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HomeMy WebLinkAbout08-1580Our File No.: 143968 APOTMAKER & ASSOCIATES, P.C. BAY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. LORRAINE M GRABAUSKAS 32 N 8TH ST LEMOYNE, PA 17043-1557 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D$ - 158D 0",vi ( T?erw% 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 a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a ]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 Our file No.: 143968 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff Attorney ID# 55140 LVNV FUNDING LLC Plaintiff, VS. LORRAINE M GRABAUSKAS Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-1580 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on April 28, 2008, STIPULATED by and between Plaintiff, LVNV FUNDING LLC, and Defendant, LORRAINE M GRABAUSKAS parties as follows: 1. Defendant agrees to pay the sum of $1,971.88, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of interest, counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant, LORRAINE M GRABAUSKAS, to the attorneys for Plaintiff in the following manner: a. Payments of $20.00 to be paid on or before the 30th of every month, starting May 30, 2008 until balance is paid. All checks are to made payable to LVNV FUNDING LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $1,971.88, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. r 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to LORRAINE M GRABAUSKAS by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for laintiff A Law Firm Enaaa m e t-'Collectioi By: . Scian, Esquire k AINE M G AUSKAS ? -a . ? (''*7 i` P7 _ L.+? _ 4 ?? i. , f ? APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff LVNV FUNDING LLC ) c/o Apothaker & Associates, P.C. ) 2417 Welsh Road, Suite 21 #520 ) Philadelphia, PA 19114 ) Plaintiff, ) vs. ) LORRAINE M GRABAUSKAS ) 32 N 8TH ST ) LEMOYNE, PA 17043-1557 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 E - /S kO C. j -r.1 CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, LVNV FUNDING LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is LORRAINE M GRABAUSKAS, an adult individual residing at 32 N 8TH ST LEMOYNE, PA 17043-1557. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $1,832.91. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is CITI-SEARS. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,832.91 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Atto for Plaintiff A Law Fi ng ed in Debt Collection BY: Dated: 2/21/2008 J Our File No.: 143968 VERIFICATION David J. Apothaker, Esq. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to uw n falsification to authorities. Davidake Attorney fk_Plainti DATE: 2/21/2008 LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 LORRAINE M GRABAUSKAS 32 N 8TH ST LEMOYNE, PA 17043-1557 STATEMENT OF ACCOUNT Debtor's Name: LORRAINE M GRABAUSKAS Account Number: 5484040851421 Original Creditor: CITI-SEARS Balance Due: $1,832.91 Our File No.: 143968 EXHIBIT "A" d 0 uAl J04 00 O d D r ` a te DIP {? 3 C 0 -{ _I c .; •• fl7 :? 5J C.a7 '^C SHERIFF'S RETURN - REGULAR CASE NO: 2008-01580 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS GRABAUSKAS LORRAINE M RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon --.-n r-.-n rrr-T-nn Tl Tl T1 7% -1 ITT-' Aff the DEFENDANT , at 2005:00 HOURS, on the 18th day of March , 2008 at 32 N 8TH STREET LEMOYNE, PA 17043-1557 by handing to LORRAINE GRABAUSKAS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.36 Affidavit .00 Surcharge 10.00 .00 3jdw)© 8' V 43.36 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 03/19/2008 APOTHAKER & ASSOCIATES By: 4? Deputy heriff A. D. LVNV FUNDING LLC, c/o Apothaker & Associates, P.C., Plaintiff V. LORRAINE M. GRABAUSKAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-1580 Civil Action PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Evan C. Pappas, Esquire, and the law firm of Shumaker Williams, P.C., as counsel for Defendant Lorraine M. Grabauskas in the above-captioned matter. SHUMAKER WILLLYVFA? P.C. Dated: q/ [? C By Evan C. Pappas, I.D. #200103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 Attorneys for Defendant :201095 CERTIFICATE OF SERVICE I, Evan C. Pappas, Esquire, of the law firm of Shumaker Williams, P.C., hereby certify that I served a true and correct copy of the foregoing Praecipe for Entry of Appearance by depositing a copy of the same in the possession of the United States mail, first-class, postage prepaid, addressed as follows: David J. Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 SHUMAKER WILL P.C. Dated: ?j By Evan C. Pappas P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 r?•_z V? T r' ? LVNV FUNDING LLC, IN THE COURT OF COMMON PLEAS OF c/o Apothaker & Associates, P.C., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : No. 08-1580 Civil Action LORRAINE M. GRABAUSKAS, Defendant NOTICE TO PLEAD TO: LVNV FUNDING LLC, Plaintiff and DAVID J. APOTHAKER, ESQUIRE, its attorney You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment maybe entered against you. SHHUUMAKER WILL S, P.C. Dated: By l Evan C. Pappas, I.D. #200103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 • 12. The Social Security Act, 42 U.S.C. §407, states the following: § 407. Assignment; amendment of section (a) The right of any person to any future payment under this title shall not be transferable or assignable, at law or in equity, and none of the moneys paid or payable or rights existing under this title shall be subject to execution, levy, attachment, garnishment, or other legal process, or to the operation of any bankruptcy or insolvency law. 13. Section 407 of the Social Security Act further provides that not only are future payments exempt from execution but so too are the funds once they have been deposited into the recipient's account in a bank or other financial institution. 14. Plaintiff has been notified of Defendants disability, her inability to pay the required amounts by Plaintiff and also that Plaintiff's only income is denied from Social Security disability. 15. Plaintiff's continued attempts to collect payments from Plaintiff despite knowing the health and financial situation of Defendant are harassing and contrary to 42 U.S.C. § 407. WHEREFORE, Defendant Lorraine M. Grabauskas respectfully requests this Honorable Court dismiss Plaintiff's Complaint and enter judgment in her favor and against Plaintiff LVNV Funding LLC. SHUMAKER WILLIAMS, P.C. Dated: 4A( tio0a By Evan C. Pappas,I.D. 0103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 Attorneys for Defendant 210206 3 CERTIFICATE OF SERVICE I, Evan C. Pappas, Esquire, of the law firm of Shumaker Williams, P.C., hereby certify that I served a true and correct copy of the foregoing Answer with New Matter on this date by depositing a copy of the same in the possession of the United States mail, first-class, postage prepaid, addressed as follows: David J. Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 214520 Philadelphia, PA 19114 SHUMAKER WILLIAMS, P.C. Dated: By Evan C. Pappas P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 _? ?? ;:7 a-,J ?°R? '? . i? ... r +_..... ?1 ..,?..? ....... -, i .1 ^?) -t .. G_ : .-: a . C?,3 LVNV FUNDING LLC, c/o Apothaker & Associates, P.C., Plaintiff V. LORRAINE M. GRABAUSKAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-1580 Civil Action PRAECIPE TO ATTACH VERIFICATION PLEASE attach the Verification of Lorraine M. Grabauskas to the Answer with New Matter which was filed on or about April 21, 2008. SHUMAKER WILLIAMS, P.C. Dated: ?cl L7?, By Evan C. Pappas, I.D. #200103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 Attorneys for Defendant 210447 VERIFICATION The undersigned, Lorraine M. Grabauskas, hereby verifies and states that: 1. She is the Plaintiff in the within action; 2. The facts set forth in the foregoing Answer are true and correct to the best of her knowledge, information and belief; and 3. She is aware that any false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: qlaxilob L aine M. Grabauska CERTIFICATE OF SERVICE I, Evan C. Pappas, Esquire, of the law firm of Shumaker Williams, P.C., hereby certify that I served a true and correct copy of the foregoing Praecipe to Attach Verification on this date by depositing a copy of the same in the possession of the United States mail, first-class, postage prepaid, addressed as follows: David J. Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 SHUMAKER WILLIAMS, P.C. Dated: By XAA? l Evan C. Pappas P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 ra ?? x' ? - c ?C ? . '' rte- ?.: ? --? ?? 4 ? ?? ? ?? ? ? r?s .v Our File No.: 143968 APOTHAKER&ASSOCIATES, P.C. By: David J. Apothaker �`'� � � f Attorney I.D.# 38423 - Ar-111: G. MountlLaurel,NJ 0 05406 �'Ef�'i SYLAMA�T't' (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 08-1580 LORRAINE M GRABAUSKAS ) Civil Action Defendant ) PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, LVNV FUNDING LLC, and against Defendant, LORRAINE M GRABAUSKAS, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on May 23, 2008, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of: Balance: LL( 1,280.00) 1.88 Less: Payments: TOTAL 91.88 David J. Apothakef, Esq. Attorney for Plaintiff A 'S I�.56 c �.� -iSy l Our File No.: 143968 APOTHAKER& ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 08-1580 LORRAINE M GRABAUSKAS ) Civil Action Defendant ) David J. Apothaker, Esquire, certifies as follows: 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on May 23, 2008, a copy of the Stipulation is attached hereto and marked as Exhibit"A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. All credits, if any, to which Defendant(s) is entitled, have been applied to the balance and are reflected in Plaintiffs Praecipe to Enter Judgment. 5. Therefore, pursuant to the Stipulation, Plaintiff requests entry of Judgment in the amount of$691.88. I verify that the statements made in this Certific on re true and correct. I understand that false statements herein are made subject to the pe lties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apothger, Esq. Attorney for Plaintiff Our file No.: 143968` ` z - APOTHAKER&ASSOCIATES,P.C. 2417 Welsh Road,Suite 21#520 , Philadelphia,PA 19114 (215)634-8920 Attorneys for Plaintiff Attorney ID#55140 = ? COURT OF COMMON PLEAS LVNV FUNDING LLC ) CUMBERLAND COUNTY } Plaintiff, } DOCKET NO.: 08-1580 vs. ) LORRAINE M GRABAUSKAS } Civil Action } STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties,and a settlement having been agreed upon: It is on April 28, 2008, STIPULATED by and between Plaintiff, LVNV FUNDING LLC,and Defendant, LORRAINE M GRABAUSKAS parties as follows: 1. Defendant agrees to pay the sum of$1,971.88, which sum Plaintiff agrees to accept in full settlement of its claim herein,inclusive of interest,counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant, LORRAINE M GRABAUSKAS,to the attorneys for Plaintiff in the following manner: a.Payments of$20.00 to be paid on or before the 30`h of every month, starting May 30,2008 until balance is paid. All checks are to made payable to LVNV FUNDING LLC,and sent to: Apothaker&Associates,P.C. J L 520 Fellowship Road 0306 , _ Mount Laurel,NJ 08054 MAY 2 2O i b 3. In the event Defendant fails to pay in accordance with the to ,t set forth in this Stipulation,then,and in that event,Plaintiff shall be entitled to obtai a en ry o Judgment against Defendant ex parte, in the sum of$1,971.88, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten(10) days,Plaintiff shall be entitled to obtain the entry of Judgment upon ex parse application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to L,ORRAME M GRABAUSKAS by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER&ASSOCIATES,P.C. Attorneys for laintiff A Law Firm Engager e Collection im ly .Scian,Esquire RRAINE M GRABAUSKAS Our File No.: 143968 APOTHAKER& ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 08-1580 LORRAINE M GRABAUSKAS ) Civil Action Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 32 N 8TH ST LEMOYNE, PA 17043-1557. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the efens Manpo er Data Center has sent back our inquiry indicated that the Defendant(s) is/are n t in t e milit David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Department of Defense Manpower Data Results as of:Dec-31-201305:03:24 •Center SCRA 3.0 Staff Report Pmuant to Sexvicememben Civil Relief Act Last Name: GRABAUSKAS First Name: LORRAINE Middle Name: M Active Duty Status As Of: Dec-31-2013 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 Dale 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 the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component' NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 6t it — 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/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAH 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: E6Q4EE363075660 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LORRAINE M GRABAUSKAS 32 N 8TH ST LEMOYNE, PA 17043-1557 COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 08-1580 LORRAINE M GRABAUSKAS ) Civil Action Defendant ) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT F-1 JUDGMENT BY DEFAULT ( f ❑ JUDGMENT IN REPLEVIN El JUDGMENT BY CONFESSION ❑ JUDGMENT FOR POSSESSION ❑ JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920