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HomeMy WebLinkAbout12-0261IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC. 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. AMBER GOSHORN 288 MEADOWS RD NEWVILLE PA 17241 Date: Defendant No. 12-261 CIVIL TERM :-) h -, Fn Uj Fri 7-" 1:71 PRAECIPE FOR DEFAULT r- _ , JUDGMENT `-=:- C? ?s t- :n C) CD Filed oehalf of Plaintiff Couns 1 f record for this ParO L -? l rJ ?/ 6 ??? 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 a?.sllo.5d?d I/ H ?42-Jf 1,5 79 W i0 USa3 ]"his communicatioll is from a debt collector is an attempt to collect a debt. A11 infomation obtained will be used i?or that puil)ose, c77357& 66'b4'? mxw 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. 12-261 CIVIL TERM V. AMBER GOSHORN 288 MEADOWS RD NEWVILLE PA 17241 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, AMBER GOSHORN , for failure to answer the Complaint. (X) Amount Due $1,087.37 Less Credits $.00 TOTAL $1,087.37 (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 judgme is to be entered and s/her Attorney of record, if any, after the default occurred and at least en ays prior to the date 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 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff l`his c.orninu ication is from it debt collector is an attempt to collect a debt. 11 information obtained will be u, ced f?fir that purpose, 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. AMBER GOSHORN 288 MEADOWS RD NEWVILLE PA 17241 Defendant No. 12-261 CIVIL TERM 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 $1,087.37, plus interest, on . (X) A copy of all documents filed with the Prothonotary in support of the?ithin i"Mhen is attached. By: 1?1 000, If you have any questions regarding this Notice, please co ct the filing part, Date: Vito / 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 1` is coin inLmicati€ n is ftom a debt collector is an attempt to collect <t debt, kny intbrynation € btained \? ill b uA,ed for that purp€ sc?. 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. 12-261 CIVIL TERM V. AMBER GOSHORN 288 MEADOWS RD NEWVILLE PA 17241 Defendant TO: AMBER GOSHORN 288 MEADOWS RD NEWVILLE PA 17241 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 ,?st a QAccx,) `X- 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 information 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. 12-261 CIVIL TERM V. AMBER GOSHORN 288 MEADOWS 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 288 MEADOWS 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. r` 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 11-16748 "l lai` C011 ID1 Lill i(',It i0l] is a debi collector and is gar) attempt to collect debt. \Il information o Nailic:d will be Utic.cl #01 tlaW Pa.aal?OSc:. Department of Defense Manpaoer Data Center Mar-14-2012 17:28:59 e-1) Mlitary Status Report 11-16748 Pursuant to the Service Members Qvil Relief Ad SeIrvice Name FffWNldde Begin DOM Active DLty Adtve Duly End Date Agancy GOSHCRN ANUEER Based on the infomration you have furnished, the C DC does not possess any inforrnation indicating the individual status. Upon seardfing thte inborn anion data barks ofthe D6paltirro t of Defense Ma pomier Data Center, based on ft inliorrratio n that you pnomded, the atom a Is thre c Trent sta it of the inndim dral as to oil branches of the Unfomhed SeMces V",, Na, rvManna Corps, Air Force, NOAA, Public Fled% and Coast Chard). 4121 14- "if Ott 4 - - Mary M. Shavely-D>cn, Director Department of Defense - Manpaner Data Center 1600 VVlson Elvd., Suite 400 Arlington, VA22209-2593 The Deferm Ma pol&w Dena Carter (DM OQ is an orgari2ation of ft Departrnert of Deform that rrlaintains; the Deform Errokrot and Eligibility Reporting Soem (DEERS) database which is the oficia l source of data an eligibility for rriitary rn ical care and other efgbilitysysters. The DoD strongly supports the enforcerrsrt ofthhe Service Mangers Chvhl ReiefAd (50 USC App. §§ 501 et seq as arnend" (SCRA) (formterly la otnn as the Solders and Sailors' Ciul ReiefAct of 1940). DMDC has issued hundreds oftihol sands of "does not possess any information indicating that the indlvidal is currently on active dfy+' responses, and hats operienced a smell error rate. In the evert the individual referenced above, or any family nu ber, friend, or representative asserts in any muner that the irndvidaal is on active duty, or is otherwise entitled to the protections of the SCRP\ you are strohgy encouraged to obtain further verification ofthe persons -bh by contacting #iE t persons Service via the "defanseh rtk mill" URL . Fyou hm a evnderce the person is on active duty and you fail to obtain this additional Service verification, punitive prohAsionls of the SCPA, n13y be mudded against you. See 50 USC App. §521(c). Ifyou obtain addbohal informtetion about the person (e.g., an SSN, improved accuracy of DOB, a middle nrarre), you can submit you request again at this Wab site and we will preside a new certificate for that query. This response rellecs active cltly Aalus including date the irtdvidial was last on active dfy, if it was within the precedng 367 days. For historical inlic rnation, piease contact the Service SCRAparts-of-contact. hbreIrnlbwmfi nan'Aa'"DulyS7aCt?s" Active d ty stabs as repartsd in this eerbicde is defined in aeoord m with 10 USC § 101(d)(1) lbr a period of more than 30 consecutive days. h the case of a member ofthhe National [Bard, includes service under a cal to active service authorized bythe President or the Secretary of Deform for a period of more than 30 corsecLM a days under 32 USC §502(0 for purposes of responding to a national emergency declared hythhe President and supported by Federal bids. AN Active Guard Resenu9 (ACF7j mternbers must be assigned against an a uft iz ed mobilization position in the unit they support. This includes Navy TARS, Marine Caps ARs and Coast Gus rd RPAs_ Achve Defy stab also applies to a Un forn ed Samoa mterrber who ism active duty commissioned dicer ofthhe U.S. Public Health Semce or the National Ooeanic andA6nosphencAdrriinistration (NCPA Corr issioned Corps) for a period of rnore than 30 consec the days. CauerW Lutnafrrdie SCRA is filmmbray Sams Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes ofthe SCRA who world riot be reported as on Active Duty under this certificate. Mary times orders are amended to eoAend the period of active duty, which wand extend SCRA protections. Persons seeldng to rely on this website certificati on should check to nroke sure the orders on which SCRA protecti ons are based have not been amended to e, tentd the inclume dates of service. Furtherrme, sore protections of the SCRA may a 4and to persons who, home roomed orders to repot for active duty or to be indicted, but who have not actually begun active duty or actually reported for induc hon. The Last Date on A ve Duty entry is irrpodart because a rarrhoer of protections of SCR A extend beyond the last dates of active duty. Those who world rely on t his certi ficate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected- VVW 4G This certificate was provided based on a nnam9 and SSN provided by the requester. Providing an erroneous narrie or SSN wil cause an erroneous certificate to be provided- Report I1):SNA48WBM ;()IttWUI)sc°ation i, al debt collector and is an attempt to collect a c:lcht. t'Ornualim oNxined will bC Used for that purpo?c. Department of Defense Manpower Data Center Mar-16-2012 16:02:38 Military Status Report 11-16748 Pursuant to the Service Members Civil Relief Act Last FirstiMiddle Begin Date Active Duty Status Active Duty End Date Service Name Agency GOSHORN AMBER 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). 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:i/www.defenselink.mil/fag/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 itwas 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:A9619FHF49