Loading...
HomeMy WebLinkAbout12-0258 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. MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 Defendant --- 1A l ? , Date: No. 12-258 PRAECIPE FOR DEFAULT JUDGMENT C'_wl Fi 7-1 C) .,.y c:-_ .. , Filed gni3ehalf of Plaintiff ?r Cou sel f record for this P?rty s? o 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 onkt " /6. Wpd a4l I s7a ?o ? 4> 1 LOW S aa. ?Wa-7 3S?o l`l is comiximlicatlon zs from a debt colleclor' An' infc+ m Ition obtained N ill t ;:? i ; _i ' )r th it ptjxjlo NrAa' N ud- 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. 12-258 V. MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, MARCIA A BITNER , for failure to answer the Complaint. (X) Amount Due $1,163.58 Less Credits $266.00 TOTAL $897.58 (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 judg t is to be entered an "is/her Attorney of record, if any, after the default occurred and at le t to days prior to the too the filing of this praecipe and a copy of the notice is attached. f Date: r-- 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 Hii?, coin munication is from a debt collector is an attempt to collec' , - 1 fiormation obtained \, ill be used f?)r that purpose, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVEL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 12-258 V. MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 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 $897.58, plus interest, on. (X) A copy of all documents filed with the Prothonotary in support of the jithin ju^ent isJ4 attached. By: If you have any questions regarding this Notice, please co c the filing party. 11 d'' Date: o f Robert N. Polas, Jr., Esquire # 201259 / Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff l hi< comII uni Cation is ftom a debt collec;tc r i? 1111 attempt to (lc°?= ?i dcbt.. t? inforrnati011 obtained ??-i11 l.ic used fctr That ? 3 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. 12-258 V. MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 Defendant TO: MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 DATE OF NOTICE: February 27, 2012 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 This communication is from a debt collector is an attempt to collect a debt. Any infonnation obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATE, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. 12-258 V. MARCIA A BITNER 2157 NEWVILLE RD CARLISLE PA 17013 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 2157 NEWVILLE RD CARLISLE PA 17013 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. k 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 11-15059 This {.t,btriiiasiclicaatiotI ai debt collector and is an :attemrlt it) collect as (lc°ht. Ai)\ infornoion obt r. tl will be ci?cxd for that purpose. Department of Defense Manpower Data Center Mar-14-2012 17:27:42 Military Status Report 11-15059 Pursuart to the Service Merrbers Qvil Relief Ad FW Middle Begin DOD Active Duty his Adfve Dulty End Date serVi y Ust No" Agen BITNER Mo AA Based on the info r abon you have furnished, the DNDC does not possess any information indicating the individual status. Upon warding the in fion s on data bands of the Departnar t of Deform Nlanpmw Data Carter, based on the inbrnationr that you provided, the above isthe current Stati S ofihe indMdlal asto aN brarchgs ofthe Urifdnrned Sermoes (Arrry, Navy, Marine Carps, Air Force, N(AA? Public F-IeaK4 and Good Gard). MaryM Snavely-Dim, Director Department of Defense - Manpmer Data Center 1600 VV son Blvd., Suite 400 Arlington, VA22209-2593 The Defense Manpaner Data Center (DMDC) is an organization ofthe Departrnert of Defense that nrlairtarnns the Defense Errdlrnert and Eligibility Reporting System (DEERS) dahaba9e wtidh is the official scree of data on eligibility for rriitary medical care and other efigbiity systems. The DoD &ongfyf supports the enforcement ofthe Service HAwrbers Cavil ReiefAct(50 USC App- §§5M et seq as anmrrdE" (SCRA) (fomherly knDm as the Sdders and Sailors' Cavil RefefAct of 194Q)- DRiDC has issued hundreds ofthousandsof"does not possess any infonrration inundating that the individual is c rrerily on active city' responses, and has aperienced a small error rate. In the overt the individual referenced above, or any famly men t)er, friend, or represertative asserts in any rrt?rrer that the irxividiml is on active duty, or is othe wse entitled to the protections othhe SCRA\ you are strongly encouraged to obtain irther verification ottee persorfs slabs by eortadngthat persorfs SaMoeviathe "deferseiric-mr UFO - . Ifyou have Wdence the person is on active duty and you fail to obtain this additional Service verification, pu bw provisions of the SCRA may be it m*ed against you. See 50 USC App- §521(c)- If you obtain additional inllbl i . on about the person (e.g., an SSN, improved accuracy of DOB, a middle rnarrne), you can scbrrit your request again at this Wald site arld wue W N preside a new certificate for that query. This response refieds active d Iy abirm including dilate the irdmduEd was last on active city, if it was within tha preceding 367 days. Far historical infarrcrt please eoniadthe Service SCRApoirts-of-oortact- hbmD ilrtbmsdfort an `Activve Duly Sous" Active dry stah s as reported in this certificate is deined in accordance with 10 USC § 101(dx1) for a period of more than 30 camafi+e days. In the case of a rnerrber ottee National Gard, includes service under a caN to active service authorized bythe Presdent or the SeQehory of Deform for a period of more than 30 corsealive days under 32 USC § 502(Q for purposes of responding to a national emergerrydeclared bythe President and supported by Federal ands. AA Active Gard Reserve (AGF? rnarrtiers must be assigned against an authorized mobilization postion in the urit they support. This includes Nervy TARS Marine Carps ARs and Coast Gard RPA& Active Duly static also applies to a Uniformed Service rnenrber who is an active dty eorrrriis9oned otieer othhe U.S- Putnic Fieallh Service or the National Oceanic and AUnosph eric Acrnnistration (NC1AA ConT ssongd Carps) for a period of more than 30 cormoutive days- Coot WqW Umbrdie SCRA fie MandW In Sane Cages Coverage under the SCRA is broader in some cases and includes some categxies of persons on active dry for purposes of the SCRA Who wAxid not be reported as on Active Qty under this eertificate- M ry times orders are aman ded to ederid the period of active day, whc h would eDdend SCRA protections. Persons seeking to rely on this website eertilcation should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service- Futherrrnre, sorre prdecicrs of ft SCRA matt eDdend to persons who have received orders to report for active duty or to be included, but who have not actually begs adiive day or el b reported for induction. The Last Date on Active Duty entry is i n porlart because a r n'ber of protections of SC edend beyond the last dates of active duty. Those who world rely on this certificate are urged to seek qualified legal co reel to erEue that al rights guaranteed to Service nwrbers under the SCRA are protected. VIW7NIG This certificate was presided based on a nacre and SSN provided bythe requester. Pmmdng an erroneous name or SSN wii dace an erroneous certificate to be promded. Report K):FROS27FCBK 1 Pi `? a debt c.c)9lect-I, and i5 an rr1?t W collect a debt_ -n ained w i 11 b, u,- or thi? '10 Department of Defense Manpower Data Center Mar-16-2012 16:00:57 MW 14 Military Status Report 11-15059 Pursuant to the Service Members Civil Relief Act W-1 -< Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Name Agency BITNER MARCIA A Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Ott 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/fag//pislPC09SLDR.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 contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:UPF94ED666