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HomeMy WebLinkAbout11-8507Rbbert N. Polas, Jr., Esquire PA Bar # 201259 Carne A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC = ( s 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff t . S ,r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL PA 17011 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. I l_ V`196 1 Cm. k 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. 0 k-W I I aWo 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. MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL 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 conrnrwrication is fiorn a debt collector acrd is an attempt to collect a debt. Any in formation 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. MOLLY ROBERTSON 2101 MAYFRED IN CAMP HILL 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 MOLLY ROBERTSON, is an adult individual with last known address of 2101 MAYFRED IN, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to HSBC BANK NEVADA, N.A. / BON TON on August 20, 2003 with account number ************7112 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectivelymarked 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. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. This communication is from a debt collector and is an attennpt to collect a debt. Any information obtained will be used for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforemenioned 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 July 5, 2008. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA, N.A. / BON TON 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 $815.20. l O.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 detrimerrt of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration WHEREFORE, Plaintiff respectfullyrequests this Honorable court enterJudgment in favor ofPlaintiff and against Defendant, MOLLY ROBERTSON, in the amo of $815.20, plus costs of this action and any other relief as the Court deems just and reasonable. 117 Robert N. Polas Jr., Esquire # 201259 - Carrie A. Brown, Esquire # 94055 11-13608 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 Custodian of Records for Portfolio Recovery Associates, LLC, LaFFy , .? 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 bythe Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsifrcationto authorities. OCT 2 8 2011 Date : By: r4? La J. A r -- Custodian of Records 11-13608 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: ************7112 MOLLY ROBERTSON Account Holder: MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL PA 17011 Consumer Account Product Code: PVT Issuer: HSBC BANK NEVADA, N.A. / BON TON Assignee: Portfolio Recovery Associates, LLC Account Number: ************7112 Date Account Opened: August 20, 2003 Date of Last Payment: July 5, 2008 Date of Charge Off: January 31, 2009 Balance at Purchase: $815.20 Purchase Date: April 22, 2010 Balance at Charge-Off: $815.20 Less Payments: $.00 Balance Due: $815.20 11-13608 HSBH93 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPTTO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, LaRY J. Andrews depose, affirm and state as follows: Custodian of Records, for Portfolio Recovery Associates, LLC hereby I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee') which is doing business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from HSBC BANK NEVADA, N.A. / BON TON ("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 April 22, 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 MOLLY ROBERTSON ("Debtor') to the Account Seller the sum of $815.20 with the respect to account number (************7112), as of January 31, 2009 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, Account Assignee claims the sum of $815.20 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC By: LA" J. Arfdr 5 stodian of Records Subsc 'bed and swornto before me on of ., 2011 No ary Pu is 11-13608 =_. - .ri 7- 'Phis communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx:717.240.6397 Plaintiff/s: Court Number: PORTFOLIO RECOVERY Expiration Date: ASSOCIATES, LLC Type of Action: CIVIL Defendants: MOLLY ROBERTSON Serve Upon: MOLLY ROBERTSON Address for Service: 2101 MAYFRED LN CAMP HILL PA 17011 Alternate Address for for Service: Type of Service: ? Adult in Charge ? Personal ? Deputize ? Certified Mail ? Posting -Copy of Cmut Order Required with po,64" Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: Robert N. Polas, Jr. Address: 140 Corporate Blvd. Norfolk, VA 23502 Phone Number: 1-866-428-8102 HSBCID EXHIBIT A (Continued) ASSIGNMENT AND BILL OF SALE HSBC Receivables Acquisition Corporation (USA) IV, (hereinafter called "Seller") has entered into a Purchase and Sale Agreement as of September 28th, 2009 ("Agreement") for the sale of One (1) Agency Recall Charged Off Receivables described in Paragraph 1 thereof to Portfolio Recovery Associates, LLC., (hereinafter called "Purchaser"), upon the terms and conditions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in each and every one of the One (1) Agency Recall Charged Off Receivables described in the Agreement and in Exhibit A attached hereto. Purchaser and Seller agree that the Purchase Price shall be as stated in Paragraph 3 of the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 22"d day of April, 2010. HSBC Receivables Acquisition Corpo tion (USA) IV Susan Solomon Senior Vice President HSBC Card and Retail Services 1111 Town Center Drive, Las Vegas, NV 89144 consolidation of any Claim with the claim of any other person are permitted in arbitration without the written consent of you and us. THE PARTIES ACKNOWLEDGE THAT THEY HAVE A RIGHT TO LITIGATE CLAIMS THROUGH A COURT BEFORE A JUDGE OR JURY, BUT WILL NOT HAVE THAT RIGHT IF EITHER PARTY ELECTS ARBITRATION. THE PARTIES HEREBY KNOWINGLY AND VOLUNTARILY WAIVE THEIR RIGHTS TO LITIGATE SUCH CLAIMS IN A COURT BEFORE A JUDGE OR JURY UPON ELECTION OF ARBITRATION BY EITHER PARTY. You MU tomato, obtain the arbitration mks of, or Nat a Glom with NAFor JAMS as tolhmva mwbwk6ww.#- JAM ?marxwa mkuwkmum :- J::.+v::K nsrrwmt s.a:.s Arlanhira avr w hadsrw What To Do If Tl ere'le Ae Error In Your Bill :DUX BILLING XISXTS - XBZP TXIS NOTIGB POX FUIURX URN This rattles contains unliertut hrtormation about your Account not, and our reaponsibdide Under the Tai Credit Billing Act. MM IB IN CABS OP EUM OR QIJBBMM ABOUT' YOUR BIL If you think your bin is wrong. or if you need more infmnmion about a tcamactioa an your bill. wnse us on • separate ahem at the address listed on yaw bill. Write to rte as noun as possible. We must hear from you no lawn than 60 days after we seat you the first bill on which the error or problem appeared. You can lelephox us. but doing so will not preserve your rights. In your letter give us dun following information • Your name and atroura number. • The dollar come= of the suspected errs. • Describe th error and explain. if you can. why you believe there is an error. If you need mare Wdorm ation. describe dun item you cow not sure about if you have atborixed us to lay your credit card bin automatically from your savings or checking accountt, you can mop the payment on any amount you think a wrong. To stop tat Payment your letter mum reach us three business days before the automa is payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE We map acknowledie your later wino 30 days, union we have corrected the arcs by than. Within 90 ayes. we mum either correct the arm of explain why we believe the bill was correct After we receive your letter. are epntot try to collect any amount YOU will have to make up any aussed payments on the questioned amour. In either case, we will acrd you a statement of the amount you owe and the date than it is due. 11 You fail to pay the amount that we drink you owe, we may report you as deliaquem. However, if roue explanation does out suisty you and you write m us within tan days wiling us that you dill refuse to Pay. we mum tell anyone to whom we furnished credit information abate you that you have a question about your bill. And we must ten you the same of anyone lo whom we gave this informamm. We must tell anyone we report you to thus the matter has been settled between us when it fatally is. If we don't follow time ores, we can't collect the rust $50 of the questioned amount, emit your bill was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES If you have a problem with the quality of property or services that You puwJused with a 01101 card, and you have tied in good firth to correct tat problem with the merchant. You may have the right rtes to pay the remaining amount due on the ptapfrry or services. There are two limitations on this right: (a) You mug have made the purchase in your home suits or, if not within your burs state, within 100 miles of your current "lint address; said (b) The purchase price must have been more than $50. These limiutiau do not apply if we own or operate the merchant. r if we mailed you the advertisement for tat property or savic es. Household Credit Services, Inc. and/or Household Credit Services (I1), Inc, provide processing services for Household Bank (SB), N.A. You may write to use at: Hau9TW0wni9ana (Silk N.A H1101-1 111 Tow Curter Drive I= Vegas, Nevada 09130 e??4_C4_ Thomas M. Kimble Executive Vice President October 1, 2004 HSBC Q1 CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT AG2198 (1U4) AGREEMENT TO TERMS AND DEFINT oms This Cardmember Agreement and Disclosure Statement, the enclosed document entitled "Important Information Regarding Your Account", amt any arnerdntem s to them are collectively the "Agreement" that govems the open end line of credit we have established for you (your Account). "You" and "your' refer to all persons who applied for rte Account -We," -us," and `ore' refer to Household Bank (SB), N.A. "Card" mesas any credit cards issued under this Agreement. You and we are bound by this Agreement from the owhat, of the time you receivs it or Iron, the elate of the first transaction, including, without limitation, the placement or posting of any Annual Fa on your Account. You may cancel your Account before using it without paying any Annual Fee if you call us within 90 days of your Account open dare, at the Customer Service number on the back of your card. You agree to use your Account only for personal, family. household, at charitable purposes. You agree not to use your Account to mike payments to us or to any of our affrlimes. You agree to only use your Account for valid and lawful purposes and that if your Account is used for any other purposes you are responsible for such use and may be required to reimburse us and MasterCard International Incorporated for all resulting amounts and expenses. PROMISE TO PAY You promise to pay according to the terms of this Agreement for all: (a) credit we extend to you or to anyone you authorize to use your Account; (b) Finance Charges, late charges. overlimit charges and administrative charges (e.g. far returned checks, tic.) provided in this Agreement; and (c) collection costs and attorneys' fats to the extent permitted by applicable law. If your Account is a joint Account, each joint Accountholder is jointly and individually responsible for all amounts due under this Agreement regardless of deurh, divwtt, other legal proceedings or any agreement that may affect liability between you. If either joint Accountholder denies liability for amounts owed, we may close your Account. I we do, you must continue to pay according to the Ierms of dais Agreement, but you will not be able to mAke new charges on your Account. USING YOUR ACCOUNT You can access your Account using your Card or by other mearu anaroved by us; which may inrhrt4 rash advanre ,ranearein- ASSICNMF.NT OF ACCOUNT We may sell, assign or transfer your Agreement and Account or any portion thereof without notice to you. You may not sell, assign or transfer your Account. CERTAIN PRIVACY PRACTICES You agree that from time to lime we may receive credit information concerning you from others, such m stores, other lenderx, and credit reporting agencies, and tut we may use this information to amend, cancel or suspend your credit privileges under this Agreement even if you are not In default with us. You agree that the Department of Motor Vehicles may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel nay listen to and record telephone tails between you and our representatives in order to evaluate the quality of our service to you and alter cmdmemberx. For additional information regarding our privacy practices, please refer to our Privacy Statement pmvkxWy provided to you. INFORMATION SNARING WITH AFFILIATES Except so limited by applicable low, you agree dud we ray shore Information we receive about your creditworthiness ("Credit Information") antler information relating M our transactions and experiences with you ("Experience Information") with persons related to as by common ownership or offillped with as by corporate control ("AfNlfates"); our Affiliates may use this information to determine If you galley for adNNon1 offers of ereuYt. You may prohibit the sharing of Credit hsformatien with our Af hates by writing N as at P.O. Box 811026, SaNaa, CA 93912-6016 and IntluMag the near, address, social security number, algatare and account number (it applicable) far each person nothing Yse site tlem Your request will aot a to the sharing or Experience Information, apply CREDIT REPORTING U you fail to fulfill the arms of this Agreement, a negative report reflecting on your credit record may be submitted to a credit reporting agency. If any specific information related to your Account transactions or credit experience with us is inaccurate, you may notify as and request m to correct the inaccurate information (ails r confirmation or the alleged error) reported to any credit reporting agency by writing to me at P.O. Box 98706, Las Vegas, NV 89193, WAIVER We may choose to delay enforcing or waive any of our rights under this Agreement in certain situations. We can delay enforcing or waive any of our rights without affecting our other rights. If we waive a right, we do not thereby waive the same right in other situations, UPDATED FINANCIAL AND OTHER INFORMATION Upon request. you agree to promptly give us accurate Menial and other inftmmaton about yourself. SEVERABILITY If any provision of this Agreement is finally determined to be void or unenforceable under any law, rule or regulation, all other provisions of this Agreement will remain valid and enforceable. ARBITRATION You agree any claim, dispute. or cmnmavctsy (whether breed upon contract; tort. intentional or otherwise; constitution; statute; common law; or equity and whether pre-existing, present or fuhue), including Initial claims, counter-claims. croa-claims and third party claims, mixing from or relating to this Agreement relatlonships which result from this Agreement, includit validity or enforceability of thus arbivatioa clause, any pan ti or the entire Agreement (Claim"), shall be resolved, upt election of you of us, by binding arbitration pursuing t. arbitration provision and the applicable sides or procedures arbtralion administrator selected at Use lime the Glum is file pasty initiating the arbitration proceeding shall have the ril Meet one of the foil" arbitration adminismoom the Na Arbitration Forum ("NAF") or JAMS. The arbitator shall lawyer with ogre Ilan ten Years experience or a retired or f judge. We agree not to invoke our right to Arbitrate an indis Cm sYo may bring In small claims town or an equivalent r aY long as the Claim is pending only in that coon. The and farms of the NAF and JAMS may be ob u ,.d by writ) Uheae agArdmUOU at the addresses Iisted below. Our addra service of process under this provision is Household C Services, Inc., P.O. Box 98740, Las Vegas, NV 89193-6740. Any participatory arbitration hearing that you attend will place in the city nearer 10 your residence whom a federal d court is located Of at such other location as agreed by die pa On MY Claim you file, you will pay the first S30 of the filing At your rerpast we will pay the remainder of the filing fee arc administrative or hearing fees charged by the arbitra administrator on any Claim submitted by you in arbitration up maximum of SI Mo. if you are required to pay may additional to the arb(matian administrator, we will consider ¦ request by to pay all err pass of dot additional far; however. we shall m obiigalad to pay MY additional rem unless the arbitrator grants m wrerd. If the arbitrator grants an award in your favor. we re(trdarrse you for my bftuOnW fan paid of owed by you is arbitration sdu"MW up to the amoum of the left that w. have Incas charged If the or(ginW Claim had been for the am= am actud award in yam favo. The pahtia shall bear the exp, of their respective attorney's fees. except as otherwise provide, law. U a stage gives you the right to recover try of them feet the fm paid to the arbitration admhhiavmor, these statutory ri; . shall apply In the arbitration notwithstanding anything to contrary contained herein. if the arbiamor I== as award in favor, Yost will no be required to reimburse us for any fan have pevigrly pad so the arbiuation administrator o for wt we are responsible. This arbitcadou agreement is made pursuant to a transact involving isreesime commerce. and shall be governed by Fed" Arbitration Act, 9 U.S.C Sectbm 1 • 16 (the "FM'ry. ' arbirtstot"apply applicable substantive law consigners with FM Intl provide wrhim reassured findings of fact and concarh of law. The arbiuatar's award shall rot be subject m appeal esc ss permitted by the FM. The parties agree tlw the award slWl kept confidential. Judgment upon the award nay be entered lo coot having jurisdit:tioq This Arbitration agreement shall survive termination of y( Ace-at as well as the repayment or all amounts borrow hereunder. if any portion of this arbitration agreemem is deer invalid or umenfotceabk order my law or stmme consistent w the FAA, it shall not invalidate the reaaiainji pardons of d ttribution IgmERM weep Agreement. e es and pevvenst Ofa ofn or be arbitration administrator and this arbitration agreement, it arbitration agreement shill govern. No class actions of joinder imum Finance Charge may increase the actual Annual usage Rate on your Account. MAL FEE :Mbsed documem entitled "Important Information Regrading Account" inlikates whether or not Your Account u svb*i to amid Fee. If your Account has an Annual Fee. you agree to n Annual Foe for each Year Your Account I- Op. or closed a bill is as MOW to be set by us from time to tote The al Fee coeapa- Hu"a okd Bank (SB), N.A., in part, for October services provided or made available to you Ibau the membw"ItlF Yew Which Includes him is tool limited fight of the cardvrcmbcr to sccega customer Service staff, he If the Cardmember to withhold paYmtm of disputed charges. e poc using sed asitia# or the billing statetoeal- sPAYMENTFEE ay add a late payment fee to Your Account for each billing you fail to pay m least the Minimum Payment and any u past due, in time to be credited to your Account by tls I 1 of your N Due Date. This late payment' in, will vary based on the net Will be., $1-1 balance as of the Payment Due Your balance is Shoo a lots: S29 if your e is more than $100 and vp to and inclading SI AOO; and $39 balance is greater than SIA00. RNED CHECK CHARGFIRETURNED PAYMENT FEE cry add a fee to Your Accourd each time a payment check, tic payment dt&wd m, Or similar instrument is not honored eturned unsatisfied by your bank or other financial on. Tbh fee is $35. I add a fee to Your Account each time a credit card check (a e transfer check, electronic check, etc.) is returned led by ua for arty reason. This fee is $35. me 'be' say Plymeot remmed unsatisfied for sty reason 'Posted to any type of trarhaaction (i.e. cash advance, e. etc.) and Finance Charges may he reioswsed back to the t dew at the APR being charged for tbat transaction type. .IMIT FEE e add an overlimil fee to your Account if your balance Your credit limit m any time during dot billing cycle. We rose this fa even if we mahoriae a impose any doges ,e Your balance to exceed your credit limit. This fee is $35. ;E OF TERMS (fncligi g Fbuaca Charges) Y CHANGE OR TERMINATE ALL OR ANY PART S AGREEMENT, Olt ADD NEW TERMS AT ANY NCLUDING WITHOUT LIMITATION ADDING OR ASING FEES, INCREASING YOUR PERIODIC NT AND INCREASING THE RATE OR AMOUNT ANCE CHARGE, OR CHANGING THE METHOD IMPUTING THE BALANCE UPON WHICH 71E CHARGES ARE ASSESSED- AMONG OTHER ii. WE MAY UNILATERALLY INCRRACR Tsar DEFAULT AND TERMINATION OF AGREEMENT You will be in default tinder this Agreement if., (u) you fail to make at least file Curren Payment Due in time to be credited to your Account by the Payment Due Due; (b) you violate any provision of this Agreement; (c) you die: (d) you become subject to bankruptcy or taeolvency proceedings: le) You supply w with misleadipg, false. incomplete or incorrect information; (f) we receive iofantation from third parties, including credit reponiag agencies, which iudici se a serious delinquency or tiurge.olt whit Other creditors; (S) you tail to provide us a phys" adtrss: (b) YOU exceed your credit limit; (i) Your payment is returned unsatisfied by your book or financial imtltuson for any rasoo; or 0) any Credit card check u retuned unpaid by us. Upon default, we have the right to close your Account, to terminate or ntlpmd Your cm& privileges under this Agreement to change the terms of yoke Account ad this Agreement, to require You to pay Yore mire Account balance including all accrued but unpaid charges immediately, and to use you for when you owe. U YOU do mot pay us, your Account balance will continue to accrue Finance Charges and fees until paid fn full and will remain subject to all the wrens and conditions of this Agreement. if we sue you, or if we hire a third piny to Collect your Account baWice, you will pay out taut Costs. reasonable to the tkf flser assets, , fees and other wllenio n easu aUrod permitted by law in the awe in which You reside. anW we will apply your payments fusi to miorneys' fees and other cats and then to principal ad unpaid Finance Charges. CREDIT AUTHORIZATIONS Sow Purchases require our prior authorization, and you my be asked by The oh sot to provide identification. If any pars of the svdwci=imn system is not waking, we may rot be able to authorize a tra ssacsion, even if you bave sufficient available crdit. We will not be liable to you if any of these evens happen. We arc = responsible fur she refusal of any merchant to accept or honor your Card. CARD RENEWAL Cards arc Issued with an expiration date. We have the rigku out o renew your Cod for any reason. ACCOUNT CLOSURE We may close yourAccount, suspend your credit privileges, or reduce your credit limit at any time and for my mom subject to de riWua mts of applicable law. In any of these evens, your Account balance will continue to scene Flnarrce Charges and tees until paid io full, and will remain subject to all the terms and conditions of this Agreement. If we close your Account you agree to destroy Your Card(s) and any unused credit card checks. If your Account has been closed. or your credit privileges are Suggiscadect you may not use your Card or credit card checks- CLOSING YOUR ACCOUNT You can called Of close your Account by writing to us en P.O. Box 80024 Salinas. CA 939124NDA ter,.,,,, ."...r .-._ . true and the amounts unaltered, You muy be liable fur kh: unauthorized use of your credit card. You will not be huts, for w"horized use dw1 Occurs after you notify, us of the loss, the, i or Possible Unauthorized use. Notification must be given by writing us immediately upon learning of the loss, theft or possible umulhorired use at P.O. Bos 80026, Salinas, CA 93912.0026 or Dy calling us at the telephone number listed on your billing aweam mt. You will not be host far any uuauthafzed use of your credt card Account when you a" us inmediaely m de phone number or sddress above. In soy case, Your liability for uttauthorfsed use of Your credit card will not exoxm 550. SECURITY We AN extending You an unsecured lint of credit. We therefore waive any security interest that mighl arise under this Agreement due to language in other loan agreemrus you may have with us. LOST OR STOLEN CREDIT CARD CHECKS You NIen to notify us immediately if any credit card checks are lost or stolen. You may notify us by cahng (888) 292.3629. CHANGE O NAME, ADDRESS, TELEPHONE NUMBER OR EMPLOYMENT You agree to give us prompt notice of any change in your name, mailing address, telepbone number or place of employnvent. STOP PAYMENT We may add a S29 fee to the cash advance balance each time payment of a credit cud check is stopped al your request. You may stop payment on a credit card check by notifying us in writing al P.O. Box 80026, Salinas, CA 93912-0026 or by calling us at the elepbmre number listed on the billing natement. When you write, include the number, payee, amount, and date of the credit card check on which psymerv Is to be stopped. If you call. YOU moat confirm the call In writing within U days. A written stop payment will remain in effect for six months unless renewed in writing. FOREIGN TRANSACTIONS FOR MASTERCARD•ACCOUNTS U you effect a tnamaactiai with your MasterCard card in a currency other than U.S. dollars, or effect it transaction in U.S. dollars outside the United Styes, MasterCard international Incorpaaled will convert the charge into a U.S. dollar amount. A currency conversion will occur even if the transaction is made in U.S. dollars. MasterCard Inserrwional will use its currency conversion procedure, which is disclosed o matins ions that issue MasterCard cards. Currently. the currency conversion rate used by MasterCard international to determine the transaction amount in U.S. dollars for such transactions is generally either a govermrenf-maa ndatcd rue or a wholesale rate determined by MasterCard International for the processing cycle in which the transaction is processed, incre" by an adjustment factor established from time to time b advances. Your total credit limit and cash advance limit may change from time to time. We will notify you of any such changes through your billing statement or by sending you a separate notice. If no separate cash advance limit is listed on your billing statement. then the amount of your credit limit available for cash advances is your total credit limit. You agree not to allow your unpad baance to exceed you total credit limit. Year unpaid balance incdsdes Finance Charges ad other charges. We are not required to extend credit if you have exceeded your toad credit limit or if the amount regIucined would cause you to exceed your total credit limit. If you exceed your total credit limit, you agree to pay us that excess amount immediately. Your total credit limit and cash advance limit may not reflect your payments for up to 14 days. PAYMENT Each statement you receive from us will identify a Minimum Paynaerll and a Current Payment Due. The Minimum Payment is calculated as follows: (t) If your New Balance is not more than $10. your Minimum Payment is the New Balance. (2) If your New Balance is more than $10, your Minimum Payment is the greater or, • 2% of the New Balance shown on your statement, or $10, or amount of periodic Finance Charges shown on your statement. (3) Any Lau Payment Fee or Ovedimit Fee will be added to the Minimum Payment calculated in (2). The Current Payment Due is the sum of: • your Minimum Payment, and • the greater of any amount pmt due. or any overiimh amount. An overlimit amount is the amount by which your New Balance exceeds your credit limit. Your Minimum Payment and Current Payment Due will be rounded up to the nearest dollar, mess doing so will cause the resulting value to exceed the New Balance. You must pay at least the Current Payment Due in time to be credited to your Account by the Payment Due Date, and failure to do so constitutes a default of this Agreement. If you do not pay at least the Minimum Payment and any amount past due in time to be credited to your Account by the Payment Due fate, you may he amessed a late payment fee. Instructions for making psymaras are on your billing statement. For a payment to be credited to you Account as of a particular day, we must receive your payment by the date and time and in the manner specified in those instructions. The Payment Due Date will be determined by us but is at least 20 days after the close of your billing cycle (the "Statement Dam"). You must pay any overlimit or put due amount immediately. You may pay more than the Current Payment Due and may pay the entire New Balwasm a my time. All payments must be in U.S. dollars. Except for disputed payments, if you pay by mail, the payment must be sent to the address specified on your billing statement. If you pay by negotiable insinunent, such as a money order or check, it man he in a form that is acceptable to us and must be drawn an a U.S. financial institution. Disputed payments, Including those narked "Payment Its Full" or otherwise restrictively endorsed, must be sent to the address for written Irquirles Muss m year s abomaL we can weep such paymens, and any that are late or partial, without waiving our rights under this Agrra- By sending su a check for payment on your Account, you andwrize su to iaitiat an electronic fads trader from yaw bank or other &-Kw Institution aceoun, accessing to the terms, of the check. This mean your chock will be converted to an electronic mauactea ad your aiginsl ehsk will na be reasons! to you by YOW bat Ytam erigeal check will be destroyed. U yeast do as want your cheeks to be converted to as deetresic funds bumhr, pease cis otpman apace at the 00" mondw on the b" of yasr card. Your checking or adult financial institution we-" may be ' ' ' , the same day we receive your Check. You may request a charge to your billing cycle date no atone than fuse a year. Yoar Wee No changes based on your request may tfloftern my Orasro Peiod you may have or incuu m the time period for which periodic Fbuuce Charger may seen*. APPLICATION OF PAYMENTS At our discretion, payments are gdsnaally applied in hue". fees and than principal Admces. we may apply yout, payment, to Iowa APR but 1 before bights APR balances. The application of paytraents Is subject to change a any time, without notice. ANNUAL PERCENTAGE RATES AND PERIODIC RATES FOR VARIABLE RATE ACCOUNTS The Daily Periodic Rate used a deermim your periodic Finance Charges will be a variable rate which may change. The Spread, Annual Percentage Rate ("APR"), Daily Periodic Rue, and minim- rate of Flamm Charge for the variable Customary APR for credit card purchases, balance transfers, arts cola advances made by credit card check, the variable Cash APR for cash advances, and the variable Default APR are indicated on the enclosed document entitled "Important Information Regarding Your Accoum." We coledae the APR by adding the Index to the applicable Spread (exp4foed on the enclosed document entitled "Important Information Regarding Your Account"). Different types of tramrtioos may have different APRs. The Daily Periodic Rae is the corresponding APR divided by 365. ANNUAL PERCENTAGE RATES AND PERIODIC RATES FOR FIXED RATE ACCOUNTS The Daily Periodic Rue used to determine your periodic Finance Charges wilt be a fixed rate. The Annual Percentage Rate ("APR") mdcorrespooding Daily Periodic Rate for the fixed Customary AMR for credit card purchases, balance unreels, and cash advances mote by as & cord check, the fixed Cult APR for cash advances, tad the fixed Default APR are Indicated on the enclosed document entitled "Importat Information Regarding Yam Account" Differam types of transactions may have diffuat APRs. The Doily Periodic Rate is the corresponding APR divided by 365. PROMOTIONAL RATE OFFERS At our discretion, we may offer you a Promotional Annual Parentage Rae for my type of transaction. The period of time for which the promotional rue applies may be limited. Certain promotional Offers may or may not be subject to Cash Advance Fees. Any Promwd-W me, the corresponding periodic rues, and the Period of lime during which it is in effect will be disclosed to You. Any pion wtload sae offer will be subject to the terms of the offer ad ads Agnaaamt. MINIMUM FINANCE CHARGE There will be a Minimum FINANCE CHARGE of SO_W for each billing cycle in which a periodic Finance Charlie is payable. Any SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC VS. Molly L. Robertson ??t?"t?* at ?urrrGr???hb OFF .C E _ -?RIFF OF i HELD 0(,tOFFICE r 2011 NOV 18 AM 10: 56 CUMBERLAND COUNTY PENNSYLti'Ah'IA Case Number 2011-8507 SHERIFF'S RETURN OF SERVICE 11/15/2011 09:21 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on November 15, 2011 at 2121 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Molly L. Robertson, by making known unto herself personally, at 2101 Mayfred Lane, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.00 November 16, 2011 DEN) S FRY, DE7 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySufte Sherff_ Te{eosoft . 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. MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL PA 17011 Defendant Date: No. 2011-8507 PRAECIPE FOR DEFAULT JUDGMENT rnm r to x• r ' C~- I%C. .. Filed on B a of Plaintiff Counsel Of re ord for this Pty 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 #11,.6o PA ATr%/ ??' 144a.?2o/H50a53 Nohee, fUaa-l?.?Q Tliis cornmunication is from a debt collector is an attempt to collect a debt. Any information obtained Nvill be used 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. 2011-8507 V. MOLLY R013ERTSON 2101 MAYFRED LN CAMP HILL PA 17011 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, MOLLY ROBERTSON , for failure to answer the Complaint. (X) Amount Due $815.20 Less Credits $.00 TOTAL $815.20 (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 judgmnn is o be entered and to his/her Attorney of record, if any, after the default occurred and at least tei da s prior to the datee filing of this praecipe and a copy of the notice is attached. Date: Robert N. Polas, Jr., Esquire # 2012 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 1'?his communication is frorn a debt collector is an attempt to collect a debt. Any information obtained will bt: used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 140 Corporate Boulevard Norfolk, VA 23502 Telephone: (866) 428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Friday 8 AM to 9 PM (EST) December 19, 2011 MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL PA 17011 11-13608 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. MOLLY ROBERTSON 2011-8507 Dear MOLLY ROBERTSON: 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 [ his communication is frt-w a debt c_olk-oor i?, ;m atiE:mpt debt. nv in iamiati€ n obtained tivill lit, u acd too IN, : p 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. 2011-8507 V. MOLLY R013ERTSON 2101 MAYFRED LN CAMP HILL PA 17011 Defendant TO: MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL PA 17011 DATE OF NOTICE: December 19, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff ? l?tg . €Tf11b7ktLC1(£?l$tt?lt ?S'C?il`d L7 t?C??t a?C)??C'?.1ttl to .1?i Fi?t?°SX!]?I 1C} Cs ??:'?`f 2l ??d??t. 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. 2011-8507 V. MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL. PA 17011 Defendant AFFIItMATION 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 2101 MAYFRED LN CAMP HILL 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. ?jl 1 Date: Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff 11-13608 This communication is a debt collector and is an aitenipt to collect a debt. An information obtained will be used for that purpose;. Department of Defense Manpower Data Center Feb-08-2012 14:58:39 Military Status Report 11-13608 Pursuant to the Service Members Civil Relief Act Last FirstiMiddle Begin Date Active Duty Status Active Duty End Date Service Name Agency ROBERTSON MOLLY 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, NOAA, Public Health, and Coast Guard). ,if 01,*4 - LW?- 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 any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/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 it was 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 memberwho 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 dutyfor 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:SHEU11TOC9 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. 2011-8507 V. MOLLY ROBERTSON 2101 MAYFRED LN CAMP HILL, 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 $815.20, plus interest, on. (X) A copy of all documents filed with the Prothonotary in I rt of the within judgment is/are attached *x ni A_ By: If you have any questions regarding this Notice, Date: Robert N. Polas, Jr., Esquire # 2012 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`liis communication is from a dent collector is an attempt to collect a debt. Ant information obtained will be ttse:d for that purpose. ?` ?,. .: