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HomeMy WebLinkAbout12-3232Robert 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 ) r Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 ASSOCIATES, LLC No. I a - 3a,;?) D C -t < V. WAZfR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 Plaintiff Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action wihing 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 S (800) 692-7375 I/ tt 1,7 aLqo qw? This communication is from a debt collector and is an attempt to collect a debt. 1 7(P a 3"'a Any information obtained will be used for that purpose. 9-9 a_?SS tp 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. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 Defendant NOTICIA LISTED 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. LISTED 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 PF,UDAN OFRECER SERVICIOS LEGAL, A PERSONAS ELGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Smice - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 31?.1iC°Atio n is '('ro 1 ?1 Ctc'n, t(fli err S ".I. 1 tl"` ""t 1t? coC 1 4' 111'tt"lfC3,t 3?zf1t):l c' tG9iitf:.1 ,'[ 7t r1 -}, ii ps'5 ?? 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 Attornevs 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. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 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 WAZIR C ALLY, is an adult individual with last known address of 3411 HAWTHORNE DR, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / AMERITECH on January 27, 2010 with account number ************8831 (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. Il ClIS 11- 11 zl t?t'?.! ? . 't'< :1710 i°'• 11 ?tll '"T'1?t ?.£.> Ol?s `,i1?- 111. 1>l l.t1: (1{) 1 £'?hlzu 11L, J .4 !1 '1; w',- d 1 91 [h l1. 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 April 13, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / AMERITECH 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 $2,331.60. 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. WH EREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, WAZIR C ALLY, in the amount of $2,331.60, plus costs of this action and any other relief as the Court deems just and reasonable. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-86642 ilt it oil fi,oill ii klc,6t L:,,,11?, :tor ?ind i 11 t to t;t)ik,! . it lv ti-1 01'r lattwl % hiclin i ''st tl'3',' u ;",d r 110t t ih 1'O, . VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry J. Andrews - 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. MAY I201 Date : --- By Custodian of Records 11-8664? 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 4 Statement of Account Account: ************8831 WAZIR C ALLY Account Holder: WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA N.A. / AMERITECH Assignee: Portfolio Recovery Associates, LLC Account Number: ************8831 Date Account Opened: January 27, 2010 Date of Last Payment: April 13, 2010 Date of Charge Off: December 31, 2010 Balance at Purchase: $2,331.60 Purchase Date: June 24, 201 t Balance at Charge-Off: $2,331.60 Less Payments: $.00 Balance Due: $2,331.60 11-86642 HSBL39 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. 1, the undersigned, Larry,j. Andrews depose, affirm and state as follows: Custodian of Records, for Portfolio Recovery Associates, LLC hereby 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. / AMERITECH ("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 24, 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 WAZIR C ALLY ("Debtor") to the Account Seller the sum of $2,331.60 with the respect to account number (************8831), as of December 31, 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 $2,331.60 as due and owing as of the date of this affidavit. Portfolio Rwq very I--_-r ..1 By: LLC stodian of Records Subscribed and sworn to before me on Notary Public ?'! 11-86642 MAY 012 of . Commonwealth of Virginia Notary Public Commission No. 7572855 My Commission Expires 1213112015 1_..- lcm .:I €=<<"?f iri?I71 a ;.i l t t;t?lleCtc;?' zlllt '` ?=T :Y11 t tt3 °" ( ?.1 tt+ti ?u 1.i t IC.. l1l4zt 1) L 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 30"' day of June 2011. HSBC Bank Nevada, N.A. HSBC B SA, N.A. Signed By: kkx, By: David Nauman Title: Vice President NSO139 1 Or, 2 ASSIGNMENT AND BILL OF SALE HSBC Receivables Acquisition Company I , HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporation (USA) IV (hereinafter collectively called "Seller") has entered into a Purchase and Sale Agreement as of May 16, 2011 ("Agreement') for the sale of Secondary Charged Off Receivables described in Paragraph 1 thereof 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 Secondary Charged Off Receivables 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 30th day of June 2011. HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporati USA) IV Signed By: By: David Nauman Title: Vice President YS 8t39 2 ff 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy +.; ppr t }}i _ Richard W Stewart Solicitor n -1 12 MAY 30 AM 3: 52 PENNSYL VA141A Portfolio Recovery Associates, LLC vs. Case Number Wazir C. Ally 2012-3232 SHERIFF'S RETURN OF SERVICE 05/24/2012 08:59 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 24 2012 af, 2059 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Wazir C. Ally, by making known unto himself personally, at 3411 Hawthorne Drive, Camp Dill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SYAM-LUTSHALL, DEPUTY SHERIFF COST: $43.00 May 25, 2012 SO ANSWERS, 2 '11,2, , ? ?/ RON R ANDERSON, SHERIFF c ('ou!?•, a to her'1 f so't ,n:: 4- 4:-`?Y' €4` SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff$ati`+tr o1nir?r/ir Jody S Smith f' E P110:40 Chief Deputy Richard W Stewart tf BERLAr D C 0UIN' ?..,., Solicitor OFF EOF'tiES"ERIFF PENNSYLVANIA Amended Portfolio Recovery Associates, LLC vs. Wazir C. Ally Case Number 2012-3232 SHERIFF'S RETURN OF SERVICE 06/06/2012 11:26 AM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2012 at 1126 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Wazir C. Ally, by making known unto himself personally, at The Cumberland County Courthouse, Room 100, Carlisle, Cumberland County, Pennsylvania 17013 its ntents and at the same time handing to him personally the said true and correct copy oft a SHERIFF COST: $43.00 June 07, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (o) CounfySuite Sheriff, I eleo>oft, Inc. IN THE COURT OF COMMON PLEASE OF CUMBERLAND CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff v. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 Defendant 1JH T Pfl7' ~ ~ ~ AR1' '~~ AM 10 16 ll TY P N5Y~YAN1 c`7 No. 2012-3232 rn ~~ ~~ v~ ~ -C ~ ~~ ~- ~ ~C p DC x --t PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, WAZIR C ALLY ,for failure to answer the Complaint. (X) Amount Due $2,331.60 Less Credits $.00 TOTAL $2,331.60 (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/hor Attorney of Record. (X) Pursuant to Pa.R.C.P.231.1, Icertify that a written notice of intention to file this cipe was mailed or delivered to the party against whom judgment ' t be entered and to i r Attorney of record, if any, after the default occurred and at lea day prior to the dat of filing of this praecipe and a copy of the notice is attached. Date: 02 `~~ Robert N. Polas, Jr., Esquire # 2012 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC Dom.} $ ~ 1'liis cc~mmu.~~icacion is l'rorn a debt collector is an attempt to collect a debt. '2 r~ny inloi~i~atiori abtained will be used. for that purpose. j~ ~V~ --t s r*t -t~~ ca t -to A r a~ --~ D+y, JJ r` ,.sold a~9a?~ a~9 s y~ ~~~~~ 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. 2012-3232 v. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 PRAECIPE FOR DEFAULT Defendant JUDGMENT Filed o half of Plaintiff Co 1 o record for this P y Q~ ~'_ Date: Robert N. Polas, Jr., Esquire # 201259 Came 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 T'hi~ communication is from a debt collectc>r is an :~tternpt to collect a debt. -lny inf'onnation obtained will be used. for that purpose. r 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. 2012-3232 v. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 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 52,331.60, plus interest, on . ~ (X) A copy of all documents filed with the Prothonotary in support of the sy: If you have any questions regarding this Notice, please contact Date: 0 0~'7 ~~ 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 Phis coitununicatian is from a debt collector is an attempt to collect a debt. ~~~ny infotynatiati obtained will. be used tar that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC . 120 Corporate Blvd Norfollc, VA 23502 No. 2012-3232 Plaintiff v. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 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 3411 HAWTHORNE DR CAMP HILL PA 17011 and is not in the military service of the United States or its Allies, or otherwise within the the Service Members Civil Relief Act and its Amendments. Date: 11-86642 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 of "Phis corrirnunicatiori is a debt collector and is an attempt to collect a debt. :1ny information obtained tivill be used for that purpose. Oepartrnent Of Defense Manpower Data Cerrter R^.anaa:auem~2exoewe scan xzx ~t~ Be io ~etsieeioeadbeas Civil Relief Act Last Name: ALLY First. Name: WAZIR C Active Duty Status As Of: Jul-25-2012 e, Ts ~1~ a1r Y,loiaW w,Yw dWr rbbn Msl10n M I6M a9' BMn WY Y TT~F. iN.,np.r ~,M~«. w...Ywdur YR.'aw sun.wuor+wn~see a.raw.e.ryw •arw ouo sau.w. .. :G. . _ !N1 h10aw Ira~rU N11aW M MMlIMI ar NNW WM MrRYYM NynCalralM b a+Mb ~ta1i OJIy Upon searaMrp dis data banes d M O~PMtrnaN'd Dsiensa Maripo~wr Data. Cater; bataU m tlK NkirnsYOn tlua You govWsd, tlfs allow K dwstesx d tM indltadtul an Ma acUw duy talus daps as to atl bwwbM dtlrs Unifonnad Swvlar{Nary. N++f', MrN» Carp, Air Fares. NOM Pu01IF HaNA, and Coast Guard).. Thk slants erAtdas idormatlon on a Sarvlrwnambar w nisAur utwt raosiwg natllluatlon d RWIA or4ts to npoa Aot Actlw Dury. .r. ~a. y~. y~rN~ ~. Mary M: `.mavNy-Olson, Dlrscbr Deparbnent d DMeme - Marywwer Dau.Centar aeon Mark cetsar Drna, solo.. oaE:25 ,~dzsso "I"his cornrnunication is a debt collector and is an attempt to collect. a debt. :~1a~v intbrmation obtained ~~iil be used fot• ghat purpose. 'f his corrirrruriication. is a dc~~t ci~llector and is ari attc;mpt to collect a dei~i. Any information obtained will be used for that purpose. __ __ __ _ _ ___ T Department of Defsnse Manpower Data Center do ~~em~mbe~ Givii R~elitr~,~t Last Name: ALLY First Name: WAZIR C Middle Nams; Active Duty S#a#us As {}f: Aug-13-2012 Reaues as or: Aug-13.so1s on -.c~•e oNr aA napes Ovh »ms o.+. .49„s ~ sbn o.t. ka.e ~ Errd ow skaWa '6eM1tan E~VS~w. -- M1IA w~ _Hs NA TMs nreponae renecp 4ryt r}.idueb' ad1W dl[Y ~i14iNbsNd on tM 11ctIlsUlltj Sisfus its ltlll Ar#it Duy r"Nw' J67 tK Yr d ~tiXer! ~Y. Nlleie 4eM our :7-1 Das. rwtlvs ~ E++d falls FtNUS s~rc,- r-or~Par~«a --_' - _ ~- NA _ -~ ~ HA No NA .w . TMa response reNeals wnw OK ~^,Ai laft e-urr duty ~42WiMle7 ~ c~PCedby meg.:weawysmtueo~~~ TM1e. WmDu er teNtr War vrse NMIOKfota s~t1MY.~tp 10.N.4~w;OVgr 6~, rtdt~0~f~tilfeMn QMs OrtNr NoNkaeon Start Quu Order «o1MraUaa Eaa Deb 542w Sawos NA N4 No- NA TMs reapawe repetts rvneHxr tla inr oral has recelaa/ ~ a repoR Mt ecWe duty Upon seerching the data banks of the Department of Defense Manpower Dgf;6`Cihfpr, based on the information that you provided, the above is the s of the indivkluai ort the active duty status data as to all branci~s of the Uniformed Services {Army, Navy, Marine Corps. Air Force, NOAA. Public Health, a Coast Guard). This status irtdudes irttormation on a Servicemember or histher unit receiving notification of future orders to report for Active Duty. t May M. 3naveiy-Qlxan, Dx+actnr bepariment of Defense -Manpower Dam Center 4t30Q Mack Center Drive, Suite 04E25 Arlington, YA 22350 11-86642 The Dafansa Manpower Data Center (DMDC} is an organization of the Department of Defarrse {DoD) that maintains the Defense Enrollment and Reporting System {DEERS} database which is the official source of data on eligibility far mitltary medical care and other eligibility systems. The Do0 strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. §501 et seq, as amended) (SCRA} {fonnerty known the SokNers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any kifarrrwtion kttficating Ehat the individual re currently on active duty" responses, and has experienced only a smelt srrar rata. In the event the individual referenced above, or any famil member, friend, or representative asserts in any manner that the individual was on alive duty for the active duty status date, w is otherwise entitled to protections ~ tfte SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that parson's Service via the "defenselnk.mil' URL: http:/Cwww.dafenseltnk.mitHaq/pislPC09SLDR.htmt. If you have evidence the person was on actve duty for ttre active duty statue date and you fail to obtain this additional Service verification, punitlva provisions of the SCRA may be Invoked against you. Sea 50 USC App. § 521(c). This response reflecis the following information: {t }The individual's Active Duty status on the Active Duty Status Date (2} Whether the individual left Duty slaws within 367 days preceding the Active Duty Status Dale (3} Whether the indvidual or hislher unit received early notification to report for a. duty on the Actnra Duty Status Date. More information on '"Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 1D USC § 101{d) {1). Prwr to 2D1 D only some of the active duty peetods Ir than 30 consecutive days in length were avaNable. In the ease of a mmmber of the National Guard, this includes servks under a call to alive service authorized by the President or the Secretary of Defense under 32 USC § 502{t} for purposes of responding to a natior~t emergency declared by the Preskterrt and supported by Federal funds. Ali Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in unit they support. This includes Navy Training and Administration of the Reserves (TARa}, Marina Corps Active Reaenre {ARs}and Coast Guard Rene Program AdministraWr (f2PAs}. Active Duty status also appt~s to a Uniformed Servke member who is an active duty commissioned officer of the U.S. Public Health Service or the National oceanic and Atmospheric Administratiom {NOAH Gommissrotxd Corps}. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and Includes same categories of persgns on active duty for purposes of fhe SCRA who would not reported as on Active Duty under ttus certificate. SCRA protections era for Title 10 and Title 14 alive duty records for all tits Uniformed Services perms Title 32 periods of Alive Duty are not covered by 5CRA, as defined in accordance with 10 USC § 101(d}{1). Many times orders era amended to extend the period of active duty, which would extend SCRA protections. Peraone seekir~ to ray on this website certification shouts dteek to matte sure the orders on which SCRA protectiar~s are based have net bean amended to extend the inclusive dates of servi Furthermore, some protections of the SCRA may extend to pentor-a who have received orders to report for active duty or to be induled. but who have actually begun alh+e duty or actually reported for indulian. The Last Date on Active Duty entry is important because a number of protections of the SI extend beyond the last dates of actNre duty. Those who could rely an this certlficate ors urged Yo seek qualified legal counsel to ensure that a0 rights guaranteed to SerWCe members under the SCI are protected WARNING: This certificate was provided based on a last rreme, SSNJdate of birth, and active duty status data provided by the requester. Providing erroneous information will cause an erroneous certfticate to be provided. certificate iD: Q~sosasEnna 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 WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 11-86642 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. WAZIR C ALLY 2012-3232 Deaz WAZIR C ALLY: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the 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 I~ This cor~~munication is from a debt collector is an attempt to collect a debt, Any information obtained will be cased for 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. 2012-3232 v. WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 Defendant TO: WAZIR C ALLY 3411 HAWTHORNE DR CAMP HILL PA 17011 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 COUR' 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 LASE 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 MAYBE 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 ~~_ Rbber'~T.^ Polas, Jr., Esquire Y - Carrie A. Brown, Esquire Attorney ID # 201259/9405'5 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff This co~~~unu~nication is from. a debt collector is ate attem~at to collect ~~~ d^~ht. Any inlbrmati.on obtained will be u;,etl for that E?uipo~e.