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HomeMy WebLinkAbout10-5171Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866428-8102 L f j `'' t` t r FAX: 757-518-0860 QVt1 P?A 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. O ..r' 17r civil Tern Plaintiff V. KEITH D DUMONT 436 C ST CARLISLE PA 17013 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 9a1.00 PA Arl Cr y7alo/ao 150 E# 44"43 "This communication is from a debt collector is an attempt to collect a debt. A.try information obviined will be used for that purpose. 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. KEITH D DUMONT 436 C ST CARLISLE PA 17013 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 Demands 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 FUADA 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 ELGI3LE 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 This communication is from a debt collector is an attempt to collect a debt. Ativ information obttiin.ed will be used for that purpose. Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfok VA 23502 TELE: 1-866-428-8102 FAX: 757-519-0860 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. KEITH D DUMONT 436 C ST CARLISLE PA 17013 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 KEITH D DUMONT, is adult individual with last known address of 436 C ST, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to CAPITAL ONE BANKon June 9, 2009 with account number ************9225 (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. This communication is from a debt collector and is an attempt to collect a debt. Any infonnation obtained ??ill be used for that purpose. 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. 8. Plaintiff is the purchaser, assignee and/or successor in interest CAPITAL ONE BANKand 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 $1,081.51. 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, KEITH D DUMONT, in the amount of $1,081.51, 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 09-18456 This communication is froin a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Yvette M. Stephen 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 unworn falsification to authorities. Date: 4/23/2010 By: 't'his 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 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************9225 KEITH D DUMONT Account Holder: KEITH D DUMONT 436 C ST CARLISLE PA 17013 Consumer Account Product Code: MC Issuer: CAPITAL ONE BANK Assignee: Portfolio Recovery Associates, LLC Account Number: ************9225 Date Account Opened: June 21, 2004 Date of Last Payment: October 13, 2008 Date of Charge Off: May 19, 2009 Balance at Purchase: $1,081.51 Purchase Date: June 9, 2009 Claim Amount: $1,081.51 Less Payments: $.00 Balance Due: $1,081.51 This communication is from a debt collector and is an attempt to collect a debt. Any inforniation obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Yvette M. Stephen. Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. 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 ("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 June 9, 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 fiuther 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 KEITH D DUMONT ("Debtor ") to the Account Seller the sum of $1,081.51 with the respect of account number (************9225), as of June 9, 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 $1,081.51 . Portfolio Recovery Associates, LLC ule 792, By: Yvette M. Stephen, Custodian of Records Subscribed and sworn to before me on of 2010 Lucretia Etheridge Ot PUb11C Commonwealth of Virginia Notary Public Commission No. 7042513 09-18456` ^ My Commission Expires 09/30/2010 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. (t t)l`sClO,Lt rC i jDL4,( `-t.. tit• CVO 001/3-11 inaccount, TO CAPITAL ONE We an pleased to open your cradle This Agreement coobas k o mislion about your account Please tad it and beep it for your coach hi the Ageenttnt the wotde "yet', "yaws" and "youce nfer to each paraaa who signed the eppliation and b aoyaoe dw who was the meow in soy way. The words W, "W", "ox," mean COW One Bank and is successra or auu. We cm de* mforci g our rW is fader dos Agreement wtmout lonig1bem Uahp Yam Acootuft. You an make Purchases and obtain cash advances (if cesh advances are m option for your aooouy) by using your =, wootad n mober, and any accom access checb (inc6tdiag Pumbess Cmeco, Canvmmca C bedo, Sgieao1 Tansfc Cbedot and other slmnar checis) that we rnsy send b you. When we providt you with account checick we will Id you purb=6 cash advances or vocial whebar they w he ash you otherwise. Convockaw Checks will always be be Unless as we alb advmaa. treated OMER AGREEMENT Previous moodily ddmx t, fneoc chant will nowx on the ethm pnvious new bellow tam the Et:t day of the new biliatg Period. Fietaooe Charge, When applicable, will be assened as follows: • Transactions `maJle?&nq the cutest billing Period: tuns transecdon deft • Undated transactions and transactions made with convenience checks: Sum the date the transaction b processed to yotw aceour? • Transactions made prior to the eurract bIDmg Paw& tom the Seat abodar day fthe nicest Wing period. C Pvb& Rarer We detamlm the daily periodic race by 365 (if yaw bft addnw who you oopmed yaw account was b IA or WI and you have riot used yaw aceart aft 100 VA we tnamoNhly periodic nos defined by dividing die aoueel pacemp rate at 30 days or more bat in making a payment or are overlmo$ Posdukodickiry pur rate(s). If my other rate change am made upiot tra thm cagy alculldo s to arm ere ban charge. tow parodic fiinnoPam to pay .us an amuse due to each seaman This Ovas us the sepwo duly balocas for a mixinthly periodic 181110 to 60 WaW lghs wader fhb Agtseement inciadita oar deny Wheice of your chap will You agree that we are cwt ra tbJt if anyone relnses to hooch by 12), and 1 axing it up b the neared W000th of 1% The yretrrrlioaccount If you do not an ywx ecwuol? you g your and(s) and accotat acwu cleric us w?dlm civical it 30 drys e rah a1?D0, p?4 special Pu'k and aperral tranef ff ? tc you naive thaw VOicable for yotr aeeouio You wane told the daily periodic ( f Equhraknt Transactions. W cash advmoeis we m option for your aomint, I'?s) who you opened your aeeetm If your account has your you can use yaw 11=11]t b pudese leave that are atrodocomy, noe(s), me nfea) wM f nou in aged u w; you directly convatt8tle to ash Thee rah agrrivriahc transactions wni $09 mot which case tha periodic fate(s) may be changed to the be traatad d welt advances and will be billed to ant cash advance tmnt Of your sooaat Cash egeaiuralatt trataaetioos include me equ0d to Yow =count opetntg, you will be advised of the podag cimt chipofs win and othc transfEr ma simibr matey sans, botr, lo" , cow products or acviaa D. CdadaaoW Fbmnarawga We aiwbet Sow charge each Y *90 Unit You sPPnet to malts pttrhnq or obtain ash day by multiplying the below fesrh seg ' ofyour account 8dvmm only cep >Q your eseeSt lilt if you have di?rent audit (sly cub attvma, pudase, special purchase, and special limits for ditiamtY seayour periode meuat o shsrmenti you transfer) by We daily Periodic raft(s) that has bum pwjonsly mwill y chanp your the credit limit on ? your disclosed to you. Each day &r" the billing q* we apply h* to anount 69 adverhoes, or may mwhhdeash advaaoes is avanabb for ash the daily periodic rant for each serwat ofof yon accent to the arbra>y tut your aaaemt W daily below of arch MWft nw ens Paywin bs. oovaed You by Pam th Agc ®?:audit lar>ti and mole To act the sepaaoe daily balance far arh reatlting tom the ese (your aooont, iocYdbB soy finance chow s amount for the arras anf of your ad other Cheraw due under me teams of this Aatmerneot Payttheads sepetift begrWag below ? sepowt and day w td w the rest be made m US, cullers Paytateob made by a maotlebb my trmaadiow and seP? add aoce fit any l?k Sntace ? calculated on inshumerit such as a aleck or t amoty scar mint be in a urns tram day's below for each segment We then subtract pWtb to us and be drawn on a U S t3socid ioetihaoion You maul pay at bat the nhioimum pay My' moans or cult posted as f that day that are allocated payment shovm on your statement Iiowevmr, you may ?, in= then the mioimtmh paymml each aagmtnt of your account Ilowavc the daily below for Or PRY the below be owned dim m ing Sill la g ?' Aimee dwW will O00ti000 pia is omskkvd to be zero for each day of to caveat to regerdteas Of whams P due you cony a balance be'niog cycle if you paid in SA W kw Babocq, if any, shown OF W yar ataoenr?t abuses a mitr6unm en your paeviots a- - , (or if your New Below was zero I m1° or a audit amoua j If your Wlutg a dbm when you opened We an aoeept We payment or POW pq a checks and YOW account was in lA err WI and you have not used your money ovdm rWA to rmwivm rrt PaaYatnaimdt " it P te4' r in tall" or omer smogar hastens aceonot after 10t31198, Snsnee dherge is tigmed by aWy?i an. Pariodb StaMnlent Each mod6 You have a below in Yoh E Yw*rbls Racer. Wham and when variable ratan w-ount, we will send your account duiog ?eab °n transsetiom b7bd account, the race(s) may vary mooft bes xi on apply to ywx to thane 00111 one ateteoteat edoeing daft through ax 1 OOe (1) moollr London Interbank OS'aed Rafe (LIBOR "0011010t dOmS m of dYa Tie atsoement dun dsfe dataminas the Jbwrdm ant 56 "Money R*e day f adh ato* or if n t 2Yx * Wau S1t?eet mo period is me biitiog period w1h e F onc d do% on the mat 'doe f puWkadm prior diat da): any A Y• &qp will be dbcdve widr yaw B ft Period ending the Firtarx:s Clwrgs nudoa Mnetnua r Frsanar Mowing m? If ant paio& rape(s) and catr?iq Charge For each billing Period that your accost Is subject 1113111111 Pie rat(s) bmNse, the finance to a Sotoce cLataq a taolnalm tool Boom eases and your minimum payment charge of 6030 will be ' may be 8 Imposed If the 10111 &a= F. Cash Adi m m Fee Fbtmlea Chwgc if a cab advance fee rmsuhbg 5uhm the apptieaaion your periodic tape(s) is charp applias to ye11,. =*UK YOU Ware told the fie when you opened $0.50, we will subhead that MOM from the $O30 mithioion im aah and Your accola t The flee WE be Cbetaod each time you obtain a the diSaatw well be billed to the putemsae sagmeat of your with advance and will be added to the ash advance aegmmt of account B. A Your account If me fee is chmaed subsequent to yoga account FiIOe C7rargs. You mqy not avoid toms safest an exah ad openioL yon will be advised file new fem. vsatas and spadel trarsmrs You ,slay avoid Soma OR M The charge on now purrlmas, new ii1 lamas, sad an new chase segment (your aUlowing =uw ? whe WW to 11311 Pur n do do not repeM other changes by Paying the total new below is till prior in, the Yea P sy? in time for it to be aedited to yow account date YOUS Payment b sue (this is that craw period on ant due daft shown on your periodic atafemat (Ify? bmg address purchased If you do not pay to attire new h&bmm from the This communication is from a debt collector an is an attempt to collect a debt. Any informatio obtain ediarf &beehfl&"r that purpose CAPIW One Is a tervke nor* "f r'.a1.1 n.. ws b lA wbenyou opened your 'and yon bare amused your a of lOf3LAA pqu mt host be received wWm 10 days eSer the due ddO. overli10it c2srge ff your amost eumeeds its asigmed age )unk aver if we appuved the ovwgmmit snot; mebmed check dsrgs ifa check b reI A b m fibr any reason, or if we cmoot honor yaw sooong soccer dwh for nay reesor sad copyhg chow for dgAcde copies of trannotioos or shsemaate aasened mfyour bftg ad&= vm in PR ? your woomot cherve ?wu opened or ff your bi ft address wet is WI when your account was opened amd you have not and your saauet aber 10)31198. 'the She asnooft were diiscbsed to you whan you opened yar mcotnt Ifaiq+ of these Suns we deranged milsegnmt to your account opening you vM be odvsed of the am flea MwrA srahip Fes. If your account has a membership floe, it was disclosed to yon when you opened your awoant The he will be billed to do Puarhse mhegsoetr of your ecaount if me in is chmged ? to Your account optsmmg, you wi0 be advised of the Hussars OMIM The tams of sq Hine offs will be disclosed b YOU at due tfma the of36r s made. N you except a ofSEr, the scums win become dI%x1ve fmmedleeely u*n o&WM" s1 a Med h the of m Del" % may wmidwym b be n debi* uodw th11 Agremmmt ie (a) YOU ffsil b Pay the mhmimmr payment our time, or (b) you aocceed your aedr Rmit. To the mad 1 11'e1 by kw, you may also be in deli uh under sirs Agreement if (1) you vbbee my of the omer W= of dils ApeemeK or any of me terms of my oma erg ant t wmu us or my of our afll alas, or f3) you made my Me or mideedlug atseemama on your gVHcmdm, or (3) bWhWt 7 or other imolvenq proceedings in iniftad by you or Wbe You. After You are in ddMk (a SAW We glue YOU say notlee Of Or right to core the d@&A ff reulydeed by hWj we may )ethics your acomsm from low ment oft err dote yak aooasMend demmd immedfde pay orM m ft b"m To the cocas pemitte' by >m', You 88= 10 PaY eB court cesd and aoUndon mrpenses bind by us in the co&cdon of any mama t you owe m under the Arument If yon de" and we rata yak edootmt fbr conecdoa b era atsotney who b not our sabtled anVbM b ibe mamt peemiped by law, you agree b pay numbie Motu ys' flees. You 8110 agree b Pay mY casts we may incur n rabievisg yaw pads, indndieg anY cosh we may isaar by bo ftyow auxa 1 l placed m a rest<icsed lust. N You Cbss Yatr AecamtL You can close your account by nodMug is h writbg Ifyou does your accooK you not stln pay 811 emousts you owe a and WE be ragxubb for coy cbsga dw you sMl ideed prior to Oft n Your WdOL Ifthere b a membersltip flee for Your BccoUnt, the lee WM eon Otnae b be chirped, to me mamt puamided by law, and due aod0unt balance hoe been paid in Sill You not also scum all amb and aroomt seom dmda b IM, cmod ail Pfd blifag w mgeu mmb and lase mbg yu r eocc ot. Ifyau wit b amp m mmaiwd user's dooms b your account, yon must send as wrMtm notice abmg wdm the user's cmd OruW) red cry account mole swot he or the orb have, Ifyou = uneble to. emm that persons end and account awes dscc& sad you advse a in writing b dose yak aoooeat, your account will be eased and bum Yun dad ffie joy mAolder, if any. may epp(y for anew &=a t if we dam die wcour4 you sod tali" pr -'W=W' will Am be li*k, bdividumily end togp*dw, fir ail amours d mged to your aoooum. Veld.)-d.l a We Gnat Your Account or &mpww CrxM F?vRsgas, we 1041' at MW d%% YA or wimout cm sod will" adwoce RMIcei temmisase Hatt Agteeme t ad/ar eeml10e:iljr or pbuneudy 304 and your am" PMIes. Thb includes, but b not limited b, skostions where you have vidbod dm Agusneot or where we hive reason b doubt yaw aedilwo r6iow (fbr , 1 11s6ifyou Pay us w;m iewfilciem sods rbeft m more slum so ooce and lees). Your oftdooi n? ? coadows der your rights to as zftour r*ftunder tbsAp ameatwimatb*g? m Chor" In Timms, we my amaad or dmp any pert of your Agrecuseck iaclndiumg to periodic atat and otlas clis m, or add or lemurs regUiremenb at my dM If we do so, we VA on you nodoe Wregaied by hw of such mtadm 1 - or d=@L Changes to tiro aims per I I Imp )see(s) will V* b your account bahnce Sum me eflbedve 60 of the csoge, vvb mcr or not the account bolam included hems trifled b the amount before the c mgt die and whedw a not you oaaII I ID Imo the aooount t]ur" to An and{ Odff tberges whR apply o your am scum from the eflbctive derv ofinedamge. ..A AWRoMb' Luca. Ths Ag mvw will be governed by Virginia hw and Federal hw. 8sverobfNhf. The y of my provision of sirs Agurnat shag notaffid d evWft ofany omarprmsiom, Lost or 85otwt Gods or AcomM Accs» Checla, If your cards or account doom dada era bet or stolen or if someone the may be usisg them wlmout your p, " Iq notify m at am by aft the 11 11, 1 numbs shown on the tat of your, periodic IMININK Your M ft Sr mmmaiaed use of your arcs or account Mons checks will mt mecaed SM.00. You wM not be Rsbk fir unsnmor!md use that outans after you no* Ua. Your BMft AdtftnL YOU agree to give us VMft Mtn of my dmmge in your biBiog add= at lams 10 days beibre the ebmge. Clangs mqy be wrinm ten All space provided on Sue ramhkseooe couponportionofyourl, iodic sheerraemt or miry be asst to the folbwbg addeetr CAP" Out, P. O. Roc SSO15, Ridmntomd, VA 23285-SO1S. lfyouraoooot is a joim aocamt or if Mae item erne per m s ] Men fo use k you ogees that all rmotiees teaKft die acaomot may be lent solely to the access shown on our bft recotdt, ConununiestIM . we mfr ail you (am live CPerae^ autamtic &ft duMCM or recorded uutesreget) at borne or wait aid thumb ads will not be cemtidesad msoucited, we my monimr ur record soy alb we mat a receim we my, I eea?e bfamadon to omera meptlis the stator or hbmey of your aooa nt we nW net inquiriss; of third pmtles in dounecdou win uninhining sad colbcdng your aooo, end you adsort m such mind parties b relent h f con ion about yon to us. GrdhoMw BWWfSs, Ordrolder bete tt may be chmnged or terminated VA" ntdioe. The I RI may be provided by thud Pffft we We not Btble far such benef3ls or fur the action or arnW= ofdwtldrd pmtiev. M& CW WAY. lfyou mdse a pon*me or ash edva m in foreign Vim or will pt domvaled btu U.S. DoOma using revoldiorr dad Visa or Mas*Cmrd ID8y ChWP You a eoaveesian She. The rate in eMM on the conversion date may difHir Stmt w rate used on the htmerticn dose. w 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 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 2~~e ' S ~ ~ ~ v. KEITH D DUMONT 436 C ST CARLISLE PA 17013 PRAECIPE FOR DEFAULT Defendant JUDGMENT 1'.. Filed on Behalf of Plaintiff Counsel of record for this Party . ~ . Date: . • . ~ o 0 '*7 -~, ~ ~~ ~ r o ~ --i rr ~ ye z V'S.~ ~~ ' !Y ~~ ~ l ~.. C~ ~ ~~ ..i. e~f*_p~y ~ D.~ .. .a'..{rn ~ ~ ca r A ~ ~ik.~~~~~~~ Ctc-~' 3?~.3~ ~,-~..2 S'ac~a ~ ~d~~ ~ ,n~ ~ ~~~ `t`his communication is from a debt collecto~• is an attempt to coIlect a debt. .Arty infot-rn.atio~i obtained will be used for that purpose. Robert N. Polas, Jr., Esquire, #201259 Carne 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 -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. Zo I o - S ~ 71 v. KEITH D DUMONT 436 C ST CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, KEITH D DIJMONT ,for failure to answer the Complaint. (X) Amount Due $1,081.51 Less Credits $.00 TOTAL $1,081.51 (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, Icertify 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 ten days prior to th to of 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 "1`his com-nw~ication is from a debt collector is an attempt to collect a debt. Arzy~ intorrnatic>n obtai~~ed will be t€sed for that purpose. ~~ PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 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} September 9, 2010 KEITH D DUMONT 436 C ST CARLISLE PA 17013 09-18456 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. KEITH D DUMONT 2010-5171 Dear KEITH D DUMONT: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sinycetely, • 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 't'his communication is from a debt collector is an attein~t to ec~llect a clet~i. Any informatio~~ ol~ix~ined will be rased for that }purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY A5SOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff v. KEITH D DUMONT 436 C ST CARLISLE PA 17013 Defendant TO: KEITH D DUMONT 436 C ST CARLISLE PA 17013 DATE OF NOTICE: September 9, 2010 No. 2010-5171 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII,ED 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 HEAR~TG AIVD YOU MAY LOySE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS: YOU SHOULD TAKE THI6 FAPER TQ 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 HIItING 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-?375 Robert N. Polas, Jr., Esquire Came A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff This evmmunicat.ic~si is frvn~ a c{el~t evllector is a~~ attempt to cc>llec:t a debt. f'~ny i~~tvrmativu obtained ~ti-iti Fie used far that pw~pvse. 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. 2010-5171 v. KEITH D DUMONT 436 C ST CARLISLE PA 17013 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 • 436 C ST • CARLISLE PA 17013 • • 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. ~~ ~1' ~~ Date: 09-18456 ~~ Robert N. Polas, Jr., Esquire, #201259 Carne 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 "1'liis communication. is a debt collector and is an attempt to collect a debt. Ar~y i.nforrnation obtained ~itl be used fir that purpose. Department of Defense Manpower Data Center Sep-23-201 Q 13:36:28 Military Status Report 09-18456 Pursuan# to the Service Members. Civil Relief Act ' ~: Last FiristtAAiddie - Begin Date. Active Duty Status Active. i]uty End Date Service ..Name Agency, DUMONT KEITH D .Based on the intormation-you have furnished, the DMDC does nut possess any information indicating the individual 'status. Upon searching the information data banks of the Qepartment of Defense Manpower Data Center, based on the information that yrou provided, the above's the current status of the individual as to all branches of the Uniformed Services {Army, Nair, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). ~M~f# Mary M, Snauety-Dixon, Director Department of Defense - Manpovder 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 vh eligibility for military medical care and other , eligibility ystems. Thee DoD strongly supports the enforcementof 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 " ar>y 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, yr 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 viathe "defenselink.mil" URL httb~llwa~v defenselink milifegfvis1PC09SLDR html. If you have evidence the person is on active duty and you fail to obtain this additional Sertrice verification, punitive provisions of the SCRA may be invoked ' against you. See 50 USC App. §521{c}. if you.obtain addtional information about the person {e.g., ah SSN, improved accuracy of DOB, a middle name'you can. submit your request again at this Web site and v~re will provide anew certificate for that query: This response reflects active duty sta#us including date the individual was last on active duty, if it was within the preceding 367 days For. hi torical'information, please contact the Service SCRA'points-of-contact..... More Information an "Adtve Outy 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 bythe Presidentand supported by Federal funds. All Acti~~e Guard Reserve iAGR) 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 dory 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. CaYeragB Under the SCRA' is Broader ire Soule .Cases Coverage under the SCRA sbroader in some cases and hciudes,some categories of persons on active duty for'purposes ofthe SCRA who would not be reported as on Active Duty under`this certificate. - Manytimes 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 vvhich 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 onto be inducted, but who have not actually begun active duty or actuapy 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 alf,nghts guaranteed to Servics 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. Fie[~or`C iC~:FMId,~.~E,~~gLll~= IN THE COURT OF COMMON PLEAS OF CUMBERLANIrCOUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 2010 - g ~ ~ ~ v. KEITH D DUMONT 436 C ST CARLISLE PA 17013 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 $1,081.51, plus interest, on . ~/l,Z ~ j O (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 filin b ~-1~- -o G Date: Robert N. Polas, Jr., Esquire # 202 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 com~nu~~ication is from a debt collector is an attempt to collect a debt. Arty ir~t~>rrnatio~l abtairted will be ifse:d iz~r that purpose.