HomeMy WebLinkAbout11-7479Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie A. Brown, Esquire PA Bar # 94055
r
Portfolio Recovery Associates, LLC u r, c
_ . Lr
s 7,1E?? T??w i
140 Corporate Blvd. I{
.
Norfolk, VA 23502 a 4 d'`
L t,
TELE: 1-866-428-8102
FAX: 757-518-0860 G1);?
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
V.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
Defendant
NOTICE
No.
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.
aw 14 ga.66
CL* Clcto-'
12? (k a6 sa3
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.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
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 coninumi.caiion is frotn a debt collector and is aii atte€npt to collect a debt.
Any information obtained x0ll be u ,ed foi- 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.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
Defendant
COMPLAINT
Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with
offices located at 140 Corporate Blvd., Norfolk, VA 23502.
Defendant PAUL J OLSON, is an adult individual with last known address of 260 CHESTNUT
DR, SHIPPENSBURG PA 17257.
It is averred that Defendant was indebted to HSBC CARD SERVICES (III), INC. / ORCHARD
BANK-NON PRIME on November 3, 2005 with account number ************8929 (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.
This communication is born a &bt collector and is an attetnl?t to collect a debt.
Anv information obtained will be used for that purpose,
5. At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and/or for obtaining services.
6. Defendant was provided with copies of the Statements of Account showing all debits and credits
for transactions on the aforementioned Account to which there was no bonafide objection by
Defendant.
7. Defendant was in default with respect to that debt for failure to make the required payments on the
Account. The last payment made on this Account was on December 16, 2008.
8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC CARD SERVICES (III),
INC. / ORCHARD BANK-NON PRIME 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
$932.83.
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, PAUL J OLSON, in the amount of $932.83, plus costs of this action and
any other relief as the Court deems just and reast
11-00193
Hiis communication is 1=rom a ci °bt collector and is are attempt to collect a deft.
Any int.onnation obtained will the used for that purpose.
Robert N. Polas Jr., Esquire # 201259
Carrie A. Brown, Esquire # 94055
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Cd$Una Patterson 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 : SEP 0 9 Mi By
s na Patters-On
Custodian of Records
11-00193
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
PORTFOLIO RECOVERY ASSOCIATES, LLC
140 Corporate Boulevard
Norfolk, Virginia 23502
Telephone: 1-866-428-8102
Fax: 1-757-518-0860
Statement of Account
Account: ************8929
PAUL J OLSON
Account Holder:
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
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
HSBC CARD SERVICES (III), INC. / ORCHARD BANK-NON PRIME
Portfolio Recovery Associates, LLC
************8929
November 3, 2005
December 16, 2008
March 31, 2009
$932.83
September 22, 2009
Balance at Charge-Off: $932.83
Less Payments: $.00
Balance Due: $932.83
11-00193
HSBF79
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, Cristina Patterson
depose, affirm and state as follows:
Custodian of Records, for Portfolio Recovery Associates, LLC hereby
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 HSBC CARD
SERVICES (III), INC. / ORCHARD BANK-NON PRIME ("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 September 22, 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 PAUL J OLSON ("Debtor") to the
Account Seller the sum of $932.83 with the respect to account number (************8929), as of March 31, 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, Account Assignee claims the sum of $932.83 as due and owing as of the date of
this affidavit.
P rt lio Re very ssoci , LLC
By:
Criatim Patterson ,Custodian of Records
Subscribed and sworn to before me on of _??p ? ?'? _ , 2011
Notary blic
11-00193
This communication is from a debt collector aitd is an attempt to collect a dcbt,
.Atty infoanation oblained will be used for that purpose.
If you fail to y the amount we think you owe, wereport you
as delinquent. However, if our explanation does not you, and
you write to us within ten days tell&Ka us you still re fuse pay we
must tell anyone we report you to that you have a question about
your bill. And we must fell you the name of anyond we reported you
to. Upon settlement of the dispute we must tell everyone we report
you to that the matter has been settled.
If we don't follow these rules, we can't collect the first $50 of the
questioned amount, even if your bill was correct.
SPECIAL RULES FOR CREDIT CARD PURCHASES
If you have a problem with the quality of property or services you
purchased with a credit card, and you have tried in good faith to
correct the problem with the merchant, you may have the right not
to pay the remaining amount due on the property or services.
There are two limitations on this right:
(a) You must have made the purchase in your home. state or if
not, within 100 miles of your current mailing address.
(b) The purchase prig must have been more than $50.
These limitations do not apply if we own or operate the
merchant, or If we mailed you the advertisement for the
property or services. HSBC Card Services Inc. and/or HSBC
Card Services (11) Inc. provide processing services for HSBC
Bank Nevada, N.A.
You may write to us at the address shown on our billing
statement or HSBC Bank Nevada, N.A., 1111 Tcwn Center
Drive, Las Vegas, Nevada 89144.
1?? /11( A--_
Thomas M. I(imble
Executive Vice President
HSBC Bank Nevada, N.A.
February 1, 2006
Visa is a registered mark of Visa International and Visa U.S.A.
MasterCard is a registered mark of MasterCard
International, Incorporated.
02006 HSBC Bank Nevada, N.A.
<F
CARDMEMBER
AGREEMENT AND DISCLOSU
STATEMENT
AG2505A (12!06) CI r
This document and accompanying Additional Disclosure Statement
make. up your Cardmember Agreement and throughout this
document are referred to as Cardmember Agreement or Agreement.
The Additional Disclosure Statement contains important Account
information including your Annual Percentage Rates ("APR"s). and
amount of any fees. Please take the time to familiarize yourself with
your Agreement and retain it for future reference.
Thank you for being an HSBC Cardmember. We appreciate
your business.
TABLE OF CONTENTS
Agreement to Terms and Definitions 1
Using.Your Account 1
Your Credit 1
Payment 2
Interest Rates and Finance Charges 4
Account Fees 7
Foreign Transactions 8
Account Renewal, Closure And Termination 9
Credit Card Fraud 10
Personal Information 10
Additional Terms 11
Your Billing Rights 14
AG2505A (12/06) CI
AGREEMENT TO TERMS AND DEFINITIONS
This Cardmember Amaemnt-and any amendments (Agreement)
govern the open end Ina of credit we have established# you (your
Account). "You" and -your' refer to all persons who applied for the
Account or are contractually liable through any other means. "We;
us," and "our" refer to HSBC Bank Nevada, NA. "Card" means anyy
credit cards or other access devices Issued under this Agreement.
Network" means Visa International, MasterCard International
Incorporated Discover Financial Services LLC or other governing
credit card network, as applicable.
You and we are bound by this Agreement from the earlier of the
time you receive It or from the date of the first transaction,
including, without limitation, the placement or posting of any
Annual Fee or Periodic Membership Fee on your Account. You
may close your Account before using, It without paying any
Annual Fee, or Periodic Membership ee If applicable to your
Account when you call us within 90 days of your Account open
date. at t)te customer service number on the. back of your card.
USING YOUR ACCOUNT
Account Use.Restrictions
You agree to use your account only for personal, family, household,
or charitable purposes. You agree not to use our Account to make
payments to us or to an of our affiliates. You agree to use your
Account only for valid and lawful purposes and. that If your Account
is used for any other purposes you are responsible for such use and
may t reqand uired to reimburse us and the Network for all resulting
amounts
Types of Account Transactions
You can access your Account using your Card or by other means
approved by us to make purchases or receive cash advances.
We may limit the dollar amount and/or frequency of any type of
transaction without notice to you.
YOUR CREDIT
Credit Umit
We will advise you of the total credit limit on your Account. All or
a portion of your total credit limit is available for cash advances.
Your total credit limit and cash advance limit may change from
time to time. We will notify you of any such changes-through your
billing statement or by sending u a separate notice. If no
separate cash advance limit is lisyoted on your billing statement,
then the amount of your credit limit available for cash advances
is your total credit Omit.
You agree not to allow your unpaid balance (including Finance
Charges and other charges) to exceed your total credit limit. We
may not extend credit if you have exceeded your total credit limit
or if the amount requested would cause you to exceed your total
credit limit. If you exceed your total credit limit, you agree to pay
us that excess amount immediate)y. Your available credit and
cash advance amount may not reflect your payments for up to
14 days.
If you have a credit card with a no preset sending limit (e.g.
MasterCard° WoridCard), please see • the Additional
Disclosure Statement.
Credit Authorizations
Some transactions will require our prior authorization and you
may be asked by the merchant to provide identification. If any
part of the authorization system is not working, we may not be
able to authorize a transaction, even if you Have sufficient
available credit. We will not be liable to you if any pt these
events happen. We. may refuse to authorize any tran ons
at our sole discretion including, without limitation, we
reasonably suspect that such authorization may result in
fraudulent or suspicious activity on the Account. We are not
responsible for refusal or failure to authorize any transaction
or refusal by any merchant to accept or honor.your Card.
PAYMENT
Promise to Pay
You promise to pay according to the terms of this Agreement
for all: (a credit we extend on your Account; b) Finance
Charges, ate charges, overlimit charges and a ministrative
charges (e.g. for research, returned checks, overdraft
tection, If applicable, etc.). provided in this Agreement; and
c) cotlecbon costs and attorneys' fees to the extent permitted
y applicable e law.
If your Account is a joint Account, each joint Accountholder is
Jointly and individually responsible for all amounts due under
this Agreement regardless of death, divorce, other leggal
proceedings or any agreement that may affect liabifity
between you. If any joint Accountholder requests to not be
liable for future transactions, we may close your Account. If we
do, you must continue to pay according to the terms of this
Agreement, but you will not be able to make new charges on
your Account
Payment
Each statement you receive from us will identify a Minimum
Payment and Current Payment Due.
Minimum Payment
The Minimum Payment is calculated as follows:
(1) if your New Balance is not more than $15, your
Minimum Payment is the New Balance.
(2) If your New Balance is more than $15, your Minimum
Payment Is the greater of.
(a) 1 % of the New Balance shown on your statement
plus the following:
• any periodic Finance Charges
• any Monthly Maintenance Fee Finance Charge, or
an amount equal to 1/12 of the Annual Fee, if
applicable, and
• any additional amounts disclosed in the Additional
Disclosure Statement, or
(b) $15
2
Current Payment Due
The Current Payment Due is the greater of,
(1) your Minimum Payment plus any amount past due, or
(2) the greater of
(a) 1% of the New Balance shown on your statement
plus the following:
• any periodic Finance Charges
• any Monthly Maintenance Fee Finance Charge, or
an amount equal to 1/12 of the Annual Fee, if
applicable, and
• any amount over your credit limit, or
(b) $15 plus any amount over your credit limit.-
Your Minimum Payment and Current Payment Due will be
rounded up to the nearest dollar, unless doing so will cause the
resulting Value to exceed the New Balance.
Timing and Form of Payments
You must pay at least the Current Payment Due in- time to be
credited to your Account by the Payment Due Date, and failure
to do so constitutes a default of this Agreement. Instructions
for making payments are on your billing statement. For a
payment to be credited to your Account as of a particular day,
we must receive your payment by the date and time and In the
manner specified in those. instructions. If your Account,is
upon aeirvery or your Duung statement. IT our Account is
delingqrent, you can avoid an additional late fee by paying at
leastthe Minimum Payment plus any past due amount by the
Payment Due Date; however, if you cannot pay this amount,
you must pay at least the Minimum Payment by the Payment
Due Date to avoid progressing to the next stage of
delinquency. You may pay more than the Current Payment
Due and may pay the entire New Balance at any time.
All payments must be in U.S. dollars. Except for disputed
payments, if you pay by mail the payment must be sent to the
address specified on your billing statement If yyoOuU pay by
negotiable instrument, such as a money order or t?heck it must
be in a form that Is acceptable to us and must be. drawn on a U.S.
financial institution. Any check, money order or -other
Instrument tendered as an accord in satisfaction, or which
includes a condition, restrictive endorsement or any
statement to the effect that acceptance of such instrument
shall constitute full or partial satisfaction of a disputed or
undisputed debt (collectively, a "Condition") must be sent to
the address for written inquiries shown on your billing
statement. You must note conspicuously on the face of the
payment instrument that it is tendered for this purpose. We
reserve the right to refuse to accept any payment that is subject
to a Condition. If the payment does not comply with the foregoing
and we process it, we will not be bound .by_ the Condition. By
sending us a check for payment on your Account, you
authorize us to Initiate an slectronicfunds transfer from your
bank or other financial Institution account according to,the
terns of the check. This. means that your check will be
converted to an electronic transaction and your anal check will
not be returned to you by your bank. Your origina check will be
3
destroyed. Your checking or other financial institution account
may be debited the same day we receive your check. If you do
not want your checks to be converted to an electronic funds
transfer, please call customer service. at the phone number on
the back of your card.
Application of-Payments
At our discretion, payments are generally applied to interest,
fees and then principal balances. We apply your payments to
lower APR balances before higher APR balances. The
application of payments is subject to change at any time,
without notice.
INTEREST RATES AND FINANCE CHARGES
Interest Rates
The APRs on your Account are either a fixed or variable rate.
Variable rates are determined by adds a spedfied amount
( Spread") to an Index (described below . The APR Is divided
6y 365 and rounded to the next highes hundred thousandth
of a percentage point to determine your Dally Periodic Rate.
The Daily Periodic Rate Is used to determine the amount of
Periodic Finance Charge (see Finance Charges).
Index For Variable Rate Accounts
Please see the Additional Disclosure Statement for the
Index paragraph below that is applicable to your Account.
(1) For each billing cycle, the Index is
rm in the month prior'tolhe month in which the
billing cycle ends. In that prior month, the highest
domestic "Prime Rate" published in the Money Rates table
of The Wall Street Journal is selected (the "Index'). If the
Index has changed, the new variable rates will take effect
with the billing cycle that ends on or after the first day of
the month following the Index change.
(2) Qyadwly index The Index for the current and each
su quarter is the highest domestic "Prime Rate"
In the Money the rbusiness day otable of The Wag f the preceding calendar
quarter. If the Index has chcar?ed, the new variable rates will billing Jury October following the Ind xt?rg in January, April,
(3) Q Please see your Additional
rs osure Statement.
An increase in the Index will increase your applicable Daily
Periodic Rates which may increase the Finance Charge due
on your Account. Each time any APR changes we will apply it
to any existing balances, excluding any Promotional or
Introductory APR that may apply.
Purchase APR
For credit card purchases, the Spread for variable rates), APR
and corresponding Daily Periodic Rate are disclosed in the
Additional Disclosure Statement.
4
Cash APR
For cash advances, the Spread (for variable rakes), APR and
corresponding Daily Periodic Rate are disclosed in the
Additional Diisclosure Statement.
Default APR
If your Account has a Default APR provision, the Default APR
and conditions that may cause a Default APR to.take effect
as well as the Spread (for variable rates), APR rand
corresponding Daily Periodic Rate are disclosed in
Additional Discosure Statement. °
Promotional or Introductory APR
At our discretion, we may offer you a Promotional or
Introductory APR for any type of transaction. The Promotional
or.lntroductory APR, corresponding Daily Periodic Rate,
period of time for which the Promotwnal or Introductory APR
applies, and conditions by which the promotional period may
be shortened are disclosed in the offer. Certain promotional
offers may or may not be sub act to Cash Advance Fees. Any
Promotional or Introductory APR offer will be subject to the
terms of the offer and this Agreement.
Finance Charges
Finance Charges are the total of the greater of (a) Minimum
Finance Charge or (b) Periodic Finance Charges, and.an
applicable (c) Cash Advance Fee Finance Charges, (
Foreign Transaction Fee Finance Charge (e) Credit Limi
Increase Fee Finance Charges ( Monthly Maintenance Fee
Finance Charges, (g) Overdraft Fee Finance Charges, and
(h) any other Finance Charge(s).
Please see the Additional Disclosure Statement for
applicability and amount of the following Finance Charges.
(a) Minimum Finance Charge. A Finance Charge that is
assessed in lieu of a lesser periodic Finance Charge in any billing
cycle in which a periodic Finance Charge is payable.
dic Finance Charges. Periodic Finance Charges are
Of tmusitiprytng the Average bill y an t (( each
of balance sacra shown ?? -the ancesy the applicable
it, Rate and then multiplying the Dally the )r 1bvthe number
i the bllnq We. To wl y1% Balances, we
egadd ?dnebeWlt bafransachona, any ca ry
s s periodic
tharges, arty assessed fees charges and subtract
errts andlor credits. If a debit transaction posts after the
iM of i but , the the I an Is occurred Belaru? r thll
?d include the transaction amount and any previous
iodic Finance Charges for each day the transaction
vas outstanding prior to the beginning of the current
As. Then, for each transaction we add th
e
vim biliina cede ether ane the total by
or of days In the 6 ft cycle. This is the Average Dairy
(1) accrue Periodic Finance Charges begin to
on e date o transaction and continue to accrue
5
until payment in full is credited to your Account However,
there is a Grace Period on new credit card purchases. That
means, If the New Balance shown onyour last statement is
paid in full by 'the Payment Due Date for that statement,
periodic Finance Charges will not be imposed on new.credit
card purchases, provided the New Balance for the current
billing cycle is paid in full by the -Payment Due Date for that
billing cycle. If however, the New Balance is not paid in full by
the Payment true Date for the immediately preceding billing
cycle, periodic Finance, Charges will be incurred on new credit
card purchases (i e., purchases appearing for the first time in
the cument cycle) from the date of the transaction and on the
previously billed but unpaid credit card purchases. from the
first day of the current cede.
(2) Casp es (including balance transfer and credit
car c ec ks . eriodic Finance Charges begin to accrue
on the date of the transaction and continue to accrue
until payment in full is credited. to the Account: There is
no Grace Period on cash advances.
Periodic Finance Charges will be calculated using the Daily
Periodic Rate in effect on the statement closing date.
You may request a change to your billing cycle date no more
than once a year. You agree that changes based on your
request may. shorten any Grace Period- you may have or
in the time period for which periodic Finance Charges
may accrue.
Any fee Finance Charge may cause the APR on the, billing
statement on which the fee Finance Charge first appears to
exceed the nominal APR..
c) Cash Advance Fee Finance Charges. Cash advances
include all advances to get cash over the counter, through an
ATM, balance transfers (if available), credit card checks: (if
available), or other "cash-like" transactions (such •as
purchasing a. money order traveler's check, casino or betting
chip, or a lottery ticket) as determined by us. A Finance Charge
wilt be computed on the amount of each cash advance.as of the
date of the transaction.
(d) Foreign Transaction Fee Finance Charge. A Foreign
Transaction Fee Finance Charge is assessed on transactions
made in a foreign currency. Your billing statement will list the
transactions separately from the Foreign Transaction Fee
Finance Charge.
(e) Credit Umlt Increase Fee Finance Charges. If you request
and are approved for a credit limit increase ("CLI*), a CLI Fee
Finance Change may be assessed to your Account.
LQ Monthly Maintenance Fee Finance Charges. A Finance
Charge that is assessed to the Account for each billing cycle
whenever that Account is dosed with a debit balance.
Overdraft Fee Finance Charges. (Applicable only to
NBC Credit Card accounts providing overdraft protection to
designated HSBC Bank USA, N.A. deposit accounts). If you
requested overdraft privileges, we will lend you from your
6
available cash advance credit limit the amount needed to
cover any overdraft due to insufficient funds on the
designated deposit account We will transfer to the deposit
account the amount of the overdraft rounded to the next full
dollar. We will not make a transfer if you do not have sufficient
unused credit available or are delinquent hereunder. In that
case, the overdraft will be subject to the usual deposit account
rules and fees. Under no circumstances shall any such
overdraft be alknived to.exceed.yyour available.ccedit limit. You
understand that we have.the'right to cancel this. Account or
your overdraft loan privileges. at anytime..
We may add an Overdraft Fee Finance Charge.toyour•Account
if your. Account is utilized to. cover. anyy; overdraft. on your
desiggnated de . it account. An OverdraW° ee Finance Charge
will be comp ,Tdd on the amount of each overdraft transaction:
(h) See Additional Disclosure Statement for any additional
Finance Charges that may be applicable to your Account.
ACCOUNTFEES
Please see the Additional Disclosure Statement for applicability
and amount of the following,fees.
Annual Fee/Periooic Membership Foe
If your Account is subject to an Annual Fee or Periodic
Membership Fee, you agree to pay this fee eadt year (or other
E?eriodic assessment if indicated on the. Additlonal Disclosure
gtatement) our Account is an,
or rJosed with a balance.
You agree that this fee will be charged to your Account.
If you close your Account within the first 90 days your Account
is open, the Annual Fee/Periodlc Membership Fee(s). are
refundable so Ioonngg as u have not used the Aocount The
Annual Fee/Periodic Membership Fee compensates HSBC
Bank Nevada, N.A. In part, for cardmember services provided
or made available to you throughout the membership year.
Late Payment Fee
A Late Payment Fee is assessed for each billing cycle in which
at least the Minimum Payment, -and any amount past due, is
not paid in time to be credited to the Account by the Payment
Due Date.
Overlimit Fee
An Overtimit Fee is assessed If the Account balance exceeds
the mayafmpose his?feeiteven if we authorize or impose any cchargeess
that cause your balance to exceed the credit limit
Other Fees and Charges
Returned Payment Fee
A Returned Payment Fee is assessed to the Account each time
a payment check; automatic payment deduction, or other
payment method Is not honored or Is returned -unsatisfied by
the bank or other financial institution. Any payment returned
unsatisfied for any reason may be reported to any type of
7
transaction (i.e. cash advance, purchases, etc.) and Finance
Charges may be reinstated back td the payment date at the
APR being charged for that transaction.
Retumed Check Fee
A Returned Check Fee is assessed to the Account each time
a credit card check, balance transfer check (if available),
electronic check or other Account access device is returned
unsatisfied by us for any reason.
Check By. Phone Fee F r ::
A Check-By Phone Fee is assessed to the Account each
time a payment is made by telephone, even if the
payment"Is made by someone other than you.
Stop Payment Fee
A Stop Payment Fee is added to the cash advance balance
when a payment of a credit card check is stopped at your
est Payment may be stopped on a credit card check by
no ing us In writing or by calling us at the telephone
num listed on the Account billing statement, so long as
such deck has not already been processed. A stop payment
request must Include the check number, payee, amount, and
date of the credit card check on which payment is to be
stopppe?d. If a stop payment is uested by telephone the call
must be confirmed in writing within 14 days. A written stop
payment will remain in etfed for six months unless renewed
in writing. The address to send a stop payment request is
disclosed in the Additional Disclosure Statement
Research Fee
A Research Fee is assessed to the Account for each sales
slip copy, statement copy and application copy requested.
Replacement Fee
A Replacement Fee is assessed to the Account if we
replace a Card that is lost, stolen, or damaged, or If'we
issue a replacement Personal Identification Number (PIN)
to facilitate access to Automated Teller Machines. If a
replacement card is requested on a rush basis, we will
charge our current fee for this service.
Reinstatement Fee
A Reinstatement Fee is assessed whenever a request to
reopen a closed or blocked Account is approved.
Additional Fees
See the Additional Disclosure Statement for any other fees
that may be applicable to your Account.
FOREIGN TRANSACTIONS
If you make a transaction In a foreign currency, the transaction
wr71 be converted by the Network, into a U.S. dollar amount in
accordance with its oppeerraating regulotions or conversion
p?dures in effect at thw e the transaction is processed.
Details concerning these procedures are, shown In the
Additional Disclosure Statement. The Network may change
the procedures, from time to time, at Its own discretion.
8
ACCOUNT RENEWAL, CLOSURE
AND TERMINATION
Card Renewal
Cards are issued with an expiration date. We have the right
not to renew your Card for any reason.
Closing Your Account
You can dose. your Account by writing to us. Your Account
balance will continue to accrue Finance Charges and other
fees and will •rematn subject to all the terms and conditions
of this Agreement. You also agree, to destroy your Card(s)
and any unused credit card checks. We will not honor any
credit card check written on your Account or authorize any
transactions after your Aunt is dosed. The address to
send your request to dose your Account is disclosed in the
Additional Disclosure Statement.
Account Closure'
We may. close your Account, suspend your credit privileges,
or reduce your creditlimit at any time and for any reason,
subject to the requirements of applicable law. In any of these
events., your. Account balance will continue. to accrue
Finance Charrgge?s. and fees, until 'paid in full, and will remain
subject to al %a terms and conditions of this Agreement. If
we dose your.Account you agree to destroy your Card(s)
and any unused. credg•card checks: If your Account has
been closed, •:or your credit privileges are suspended, you
may not use your Card or credit card checks.
Default
You will be in default under this Agreement if: gate you fail to
make at least the Current Payment-Due in time credited
to your Account by the Payment Due Date; (b) you violate
Ion; f) we receive information from third pi
I R reporting agencies, which indicate a si
ncy or charge-ofF with other creditors: () you
us a Dhvsical address:' (h) you exceed vour
mmit; r your payment is returned unsaasnea Dy your Danis or
other nanciW institution for any reason; or 0) any credit card
check is returned un aid by us. Upon default, we have the
right to dose your Aurat, to terminate or suspend your
credit privileges under this Agreement, to change the terms
of your Account and this Agreement, to require You. to osv
)a us, your Account balance will continue to
Charges and fees until paid in full and will
to all the terms and conditions of this Agreei
you, or if we hire a third party to collect your
extent permittea oy iaw in.tne state in wnicn you resme,
cost wits land pthenoto priinciciipal andreunpattorneys id nai e Chaerges.
Security Interest
If you have not completed a Security Agreement for your
Account, we are extending you an unsecured line of credit.
If you have completed an :application and Security Agreement
for a secured account, the terms and conditions contained
within this paragraph apply to your Account As Secures for your
perfomaance under- this Agreement, including but not limited to
and grant to us a first priority security interest in all money now
and hereafter In the deposit account with the bank disclosed in
the "Additional Disclosure Statement". You authorize us to
restrict withdrawals from your Deposit Account until such time
as this Account Is dosed and all your indebtedness is fully
satisfied or until this Account is otherwise modified by us. If you
exceed-your credit limit, or otherwise default under the terms of
your Agreement, or if this Agreement is cancelled by you or us
for any reason, we may at any time thereafter and without
advance notice to you, apply all or part of your Deposit Account
to the.psyment and satisfaction of any and all amounts owed
under Ft its Account and any replacement secured credit card
account. In addition we may use any other remedies permitted
or otherwise available to us. If the amount in your Deposit
Account is not sufficient to retire all obligations incurred related
to your Account, you agree to pay the amount owed to us
CREDIT CARD FRAUD
Lost or Stolen Credit Card or Account Checks
You agree to notify us immediately if your credit card or
credit card checks are lost or stolen. You may notlIly us by
calling us at the. phone number disclosed in the Additional
Disclosure Statement.
Liability for Unauthorized Use
You should retain oopies of all charge slips until you receive your
statement, at which time you should verify that the charges are
true and the amounts unaltered. You may be liable Tor the
unauthorized use of your credit card. You wfil not be liable for
unauthorized use that curs after you notify us of the lim, theft
or possible unauthorized use. Notification must be given either
by writing us immediately upon learning of the bss, theft or
possible unauthorized use or calhng us at the telephone number
listed on your bigin statement. You will not be liable for any
unauthorized use of-your credit card Account when you notify us
immediately by phone or In writing. In anyy case, your liability for
unauthorized use of your credit lord Wll not exceed $0. -The
a to notify us of unauthorized use of your credit card Is
di?i in the Additional Disclosure Statement. You may also
call u . at the telephone number listed on your billing statement.
PERSONAL INFORMATION
Change of Name, Address, Telephone Number
or Employment
You agree to give us prompt notice of any change in your name,
mailing address, telephone number or place of employment.
Updated Financial and Other Information
Upon request, you agree to promptly give us accurate
financial and other information about yourself:
Credit Reporting
If you fail to fulfill the terms of your credit obligation, a negative
report reflecting on .:your credit record may be submitted to a
credit reporting agency. If any specific information .related to
your Account transactions or credit experience with us is
inaccurate, you -maYY notify us to, correct the inaccurate
information (after co rmation of the alleged error) reported to
any credit reperting agency by writing to us at P.O. Box 98706,
Las Vegas, NV 89993
Certain Privacy:Practices
You : agree that from time to time we may receive credit
information concerning you from others, such as stores, other
lenders, and credit reporting agencies, and that we may use this
information to amend, cancel or suspend your credit privileges
under this Agreement even If you are not in default with us. You
agree that the Department of-Motor Vehicles may release your
residence address to us, should it become necessary to locate
you. You agree that our supervisory personnel may listen and
record telephone calls.between you and our representatives in
order to evaluate the quality of our service to you and to other
cardmembers. For additional information regarding our privacy
practices, please refer to our Privacy Statement.
ADDITIONAL TERMS
Change of Terms (including Finance Charges)
Arbitration
Please see the Additional Disclosure Statement for
applicability to your Account.
This arbitration provision, shall apply to any Claim against us,
and to eacji of our parents, subsidiaries affiliates, any company
providing a rewards feature In conjunction with this Agreement,
predecessors, assigns, and each of their
9 10 11
officers, directors, agents, and employees. You agree any claim,
dispute, or controversy (whether based upon contrail; tort,
Intentioonal or otherwise; constitution; statute; coupon law* or
Wing
??qquu??yy and whether pre-existing, present or future), i ips
intiiaf claims, countervdaima, cross-claims and third clakns,
arising from or relating to this Agreement or the
which result from this Agreement, including the validity or
enforcaabiNty of this arbitration clause, any thereof or the
entire Agreement ("Claim"): shall be upon the election
aaminlsrrawr serecxea ai the urns me tAm is rues. i no parry
in"ng tits arbitration proceeding shall have the right to select
one of the fdiowi three arbitration administrators: the National
Arbitration Form )the American Arbitration Association
("AAA') or JAMS. arbitrator shall be a lawyer with
fiteerrt? yea or a retiredor amreoe re than
former We not to
i m*e our right to arbitrate an individual YOU may bring in
small claims court or an equivalent court, if any, so Iorrg • as the
Claim is only in that court The as and fomrs Of the
NAF; AAA and" JAMS may be obtained by writing to two for
os6vici of tions at .the nd addresses thpro ? below. BC Card Services
Ina, P.O. 98740, las Vegas, NV 89193-8740.
Any eartlapatory arbitration hearing dW you attend will take place
in tine city nearest to your residence. where a federal district court
is located q' at such other location as aaggreed by the parties. On
any Claim you file, you will pay the'11: o of the filing fee. At your
we will y the remainder of the filing fee and any
addmmi iletrative or hearing fees charged by the arbitration
administrator on any Claim submitted by you In arbitrati?onn r? to a
e a?rbitratiio' admi you nistrator, wee wig to considea a req? fyeoes
to all or part of the additional fees; howaver, we shall not be
to pa any additional) fees unless the arbitrator grants
will : baward. the ursa you for any additional feces pd oor Ih your owed by you two
the arbl6naUon administ itor up to the amount of the fees that
would have been charged if the original Claim had been for the
amount of see actual award In yar parties shall bear
the of their resPecwe allDMGYs fees except as
otherwise provided by law. k a statute gives you the to
recover any of these fees, or the fees Palo to the arb on
administrator, these stagy rights shall =tied the arbitration
notwitmianding anti g to the contrary cor tied herein. If the
arbitrator issues an award in our favor, you will not be required to
reimburse us for any fees we have previously paid to the
arbitration administrator or for which we are r;Donsl le.
This arbitration agreement is made pursuant to a transaction
involving interstate commerce, and shall be governed byy t?he
Federal Arbitration Act 9 U.S.C. Sections 1 - 16 (the "FAA
The arbitrator shall apply applicable substantive law consistent
with the FAA and providde written reasoned findings of fact and
conclusions of law. The arbitrator's award shall not be subject
to apppeal except as pe the FAA. The parties agree
thattha award shall be k ptdcby onfidential. Judgment upon the
award may be entered in any court having jurisdiction.
H
THE PARTIES ACKNOWLEDGE THAT TH.Y HAVE A
YOUR BILLING RIGHTS
RIGHT TO LITIGATE CLAIMS THROUGHF A COURT
BEFORE A JUDGE OR JURY BUT WILL NOT HAVE THAT
PARTIES .HEREBY PARTY
KNOWINGLLYANDB VO UNTARILY
What To DO If There's An Error In Your Bill
WAIVE THEIR RIGHTS TO LITIGATE SUCH CLAIMS IN A
COURT BEFORE A JUDGE OR JURY UPON ELECTION OF
ARBITRATION BY EITHER PARTY. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR
i
l
f
l
i
fil
h FUTURE USE
e a Q
e arbitration ru
es o
, or
a
m
You mayy contact, obta
n t
JAMS
f
ws: -
AAA
ll
ith NO
:z
or
as
o
o
w
,
National Arbitration Forum JAMS
3 ` y
This notice contains im rtant information about your rights and
our res
onsibilities under th
Fair Credit Billin
Act
P.O. Box 50191 45 Broadway
N
Y
k
1
5 p
.
g
e
ew
or
, NY
Minneapolis, MN 55405
000
www.aarform.com www.jamsadr.com NOTIFY.US IN CASE OF ERRORS OR QUESTIONS
Code of Procedure Financial Services ABOUT YOUR BILL
Arbitration Rules
and Procedures
American Arbitration Association
1150 Connecticut Ave. NW 6th floor
Washinslton, DC 20036-4114
www.a r.o
Arbitration ules for Consumer
Disputes (Claims under $10,000)
Commercial Arbitration Rules
(all other claims).
Assignment of Account
We may sell, assign or transfer your Agreement and Account
or any portion thereof without notice to you. You may not sell,
assign or transfer your Account.'
Waiver
We may choose to delay enforcing or waive anyy of our rights
under this Agreement in certain situations. We can delay
enforcing or waive any of our rights without affecting our other
rights. woe waive a right, we do not thereby waive the same
right In other situations.
Severability
If any provision of this Agreement is finally determined to be void
or unenforceable under any law, rule or regulation all other
provisions of this Agreement will remain valid and enforceable.
Applicable Law
This Agreement and your Account will .be governed by federal
law and the laws of the state of Nevada, whether or not you live
in Nevada and whether or not your Account is used outside
Nevada. This Agreement is entered into in Nevada and all credit
under this Agreement will be extended from Nevada.
If you think your bill is wrong or if you need more information
about a transaction on your bill write to us (on a separate sheet)
at the address listed on your billing statement. Write us as soon
as possible. We must hear from you no later than' 60 days after
we sent you the first bill on which the error or problem appeared.
You can telephone us, but doing so will not preserve your rights.
Please include the following information in your letter.
• Your name, account number and.signature,
-The dollar amount of the suspected error; and
• Describe the error and explain, if you can, why you believe
there is an error.
If you need more information, describe the item you are not
sure about. If you have authorized us to pay.:your Account bill
automatically from .your savings or checking account, yyo?u can
stop the payment on any amount you think is wrong. To stop
the payment, your letter must reach us three business days
before the automatic payment is scheduled to occur.
YOUR RIGHTS AND OUR RESPONSIBILITIES
AFTER WE RECEIVE YOUR WRITTEN NOTICE:
We must acknowledge yyour letter within 30 days, unless we
have corrected the error Dy then. Within 90 days, we must either
correct the error or explain why we believe the bill was correct.
After we receive your letter, we cannot try to collect any amount
you question, or report you as delinquent. We can continue to bill
you for the amount you question, including Finance Charges, and
we can apply any unpaid amount against your Credit Limit. You
do not have to pay any questioned amount while we are
investigating, but you are still obligated to pay the parts of your
bill thaf are not in question. .
If we find that we made a mistake on your bill, you will not have
to pay any Finance Charges related to any questioned amount.
If we didn't make a mistake, you may nave to pay Finance
Charges, and you will have to make up any missed payments on
the questioned amount. In either case, we will send you a
statement of the amount you owe and the date it !s due.
12 13 14
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.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
Defendant
Date: 1- 11
No. 11-7479
PRAECIPE FOR DEFAULT '
JUDGMENT
Filed on Behalf of Plaintiff
Counse ecord for this P
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) 757-518-0806
Attorneys for Plaintiff
This communication is from a debt collector is an attempt to collect a debt.
AnN information obtained will be used for that purpose.
pxntik a 14.topi a
?Ic it 12D I SS
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. 11-7479
V.
PAUL J OLSON :
260 CHESTNUT DR
SHIPPENSBURG PA 17257
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, PAUL J OLSON , for failure to answer
the Complaint.
(X) Amount Due $932.83
Less Credits $.00
TOTAL $932.83
(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.RC.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' to be entered and tpqs/her Attorney of
record, if any, after the default occurred and at least t da prior to the dat o e filing of this
praecipe and a copy of the notice is attached.
Date: ?
Robert N. Polas, Jr., Esquire # 201259
Carrie A. Brown, Esquire, #94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA 23502
(T) 1-866-428-8102
(F) 757-518-0806
Attomeys for Plaintiff
This 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
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)
November 10, 2011
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
11-00193
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. PAUL J OLSON
11-7479
Dear PAUL J OLSON:
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
Friqu
This communication is from a debt collector 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 Blvd.
Norfolk, VA 23502
Plaintiff No. 11-7479
V.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
Defendant
TO: PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
DATE OF NOTICE: November 10, 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?blas, Jr., Esquire
Carrie A. Brown, Esquire
Attorney ID # 201259/94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, Va 23502
Attorneys for Plaintiff
This communication is from a debt collector is Wi attempt to collect a debt.
Any urformation obtained will be used for that purpose.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CML ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATE, LLC
140 Corporate Blvd.
Norfolk, VA 23502
Plaintiff No. 11-7479
V.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
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
260 CHESTNUT DR
SHIPPENSBURG PA 17257
and is not in the military service of the United States or its Allies, or otherwise within the provisions of
the Service Members Civil Relief Act and its Amendments.
Date:
Robert N. Polas, Jr., Esquire, #201259
Carrie A. Brown, Esquire, #94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA 23502
(T) 1-866-428-8102
(F) 757-518-0860
Attorneys for Plaintiff
11-00193
1-his communication is a debt collector and is an attempt to-collect a debt.
Arty information obtained will be used for that purpose.
Department of Defense Manpower Data Center Nov-22-2011 14:30:21
Military Status Report 11-00193
Pursuant to the Service Members Civil Relief Act
Last First Middle Begin Date Active Duty Status Active Duty End Date Service
Name Agency
OLSON PAUL J 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 informati on 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).
ray. )4. ,r?.?-4,?...
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. §§ 601 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 httn:/Mww.defenselink.miVfaa/Dis1PC09SLDR.h-tml. 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 inforimation on "Active Duty Stativs"
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 (NOAH 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 10:01 CTLL2CEB
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. 11-7479
V.
PAUL J OLSON
260 CHESTNUT DR
SHIPPENSBURG PA 17257
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 $932.83, plus interest, on.
(X) A copy of all documents filed with the Prothonotary in support
By:
If you have any questions regarding this Notice, please
Date:
party. l1
- 1 "
attached,'
.s
Robert N. Polrf, Jr., Esquire # 201259
Carrie A. Brown, Esquire, #94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA 23502
(T) 1-866-428-8102
(F) 757-518-0806
Attorneys for Plaintiff
is communication is from a debt collector is an attempt to collect a debt.
Anv inforrnation obtained will be used for that purpose.
t
Irk