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Home My WebLink About12-2902Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 B ;J Attorneys for Plaintiff' ie 0 0 (; ' " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 Defendant NOTICE No. d-- agOP 0, 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. s aM}9103.1S?Zl ?j ? i7as3? Robert N. Polas, Jr., Esquire PA Bar # 201259 Carne 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. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 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 CONSEGUIIZ 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 COnIhILInication is firoin a debt collector any is a€i auenipt to collect a .debt. r tiN inforinaticm obtained N,01 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. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant MARY MARTIN STETS, is an adult individual with last known address of 15 ETTER RD, NEWBURG PA 17240. 3. It is averred that Defendant was indebted to GE MONEY BANK F.S.B. / WAIL-MART on September 1, 1988 with account number ************6018 (hereafter referred to as "Account") A copy of the account history is attached here to and collectively marked 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 cornanunieation is frorn a debt collector and is an attempt to collect a debt. Any inforination obtained x ill be used for thal purpose. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned 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 January 11, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK F.S.B. / WAL-MART 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 $3,025.07. 10. 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 detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, MARY MARTIN STETS, in the amount of $3,025.07, plus costs of this action and any other relief as the Court deems just and as able. Robert N. Polas Jr., Esquire # 201254'""-- Carrie A. Brown, Esquire # 94055 11-65015 This communication is ?Fiorn a debt collector and is an attempt to collect a debt. :any information obtained x ill be used for that purpose.. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mary L. Moore 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 by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date : APR 16 2012 _ B )A?t,L- Moore Custodian of Records 11-65015 This communication is from a debt collect6r and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************6018 MARY MARTIN STETS Account Holder: MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 Consumer Account Product Code: PVT Issuer: GE MONEY BANK F.S.B. / WAL-MART Assignee: Portfolio Recovery Associates, LLC Account Number: ***`*********6018 Date Account Opened: September 1, 1988 Date of Last Payment: January 11, 2010 Date of Charge Off: August 19, 2010 Balance at Purchase: $3,025.07 Purchase Date: June 30, 2011 Balance at Charge-Off: $3,025.07 Less Payments: $.00 Balance Due: $3,025.07 11-65015 GECL51 This communication is from a collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, _ Mary L. Moore , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 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 GE MONEY BANK F.S.B. / WAL-MART ("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 June 30, 2011. 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 MARY MARTIN STETS ("Debtor") to the Account Seller the sum of $3,025.07 with the respect to account number (************6018), as of August 19, 2010 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 $3,025.07 as due and owing as of the date of this affidavit. folio Recovery Associates, LLC ?) 6"A-6? By: _ Mary Dore:e , Custodian of Records Subscri nd sworn t re me on Notary POW 11-65015 APRJ G 2012 , 2012 Erin L. Carr Commonwealth of Virginia Notary Public Commission No.7509898 70311 015 My Commission ExP This communieation is front a debt collector and is an attempt to collect a debt. < ??? in1orniai._ion obtained will be used for that purpose. Walmart® Credit Card Summary of Account Activity Previous Balance - Other Credits New Balance Credit Limit Available Credit Cash Advance/Quick Cash Limit Available Cash Statement Closing Date Days in Billing Cycle MARY MARTIN STETS Visit us at walmartcomkredit Account Number: ? 6018 Customer Service: 1-800-641-4526 $3,025.07 $3,025.07 $2,650 $0.00 $200 $0.00 08/19/2010 28 Payment Information New Balance $0.00 Minimum Payment This Period $790.00 Amount Past Due $0.00 Total Minimum Payment Due $790.00 Payment Due Date 08/22/2010 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to 535.00. Tran Post Dale Date Reference Number Description of Transaction or Credit Amount 08/19 08/19 F9112DDKPD09NGW CHARGE OFF ACCOUNT-PRINCIPALS ($2,418.99) 08119 D8/19 F9112DDKP009%990 CHARGE OFF ACCOUNT 'FINANCE ($606.08) CHARGES' FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED O8/19 08/19 INTEREST CHARGE ON PURCHASES $0.D0 08/19 08/19 INTEREST CHARGE ON CASH ADVANCES $0.D0 TOTAL INTEREST FOR THIS PERIOD $0.00 2010 Totals Year-To-Date Total Fees Charged in 2010 $0.00 Total Interest Charged in 2010 $135.54 Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual interest rate on your account. Type of Balance Expiration Annual Percentage Portion of Balance Balance Subject to Interest Balance Date Rate Assessed This Rate Interest Rate Charge Method Current Transactions Regular Purchases & WA 29.90% Entire $0.00 $0.D0 2D Cash Advances Transactions on or before 0 3/0 712 01 0 Regular Purchases N/A 29.90% Entire $0.00 $0.00 2D Cardholder News and Information The year to date information shown on this statement reflects a partial year, starting from the time the information first appeared on your billing statement. PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE. NOTICE We may convert your payment into an electronic debit. See reverse for details, Billing Rights and other important information. 5404 90H 1 5 19 100819 Z X PAGE 1 of 1 9112 7400 FS00 OICQ5404 Detach and mail this portion with your check. Do not include any correspondence with your check. -? Account ce Walmart or" A, Total Mini Amount Payment Due Num1 Overlimtl New ? Balance mum Save more): Live better. Payment Due Past Due Date Amount $790.00 $0.00 08/22/2010 $0.00 $0.00 Payment Enclosed: ? ? ? ? ? . ? ? ill 011111¦I11I1M1J`11 III I, se blue or black ink. New address or email? Print changes on back. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 1724069134 Make Payment To: WALMART/GEMS P.O. BOX 530927 ATLANTA, GA 30353-0927 0 GE Money Bank BILL of SALE PRA 120-day Mid Prime - June 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement'), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC (`Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on June 19, 2011, and as further described in the Agreement. GE Money Bank By: '-- Title: CFO Retailer Cred' Services Inc By: Title: President General Electric Capital Corporation By: Title: Vice President GEC 451 /of 9 0 BILL of SALE PRA 120-day Mid Prime - June 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December. 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"'), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on June 19, 2011, and as further described in the Agreement. GE Money Bank By: Title: CFO Retailer Credit Services Inc By: Title: President General Electric Cap By: Title: Vic Presi ent GE Money Bank Corporation GEC45/ zot Z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith - f, Chief Deputy s Richard W Stewart Solicitor Portfolio Recovery Associates, LLC Case Number vs. Mary Martin Stets 2012-2902 SHERIFF'S RETURN OF SERVICE 06/04/2012 01:07 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 4, 2012 at 1307 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mary Martin Stets, by making known unto herself personally, at 15 Etter Road, Newburg Cumberland County, Pennsylvania 17240 its contents and at the same time handing to her personally the said true and correct copy of the same. SHA , SHERIFF COST: $88.00 June 06, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shenff, Teleosaft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff v. MARY IvIARTIN STETS 15 ETTER RD NEWBtJRG PA 17240 Defendant Date: No. 12-2902 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf of Plaintiff Counsel of record for this P :~ C ~-~ ~ ~- .'i. r"' ~ ~ ~ ~ ~ ~ r ~~ ~ csf~-' 3> -' ~ ~ ~~.. . ~~ -o ~Q ~ oc~ ~~ P~ ~s~' -~ ~" Robert N. Polar, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 'I'bis communication is from a debt collector is an attempt to collect a debt. Any information obtained. will he used i'or that l~ulpose. Q~+dr 's~~ p~ l` ~° u IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff No. 12-2902 CIVIL v. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, MARY MARTIN STETS ,for failure to answer the Complaint. (X) Amount Due $3,025.07 Less Credits $.00 TOTAL $3,025.07 (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 Finat 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, Icertify 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 r Attorney of record, if any, after the default occurred and at least to ys prior to the dot f t filing of this praecipe and a copy of the notice is attached. " Date: U Robert N. Polas, Jr., Esquire # 201259 `' Carne A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communicatiarl is front a debt collector is an attempt to collect a debt. Any infc~rlnation obtained will be used for that }xupose. 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. 12-2902 CIVIL v. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 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 $3,025.07, plus interest, on . 1 A ~~ (X) A copy of all documents filed with the Prothonotary in support of the in judkm t i attached. r By• ----- ---- If you have any questions regarding this Notice, please cont t filing party. Date: 1 ~ l ~' Robert N. Polas, Jr., Esquire # 2012 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This eammunication is from. a debt collector is an attempt to collect a debt. Any uzfonnation obtained will. be 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 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) June 28, 2012 MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 11-65015 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. MARY MARTIN STETS 12-2902 CIVIL Dear MARY MARTIN STETS: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Robert N. Pales, Sr., Esquire Came A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff f~, '~~` This communication is fiY~m a debt collector is nn attempt to collect a debt. Any ini'i~tmation abtriined will be E~secl for that purpose. 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. 12-2902 CNII. v. MARY MARTIN STETS I S ETTER RD NEWBURG PA 17240 Defendant T0: MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 DATE OF NOTICE: June 28, 2012 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTt'H 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 MAYBE 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. 1F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIltING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WTTH 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 Cazlisle, PA 17013 (717) 249-316b 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 Tltis contnwnication is ti~om a debt c~~ll~^ctor is ;tn attempt to collect a debt. Any information obtained will lie ued for that purpc-se. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 No. 12-2902 CIVIL Plaintiff v. MARY MARTIN STETS 15 ETTER RD NEWBURG PA 17240 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 15 ETTER RD NEWBURG PA 17240 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: 11-65015 ~~v ~, Robert N. Polas, Jr., Esquire, #201259 ~--~'~ Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is a. debt collector alzd is an attempt to collect a debt. Any infornation obtained ti4rill be used for that purpose. Department of Defense Manpower Data Center ~ptbtle Rt~plo~ Rusn~t #+a 3tw~cem~cmbe~ G~vi1 Reliief Act test Name: MARTIN STETS First Name: MARY Active Duty Status As Of: Jul-23-2012 ~tswna esa : ai-23~2or2 04:~ s~ ~: ,~ 13 NA NA NO NA TM~ fMp01W f rns tdsidwis' ~GiN ~ sWw God m tln Ariiw QAY'$Mi Gals .~ ~ '.C'. ~'~ I i.A~ - ~~L,~ NA NA No NA TMs nsponN ro6sclt wfMr! M YidlHduY INF se.~w duly tCi4nt MiMiIM1 367 drys p1~OShcrp UIU Ik'W~ OtMY S{~fW1 Dslr I ru ~ Na I No ~ r~ I I I T1ty ro+vwN. MscM whMMr tM ridYldwl «MMhw wMl Mw nuMd wy nalpla6an w rport br uYrt• dWr I I Upon saarcdring the data banks of des DspartmeM of Os(arns Manporwr Oars Center. based on the ~forrnation that You provided, the above is the of the individual on the adhro duty statue dste ~ to aM branches al the UrriForrned Ssrvkxs (Army Navy, Marini C«ps, Ak Ftxee, NOM.. PtrbMc Fieettl6 Coast twsrd). This status k-cludes irT6orma6on on a Servicenrsrnberor ttislher unit receiving notlBcatbn of fiduro orders io report for AcdW Duty. Mary M. Shovely-Dixon, Directs Department of Defense - AiNr-power Data Garner 4p8~00 Mark Cerrter Drive. SuNs 04E25 rl,~g2350 The Defense Manpower Data Center (DMDC) is an orgartization of tlrs Department of Defense (DoD) that: mafntaNx the Defense Enrdtrrrent and RePortin9 System {DEERS} database which is the oRkisl source pf c~ta on eNgitriNty for mNittxy medical taro and other eNgibNily systems. The DoD stmngiy supports the enforcerrrerrt d ihs Servk~members CtvN Ftelfei Act (50 USC App. §501 et seq. as amended) {SCRA) (farrtrsAy kno+am a the 5oidisrs' end Saibrs' CivN RsNsf Ad of 194U} DMDC has issued hundred of thousands of "does not possess any information 9 that the individual ~ errantly an active dultl' responses, and has axperienasd only a ameN error rats. ~ the event the individual relererrced abgw, a any famNy member. friend, a repnterrtetive asserts ~ any mervror Drat the irMividuel w~ on active duty for the adiw duly s1~ date. or is otlter~wise errtltlsd to ti prolecdor-s of the SCRA. You are atrongy er~cotragsd to obtain firtlrer ver9Rcatlon of the person`s s~rtus by contacting that person's Service via the "defenseNnk.rnN" URL; hqp:l/www.delensslirdt.miUfaypislPC09SlDR.hdN. if you hm evidence the person vva on active dory for #re Iwtive drMy st~us data and you fail to obtain flea addifbtrel Service verilicstlon. punNive provisions of the SCRA may bs inrrolrad against you. See 50 USC App. §521 {c). This response reflects the foNowing informatlon: {1) The urdivldual'a Adhrs Duty status on the Alive Duty Statue date {2) Whstlrx the individual left Acti+ Duty sbous witlim 367 days preceding the Active Oury 3taha Date (3} WhMher fM indvdual a tddtrer unit received early notification b report for active duty on tits Active Duty Stakrs Date. Mare information on 'Active Duty Status" Active duly statue a8 reported in tltis artit4cate ie defined br acoadana- with 10 USC § 101(d) {1). Prior to 2010 only sane of the acNivp duty periods k tfron 30 carsewdve days sr largri+ were available. In tiro cross of a member of the Natlond Guard, tlrls hdudee service under a caN to',acdve sarvke autiroriad by fhs President or the Secretary of De~(ense undo 3Z USC §502{!) for purposes of responding to a national .nrors.nry degerod by the Presidarrt and auppaNd by Federal funds. AN Active Guard Reserve {AG1t) members rrxnt be assipred against an authorized nroblNZptlan posNfon M unit itroy support. Thfa indudes Navy Troinirp and Administration of the Reserves {TARa), MerMro Cape Actifve Reserve (Arts) and Cgest t3uard Rese Program Admhri~rabr (RPAs). Adbe Duiy stetwr also appNes to a Ikiifamrod Service member who b an actlw duty commiasfarsd olalar of the U.B. Public FlsaNh Service or the National Orroanic and Atrnoephsric AdmlMstratlan (NOM Commisafoned Caps). Coverage Under the SCRA is Broader in Some Cases coverage under the sCRA is broader h some cases err! irrcAudee some catsgoriss of persons on actlw duty for purposes of the si;~ who would nor reported ~ on Adlw Duty under title cartMcate. SCRA prdectiona aro for Title 10 and Title 11 active dunr reoonis for aN the Unifornrod Ssrvkas psrio TNSs 32 periods of Active Duty acs net covered by SCRA, as defrrod h accordance with 10 USC § 101(dx1). Many tunes c-ders era amended to extend the period of active duty. which would extend SCfiA prdediorur. Persona seeking to rely on tfNs webaNe certtion should clrodt to make sure the orders on wlrklr SCRA P an based haw rtar been arrrerMed to e><prnd the irrdusiws dates of serv Ftrtlremroro, Bans protectiarrs of the SCfiA may extend to persaro who hew received ceders to report for adhrs duly a to be , but who trove adualltr begun active duly or arAuaNy reported for induc~rr. The Last Date on Active Duty enhy ~ important because a number of ~ ~ the S exNnd beyond the last dates of active duty. Those who oorafd rely on this certificate aro urged to seek gratified legal camesl to ensuro that ~ rights 9uarantesd to Service rrrrrnbeets under the arse protec6ad WARNING: This csrtifirsais was provided based on a last name, SSN, and active duly status data pravtded by tfte raqusster. Provkikrg, erroneous infonmtion wiN cause an anorrooue certlficefe to be provided. Report ID: 8SH6TO4tKS