Your card account will be credited on the due date with that amount. purchases.Other promotional offers not described above may also allow Phone.Call the phone number on Page i of your statement to make YOU to have a grace period on purchases without having to pay all or a a payment.We may process your payment electronically after we portion of the promotional,balance by the payment due date.If either is verify your identity,The payment cutoff time for Phone Payments is the case,the promotional offer will describe what happens, midnight Eastern time.This means that we will credit your account How We Calculate Your Balance Subject to Interest Rate.We use a as of the calendar day,based on Eastern time,that vie receive your daily balance method(including current transactions)to calculate interest payment request. charges.To find out more information about the balance computation Express Mail.Send payment by courier or express mail to:Payments method and how the resulting interest charges were determined,contact Department,1500 Boltonfield Street,Columbus,OH 43228.Payment us at the Account Inquiries number on the front. must be received in proper form at the proper address by 5 p.m.Eastern Balance Transfers.Balance transfer amounts are included in the tirne to be credited as of that day.All payments received in proper forrrti "Purchases"line in the Summary of Account Activity(if balance transfer s at the proper address after that time will be credited as are available on your account). of the next day. Transaction Date,The Transaction Date shown on the statement is also if you send an eligible check with this payment coupon,you authorize the Sale Date, us to complete your payment by electronic debit.If we do,the checking account will be debited In the amount on the check.We may do this as Other Account and Payment Information. soon as the day we receive the check.Also,the check will be destroyed. Payment Amount.You may pay all or part of your account balance at any time.However,you must pay,by the payment due date,at least the minimum payment due- When Your Payment Will Be Credited.if we receive your payment in proper form at our processing facility by 5 p.m.local time there,it will be credited as of that day.A payment received there in proper form after that time will be credited as of the next day.Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay of tip to'5 days in crediting a payment we receive that is not in proper form or is not sent to the correct address.The correct address for regular mail is the address on the front of the payment coupon.The correct address for courier or express mail is the Express Mail Address shown in the Express Mail section. T03174 PLEASE SEE IMPORTANT INr-ORMATION ON PAGE 4 SN1G./TGI/SGG/SGP/H1Ps-2 APR13 Page 2 of 4 Change of Address Please print address changes in blue or black ink. Account: **** **** **** Q441 Total Fees Charged in 2014 $210.00 Total Interest Charged in 2014 $288.83 LCASHADVANCES HARGE CALCULATION t:e Your Annual Percentage Rate APR is the annual interest rate on your account. AnnaalPercenha9e:Rate(APFI 9 ( ) Batance':Subject itt twiteres#.Ite `< tnft C#1irge CES . D V $2518.15 $5223 teD =Dai 27.15%-(D)(V) $0.00 Page 3 of 4 S Credit Reporting Disputes.If you think we reported inaccurate Lis at the Customer Service address After we finish our investigation,one of two things will happen; information to a credit bureau write shown on Page 1. If_we made a mistake:You 1^�ill not have to pay the amount in question Report a Lost or Stolen Card Immediately.Call the Account Inquiries or any interest or other fees related to that amount. number shown on Page 1. If we do not believe there was a mistake:You will have to pay the What To Do If You Find A Mistake On Your Statement s end you a4taterr:er:.tlof heramoutnt YOU owe.andintttand fees.he date Payr will ent If you think there is an error on your statement,write to us at the is due.We may then report you as delinquent if you do not pay the address for billing errors and customer service inquiries shown on Page 1 of our amount we think you awe. 9 Y statement. if you receive our exPianation but still believe your bill is wron In your fetter,give us the following information: nwst write to us within 10 days telling us that you still refuse tcpay r • Account information.Your name and account number, if You do SO,we cannot report you as delinquent without also reporting Dollar_ amount:The dollar amount of the suspected error. that you are questioning your bill.We must tell you the name o;` escriptiar.of problem;if you think there is an error on our bill, anyone to whom we reported YOU as definquent,and v.-e must let those D Y organizations know when the matter has been settled between us. describe what you believe is wrong and why you believe it is a mistake. !f we do not follow all of the rules above,you do not have to You must contact us: With In£i0 days after the error appeared ment. first$50 of the amount you question even if your bill is correct.ay the At'east 3 business days before nautomat d paymaent s scheduled, Your Rights if You Are Dissatisfied With Your Credit Card Purchases if You want to Stop payment on the amount You think is wrong. If You are dissatisfied with the goads or services that you have You must notify us of an with your credit card,and you have tried in good faith to correct the aced y y potential errors in writing.You may calls problem ar:'th the but if you do tare not required to investigate any potential errors and rem merchant,you may have the right not to pay the ng arnount due on the Purchase. you may have to Pay the amount in question, a What WI#Ka en After We Recelya Your Letter To use this right,ail of the fallowing must be true: 7. The purchase must have been made in your home state or within 100 When we receive your letter,we must do two things: miles of your current mailing address,and the purchase price must 7. Within 30 days of receiving Your letter,we must tell you that have been more than$50.(Note:Neither of these are necessary it we received your letter.We will also tell you if we have already Your purchase was based on an advertisement we mailed to you,or corrected the error. it we own the company that sold you the goods or services.) 2. Within 90 days of receiving your letter,we must either correct 2. YOU must have used your credit card for the purchase.Purchases the error or explain to you why we believe the bill is correct. made with cash advances from art ATM or with a check that accesses While we Investigate whether or not there has been an error: Your credit card account do not qualify. We cannot try to collect the amount in question, 3-YOU must'lot yet have fully paid for the purchase. or report you as delinquent on that amount. if all of the criteria above are met and you are still dissatisfied with the The charge it,question may remain on your statement, purchase,contact us in w.ritino at the address for billing errors and and we may continue to charge you interest on that amount. customer service inquiries shown on Page 1 of your statement. While you do not have to pay the amount in question, While we invest! You are responsible for the remainder of your balance. discussed above hrulese same apply Afterwe finish our inv tigati n,we w ll telrf you our We can apply any unpaid amount against decision.At that Paint,if we think you owe an amount and you do not 9 Your credit limit. pay,we may report you as delinquent. EM T03175-ME-1238.5300-0035.9-E-34-X--04/01/12.29--P--0-Y-7-0-0-0----01/17/14-GDAB-May 16,2014-0-0-V N... PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 SMCrTGV,SCC:5CP:HIPs-4 APR13 Page 4 of 4 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 �` ) �?' Blatt, Hasenmiller, Leibsker & Moore, LLC �� :' — ' 1835 Market Street, Suite 501x` 15 Philadelphia, PA 19103 t =�c t st,r?I i TELE: 215-564-1567 �� ; Lj � ' ? 1 FAX: 215-564-3818 + CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 FINTHE OF COMMON PLEAS Philadelphia, PA 19103 COUNTY, PA Plaintiff, vs. AVA I SHAFFER No. "� 105 ARNOLD RD ENOLA PA ]7025-2102 Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK,N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: t By. 1 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 ✓Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 PPTXPEAI (07/18/2014) 2955351 Attorneys For Plaintiff 11111111111111111111111II11111111111111111111111111III1I111111111111IIIN Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FOF of �:niriGr [1 HOT HOND' Ai OFFICE': F THE SHERIFF ni`ti NOV 26 Ali 11: 23 CUMBERLAND COUNTY PENNSYLVANIA Citibank, N.A. vs. Ava 1 Shaffer Case Number 2014-6491 SHERIFF'S RETURN OF SERVICE 11/19/2014 07:36 PM - Deputy Shawn Harrison, being duly sworn according to law, served//t e equested Complaint & Notice by handing a true copy to a person representing themselves t. •e fephe Shaffer, husband, who accepted as "Adult Person in Charge" for Ava I Shaffer at 105 Ar •'monad, Ea -t Pennsboro Township, Enola, PA 17025. SHERIFF COST: $44.95 S AWN HARRISON, DEPUTY SO ANSWERS, November 21, 2014 RONNY R ANDERSON, SHERIFF (r,)CountySuito St it(,'Te!eosofi. Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 orc 29 All 11: CUMBERLAND COUNTY PENNSYLVANIA CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. AVA SHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-6491 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant AVA 1 SHAFFER in this matter in the amount of $2,575.61 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 12-12-14 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: December 2S, 2014 By: 2955351 PPTJPFJI (09/16/2014) 1111 111111110101111111111111111111111111111111111111111111111111111111111 Respectfully submitted, BLATT, HASENMIL & MOORE, LLC EIBSKER Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 CSC /one PL.4 2 /I/ er14 .cf_ s Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 1 91 03 vs. AVA 1 SHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-6491 AFFIDAVIT OF NON-MILITARY SERVICE I, attorney for Plaintiff, states: 1. That the Defendant(s) is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; 2. The statement that Defendant(s) is not on active military service is based upon Defendant(s) Military Status Report pursuant to 50 U.S.0 App. Section 521, 525 which was obtained from Plaintiff's undersigned counsel's firms search of the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scra/scraHome.do). See Defendant(s) Military Status Report attached hereto. 3. That the Defendant(s) AVA 1 SHAFFER is (are) older than eighteen (18) years of age. 4. That the employment status of the Defendant(s), AVA 1 SHAFFER is (are) unknown. 5. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. 551 P295PTJC3AMI (09/05/2014) 1111111111111 1111111111 11111 11111 11111 11111 11111 1111111111 11111111 I affirm under penalties of perjury that the foregoing representations are true and correct. Dated: -1:43[1f By: SUBSCRIBED AND SWORN Before me this d 3 day of Pecesiber- ,20 By: aidu... Nota Public BLATT, HASENMILLER, E MOORE, LLC Syretta Martin, sq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 QF NNSYLVM NOTARIAL seAL MATThEW MAJESKILNotery Public City of Philadelphia, Phila, County My Commlasion Exelres June 27,2018 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Department of Defense Manpower Data Center Status Report Pursuant to Servicetnembers Civil Relief Act Last Name: SHAFFER First Name: AVA Middle Name: Active Duty Status As Of: Dec -23-2014 Results as of : Deo -23-2014 04:55:05 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 Within 367 Das 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 . r- No NA This response reflects whether the indl idual or his/her unit has recetved'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 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: X144V50311527A0 CITIBANK, N.A. vs. AVA I SHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-6491 TO: AVA I SHAFFER Date of Notice: December 12, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 This'is a communication from a debt collector. obtained will be used for that purpose. 2955351 PPTNLRSI (09/16/2014) 11111111111111 111111111111111111 I I Ill 1111111111111111111111 111111 By: BLATT, HASENMILLEt BSKER & MOORE, LLC Syretta Ma , Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 This is an attempt to collect a debt and any information CITIBANK, N.A. vs. AVAISHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 14-6491 TO: AVA I SHAFFER NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHONOTARY Dated: /a/24/// By: �- IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 2955351 PPTNDJNI (09/16/2014) 11111111111111101111111111111111111111111IlIII1111111111111111111111111 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff CITIBANK, N.A. c//o Blatt, Hasenmiller, Leibsker & Moore, LLC vs. AVA I SHAFFER Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION 14-6491 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly VACATE the Judgment that was previously filed, by the Plaintiff, with the Court in the above referenced matter. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: 2955351 ,LJ- 16%4,9G ��l 3is►9g Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK, N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. AVA I SHAFFER 105 ARNOLD RD ENOLA PA 17025-2102 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION 14-6491 CERTIFICATION OF SERVICE I, do hereby certify that I sent a true and correct copy of the foregoing via U.S. Regular Mail, to the Defendant(s) at the address below. ohn Matthew Hyams Law Offices of John M. Hy 555 Gettysburg Pike Suite C-402 Mechanicsburg, PA 17055 Dated: LI`zIls- 2955351 PPTNCOSI (09/18/2014) Syret : artin, Es • PA Bar #309370 Frank Janello, Esq PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818