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HomeMy WebLinkAbout11-7529Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 ii 0 TA TELE: 1-866-428-8102 e 4 k' 4 FAX: 757-518-0860 2: r ., Attorneys for Plaintiff (; n t k ANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. !?/ Z Norfolk, VA 23502 No / g Plaintiff V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 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 7 , 0 O pa' Pennsylvania Lawyer Referral Service yo /a (800) 692-7375 c 9 4 ?*&54197 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 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 ? Ill, -tilll?i-".?.tl.OT17'x ?I£11T1:9 t1C;?t (:£???c?C"ifrT`<It ? 9. <til_i?1:1.?'' (.)E ??. ? _r? ?x Anv ins onnation obtained will ,t; 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. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant SHARON B AULT, is an adult individual with last known address of 5340 OXFORD CIR APT 55, MECHANICSBURG PA 17055. It is averred that Defendant was indebted to HSBC BANK NEVADA, N.A. / ORCHARD BANK on February 3, 2007 with account number ************9836 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit 11A.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. I hi ; cormkr miceatwrr is from <a c " rcl i?; an aucrrrpt 11 env inform rr6 ll be kiss { f0t- dix ;? . 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 February 11, 2009. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA, N.A. / ORCHARD BANK 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." 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 $871.38. 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, SHARON B AULT, in the amount of $871.38, plus costs of this action and any other relief as the Court deems just and reasonab 1 v Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 10-93771 ??=fun t;or i•, f oiii a of t t {°«lic,ctor <????ci id an ItIf°In?I s1. "tt' ]{ , .t t?tsitO17 1t?l 1Slc'€? '?6'l?? be u6( ?d for thal porpc < . VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Chela Wise 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 : Trr r A k o 'ZLl 1 By: C?A A t C.hela Wise Custodian of Records 10-93771 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: ************9836 SHARON B AULT Account Holder: SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA, N.A. / ORCHARD BANK Assignee: Portfolio Recovery Associates, LLC Account Number: ************9836 Date Account Opened: February 3, 2007 Date of Last Payment: February 11, 2009 Date of Charge Off: September 30, 2009 Balance at Purchase: $871.38 Purchase Date: March 23, 2010 Balance at Charge-Off: $871.38 Less Payments: $.00 Balance Due: $871.38 10-93771 HSBH67 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, C:hela Wasp Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 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. / ORCHARD BANK ("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 SHARON B AULT ("Debtor") to the Account Seller the sum of $871.38 with the respect to account number (************9836), 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 $871.38 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC By: .f ela Wise , Custodian of Records Subscribed and sworn to before me on of 2011 Public 10-93771 flit P13iYlP1P1IC iIEtC>tl is fron) 2i delA c:olle too l,Md is <iii at(,_'mpi I<) , k:r ,'':.7 tkbi, :?rxy in I'c}nnittioil ohtamied %?ill b uNed for tfiZ? W BILL OF SALE 40 HSBC CARD SERVICES (III) INC. (f/k/a HOUSEHOLD CARD SERVICES INC.) ("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 (M) INC. and Portfolio Recovery Associates, LLC, ("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 (III INC. By:i,-?--- ---__? Name: Susan Solomon Title: Vice President-Assistant Sege!= HSBC BANK NEVADA N.A. By: --- Name: Susan Solomon Title: Senior Vice President d 6r 11 C At Li ? 0-2 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. 11-7529 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 PRAECIPE FOR DEFAULT Defendant JUDGMENT r , C? Cn 4 r6 eu 70 7 CD -<,X- Ln <CD "Tl C= l 7 1 Filed on Behalf of PI ' ti Co el of record f th' arty Date: Ro6ert N.Polas,Jr.,Esquire#20125 3 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 $771 s This conuntmication is from a debt collector is an attempt to collect a debt. Any infonnation obtained will be used for that purpose. jvbb Cat/V IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES,LLC 120 Corporate Blvd Norfolk,VA 23502 Plaintiff No. 11-7529 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,SHARON B AULT ,for failure to answer the Complaint. (X) Amount Due $871.38 Less Credits $75.00 TOTAL $746.38 (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 1.1,1 certify that a written notice of intentio le this praecipe was mailed or delivered to the party against whom judgment is to be a eyed d to his/her Attorney of record,if any,after the default occurred and at galt ten days pri r to date of the filing of this praecipe and a copy of the notice is attached. Date: Robert N.Polas,Jr., ,squire#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 This communication is from a debt collector is an attempt to collect a debt. Any infonnation 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. 11-7529 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 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$796.38,plus interest,on. (X)A copy of all documents filed with the Prothonotary in support of the wi ju hed. dg is/are c ay By. ` s. If you have any questions regarding this Notice,pie e c tact the fili pa Date: S obert N.Polas,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 Phis commwveation is from a debt collector is an attempt to collect a debt. Any inforination obtained will be used for that ptupose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk,VA 23502 Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation; Monday through Thursday 8 AM to 11 PM. Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) February 12,2013 SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 RE: Portfolio Recovery Associates,LLC VS. SHARON B AULT I1-7529 Dear SHARON B AULT: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, ()w�,07&-,U c �r Robert N.Polar,Jr.,Esquire Carrie A.Brown,Esquire Mark R.Garvey,Esquire Attorney 11D#201259/94055/312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk,VA 23502 Attorneys for Plaintiff 10-93771 Im This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that ptupose. 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. 11-7528 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Defendant TO: SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 DATE OF NOTICE: February 12, 2013 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 Cu Q 42� -�11- Robert N. Poles,Jr., Esquire Carrie A. Brown, Esquire Attorney ID S 201259194055 Portfolo Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk,VA 23502 No. 11-7529 Plaintiff V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Defendant AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel,as attorney for plaintiff,herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter,and that to the best of my knowledge,information and belief,the above named Defendant, is over 21 years of age,is last known to reside at 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 and is not in the military service of the United States or its Allies,or otherwise within the provisions of the Service Members Civil Relief Act and its Amendments. Date: Robert N.Polas,Jr.,Esquire,#201259 -� Came 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 10-93771 This communication is a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Department of Defense Manpower Data Center ResuMsas of:Feb-28-20,306:,6:23 SCRA 2.3 P aeusat to Servtcemenibm Ovd Relief A,ct Last Name: AULT First Name: SHARON B Middle Name: Active Duty Status As Of: Feb-25-2013 On Adw Duty On Aralw Duly Stews Dab Active Duty Stan Dole Adiw Duty SW Deb Sbaa Servios convon" NA NA NA This MOP— *4 10,Mdhsh arAve dory ewua bond on OW ACweow sm"Date t.MASUw Duly Wdsh 367 Dsyn of AdWe Duty ft"Dab Acdvs Duty start Date Ad-Duly End Dade StaWa 3ervke Oamponenc NA NA ..NO - NA This response redeob where Me individual MR aotiw 4uly,ssiai M"367'dnya Praoadbg the Aalw Duty Stews Dab The MerMeror H"sr"Was NotlMd al a Future Ca"b Adlw Duty on Active Duly Stapu Bate Order NobTosdon Sort Dale Order NaftsAm end Deb Status Samos cwnpanmt NA NA...':. - tip NA This response rslleob aausaNr 1M Mdtvkkaai.0r.W M unit has reoaived!Mdf'nOW40ott to repel W aAHe duty Upon seard*V the data banks of Me Department of Defense Manpower Dais Caritar,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or hisiher unit receiving notification of future orders to report for Active Duty. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Carter Drive,Sulte 04E25 Arlington,WA 22350 10-93771 The Defense Manpower Data Center(DMOC)is an organization of the Department of Defense(DoD)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 Servicemembers Civil Relief Act(50 USC App.§501 et seq,as mended)(SCRA)(formerly known as the Sddiers'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 only a small error rate. In the evert the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status slate,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 "dafenseli nk.mil"URL:http:/Iwww.defensMink.mil/faq/pis/PC09SLDR.htmi, If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 387 days preceding the Active Duty Status Date(3)Whether the individual or histher unit received earty notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§602(f)for purposes of responding to a national emergency declared by the Presiet and supported by Federal funds. AN Active Guard Reserve(AGR)members must be assigned against an authorised mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reaerve(ARs)and Coast Guard Reserve Program Administrator(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). Coverage Under this 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. SCRA protections are for Tide 10 and Tide 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1)_ 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID•.AASQBUL2V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION COVER SHEET Plaintiff(s) Portfolio Recovery Associates,LLC Case Number: assignee of HSBC BANK NEVADA,N.A.l ORCHARD BANK 11-7529 120 Corporate Blvd Norfolk,VA 23502 Type of pleading: Default Judgment Code and Classification: Filed on behalf of: Portfolio Recovery Associates,LLC assignee of HSBC BANK NEVADA,N.A./ORCHARD BANK (Name of the filing party) Vs ® Counsel of Record c Individual,If Pro Se Defendant(s) Name,Address and Telephone Number: SHARON B AULT Robert N. Polas,Jr.,PA Bar 201259 5340 OXFORD CIR APT 55 Carrie A. Brown,Esq.,PA Bar 94055 MECHANICSBURG PA 17055 120 Corporate Blvd Norfolk,VA 23502 Telephone: 1-866-428-5102 Attorney's State ID: Attorney's Firm ID: Pam- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 PLAINTIFF vs. NO. 11-7529 SHARON B AULT 2300 KEBNT ST CAMP HILL PA 17011-3630 DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION-MONEY JUDGMENTS TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. ter', (1) Direct to the Sheriff of CUMBERLAND County,PA; (2) against SHARON B AULT Defendant(s); ak€ (3) and against PNC BANK Garnishee(s); — /0 c f ‘t s/vc�• p ed(//s/e P� /70/3 (4) And index this writ (A) against SHARON B AULT Defendant(s) (B) and against PNC 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,certif•. - i f deposit, ceivables,collateral, pledges,documents of title,securities,coupons and safe deposit boxes. A-) (5) Amount Due: $796.38 Signature/ID Number Interest From March 15,2013: $8.45 Robert N.Polas,Jr.,Esq.#201259 (At an interest rate of 6%per year) Print Name Total: $879.83 Plus costs&interest Carrie A.Brown,Esq.#94055 (Total includes post judgment credits) ® Address s a cOCY Ci‘dk \ .5g- 600 G B I° Norfolk,VA 23502 (12. 00 d2, Co, t7 S. sb P 10-93771 C K 53 4 S).%(0 31c‘ X466 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used fd'r that purpose.wi WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2011-7529 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Portfolio Recovery Associates,LLC Plaintiff(s) From Sharon$. Ault-2300 Kebnt St.,Camp Hill,PA 17011-3630 (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 PNC BANKGARNISHEE(S)as follows: PNC BANK- 105 Noble Boulevard,Carlisle,PA 17013 All accounts including but not limited to all savings,checking and other accounts,certificates of deposit,notes receivables,collateral,pledge,documents of title,securities,coupons and safe 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$796.38 Plaintiff Paid$ Interest From March 15,2013-$8.45(At an interest rate of 6% per year) Attorney's Comm. % Law Library$.50 Attorney Paid$175.50 Due Prothonotary$2.25 Other Costs$ Date: 11/4/2013 El David D. Buell, Prothonotary B : / ! Deputy REQUESTING PARTY: Name : Robert N. Polas,Jr.,Esq. 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 Sheriff I PRO! Jody S Smith ' F� � HOY 14 : Chief Deputy Richard W Stewart h, CUMBERLAND COU.Ji y Solicitor OFFICE OF T14E St< iF= PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Sharon B. Ault 2011-7529 SHERIFF'S RETURN OF SERVICE 11/07/2013 11:40 AM -William Cline, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Banking Officer, 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 13, 2013 to Sharon Ault at 2300 Kent Street, Camp HIII, PA 17011. C INE, DEPUTY SO ANSWERS, November 12, 2013 RONNY R ANDERSON, SHERIFF (c)Coun:ySW O Shorif!,TdeosoR,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES,LLC No. 11-7529 :. Plaintiff ;, mcv rr r r-ri • VS. . ' fir= .� er' SHARON B AULT `Ar,— -- ' Defendant C)• Vs. • —< 47-. PNC BANK,N.A. Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the writ of attachment filed again the Garnishee only in the above-entitled matter, without prejudice. I =ert 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 T s^a lC.l._^, Ctt� /4 ozq!Q 10-93771 • 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. 11-7529 • NORFOLK,VA 23502 •• Plaintiff • • vs. SHARON B AULT •• 5340 OXFORD CIR APT 55 • MECHANICSBURG PA 17055 • Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dissolve Attac t upon S7 'ON B AULT and,by First Class Mail,Postage Pre-Paid, a copy thereof on this day of 6-- , 2013,to: SHARON B AULT PNC BANK,N.A. 5340 OXFORD CIR APT 55 105 NOBL :? VD MECHANICSBURG PA 17055 CARLIS ,/'A 17013 Date: A , Rob" 1. 'o1as, 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 10-93771 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 �.: ,J It -O iH i).0 THE : Ri�1THO 'NQ A t 70 11;JUN E6 PH 2:35 CUMBERLAND cOUHT PENNSYLVANIA oF.mlC,OFTHE $14 RIFF Portfolio Recovery Associates, LLC vs. Case Number Sharon B. Ault 2011-7529 SHERIFF'S RETURN OF SERVICE 11/07/2013 11:40 AM - William Cline, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Banking Officer, 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 13, 2013 to Sharon Ault at 2300 Kent Street, Camp HIII, 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: $90.19 SO ANSWERS, June 13, 2014 (c) CountySuite Sheriff, Teleosof, Inc. RSON, SHERIFF 00-R rNDER e4.4 1G 7b 3073$ 2 ' 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. 11-7529 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 N c Defendant. PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE-ENTITLED CAUSE AS SETTLED AND SATISFIED. sp tfully Submitte , Obert N. Polar, 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 10-93771 I' 36 914 y p This communication is from a debt collector and is an attempt to coll�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. 11-7529 V. SHARON B AULT 5340 OXFORD CIR APT 55 MECHANICSBURG PA 17055 Defendant. CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle and Satisfy upon SHARON B AULT by First Class Mail, Postage Pre-Paid, a copy thereof on this ay o& , 2014,to: SHARON B AUL 5340 OXFORD C APT 5 MECHANICSB l 55 . Date: Ro 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 10-93771 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.