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10-4056
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION COVER SHEET Plaintiff(s) Portfolio Recovery Associates, LLC Case Number: ~~ ~ y'~5(p CtV 1~ assignee of CAPITAL ONE BANK NA/ _ 140 Corporate Blvd. Norfolk, VA 23502 Type of pleading: Civil Complaint Code and Classification: Commencement of Action Filed on behalf of Portfolio Recovery Associates, LLC assignee of CAPITAL ONE BANK NA/ (Name of the filing party) Vs ^ Counsel of Record ^ Individual, If Pro Se C'7 © _ i. , Defendant(s) Name, Address and Telephone Numlj~a' ~' p c_ ~I _.._ ,iii'! TAMMY L NEAL 438 MEADOW DR r r, Carrie A. Brown Esq. PA Bar~~055 -- -'"' ~ _` i ~ f r ? °~' :- CAMP HILL PA 17011 , , Robert N. Polas, Jr., PA Bar 2~~~59 _ ~' 140 Corporate Blvd. '~~ c:;:" ~ -; :` ; ~' Norfolk, VA 23502 =~ a~~~ ~; Telephone:l-888-428-8102 "'" ~` Attorney's State ID: Attorney's Firm ID: ~ Ra. oo Pu s~nr/ C~ IS'iq/!t 5028 12~ay38,S7 This ccnn-ntsnicatii»~ i4 from a deb# collector is a~7 attempt to cc~llec# a debt. _~n~ i~xtorn7ation ob#ained u-i11 be used t~>r tha# purposes. Came Brown, Esquire PA Bar # 94055 ~/kobert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 No. Plaintiff v. TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 Defendant 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 an 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 of any money claimed or any other claim or relief requested by the Plaintiff. you may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. 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 Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (800) 692-7375 I.hiy cammunic~tion is from a debt coilectr.>r i4 an attempt to collect a debt. tity ittfonx~:~tion obtained ~~ill be used for tl~st p~tirpa5e. Came Brown, Esquire PA Bar # 44055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. . Norfolk, VA 23502 . Plaintiff No. v. TAMMY L NEAL 438 MEADOW DR CAMP HII.L PA 17011 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esate contra usted. usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o ~ por cualquier otro reclamo o alivio solicitado por Demandante. usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service -CUMBERLAND County Bar Association Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (800)692-7375 -t"his camr~nunicatib~zs_ is frc~z~~ a debi collector is ~~~ attempt to ~,oltect a debt. ;~~y inf<:}n~xati{~n s3btar.netl ~~r'll he ~ise~l f~`k° that. purpc3~e. Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-512-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. v. TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant TAMMY L NEAL, is adult individual with last known address of 438 MEADOW DR, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to CAPITAL ONE BANK NA/ on July 8, 2009 with account number ************2682 (hereafter referred to as "Account"). A copy of the account history is attached here to and marked as Exhibit "A." 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. "Chic cc~nunualication is from a debt c~llec~tcn- and. is an attempt to cc~l'lect a debt, Any inf~>rn~atiE.zn c~l~tained rill be u.4ed far that ptrrl~<3se. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. ?. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on May 8, 2009. 8. Plaintiff is the purchaser, assignee andlor successor in interest to CAPITAL ONE BANK NA/ and Plaintiff is now the holder of the Account. A true and correct copy of the affidavit is attached hereto as Exhibit "B." 9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of $4,519.29. l0.Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, TAMMY L NEAL, in the amount of $4,519.29, plus costs of this action and any other relief as the Court deems just and reasonable. 09-15493 ~- ~~ Carne A. Brown, Esquire # 94055 Robert N. Polas Jr., Esquire # 201259 This c€3ir~tn~u~icaticai~ is l~ron7 <~ debt ct~llect€~r is an attempt C« collect a debt. .~~n}- i~~lorn7ati€~n c~bkained ~~-i11 be u,5c:d t~~r thai p~rrp€3se. PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428=8102 Fax: 1-757-518-0860 Statement of Account Account: ************2682 TAMMY L NEAL Account Holder: TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 Consumer Account Issuer: Assignee: Account Number: Product Code: MC CAPITAL ONE BANK NA/ Portfolio Recovery Associates, LLC ************2682 Date Account Opened: November 10, 2006 Date of Last Payment: May 8, 2009 Date of Charge Off: -June 15, 2009 Balance at Purchase: $4,519.29 Purchase Date: July 8, 2009 Claim Amount: $4,519.29 Less Payments: $.00 Balance Due: $4,519.29 "l.his con~~x~unicatian is f~•~cn ~ debt collectoz• and is a~~ attempt. to collect a debt.. Any infb~n~atiozi obtained u>ill be used for that parpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Kelly M. Roberts, Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing business at Riverside Commerce Center, 120 Corporate Boulevard, Norfolk, Virginia, and I am authorized to make the statements, representations and averments herein, and do so based upon personal knowledge and a review of the business records of the Account Assignee and those account records transferred to Account Assignee from CAPITAL ONE BANK NA/ ("Account Seller"), which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold; assigned and transferred by the Account Seller on July 8, 2009. Further a review of the records reveals that the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the account records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from TAMMY L NEAL ("Debtor ") to the Account Seller the sum of $4,519.29 with the respect of account number (************2682), as of July 8, 2009 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the account records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, there is currently due and owing the sum of $4,519.29 . Portfolio Recovery Associates, LLC By Kell .Roberts, Cus dian of Records and sworn to before me on / of ,,, ~ Lucretia Etheridge Commonwealth of Virginia Notary Public Commissbr~ No. 70x2513 My Commission Expires 091301010 09-15493 'phis c;-on~~i~~unication is from a deist. collector and is an atten~il3t ro collect a dek~t. ~~ny infannaticm obtzained ~~ill be ~xsed fc~r that purpc>c;t. PORTFOLIO RECOVERY ASSOCIATES, LLC ME TO CAPITAL ONE. We aro phased io ~ your credit aocaaat. Tbia Agtnanmt ooolahn ioEotmetian about yota aooouot Please mad it and beep It fix yrrur teoorda. >o thie Agrtxmeat d1e words "You", "Y~," and "yet®• Rf~r 1o each petspr who atgtlCd 111E appliwtiOA and to agyane else who urxs 111E aocaart m nary Way. The words "we", "ets", "our," mean Capidl Oae l3aok and ice srrxasaors or > We an delay eafotc~g ota rights under Chia Agreemeamwithout !wing !bean. Using You Aooouttt You can mdse putchmes and obtain cash adva>vas (if cash advaacea ace an option tar yea aooomu) by using your sad, accotart nmrber, and any acoovmt arses eilerb (atrlrrdavg Purchesa (2reda, Ganvmieoee CberJa, Special TramEer Checi~ and other similar chec]cs) that wa may rind to yw. Whin we provide you with atxotmt acxess checica, wa will Dell yon wlidher they will be tteamtd as ptasdtases, ash advances a apeoial traosfas. Unless we tdl you otherwise, Conva»ence C7sxb will elvvaya be treated as cash advaocGa. You agree that we tae not r+eapoawbie if atspoae rofi>sa to hanar yore aorouot. If you do not use Your scewtmt, you may cannel it by reboring your card(s) and aooormt aocGV rbedts to m within 30 days a9eryou teoeive them. Cash Equlvalattt TranaaCtiorts. Ifcash advaooes aro an option for your aocotro~ ycw coo tree ywr aocauot to putdwse ~ that are directly canvat-b1e to cash. Time cash ogtavsieot tiamaaiorrs will bo treated as cash advances and will ba billd m the cash advadx segmam of your aaamt Crib hattfadierts include the purchase of wiro transfer moray orders, beta, btOsy tidtetr, casdto gaming eabipa, arrd other aiorihr products a savior. Your Credit L(mit You agree fo maloe purrbeap err obtain ash advauoea ody up id your credit limit If you haw dilTeraR credit limits for diffaan ofyour aooota~t, you will be iaEorrned of the ued8 limit as your periodic atimemeat We mry damge your credit limit ~ arry Bove, may limit the anwrart that is avsilabb fur cash advances, a may etrchrde tenh advaoca eataely from your aiocoratt Wa may honor iA c>oxas of Yorr:credit Lmlit and those naoseedaaa w3l tie oavaal by this Agaanent ililakittg Payments. You promise to pay ~us ail snota-m d--e rrosulting from the use of yoga acowar; incirrdiog aaq fmutex charges aad other ~ due under the matins of this A®neemmt. Payrr-mn moat be rode in U.S. dolbrs. Payments made by a oegotiabla iasawnalt ouch as a check err a money order' cant be i4 a Evan accephibk i4 ua and be drawn on a U.S. financial iastiludon. You must pay at least the nvioioaimv paymaffi shown on your staoeovent However, Y~ ~ t~Y mare than the mioimrao psymem or pay the balance in ail. In any case, fitamoe r]mrgea wID oootirara to be assexsod during billing periods dint you arsy a baleooe regardless of whaher a trot ywr stameormt shows a min®ran >~>~~ we an aooept ]ace paymalts or partial payments or checles and money orders merited 'paymatt in fitil" err other similar langtrege with,o<u losing soy of our-tigha under this Agteemeat ioclerdwg our right>n rereiw payment in full. Periodic Statatrtant Bach marrth you have a belanoe in your aacouat, we will rood you a atabemart ahowarg aU taosactioos billd m Your accotrot daring the billing period. 'ib~l9iog period is the time Sinn one a0amnart clwiog date througbxtrd,inciudmg the next atamaneK cloaigg date. The ststermtt edosiog date deramioea the rnorah of a specific bt'ilro' g Pam Far ~pk Y~ Jantrety b~B period is the billutg Period wpb the closing data m Jaottary. Rnartce t'hargs kdarmation. A. A~lmirrrron Finance Chcrrgs. Far each billing period Ilmt acootmt is subjax to a fioaooe chag~e, a mioioam total fiwooe charge of SOSO will be imposed. If the Dotal fmatroe charge resorting firm the appliatioa yet>< Periodic rate(s) ;s less thin stl.$0, Vve will atrbtrect that amotalt firm the tOSO nrioimuar and the diffama will be billed to the pure~ase segrtleffi of your axotart B. ,lexrrrLeg Fbimres Cluvge You may not avoid fmame chetg~e an cash sdvanoes and apocial haosEers. You mry avoid >inerroa wee ~ new Pte, ~+' sparest peadreses, and on rww other charges by Paying the toW raw baleoa m full prior to the date 1~ P~ is due (tltis is the grata period on uew purchases). ffyou do not pay the aura trsw belaaex 6o~thi5 CUSTOMER AGREEMENT 001!3-11 pmiala modhly statement, finmnce ~ will aarue ~ the ratite previous new behmce Error the fast day of the new billing period. Finance charge, whirl appliabk will be 4 aase~ased a9 EDilOWa: Tramactioffi made during the tarrreat billing period: from traasxtian dace. • Undebed aamacfiaru acrd h~aasecfiona made with convenima chaeka: from the dales the tsaflsacr~on is lxooessed to your accrnart • Transacficos made prior to the ctaseot btu' g period: from the fast alerrdor day ofdle cutra~t billing period. C. Pertodic Rata We demamiae the daily periodic tame by dmdmg the amuel pa+otahye tame by 365 (if your biliorg addtem whin you opaled your accouiot was in IA a Wl and you have not used your aoootmt aflrr 1OV31P98, ere we mardily periodic rata determ~ed by dividing the aonud par~age rate by 12), and camding it up to ~ nearest 1/1000dt of 1%. The rate may be di~rrnt for each segment of your acoaart (e.& cash dvarroe. Pia, special prarhme, and spociel hana5er if aPPlicable far your accotart~ You were told the daily periodic rate(s) whin you opined your seaoota>t. If your eoocrrot has as iotroducoory tate(s~ the rate(s) Will reaarin in e&ct ttubss you era 30 days or mote lame in malong a payment err one overi'mtit in which case the periodic tone(s) may be chmtged to the poductary rates} Tf any dher rate chaogaa are made aubsaqumt W your aoroeud opeaarg, you will be advised of the new rate. D. Calm Firr®ret Clwvge We aksdeme 5oeooa charge each day by mumplyalg the balaaex of each segment of your saooelnt (eg. ash dvaooe, purehtne, special prachese, and special transfer) by the detly periodic rate(s) that has bees previously dixlosad tQ yea. Farb day during the biilivg cycle, we apply the derily periodic rate Sot' eadt sggramt of your sceoemt to the daily balmoe of each segrnaa. We thou add up the trsulb of <•adaelebow to arrive at your total periodic fiwmcx To gtt the separate daily bahrnces for each aeg<nera of your accamt tint the crurmt billing cycle, each day wa take the xpaate begnmiog balsrce trrr each segment and sepanuely add any trsvnctiorn and say periodic finance ~ alculamed on the previous day's baler-oe far oath segmmt. Wa then abu'act soy paymmb or tzedits pasted as of that dq that arc alloatd rn ash aegavent 'ibis gives us the seperrefe daily balances far aa~ se~mart of your ecoount However, the daily balance for purcbasm is oansidaad iA be m+o for each day of the currant b1llmg cytde if you Paid in bill ~e New Bahnrce, if aoY, shown ~ Y~ !saviour statement (or ;f your New l3alaloe was aero ar a credit amotmt). If your billing address whey you opened your axormt was in TA a WI and you have sot used your aooouot aRer 10131198, finance cherga is figuartd by t~iYmB ~i) ~ ~ ~a daily balance of your E. (/cPtabls Rata Wlvera and whey variable rases apply to your accora-; the raft(s) may vary alatlhty based on err the highest one (1) raooth Condos Inmerbaok Offiaed Rate (I.IDOR~ published in the "Hooey Rates" section of Tha A'oll Slb~ed Jaarro! w- the 5th day of eadr nrordh, or ifnot published ca that day, on the most recent data of publication prior to drat day; airy changes will be e~eCtive wilt yore Billing Period lading @re 6ailovring moon. if @-e periodic taro(s) and eorteapond;og anrard P~+~ Ada) , the finance charge wID iperease and your mionmml paymm may be greats. F. Cash Advance Fee Finm>ce Chage. if a ash dvma Eee aPP~ ~ Y~ axouat, you were told the fix whey you opined your aooamt The fee will be charged each time you obtain a cash advance and will be added to the ash advaax se®v~tevt of your a If the fro is changed subsequent to Your' account opeeing, you Will be edvixd ofthe raw fee. Other Charges. The folbwiog dlergps may ba bilbd to the purrdrase segareot ofyotr a lame charge d'we do not tscaive yoer payment a1 time for ii m bo aadited m yo-a acmrmt by the due date shown on your periodic ststemeat (if your brlly~ adds communication is from a debt collector and is an attempt to collect a debt. Any information ;h~~p~,~i~tsed for that purpose. l7"dbl rM~ le ~ .r,.,t..' ~...6 wfY`...:,d n... a.._...e_i n_~,._a__ was m IA when you opened yrna aocoemt end you Gave stormed ytrar account affil 10/31198, ptryntmt trntet 6e tteodvbd vvitttet 10 days aS>oc the dtta dale); ovs]'aeti< dvage if yea eooount ertceedt its credit litait, even if we approved the ovaihait amotee~ retruaed check ~ if a drx]r b tetitned to m Sa soy messy a if orb a»not honor yea at>oonait socets rheclot Sx mY nenrny and mPYmB for dnptax6e copies of haoeectioae a alaeemeots anises tegnhed Sx bi0bg dispute rmobyion. These ~ wi0 not be assessed ti'yosa blltmg address was b PR whm your acoouot was opened a if yea bilrmg sddtaee was is Wi wlm your eooottot was opened and you nave not used year aooomt atbr 10!31/98. The fee amoemts wem diealoeed to Y~ vdtea 1~ oPa'~ Y'~ ~~ Ife-Y of these fees are suMoqueot to yotr .oomaa opesriog, you will be advised ofdre new fee. Nlstnbershlp Fee If yea acootmt he's a manbaahp fee, k was diecloaed in yon when you opmed yule aoxna. The fee wilt be belbd >b flre prarhase aegotemt of yea aocoteat if the fee b dieoged anbeequeot to your aorntrot opeeamg, yon wffi ba advised of the Fitit«av Otters. The tams of any Sm:Ie o11ir we'0 be dietlosed >a yon at the time the ollis it made If you eooept an otter, the terms wID bxtsme e~'ectiw bnmodblely nakae odrawbe epeciSed b the oSir. DetauR. we may eomida yon to be in defiult milt this Ageeematt i1: (a) you fail to pay Cite ntinbreaa payment m time, a (b) yet eraxed yorr credit Bosit. To fire actert permimed by law, yon may also be in de8uit radar dlb Agreement i0 (t) y+oer violde erry of the offer terns of this Ag<eemert, a any of the tams of arty ether agneaetert wish res or say of orr eS~btea, or (2) you erode arty She or mbbedittg smraabnaa a< yea eppibatioo, a (3) beolnoQS~y or odts imolveacy penceed'og¢ alb irutihrled by yen or against Y~ ABer you aro m deSaolt (a aSs we gyve year eery notice of a right b sae the. deSark ~ regstQed by laws we may metrid yea aooant fronn new tramectiore, err dose yar aooorast and demead ioaatediete payment of Ute eethe outaomdbg balasoe. To Ste eateot pamtl~d by law, Yon agree to pay aIl coral oosb and wliectioa expemes oaaeed by us in the collectiae of sry atnotmt you own us tnda t~ Agreement: lfyea deSerk and we:~ yea axoesnt Sa oollectbn to ao who b sot our asleriod arapbyee, to the serest psmibed by 4w, you agree to pay rarembb atlanteya' Sees. You also agree to 1nY e1Y oasis orb may roar m mtrieviog yar cards, ietcindmg eery ~ we may iaaa by having year at>camt pytoed m a reeteicsed test. N You Clogs Yotu Account. You tea cbee your tt>cotmt by notifying ue in waiting, if you cbee yar aooomd, ytrn a.rrt roll pay all amotmb you owe to and wtll be respoonbb Sa any ~ that you atr~oeized prior to giving>m yar antis. Ifthab b a mambas>up foe ter your aooaag. Sro bee wrli caatinaae to be m the esdaet permitted by law, ueehl Ste aooorot nations bas ban peril m Stil. Yet mast elan retina all cards aed account: looms d~ >n m, taaod ell peaeeQtaiaed br1HOg erg and name tahtg yotr aooossnG If yon wad to stop ao asMhaiad tac'a aooees>A your ate, yon must send m wtiHm eaotioe aleog widr the ass's coed (ifaay) and aey axormt souses drerlro he a she may Nava If you aro >nebk b ranee that peesonh card and accormt atceea daeelas, and yon advise ua hr ~bg >q cbse Yorr aoooaut, Iron' aoooeaat wrTi be ebeetl sail badr you and the Joint eerdholder, if eery, may apply Sa a new ensurer. if we dose the acooom, yw and the~oiat aedholder, ifaery, wall snit be Babb, individueffy amd togemer, for alt emulate dteged do Yea accooaoG W tl.i-:; l H We Ctutcsl Yotu Acootmt or Suspend tit P~itAlegee. we mry at trty timq with a wi8toat cause sail advmx notice, teemmesegrit Agtbemeot aad/ar tamP~y~tY sutpetd Your abdit prinlegee. This iaadudee, but b sot limited Go, tidratioae whore yon have vbleeed this Ag~eatoem a where we have reason bo doubt yea aeditwerdtioeae (for etoanpb, ifyw pay m wtlh iasa~cieat Sods dreclm oa morn thm an oocssiomt basis). Your obiiguda-+e arils tbie Ageeemeot cute aSer yore righu 14 obtrtb credit have been tamimssed a aeretreoded. we may delay in errfammg as rights ands this Agieeenmtwffioat losing thmo. Chattpee ht Terms. We may aeoend ar ehasge guy pet of yotr Agreement, ittchrd'mg the perbdie rates sad attic ~'8a. a add s remove at sty time. If wa do ao, we oral) !~ Y'~ notice ifregaired by few of endt a s droo®e. m 9re emd peroeotage rate(s) wSi apply to yea ateernrt baleaoe Sum the ettlxeive data of the ~ wheffis ar not the aocormt bahma cdtded loemt 1n'Ded to the aocamt beSrm the ~ date and wtmma or not you tootioae to lase the aoooamt. t3nagw to ins sad oilier clvtges well apply m yea aceora>< from the eflbctlvb date ofthedmga. - ., Appileutbls ~ This Agreemcat will be goveamd by Virginia law aed Federal hrw. ~ T ~ Y ~ e1Y l~rovisiaa of lira AgReemetrt shell not eB'ect flte validity of eery odrs proviaieos. Lost ~ Siolen Cards err Acootptt Atxoes Checks. If your cads or annual erases chocle arc loot a sEOlea s if aomeo>x else mqy be utbg Stem without yore pamiwion, mtily ea et can by telling the tebphase number shown an the 5oat of your periodic sesomtem. Yea ]bbe7'Ky for tmmtlbarized me of your cerch a eteant at>aae etredsa w81 not erxeed 550.00. Yet will not be trobb for rneesyhoriaed use that ooars sibs you trotify m. Motu Btigrtp Adtite~. Yau a~+x >a gnro to vvriaen notix of atry ~ in yea baring add<am at lean 10 days before >jae cbaoga. l mety be vat~ten io rho specs provided oa ilea rbeoithsooe coupon ]ration of yotr periodic ate6earmt a may be amt m ~e foliowhrg add<eaa: laspilal tine, P. O. Bear 85015, Richmond, VA 23285-5015. If your aoootent is a joitd aceot~ s if more then ores person ~ ptsminbd b rise if, Yon agree that ell rega+cCmg the stoarot may be 'scot nobly to the address alrowa oa err br'>fmg teootda. Ctmtmtatit~tlar>s. We may ~ Ya+ (-~8 ~ atrtoaro6c dialing davioa, a recorded m~mgm) at has a wait rail those alb wr71 rat be oooaiderbd ianolici0ed. We may tnoerilor a reoad soy alb we mdoe or receive. We may release ilsibtnsaticn 1d o@-ers tegpnihrg the ataure s biseory of your aooosat We may melee ingreiea of bbd parties Bs comettioa vrSr B ~ ~~g 1"~' ~~. ~ Y~ atslhorime each third pertiea >n mbase abort ytmto us. Csudholder BenelNe, Cardholds besaSta may be a termiae0ed widront ratite. The bents may be provided by thhd pertiex we ue osot 3iable Sa arch bra s tic the sctiom a a offfiethird perch. US. Cunatcy. Ifyou mains s psrrelrase or tech advmoe b enrar~y, the llenasctien vvlU be canveroed into U.S. Dulles terksg Visa or Mae6a(aead regubriom soil Visa ~ MmeeeCeed may charge you a oaevaaioa Sra 1Le rasa is effect oa the uonvasum date may din's tlom the rate teed on the haosacdon data. ~ F This communication is from a debt ctnlformatand is an attempt to collect.a debt. u nose. obtained will be used for that p P VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Kelly M. Roberts hereby states that she/he is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 4/6/2010 gy; SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~i~l Sheriff ~ ~'~,;~f~( Jody S Smith Chief Deputy ~ ~~ ~ ~~ ~~~~ ~~~ ~ ~ ~~ ~~ ~~ ~'t ~t•~r6 _~,~ Richard W Stewart ~ ~`' ~``~~ ~~~ Solicitor c~F~c~ rrr ' "E sr~ERiFr ~~~V Portfolio Recovery Associates, LLC Case Number vs. 2010-4056 Tammy J. Neal SHERIFF'S RETURN OF SERVICE 06/17/2010 08:36 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2010 at 2033 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tammy J. Neal, by making known unto herself personally, at 438 Meadow Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally ', the said true and correct copy of the same. SHERIFF COST: $41.50 June 18, 2010 .~ RYAN BURGETT, D SO ANSWERS, RON R ANDERSON, SHERIFF ;c~ CountySui[e Sheriff. Teleosafi. Inc. Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 V Plaintiff Tammy Neal 438 Meadow Drive CampHill, PA 17011 Defendant ANSWER TO CIVIL ACTION To Whom It May Concern: FiLE,~.., : ~ :'~. ~~ THE' ~- , ~.r '",~°~~2Y 201QJL ~3 ~i~ifl~ lZ GUi,~I_;~ - - ~~iufv~fY L[G~ NO. 10-A4~6~-Civil Term I am writing to you regarding the attached letter that I received about a Capital One outstanding bill I owe. 1 sc I would like to start off by saying I understand this is my responsibility to repay this debt. I was making monthly payments of which I could afford to Capital One for the longest time. Even tho it wasn't the full monthly payment it was still a payment of good faith and Capital One continued to add late charges to my account which then would make the following monthly payment even higher. I made several attempts to work with them and ask them to stop doing that until I could get caught up. I also ask them if there was something that could be offered to me such as a forbearance or deferment of payment until I could get my feet back on the ground: As usual I was speaking to someone for another country and they told me there was nothing they could do for me. Capital One continued to call and send letters requesting more than I could afford to pay. So I got frustrated and just stop making payments all together. 2°d is the fact that this all happened when the recession hit. I do have a full time job that I have been at for 20 years. At my job I was given the choice to either keep my job and accept no more raises which at that time it had already been two years since I received a raise or loose my job entirely. I chose to stay at my job and receive no more pay increases. Therefore it has now been coming up on 4 years since I have received a raise from my employer and there doesn't seem to be one coming anytime soon either. I am a single mother who struggles everyday to just make ends meat with paying the everyday bills. I have to feed and cloth my daughter. I have to provide a roof over our heads. So with that being said I'm gonna give you a break down of my monthly income and what I pay out for everyday living expenses. I bring home the following: $2,624.00 a month I pay out the following for everyday living: Rent: 725.00 Electric: 161.00 (this is a budget amount) Car note: 333.00 Cable: 180.00 (which includes my landline phone and Internet) Car Ins: 81.00 PSECU: 100.00 NCB: 100.00 (This is for another credit card) Day-Care: 600.00 Cell Phne: 60.00 Grand Total: $2,340.00 Okay so now, as you can clearly see with what I bring in and what I put out in monthly expenses I am left with $284.00 a month. And I haven't even purchased any groceries for my daughter and I to eat nor have I put gas in my car in order to come and go from work. So if you can see a way of me paying any kind of money to you for a monthly payment please let me know how I can do this. At this point I see no way that I'm gonna be able to give you any kind of money. Everything around me has gone up in expenses except my paycheck and I have nothing to offer you. I'm sure at some point in my life I will be able to pay this loan back but I don't see it happening anytime in the near future. And for this I apologize, but I must provide for my daughter 1St and foremost. Sincerely: ~~ ~ ~~ CY)-~fi-ICS Tammy Neal 43 8 Meadow Drive Camp Hill, PA 17011 717-695-4948 Home 717-720-3298 Work Carne Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CNII, ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 No. I O ' 4 05 ~P ~~~<<T~ Plaintiff v. TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 Defendant 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 an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You aze 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 of any money claimed or any other claim or relief requested by the Plaintiff. you may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIl~TG 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 Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (8001692-7375 TRUE COPY FROM Ktcvrcu In Testimony whereof, l here unto set my hand and the ssa~ of said st Carlisle, Pa. Thfs_~~' d ~axirt ~ 20 ~1._ ~~ ~ k. This communication. is fraru a debt collector is an attempt to collect a debt. Airy in.fonnation obtained vF~ll he used for that purpose. G --~ IN THE COMMON PLEAS COURT OF CUMBERLAND COUNT'~~ us ~~ n~a ~ r- tv ~~ PORTFOLIO RECOVERY ASSOCIATES, LLC ~~ ~ .~ °o ~~ ~_'a w ~rn Plaintiff v ~ • t" ~, Case No.: 2010-4056 ~ ~,. TAMMY L. NEAL Defendant STIPULATION OF SETTLEMENT It is stipulated this ~~ day of J~y,~010, by and between the above-named parties, that if said Defendant pays to Plaintiff, at 140 Corporate Boulevard, Norfolk, Virginia 23502, the total sum of $4,711.29 to be paid as follows: monthly payments in the amount of $50.00 are to be paid by the 24~' day of each month until this account is paid in full. Monthly payments will begin on August 24, 2010 and will be paid on the 24~ day of each month thereafter. Plaintiff shall enter the above-styled matter as "SETTLED IN FULL". Should the Defendant default on the payment as herein provided, and does not cure said defect within ten (10) days after written notice to him/her at his/her address of record, Defendant shall consent to a judgment for $4,792.68 with prejudgment interest thereon and costs of this proceeding, unless any credits for payments are paid. TIME IS OF THE ESSENCE OF THIS AGREEMENT. Dated: ~- d~ - ~ ~ Respectfully submitted, TAMMY j~NEA~, DEFENDANT 438 Meadow Drive Camp Hill, PA 17011 1 ~ n 1111 ~ ~ . ~L~~~[L~./ CABBIE A. BROWN, ESQJl1I~CE ATTORNEY FOR PLAINTIFF 140 Corporate Blvd Norfolk, VA 23502 1-866-428-8102 ext. 18103 09-15493 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES,LLC . 120 CORPORATE BLVD NORFOLK, VA 23502 • Plaintiff No. 10-4056 v. • TAMMY L NEAL 438 MEADOW DR • CAMP HILL PA 17011 • PRAECIPE FOR DEFAULT Defendant : JUDGMENT • • • t._ r- •C. f ) File• Behalf of Plaintiff C s of record for t ' 'arty ~` Date: Robert N. Polas, Jr., Esquire,#201259 Carrie A. Brown,Esquire, #94055 Mark R. Garvey, Esquire,#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 09-15493 41/0.50 ply PLFF a* 39(0888 e- 609319 N ice fY12 i tect This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD • NORFOLK,VA 23502 •• Plaintiff No. 10-4056 v. TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 Defendant • • • C ula�> PRAECIPE FOR DEFAULT JUDGMENT relajad Please enter Judgment in Favor of Plaintiff and against Defendant,TAMMY L NEAL ; rfaiinre-te- am . (X) Amount Due $4,519.29 Less Credits $.00 TOTAL $4,519.29 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237 (Notice for Final Judgment or Decree),I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom ju•: -nt is to be entered and to his/her Attorney of record,if any, after the default occurred and . le.: ten days prior to - III to of the filing of this praecipe and a copy of the notice is attac• d. Robert N. Polas, Jr., Esquire,#201259 Carrie A. Brown,Esquire, #94055 Mark R. Garvey,Esquire,# 312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk,VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 09-15493 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES,LLC . 120 CORPORATE BLVD . NORFOLK, VA 23502 • Plaintiff No. 10-4056 v. : TAMMY L NEAL 438 MEADOW DR : CAMP HILL PA 17011 . Defendant .• • • NOTICE OF JUDGMENT (X)Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of$4,519.29. (X)A copy of all documents filed with the Prothonotary in support of • - within . .gmen i are attached. / By:-- -- — ----- If you have any questions regarding this Notice,please •.nta/ e filing "Or / Robert N. Polas, Jr., Esquire,#201259 Carrie A. Brown,Esquire,#94055 Mark R. Garvey, Esquire, #312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 09-15493 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM(EST) October 31,2013 TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 RE: PORTFOLIO RECOVERY ASSOCIATES,LLC VS. TAMMY L NEAL 10-4056 Dear TAMMY L NEAL: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Recd{� Robert N. Polas, Jr.,Esquire Carrie A. Brown,Esquire Mark R. Garvey,Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff 09-15493 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION—LAW • PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD • NORFOLK,VA 23502 Plaintiff No. 10-4056 v. • TAMMY L NEAL 438 MEADOW DR • • CAMP HILL PA 17011 • Defendant TO: TAMMY L NEAL 438 MEADOW DR CAMP HILL PA 17011 DATE OF NOTICE: October 31,2013 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 Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 �J J Pc-e Robert N.Polas,Jr.,Esquire Carrie A.Brown,Esquire Mark R.Garvey,Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 09-15493 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION -LAW • PORTFOLIO RECOVERY ASSOCIATES,LLC • 120 CORPORATE BLVD • NORFOLK, VA 23502 Plaintiff No. 10-4056 v. • TAMMY L NEAL • 438 MEADOW DR • CAMP HILL PA 17011 Defendant • AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for plaintiff,herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge,information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 438 MEADOW DR CAMP HILL PA 17011 and is not in the military service of the United States or its Allies, or otherwise within the provisions of the Service Members Civil Relief Act and its Amendments. /0" Robert N. Polas, Jr.,Esquire,#201259 Carrie A. Brown, Esquire,#94055 Mark R. Garvey,Esquire,#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 (T)(866)428-8102 (F) (757) 518-0860 09-15493 Attorneys for Plaintiff This communication is a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Results as of•Nov-15-2013 04:52:36 SCRA3.0 ti Status Report x r Pursuant to Sery cemembers Civil Relief Act Last Name: NEAL First Name: TAMMY L Middle Name: Active Duty Status As Of: Nov-15-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Data 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 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 Mo' 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Maui, YAL Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 09-15493 • 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.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(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(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: 55Y6957AMOEFYCO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION COVER SHEET Plaintiff(s) Portfolio Recovery Associates,LLC Case Number: assignee of CAPITAL ONE BANK(USA)NA/CAPITAL 10-4056 ONE BANK,N.A./CAPITAL NATIONAL ASSOCIATION 120 Corporate Blvd Norfolk,VA 23502 Type of pleading: Default Judgment Code and Classification: Filed on behalf of: Portfolio Recovery Associates, LLC assignee of CAPITAL ONE BANK(USA)NA/CAPITAL ONE BANK,N.A./CAPITAL NATIONAL ASSOCIATION (Name of the filing party) Vs Counsel of Record ❑ Individual,If Pro Se Defendant(s) Name,Address and Telephone Number: TAMMY L NEAL Robert N. Polas, Jr., PA Bar 201259 438 MEADOW DR Carrie A. Brown, Esq., PA Bar 94055 CAMP HILL PA 17011 Mark R. Garvey, Esq., PA Bar 312686 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Attorney's State ID: Attorney's Firm ID: