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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. (2?? aoolbVs -0 it 1 F'D sip '94-a7S9? 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 PRAIRIE RIO6E At JCPenney, providing you with an improved stropping experience matters. Join us at our new location in the Shoppes of Prairie Ridge. Shop your new store where you'll find great brands, great services and something else to love - skincare, color and fragrance at Sephora inside JCPenney. 10225 77th Street S E P H O R A= Pleasant Prairie, W1 53158 JCPenney AJENN ccoui tENumber:T 841 CustomerSelrvice: a1t-jcp.800com/credft 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 At JCPenney, providing you with an improved shopping experience matters. Join us at our new location in The Village at Fairview. Shop your new store where you'll find an incredible selection of furniture for every room in your home. Plus, discover something else to love - skincare, color and fragrance at Sephora inside JCPenney. SEPHORA = 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 scRa ~.2.2 ~ ~, Ttia ra~paw nMeed Yia iidirieuaN adM A/y >~ bind on pr AW.r duy 9dYw dad I ~ 1 -u I Ne I ~ I I I rnrs nw.~d wrw. r» ednAdur hAt adiw duy gaka wMn dB7 dy. PAW ~ kM ~Y 9dda ~+ I I No I rndnaiponaarwwwh.Yi«wsirdwsw«bwM.yawn.anawrwynoMldtlenlo..portf«.dwdu9~ 1 ~ +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