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HomeMy WebLinkAbout10-4165Carrie Brown, Esquire PA Bar # 94055 Robert N. Polar, Jr., Esquire PA Bar # 201259 FUR-t.± ; 'CE r T Portfolio Recovery Associates, LLC !,?? Tf-f Pn;,i,l.!rl'tnTh 140 Corporate Blvd. Norfolk, VA 23502 2010 JIUA 22 PM 12; 42 TELE: 1-866-428-8102 FAX: 757-518-0860 -, } Attorneys for Plaintiff i?TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 No. ?? - q16 Plaintiff V. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011-1525 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 c-a /Y0 4, /?iJ U 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: 757-518-0860 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. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011-1525 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 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. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011-1525 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 LUCAS H FLIPPEN, is adult individual with last known address of 9 DOGWOOD CT, CAMP HILL PA 17011-1525. 3. It is averred that Defendant was indebted to HSBC Card Services (III),/GM Flexible Earnings on January 26, 2009 with account number ************4509 (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. 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. 7. 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 December 29, 2007. 8. Plaintiff is the purchaser, assignee and/or successor in interest to HSBC Card Services (III),/GM Flexible Earnings and Plaintiff is ow 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 unpaidi on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of $1,227.74. 10. 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, LUCAS H FLIPPEN, in the amount of $1,227.74, plus costs of this action and any other relief as the Court deems just and reasonable. Carrie A. Brown, Esquire # 94055 Robert N. Polas Jr., Esquire #201259 09-05033 PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account : ************4509 LUCAS H FLIPPEN Account Holder: LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011-1525 Consumer Account Issuer: Assignee: Account Number: Product Code: MC HSBC Card Services (III),/GM Flexible Earnings Portfolio Recovery Associates, LLC ************4509 Date Account Opened: December 11, 2006 Date of Last Payment: December 29, 2007 Date of Charge Off: July 31, 2008 Balance at Purchase: $1,227.74 Purchase Date: January 26, 2009 Claim Amount: $1,227.74 Less Payments: $.00 Balance Due: $1,227.74 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 HSBC Card Services (III),/GM Flexible Earnings ("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 January 26, 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 LUCAS H FLIPPEN ("Debtor to the Account Seller the sum of $1,227.74 with the respect of account number (************4509), as of January 26, 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 $1,227.74 . Portfolio Recovery Associates, LLC Ke M. Ro erts, Cu todian of Records Subscribed and sworn to before me on of ? Nota ublic 09-05033 2010 m; '? ucreti? Efhendge Commonwealth of Virglnla Nctary Public Commission No, 7042513 My Commission Expires 09130i201 0 PORTFOLIO RECOVERY ASSOCIATES, LLC 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 By: -°? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,,,., Sheriff ~1~~.L; ' ' -,~~~~ ,.~ ~~ ~~,~~e,rr ~sft~rr~G~rf~~ ~~~ 'T~..~r ~L t s ~ - Jody S Smith t~ Chief Deputy ;;,-. i~ 2' ~'~ ~ ` ~ ~ ~t~~a ~~~ Richard W Stewart Solicitor ~p~r::F. „ -~F ..~_~~~:. ~ ~;.~~i~ ~,_ r <;.. ~~l~ !~ Portfolio Recovery Associates, LLC Case Number vs. Lucas H. Flippen 2010-4165 SHERIFF'S RETURN OF SERVICE 06/23/2010 08:21 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2010 at 2021 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lucas H. Flippen, by making known unto David Clouser, adult in charge at 230 Prowell Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $55.00 June 24, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (c1 Crnu?t, Suite She«i~f_T~eleasaR. {r,C_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011 Defendant No. (O - 141 (0 6 PRAECIPE FOR DEFAULT JUDGMENT ETt r r? ^? ?? C?XYe co -0 Filed on Behalf of Plaintiff C ,.rn r-j Counsel of record for this y r-o Date. Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-888-772-7326 (F) 757-518-0860 Attorneys for Plaintiff 7JcL i4j. 1 2 .2417 ?-1 A,144 kf- Al ? & t (? CL This communication is from o debt collector is an attempt to collect a debt. And information obtained will be used for that purpose. IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. V. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, LUCAS H FLIPPEN , for failure to answer the Complaint. (X) Amount Due $1,227.74 Less Credits $.00 TOTAL $1,227.74, plus court costs and statutory interest from the date of judgement (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.23 1. 1, 1 certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of record, if any, after the default occurred and at least to days prior to the dat the filing of this praecipe and a copy of the notice is attached. Date: Robert N. Polas, Jr., Esquire #20125 Carrie A. Brown, Esquire #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-888-772-7326 (F) 757-518-0860 Attorneys for Plaintiff This connnunication is from a debt collector is an attempt to collect a debt. Any- in?forination obtained will be used for that purpose. PORTFOLIO RECOVER" ASSOCIATES, LLC Litigation Cepartn, nt 140 Corporate Boulevard Norfolk. VA 23502 Telephone 1 (866) 428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Friday 8 AM to 9 PM (EST) July 13, 2010 LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011 09-05033 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. LUCAS H FLIPPEN CASE NO.: 2010-4165 Dear LUCAS H FLIPPEN: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania. Rules of Civil Procedure. Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff l his co111nmnjCifl?'l0t) la fro) I) a &I-It C011'CIJ iti I 1:01flat a 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. 2010-4165 V. LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011 Defendant TO: LUCAS H FLIPPEN 9 DOGWOOD CT CAMP HILL PA 17011 DATE OF NOTICE: July 13, 2010 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 Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (800) 692-7375 Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff i'hi5 comnuinicati?n is from i debi coll.-cwt ?tr :U?. mpI to collect a deht. All" int'onnation obtained 461! t,r w,,-d for J, it -urposc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATE, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. 2010-04165 V. LUCAS H FLIPPEN 9 DOGWOOD CT 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 9 DOGWOOD CT 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. Date: Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff 09-05033 1-his cornmuniention is a debt collector anti is an attempt to collect a debt. Any infoanation obtained will be used for that ,purpose. Department of Defense Manpower Data Center Aug-06=2010 12:43:23 Military Status Report 09-05033 Pursuant to the Service Members Civil Relief Act Last FirsWiddle Begirt Date Active Duty Status Active Duty End Date Service Name Agency FLIPPEN LUCAS H eased on the information you have furnished, the DMDC does not possess ary information inuicating the individual Satus. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information thatyou 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). lrq- 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 anyfamily 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 hto:/&v +rw.defenselink,miUfa=is/PC09SLDR.htmll 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 againstyou. 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 "Alive 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 Nat onai 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 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 Me SCRA is Broader in Some Cases' Coverage under the SCRA is broader i n 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 ti mes orders are amended to extend the perod 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. oe.,,..arn•12nhnn iecV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. V. LUCAS H FLIPPEN 9 DOGWOOD CT 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 $1,227.74, plus interest, on. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. By: If you have any questions regarding this Notice, please contact the filing party. Date. (?_ ( ?_ to Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-888-772-7326 (F) 757-518-0806 Attorneys for Plaintiff This cone nunication is from a debt collector is an attempt to collect a debt. Any inlorrnation obtained will be used fior that purpose.