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Home My WebLink About11-0321Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 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. I Norfolk, VA 23502 No. ??l I Sal , IV it -7 Plaintiff V. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 c o Defendant -OZ = --+ a,C7 c_ _`+R1 Mr ? G7 NOTICE c) You have been sued in Court. If you wish to defend against the claims set forth in the following p1Fg§? ydipnu „ e action withing twenty (20) days after this Complaint and Notice are served, by entering a written ape, ?sonally' or by an attorney, an filing in writing with the Court your defenses or objections to the claims set forth against-pu. 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 NOT 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 9 a Do `t'A a This communication is from a debt collector and is an attempt to collect a debt. y5 Any information obtained will be used for that purpose. Y.<,3 3 ?Gl? Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfok 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. AMY C SHEPHERD 6315 LOCUST IN MECHANICSBURG PA 17050 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 This corn.munication is fronn a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 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. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant AMY C SHEPHERD, is an adult individual with last known address of 6315 LOCUST LN, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to CAPITAL ONE BANK, N.A. on July 8, 2008 with account number ************3873 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively 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 information obtained will 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 obj ecti.on 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 January 12, 2009. Plaintiff is the purchaser, assignee and/or successor in interest CAPITAL ONE BANK, N.A. and Plaintiff is now the holder of the Account. A true and correct copy of the affidavit is attached hereto and collectively marked as Exhibit "A." 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 $1,288.51. 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, AMY C SHEPHERD, in the amount of $1,288.51, plus costs of this action and any other relief as the Court deems just and reasonable. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 09-95218 This communication is from a debt collector and is an attempt to collect a debt. Arm- information obtained xvill be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, TTyaHellgp} hereby states that he/she 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 09-95218 By: eaya e Custodian o fiords This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT A This communication is from a debt collector and 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: 1-866428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************3873 AMY C SHEPHERD Account Holder: AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase: Purchase Date: Product Code: MC CAPITAL ONE BANK, N.A. Portfolio Recovery Associates, LLC ************3873 July 8, 2008 January 12, 2009 July 18, 2009 $1,288.51 August 11, 2009 Balance at Purchase: $1,288.51 Less Payments: $.00 Balance Due: $1,288.51 09-95218 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Mam Holle bwk , 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, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from CAPITAL ONE BANK, N.A. ("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 August 11, 2009. Further, 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 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 AMY C SHEPHERD ("Debtor") to the Account Seller the sum of $1,288.51 with the respect to account number (************3873), as of August 11, 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 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 $1,288.51 . Portfolio Recovery sociates, LLC -16ZtQ= I a I By: o11enbeek , Custodian of Records \Ij Subscribed and sworn to before me on 31 of eC--• 2010 -Cy? Notary Public 09-95218 ?''. ?,N • B,o Ric'''-, 0" Z:A i 7H -niis communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Annex A Forward Flow Receivable Sale Agreement Amendment Number 2 Exhibit 1 to Forward Flow Receivable Sale Agreement dated February 6*, 2009 BILL OF SALE Closing Date: August 11th, 2009 Capital One Bank (USA), National Association ("Seller', in consideration of a and other valuable consideration, the receipt of which is hereby acknowledged, hereby sells, assigns and transfers all right, title and interest in the Accounts identified in the Sale File entitled 20090806.PS32CP.SLDFLEl.TXT (which may be in electronic form) to, Portfolio Recovery Associates, LLC ("Buyer'), without recourse or representation except as expressly provided herein or on the terms, and subject to the conditions, set forth in the Agreement (as defined below). This Bill of Sale is delivered pursuant to that certain Forward Flow Receivable Sale Agreement, dated as of February 6th, 2009, as amended, by and between Seller (as successor to Capital One Bank) and Buyer (the "Agreement"). All capitalized terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such terms in the Agreement. The Cutoff Date for the Sale File was August 6th, 2009. ' CAPITAL ONE BANK (USA), NATIONAL ASSOCIATION By: Name: Jonathan Stalls Title: Recoveries MVP CApF-35 Hoiw211986.10045016.00036 20100427_RMAPRA_?8 s73873_20100427.-stmt.txt 1 CYCLE # 17 CAPITAL ONE CYCLE FACSIMILE REPORT 03/18/2010 - 04/17/2010 PAGE 3547 ACCT-ID: X2967 CARD/ 8 3873 STMT-TYPE: ENGLISH TPC. MP HOLD: OW SAC-PGM: PREV-BALANCE: $1,273.21 PYMTS&CREDITS : $0.00 $0.00 TRANSACTIONS: $0.00 NEW-BALANCE : 11,273.21 MINIMUM PYMT : $541.00 $0.00 DUE-DATE : 05/14/2010 CREDIT-LIMIT: 500 CREDIT-AVAIL : 0.00 500 CASH-AVAIL : 0.00 RPAY-TOTMTHS: 0 RPAY-TOTCOST : 60.00 $0.00 36MA-TOTCOST: $0.00 INTEREST-CTD: $0.00 INTEREST-YTD : $0.00 $0.00 FEE-AMT-YTD : $0.00 HIGH-LATEFEE: 534.00 HIGH-PNLTY-APR: 23.15'% 0.000 CLOSE-DATE : OOB: N MISS-ADDR: N BK-HOLD: N BANKRUPTCY: N LEGAL: N CTC-CHG-IND: ARCH: Y REASON: 04 HARDCOPY: 04 ACTIVE WATCH: WO CRED-RVK: PO CUR-PD: 00 CTC IND: INS: RETURN-MAIL: CHARGED-OFF: BD XFER: FRAUD: OL: 11 REWARDS: N INTR CHRGS LATE FEE CASH-LIMIT 36MA-MTHPAY: FEE-AMT-CTD: OVERALL-APR: NEW: N ESPP: N CLOSE: MULTI-IND: S PROV-ID: 000001 US PROF-CNTR: 0000000001 COB SERVICE-OWNER: 000011 Mainstreet OL-OPTIN-IND: AMOUNT RATE CORR APR INTEREST CHRGS AMY C SHEPHERD Purchases 0.00 00.0634200 0023.150000000 0.00 6315 LOCUST LN Cash 0.00 00.0634200 0023.150000000 0.00 MECHANICSBURG PA 17050733615 US TBAL C/I BALANCE 0001 01 0002 01 TRANSACTION DATA SUMMARY NAME: AMY C SHEPHERD CUST TYPE: 0 PRINT AREA: 001 NUM OF CREDITS: 00000 AMT OF CREDITS: SO.00 PYMTS : 00000 AMT OF PYNTS : SO-00 NO CREDIT TRANSACTIONS FOR THIS CYCLE NUM OF NAME: AMY C SHEPHERD CUST TYPE: 0 PRINT AREA: 020 NUM OF DEBITS : 00000 AMT OF DEBITS : $0.00 NO DEBIT TRANSACTIONS FOR THIS CYCLE Page 1 t 20100427_RMAPR? 38733873-20090718_stmt.txt 1 CYCLE * 17 CAPITAL ONE CYCLE FACSIMILE REPORT 06/18/2009 - 07/17/2009 PAGE 4339 ACCT-ID; 2967 CARD#R ?M3873 STMT-TYPE: ENGLISH REWARDS: N FEE-FOR-BALANCE: N PREY-BAL: $1,144.09 PAYMENT&CREOITS: $0.00 FINANCE CHRGS $22.12 TRANSACTIONS: $107.00 NEW-BALANCE: $1,273.21 MINIMUM PAYMENT: 5541.00 LATE FEE: $39.00 DUE-DATE: 08112009 CREDIT LIMIT: 500 CREDIT-AVL: 0.00 CASH-LIMIT: S00 CASH-AVL: 0.00 OVERALL-APR: 23.150 TPC : MP 14OLD: 000 CLOSE-DATE: DUB: N MISS-ADDR: N WATCH: WO CRDT-REV: PO OL: 11 PD: 07 CTC IND: INS: PC: 0000000001 ARCH: N REASON: 00 HARDCOPY: 02 NEW: N EBPP: N SERVICE-OWNER: 000011 SAC-PGM: CLOSE: CHARGED-OFF: XFER: FRAUD: BK-HOLD: N BANKRUPTCY: N CHARGEOFF: N LEGAL: N FRAUD: N TRANSFER: N CTC-CHG-IND: PROBE-IDS: LINE: DELQ: OVLM: AUTH: REIS: PROD: PRIC: USR1: USR2: USR3: MESSAGE-IDS: PAST-DUE: INSURANCE: TRIAD M1: R0002 TRIAD M2: TRIAD M3: XFR: TBAL C/I BALANCE AMOUNT RATE CORR APR FINANCE CHARGE AMY C SHEPHERD Purchases 0001 01 1,162.48 00.0634200 0023.150000000 22.12 6315 LOCUST LN Cash 0002 01 0.00 00.0634200 0023.150000000 0.00 MECHANICSBURG PA 17050733615 Us TRANSACTION DATA TRANDATE REFERENCE NUMBER MERCHANT DESCRIPTION TRANS-AMOUNT POSTDATE C/O FC CARD NUMBER 07132009 PAST DUE FEE 39.00 07132009 D N? 3873 07172009 CAPITAL ONE MEMBER FEE 39.00 07172009 D N 3873 07172009 OVERLIMIT FEE JUL 17, 200 9 29.00 07172009 D 3873 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Page 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff -?ERIFF FILED-OFFICE OF THE PROTHONOTARY zoi j saw 24 AM 00 1 CUMBER SYN MANICOUNTY PENN Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Amy C. Shepherd Case Number 2011-321 SHERIFF'S RETURN OF SERVICE 01/19/2011 07:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2011 at 1910 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Amy C. Shepherd, by making known unto Richard Horner, adult in charge at 6315 Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 20, 2011 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (C) (7CUIt.ySLMP S enff. lekw5oft_ Inr,. J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW Plaintiff V. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Defendant MAR 8 20H Date: No. 2011-321 PRAECIPE FOR DEFAULT `? .. JUDGMENT rnru 'P- .. ? as ? "'CJ art -<> A? N Filed on Behalf of Plaintiff Counsel of record for is Party k r?6L 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 PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 = This communication is fi-om a debt collector is an attempt to collect a debt Any information obtained will be used for that purpose. Q I'a's 1N, P0 Pd CQ 5jj 0Q &I N,)j'ce !' 4i le-C( 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. 2011-321 V. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, AMY C SHEPHERD , for failure to answer the Complaint. (X) Amount Due $1,288.51 Less Credits $.00 TOTAL $1,288.51 (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) Date: Pursuant to Pa.R.C.P.23 1. 1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to be enter and to his/her Attorney of record, if any, after the default occurred and at least ten days prior t date of the filing of this praecipe and a copy of the notice is attached. 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 comrnunication is from a debt collector is an attempt. to collect a debt. Arty inlorrnation obtained will be used 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) February 15, 2011 AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 09-95218 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. AMY C SHEPHERD 2011-321 Dear AMY C SHEPHERD: 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 ! his communication i? from a debt t ollecior i,? an attempt ? collect a deb Anr , inti+milalOn obfamed will b .so,, liar t( 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. 2011-321 V. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Defendant TO: AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 DATE OF NOTICE: February 15, 2011 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 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 [ laiq rt;rr?r?t?z??ic???tts?t? iy lz?c=xa? i? sic°k7t c?}I€c?:Ct)t° i? ;fry °E°t ?Y ?i?a-;?. 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. 2011-321 V. AMY C SHEPHERD 6315 LOCUST LN MECHANICSBURG PA 17050 Defendant AFFIItMATION 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 6315 LOCUST LN MECHANICSBURG PA 17050 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, #2012: 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 09-95218 This communication is a cleft collector and is an attempt to collect a debt. Anv i.nfonnation obtained will be used for that purpose. Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Mar-01-2011 15:32:13 Last First/Middle Begin Date Active Duty Status Active Duty End Date 7 Service Agency Name Based on the information you have furnished, the DMDC does not possess any information indicating the individual SHEPHERD AMY C status. Upon searching the infonnation data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www defenselink mil/laq/pis/PC09SLDR html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:1T73ICBKAI