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Home My WebLink About12-2912Robert 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 t 11 Attorneys for Plaintiff V3 ER l? U! i j 'lf 4 t'_ 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. TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 Defendant NOTICE No. I a as l d- blil 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 S µ 1? ? lpd This communication is from a debt collector and is an attempt to collect a debt. CL Any information obtained will be used for that purpose. V??a-? ?((S8 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 9,1055 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. TONYA HODGE 43 W BALTIMORE ST 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) dial 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 " ,111s c:ol.xmnlunicatiol' is li-oili a (lel)t: Collector kInd Is an attempf. to C:ojlc°Ct a dcht, Any intormation obtained ,x il( be uscd l'()r that purpos ;. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 9,4055 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. TONYA HODGE 43 W BALTIMORE ST 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 TONYA HODGE, is an adult individual with last known address of 43 W BALTIMORE ST, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to GE MONEY BANK F.S.B. / WAL-MART on December 20, 1998 with account number ************0608 (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. !'hi, k.of munic;ation is fi-on) dclit collector gild is all "Ittetyipt to Collect a debf \r)y inf,6r1nattoll obtained will be used f6r that 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. 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 March 17, 2010. 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 $1,173.76. 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, TONYA HODGE, in the amount of $1,173.76, plus costs of this action and any other relief as the Court deems just and reasonable. 9 Robert N. Polas Jr., Esquire # 201259'-` Carrie A. Brown, Esquire # 94055 11-82736 FIlls. ,:onllliwllcatlol) is from a dcht collector alld Ili iIII attempt to collect <a deht. Any Hifi,lrination ohtaMed will he used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, ltirla 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. APR 112012 Date : By: ILM pellman Custodian of Records 11-82736 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: ************0608 TONYA HODGE Account Holder: TONYA HODGE 43 W BALTIMORE S'T CARLISLE PA 17013 Consumer Account Product Code: PVT Issuer: GE MONEY BANK F.S.B. / WAL-MART Assignee: Portfolio Recovery Associates, LLC Account Number: ************0608 Date Account Opened: December 20, 1998 Date of Last Payment: March 17, 2010 Date of Charge Off: September 30, 2010 Balance at Purchase: $1,173.76 Purchase Date: July 29, 2011 Balance at Charge-Off: $1,173.76 Less Payments: $.00 Balance Due: $1,173.76 11-82736 GECL92 This communication is from a collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Walmart :;. Save money: Live batter..." Walfflart® Credit Card TONYA A HODGE Account Number: _0608 Visit us at walmart.oom/credit Customer Service: 1-80D-641-4526 Summary of Account Activity Previous Balance - Other Credits $1,173.76 $1,173.76 New Balance $0.00 Credit Limit $960 Available Credit $0.00 Cash Advance/Quick Cash Limit $192 Available Cash $0.00 Statement Closing Date 09/30/2010 Days in Billing Cycle 28 Transaction Summary Tran Post Date Date Reference Number Description of Transaction or Credit Amount 09130 09/30 F9112DOM100999990 CHARGE OFF ACCOUNT-PRINCIPALS ($861.75) 09130 D9130 F9112DOM100999990 CHARGE OFF ACCOUNT "FINANCE ($312.01) CHARGES' FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 09130 09/30 INTEREST CHARGE ON PURCHASES $O.DO 09/30 09130 INTEREST CHARGE ON CASH ADVANCES $0.DO TOTAL INTEREST FOR THIS PERIOD $0.00 2010 Totals Year-To-Date Total Fees Charged in 2010 $39-00 Total Interest Charged in 2010 $83.59 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. Interest Charge Calculation Your Annual Percentage Rate (APR)s the annual interest rate on your account. Expiration Annual Portion of Balance Balance Subject to Interest Balance Type of Balance Date Percentage Rate Assessed This Rate Interest Rate Charge Method Regular Purchases & NA 29.90% Entire $0.00 $0.00 2D Cash Advances 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 irtfomeation. 5904 BDH 1 5 3 100930 Z X PAGE 1 0£ 1 911, 7000 £1)00 OICQ5404 Detach and mail this portion with your check. Do not include any correspondence with your check. too AccountNUmber: vr' 4s. walmart Total Minimum Amount Payment Due ce Ovorllmtt New Balance Save money. Uve better. Payment Information New Balance $0.00 Minimum Payment This Period $449.00 Amount Past Due 80.00 Total Minimum Payment Due $449.00 Payment Due Date 10103/2010 Late Payment Waming:If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to $35.00. Payment Due Past Due Date Amount $449.00 $0.00 10103/2010 $0.00 $0.00 Payment Enclosed: ? ? ? ? ? a ? ? Yp,Ii?? IgII Please use blue or black ink. New address or email? Print changes on back. M ITI, IONNYA A HOIIIDGE 43 W BALTIMORE Sl' CARLISLE PA 17013-3808 Make Payment To: WALMART/GEMB P.O. BOX 530927 ATLANTA, GA 30353-0927 CuslomerSeMce/Quesdons: For account information, pleasecall the toll free number on the front of this statement. Unless your name is listed on this statement your access to information on the account maybe limited. You may also mail questions (but not payments) to: P.O. Box 981470, El PasoTX 79998-1470. Please includeyouraecont numberon arrycorrespordenceyou sendto us. Payments: Send payments to the address listed on it* remit portion of this statement or pay online. Nnfilw See below far vourBillm Rghts and other important information. Telephaing about billing errors will not preserve your rights under federal law. Purchases, returns. and payments made tilt prkNto billing date may not appear until ne7d month's statement. When you provide a check as payment, you authorize usehhertouseintrmahon yourcheck lomakeaone-time electronic fund transfer from youraccountor toprocessihepayment as a check transaction. When we use information from yourcheck to make an electronic fund trenster, funds maybe withdrawn from your account as soon as the same day we remains y ?yment, and you will not recewe your check back from your financial institution. You may choose not to two your payment collected eNct, Measly by sending your paymntntd with the p mad stub), In yart own envelope - not the enclosed window envelops, addiressedto:P.O.Box980098,Odando,F 328 andnot ePayna A ress. What To Do n You Think You Find A Mistake On Your Statement If you think there is an error crn your statement, write to us at: GE Money Bank P.O. Box 981470, El Paso, TX 79998-1470 In your letter, give us the following information: • Account information: Your name and account number. • Dollar amount The dollar amount of the suspected error. • Descc%npion of Problem: If you think there is an error on your bill, descnbewhalyou believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement You must notify us of any potentialerrors wwrdinp. You maycall us, but if you do we are not required to investigate any potential errors and you may have to pay the amoral in question. While we investigate whether or not there has been an error, the following aretrue • We cannot try to tolled the amount in question, or report you as delinquent on that amount • The charge in question may remain on your statement, and we may continue to charge you interest on that amount. Bul, if we determine that we made a mistake, you will not have to pay the amount in question or arty interest orotherfees related to dial amount. • While you do nothave to pay the amount in question you are responsible forihe remainder of your balance. • We can apply any unpaid amount against your credit link. Your Rights If You Are Dissatislfod With Your CredN Caro Purchases If you are dissatisfied with the goads or services that you have purchased with your credit card. and you have tried in good faith to correct dhe problem with the merchant, you may rave the right not to pay the remaining amount dueon the purchase. To use this, right, all d the following must be true: 1 The purchase must have been made inrurhome state orwithin100 miles of your current mailingg address, and the purchase price must have been more than $50. Neither of these are necessary if your rurchase was based on an advertisement we mailed to yam, or I we own necompanythatso d you the goads or services.) 2. YOU must have used your credit card for the purchase. Purchases made with cash advances from an ATM orwith a check that accesses your credit card account dono3wify. 3 Youmust antyethaveTullypadlorthepurchase. If al of the criteria above are met and you are still dissatisfied with the purchase, contact us in wri ngat: GE Money Bank P.O. Boa 981470, El Paso, TX 79998-1470 White we investipate, the same rules apply to the disputed amount as discussed above. Af 0 we finish our Imrestgation, we will tell you our decision. At that point, if we thinkyou owe an amount and you do ant pay we may report you as dells luent . Information About Payments: You may Ppaeyy more than the Total Mlnfmum Paymad of any lime. Payments recehed after 5 00 PM (ET) on a day oil be credit ed as of the nod day. Credit to you Accalnt may be dayed upp to five des if payment (a) is no remained at the Pa nt Address, lib is not made in U.S ddars d awn one U .S. financial ins9lul on kcatad in the U.S., (c) is not accompanied by the remittance coupon adact ad to your statement, {d) contains more than one payment or (1)includesstaples paperclips, tape afolded check, orcorresplxdenoeot arn/ ttyyppee Ai written communications cono" dspnted amow s ?dfeck a other payment lnsfrume t that (I indicates that the end c o nsMufes' n if n fulr or is tendered as f? satisfaction of a is ufed amount or (ti is tendered with other conditions or limitations d'DSWtad payments"), mus be mailed or delivered to us at Pit. Box 981470, EI rasa. TX 79958-1470 Credffs To YourAccount., An amount shown in parenthesis or preceded a minus ((-) sign is a credit or credit balance unless otherwise indicated, redils will be applied to your previous balance immediately upon receipt. but will notsatisyi anyrequIr payment that maybe due. Credit Reports And Account Information: If you believe that we have reported inaccurate information about you to a consumer reporting agency, please contact us at PO Box 981471, El Paso, TX 79996-1471. In doing so, please Identify the inaccurate information and tell us why you believe it is incorrect. V you have a copy Of the credit report that inc ndes the inaccurate information, please include a of that repot. We may report information about your account to credreaus. Late payments. missed payments, or other defaults on you account may be reflected in Method 1: The balance subject to Interest Chirge is your previous balance or what you owe at the beginning of the bitting cycle. a do not subtract any s and credits shown on the front side in calculating the balance; r it what you owe at the beginning of the cycle is paid during the cycle, yourbalancesubfed to kiterffCharge s $0. Method 2D (Dairy Balance method): We fgue the interest charge on your account b applying the periodic rate to the daily balance" of yyoour account foreachdalinthehTlingcyde. Wethen cidtheinterestiothedaiybalance To get the daily balance we take the begin nq balance of your account each day (wMch includes unpaid Intermit, add a ry new charges, and a cabhefees,a?nnydsubl2danypaymeMsorcredks. ThsgthesustheWiX ?p0anr31e ?ty belani will lo of s la culaattedz? eadt balaannce edtll?ie on your account. The balance((s)1 shown in the Interest Charges s ion of the statement is the sum o. the daily balances far each day in the billing cycle Method 2M A nrage Daily Balance includ" current transactions): Wehguretheinterestcharge onyour amount byafpl irgtheearodic rateto the 'average dally balance" of Qr account- r0 gel the avarag3 deity balance' we take the beginning lance of your account each day, whictm includes any unpaid intereat charges from the previous billion curie, add any new changes, and a pl able fees and subtract a ry paynrerds or credits. Thi gives us the dallpv balance Then, we add up all the dairy balances for the billing cycle and dfvidelhetoial by the number of days in the biting cycle This gives us the'avwage defy balance,' which sthe balance shown in the Interest Charges section of Iris statement , Any average daily balance of lass 9tai zero will be treated as zero. A separate average daily balance will be calculated for each balance type on your account. Method 3M (A o Daily Balance euoluding current tronsasions): Wei1gursthe Mereslcharge onyour amount byappyirgtheemodkrate to the 'awfage daily halaoce' of your account. To got the swags daiiryy balance' we take the begimhg lelance of your account each day which krch des arty unpaid k4eneel changes fear to prevkns blfeg cycle and add applicable fees and subtract antmants or credils We do ant add in a new chaffs this ghee us the daily balance. Then, we add rip a l the dam hasnrres to the DRng cycle and diode the total by the mmberoi days m the filling cycle Ths gives us the "average daily balance; witch s the Wnce shown n One Interest Changes section of this statement. Any average da ry balance d less than zero will be treated as ze o. A s? orate average daily get the •average co balart03' we take the beginning name or your acrxxtnt each day applicable fees and subtract anryy pav reins, credits and unpaid imaestdrarges from the previous filling cede 4 do ant add in any new charges. Ths us the dairy balance. Ti hneenn we add up ailthe dailryy balances for the bit ycie and divide the total by the number of days the Intfie billing cycle Ths lig es us the `average dally balance," which is balance shown In the Interest Charges section of this statement. Any average dam balance of lass than zero will be treated as zero. A separate average day balance will be calculated fir each balance type on your account. Method 6 (AvpeVs Deily Balance Including current transactions and excluding amount nt I Indi t ra?dic?rate? tto the aawa ? gei ? balanc e' of yynu account. ogetthe'averagedailybolance'wetakelhebegrn balanced your acconn each day, add arty new chars and a" fees and subhacl ay payments, credits and unpaid inte alai charges from (tine previous Lillkg cyc e. Ths gTres us the dairy balance Then, we add up all tike it ly balances to the filling cyrie an d divide thou total by the number ot days m the blliag cycle. THs life es s the "average daily balance' whkh's the lance stxnvn m the Interest Charges of of Ihs statement. Amy average da balance of less than zero will be treated as zero. A separate average dal balance wit beakulated for each baiancetype onyour account Method 7: The balance subjed to Interest Charge Is determined by taking the amount you sae at the beginning of the cycle and subtract any payments and credits and any pnor Interest Chargqee not ppaad during the cycle However, 'rf what you owe at the begmni g of itce cycle is paid during lhecycle, yourbalancssubject to Inter tCharges; Bankruptcy Notice: If you file bankruptcy you must send us notice. Including account number and all information related to the proceedinrgg to the following address: GE Money Bank, Attn: Bankruptcy Dept. PO Box 103104, Roswell, GA 30076. Your account Is owned and serviced by GE Moray Bank. Heading Impaired: TDD users call 1-800-444-1732. C 1 C05404 - 4 - 060/2010 This is an attempt to collect a debt and any information obtained will be used for that purpose. *By providing a telephone numoeron your account, you consent to GE Money Bank and any other own er o r servicer of youraccount contacting you about youraccount including using any contact information or cell phone numbers you provide, and you consent to the use of" automatic telephone dialing system and/or an artificial or prerecorded voice when contacting you, even if you are charged folhe call underyour phone plan. For changes of address, phone number and/or email, please check the box and prim the changes below. Name Street Addis City, State, ? Zip Phone # E-mail Home Phone # Business Phone # 'Cell # or other phone IF we an use to contact you Email Addis By oroviding your small address, you agree to receive email communications about your account and also give permission for us to share your email address to Walman. GE Money Bank BILL of SALE PRA 120-day Mid Prime - July 2011 For value received and in fizrther 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 July 19, 2011, and as further described in. the Agreement. GE Money Bank By: Title: CFO Retailer Credit Services Inc By: Title: President General Electric Capital Corporation By: Title: Vice President GECL9Z z0f 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody 3 Smith Chief Deputy X12 MA's 22 ?? q Richard W Stewart Solicitor OFf cE E: ERA=r CUM??R?AN? pE??sYLyA??a Portfolio Recovery Associates, LLC Caere Number VS. Tonya Hodge 2012-2912 SHERIFF'S RETURN OF SERVICE 05/14/2012 06:58 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, staffs that on May 14 2012 at 1858 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tonya Hodge, by making known unto Jacob Hodge, Husband of Defendant at 43 W. Baltimore Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the some time handing to him personally the said true and correct copy of the same. UTSHAL, PUTY SHERIFF COST: $34.00 May 18, 2012 SO ANSWERS, ""- &'; Z RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Telecsoft, 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. TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 Defendant ~.. Date: No. 12-2912 CIVIL PRAECIPE FOR DEFAULT JUDGMENT _~ e ,~,, c°_r ~ __~ ~~. ~ ~- G ''a c~ may, ~' ~ c3 ' ~+' c-> ~ o ~ c-' 2 O ~~ ~ ? ~r.: -~ -~ .-~ Filed on Behalf of Plaintiff Counsel cord for thilfl'art~ 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 ~- ~' ~~ u C~ ~ o~~ l l'Z This communication is tote a debt collector is an attempt to collect a debt. ~ '~ (~,3ez Any iliforlnation c:~btained Will be used. for that ptls-pose. 2 ~~~ 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. 12-2912 CIVIL v. TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Pease enter Judgment in Favor of Plaintiff and against Defendant, TONYA HODGE ,for failure to answer the Complaint. (X) Amount Due $1,173.76 Less Credits $.00 TOTAL $1,173.76 (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 file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of record, if any, after the default occurred and at least ten days to the date of the i g of this praecipe and a copy of the notice is attached. `~ V Date: ~ ~ 7 / ; Rob 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 from a debt collector is an attctnpt to collect a debt. AI~y irlforlnation obtained. will. be used :far that purpose. 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. 12-2912 CIVIL v. TONYA HODGE 43 W BALTIMORE ST 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 $1,173.76, plus interest, on . ~ (X) A copy of all documents filed with the Prothonotary in support of sy: If you have any questions regarding this Notice, please contact the Date: f~4 ~ 7 ~~~~ Robert N. Polar, Jr., Esquire # 241259 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 comzzlunication is from. a debt collector is an attempt to collect a debt. Any information. t:~btain.ed will. be used. far that puzpose. RORTFOLIO RECOVERY ASSOCIATES, LLC t_itigation Department 140 Corporate Boulevard Norfolk, VA 23502 Telephone: (866} 428-8102 Fax: (757) 518-ossa Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday $ AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST} June 18, 2012 TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 11-82736 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. TONYA HODGE 12-2912 CIVIL Dear TONYA HODGE: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pettnsylvania Rules of Civil Procedure. Sincerely, ~~ ~ ~ ~~ Robert N. Polas, Jr., Esquire Came A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff +^ tr_ This i;ommunication is fmm a debt collector is an altc~npt to c;ollc~;t a debt. AnY information ublainec! will he used f.'or 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. 12-2912 CIVIL v. TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 Defendant T0: TONYA HODGE 43 W BALTIMORE ST CARLISLE PA 17013 DATE OF NOTICE: June 18, 2012 YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPIrARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTTH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAIl~iST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARIlVG AND YOU MAY LOSE YOUR PROPERTY OR OTHER Qt+IPORTANT 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 WfTH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIG®LE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service -CUMBERLAND County Bar Association Court Administrator 32 South Bedford Sttcct Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800)692-7375 ~~-v P~~~ Robert N. Poles, Jr., Esquire Came A. Brown, Esquire Attorney 1D # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff This communication is fmm u debt collector is an uttempi to collect a dabs. Any information obtained will be u,cc1 for that purlx~e. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC . 120 Corporate Blvd Norfolk, VA 23502 No. 12-2912 CIVIL Plaintiff v. TONYA HODGE 43 W BALTIMORE ST 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 43 W BALTIMORE 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: 11-82736 / ~~~ Robert N. Polar, Jr., Esquire, #201259 L--- 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 and is an attempt to collect a debt. Any infornation obtained will be used for that purpose. Department of Defense Manpower Data Center Ptuwant ~ Ser+vi~ t~i~il Relief Aat Last Name: HODGE First Name: TQNYA Active Duty Status As Of: Jul-23-2U12 Rpu&i es d : ,AY43-201 Y 04s scw- ~. ~. a. . r~- .Q. ~> -~: ~z' `. ~ ~ -~ NA !4- NO NA TNs M titsdls wtw+~ 6» i1di+A0wd Ise ac6w duy iheia wM1Mn 367 dns pro~dkp 1N AcW Wty etNu DAM 1 NA ~ NA t Nn I HA ~ I 1 nr. ~..~.. ~.s.a. vAia6,r 6w ~wa~w «i,rnw wax Mr ~aw.d ary nd6a6on w npae i« aAlw axy I 1 Upon asarctdng the Oats banks of tl1s Departrrrsnt of Oderros Merpowsr Date Center tweed on tM formation tltat you provided, the shove b Uia statu of d'ro individt+el on iM adios duly status dais as to aN txamchea of the Unitbmrad Services (Mny, Navy, Marini Corps. Rk F«as. NOM;. P~iic Health. Comet f3uard). This status indudss informedon on a Servkxmember a hie-her unit recsiving notflilrotlon of futuro orders ~ roport far Active Duty. Mary M. Snavely-Ofxon. Ditecoo- Dep~ubnent of Defense - Manporwer Data Center a~sitoro~lMser~tcyct~e2n2ter Drrtre, sulfa atc2s f T'iT~1 J~-350 The Dafertse Manptrwsr Data Cantor (Dh1DC) b an organization of the Departmsrtt ~ De/snsa {DaD} tl>at mairttairts the Deienae Enroimertl arxt Reporting System {DEERS} datatxise which is the ottk3al source of data on eigfbNtly for mifitarp rrredicat care and other eli~bAity systems. The DoD strorpy supports dte sMorosnwrrt of the Servicemembere ChtY tieliat Act (50 USC App. §501 et esq. ~ amended) {SCRA} (torrrteriy krawn a the Soldiers' and Saibrs' Civil F2sisf Aet of 1940} OMOC has issued hundreds o/ thousands of "does rat posses any ktforrnatiort indading that the individual ~ arrarrHy on active duly" responses, arxt has experieraed only a smell error rob. In tlts avant ttw kt~vidt-al rsferaraad above, or any (arrtiy msrttber, friend. or represarasdve asserts b arty rrtartnar Utat the irttlividual vtuw on active duty }or fM active duty statue date, or ~ otharwke entitled to ti P ~ ~ SCRA. ter aze > b a~ fasttt•r vsriN~atfon of the pwsars status by contacting that person's Service vie the "dehnseNr-k.mii" URL: htaJtwww. t.DR.hhrtL It you have evkisnce the person was on active duty for the actlw duty status date and you tai b obtain tlris additbnal Service veriRoatiort, partitive provisions of the SCRA may txj invoiced against you. See 50 USC App. ~ 521(c). Tftta response rollects the foiawing inbrrnation: (1) The individual's Adios Duty sleds on the Alive Duy Status Date (2} Wttetl-sr ttte'bditiduN bR Duty afaWS vwOrirr 36T days precadirq Ure Ardive Day 3istus Dab (3} VVttelher ill indfviduN or hidhsr unit received eery rtotificatim to sport for a day on the Adhna Duty Stedat Dale. More information on 'Active Duty Status" Alive day stadu ~ reported in this cerdYlcats is dsfrtsd b acoordancs with 10 USC § 101(d) {1). Prior b 2010 ordy some of the active duly periods d than 30 cortseattive days h IengM vvera avail~le. In the case of a mambas at tlrs NaNOrml Guard, tlrb irNdudss service under a cal taacUvs service authorized by tt» President or the SecxNary of Detsrtse larder 32 USC § 502{t} for purposes d rasporrding b a national wnergNay declared by the President and supported by Fedan4 funds. Ap Acthre Guard Rasertrs (AGR} ntsntbsrs stub be asttigrtsd against an authorized ~ pattitlort to unit they support. Thin includes Navy Ttaindrg and AdmMistration of the Reserves (TARs), AAertrre Corps Actlve Reserve (ARa}turd Cgaei Guard Rase Program Adm4tiatrator {RPAs} Adios Duty stNua also apples b a Untlormed Service member who is an active clay oommissiorwed orWcer of the U.S. Public iiseih Ssrvk:e ar the National Oceanic and Atnaephsric Admirrislratlon (NOAH Commfabnsd Corpsy, Coverage Under the SCRA is Broader in Some Cases coverage under ill SCRA is broader in some saws and inckrdart same categories of parsons an active duty for purposes of the SCR who wwrW rat repordhd as on Adhrs Duty under bia oerttltoata. SCRA protections are fix Title 10 and Title 14 alive day records for ai the Urritormed Services psrio T"ttle 32 periods of Adtve Duty era not covered by SCRA, a6 dsikted in arxardartce with 10 USC § 101(dx1). Nbny times orders are amended to exdsxt the period of adNe duty. which vrouW extend SCRA prdediona. Persona seeking to roy on thb wstxrile ceHtticaticwr shotdd oMdc to make sure tM orders on whip SCRA protectlats ors basal have rat been amended b extend the ir~i+Ve dsmsa of sarvi FtsiFtermore, eom• protedfons of the SCRA may extend to persons who ltatre received ceders b report for adira duty or b be irrdtu~ed. lwt who have adualiy begun actira dully or aduaiy reported for ittdudbn. TM Lout Data on Active Duy entry is important because a number of protiecsons of tM Si extend ltd the last dates of active day. Those vtAto Mould rey on this cartificsle are urged b seek quatttiad legal counsel b erastxts that aN rights guerarttssd b SeKVice members under the 3CI are proNcted WARNING: Tiffs cerdfk:ab was prwkfed based on a last name. SSN, and adivet clay stelae date provided by the requester. Providing wnorreous irttonnttion vrii cause an enoneous oertlicale b be provided. Report ID: 83T5IUF46U