HomeMy WebLinkAbout11-0329Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie A. Brown, Esquire PA Bar # 94055
Portfolio Recovery Associates, LLC FILED-OFFICE
140 Corporate Blvd. 'OF THE PROTHONGTARY
Norfolk, VA 23502 01
#M11: 43
TELE: 1-866-428-8102
FAX: 757-518-0860
Attorneys for Plaintiff 'CUM B-'?' NTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
140 Corporate Blvd. No. p?l
Norfolk, VA 23502
Plaintiff
V.
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
Defendant
NOTICE
CANil_Ry OA
You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take
action withing twenty (20) days after this Complaint and Notice are served, by entering a written appearance, personally
or by an attorney, an 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 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
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
(!P Caw ?b Q I'D
QV 4 53 SD
C 5TJ 001
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 10, 2007.
8. Plaintiff is the purchaser, assignee and/or successor in interest CHASE BANK USA, 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 $1,646.64.
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, PRADEEP DASS, in the amount of $1,646.64, 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
09-97610
This communication is from. a debt collector and 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, TMI Hollenbock
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 unworn falsification to authorities.
Date
09-97610
--I??
By:
Custodian of Records
This communication is from a debt collector and is an attempt to collect a debt.
Anv infr%rmatinn niktainwi -rill 1.e „-e.i r-- A...a
AFFIDAVIT OF SALE
OF ACCOUNT
BY ORIGINAL CREDITOR
State of Maryland, County of Frederick
Angela M. Shubert (want) being duly swarm, deposes and says:
I am over 18 and not a party to this action. I am the Operations Maur (title) of Chase
Bank USA, NA. In that Win, I am cuskdan of the creditor's books and records, and
am aware of the process of the sale and assignment of electronically std business
records.
On or about September 10, 2009, Chase Bank USA, NA (creditor) sold a pool of
card-off accounts (the Accounts) by a Pt a and Sale Agreement and a Bill of Sale
to Portblie Recovery Associates, LLC . As part of the sale of the Accounts, electronic
records and o6er records were transhrr+ed on individual Accounts to the debt buyer.
Thy rwm* a kept in the or ary course of busmess of Chace Bank USA, NA.
I am not *wan of any arm in there accounts. The above statements are true to the best
of my knowliedge.
Signed this 16* day of September, 2009.
&9121
* Manager
Sworn befog" t* 15,"' day of September, 2009
(Notiry Stamp)
RUTH E
w Mft"?#CK COUNTY
t, .4g I-- 12
t A 001 tU
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170
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and ire Pt ing wtrk h q*wg on vwcw.c,ww
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MUM wNh y?ourreoordL ?? ? f
wt
a
kdvw UM 7w mMn alv pWON Mon am go,
and
OW who is M*wM 1 it ym ave*
Vba =
aip w the ? qM AOfiffi ooouo or PKM who
gwmw -
pMsdan theAooourtt. t
a°nd° a IDTheC
oetbrs to the Chore VNe C
which we b Yom A~ W" b yaw Cif y?
andku MGWlF Wd Acoomt rrhh ut.
un Of YOW AoociAL ft haws Wp YOU the C846)
YOU aged W. You
My M the Card Iwe orpzaw*. goo& &W 10 ObUM
sewicft on c mdit tram ft Cud
s)"). You may Aft P ftcam I* sot w loans
loom to or ton pqm who YA
Card (such a amft bmW wdWIM Q hour
ha Is or Uk)wMW depew upon t? rlraohbw (AM)
010
idtion , in Proper penonari
you Mby use
Chw Visa andlbr MOW Chec
king do dw' M
W or)
wift we issue to YOu to obtain Cash A?dvan m We do not
h" no ?? dhonorihe Card ate, wd we
of them. We wit not be pebb?e refuw to accept e?i?er
othOt per9on does not hear your Card, m&&&% any No Check, that form
of r for a Purchase or Cash Advww, or fail$ to
PrOvO MY SOO M* avaib * to by w. From tune i )u to time you mayy be reed to fum ideMip om when
Cruet Without A Card. It you or someone
b
rcuft"h Advsr? cr y0a ApMMgo" ae? OR ant
a or OM* a Yaw NUMM
mo t b mete e
ft
Cad (ach go
a?= bra moM order a temp or
Card I* Cho* 41
P aNw W11 be out no
? ?
c'd ozs.ON
yv?
For ppb
CWW -a t>tt tR ? Phi or be
dft is
upon
Ma *w w1r yw awN MOW b us
sur'°ifze Cacho Mee mount of jW tad.
-? a c?dt Add, gtedc to YntK
rwmb Of Ch L Ewh ChOl* =tlW y?,r Account
nnm*s) t:Onad on bye ?K# wtase
"' U* MM =NFMWNW
Advents wed b dw AS=
M ? ft do* we poy y my rd to a
We Cb rrw filvo ° antler ft
MOW a pay Ow a
Chft ?ar Check aad we No not
Uwe!
A be not betrq b ?? pdd by
.
Q"ft For rde on OM ?' Pe?bdc a1?
lww !bra Ptiad? wM, a C,K y,'
a 4y" AeWR Of ft* ? We ? ft
.-.You* YN
la ii W4 c heft that + e
err n *r?. we i
d ?Cas?ah Ad+a?cea -rte abow 0°? smou? and
H ° pft joie Ourpea
W.
T b
Is INS O*d
the IZZ"oft! aftftlania We may ft
any ON clay. "Ok*M we WN 9W your Aoook on
We area not obi
aIhorl0 a
Y? ? or your A6=0 or to hftw&m pa
U*q Ch it.
y a
exceeded or would be a or caih Am** &e has been
?(? you
'a" kW to Pay amount owed to
have notified us of of ave det?ermo? thath h (3? YOU
Me% tlw Card oryou
Checks ha" Or may have been lost cw
4bG orin fault or your rights under O r(4) You are
or been revoked. INS A have expired
our brjzatior? system is not fuify
rA•'
10*4 W,, O*y rtot be.w* b 9% our "mw kr some
?OWN NOW
we 1w w
roaeons wr q?vt Mort For ft"
a syn ° 'Pid ft dMt of how our
our
aL4hftwm
t Wbe fw nww " nor
9M9- an
dWp ? qC you "Oft us to?pay
and
Ad+ Cash
Umi imtoun
Acmwt Adva aPrornl®e bpay to ror d afr R for wft t Oww and Other Charges
that you ftuy owe us.aa odter amots fesponaft Onor muft charges on for any
d to your lauch as
buk of ho1e1 or car tarsal PACO" VW ON Pied b be
?
dwW Polies f xAflcaint underO? of
M* u?aufhof IN aruedn?Yju MY ° be We fol,
doom ww b ? go Of Your Aooqu)% as
anrourtis chyme N Ioraq
Pm* b oft Me on
other perms uang youru Card a Pam Yw your
Or YO, A or
Pied of ant any
AckA
pemon is " for suds wa d mm than one
IYE ? ' on Wo nay
sum re p s) At =hi •w? p?
Ea
aretdtOwn ?p? ko amid cash
SCCM perfodtc ? aedtoron ? not *% we the * WW bdanaeon ?A"bld for
Cashi
any ffm
Pub or to obW CaA you w to to unpaw MOM
the
do we ma kitL y Account 00"d ftse if
ree t y it i ?y `c - the e1coese arb you
change or cs" yow ae?t one a9re° Mal we may
any time without Prior s km at
notice and
obligation to pay amounts that you Owe under yth s
Agreement. Any such
from our Periodic review m resuk
and/or Conran on yWX Aacotmt
r ap es (credit bureaus).
n a a7C • nF.
We*
WO va W4 you a
adwam I" s no Me" W" cyal Pwk*
Gargb h" been irnpoe d y Mtan it of when a sow not rrr edge any no'* w y you do
on M.- A"IN.O.AN pp*b . m? ? ? by a in sc? w??t ?-
WjWlI:mk *WWt
Ar
??
P41raft mum Moo rw
p S. 6km or such Or °r
maw Q? p"mt =40 wit ra1 as we
a 101111d or dra?it
mm?aaqq a b
iiev that it W p • ?Aoootrit torreasons .
signature is missirgj; Csuch as when a
than
thZZIn ewritan amount; ori? flummt amofmt ad wdead on
1 not me& ?t Im is ro t byyOwbWkWI will it be roturn?d to CIROIN110yawAmAror a
s 4nY p:<Yment C i$rIct f ?° ?
aca won 110001111" ert U Old Slalim duuge you any WA *6dion fees WO VYdo&
U.S. "m drawn on a non-U.S.
?* mak in IIIIIIIIIIIIIAM
UN a can OWD ate or MW pwwft and pals
such as
Up*
At ow * m tub', wlMOA"sry of our d0k
' option, we omay twit You to aldp Mhn urn
. Financ? a l condrn emt0on m°nq? iOu P f?• WRIng
amm on the
e suuch and
ncee with the rrm 0% t?gd ij b& ?? wed in
nwf?p$ ? l? p"Not El?you
us at WO you? Pat lbear' i,o°°ay?ou n y
Date. Your m ;;MTZ= ?e Payment Dtte niftnuin 1 othe n larger amount of the Cit.
e ft*mm Payment lradion
Acm th
POW Is ndpiled
New balance or Ca your tiro tach? your Purchases
N it Is less than $10); plus an New nc?
2) the larger amours of the minimum fmcbon
shown on the Pricing Schedule mufliplfed
Py "Your Cash
Advances New Balertce or $10 C0( your entire Cash
Advances New Balenoo y k 4 teas ttwn $1Or plus
3) any past dare amount; Ous
'?1 01 %AJJ WIMAII MY - ' J nor • n.
you owe in excess of your
46. 1 . .`
?,? 41 C?11 App9a
f ?
Of ft
pqmmon A4=0 mWW we may
Cn006• in ow Soto ,tw
' post
Y
WftM* on ft dete we mc*o
ft4
10 You room ocyow p a y may ft
date to AN* Vo y cold
u&m pVft kr
on
MW Ind
institV W on which ft
km of pq"" WN
reason of ft av ftm. taro
Ympa?nft OW ? tamer deteyrd. YOU by
Crftg BdiliON And .,..M
c" bdw.m . on PEYFIFN d them is a
whkh *OWN a WMV&. we wg apply ,
Wm* owed. v You ask. we wl r#UW any o" bdance
9= romdns do not ask if a o0 babnof
wo
Aooouw for 6 npnft ws
&ftio
W* My send You the cwt 6
charpa b YMAUM* and aproe to
I" Le * my W
ago IN is b ynu in
error.
kx?ude an your Am m
by PUMne. a m*,n,
bad OW a Cob
trensiction Pwftft
fps. TMI IA
of Fkw os Provides for the
- ? PW*Aklii q?s o bw
Ch?ge deters p
log is
for Pimho es
and Cash ad+ranoes, bat ft mo The Fkw"
ft USM 16
?y as •strorego Ih W"n d*
-*&44 average ?? ? t4
?•
Is MWOft by .Each arm baMncstor a M*" Cholp in the in ft Fhano+
apples for the computation of the &hodWe
AvorMp Obya rnanr pectic rate. lance for
determkW each of raverdaa??nce. Hem is how we
?Y m the bl?ng cYcW, we take ?hat? s b. For each
01 Pwdmm or Cuh On Your w "Um Acmu add
ne
he
bdm am ad"ana$$ or deW to tany
h arMY Mntm or seas
or Purchases and the dai?r balance for to the
cash
4 .
5 p? Of Me FMno,? C
$ 1 WWp' by $4.17 W RIOMP
„` ' Now of
Chl* Apiiw Md peefod.
on F ...j tend Cash
b16V cycle in whidt .Mw bnm*n of t*
Acoount is W W POW 10 your
?M k or.. d our oft to deb the
them Is . o
Cyde f Mfto Rwdmw" PWM for a
tot x b )swof 9
dm" PWAOW mdhi a Oxmnonyeur
is zero of f 111 Paid and "cftd in ful by rie end of
? g cyft
80cum of the rnenrW in w" p"mgft we
Y" A
balenoe(=) o" fie Cash FhmOWW 4W 1* on Purdue, Paid in OW b avoid
Fft You we be d A T
fee
FkW s " to
a*" to so P-W us aaran"cft
Sdherf h for ? an pdgn9
aarm-
fee and d r ,when
"Posed,
wit t1i bow
o<
th9ft tees anld aNae ,and a-r 14nftw or mm*m
Pridj ?i Sdiedule ?e in fa
nexanir fee or a -WA!
inforrrralbn, U fee or dw" or ? of s? charm Accal apply to your
an' II? 18 QVmd f?ipFee.Anon.n(?p.?
bY You WhOw Um 9 ow Iml y or 1^ Aoooutt is
•806 810or?Fee.A
for eachorlgir?l acopm * ard I* bVood evi yo
dwirlit u re4uest. The f" is not owed i=11,*rF....
surd! a Oftis Raw" reveals a biking error as • Late Payment Aft imV
Date Payment which is not Qa ft P? D ue
on our mor"ly * aync?rM e
• Reamed P by
wl not honor yo r ched Orr Plymf" WnpOsqd ent f k your hank
cannot prom IL or we
m wre your Account balance ex
CeAds ? cwt I mil on
YOWAOmift
ftft M. Cohn d Me Oft or
in snnownt a do not sppy ? Iorg nt t1e ?a?? br
Aooount k b one of the ? ? ?
8wtedu(e. Tttpd AM
albriiebt lh aPabelltxil actor, the ft by,
t & We AL , CA
. AMIE IA( IN
arc ' , ? we
Sown c?arol(nah
ard WY
Y a "f**
saww"Ma
h
t
c?o
pidwa nneclat w aPbon L f You cho ?s o
? o? to to
xvQ d = whh thb W"b t?? k wld
Dual!. Yba Aooount wNi be in ddit and we can
mq*s to be toW a g bebw be paid M is
in oftat of =Mwaron t n) y'm+??aed the
cradt M*
Miami owed- under M Mtn
dw or
y to pay
¬
tois? not
knW 106 Or am
s
tied W a a etiyou) "or
ft'" In order b tolm ft soft
Oak Aftemm"
Aaeeda1enb lb Th Av*i wwwwwomew
of Ilse of "hie my ? and we
c
VA " md 19 m set the eMhodrs ddVe S" M We
any rid Mn&W. is
mq *hWd y . j e immded w" d
can apply Will otddmdbg unpaid I r?
mw
.woWd i .
I C*dww
Cha WI or tmpm a tee or ch not s
o
AI will be ettectiye only in this
t an mmft" N: (1) suer TOM daYou
te
so
wl MW IN MUDD of the chanp (or vj* IOW delis
lndkW in the di fwt on us nadae raftg the d ire at the aWrifis . ? u. .
lf?
YOU wrote -to ua
f.
t
in bWp cur ? tin ao into U.,
n?fond. tric. Visa am or Alm":Nd eft No f* InNrown
MUM ab or
bebe fm trat a MOded ft day
Per4ft The PO"hg doe ino WN by ons .
p? dateOm" amefte WS VWMon
?+ date aperior?c ant ttN
do not set ft y Sian We nor daft
anypoAfon d' 7. .1.
of i.
AgrewnerK bscem w% iu p° go o& . Thin
approved Account. in advion to ? ° we
00 b YOU itk COfl?erk b bMA44
In W" Aomft
g
d your Un tl»
any aof of our *b WxW la -j r
The knOdty °f V pmvidon of If s
"WL
tr Va
you
Y:r W
tM d we Of Pelt aft
You MINN?bleIN1* rmaWah" ualyuCar *u
wtr .I" br WM*A iced un tp,t coax,
MM-AZ
7 or by caft us ld b" at .?wv.
loft met a W iwi Us$ d
Cad In ?6 , You ? for urn we rdp not
?? anyone who Is leatd a COW for,
YO
Cad) Is 't MWM W AW uthoror am * to WW you Wv or yw
Amo&g to #W
same as you aw qt ? Your
be kftd
by you. Such auftrltq' w0 continua Una You W'd o it by
nol: d In your phyaiiad per.
a
nd y is a CZ='lo an authorized u, by also
ciao h
another person, use wfl not be
rq or m "M In m is °w I?rrhf?a' ' Ofl*
We c
?NL cmwyow Y
Cid m oft
kw wwe iw
o On: you &e j ?',l ?? you of a
orolme cuk ay to W."
fm*w IN your u.0 tbt C hm besh
btM crutceNed: In ft? molt ? ?Chedc$ hst
wmpff enta for Puu?ortW-mymwd
AiWas We MSPtinWe brMY Ndv ml orm86 on WAcm" am
ARW It is dosed you
a?noaf Your at any font
AN Cafe bsufd on your 9 ui and.
remain ti?ble br Aoootmt h Wd. You wig
ajob+taooot CI (fir
00 or had jawed a Card on
aio ?
g d Cards in hall 7m4 P4 to
r* an?r cattoetieltoa of on us of
fit can m*"
You wkm to tar d Yaw A"IK C&* bVied On we i
waiMS ; ? 1'our?o ,?.? epvy
have ent Y
we nay
yft
agree tltet a ax am er fW kdo"We"n. You
my bO
( bwicdy
end used m+aurntt repot rogodafed one anlr update, renewal or wk SMSnow
AcwA N y" "NA You wl be of on Your
ad s im °gt+te?ed M4 I% d fm MM amid maTe - - - - i"dd w" uw wt d to
? ? as ? contained (nyo?ur t
a and others f-& p se ton you wit,?! d our
we
e for their Produc4 or sewft
your
-NWM And Chan" Of Y
Cart bend
s and anYtttl?er noku ID YOU at U
send *Wmft our flea. It 0 * a A , ?e4s
we can
inform us nodM WMPUY of-any to either of you. You
Promise to
write b us at to in Your address. You
ddnss cbelow To •Y
Wove cus? I
$W
may bs oea?nd sataJrrhr, yow a c
Fam-W Currency T+'anaactions. Transactions on your
?..,I ca?dend unlwnoti?ed.
err^ a M dt adt ?f?
Aoo w to the addross or hank about yotr
monUtty stalunent, a y- r of Wig.
error:r kw /-_ a ??
pnor' b! ire If' or deft ft
provide us w tu? iTM- F=-on, stun
?xtq or admtrwee ass?1 w a our ? ?, you
'?„? Maur resaorabie a 1fNtime
M we toss db ? tD to as requested
an M may be Il W tar any loss we
MOTN FOR PUTUM tai
irdor wft about
-Act. under tl?e Fair Credit BMkv
Ys IN CM Of ?s Or 4uesfens AbM
YQ? ?? wrap, a dyrw need mon
e sheet at the &*WN?btf?id Con wry morahy
s?ynoetrk Wft 1o us as loon as pbeet& t rnwt hear
tWd bi (n eatp halve sentyou the
_ al us but doinq'o rr?h not You can
in your leper. g w us the ?CaNv E inform .
• hour Warne and l?oooure rs,mber.
• The dear amount of ax
Oe the error and ??? Yom. y?u
re is an error, d y need more in?
dewft the Item you are not sure •
h Y u haw suft*w us to pay y aedi<
can s" ft onw or fit. You
stop she payment Y? r
days betwe the paymej a dufed to ow.
Recehro Yom And Ow RUM Igoe: After We
letter wft 30 n fi e' We moat
wdM we havO CO or?by
then. Within w y$, we must either correct the rr
e Al<,er ? e ??? ?? a or or
Y , we cannot try to Collect any
--_ .. _... -- . --.-.__ ..---- ------_ - YOU . a meet VIII 7Q .idi?....?a Ut- - _ -
you for IN amount you question, i dint g
Finance OwgM and we cm apply m unpaid arttotant
aOMt your ON* wit. YOU do not have to pay any
, "' I bit You ?ablpbed to pet to Pam of your xe not in
0 we W we made a mieWw an yaw ta, you wM not
have b pay any Firw= Chow mMted b any queeliorMu.
artrout;. we ?dn't madoe • Midsb? you awry haw b pay
,and wi have b mailee up any tr?e,ad
MY oa snrourd. to Ww c@Ww vA
sand you a slatamW of the waft you owe and the date
that 4 is due.
0 you fait to pay the amount to we drink you ova} we
may report you aa. ddMuent. However, a our exptuwdon
doe: not sa a you and you write b us wti ten dap
nspo li r? in that you std rotate b IMN we mud Id nVm we
you iotyou tyre a arbout yarb pro
must UA you the nano of anyone we n?portad you to. We
must tali anyone we report to that the matter has been
settled bebreen ua when la.
d we dod 101owtheeea ttt, wcant cow to we &W
of "Vis qu ? hm
a -=71 it iv d 1y or Image to you
ptwdtased with ac?redt card, andyoq gave triad in goodh
to correct thppeaayyprobierrt with the mudraK you may nave the
serAM notto
are tvra an lhia ( moat
leave made the purduas in hors stdo, all not wghin
your home stile, wahin 100 miles of your ewrrent maft
ow and (b) The pidwe pft must have been more
These !'andations do not apply W we own or operata the
men awl, or y we mailed you the adverttwnent for the
property or seMm.
THE CHASE MANHATTAN BANK (USA)
UFW (U 5-95
Sttllet$t1?tR 368 M99wM Mrrlbaf:tR'?
$1.i VISA ova= $moo 31t230.94
M-- law rr7riew0Chuewdowdem
ARM" Elxlstad t"w4m pAraau7! AintaRbo*.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FILED-OFFICE
OF THE PROTHONOTARY
2011 JAN 24 PM 2: 41
u PENNSYLVCOUNTY
Portfolio Recovery Associates, LLC
vs.
Pradeep Dass
Case Number
2011-329
SHERIFF'S RETURN OF SERVICE
01/20/2011 03:31 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January
20, 2011 at 1531 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Pradeep Dass, by making known unto himself personally, at 613B Geneva Drive,
Apartment 25, Mechanicsburg, Cumberland County, Pennsylvania 17055 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 21, 2011
n
RYAN BURGETT, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
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.
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
Defendant
Date: LIAR 8 2011
No. 2011-329
-ca 3?
PRAECIPE FOR DEFAULT rn a? F
JUDGMENT Z ? n
D cx? --4c:)
v -n
C-)
Filed on Behalf of Pla' tiff
Counsel of record fo t s Party
L Robert N. Polas, Jr., Esquire, #2012
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 communication is from a debt collector is an attempt to collect a debt.
Any information obtairied will be used for that purpose.
06wS1q'6brd't(
v >80'
dsb
D ce ?CA
N ed
IIL
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. 2011-329
V.
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, PRADEEP DASS , for failure to answer
the Complaint.
(X) Amount Due $1,646.64
Less Credits $.00
TOTAL $1,646.64
(X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the
cgmplaint 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, 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 entered and to his/her Attorney of
record, if any, after the default occurred and at least ten days p ' t the date 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
This communication is from a debt collector is an attempt to collect a debt.
Anv inforrnation obtained will be used for that purpose.
I%
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
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
09-97610
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. PRADEEP DASS
2011-329
Dear PRADEEP DASS:
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
it1tT11llltt;'alioSl is (rov Ci j= y i dobi
Any inf'Onmoion,
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. 2011-329
V.
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
Defendant
TO: PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
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
iILET)h:al(c: t1. 31 t'? l ? _ 'i?1? t ..; it r?CE,li.
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. 2011-329
V.
PRADEEP DASS
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
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
613B GENEVA DR APT 25
MECHANICSBURG PA 17055
-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, #20125
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
09-97610
This coninlunication is a debt collector and is an attenipt to collect a debt.
Any infonnation 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 15:29:35
Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
DASS PRADEEP Based on the information you have furnished, the DMDC does not possess any information indicating the individual
status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the
above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, 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) (fonmerly
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/fM//piis/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 I13:613 1 IPBOR82