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HomeMy WebLinkAbout11-4290IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. P M LEONARD 120 LINN DR CARLISLE PA 17013 Date: Defendant QUL 01200 No. 11-4290-CIVIL ern c r- PRAECIPE FOR DEFAULT r` JUDGMENT D ut o ° a * zs © c') :x -6 z- x cn v Filed on Behalf of Plaintiff Counsel of c rd for this Party Z Robert N. Polas, Jr., Esquire, #201259 ?-- Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-888-772-7326 (F) 757-518-0860 Attorneys for Plaintiff is oblainec( +.?ill ' e as r°d ti',s° (Vo?,e, '(vl0?i )?ec? 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. 11-4290-CIVIL V. P M LEONARD 120 LINN DR CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, P M LEONARD , for failure to answer the Complaint. (X) Amount Due $11,644.64 Less Credits $.00 TOTAL $11,644.64 (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.231.1, 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 ttorney of record, if any, after the default occurred and at least ten da rior to the date of th ili g of this praecipe and a copy of the notice is attached. Robert N. Polas, Jr., Esquire #201259 Carrie A. Brown, Esquire #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-888-772-7326 (F) 757-518-0860 Attorneys for Plaintiff k froni ;1 debt are alLe°rrif-=1 to t ;k'bt. end ; t1t ?rZtta =rt ;?1??., ?fic?cl will' 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. 11-4290-CIVIL V. P M LEONARD 120 LINN DR 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 $11,644.64, plus interest, on. (X) A copy of all documents filed with the Prothonotary in suppo4theXthin j ent attached. By: If you have any questions regarding this Notice, please contact th . J V 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) 757-518-0806 Attorneys for Plaintiff I Ilk a;?tlt'1£Y11II17? 311 31 IS ?CfTC' :q d, TAI Any FE7ti?TI213t1 €' 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) June 6, 2011 P M LEONARD 120 LINN DR CARLISLE PA 17013 10-68226 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. P M LEONARD 11-4290-CIVIL Dear P M LEONARD: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, 44 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 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. 11-4290-CIVIL V. P M LEONARD 120 LINN DR CARLISLE PA 17013 Defendant TO: P M LEONARD 120 LINN DR CARLISLE PA 17013 DATE OF NOTICE: June 6, 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 :xd S 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 t 3 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. 11-4290-CIVIL V. P M LEONARD 120 LINN DR 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 120 LINN DR 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. Date: QUL 012011 10-68226 _Il Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff €c &wn k a debt collo' f .?t _ ?_? tc} collc(t a Iebt. Department of Defense Manpower Data Center Jun-17-2011 15:23:57 Military Status Report 10-68226 Pursuant to the Service Members Civil Relief Act Last FirstiMiddle Begin Date Active Duty Status Active Duty End Date Service Name Agency LEONARD P M Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the inforration 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' Cavil 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 httpJ/~ defenselink mil/faglpislPC09SLDR.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:JMLHN4U500