Loading...
HomeMy WebLinkAbout12-3494Robert 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 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. ?? - 741 I.IC??I. l V. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 Defendant NOTICE L cn ?" 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. f= 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 /a 3, ??S' (717) 249-3166 Pennsylvania Lawyer Referral Service C? ??g-? (800) 692-7375 186scg This communication is from a debt collector and is an attempt to collect a debt. K- tC??. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866428-8102 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. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 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 This communication is from a dcbt collector and is all attempt to collect a dcbi Ariy information obtained will be ii ce l for t}gat purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866428-8102 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. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 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 RAEGAN ZAMPELLI, is an adult individual with last known address of 3 GOLDENROD DR, CARLISLE PA 17015. It is averred that Defendant was indebted to GE MONEY BANK F.S.B. / JC PENNEY on May 16, 1994 with account number ************9338 (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. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. This COMIM liCation is from a debt collector and is ate attempt to collect =j (lebt. F1ri-' intormation obtained will be used K)r that: purpose. 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. 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 February 28, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK F.S.B. / JC PENNEY 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 $859.91. 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, RAEGAN ZAMPELLI, in the amount of $859.91, 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 11-75785 ThIS COMMUnication is from. a debt collector and is an attempt to collect it dcbt. Any infe+rmation obtained Will be LISuC l for tlUat l)Lirpc; e. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mary L. Moore hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date : IMAY 10 2017 11-75785 B} (20 L Marv i A,re .-.- Custodian of Records 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: ************9338 RAEGAN ZAMPELLI Account Holder: RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 Consumer Account Product Code: PVT Issuer: GE MONEY BANK F.S.B. / JC PENNEY Assignee: Portfolio Recovery Associates, LLC Account Number: ************9338 Date Account Opened: May 16, 1994 Date of Last Payment: February 28, 2010 Date of Charge Off: October 1, 2010 Balance at Purchase: $859.91 Purchase Date: July 29, 2011 Balance at Charge-Off: $859.91 Less Payments: $.00 Balance Due: $859.91 11-75785 GECL92 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, lV L. Moore 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 GE MONEY BANK F.S.B. / JC PENNEY ("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 July 29, 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 RAEGAN ZAMPELLI ("Debtor") to the Account Seller the sum of $859.91 with the respect to account number (************9338), as of October 1, 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 $859.91 as due and owing as of the date of this affidavit. P folio Recovery Associates, LLC By: UY • , Custodian of Records Subscribed and,5worn to before me on MAYA 0 2012 , 2012 Notary Public 11-75785 samerlaAnA6la 91e*we11 commonwealth of v?rginla Notary Public Commission No. 7509732 rely commission Expires 1113012015 This COMMLill ication is from a debt collector and is an attempt to colle=ct a. debt. Inv inf'orma.tion obtained will be used for that purpose. BILL of SALE PRA 120-day Mid Prime - July 2011 GE Money Bank For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in. the Agreement), delivered by Seller to Buyer on July 19, 2011, and as further described in the Agreement. GE Mone Bank ? r By: Title: CFO Retailer Credit Services Inc /??7 By: _, % Title: President General Electric Capital Corporation By: Title: Vice President GE Money Bank BILL of SALE PRA 120-day Mid Prime - July 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on 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 r.,,, or 0* 4 9- '7- at 9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson a Sheriff Jody S Smith Chief Deputy -% Richard W Stewart w Solicitor - Portfolio Recovery Associates, LLC Case Number vs. Raegan Zampelli 2012-3494 SHERIFF'S RETURN OF SERVICE 06/07/2012 04:02 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2012 at 1602 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Raegan Zampelli, by making known unto Mark Zampelli, Husband of Defendant at 3 Goldenrod Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. MI HAEL BAR ICK, DEPUTY SHERIFF COST: $34.00 June 08, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF C M ~ "`' ` ~i~~~~~~djA~t r O MON PLEAS OF CUMBERLAND COUNT'S, PA CIVILACTION-LAW ~;^~s~ ~~,n :~ . ~. -~ ~..~ L I i i ~ 0 ~ PORTFOLIO RECOVERY ASSOCIATES, LLC '`~_P`~3c~~..~t! COUNTY 120 Corporate Blvd t''=P~~SYL ANIA Norfolk, VA 23502 Plaintiff v. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 Defendant No. 2012-3494 PRAECIPE FOR DEFAULT JUDGMENT Filed on alf of Plaintiff Coun of ecord for this icooen N. colas, ~r., >/squire ~F ~u1z5~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 Qom} ~ ~ (~. ~ of Q ~~.~- ao q ~y 1 ~~ a ~ ~~~;I~d This camll~ul~icatian is fralj~ a debt callecta~• is an attclnpt to collect a debt. ~~ ~'1 A.Ixy i.I~farrnatic>n t:~bt<Iined ~~%ill he ~lsed far that }~rirl~~>sc. 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. 2012-3494 v. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, RAEGAN ZAMPELLI ,for failure to answer the Complaint. (X) Amount Due $859.91 Less Credits $.00 TOTAL $859.91 (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 noti a of intention to filet praecipe was mailed or delivered to the party against whom judg n is to be entered a to s/her Attorney of record, if any, after the default occurred and at t to days prior to the ate o the filing of this praecipe and a copy of the notice is attached. ,, Date: Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This comzl~unic~itioll is fro~n? a debt collector is ~~n attempt tc~ collect zx debt.. ~1~~% i.nfot~lnation {obtained ~r-i11 he t.14ed foa~ th~it 1-~rtrl~c~se. 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. 2012-3494 v. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 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 $859.91, plus interest, on . (X) A copy of all documents filed with the Prothonotary in support of By: If you have any questions regarding this Notice, please Date: a/ a party. attac Robert N. Polas, Jr., Esquire # 20125L/ 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 com~rj~w~icatial~ is fI•u~t~1 a debt collector is an attel~~tpt to collect ~ debt. A.I~y infarlxlatit:}n t:~btained ~~°i.ll be r~secl i:or that l~rtrpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 No. 2012-3494 Plaintiff v. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 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 3 GOLDENROD DR CARLISLE PA 17015 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. _ i Date: Robert N. Polar, Jr., Esquire' #2012: Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F)(757)518-0860 Attorneys for Plaintiff 11-75785 This colnm~~t~icatio~I is a debt collector al~ci is an atten~:pt to collect a d4~bte An}- inl'orn~Iatiol~ obta.inecl 4~i1.1 be usccl for tlxai puap<:~se. Department of Defense Manpower Data Center R"~~eee"` '~~`~32°,E"'°`3' scan zs i Statti~ Rtspc~rt P"ursua~tt to Seruieernembers Civil Relief Act Last Name: ZAMPELLI First Name: RAEGAN Active Dury Status As Of: Ju1-03-2012 +wee owr sw wu ~ww ovy Frr ~ aw s.vq» cma~,w O.+KLra 0.tr l . r~8. Wy ,?ben DMe tiA NA qb NA __. •-^^^-^-. 79vs rssponae reaapa Ure hM+fJUals' a five ddy ebbs bseetl an tla /wove o+M bgdus Owls .~._ , M NM Cv~ W.Mr~ Ht P,y, d aKxn. ~Y <uon Pwr +tctin <;wr 6+.., as. ...F-- ,:m.. a,p. E r an. T ssa. s.,+.. ~«.+w,.M NA lVM1 No NA 7ies!esppna eanxas Mwre ~iw inGlYq~oal kA uws dby sran~s 3e7 ~Y%P uw Fcws Prrtr S~aWe Pale 71h WRtrla fYet4,r lhMl vrr voran d,F,NaI+~UF nFtW PY4m Ayvl0~4 lrer Dab Order NplAUlkre 84<r Dale W, PdNN~nu~P~a Dar. Spi+1 _ ri! qb Ser•.ts fpryrpr~~rM1 ~_ tU ttda retyrape ralle4b vi,pyrp tlw gNlalAaYp raenrea unll hw rawrvad eMy nWM1eatlpe b report qtr eve dWy Upon seazching the data banks of the Department W Defense Manpower pate Cent, based on the informatkm that you provideq the above Is Iha status of the individual on the active duly status date es to all branches of the UMtormed Services (Army, Nary, Marina Corps. Air Forte, NOM, Public Health, and Goas1 Quard). This s€atus indudes Information on a Savicemember or bisiher un@ rocalving notification of future orders b report for Active Duty. "v'~4./~~r.~r Mary M. Snavety-Dixon, Director Department of Dehsnae -Manpower Data Center A 800 Mark Center Drive, Sulte d1E25 p fr1~~2350 TI7is cot~mut~icatic~n is ~ dtbt c-olleetor ~~tlci. i5 an attempt to cgllect ~ deft. ,~nyr in:fo~-nzatiot~ obtained ~,~ ill tie used tc;r that purpc:}se. Tl~~is coinmu~iicz~tion is a ~elat ~;ollector ~~:uc~ is an attempt to eolleut a t~e;bt. ~n}' in_fc~nx~atioi~ obtaizaec! ~~,>ill 13e usetf for that ~~.~rpcasc. PORTF0~1O RECOVERY ASSOCIATES, LL.C Litigation Department 140 Corporate Boulevard Norfolk, VA 23502 Telephone: (866} 428-8102 Fax: (757} 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST} June 29, 2012 RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 11-75785 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. RAEGAN ZAMPELLI 2012-3494 Dear RAEGAN ZAMPELLI: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvani Rules of Civil Procedure. Sincerely, _ - ~--_ .. a ~ti ~ _ ~ _ _ - 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 r. ~ ~~~: Tlxis cc~nu~unication is from a clehat collector is ~n attempt to collect a cleft. Aszv infarc~~ation ©btained ui.11 he used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. 2012-3494 v. RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 Defendant TO: RAEGAN ZAMPELLI 3 GOLDENROD DR CARLISLE PA 17015 DATE OF NOTICE: June 29, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY C OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE 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 ~-~ ~„ R ~, r., sq ire .~ Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff "I`Ixig coxnmunicatioxi. i~; f~•cxxxx a debt collector i~ .xxx attempt cox collc;ct a debt. Any infonxxataon obtained will be xised fo~° tlx~xt Ix~xrpo5e.