HomeMy WebLinkAbout11-7677Robert 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: 1-866-428-8102
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
V.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Defendant
NOTICE
No. //_ 7,177 6,V1 G 7r--
6) fzi6) d
-
M c
)
x --a r i
-W
?i
CJ
q4 4
C -
ii
--A
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 s
(800) 692-7375 , lazo a PC/A/ J
/ pO S-8, ?
This communication is from a debt collector and is an attempt to collect a debt. ^
45 ? ??
Any information obtained will be used for that purpose. GL
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. :
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
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
11iis coninwilication is boon a debt colle, for and is an ationpt to collco a debt.
Aiiv inforination obtained sill 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.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Defendant
COMPLAINT
Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with
offices located at 140 Corporate Blvd., Norfolk, VA 23502.
Defendant FORREST MILLER, is an adult individual with last known address of 526 SHED RD,
NEWVILLE PA 17241.
3. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / WAL-MART on
November 13, 2008 with account number ************3945 (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.
At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and/or for obtaining services.
'['iti c:cgn1111tinication is from <, debt c?,J1>.?.' ,, iid is nn attcmp( 1.0 colkxi a debt,
Any information obtained v 11 `?e L&A for lha purpose.
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 18, 2008.
Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK, F.S.B. /
WAL-MART 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
$1,064.99.
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, FORREST MILLER, in the amount of $1,064.99, plus costs of this
action and any other relief as the Court deems just an asonable.
Robert N. Polas Jr., Esquire # 201259
Carrie A. Brown, Esquire # 94055
10-99257
This c(nimiunicatinn is from a debt collector and is an attempt to c ollecl a
Any inforniatioii obta nci will be used f()r (fiat purpose,
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Cristina 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 au ities.
Date : SEP ! ! zen B
Cristina Patterson
Custodian of Records
10-99257
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: ************3945
FORREST MILLER
Account Holder:
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Consumer Account Product Code: PVT
Issuer: GE MONEY BANK, F.S.B. / WAL-MART
Assignee: Portfolio Recovery Associates, LLC
Account Number: ************3945
Date Account Opened: November 13, 2008
Date of Last Payment: December 18, 2008
Date of Charge Off: August 2, 2009
Balance at Purchase: $1,064.99
Purchase Date: May 27, 2010
Balance at Charge-Off: $1,064.99
Less Payments: $.00
Balance Due: $1,064.99
10-99257
GECI25
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, Cr(stins Patterson , 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 GE MONEY
BANK, F.S.B. / WAL-MART ("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 May 27, 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 FORREST MILLER ("Debtor") to
the Account Seller the sum of $1,064.99 with the respect to account number (************3945), as of August 2, 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 $1,064.99 as due and owing as of the date
of this affidavit.
folio overy socia LLC
y: Cristina atterso ustodian QfRecords
Subscribed and sworn to before me on A) of 2011
u , Victoria Gray
Not 1C Commonweaith of Virginia
Notary Public
Commission No. 7372000
10-99257 '" My Commission Expires 11!3012014
(` > natataication is from a debt coliector and is an attempt to collect a debt,
ra?r ?, r F3ratinn c?htallied will be used for tbat purpose.
0 GE Money Bank
BILL of SALE
PRA 120-day Mid Prime - May 2010
For value received and in fiuther consideration of the mutual covenants and
conditions set forth in the Forward Flow Receivables Purchase Agreement (the
"Agreement'), dated as this day of April 2010 by and between General Electric Capital
Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and
Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio
Recovery Associates, LLC (`Buyer"), Seller hereby transfers, sells, conveys, grants, and
delivers to Buyer, its successors and assigns, without recourse except as set forth in the
Agreement, to the extent of its ownership, the Receivables as set forth in the Notification
Files (as defined in the Agreement), delivered by Seller to Buyer on May 19, 2010, and
as further described in the Agreement.
GE Money an
t
By:
d( 'nJrfft4-,L-
Title: CFO
Retailer Credit Services Inc//,, `D
By-
Title: President
General
By.
Title:
SHERIFF'S OFFICE OF CUMBERLAND-0, "TY
Ronny R Anderson
Sheriff tr?, of ?r?nar? 4'511 OCT 18 PCB
?attr
Jody S Smith -?'4
Chief Deputy , - f7?J MBERLANO I EM
Richard W Stewart Solicitor ON CE OFT"E'-ERIFF
Portfolio Recovery Associates, LLC Case Number
vs. 2011-7677
Forrest Miller
SHERIFF'S RETURN OF SERVICE
10/11/2011 11:27 AM - William Cline, Corporal, who being duly sworn according to law, states that on October 11,
2011 at 1127 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Forrest Miller, by making known unto Cheryl Miller, Mother of Defendant at 526 Shed
Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the me time handing to
her personally the said true and correct copy of the same.
WILLIAM CLINE, DEPUTY
SHERIFF COST: $40.00
October 13, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
;c) Coui rySuite Sheriff. Telensoft. Inc.
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. 11-7677 CIVIL TERM
V.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241 PRAECIPE FOR DEFAULT
Defendant JUDGMENT CZ c
xrT1 r" .
r—
a
Filed on Behalf of Plaintiff
Counse of record for ' Part
Date:
I
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
6lL4
��
a F7o"I
This communication is from a debt collector is an attempt to collect a debt.
Any inf'onnation obtained will be used for that purpose. `
NO (11
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. 11-7677 CIVIL TERM
V.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant,FORREST MILLER ,for failure to
answer the Complaint.
(X) Amount Due $1064.99
Less Credits $768.13
TOTAL $296.86
(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.231.1,I certify that a written notice of intention to file this praecipe was
mailed or delivered to the party against whom judgm is to be entered and er Attorney of
record,if any,after the default occurred and at lease days prior to the d e of a 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
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 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. 11-7677 CIVIL,TERM
V.
FORREST MILLER
526 SHED RD
NEArVILLE PA 17241
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$296.56,plus interest,on.
(X)A copy of all documents filed with the Prothonotary in suppo '' f the wq 'ud nt is/are a
a J� 4A
By:
OL
If you have af;uestion�Ss regarding this Notice,please c act the filing party
Date:
Robert 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
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
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 5 PM,
Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST)
February 12,2013
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
RE: Portfolio Recovery Associates,LLC
VS.FORREST MILLER
11-7677 CIVIL TERM
Dear FORREST MILLER:
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
Mark R.Garvey,Esquire
Attorney ID#201259/94055/312686
Portfolio Recovery Associates,LLC
120 Corporate Blvd
Norfolk,VA 23502
Attorneys for Plaintiff
10-99257
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
120 Corporate Blvd
Norfolk,VA 23502
Plaintiff No. 11-7677 CIVIL TERM
V.
FORREST MILLER
526 SHED RD :
NEWVILLE PA 17241
Defendant
TO: FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
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
V kj
Robert N. Polas, Jr., Esquire
Carrie A. Brown, EsgWre
Attorney ID#201259/94055
Portfolio 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. 11-7677 CIVIL TERM
Plaintiff
V.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
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
526 SHED RD
NEWVILLE PA 17241
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
10-99257
This communication is a debt collector and is an attempt to collect a debt.
Anv information obtained will be used for that purpose.
Department of Defense Manpower Data Center Resues as of:FW25-2013 09:53:59
SCRA 2.3
ftim
PUrVM*toSftvioemembasQvffReWAcI
Gast Name: MILLER
First Name: FORREST
Middle Name:
Active Duty Status As Of: Feb-25-2013
On Adhre Duty On AdWe Ddy Stsbsl Oats
Acbm MAY SWt Dart Aceve Otsty End Dais Stall Ssrnce CstroonsrA
NA NA -_NO, NA
TNa response reeeola tltr_t{kstduW'erAV*duty$ous based an#*Aotlw,DuOr spats Dese
Let At"Duty WWn 307 Days of Adiw Duty eptn Daft
AM"DL*Start DOW Acura qtly Fit Delp sfsaes ser**cwrparrer
NA NA No NA
This response ro%M wits the owtoidust fe0 Wo"duty atetuu waft 397-days Preoedh0 the AA"Duly Sswu D i to
The Membsror MWMw firs wes Neff"d e Futon C04JP to Adre Duty on Aaft Duty S W1s flee
Order Nowkwon SWt Do* Order NoOk Iart End Dda status Sarolce cor p Ward
NANA NA
This response raMr3s wheew the fndW*W.orhWtler una has Murat essV rwfte an to report for so"duty
Upon searddng the data banks of the Department of Defense Manpower Data center,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 Mather unit receiving notification of future orders to report for Active Duty.
#Wk pl.
e►�
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Canter Drive,Suite 04E25
Arlington,VA 22350
10-99257
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official sake of data on eligibility for military medical owe and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Seers'and Sailors'Civil Relief Act of 1840). 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 event 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 date,or is otherwise entitled to the
protections of ttre SCRA,you are strongly encouraged to obtain further verification of the persons status by contacting that person's Service via the
"defenselink.ml'URL:http:Nwww.defenselink.milMaglpis1PC09SLDR.htm1. 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 inked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individuaPs Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status~3137 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early 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§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. AN Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RDAs). 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 the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some canes 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 Title 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 webode,
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,SSNldats of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate 1D: GUO15HNE6R
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
PORTFOLIO RECOVERY ASSOCIATES,LLC
120 CORPORATE BLVD
NORFOLK,VA 23502
PLAINTIFF
VS. Nb. 11-7677 CIVIL TERM
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
DEFENDANT(S)
PRAECIPE FOR WRIT OF EXECUTION-MONEY JUDGMENTS '
TO THE PROTHONOTARY: i
ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER.
(1) Direct to the Sheriff of CUMBERLAND County,PA; .4 p► C?.
(2) against FORREST MILLER Defendant(s); 9-�yd tot
(3) and against MEMBERS 1ST FCU BANK Garnishee(s);
(4) And index this writ
(A) against FORREST MILLER Defendant(s)
(B) and against MEMBERS 1ST FCU 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,certifi5x—��eposit,notes a ables,collateral,
pledges,documents of title,securities,coupons and safe deposit boxes.
(5) Amount Due: $296.86
Signature/ID Number
Interest From
March 15,2013: $1.87 Robert N.Polas,Jr.,Esq.#201259
(At an interest rate of 6%per year) Print Name
Total: $298.73 Plus costs&interest Carrie A.Brown,Esq.#94055
(Total includes post judgment credits)
120 Corporate Blvd
Address
Norfolk,VA 23502
IQ. SD �' h
da 5
` soul
10-99257
U oa 4-Z)-o A
-�k qq al )cit.
This communication is om a aebt collector and is an attempt to collect a debt.
l!(J
Any information obtained will be used for that purpose.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 11-7677 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 FORREST MILLER,526 SHED ROAD,NEWVILLE,PA 17241
(1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed
to attach the property of the defendant(s)not levied upon in the possession
of GARNISHEE(S)as follows:
MEMBERS 1sT FCU BANK,1711 SPRING ROAD,CARLISLE,PA 17013,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 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;
(2) 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$296.86 Plaintiff Paid$
Interest FROM MARCH 15,2013-$1.87 AT AN INTEREST RATE OF 6%PER YEAR
Attorney's Comm. % Law Library$.50
Attorney Paid$177.50 Due Prothonotary$2.25
Other Costs$
Date: 12/09/13
David D.Buell,Prothonotary
(Scat)
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
Sheriff
Jody S Smith - T, ,
Chief Deputy r
Richard W Stewart i { ;, `
Solicitor
iibt.riLACcilJ LOU
PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs. Case Number
Forrest Miller 2011-7677
SHERIFF'S RETURN OF SERVICE
12/11/2013 02:05 PM - Dawn Kell, 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton
Township, Carlisle, PA 17013, Cumberland County, by handing to Dolores Shank, Teller II, 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 December 13, 2013 to Forrest Miller, 526
Shed Road, Newville, PA 17241.
DAWN KELL, DEPT
SO ANSWERS,
December 13, 2013 RONNY R ANDERSON, SHERIFF
scR.H;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES,LLC
No. 11-7677 CIVIL TERM
Plaintiff
VS. c. s
. C= �..
FORREST MILLER "
Defendant
MEMBERS 1ST FCU BANK `Z
Garnishee PO
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Please dissolve the writ of attachment filed against t Garnishee only in the above-entitled
matter, without prejudice.
Ro 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
$9. s�a
10-99257 e 2L)
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. 11-7677 CIVIL TERM
NORFOLK, VA 23502
Plaintiff
vs.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Defendant
CERTIFICATE OF SERVICE
The undersigned does hereby certify that I served a copy of the foregoing Praecipe to
Dissolve Attachment upon FORREST MILLER and MEMBERS 11T FCU, by First Class Mail,
Postage Pre-Paid, a copy thereof on this .3 day of cr C_ti , 201 to:
FORREST MILLER MEMBERS 1 ST FCU BAINK
526 SHED RD 1711 G RD
NEWVILLE PA 17241 CA , PA 170
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
Attorneys for Plaintiff
10-99257
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
v.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Plaintiff : No. 11-7677 CIVIL TERM
Defendant.
PRAECIPE TO SETTLE AND SATISFY
PLEASE MARK THE JUDGMENT IN THE ABOVE -ENTITLED CAUSE AS
SETTLED AND SATISFIED.
R= pect fly Submitted,
-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
Attorneys for Plaintiff
10-99257
et--# LC9?31
-+ 30) W/
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
v.
FORREST MILLER
526 SHED RD
NEWVILLE PA 17241
Plaintiff : No. 11-7677 CIVIL TERM
Defendant.
CERTIFICATE OF SERVICE
The undersigned does hereby certify that I served a copy of the foregoing Praecipe to
Settle and Satisfy upon FORREST MILLER by First Class Mail, Postage Pre -Paid, a copy
thereof on this 1 t day of
Date:
10-99257
,2014, to:
FORREST MILLER
526 SHED NI
NEWVILL . ' : 7241
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
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
of corputpt,
JUL —3 AM 10: 30
OFFICE QF THE !'SRIFF
CUMBERLAND COUHT'I
PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs.
Forrest Miller
Case Number
2011-7677
SHERIFF'S RETURN OF SERVICE
12/11/2013 02:05 PM - Dawn Kell, 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, Members 1st Federal Credit Union, 1711 Spring Road, North
Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Dolores Shank, Teller II,
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 December 13, 2013 to Forrest Miller, 526
Shed Road, Newville, PA 17241.
07/02/2014 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. However, plaintiffs attorney filed a
praecipe to settle and satisfy 06-18-14.
SHERIFF COST: $94.36 SO ANSWERS,
July 02, 2014
(c) CountySuite Sheriff, Teleosoff, Inc.
RONNY R ANDERSON, SHERIFF
ci ° Vor
P-+- 30709