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HomeMy WebLinkAbout12-2907Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar It 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 a TELE: 1-866-428-8102 FAX: 757-518-0860 ' Attorneys for Plaintiff'" t'?.,r Jr) ?„ , rGTll; 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. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 Defendant NOTICE agog C??? ? No. a ' 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. ct"', @X63. 7S lQ g Any information obtained will be used for that purpose. t, ? 'y- ,r, 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. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 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 CONSEGUIR 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 TIUS co1ra111LI aiUat:iara JS h-0111 a debt collector, aril IS 111 :attempt to collect a debt Any intoniiatioji obtained a ill he u,,ed for that ptarpo.SC. 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. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 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 JAMES L GITT, is an adult individual with last known address of 31 OTTO AVE, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / SEARS on June 24, 2009 with account number ************4173 (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. hl,ii'. ?-ona3 uiiicalloti is from a. debt collector aild is all allcinjit to Collect a debt. Arty i«fornnation obtaithd ?,AJIl be Disc for that purposc. 6. 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 September 24, 2010. 8. Plaintiff is the purchaser,, assignee and/or successor in interest HSBC BANK NEVADA N.A. / SEARS 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." 9. 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 $1,845.18. 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, JAMES L GITT, in the amount of $1,845.18, plus costs of this action and any other relief as the Court deems just and reasonable. Robert N. Polas Jr., Esquire # 20125 Carrie A. Brown, Esquire # 94055 11-74633 Fhl? - conimunication_ is fi-on-i t debt collecto r and is W1 attempt to Collect a debt, :Any, infonliation obtained will be tiled Ibr that pure o-.,. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Itina Spellman 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 unsworn falsification to authorities. Date : APR 112012 _ By: tuna S0116-IM Custodian of Records 11-74633 This communication is from a debt collector 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: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************4173 JAMES L GITT Account Holder: JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA N.A. / SEARS Assignee: Portfolio Recovery Associates, LLC Account Number: ************4173 Date Account Opened: June 24, 2009 Date of Last Payment: September 24, 2010 Date of Charge Off: February 28, 2011 Balance at Purchase: $1,845.18 Purchase Date: August 26, 2011 Balance at Charge-Off: $1,845.18 Less Payments: $.00 Balance Due: $1,845.18 11-74633 HSBM 18 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, Itina Spellman , 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 HSBC BANK NEVADA N.A. / SEARS ("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 August 26, 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 JAMES L GITT ("Debtor") to the Account Seller the sum of $1,845.18 with the respect to account number (******"""4173), as of February 28, 2011 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 $1,845.18 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC By: Itina Spell Custodian of Records Subscribed and sworn to before me on Notary Public 11-74633 of APR 1 It 201?2012 6, LOSOY Commonwealth of \141mla Notary Public Commission No. 7572855 My Commission Expires 1213112015 Iiis communication is from a debt collector and is an aftcnipt to collect a debt. ?\w, 1111,01-111alJon obtained will be used ]"or that purfsOse. EXHIBIT B ASSIGNMENT AND BILL OF SALE HSBC Bank Nevada, N.A. and HSBC Bank USA, N.A., (hereinafter called "Seller") has entered into a Purchase and Sale Agreement as of May 16, 2011 ("Agreement") for the sale of Accounts and Account Documents described therein to Portfolio Recovery Associates, LLC., (hereinafter called "Purchaser"), upon the terms and conditions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in each and every one of the Accounts described in the Agreement and in Exhibit A attached hereto. Purchaser and Seller agree that the Purchase Price shall be as stated in Paragraph 3 of the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 261hday of August, 2011. HSBC Bank Nevada, N.A. Signed By: By: Stuart Austin Title: Assistant Vice President HSBC Bank USA, N.A. _ Signed By: 91? By: Stuart Austin Title: Vice President 1456M / 6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. James L. Gift `i4, , 13 Case Number 2012-2907 SHERIFF'S RETURN OF SERVICE 05/11/2012 03:34 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2012 at 1534 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James L. Gift, by making known unto himself personally, at 314 Otto Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 May 17, 2012 NOAH CLINE, DEPUTY SO A NSWERS`, Ky' RONW R ANDERSON, SHERIFF (c) County5uite Sheriff, Telecsoft. Inc, t~ ~~ f.lJ-L~'`~iv~L.. ~.: ~:i~ rr'~~~F#Qtd~TAF~3' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Pry ~? ,~ P I~ ~ (~ ! ~~ , ~ : f Q CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES. LLC '~'`~"~~YE~VANIA 120 Corporate Blvd Norfolk, VA 23502 Plaintiff v. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 Defendant ~~ ~\ ( , Date: ~ No. 12-2907 CTVIL PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf of Plaintiff Cowie of record for this ~ 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 AIL. pd a ft ~9~797 ' 4f ~~ ~c IMn.~9~ ..Phis a~r~~u~nta~lieatic±n is torsi ~i debt a>llectc~r is air ~tteriilat t~> collect a dent. ~' ~~ssv i»iU~~lssatic?n obtai~ied ~~ill hc; u,,ed for tlsat purpose;. 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. 12-2907 CIVIL v. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, JAMES I. GITT ,for failure to answer the Complaint. (X) Amount Due $1,845.18 Less Credits $.00 TOTAL $1,845.18 (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, Icertify that a written notice of intention to filet pra cipe was mailed or delivered to the party against whom judg n is to be entered an o his er Attorney of record, if any, after the default occurred and le t to days prior to the to 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 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F)(757)518-0860 Attorneys for Plaintiff `l~.i~ co~~~r~~~~~~~~~ia~tiott is born a tlel~t collector is ~zn atternl~t to collect <z pie-fit. 1ny intoi~~~ation obtained ivili he u~~ed for that hurpc~sc;. 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. 12-2907 CIVIL v. JAMES L GITT 31 OTTO AVE 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 $1,845.18, plus interest, on . (X) A copy of all documents filed with the Prothonotary in support of t1~ withid']~gme1'l~i~?7lke attached. By: If you have any questions regarding this Notice, Date: ~3 :~ Robert N. Polas, Jr., Esquire # 2012 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 ~ ~~i~ E:<~~~unttnicttic+t~ is arc}trr a de[~t eollec~tc~~~ is an ~~ttertzltt tc~ ~c~11e~t a ciet~r. ~~rly infr~I~~~~ati~~n ~I~taia~ed ~~~ill 1?e used Iur that ~~~irpt~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. 12-2907 CIVIL Plaintiff v. JAMES L GITT 31 OTTO AVE 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 31 OTTO AVE CARLISLE PA 17013 and is not in the military service of the United States or its the Service Members Civil Relief Act and its Amendments Date: within the v~vi~ions of Robert N. Polas, Jr., Esquire, #20125 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)I-866-428-8102 (F) (?57) 518-0860 Attorneys for Plaintiff 11-74633 [ !~1~; c~~r~~rnunicatiori is a deht colle;ctar and is an ~~tte~~npt tc:~ e«llect a debt. ~dw intormatio~~ obtained will be used ft~~~ that pu~-~x~se. ___ _ T Department of Defense Manpawer Data Center ~hus~nt #o ~erw~Y~ce~~atb~~rs ~;r~ii belief t Last Name: GITT First Name: JAMES L. Middle Name: Active Duty Status As Ofi: Aug-13-2012 ~Cesulis as nfi : Aut5-13.2012 rJd:~81:48 SGP.A 2.] ~ Actwe putt' fh+ Active Duty gtA1Ub Date ~~ ~~~~ Actas Duly Start Date ~ ~ _ Actwa Outy Erxl. Da[a ._,___ 5laars~ See ice Corrpaneat ~~~~ kA t1A 1Yo NA ~~ Th's response rW.6oets the IndivFduala' active do-'ty stptus based on the AcIWe aAY Status bate teh Active Duty wAhin 387 Days of Active aWY Status bate ~ Arses bury Start Data . _ ___ ._ . __. -._ ._ ... M1'A Active Aury End pale ...... ~.., e ~ ._.~_.... ________ NR S~tus ._.__. _____~.~.~~v _.., , . No :rerv#cN C:~nnert . NA Tt>i'% rezpc,wa refleets wirers tl» [n<1,'~~f0an; Iv( tretiroe dory statusW6tldrr 88?days fxeradmg thH A<:wtr Duty Status (Seta The Mam6er a HksMer t)ntt was Nptitred of a Puttee C,~1-Im t8 Acttve Oldy oa AcWe buty$ta(us p81r Chdar NdAieatlon Start nafe .. On1ur PiattftcaCi6n End sate S#alus 5ervica Comparceat .. ___.~ ..... ~~ .._.._...... NA No NA 7tns response reflects wheSher fhe indivi~ial or hWher unit has received patlydotiFlcatioo to report roe active duty Uptm searching the data banks of the Department of Defense Manpawer Data Center, based on the infomtafion that you provided, the above is the stet a# the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy,. Marine Carps, Air Force, NDAA, Public Health, a Coast Guard). This status Includes information on a Servicemernber ar hisittar unit receiving notification of future orders to report #ar Active Dury. 1~' .++~ F Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Genfer 4$00 Mark Center Drive, Suite 04E25 Ariingtan, VA 22350 11-74633 The Defense Manpower Data Center {DMDC} is an organization of the Department of Defense (DoD}that maintains the Defense Enraliment and Eligibility Reporting System {DEERS) database which is the official source of data an eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 5f11 et seq, as amended} (SCRA) tformerly known a3 the Soldiers' and Sailers' Civil Relief Act of 1940}. DMDC has issued hundreds of ihausands of "does net possess any informafion indicating that the individual is currently on active duty" responses, and has experienced only a smelt error rate. in the event the individual referenced shave, or any family member, friend,. or representative asserts in any manner that the individual was an active duty for the active duty status date, or is otherwise entiFted to the protections of the SCRA, you are strongly encouraged io obtain further verification of the person's status by contacting that person's Service via the "detenselink.milM URL http;ltwww.defenselink.millfaglpisPPC09SLDR.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 USC App. § 521(c}. i This response reflects the foltawing informakian: (t) The individuai'sActive Duty status on the Active Duty Status Date (2} Whether the individual left Duty status within 367 days preceding the Active Duty Status Daie (3} Whether the indtviduai ar hisiher unit received early nati#icaiian to report for a duty on the Active t)uty 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 li than 30 consecutive days in length were available. in the ease of a member of the National Guard, this includes service under a calf to active service authorized by the President nr the Secretary of Defense under 32 USC § S02(f} tar purposes of responding to a rratianai emergency declared by the President and supported by Federal funds. Ali Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in unit they support. Phis includes Navy Training and Administration of the Reserves (TARS}, Marine Corps Active Reserve (ARs} and Coast Guard Rase 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 ACmaspheria Administration (NOAA Commissioned Carps}. 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 reported as on Active Duty under this certificate. SCRA protections are for Tite 10 and Title 14 active duty records for all the Uniformed Services perio T'rtte 32 periods of Active Duty are net 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 servi Furihemnore, 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 actually begun active duty ar actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the Si extend beyond iha last dates of active duty. These who could rely an this certificate are urged to seek qualified Eegat counsel to ensure that all rights guaranteed to Service members under the SCI 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: MO4H4N8AGS 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) July 25, 2012 JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 11-74633 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. JAMES L GITT 12-2907 CIVIL Dear JAMES L 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 Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff ..This ctn~u~»~~ni~ation is frt~~~n a debt uollccaor is an atl:empl. to collect ,r ~i~°ht. ~~ ~~'~n~~ i~nt{~rn~atior~ obtained will (~e iasccl fi,~r that purpose. ~~ IN THE COURT OF CO'_VIMON PLEAS OF CUMBERLAND COUNTY, PA ' CIVIL ACTION - I.AW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff No. 12-2907 CNIL v. JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 Defendant TO: JAMES L GITT 31 OTTO AVE CARLISLE PA 17013 DATE OF NOTICE: July 25, 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 LOUR" 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 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 OFFICI 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 Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff ~[~iis c~~~nrmu3yi~,~tio» is frozl~i <~ clc;ht cnlle~xt~~r r; .ua ~~~un2,?[ to c~oltcct a d; ht. ~~1nv infi?rn~adnn obt<3it~ed ~wil! be u~~_c~ fcrr chat ~iw~r~ct.