HomeMy WebLinkAbout12-3448Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie A. Brown, Esquire PA Bar # 94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd t •i:?? TA
.
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
V.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Defendant
NOTICE
,e;t.3?`?g Ci?t l
No.
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.
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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.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
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
ELGI13LE 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 frorn a debt collector and is an attempt to collect a debt.
Anv information obtained will be used Ear 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.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Defendant
COMPLAINT
Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with
offices located at 140 Corporate Blvd., Norfolk, VA 23502.
Defendant JENNIFER SMITH, is an adult individual with last known address of 808
GRANTHAM RD, MECHANICSBURG PA 17055.
It is averred that Defendant was indebted to GE MONEY BANK F.S.B. / JC PENNEY on
September 19, 2004 with account number ************4884 (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.
'( hiS co?m111LInication is from a debt collector and is aii atteml-.it to collect a debt.
Any information obtained will be used for that Pur}x;se.
6.
8.
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 July 30, 2010.
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."
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
$1,319.77.
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, JENNIFER SMITH, in the amount of $1,319.77, 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
11-80845
This ccnnmLill ication is from a debt collector and is an attempt to collect ,r d bt.
Any ird'onnation obtained will be used tor that 11ur110se.
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 : APR 2 0 Zn1Z
.
B o? O?)
0 L. Moom
Custodian of Records
11-80845
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 : ************4884
JENNIFER SMITH
Account Holder:
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Consumer Account Product Code: PVT
Issuer: GE MONEY BANK F.S.B. / JC PENNEY
Assignee: Portfolio Recovery Associates, LLC
Account Number: ************4884
Date Account Opened: September 19, 2004
Date of Last Payment: July 30, 2010
Date of Charge Off: March 7, 2011
Balance at Purchase: $1,319.77
Purchase Date: September 30, 2011
Balance at Charge-Off: $1,319.77
Less Payments: $.00
Balance Due: $1,319.77
11-80845
GECM50
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 , Custodian of Records, for Portfolio Recovery Associates, LLC hereby
depose, affirm and state as follows:
I am competent to testify to the matters contained herein.
2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing
business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and
practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is
based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's
records, including a review of the business records transferred to Account Assignee from 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 September 30, 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 JENNIFER SMITH ("Debtor") to the
Account Seller the sum of $1,319.77 with the respect to account number (************4884), as of March 7, 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 $1,319.77 as due and owing as of the date of
this'affidavit.
s, C
Custodian of Records
APR 2 0 2012
to before me on of 72012
Ayiesha N. King
ary 15ublic Commonwealth of Virginia
Notary Public
Commission No. 7509711
11-80845 My Commission Expires 05/31/2015
This communication is from a debt collector and is an attempt to collect a debt.
Any intorniation obtained will be used for that purpose.
GE Money Bank
BILL of SALE
PRA 180-day Mid Prime - September 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 September 20, 2011, and as
further described in the Agreement.
GE Money
By; Bank C/
Title: CFO
Retailer Credit Services Inc
By: G../
Title: President
General Electric Capital Corporation
By,:
Title: Vice President
C71MV450 1 of 2
BILL of SALE
GE Money Bank
PRA 180-day Mid Prime - September 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 September 20, 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. J-- q_1
Title: Vice President
c NTv 2 ,f 2
W?.
sa0- OF
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PO Box 965009 Orlando FL 32896-5009
Summary of Account Activity
Previous Balance
- Other Credits
New Balance
Credit Limil
Available Credit
Statement Closing Date
Days in Billing Cycle
Payment Information
$1,319.77 New Balance $0.00
$1,319.77 Minimum Payment This Period $461.00
$0.00 Amount Past Due $0.00
Total Minimum Payment Due $461.00
$1,200.00 Payment Due Date 0311012011
None
Late Payment Warning: If we do not receive your minimum
03/07/2011
payment by the date listed above, you may have to pay a late
28 fee up to $35.00.
rrans acuun summary
Tran Balance
Date Reference Number Type Description of Transaction or Credit Amount
03/07 F9119002200999990 R CHARGE OFF ACCOUNT-PRINCIPALS ($1,013.83)
03/07 F911900220D999990 R CHARGE OFF ACCOUNT *FINANCE CHARGES' ($305.94)
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
03!07 INTEREST CHARGE ON PURCHASES $0.00
TOTAL INTEREST FOR THIS PERIOD $0.00
2011 Totals Year-to-Date
Total Fees Charged in 2011 $0.00
Total Interest Charged in 2011 $50.18
Merest Charge Calculation
our Annual Percentage Rate (APR) is the annual interest rate on your account.
Annual Balance
Expiration Percentage Subject To Interest Balance
rpe of Balance Date Rate Interest Rate Charged Method
egular NA 23.99% $0.00 $0.00 E
PLEASE NOTE YOUR MAILED PAYMENT MUST BE RECEIVED BY 5 P.M. (ET) OR YOUR IN-STORE PAYMENT MUST BE
RECEIVED DURING STORE HOURS ON THE DUE DATE.
NOTICE: Your payment may be converted into an electronic debh. See reverse for details, Billing Rights Information and other
important information.
PLEASE DETACH AND RETURN THIS STUB WITH YOUR CHECK PAYABLE TO GEMS.
Account Number: 41
Total Minimum Amount Past Due Payment New Balance
Pa ment Due Due Date _ _
$461.00 $0.00 03/10/2011 $0.00
u ¦¦ I p FILL IN TOTAL PAID $ ? ? ? ? [I. ? ?
fll'II,I?I IN I?®'°'"? NI New address or email? Print changes on the back.
JENNIFER L SMITH
B08 GRANTHAM RD
MECHANICSBURG PA 17055-5880
P.O. Box 960090
Orlando FL 32896-0090
5433 A1R 1 5 7 1.10307 ZX PACE 1 of 3 9119 3400 MI5 01EA5433
AS FRIRMFW
301 East Stacy Road
Fairview, TX 75069
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THE BEn UTY ITY
Cardmember News & Information
Please Note: Enclosed is the Privacy Policy for this account. Please take a moment to read it, then keep it vhth other financial
documents. If you have previously exercised your choice under the policy, you do not need to do so again.
5433 AIR 1 5 7 110307 Z X PAGE 2 of 3 9115 3400 MI75 01EA5433
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
,r
OFFICE o ThE -`-EP.irF
.. °.
l.?!?i`I two°3 t.:
aEhv'
Portfolio Recovery Associates, LLC
vs.
Jennifer Smith
Case Number
2012-3448
SHERIFF'S RETURN OF SERVICE
06/01/2012 04:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 1
2012 at 1645 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jennifer Smith, by making known unto Ronnie Smith, Husband of Defendant at 808
Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
June 06, 2012
X:fz
STEPHEN BENDER, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
Icj CountySuite Sheriff. Teleosoft. Inc
~. ~,~.M
IN THE COURT OF COMMON PLEAS OF CUMBERLA1vD COUNTY, PA ~j
CIVIL ACTION -LAW ~,~ ~~~' 1} ~~ J' 0~
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 Corporate Blvd
Norfolk, VA 23502
Plaintiff
v.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Defendant
Date:
~~~ PE NKSYLYbN1
No. 12-3448 CIVIL
PRAECIPE FOR DEFAULT
JUDGMENT
Filed on Behalf of Plaintiff
Counsel of rd for this Pa
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
a~`~'
C~ ~`
This communicatio~i is from a d~cbt collector is an attempt to collect a debt. ~~
Any inforlnatic:m obtained. will. be I.ISed t'or that Parpose.
~Q
~,3 -Ii
s7`l3'~
~ ~~
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. 12-3448 CIVIL
v.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, JENNIFER SMITH ,for failure to
answer the Complaint.
(X) Amount Due $1,319.77
Less Credits $.00
TOTAL $1,319.77
(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 Attorney of
record, if any, after the default occurred and at least t s prior to the date a ing of this
praecipe and a copy of the notice is attached.
Harp. ~ 1 ~ ~ 1~~
Robert N. Polas, Jr., Esquire # 212
Carrie A. Brown, Esquire, #94055
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
(T) 1-866-428-8102
(F) (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector is an attctnpt to collect a debt,
Any irlformation obtained will. be used. for that prtl~pose.
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. 12-3448 CIVIL
v.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
Defendant
NOTICE OF JUDGMENT
(X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in
the amount of $1,319.77, plus interest, on .
(X) A copy of all documents filed with the Prothonotary in support of th hen ju t attached.
;.;;.
By: __ ~
If you have any questions regarding this Notice, please
Date: ~ ~ ~ ~O"
the filing party.
Robert N. Polar, Jr., Esquire # 201259
Carrie A. Brown, Esquire, #9405'5
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 i'or that ptupose.
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 $ AM to 11 PM, Friday 8 AM to 9 PM,
Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST)
June 28, 2012
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
11-80845
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. JENNIFER SMITH
12-3448 CML
Dear JENNIFER SMITH:
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Penmsyivania
Rules of Civil Procedure.
Sincerely,
(~q~,~ ~ 4~..~ ~~
Robert N. Poles, Jr., Esquire
Came A. Bmwn, Esquire
Attorney ID# 201259/94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA
Attorneys for Plaintiff
This communication is fmm ~ debt collector is an attempt to collect a debt.
Any information obtained tivill be utiecl fir that purpose.
[N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION -LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
140 Corporate Blvd. .
Norfolk, VA 23502 .
Plaintiff No. 12-3448 CNIL
v.
JENNIFER SMITH
808 GRANTHAM RD .
MECHANICSBURG PA 17055
Defendant
TO: JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
DATE OF NOTICE: June 28, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WCTH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UAILESS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT M~IY 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 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 ]~
~,~~ ~ ~~
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
'this conununication is tivtn a dobt culk~ctor is an attempt to calle~a a debt.
Auy information obtained will be u.~ceci far that purpose.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION -LAW
PORTFOLIO RECOVERY ASSOCIATES,
LLC
120 Corporate Blvd
Norfolk, VA 23502 No. 12-3448 CNIL
Plaintiff
v.
JENNIFER SMITH
808 GRANTHAM RD
MECHANICSBURG PA 17055
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
808 GRANTHAM RD
MECHANICSBURG PA 17055
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:
Robert N. Polas, Jr., Esquire, #2012:59
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
11-80845
This communication is a debt collector a.nd is an attempt to collect a debt.
Any information obtained tivi]..1 be used for that purpose.
Department of Defense Manpower Data Center
~ Rtepo~t
~ $e~vicemle~nbea I~il Relief Act
Last Name: SMITH First Name: JENNIFER
Active Duty Status Rs Of; Jui-23-2012
fteau~ as d : ,A~i-23-207204:42:10
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~ +ng the dam banks of iha Departrnant a oefenea Manpower Data carter, ixased on the iniorrnation that you provided, the above is the of
the on sM aahro duty ataan dsN as m ail brand>es at the Unnamed sarvkxis (Amry, Navy, Marine Corps. Air F«a. NOM; PubNo Hedlh, an
Cowl Guard). Thin status inriudes irMOrma6on on s 5enriaernernbsr or hidherunit roaming nodlicatlon of luturo orders to report far A1~ive Duty.
Mary M. S~nevely-Dixon. Director
DepMtnlsnt of DaderKe -Manpower Data Center
4800 Mark CerrMr Drive, Suits 04E25
~n2350
The Detente Mer-power Data Cengrr {DfJDC) is an organization of the Departrrrsnt o/ Defeats {DoD) tttaR makrtakts the Detense EnroNnwerrt and
Reporting System {DEERS) datatraae which is the otik~ai saxes of dab on eYg~7ity for military mewl care and otlrsr eHpibilky eysESma•
The Do0 strongly support the entoroerrtent of the Servicernerr~bers CtvN Reief Ad (56 USC App. §501 et seq, as amended) (SCRA) (lorrrterty krawn a
the Soldiers' and 3ailsors' Civil Reisf Ad of 19~W). DMDC has issued hundreds of ttausan~ d "does rat possess any intamatlon indicating that the
individual ~ ctrrerMly on acfhre duty" -eapornea, and tna expxierrasd ady a amai errer rats. In tM event the irKkvMt~ rafeserrad aiypw, a any /amity
mernlrer, fiiarrd, a npreserrOaWe assert ~ any manner Ihei the individual yore on active duly for the adiw duly status dab, or t oths-wiae entllkd b it
protectbrrs of tM SCRA. you ors atrwrgy encouraged b abtakt hxttrer verYicttlon of the peraart`s status by contctlng that peroon's Ssrvk,e va the
"detsrrseink.md" URL: tgtp~Jlwww.dsdirgeiink.m~il'tacYP~C~IOR.hMA. fl you have svidstrce the parson was on adiwt qty for tM actve daly stew
date arrd you tai b obtin This adddionai Service +reriicaFfeorr. punitive provision of the SCRA may bs invoiced agair~d you. See 50 USC App. ~ 521 {c).
This reapone rollsets the foiosirrg irtformatlai: {t) The individual's AcOvs Duty atak» on the Acthre Duty Statue Date (2) tMretlrsr thee.. individual bft
Duty statrm rvitlrin 387 dsys precedkrg fM Aciiw Duty Status Dab (3) VYtNther tM individual or blether unit received early rrotlication b report for a
duty on the Actlva Duty Status Date.
Mare information on "Active Duty Status"
Alive duty stsbw as roporbd in this certYlcats is defined in accordarree with 10 USC § 101(d) {7 ). Prior b 2010 only some al the adivs duty periods k
tfear+ 30 cornsautlv+s days in length were available. In the tress of a member at 8re Natforail Gusrd, tlris ndudss service under a tnN to segue servke
autharizad by tta President or the 3arxedsy of Dsfaree tmrbr 32 USC § 502(f) tar pueposes of rpponding b a natiorrai emergeray dedered by the
President and supported by Federal funds. Ai Act•ve Guard Reserve (AGR) rrnmbera rant be assigned against an authoriza~d mobiMraBor- poaltlon in
unit they support. Thh~ includes Navy Trairrirrg and Admirtistratlon of the Reserves (TARs)a, Merkrs Caps Active Reserve (ARs) and Coast Guard Rase
Program Adminiatrabr {RPAe)_ Active Duty status also apples b a lkrlformsd Serviw rrrernber who is an ectlw duty cummissiorred ollicar of the U.S.
Public FIseIMr Service a the Natfarel Oceanic and Atmospheric Admkratratlon (NOAH Commissioned Caps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA rs broatlx h some cases and includes some categories of parsons on acNw duly for purposes of the SCRA who would not
reported as ar AcBvs Duly under tht oertllkate. SCRA protoctlona are ta• Tills 10 and Title 14 actlvs duly reoo+ds br ai tits UNtamed Services pert
Title 32 period of Active Duty are net covered by SCRA, as def4red in acwrdanas with 10 tiSC § 101(dx1).
Meng tlmes order aro amended b exosrrd the period o/ active duty, which would extnd SCRA proladiona. Persons seeking b rely on'this MrebsNs
certan shortld ohedc b make sure the orders on which SCRA protectlons aro based treys rat been amended b etdrnd tlts irrdutive dates of sexvi
FixBrennars, some proMrdians of the SCRA may extend b persona who have raaw~ ordeiro b report for active duty or b 6e irrirrcted. but who trove
ac~ly begun active duty or aduaiy reportd for indudbrr. The Last Dots on Active DcAy entry is important because a nraN,rer of protedlorts of the Sa
extend bsyorM the fast dates of active duty.
Those who could rely ar this carfilfcatt ere urged to seek qua 'idled legal leanest b errrwis that aN rights guffianted b Service rtnmbera under the SCI
are protecdrtd
WARNING: This certlticate was prwided based on a lad name, SSN, and ac~iiva duty status dabs prevkfed by She requester. Providing erroneous
informatlon veil core. an erroneous cerlfReat b be provided.
Report ID: 4UDPF6GUTR