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HomeMy WebLinkAbout12-0264IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 12-264 CIVIL TERM V. KATHY CESSNA 102 S ORANGE ST CARLISLE PA 17013 PRAECIPE FOR DEFAULT Defendant JUDGMENT U, r g r r- = -4 C:' <CD CD Filed on Behalf of Plaintiff >;z .y, Coun of record for this art t CD - 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 atuf '? l4. So?? a,? Mi8 ?m..r # m-'atiojl i4 ftom a debt collector is are a:zttcmpt to collect a d6t 16111;!ra& env int"ormation obtained will. be u?cd f"or that pffl-POSC. Q#?7, 7.5 OWlcci(a(?( 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. 12-264 CIVIL TERM V. KATHY CESSNA 102 S ORANGE ST CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, KATHY CESSNA , for failure to answer the Complaint. (X) Amount Due $1,560.47 Less Credits $.00 TOTAL $1,560.47 (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 judgme .s to be entered and to er Attorney of record, if any, after the default occurred and at least n ys prior to the date of the 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"leis communication is from a debt collector's are attempt to cc}llc:c, a clc lit, Any iTIformation obtained will be used li)r 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. KATHY CESSNA 102 S ORANGE ST CARLISLE PA 17013 Defendant No. 12-264 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 $1,560.47, plus interest, on . (X) A copy of all documents filed with the Prothonotar B If you have any questions regarding this Notice, please Date: Robert N. Polas, Jr., Esquire # 20125 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 i`hi ; communication is from a debt cc-,Ilec°tor ss an attempt io collect a cleft. t? informatioj obtained ?, ill he uc'Zcd c?r that fsug)ose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 ASSOCIATES, LLC No. 12-264 CIVIL TERM Plaintiff V. KATHY CESSNA 102 S ORANGE ST CARLISLE PA 17013 Defendant TO: KATHY CESSNA 102 S ORANGE ST 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 Pg2&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 infonnation obtained n7ll 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. 12-264 CIVIL TERM V. KATHY CESSNA 102 S ORANGE ST CARLISLE PA 17013 Defendant AFFHZMATION 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 102 S ORANGE ST 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. Date: i 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 11-16737 11: unication is la debt col Iector and is are at1'('1iw ?11e(1-t a debt. )r nation ob mned. will bC Wwd for that purpose. Department of Defense Manpcsner Data Center Mtar-14-2012 17:28:53 IOPM%IL U01-2 Military Status Report 11-16737 R.rsuant to the Service Merrbers Ovil Relief Act N? FirsMVkidle Begin 13968 ACdW Duty Sh&n Active Duly End Dde Service Againcy CES A KATHY Based on the information you have furnished, the DM7C does not possess any information indicating the individual status. Upon searching the intiomalion data banks oftlte Depatrnatt of Debase Manixm r Data Center, based on the information that you provided, the above is the crrentshahs ofthe indimcllal as to all bytes ofthe lkifomed Services (Pony, Navy, Marine Caps, Air Farce, NOAA Public Flealth, and Coast Guar . ot, Mary M. Snavely-D6cn, Director Department of Defense - Manpaner Data Center 1600 Wlson Bvd., Suite 400 Alington, VA22209-2593 The Defense Merlpower Data Center (DMDQ is an orgammbon ofthe Departrrat of Defense that maintains the Detiense Firolirriert and Eligibility Reporting Syntem (DEERS) database % ich is the official source of data on eligibility for rriitiery medical care and other eligibility systerrs- The DoD strongly stppa is the ertiorcmiert ofthe Service Members Civil Ref efiAct (50 USC App. §§501 et seq as ar nerik" (SCR A) (farrEdy lauuat as the Solders' and Sailors' Civil ReiefAct of 1940). DMDC has issued hrtcteds off usards of "does not possess any inibrn on iruicating that the indviclual is arrently on active duty' responses, and has experienced a srtal error rate. In the evert the individual referenced above, or any larn y marrber, fiend, or reprreser Ab%e asserts in ary merrier titet the individual is on active duty, or is othemse entitled to the proteclionts oftite SCPA you are strongly encouraged to obtain Bihar veriiceben ofthte persais Status by cmtac ing #vt persons Service via the "defasdriknir URL . Ifyou have emdentoe the person ism active dty aid you fail to obtain this additional Service veriication, puribw provisions of the SCRA maybe irwdead against you. See 50 USC App. §5210. Ifyou obtain additional information about the person (e.g., an SSN, inproved accuracy of DOB, a middle nacre), you can submt your reguast again at this Vlbb site and we wit provide a neunr ceuiifi date for that query. Th1is response retleds active dL y dzhn inducing date the individml vMas last on active duly, if it was within the preceding 367 days. Far historical inlion i oR please eonttad ft Service SCRA points-of eonttad. Nbm kmftm=Vbnan 'Actifve DlunyS9stus" A[five city siaha as reported in this oertiicate is clef rued in accordance with 10 USC § 101(cn(1) for a period of more than 30 corseca6ve days. h the case of a m ar ber ofU'te National Guard, includes service under a cal to ac tiw sarvioe aulhon2ecl bythe President or the Secretary of Deform for a period of more than 30 eorseative days under 32 USC § 502(13 for purposes of responxing to a national emergency declared bythe President and supported by Federal funds. Ad Active Card Resew (AC,Rj members n 6t be assigned agmrist an aLMmzed n mbiizabon position in the tilt they a.pport. This irtdu d Navy TARS Marine Caps ARs and Coast Guard RPAs. Active Dotty stalls also applies to a Uri formed Service member who is an adne duty eorrmssoned dicer ofthe U.S. Public Fleaih Service or the Natiorml Oceania and Ailnosphenc Acirtinsh-eh n (NCA A Ck rrmssionted Caps) for a period of more that 30 consecutive days- Covwnw Lkxbrtbe SCRA iS B ONftW I r Same Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active city for purposes ofthe SCRA who %wxld not be reported as on Active Duty under this certificate. May timtes orders are amended to ekend the period of active duty, whch world ekend SCRA protections. Persons seelang to rely on this website certiicati on should check to make sure the orders on whidt SCRA pretetbors are based have riot been amatded to extend the inclusive dates of service. FurtherrmeQ some prdectiors of the SCRA mtay etend to persons who have received orders to report for active city or to be inducted but who have not adualty, begin active duty or actually reported for induction. The Last Date on Active Duty entryis inportart because a rurrtoer of protections of SCRA edertd beyond tits last dates of active duty. Those Who world rely on this eertif cafe are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are proteded- VY RIVN A This oenti ficate vas presided based on a name and SSN presided by the requester. Prcmdng an erroneous name or SSN Will cause an erroneous oertif cafe to be provided. Report ba LD1HEEPVNB I'ili, I.°.-..1tioll i,? a debt collector and is its rf, 1,a, to collect a debt, eta :HO ion obt,nnecl will bC LJScd ,1*01 111W purp ::?. Department of Defense Manpower Data Center Mar-16-2012 16:02:33 Military Status Report W 11-16737 Pursuant to the Service Members Civil Relief Act -< Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Name Agency CESSNA KATHY 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, NOAH, Public Health, and Coast Guard). Aot t4- &16? 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 mannerthat 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:llwww.defenselink.millfag/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 submityour 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:QDAB1196NO