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HomeMy WebLinkAbout11-7481Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-81028 CC() ' FAX: 757-518-0860 n ?ig Attorneys for Plaintiff AND CouK 1 V ?N5Y! 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. ,1-? a ` Lvd v. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action 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?,? ?4a•°°`'a any 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. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 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 conintunication is 1-roin a debt =_11?, 1 r.,;0 is are attempt to collect a debt. Any information obtained will be used for that purpose:. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. CRYSTAL A JOSEPH 19WMAIN STFL2 SHIREMANSTOWN PA 17011 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant CRYSTAL A JOSEPH, is an adult individual with last known address of 19 W MAIN ST FL 2, SHIREMANSTOWN PA 17011. It is averred that Defendant was indebted to HSBC BANK NEVADA, N.A. / SEARS SOLUTIONS on March 17, 2008 with account number ************8434 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A.11 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 from a debt collector azrd is aii attempt to colleca a deN, Aiw infortnation obtained will be used for drat purpose. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 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 January 26, 2009. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA, N.A. / SEARS SOLUTIONS 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 $1,051.51. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, CRYSTAL A JOSEPH, in the amount of $1,051.51, plus costs of this action and any other relief as the Court deems ju Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 10-95508 :this communication is fron a debt collector ai)d is an attempt to c°o lect a debt. Any information obtained v, ill be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, CdsUna 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 2011 10-95508 B Cdstina Patterson Custodian of Records 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 : ************8434 CRYSTAL A JOSEPH Account Holder: CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 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 BANK NEVADA, N.A. / SEARS SOLUTIONS Portfolio Recovery Associates, LLC ************8434 March 17, 2008 January 26, 2009 September 30, 2009 $1,051.51 March 23, 2010 Balance at Charge-Off: Less Payments: Balance Due: 10-95508 HSBH67 $1,051.51 $.00 $1,051.51 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 Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from HSBC BANK NEVADA, N.A. / SEARS SOLUTIONS ("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 March 23, 2010. 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 CRYSTAL A JOSEPH ("Debtor") to the Account Seller the sum of $1,051.51 with the respect to account number (************8434), as of September 30, 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 $1,051.51 as due and owing as of the date of this affidavit. rt lio Rec ery Ass a LC By: Cdstina a erson , ustodian of Records Subscribed and sworn to before me on of )2011 Notary Public 10-95508 This eonttxttt1tication is fro n a debt collector and is att attempt to collect a debt, An, information obtaitted will be used for that ;turpose. 40 0 BILL OF SALE HSBC CARD SERVICES (IIn INC. (f/k/a HOUSEHOLD CARD SERVICES INC.) C' Seller'), for value received and pursuant to the terms and conditions of the Receivables Purchase Agreement ("Agreement') dated October 26, 2009 between Seller and HSBC CARD SERVICES (III) INC. and Portfolio Recovery Associates, LLC, C Purchaser), does hereby sell, assign and convey to Purchaser, its successor and assigns, all right, title and interest of Seller in and to those certain Purchased Receivables (as defined in the Agreement) listed on the attached Exhibit A (Sale File), without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Agreement. EXECUTED this 20 day of March, 2010. HSBC CARD SERVICES (M) INC. By: ---? Name• Susan Solomon Title: Vice President-Assistant Secretary HSBC BANK NEVADA N.A. By: Name: Susan Solomon Title: Senior Vice President AbV SHERIFF'S OFFICE OF CUMBERLAND. "COUNTY Ronny R Anderson Sheriff C tUtttat ?ttfrt6rr,l,?? i i % ? .,, ,+ , Jody S Smith I ?+ P ill Chief Deputy ? -? ' '`E•, r' 1 ? ? C. Richard W Stewart 'sSYI'v'?;:tld Solicitor OFF F OF -r s"=R'FF Portfolio Recovery Associates, LLC vs. Crystal A. Joseph Case Number 2011-7481 SHERIFF'S RETURN OF SERVICE 10/11/2011 08:24 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2011 at 2024 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Crystal A. Joseph, by making known unto herself personally, at 19 W. Main Street, 2nd Floor, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. MICHELLE GU SHALL, DEPUTY - SHERIFF COST: $58.00 October 13, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (oj i?ountySuile Shenft. Teleosoft Inc 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. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant Date: _ No. 11-7481 Civil C,-, PRAECIPE FOR DEFAULT ? U) j ;1-"Y+ JUDGMENT r i r..._ ?> -?- cs r ,e --A t- Filed on !half of Plaintiff CounseX o record for this Papty k I ?? J 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 410.50 PO Air! C* 1?4ais?sozyo 004m This cor_ ytiunic<ation. is from a debt collector is an attempt to collect a debt. Any information obtained will be Lised for that purpose. 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. 11-7481 Civil V. : CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, CRYSTAL A JOSEPH , for failure to answer the Complaint. (X) Amount Due $1,051.51 Less Credits $.00 TOTAL $1,051.51 Date: (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.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 ys prior to the date, the filing 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) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff `l'hIS Cornnitini.cation is from a debt collector is an attempt to collect a debt. Any infonnation obtained will he Used fior 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 CRYSTAL A JOSEPH 19WMAIN STFL2 SHIREMANSTOWN PA 17011 10-95508 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. CRYSTAL A JOSEPH 11-7481 Civil Dear CRYSTAL A JOSEPH: 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 is. I his coII1tnunicatiol) i?" from a debt . r Cl ghct a debr_ 1ny information €=blame(' , i l I 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. 11-7481 Civil V. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant TO: CRYSTAL A JOSEPH 19WMAIN STFL2 SHIREMANSTOWN PA 17011 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 Robe Tas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff 'n -ilia 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. 11-7481 Civil V. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 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 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 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 10-95508 This communication is a debt collector and is at) attempt to collect a cleft. Any, information obtained will be used for that purpose. Department of Defense Manpower Data Center Feb-08-2012 14:52:54 Military Status Report 10-96508 Pursuant to the Service Members Civil Relief Act A( Last FirstiMiddle Begin Date Active Duty Status Active Duty End Date Service Name Agency JOSEPH CRYSTAL A 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, NOAH, Public Health, and Coast Guard). 41130 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or anyfamily 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.millfaqlpis/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 itwas within the preceding 367 days. For historical information, please contactthe 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:AEAM6406U9 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. 11-7481 Civil V. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $1,051.51, plus interest, on. (X) A copy of all documents filed with the Prothonotary B If you have any questions regarding this Notice, please 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 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used loo that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 PLAINTIFF vs. NO. 11-7481 Civil CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION-MONEY JUDGMENTS k TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Direct to the Sheriff of CUMBERLAND County,PA; (2) against CRYSTAL A JOSEPH Defendant(s); (3) and against METRO BANK Garnishee(s); G (4) And index this writ =ry (A) against CRYSTAL A JOSEPH Defendant(s) (B) and against METRO BANK Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the garnishee(s). Specifically describe the property per attached property description. All accounts including but not limited to all savings,checking and other accounts,certificates it,notes ei bles,collateral, pledges,documents of title,securities,coupons and safe deposit boxes. ,1 ficates (5) Amount Due: $747.00 A—) Signature l)Number Interest From March 6,2012: $45.34 Robert N.Polas,Jr.,Esq.#201259 (At an interest rate of 6%per year) Print Name Total: $792.34 Plus costs&interest Carne A.Brown,Esq.#94055 (Total includes post judgment credits) 0 120 Corporate Blvd Address CLkLA Norfolk,VA 23502 ld. 00 it I� Cp ll 11 x 10-95508 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-7481 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC Plaintiff(s) From CRYSTAL A.JOSEPH, 19 W. MAIN ST. FL 2,SHIREMANSTOWN,PA 17011 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: METRO BANK,3201 TRINDLE ROAD,CAMP HILL,PA 17011, ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS,CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT,NOTES RECEIVABLES,COLLATERAL,PLEDGES, DOCUMENTS OF TITLE,SECURITIES,COUPONS AND SAFETY DEPOSIT BOXES. and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$747.00 Plaintiff Paid$ Interest FROM MARCH 6,2012-$45.34(AT AN INTEREST RATE OF 6% PER YEAR) Attorney's Comm. % Law Library$.50 Attorney Paid$195.50 Due Prothonotary$2.25 Other Costs$ Date: 11/6/2013 David D. Buell,Prothonotary By: Deputy REQUESTING PARTY: Name : ROBERT N. POLAS,JR.,ESQUIRE Address: 120 CORPORATE BLVD NORFOLK,VA 23502 Attorney for: PLAINTIFF Telephone: 1-866-428-8102 Supreme Court ID No. 201259 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i Sheriff #_' i E P t�J T H Q O rU t k Y Jody S Smith w ii ( :` � 7 Chief Deputy � Richard W Stewart "ry CUMBERLAND COUNTY Solicitor 0MCE OF x14:w'RE;IFP PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Number Crystal A. Joseph 2011-7481 SHERIFF'S RETURN OF SERVICE 11/18/2013 09:31 AM - Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Maria T. Theodoratos, Assistant Store Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November ,, 2013 to Crystal A. Joseph at 19 W Main St, FI 2, Shiremanstown, PA 17011. RIAN CGRZ XC69kl puTy SO ANSWERS, November 19, 2013 RbNW R ANDERSON, SHERIFF (c)CcuntySwke Sheriff,Teleosofi.Inc. k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES, LLC NO. 11-7481 Civil 120 0,ORPORATE BLVD NOhFOLK, VA 23502 PLAINTIFF vs. k CRYSTAL A JOSEPH 19 W MAIN ST FL 2 - 4J SHIREMANSTOWN PA 17011 rT1 rY DEFENDANT(S) 1r? INTERROGATORIES TO GARNISHEE �� TO: METRO BANK 3201 TRINDLE ROAD CAMP HILL, PA 17011 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty(20) days after service upon you. Failure to do so may result in judgment against you. h B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached", including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information is possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. 10-95508 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. I E. % INTERROGATORIES TO GARNISHEE DEFENDANT(S) - CRYSTAL A JOSEPH 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and address. Defendant has less than $300 exemption IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? % 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, including the identification number or other designation of the box or boxes. Include a full description of the content and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. 10-95508 h This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state —7hctlhor or not the Defendant(s) own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not thereare any encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s) and state the reason for the exemption, the amount being withheld under each exemption, the amount of funds in each account, and the entity electronically deposition those funds on a recurring basis. S. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s)had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charge by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. Robert N. bolas, Jr., Esquire#201259 Carrie A. Brown,Esquire#94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff k 10-95508 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 does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief ( I TURE) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC No. 11-7481 Civil Plaintiff , , vs. CRYSTAL A JOSEPH ip-v Defendant f„ p vs. '"► � '.a' METRO BANK Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the writ of attachment filed agains a arnishee only in the above-entitled matter,without prejudice. obert N. Polas,Jr.,Esquire#201259 Carrie A. Brown,Esquire,#94055 Mark R. Garvey,Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 10-95508 LL Horst, This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD No. 11-7481 Civil NORFOLK, VA 23502 Plaintiff vs. CRYSTAL A JOSEPH 19 W MAIN ST FL 2 SHIREMANSTOWN PA 17011 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dissolve Attachment CRYSTA JOSEPH and , by First Class Mail, Postage Pre-Paid, a copy thereof on this up of , 2013,to: CRYSTAL A JOSEPH METRO BAN 19 W MAIN ST FL 2 3201 T LE SHIREMANSTOWN PA 17011 CAM IL A 17011 Date: Ro . Polas, Jr., Esquire#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 10-95508 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD _ NORFOLK, VA 23502 �'' Plaintiff : No. 11-7481 Civil zrn V. t!� 1 r_ =r= CRYSTAL AJOSEPH • c3 _ � v - 3531 RUTHERFORD ST#2 • - ? HARRISBURG PA 17111-1853 • CJt • Defendant. • • • • PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE-ENTITLED CAUSE AS SETTLED AND SATISFIED. Res p ctf y Submitted, '7/ / obert N. Polas, Jr., Esquire# 201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 10-95508 a k so sopa cktki This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD • NORFOLK, VA 23502 Plaintiff : No. 11-7481 Civil v. • • CRYSTAL A JOSEPH 3531 RUTHERFORD ST#2 • HARRISBURG PA 17111-1853 • Defendant. • • • • • • • CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle and Satisfy upon CRYSTAL A JOSEPH by First Class Mail, Postage Pre-Paid, a copy thereof on this/)day of , 2014, to: CRYSTAL A JOSEPH 3531 RUTHERF• ' II ST#2 HARRISBURG 'A 11-185 // D Air ate: Date: Robert N. Polas, Jr., Esquire# 201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 10-95508 Attorneys for Plaintiff ,1.: This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OT'ri.IJNQ_. (IP ?IA JiN IS 'PH 2: 3` Ct1hPENNSYLVA4 COUNTY Portfolio Recovery Associates, LLC vs. Crystal A. Joseph Case Number 2011-7481 SHERIFF'S RETURN OF SERVICE 11/18/2013 09:31 AM - Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Maria T. Theodoratos, Assistant Store Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 19, 2013 to Crystal A. Joseph at 19 W Main St, Fl 2, Shiremanstown, PA 17011. 06/13/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $90.19 SO ANSWERS, June 13, 2014 RONNY R ANDERSON, SHERIFF (c) CournySuite Sheriff, Teleosoft, Inc.