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HomeMy WebLinkAbout12-3444' Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 ii I i 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 140 Corporate Blvd. Norfolk, VA 23502 V. MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. Z-3q Ll 4 CiW You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty (20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, an filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ?M} %)03.7sad C t6l C 1z-it rco sl 0 1 `7 q-? 01 P.4 Q7S9bS ?3o? ?0 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. : MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demands 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 par Demandante. usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAVEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FUADA 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 debt collector at'td is an attempt to collect a debt. Arty information obtained will be used ?l(.)r that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA. 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 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 MARCIA A KREISER, is an adult individual with last known address of 920 N FRONT ST APT 5, LEMOYNE PA 17043. 3. It is averred that Defendant was indebted to CAPITAL ONE BANK N.A. on June 18, 2002 with account number ************9300 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A." 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 cotntnunication is fiom a debt collector and is ati attempt to collect a debt. ?rty information obtahicd will be used for 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 December 4, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest CAPITAL ONE BANK N.A. 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 $1,138.15. 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, MARCIA A KREISER, in the amount of $1,138.15, plus costs of this action and any other relief as the Court deems just and reasonabl Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-78569 This coinn7Lill ication is from a debt collector ant] is an attempt to collect a debt. Ariv infonnation obtained will be used tier that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mary L. Moore _ hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date : APP 2 Q 2012 11-78569 B : 1?V ry r once 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: ************9300 MARCIA A KREISER Account Holder: MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 Consumer Account Product Code: MC Issuer: CAPITAL ONE BANK N.A. Assignee: Portfolio Recovery Associates, LLC Account Number: ************9300 Date Account Opened: June 18, 2002 Date of Last Payment: December 4, 2010 Date of Charge Off: July 14, 2011 Balance at Purchase: $1,154.81 Purchase Date: August 15, 2011 Balance at Charge-Off: $1,138.15 Less Payments: $.00 Balance Due: $1,138.15 11-78569 CAPM04 This communication is from a collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Mary L. Moore 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 CAPITAL ONE BANK N.A. ("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 15, 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 MARCIA A KREISER ("Debtor") to the Account Seller the sum of $1,138.15 with the respect to account number (************9300), as of July 14, 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 $1,138.15 as due and owing as of the date of this affidavit. Recovery Associates, LLC Custodian of Records APR 2 0 2012 to before me on 4 92012 N Public Ayiesha Commonwealth N. of King Virginia Notary Public 11-78569 ) L(V Commission No. 7509711 MY Commission Expires 05/31/2015 ..This communication is from a debt collector and is an attempt to collect a debt. Any inforniation obtained will be used for that purpose. Ca, i One, N.A. 15000 hm on, V l One Drive Richmond, VA 23238 Bank Exhibit 1 to Forward Flow Receivable Sale Agreement dated June 30th, 2010 BILL OF SALE Closing Date: August 15, 2011 Capital One Bank (USA), National Association ("Seller"), in consideration of a Purchase Price of $. i other valuable consideration, the receipt of which is hereby acknowledged, hereby sells, assigns and transfers all right, title and interest in the Accounts identified in the Sale File entitled 20110608.PS56CP.SLDFLEI.TXT (which may be in electronic form) to Portfolio Recovery Associates, LLC ("Buyer"), without recourse or representation except as expressly provided herein or on the terms, and subject to the conditions, set forth in the Agreement (as defined below). This Bill of Sale is delivered pursuant to that certain Forward Flow Receivable Sale Agreement, dated as of June 30th, 2010, by and between Seller and Buyer (the "Agreement"). All capitalized terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such terms in the Agreement. The Cutoff Date for the Sale File was August 10, 2011. The aggregate Unpaid Balance of the Accounts as of the Cutoff Date was $ -- CAPITAL ONE BANK (USA), NATIONAL ASSOCIATION By: Nam • onathan Stalls Title: SVP C44 A" 0 # 501343 Your account works differently now that you`re 7 payments late. Please see the next page for important account information. .-.............. - ...... Pagel of 2 1-800-258-9319 --- -- - -- - - - --` www.capitalone.com/solutions Jun. 14-Jul. 13, 2011 30 Days in Billing Cycle 1 IMPORTANT ACCOUNT UPDATES Platinum MasterCard 9300 your full balance is due. An ent ou make will reduce our balance and hel YAaI`m Y Y ppay off NEW BALANCE PAYMENT DUE DUE DATE yourde6tfaster.lheamount}rouowemaydiNerrfyou'veenteredinto aseparatepayment i agreerrent. $1,138.15 $1,138.15 PAST DUE ! Available Credit 50.00 I Previous Balance Payments and Credits Fees and Interest Charged 51,085.29 - 50.00 + 552.86 } TRANSACTIONS PAYMENTS, CREDITS & ADJUSTMENTS FOR MARCIAA KREISER #9300 FEES `- 1 1' ILL PAST DUE FEE $35.00 Total Fees This Period $35.00 Total Fees This Year $231.00 INTEREST CHARGED INTEREST CHARCE PURCHASES 517.86 Total Interest This Period 517.86 Total Interest This Year $108.82 Transactions New Balance 50.00 ---\I - ? 51,138.15 -, Help is Available. Just pick up the phone. Call 1-800-2S8-9319 and a specially trained agent will be happy to help you check your balance and make payments. INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) s the annual interest rate on your account. Type of Balance Annual Percentage Balance Subject to Interest Charge Rate (APR) Interest Rate Purchases', 19.80% 51,097.37 51i 86 gash24.90;6 D 50.00 SO 00 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO V MN.CAPITALONE.COM/SOLUTIONS TO MAKE YOUR PAYMENT ONLINE. Account Number: 300 Due Date New Balance Amount Enclosed Past Due $1,138.15 300 Manage your account online. Visit www.capitalone.com/solutions to manage your account online. Have information at your fingertips 24/7 without picking up the phone. 4crooaa MARCSA A KRETSER 920 N FRONT ST APT 5 LEMOYNE, PA 17043-1036 111.111111.1III,1111111' 1' 1-PIIPP1IIII I -III[IIIIhllIll.III Capital One Bank (USA), N.A. P.0 Box 71D83 Charlotte, NC 28272-1083 nIIIIlrlnrrn111rhrI1lPll^IInlPrllrldlirllr?llhllll?hll Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. lkow can i avoid paying Interact Chargas7 Each month you pay your 'New Balance" in full, you will have a minimum grace period of 25 days with no interest charge on all new 1) Purchases, 2) balance transfers, 3) special purchases and 4) oche,- charges. If you have been raying your account in full with no interest charges applied and you do not pay your next bill u fu !I, prorated interest charges will be assessed. There is no grace period on cash advances, S'K'A! transfers, or on any rew transaction when there is an unpaid balance from a previous bill Row is the Interest charge appiieci7 Interest charges accrue from the 1) date of the transaction, 2) date the transaction is processed or 3) first calendar day of the billing period Interest charges accrue on erery unpaid amount until it is paid in fun This means you may owe merest charges even if you pay the entire -New Balance- one month, but did not do sofor the previous month. Unpaid interest charges are added to the proper segment of your Account. rowayer, we reserve the right to not assess interest charges at any time. Do you assess a Minimum Interest Char(R? Yes. A minimum INTEREST CHARGE of 50.50 will be assessed for each billing period your account is subject to an interest charge crow did you Calculate the Interest Charge? There are several calculations that are used to determne your total interest charge. 1. To get your Daily Balance: For each segment, 1) take the beginning balance and add in new transactions and the periodic interest charge on the previous day's balance. 2) Subtract any payments and credits for that segment as of that day. The result is the daily balance for each segment. However, if you paid your previous month's ca!ance in full (or if your balance was zero or a credit amount), new transactions which post to your purchase or speual purchase segments are not added to the daily balances. Also, can=.jctions that are subject to a grace period are not added to the daily balances. 2. To find your Average Daily Balance. 1) add the daily balances together and 2) divide the sum by the umber of days in the billing cycle. 3 Estimate your Total Interest Charge 1) multiply your average daily balance by the daily periodic rate and 2) multiply the result by the number of days '.n the billing period. NOTE Due to rounding or a minimum interest charge, this calculation may vary from the interest charge actually assessed. Is the. "Payment Due" a Payoff Amount? No. All stated amounts are owed on the date of the statement. However, because interest, late charges and other charges might change from day to day as provided in your customer agreement, the amount due on the day you pay may be larger For example, it you pay the amount stated in this statement, your account might still have a balance after your payment is received. Also note that the amount you owe may differ 6 you've entered into a separate payment arrangement. Please call the number on the front of t'e statement for an exact payoff amount. How can my variable Annual Percentage Rate L" change? Your APR may increase or cecrease based on one of seven standard indices reported in The Wall Sbeet7ouma/. To find which index is used for your account, look for a code (P, L, C, S, D or F) on the front of this statement next to the APR(s) Then check the table below. Code next to your When your Annual Annual Percentage Index which your rates are based on Percentage Rate Rate (APR) will change P 111III Quarterly Prime+ margin previously disclosed to you The first day of the L Quarterly LIBOR+ margin previously disclosed to you billing periods that G Quarterly GD+ margin previously disclosed to you and in January April, S !3ankcard Prime + margin previously disclosed to you July and October D by Prime+ margin previously idis 6etl to you The first day of each F Monthly LIBOR + margin previously disGosed to you mon[hty billing G Treasury LIBOR + margin previously disclosed to you period Are there Additional Fees associated with try account? Yes, under certain orcumstamces, you may he assessed a Late or Returned Payment Fee. You may also be assessed overlimit fees d permitted by law. You will also be required to pay all of our actual collection expenses, Mtormeys' fees and court costs unless the law does not allow us to collect these amounts. we reserve the right to not assess fees without prior notice and without waiving our right to assess a similar fee later. wbat happens if my Account is 5usgended7 we may close or suspend your account and your right to obtain credit at any time and for any reason, even if you are not in default. Account suspension can be permanent or temporary. If your account is closed or suspended ycu must 1) stop using your credit card and account, 2) cancel all automatic payments, 3) clestloy all credit cards and access checks, and 4) pay all amounts you owe us, even d they were charged after the account was closed or suspended How do I Make Payments? Payments you mail us will be credited to your account as of the business day we receive them, as long as 1) you send the bottom portion of this statement and your check in the enclosed remittance envelope, and 2) your payment is received in capital One's processing centers by Spot local time. Pease allow at least seven (7) business days for mail delivery Mailed Payments received by Capital One at any other beacon or in any other form may not be credited as of the day they are received. Do you Process Paper Checks as an Electronic Funds Transfer? When you provide a check as payment, you authorize us and our agents either to use information from your check to make a one-time electronic fund transfer from your deposit account or to process the payment as a check transaction When we use information from your check to make an electronic fund transil funds may be withdrawn from your deposit account as soon as the same day we receive your payment and you will not receive your check backfrom yourfinanclal institution. Your authorization is not limited by the date on the check. We may resubmit and electronically collect the returned payments what if I file for Bankruptcy? d you are entitled to bankruptcy protection, this communication is for information only, it is not an attempt to collect, assess or recover a debt or claim. Do not send us payments without speaking with your bankruptcy attorney or the Bankruptcy Court N you have questions about your account or bankruptcy proceeding, please have your attorney contact us. If you or your attorney would like to contact our bankruptcy claim s'enrcer directly, please contact. capital one PO Sox 30285 $a t Lake City, UT 84130-0285 BILLING RiGHT5 SUMMARY (Does Not Apply to small Business Accounts) what to Do If You Think You Find A Mistake on Your Statement: N you think there is an error on your statement, write to us a t. Capital One P O. Box 30285 Salt Lake City, UT 84130-0285 In your letter, give us the following information. Account information Your name and account number Dollar amount The dollar amount of the suspected error. Description of Problem' If you think there is an error on your bill, desionhe what you 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 potential errors in_w[iting. You may call us or notify us electronically, but it you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we invesngate whether or not there has been an error, the following are true. We cannot try to collect 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. But, d we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. White you do not have to pay the amount in question until we send you a notice about the outcome of our investigation, you are responsible for the remainder of your balance. Your Rights If You Are Dissatisfied With Your Credit Card Purchases. If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true. 1 You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not quaafy, 2. You must not yet have fully paid for the purchase if all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at. Capital One P.O. Box 30285 Salt Lake City, UT 84130-0285 While we investigate, the same rules apply to the disputed amount as discussed above After we finish our investigation, we will tell you our decision. At that point, 0 we think you we an am urt and you do not pay we may report you as delinquent Capital One supports information privacy protection'. see ourwebsne, at vu,vAV capralone. com Capital one is a federally registered service mark of Capital One Financial Corporation. All rights reserved lu 2010 capital one TC-10 0x3111 l To change or update your address please call 1-800-258-9319 or visit www.crapitalone.com/solutions 200866 Now that your account is 7 payments past due, the changes detailed below will apply to your account. Hopefully, these changes will make it easier for you to take control of your finances again. Capita, Your balance is still due and you'll be contacted soon to discuss options for resolving your debt. You are responsible for paying the full balance on your account as well as any associated collections expenses as provided in your customer agreement, unless the law where you reside does not allow us to collect such expenses. If we continue to send you statements, you'll now receive them quarterly instead of monthly. We may continue to report the status of your account to the credit bureaus, unless prohibited by law. We will also report when your account is paid off. Help is available. We understand that it can be challenging to manage your finances. Here are three important facts about your account that may help make it easier for you to repay your balance: 1) Highest interest balances are paid first: You will no longer be charged past due, over limit, or membership fees. 2) No more compound interest: Future interest charges will never accrue interest-making it easier to pay down your debt faster. 3) Regular payments will resolve your debt: Since your interest doesn't compound, making regular payments will get your balance paid. Call 1-800-258-9319 to discuss your options. If a third-party agency is already managing your account, your call will be automatically routed to them. Remember, you can check your balance and make payments online any time at www.capitalone.com/solutions. W Help is available. Just pick up the phone. Call 1-800-258-9319 and a specially trained agent will be happy to help you check your balance, make a payment and answer any questions you may have. CD 2011 Gtpital One. Capital One is a federally registered ;rewire murk. All rights reserved. Capital One® Customer Agreement Welcome to Capital One.-,, Thank you for opening a credit Card Account with us. This Customer Agreement ("Agreement") contains the terms for your Capital One credit Card. Some Definitions. The meanings of the terms you see in italics appear in the Glossary Section. To make the Agreement easy to understand, we will also use the following personal pronouns: "You," "your" and "yourself" mean each applicant and co- applicant for the Account; any person responsible for paying the Account; and anyone You authorize to use, access or service the Account. It also includes an Authorized User as defined in the Glossary Section. "We," "us," "our" and "Capital One" mean Capital One Bank (USA), National Association; and its agents, authorized representatives, successors, and assignees. Account Documents. Your Account with us is governed by the following documents: (1) this document; (2) all Statements; (3) all rewards information and documentation if your Account has rewards; (4) any Privacy Notices describing our limitations on sharing information about you with others; (5) your Card benefits brochure which describes benefits provided by the Payment Card Network for your Card and Account. The most current version of your Card benefits brochure will replace all prior versions; (6) the "Security" Agreement if you have a secured Card; (7) all disclosures and materials provided to you before or when you opened your Account, including Truth in Lending Disclosures; (8) all other documents and disclosures relating to your Account including those provided online; and (9) any future changes we make to any of the above things. Please read these carefully and keep them for future reference. An image of any of these can be used instead of the original. New Offers. In the future, we might make new offers to you or forward offers from others that we think you might be interested in. These offers may have new or different terms and documentation for these offers will be provided when we make you the offer. If you accept the offer, your previously disclosed terms will still apply except as modified by the offer. Account Information. We need information about you to manage your Account The information we need includes: (1) your legal name; (2) a valid U.S. mailing address and residential address (if different); (3) your date of birth; (4) your social security number or other government identification number; (5) your telephone number(s); and (6) your employment and income information. You must tell us when this information changes. Please update your address in the manner provided on your Statement. You may also update some of this information by logging onto your Account on our website or by calling one of our representatives at the telephone number provided on your Statement or on the back of your C.'ard. We may require you to provide additional documents that are acceptable to us to verify this information or any changes. We maintain the right to restrict or close your Account if your information cannot be verified or if you do not provide additional information as requested. Your Revolving Credit Line and Spending. Your Account features no over limit Fees for additional spending flexibility. While transactions in excess of your revolving credit line will not result in an over limit Fee, they will be immediately due and payable in your next periodic Statement. The revolving credit line is the maximum amount you can borrow and choose to repay over time. Transactions and Fees in excess of your revolving credit line may not be honored. If honored, however, they will be subject to this Agreement. Any transactions honored in excess of your revolving credit line will riot result in an increase of your revolving credit line unless we expressly notify you otherwise. Your initial revolving credit line will be disclosed when your Account is opened. Unless required by law, we may increase or decrease your revolving credit line at any time without prior notice to you, may limit the credit available for Cash Advances or may take away your ability to obtain Crash Advances. Your current revolving credit line will be identified in your periodic Statements. Using Your Account. You promise to follow the terms of this Agreement as long as your Account remains open or has a balance. Please sign the Card immediately when you receive it. The Card is valid during the dates provided on the front. The Card is our property, and you will return it to us or destroy it if we ask. You will take reasonable steps to prevent the unauthorized use of your Card and Account. We are not responsible if anyone refuses to accept your Card for any reason. Also, we may reject any transaction for any reason. Unless we tell you otherwise, we will bill each transaction to the applicable Segment of your Account and apply it against your available credit limit for the Account and Card for that Segment in each Billing Cycle. You may also obtain Cash Advances and Transfers if they are permitted for your Account. Unless we agree, you may not use a Transfer to transfer amounts from other Accounts with us or any other company within the Capital One organization. You must not use, or try to use, the Card for any Internet gambling transactions or transactions that are illegal or not permitted by us. You will still be responsible if you do. In addition, these transactions will be subject to this Agreement, and you might have to reimburse the Payment Card Network and us for all damages and expenses. From time to time, due to circumstances beyond our control (such as system failures, fires, floods, natural disasters or other unpredictable events) our services might be unavailable. When this happens, you might be unable to use your Card or obtain information about your Account. We will not be responsible or liable if this happens. Rewards. Your Account might provide you with the opportunity to earn rewards. If it does, we will separately provide you with all information and terms about your rewards. We will include on your Statements all rewards you have earned. It might take up to two Billing Cycles for your earned rewards to appear on your Statement. Using Your Access Checks. When we provide you with Access Checks, we will tell you whether we will treat them as purchases, Balance Transfers, Cash Advances or Special Transfers. Only the person we designate may use Access Checks. Access Checks may not be used to pay any amount you owe us or any other company within the Capital One organization. We may reject and not pay any Access Check for any reason. Some examples of reasons why we may reject and not pay include: your Account is delinquent, charged-off, bankrupt, lost/stolen or closed;. our fraud system prevents the offer fulfillment; your Account is overlimit; or the checks have expired. Any liability for our wrongful dishonor of an Access Check will be limited to your actual damages and will not exceed the amount of the Access Check. When you use an Access Check, you will have fewer rights to dispute merchant transactions than with other uses of your Card. Please see the "Billing Rights Summary" part of your Statement and your other Truth in Lending Disclosures for more information. Stopping Payment of Access Checks. You may request a stop payment on any Access Check by contacting us as provided on your Statement. We may charge you a Fee to stop payment as described in the Interest Charges and Fees section. If you call us to stop payment, you must also send to us a written request within 14 calendar days. We will have a reasonable amount of time after your stop payment request to research the situation and complete it. We will not be responsible if we cannot complete the stop payment because the Access Check was already paid, you do not give us the information we asked for or the information you gave us was incorrect. If we cannot stop payment for these reasons, we may still keep the stop payment Fee. Once we complete a stop payment, we do not have to release the stop payment order unless the same person asks us to. If we re-credit your Account after paying an Access Check following a valid stop payment order, you give us all of your rights against the payee or other holder of the paid Access Check. You also agree to help us in any actions we might later take against that person. Using a PIN. We may give you a personal identification number (PIN). For security reasons, you might have to provide the PIN before you are able to complete some transactions using the Card. With a PIN, you may use your Card to: (1) obtain cash from certain automated teller machines (ATM) or (2) make purchases at certain merchant or retailer point-of-sale devices (POS). You may do these things if the ATM or POS requires entry of a PIN and displays the logo of the Payment Card Network on your Card. We will treat all ATM transactions as Cash Advances and all POS transactions as purchases. You should keep your PIN secure and not write it down, give it to anyone, or keep it. with your Card. If you lose your Card or believe that someone has gained unauthorized access to your PIN, you must contact us immediately. Authorized Users. You may ask us to add one or more Authorized Users with additional Cards on your Account. If we agree to your request, we will need certain information about the Authorized User to manage your Account. This will be the same information you provided about yourself as described in the Account Information Section. We may limit an Authorized User's ability to initiate certain transactions. If we do, we will tell you about these limitations before adding any new Authorized User on your Account. Once we acid an Authorized User to your Account, we may discuss your Account with them and provide them with Account information. You will be responsible for the Authorized User's use of the Card and your Account as well as anyone else they allow to use your Card or Account. This will be true even if you did not want, or agree to, the use. Removing an Authorized User. If you want to remove an Authorized User from the Account, you must contact us as provided on your Statement and request their removal. We will have a reasonable amount of time after your request to research the situation and remove them. Y'ou also must immediately destroy all Cards in their possession and cancel all of their billing arrangements to the Account. We will not do this for you. During this time, you still will be responsible for all amounts they charge to the Account. You will be responsible even if these amounts do not appear on the Account until later. An Authorized User may remove themselves from the Account upon request. We may close your existing Account and/or issue a new Card with a new Account number. Your Promise to Pay. You promise individually and jointly to pay us all amounts due on your Account. This includes amounts where you did not sign a purchase slip or other documents for the transaction. If you use your Card number without presenting your actual Card (such as for mail, telephone or Internet purchases), this will be treated the same way as if you used the Card in person. If you let sorneone else use your Card, you are responsible for all transactions that person makes. Your promise to pay us will apply to your estate if you die. Statements. We will send you one Statement for all Cards on your Account unless the law does not require or permit us to send a Statement. Statements will be sent at the end of each Billing Cycle when your Account has a debit or credit balance of more than $1.00, or if we have charged any Interest Charges to your Account. Your Statement will show all transactions billed to your Account during the Billing Cycle along with other important Account information. Disputed Transactions. You must inspect each Statement you receive and tell us about any errors or questions you have as described in the "Billing Rights Summary" part of your Statement and other Truth in Lending Disclosures. If you do not notify us as provided in those disclosures, we may assume that all information in the Statement is correct. If you dispute a transaction made by you or someone else on your Account, and we later credit your Account for all or part of the disputed amount, you give us all of your rights against that other person. You also will: (1) give us any merchandise or other purchases you received in connection with the disputed amount if we ask; (2) not pursue any claim or reimbursement from the merchant and that other person; and (3) help us pursue and get reimbursement from the merchant and that other person; your help includes giving us documents that we ask for and that are acceptable to us. Interest Charges and Fees. We will charge Interest Charges and Fees to your Account as disclosed to you in your Statements and other Truth in Lending Disclosures. In general, Interest Charges begin to accrue from the day a transaction occurs. However, we will not charge you interest on any new balances posted to the purchase Segment of your Account provided you have paid your previous balance in full by the due date. We will treat the following Fees as purchase transactions unless otherwise specified below. These Fees apply to your Account only if they are provided in your Truth in Lending Disclosures. We may increase your Interest Charges and Fees as described in the Changes to Your Agreement section or in your Truth in Lending Disclosures. • Membership Fee_ We may charge you this Fee as early as your first Billing Cycle or the first Billing Cycle after this Fee becomes effective. If it is an annual Fee, we may then charge it approximately once per year. If it is a monthly Fee, we may charge it once in each Billing Cycle. This Fee is payable in advance even if you do not use your Account. • Late Payment Fee. We may charge you this Fee if we do not receive your payment in time for us to credit it by the due date shown on your Statement. • Returned Payment Fee. We may charge you this Fee each time any payment you make to us is not paid by your financial institution for any reason, even if that institution later pays it. • Returned Access CEheck Fee. We may charge you this Fee if we do not pay an Access Check for any reason, including when your Account is in default, overlimit, suspended or closed. • Stop Payment Fee. We may charge you this Fee each time you request us to stop payment on an Access Check or you renew an existing stop payment order as provided in the Stopping Payment of Access Checks section. • Copying Fee. We may charge you a per-page Fee for copies of transaction documents or Statements unless they are required in resolving a billing dispute. • Cash Advance Fee. We may charge you this Fee each time you obtain a Cash Advance. This Fee will be treated as a Cash Advance transaction. • Transfer Fee. We may charge you this Fee each time you obtain a Transfer. This Fee will be treated either as a Special Transfer or purchase transaction depending on the Segment in which the Transfer posts. Transactions Made in Foreign Currencies. If you make a transaction in a foreign currency, the Payment Card Network will convert it into a U.S. dollar amount, The Payment Card Network will use its currency conversion procedures in effect when it processes the transaction. The conversion rate in effect on the processing date might differ from the rate in effect on the transaction or posting date. We do not currently adjust the currency exchange rate or charge any additional currency conversion Fees. No Warranties. Except as otherwise provided in the "Billing Rights Summary" part of your Statements, we are not responsible for any claim you might have regarding the purchases of goods or services made with your Card. Merchant Refunds. If you are entitled to a .refund for goods or services purchased with your Card, you will accept these refunds as credits to the purchase Segment of your Account. We do not control when a merchant sends us your refund. We will also have a reasonable amount of'ime after we receive your refund to process it. Minimum Payment. Your Statement will provide instructions for making payments, including the amounts due and the due date for receiving your payment. If applicablE:l, your Statement will also include a minimum payment amount. To avoid a late payment Fee, you must pay us at least this minimum payment amount by the due date provided in the Statement. If you exceed your revolving credit limit, we may request a higher rninimum payment from you. In addition to the minimum payment, you may pay all or part of the total balances on your Account. However, you must still pay at least the minimum payment amount each month, even if you paid greater than the minimum on the previous Statement. We will continue to charge Interest Charges during Billing Cycles when you carry a balance regardless of whether your Statement includes a minimum payment that is due. If your Account is 180 days past due, part of a bankruptcy proceeding or otherwise charges off, the entire balance is immediately due and payable. Making Payments. Your payments must be in U.S. dollars from a U.S. deposit account and otherwise be acceptable to us. We do not accept cash payments through the mail. You may not make payments with funds from your Account or any other credit account with us or any other company within the Capital One organization. Mailed Payments. You must mail payments to us at the address provided on your Statement or as otherwise instructed by us or our agents. We will credit it to your Account on the day we receive it, if: (1) you send the payment coupon included with your Statement in the same envelope with your payment; (2) you include your Account number on your payment; and (3) your payment arrives at the address indicated on the payment coupon in our processing center by the time indicated on your Statement. If your due date occurs on a day on which we do riot receive payments, any payment received the next day which conforms to the above requirements will not be treated as late. Please allow at least 7 days for postal delivery. Unless we or our agents specifically instruct you to rernit payment in a different manner, payments received at any other location or in any other form might not be credited for up to 5 days. This might cause you to be charged late payment Fees and additional Interest Charges. Faster Payment Services. We may make services available that allow you to make faster payments through a customer service representative using a telephone, the Internet or other payment system. We will describe the terms for using these services before you use them. You do not have to use these other payment services, and we may charge you a Fee for using them. If we do, we will tell you the amount of the Fee at the time you request the service. We are not responsible if a payment made using our payment services is rejected or not paid. Even if it is, we may still keep the Fee. If you give your Account number or other Account information to someone else to make a payment for you, we may provide Account information to them and process their payment as if you made it. We may refuse to accept any payment made by someone else for your Account. If we accept a payment made by someone else for your Account, you will be responsible for the payment made even if that payment is rejected or not paid. Payment Processing. We may accept and process payments without losing any of our rights. Even if we credit your payment to your Account, we may delay the availability of credit until we confirm that your payment has cleared. We may resubmit and electronically collect returned payments. We may also adjust yourAccount as necessary to correct errors, to process returned and reversed payments, and to handle similar issues. When you provide an Item as payment, you authorize us either to use information from your Item to make a one time electronic fund transfer from your deposit account or to process the payment as an Item. We will provide additional information about. this process on your Statement or other documents we send you before your payment. You may contact us and ask that we not process your future Items in this way. When you provide an Item as payment, it might also be converted into an electronic image and collected and returned electronically. These electronic images may also be converted to substitute checks. We will not be responsible if an Item you provide has physical features that when imaged result in it not being processed as you intended. How We Apply Your Payments. We apply your minimum payments to lower Annual Percentage Rate balances before higher ones. We apply any portion of your payment, in excess of your minimum payment, to higher Annual Percentage Rate balances before lower ones. Items with Restrictive Words, Conditions or Instructions. All Items that have restrictive words, conditions, limitations or special instructions added (including Itcrns marked with the words "Paid in Full" or similar language) and all accompanying communications must be mailed to and received at: Capital One, P.O. Box 30285, Salt Lake City, UT 84130-0285. If you make your payment or send any accompanying communications to any other address, we may accept and process the payment without losing any of our rights. Credit Balances. We may reject and return to you any payment that creates a credit balance on your Account. Any credit balance we allow will riot be available until we confirm that your payment has cleared. We may reduce the amount of any credit balance by any nevv amounts billed to your Account. You may contact us as provided on your Statement and request a refund of any available credit balance. If you contact us in writing, we will refund your credit balance within 7 Business Days from our receipt of your written request. Account Default. We may consider you in default of your Agreement with us if: (1) you do not make any payment when it is due; (2) any payment you make is rejected, riot paid or cannot be processed; (3) you exceed, and fail to immediately repay the amount over, your revolving credit line by the following due date; (4) a bankruptcy or other insolvency proceeding is filed by or against you; (5) you die or are legally declared incompetent or incapacitated; (6) we determine that you made a false, incomplete or misleading statement on any of your Account documentation, or you otherwise tried to defraud us; (7) you do not comply vvith any term of this Agreement or any other agreement with us; or (8) you permanently reside outside the United States. For certain actions, including changing the rates and Fees on your Account, our options appear in our original offer materials when you opened your Account. Remember, paying the Fees charged in connection with a default will not by itself cure the default. In addition, if you are in default, we may take the following actions without notifying you, unless the law says that we must notify you: (1) close or suspend your Account; (2) lower your credit limits; (3) increase your minimum payment; (4) demand that you immediately pay the entire balances owing on Your Account (for example, as described in the Minimum Payment section); (5) continue to charge you Interest Charges and Fees as long as your balances remain outstanding; and/or (6) pursue any other action against you that the law allows, which includes the filing of a lawsuit against you. You must pay us all of our collection expenses, attorneys' fees and court costs unless the law does not allow us to collect these amounts. Communications. We may contact you from time to time regarding your Account. We may contact you in any manner we choose unless the law says that we cannot. For example, we may: (1) contact you by mail, telephone, email, fax, recorded message, text message or personal visit; (2) contact you using an automated dialing or similar device ("Autodialer" ); (3) contact you at your home and at your place of employment; (4) contact you on your mobile telephone; (5) contact you at any time, including weekends and holidays; (6) contact you with any frequency; (7) leave prerecorded and other messages on your answering machine/service and with others; and (8) identify ourselves, your relationship with us and our purpose for contacting you even if others might hear or read it. Our contacts with you about your Account are not unsolicited and might result from information we obtain from you or others. We may monitor or record any conversation or other communication with you. Unless the law says we cannot, we may modify or suppress caller ID and similar services and identify ourselves on these services in any manner we choose. When you give us or we obtain your mobile telephone number, we may contact you at this number using an Autodialer and can also leave prerecorded and other messages. We may do these things whether we contact you or you contact us. If you ask us to discuss your Account with someone else, you must provide us with documents that we ask for and that are acceptable to us. Credit Reports. We may provide information about you and the Account to consumer (credit) reporting agencies and others as provided in our Privacy Notices. Information we provide might appear on your and the Authorize Users' credit reports. This could include negative information if you do not comply with the terms of this Agreement. We may obtain and use credit and income information about you from consumer (credit) reporting agencies and others as the law allows. Closing or Suspending Your Account. You may ask us to close your Account by calling or writing us as described on your Statement. Your Statement will provide additional information about this process, and we may also separately provide you with additional details after your request. This might include payment information. If you use your Card or charges post to your Account after you ask us to close it, we may keep it open or reopen it. We may close or suspend your Account and your right to obtain credit from us. We may do this at any time and for any reason, permitted by law, even if you are not in default A suspension of your Account might be permanent or temporary. If your Account is closed or suspended for any reason, you must stop using your Card. You must also cancel all billing arrangements to the Account. We will not do this for you. If we close or permanently suspend your Account, you must also destroy all Cards. You must still pay us all arnounts you owe on the Account, even if they are charged after your Account is closed or suspended. Lost or Stolen Card. You will take reasonable steps to prevent the unauthorized use of your Card and Account. If your Card is lost or stolen or if someone else might be using it without your permission, you must tell us at once. You may tell us by calling the telephone number on the back of your Card or on your Statement or by writing us at the address on your Statement. You will not be responsible for charges made to your Account that are found by us to be unauthorized. If we reimburse your Account for unauthorized charges made using your Card, you will help us investigate, pursue and get reimbursement from the wrongdoer. Your help includes giving us documents that we ask for and that are acceptable to us. Changes to Your Agreement. At any time, we may add, delete or change any term of this Agreement unless the law prohibits us from doing so. We will give you notice of any changes as required by law. If we do notify you of changes, we will send you a separate notice or inform you on your Statement. We may send this notice to you electronically as permitted by law. Our notice will tell you when and how the changes will take effect and describe any rights you have in connection with the changes. Your variable Annual Percentage Rates (if applicable) can go up or down as the index for the rate goes up or down. If we increase your Interest Charges for any other reason we will notify you in writing. If we increase your Fees or other terms of your Account we will notify you in writing and inform you of your options in advance, including the right to opt out of some of these changes. We may increase your Interest Charges for new transactions and your Fees after the first year of the Account. Also, if your payment is not received) within 60 days after the payment due date, we may increase your Interest Charges and Fees for existing balances and new transactions at any time. We may change any other terms of your Account at any time. The Law that Applies to Your Agreement. We make decisions to grant credit and issue you a Card frorn our offices in Virginia. This Agreement will be interpreted using Virginia law. Federal law will be used when it applies. You waive any applicable statute of limitations as the law allows. Otherwise, the applicable statute of limitations period for all provisions and purposes under this Agreement (including the right to collect debt) will be the longer period provided by Virginia or the jurisdiction where you live. If any part of this Agreement is found to be unenforceable, the remaining parts will remain in effect. Waiver. We will not lose any of our rights if we delay taking any action for any reason or if we do not notify you. For example, we may waive your Interest Charges or Fees without notifying you and without losing our right to charge them in the future. We may always enforce our rights later and may take other actions not listed in this Agreement if the law allows them. You do not have to receive notice from us of any waiver, delay, demand Or dishonor. We may proceed against you before proceeding against someone else. Assignment. This Agreement will be binding on, and benefit, any of your and our successors and assigns. You may not transfer your Account or your Agreement to someone else without our written permission. We may transfer your Account and this Agreement to another company or person without your permission and without prior notice to you. They will take our place under this Agreement. You must pay them and perform all of your obligations to them and not us. If you pay us after you are informed or learn that we have transferred your Account or this Agreement, we can handle your payment in any way we think is reasonable. This includes returning the payment to you or forwarding the payment to the other company or person. Glossary. -'Access Check" means any check we send to you to access your Account. We may also refer to an Access Check as a "convenience check" or a "purchase check." -"Account" means your Card Account with us. -"Authorized User" means one or more persons who may use the Card but is not responsible for the repayment of the Account. "Balance Transfer" means a Transfer posted to the purchase Segment of your Account unless otherwise described in your Truth in Lending Disclosures. -"Billing Cycle" means a period of time that might vary in length but is approximately 30 days. The specific period of time is described on each Statement. However, you will have a Billing Cycle even if a Statement is not required. We will often specify a Billing Cycle by the month in which its closing date occurs as provided on the Statement. For example, a "March Billing Cycle" will have a closing date in March. We may also refer to a Billing Cycle as a "Billing Period." If your Account balance has charged off, we may switch to quarterly Billing Cycles to your Account. -'Business Day" means any day in which Capital One's offices are open for the processing of payments and credits. -"Card" means any Capital One credit Card associated with your Account, which includes all renewals and substitutions. It also means any other access device for your Account we give you that allows you to obtain credit, including any Account number and any Access Check. -"Cash Advance" means using the Card to obtain loans in cash or things we consider cash equivalents. Cash equivalents include wire transfers, travelers' checks, money orders, foreign currency, lottery tickets, gaming chips and wagers. Cash Advances are posted to the Cash Advance Segment of your Account and not to your purchase Segment. -"Fees" means charges imposed on your Account that are not based on the Annual Percentage Rates. -"Interest Charges" means any charges to your Account based on the application of Annual Percentage Rates. -"Item" means a check, draft, money order or other negotiable instrument you use to pay your Account. This includes any image of these instruments. This does not include an Access Check. -"Payment Card Network" means Visa Inc., MasterCard International Incorporated, or any other network provider displayed on the Card. -"Segments" means the different parts of your Account we may establish that are subject to unique pricing, grace periods or other terms. We create these parts of your Account for such things as your purchases, Cash Advances and Special Transfers. -"Special Transfer" rneans a Transfer Posted to the Special Transfer Segment of your Account and not to your purchase Segment. -"Statement" means a document or information we provide to you showing Account information including, among other things, transactions made to your Account during a Billing Cycle. We might also refer to your Statement as a "Periodic Statement" or a "Billing Statement." -"Transfers" means balances transferred from other Accounts to this Account and includes: Balance Transfers and Special Transfers. -"Truth in Lending Disclosures" means any Account information we provide to you that is required by the federal Truth in Lending Act and Regulation L. These include your application and solicitation disclosures, Account opening disclosures, subsequent disclosures, Statements and change in terms notices. (0 2010 Capital One Capital One is a federally registered service mark. All rights reserved. Capit? " 058 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff n ; t? i r Jody S Smith Chief Deputy Richard W Stewart Solicitor v,,,,ta p{ utrttsrp ?b l ,???41 r -JF'' BED ,tLk,t'D t,OUN PEWISYL`/WilA Portfolio Recovery Associates, LLC VS. Marcia A. Kreiser Case Number 2012-3444 SHERIFF'S RETURN OF SERVICE 06/04/2012 07:42 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 4, 2012 at 1942 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Marcia A. Kreiser, by making known unto herself personally, at 920 N. Front Street, Apartment 5, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $44.00 June 06, 2012 RYAN BURGETT, DEW --N SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. ..~L_~.D-El~~#=tC~ ~~ .~~ ~ lid i'R~TFl~NQTA Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW ~~~~ ~~~ , ~ ~~ 2~ PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff v. MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 Defendant Date: °~~~~a-~ couNr~ ~~NNSYLVANlA No. 12-3444 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf of Plaintiff Counsel ord for this P y Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any izrforznation obtained will be used for that pzzz~pose. Q~ ~ Ck~ ~a I Co. S~o~d af~ ~~3(o i ~~~3ac~ ~~ ~~~ 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. 12-3444 CIVIL v. MARCIA A KRRISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, MARCIA A KREISER ,for failure to answer the Complaint. (X) Amount Due $1,138.15 Less Credits $.00 TOTAL $1,138.15 (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/ ear Attorney of record, if any, after the default occurred and at least t ys prior to the date t fling 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 communication is from a debt collector is an attempt to collect a debt. Any information obtained will. be used 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. 12-3444 CIVIL v. MARCIA A KREISER . 920 N FRONT ST APT 5 LEMOYNE PA 17043 . Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered agalinst you in the amount of $1,138.15, plus interest, on . ~, ~ ^r (X) A copy of all documents filed with the Prothonotary in support of t~ ithi If you have any questions regarding this Notice, please con t filing party. Date: ~ /i1 Robert N. Polas, Jr., Esquire # 201259 Carne A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is frotal a debt collector is an attctnpt to collect a debt. Any information. t:~btained will be used }'or thaC l~tupose. ~.. i PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 140 Corporate Boulevard Norfolk, VA 23502 Telephone: (866} 428-8102 Fax: (757} 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) June 25, 2012 MARCIA A ICREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 11-78569 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. MARCIA A KREISER 12-3444 CNIL Dear MARCIA A ICREISER: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Robert N. Poles, Jr., Esquire Carrie A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff # ~~ This communication is from a debt wllectar is an attempt to collect a debt. any infonnatinn obtained will 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. 12-3444 CIVIL v. MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 Defendant T0: MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 DATE OF NOTICE: June 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 COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIII~SS 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 OR 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 HIRWG 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 Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff -Chic cotntnunication is from a debt collector is au attempt to culled a debt. Any inforn~aiion obtained will ba used for that pumase. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 No. 12-3444 CNIL Plaintiff v. MARCIA A KREISER 920 N FRONT ST APT 5 LEMOYNE PA 17043 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 920 N FRONT ST APT 5 LEMOYNE PA 17043 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: 11-78569 Robert N. Polas, Jr., Esquire, #2012: Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This cornmilnication is a debt collector and is an attempt to collect a debt. A.ny informatiarl obtained will be used for that purpose. Department of Defense Manpower Data Center $apart ~tn~aa~at to 3t~,~cas Cavil Rirlit>rf Act Last Name: KREISER First Name: MARCIA A Active Duty Status As Of: Jul-23-2012 fteauib ea d :.A~F23.2012 ~ ~ ~ ~ Tf1ia 11ap01W laeaE~ 611 ~IdiM~i~ My' fA I~ ~Mf/ load dl Ala ~1Y~ ~Y a~i ~a,~ NA lVl~ No lJ/t Thk raapafala rsMcb wfrra' tlu 4kiNdnN N0. adlw dolt aiaMn wMhln 367 dqs pwaailkp fln Acaw Ou1y Sladrp OaM raA I ~ 1 No I IJA 1 Ttrls repom. raasaea aNnOwr we IndNidual «nw/w udl n.. noaihd «rk noMwaan q nrral4« acdw dirt I 1 Upon searching the dam baMcs of the Dapartrnarrt or Osrenss Manpower Gala Center, based on the InkonnaUon that yoo provided, the above is the st of the ir~viduei on the active dt>ty amtlrs dam as to aN lxancltes of the Ur4lbrrned Servkxs (Army Navy, Martne Corps. Ak Foroe. NOAH, PubNc Health, Cowl t3uaM}. This smlua includes ir>•ormsdon on s Servicarrwmbsr or ttasRrer unit rocsivurg ralili~ion of firhiro orders to report /or Active Duty. N-wr. ~. ,a.~,_~.. Mary M. Srrevely-0ixon, Director Department or De/ense - Mar-pcwver Dam Center 4800 Mark CerrNer Drive, Sins 04F.25 ~~yJ~22950 Tha Defense Manpawet Data Canter tDMDC) b an orgarNZation of the Department of Defense {DoD) Meat mafMdns ttm Deksrras ErxoNrrient and Reporting 3ystan {DEERS) database which is tha oftk~ai eowtx of data on eNg~iNty for m'd'itary medical cars and other eNgibNity aYatsmS. The OoD strongly supports the eraforcernent of the Servkxnrombsrs CMN Relief Act (50 U3C App. § S01 et seq, as amended) (SCRA} (tamerty known as the Sokfiers' and Sailors' ChrN ReNsf Ad of 1940}. DMDC has issued hundreds of Uiousarde of "daa rrot poassss any intormatbn ir-dimsting that the individual ie currently on aura duty" responses. and has sxperiervcsd ony a amaM emsr rata. M the want tlae individual referertcsd abgw, or any (army msrtabw, friend, or rspreeerdatlva assorts in any mennar Mael the individual vas on active duty for the active duty status date. of is otlw~wdae entitled to iM prolsctloras of tM SCRA. You are strong encaaaged to obtain furttrsr vertlicatlora of the parson's status by contactlng that person's Ssyvice via fhe "defeerraeNrakmil" URI: fatgtJlwww.detiraatink,miUfatypiNPCOBSLDR.hhrd. M you have BvicNr>ce 1M person urea on active duly for iM derive +iuty atatw dale and you fail 6o abfsin this addNionel Service veriNcstiaa. punitive prravvisions of tl~s SCRA may be irnroked againd you. Sae 30 USG App. § 521(c). TNa response -eNects the toNowing intorrnation: (1) Ths individual's Active Duty atria an the Ardivs Duty Status DaN (2) Whetlaer tt-s irdividtuA bR Actb Duty stMus vvitisin 38T days preceding the Adiw Duy 3taha Data (3} YVtaelher the individuM or blather unit reeeiwd eery rvotiNcatla~ b report for active duty on the Artlva Duty Stsbra Date. More information on "Active Dury Status" Active dory status ~ roporbd in this ate is deNraed in acrbrdance with 10 USC § 101(d) { 7 }. Prior b 2010 only some of the swtiva duly periods k than 30 conseioutlve days ~ length vvsre avaNaWs. to the rase of a member of the tVatlonal Guard, tlMe irrctudes servios under a caN to ~fivs service autlwrized by the President or the Secrehry of i)afense under 32 USC § S02(Q for pugaoses of rWpordmg to a rtaticnN errNrysrwy declared by the Presidar-E and supported by federal funds. AN Actlva t3uaM Reserve (AQ#t) rrwrnbers nenK be assigned sgakrst ~ autlmrized mobN~ttion position in unit d>eY aupparl. This includes Navy Training arx! AdmlNstrrNbn of the Reserves (TARS)„ Marina Carpe Adhre Reserve (ARS) and Coast Guard Rase Program Admkaiatrelor (t~^As). AdMs Duty stator also appNee to a Unronned Service member who is an active duty commiasionsd oA9csr of the U.S. Public Fie.Nh service a the Natknal Oceanic and Atnaosptaeric Admkrktratlon (NOAH Canmtssionsd Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the sCRA is broader to some casa+t and irrchadat some categories of persona on active duly for of the SCR/i who wand not repaMd ~ an Actlvs Dury under ~ certNkxte. SCRA prntectlorts are for TNte 10 and Title 14 sctlve dory -eoorde for aN the Unifomisd Services psria Title 32 psrioda of Active Duty ors not covered by SGRA, ~ defkasd in aocardance with 10 USG § 101(dxt ). Many tkraea order ens amended to edarxi tlve period of active duty. vrfak;h would saderd SCRA protectlaaa, Persona seeking to rayon tlais webabe certidicatkan should chedt to make aura the a~xs on vvMch SCRA protections an based have tort lasso amended b saMnd the kaeJusiYS daNe of serv Futlsenraors, some proter4foras of the SCRA may eaderd m persona vviso have raeeived orders to rpsoR for adNe duly a to be kduc~ed, but vvtw have aau~ry begun active duty or actuaNy rsporbsd for inducdcn. The L~ Date on Active Dury entry is irraportent because a raamber of prodsrkions of the S extend bsyorx! the last dates of active dory. Tfase who could rely on this arrtiNcats are urged to seek quaNlfed Mgal oouneei to ensure that aN rigFMs guaranteed tp Service rtNrrrbeRS under the are proter4ed WARNING: This certiflcab vvae provtrNd based an a lard name. SSN, and ar4ive duty status daM provided by the rer•u+sater. Providkag erroneow irrfonrwdora wiN cause an srronsora certlNcata io 6e provided. 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