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HomeMy WebLinkAbout11-8843 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. 11-8843 CIVIL V. KIRK GITT 127 LONG RD APT 3 NEWVILLE PA 17241 PRAECIPE FOR DEFAULT Defendant JUDGMENT rn Z� C co yC> N ,.4 Filed on Behalf of Plaintiff Couns o record fort ' y Date: DEC 12 2013 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 11-17685 0 g" 001 p * a 3q s73 r C�)u mak This communication is from.a debt collector is an attempt to collect a debt. Any information obtained will be used for that pupose. 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. 11-8843 CIVIL V. KIRK GITT 127 LONG RD APT 3 NEWVILLE PA 17241 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,KIRK GITT ,for failure to answer the Complaint. (X) Amount Due $1,015.37 Less Credits $148.12 TOTAL $867.25 (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 judgment is to be entered and to his/her Attorney of record, if any,after the default occurred and at least ays prior t date of the filing of this praecipe and a copy of the notice is attached. 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 11-17685 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that puipose. 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. 11-8843 CIVIL V. KIRK GITT 127 LONG RD APT 3 NEWVILLE 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$867.25. (X)A copy of all documents filed with the Prothonotary in support of th ithin i dg en -are attached. By:---- — ---- If you have any questions regarding this Notice,please contac h filing party 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 11-17685 This communication is froin 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 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) November 1, 2013 KIRK GITT 127 LONG RD APT 3 NEWVILLE PA 17241 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. KIRK GITT 11-8843 CIVIL Dear KIRK GITT: 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 11-17685 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION—LAW PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff No. 11-8843 CIVIL V. KIRK GITT 127 LONG RD APT 3 NEWVILLE PA 17241 Defendant TO: KIRK GITT 127 LONG RD APT 3 NEWVILLE PA 17241 DATE OF NOTICE: November 1,2013 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 Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717) 249-3166 V� jf U 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 11-17685 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. 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. 11-8843 CIVIL V. KIRK GITT 127 LONG RD APT 3 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 127 LONG RD APT 3 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. 74 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)(866)428-8102 (F) (757) 518-0860 11-17685 Attorneys for Plaintiff This coinniunication is a debt collector and is an attempt to collect a debt. Any information obtaiiaed will be used for that purpose. • Results as of:Nov-04-2013 02:32:23 SCRA 3.0 Status Rq)ort Pursuant to S ervicernemlers CiW Relief Act Last Name: GITT First Name: KIRK Middle Name: Active Duty Status As Of: Nov-04-20.13 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duly status within 367 days preceding the Active.Duty Status Date The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or hWher unit has received early notification to report for active duty Upon searching 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 his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 11-17685 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 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 at 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 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 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:/Avww.defenselink.mil/faq/pis/PC09SLDR.html, 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 USG 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 3 67 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. All 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(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 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 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: R5BAE737U012VB0