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HomeMy WebLinkAbout09-3097 Our File No.: 204419 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. YVONNE M BRYSON 13 E LOCUST ST ENOLA, PA 17025-3025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - 307 wit ter-W, 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. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.:' 204419 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. YVONNE M BRYSON 13 E LOCUST ST ENOLA, PA 17025-3025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT I. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are YVONNE M BRYSON, an adult individual residing at 13 E LOCUST ST ENOLA, PA 17025-3025. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4559542400892202; and said account was issued to Defendant(s) by WASHINGTON MUTUAL BANK, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $3,495.40. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". . 7. ' Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,495.40 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SOCIATES, P.C. Attorne f Plaintiff A Law Firm En as d in Debt C ectioi BY: Dated: 5/7/2009 David J. Kothaker, Esquire Our File No.: 204419 VERIFICATION David J. Anothaker, Esquire 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 relat' to worn falsification to authorities. David J. Apo ? Esquire Attorney for Plaintiff DATE: 5/7/2009 PAYMIM M041CM BAUINCEASOF ACOgMf DUE 067E PAYMENT 000LY200a !UMBER MaasM ,afM.{z7maLn N02.00 it.7llaa 4868-54244)DW2202 rr.r Cl.?wf w.us.r ar..4..rr«r.s W ANWNT DMAKa M..ff M Wfr WO rfp fr.?• e aq: au $ CUM?.?? Hru PIg11. ..Iut Ks? OHiO MW cho" Papble is MYrarplen mubw WASHINGTON MUTUAL CARD SERVICES YVONNE M BRYSW f4139 P.O. BOX 080407 120 REGENCY WOODS N DALLAS TX 7SH04W CARLISLE PA 170139085 ...111.11..u... III ... I Lo.111m111....n... 4559542400892202 0046200 0275386 0006300 24 ?., DETACH HERE y C Calarfll 6012 fir? aK t fNiia Ifjf {' 11 '.l M all $6238 11?a1IMk Naaaapw .. POUR ACCOUNT IS PAST DUE AND OVER ITS CREDIT LIMIT. Man pry dw mWmm payma{tl laid above dap rIM -awar0alaamarlImnlaCl m -1 aa101Ya.1.900.200.11"1. 'FOR BILLING ERRM AND INPORTAKT BFOIOIA7I014 SEE REVERSE SIDE ,. •Bahlrroa Ca.opay Awaraps Dally Pabme Anwo % Fbonm Oran ' DWIV Bdoaw• Rafe Rab (APR) ChwW Tams Sbrdrd Puiduw - wawa Cyrda .$2.083.82 .0035%' 30.48%' 082.74 Tam A SWrlard Caoh - Curran Cydo $0.00, . • * .0835%' 30.49%' SOAR Term B NOR A4 RMCENTAGE RATE91Ia bNao crab:.. 28.09X. 'Those rags mar want For 244aur Avlaaalod Aci aid Warr{Non• 0b call 1400.280581 of wMI us at www.pwtd mA0m Your aocB1I1R b brand by WashkooR 0*AW Batik FlaldOraen. NV. • 'r co FILEDa „r OF THE 200" PEA Y t PH 12: 10 't8.5o Pd A TrY c?c.'* t33'7 ? R RT* oZa51(o5 Sheriffs Office of Cumberland County R Thomas Kline e'pto st cuabry Edward L Schorpp Sheri b' Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFF4E OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/28/2009 12:07 PM - R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Yvonne M. Bryson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Yvonne M. Bryson. George Bryson, father in law of defendant states Yvonne M. Bryson has never resided at 13 E. Locust Street Enola, PA 17025. She lives at Regency Woods North, an exact address is not available. SHERIFF COST: $46.50 SO ANSWERS, May 29, 2009 2009-3097 Portofolio Recovery V Yvonne M. Bryson R THOMAS KLINE, SHERIFF c r ' _ a 77 C?TM i_ c. < Our File No.: 204419 APOTHAKER & ASSOCIATES, P.C. ~, BY: David J. Apothaker ', Attorney LD.# 38423 520 Fellowship Road C306 ', Mount Laurel, NJ 08054 I, (800)672-0215 Attorney for Plaintiff ', i PORTFOLIO RECOVERY ) CIOURT OF COMMON PLEAS ASSOCIATES, LLC ) C~LTMBERLAND COUNTY Plaintiff, ) ', vs. ) 0.:09-3097 YVONNE M BRYSON ) Defendant. ) I~', PRAECIP TO REINSTATE COMPLA T -CIVIL ACTION TO THE PROTHONOTARY: i Kindly reinstate the Complaint in th~ above captioned Civil Action for an additional thirty (30) days. APOTHAKER & AS O TES, P.C. Attorney for ain ff A Law Firm Eneaae i D t Collectioj BY: David J. Apothal~er, Esquire Dated: 7/10/2009 Our File No.:' 204419 APOTHAKER & ASSO LATES, P.C, BY: David J. Apathaker, Esquire, Esq. Attorney I.D.#384.23 524 Fellowship Road 0306 Mount Laurel, NJ 08054 CBOO> 672-0215 Attorneys far Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC clo Apothaker & Associates, P.C. 520 Fellowship Road 0306 Mount Laurel, N3 0$054 Plaintiff, vs. YVONNE M BRYSON 13 E LOCUST ST ENOLA, PA 1'1025-3425 Defendant. r , ~~iY 1A ~~ COURT Off' COMMON PLEAS CUMBERLAND COUNTY NOTIC f `"r ~-_. t ~ 4..,'3 . r~ .::~ -,.. ,~. ~< -_ f Yau have been sued in court, If you wish to defend. against the claims set forth in the following pages, you must take action within twenty (20} days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in wrtin~ with the court your defenses or objections to the claims set forth against you. You are warned that if you f '1 to do so the case may proceed without you and a judgment may be entered against you by the court witl~iaut further notice far any money claimed in the complaint or for any other claim. or relief requested by the plaintiff. You may lose money or property ar other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT` ONCE. 'CF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAW R, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAMAY OFFER LEGAL, SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCLATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 244419 APOTHAI~.ER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney LD.#38423 52fl Fellowship Road C306 Mount Laurel, NJ 08054 ($flfl) 672-0215 Attorneys far Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC e/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 0$054 Plaintiff, vs. YVONNE M BRYSON I3 E LOCUST ST ENOLA, PA 17025-3025 Defendant. COURT 01~ COMMON PLEAS CUMBERI:!AND COUNTY NO.. CIVTL AC`T'ION COMPLAINT FIRST CUT~INT 1. Plantiffis PORTFOLIO RECOVERY ASSt~CIATES, LLC c(o Apothaker & Associates, P.C., 520 Fellowship Road C3fl6, Mount Laurel, NJ 0$054. 2. Defendants} is/arc YVONNE M BRYSON,' an adult individual residing at 13 E LOCUS"T ST ENOLA, PA 17025-3025. 3. Plaintiff PORTFOLIO RECOVERY ASSOICIATES, LLC, is the Assignee and Successor in Interest of Account #4559542400$92202; and said account was issued to Defendant(s) by WASHI~1CxTON MUTUAL BANK, the Original creditor. 4. Defendant received, accepted and used the acc<bunt to its benefit. S. This account is in default and Defendants} ha$ an unpaid balance of $:3,495.40. A true and correct copy of the total due and owing is attached hereto, nnade a part) hereof and marked as Exhibit `'A"' 6. All credits, if any, to which Defendant{s) is'entitled, have been applied to the account axial are included in Exhibit "A'" _ 7. Although demand has been made, Defendant{s} has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendants} for the sum of $3,495.40 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APCUTHAI~ER & IOCIATES, P.C. Attomey~f 1Plaintiff A Law Firm En~a~ irf Debt erection $Y: _ David J. thak~r, Esquire Dated: 5!7!2009 Uur File No.: 204419 vE~zcA~C~orr David J. Apothaker Esquire 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 fotiegoing Civil Action Coznplain# are true and correct to the best of my knowledge, infozmation, and belief. 'The unjdersigned understands that the statements therein are made subject to the penalties of l $ Pa.C.S.A. 4904 relatiz~to'' un,~worn falsification to authazities. David J. Apo ~r, Esquire Attorney for Plaintiff DA'L'E: 5/7/2009 ' r~vtterr twtw sAwtt>:Aataa' A~ernarr tx>~ o~tE nv~rr ~n mnr~at n r•u.antawtr•cur,rxinssrm ~ ~~ (~- t ®~55!•b444.OOds~2Yff+! 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V~T1~~~ Zui;3 `'i f 7 ;~ ~ ~ ~! $l0. oc~ Po ATN ~~- l~tao79 ~*aasrss Sheriff s Office of Cumberland County R Thomas Kline ~i~. ~ `~ ' t+ ff ,n ~ ~?~ Sheri ~'~~' ~;"~ ~~ `'~~ ~,~~~titn nt L~rir+Lr~~~h Ronny R Anderson ~^' ~ ~ ~~}~ ~ ~ ; ~ Chief Deputy ~. ~~ .,~. ~~~~ ~,~.~v '~ tii.' j` '.,y ~' w 1'L Jody S Smith ~ `~ ~'~ ;'~'~~ ' ~ ;t t:. w ~ Civil Process Sergeant ~Fx~c~ ~" ~~~ : ~~~!~~ C ~.tV ~; ; . `r-~ i Edward L Schorpp Solicitor Portfolio Recovery Associates, LLC Case Number vs. Yvonne M. Bryson 2009-3097 SHERIFF'S RETURN OF SERVICE 07/31/2009 08:38 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 31, 2009 at 2038 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Yvonne M. Bryson, by making known unto George Bryson, husband of defendant at 129 Regency Woods North, Unit MHP Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 03, 2009 SO ANSWERS, ~~il~~ni~ ,~: R THOMAS KLINE, SHERIFF Deputy Sheriff V ' r Our File No.: 204419 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 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. YVONNE M BRYSON Defendant -FICE s P O 1iONOTAKY (,l,?t BERLAND COUNT`t ,ENNSYLV"'A COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-3097 Civil Action PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, and against Defendant, YVONNE M BRYSON, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on October 6, 2009, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount o£ Balance: Less: Payments: Plus: Interest from October 6, 2009 TOTAL >9 David J. Apothaker, Esq. Attorney for Plaintiff Dated: March 5, 2011 (LMA s co o t, Ck,U: ?q B a S o-i or MOA ved $ 3,728.59 ( 472.00) r Our File No.: 204419 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 PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. YVONNE M BRYSON Defendant David J. Apothaker, Esquire, certifies as follows: Civil Action 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 October 6, 2009, 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. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $3,728.59, giving the Defendant credit for payments made totaling NO.: 09-3097 $472.00, for a total of $3,256.59. are true and correct. I understand of 18 Pa.C..5-A. §4904, relating to David J.po aker, Esq. Attorney ? laintiff I verify that the statements made in this that false statements herein are made subject to the unworn falsification to authorities. Dated: March 5, 2011 r Our File No.: 204419 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 PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. YVONNE M BRYSON Defendant COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF CUMBERLAND NO.: 09-3097 Civil Action : SS. 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 129 REGENCY WOODS N UNIT MHP CARLISLE, PA 17013-9085. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 222 2593, if the De ndant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the efe se Manp er Data Center has sent back our inquiry indicated that the Defendant(s) is/are of in a mi ' ary. 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 unworn falsification to authorities. Request for Military Status 'Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Mar-05-2011 07:00:59 Last Firs#AYIiddle Begin Date Active Duty Status Active Doty End Date Service Agency BRYSON YVONNE Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). 14. )6t In Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Service Members 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 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 is on active duty, 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 h_ttpaHwww.defenselink.mil/fag/pis/PC09SLDR.html. If you have evidence the person is on active duty 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). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the https://www.dmdc.osd.mil/appj/scra/popreport.do[3/5/2011 9:58:18 AM] Request for Military Status 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 TARs, Marine Corps ARs and Coast Guard 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) for a period of more than 30 consecutive days. 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. 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 SCRA extend beyond the last dates of active duty. Those who would 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 name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:SRE542U09L https://www.dmdc.osd.mil/appj/scra/popreport.do[3/5/2011 9:58:18 AM] Our file No.: 204419 --, APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. YVONNE M BRYSON 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: Defe nt. 175- It is on September 11, 2009, STIPULATED by and between Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, and Defendant, YVONNE M BRYSON parties as follows: 1. Defendant agrees to pay the sum of $3,728.59, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $372.00 have been applied to the amount of 53,728.59, and the amount due and owing as of September 11, 2009 is 53,356.58. 3. The sum aforesaid of $3,356.58 shall be paid by the by Defendant, YVONNE M BRYSON, to the attorneys for Plaintiff in the following manner: a. $50.00 to be paid on or before the 5`h day of each month, beginning October 5, 2009 until paid in full. All checks are to made payable to PORTFOLIO RECOVERY ASSOCIATES, LLC, and sent to: t to te ;--- r .' . as ? _ ZUU9 r'' C COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-3097 Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 204419 4. 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 parse, in the sum of $3,728.59, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. 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 er parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to YVONNE M BRYSON by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation.. AVOTHAKBR & ASSOCIATES, P.C. Attorneys for Pla' tiff A Law Firm Engaged ' allection By: t_ ---' -, 11 ) imb y F. Scian, Esquire" VONNE M BRYSON G? -. LA_ A