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HomeMy WebLinkAbout12-3913Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. 77 Norfok VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff q 17 , 1t'L4'A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 ASSOCIATES, LLC No. _-3 cl13 eivi I V. REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Plaintiff Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action 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 Q ' (800) 692-7375 This communication is from a debt collector and is an attempt to collect a debt. Ck ?N9 Any information obtained will be used for that purpose. a "? 10 d 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. REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 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 elate contra usted. usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 This colnnlUnication is from. a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 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. REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant REBECCA BEAMER, is an adult individual with last known address of 37 CREEK RD, CAMP HILL PA 17011. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / GAP on December 2, 2007 with account number ************2251 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A." 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. This cone-nunication is from a debt collector and is an attempt to collect a debt. Any information obtained 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. 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on December 17, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / GAP 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 $3,393.28. 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, REBECCA BEAMER, in the amount of $3,393.28, plus costs of this action and any other relief as the Court deems just and reasonab 41 Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-77172 This conirnunication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used fbr 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 unswom falsification to authorities. ??M Date : JUN 0 6 2012 y: Marv L_ Moore Custodian of Records 11-77172 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: 1-866428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************2251 REBECCA BEAMER Account Holder: REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / GAP Assignee: Portfolio Recovery Associates, LLC Account Number: ************2251 Date Account Opened: December 2, 2007 Date of Last Payment: December 17, 2010 Date of Charge Off: December 15, 2010 Balance at Purchase: $3,393.28 Purchase Date: October 28, 2011 Balance at Purchase: $3,393.28 Less Payments: $.00 Balance Due: $3,393.28 11-77172 GECM68 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 CAPITAL RETAIL BANK / GAP ("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 October 28, 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 REBECCA BEAMER ("Debtor") to the Account Seller the sum of $3,393.28 with the respect to account number (************2251), as of October 28, 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 $3,393.28 as due and owing as of the date of this affidavit. Po 'o Re o ery sociates, LLC By; Moore, Custodian of Records JUN 0 6 2012 Su c ' an sworn to before me on of , 2012 Notary Public i 11-77172 ?Ayiesha N. King mmonwealth of Virginia Notary Public 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 information obtained will be used for that purpose. 0. GE Money Bank BILL of SALE PRA 120-dav MMd Prime - October 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 October 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) f By: Title: Manager Finance ces Inc Retail2; By: Title: President General Electric Capital Corporation By: Title: Vice President 1&?CM-48' 10F41- 0 GE Money Bank BILL of SALE PRA 120-day Mid Prime - October 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 October 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) By: Title: CFO Retailer Credit Services Inc By: Title: President General Electric Capital Corporation By- Title: Vice President ?jEa?+68 7•f 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Rebecca Beamer t OFF IC .; .F zF FRO 1 i7OK !r", 2112 JUL -9 AM 43 CU PE"S LVAMIA Case Numb, 2012-3913 SHERIFF'S RETURN OF SERVICE 06/29/2012 05:33 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to la , states that on J 29, 2012 at 1733 hours, he served a true copy of the within Complaint and Noti , pon the within n defendant, to wit: Rebecca Beamer, by making known unto herself personally, t 3 Creek Road, CE Hill, Cumberland County, Pennsylvania 17011 its contents and at the s ' e h nding to her pers the said true and correct copy of the same. + SIJAWN HARRISON, DEPUTY SHERIFF COST: $43.00 July 05, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Defendant . .~ ~; ~, No. 12-3913 CIVIL ~~ ~ • z~ c' r ~~ PRAECIPE FOR DEFAULT 20 3 JUDGMENT Tf ~ ~ -.{ N .,.~ LJ Filed on Behalf of Plaintiff Counsel ofi~ord for this P -*z r- -, ~s ~ ; -~ t- r*; . _~ 1 ~ ~~ /. Date: Robert N. Polar, 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 Q~ a~~.501'd '"- Ck.# a~g'y ~~a $ 1'l~is cc~mmG~nication is from a debt callectar is :gin r~tternpt tc~ ec~llect a debt. Any inf'ot~-nation obtained will be used lc~r that p~irpose. (~ `0~ ~~ 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. 12-3913 CIVIL v. REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, REBECCA BEAMER ,for failure to answer the Complaint. (X) Amount Due $3,393.28 Less Credits $.00 TOTAL $3,393.28 (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 bee d and to his/her A e of record, if any, after the default occurred and at least ten days r t the date of the fil' g of is 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 Phis comm~ulication is from a debt collector is an attempt to collect a debt. .~lny 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. 12-3913 CIVIL v. . REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter been entered against you in the amount of $3,393.28, plus interest, on . (X) A copy of all documents filed with the Prothonotary in support of the n jud ttached. ^.r~'"~ sy: _ If you have any questions regarding this Notice, please contact the filing Date: $ a7 ~ a 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 0 .r t is~ ,' 'Phis cc~mmi~nication is from ~~ debt collector is an attempt to collect a debt. ,~lny information obtained will be used hi~r 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. 12-3913 CIVIL Plaintiff v. REBECCA BEAMER 37 CREEK RD CAMP HII.L PA 17011 Defendant AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for plaintiff, herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 37 CREEK RD CAMP HILL PA 17011 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. Polar, 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 11-77172 '~Clris corr~rnuriicatioi~ is a debt collector and is an attempt to collect a debt. :1n_v i~~formation obtained will be used for that purpose. Department t7f Deft3nse MailpOwer Data Can#er ResNtsssot:Aupb,3x2o,294. a:,, sc a z.a P~trtwa~t t~ ~~ct~ber~ Civil ~teliief Aat Last Name: REAMER Firs# Name: REBECCA Middle Name; Active Duty Status As Of: Aua•13-2012 a, ~uw. Doer. ow -,~aa.ONy etMw Dr. _~ - .~wsaNtr ~trt ore acw. wry >:~ v.r s4an ` e«vte. ~+oa+.r~ NA ru `, F~ NA itch resparsee re M1ea4Cse.R~tlirte~' antra daH it6eu tnsed on M At;Wy Steen Date LNS+titM't f1AY l~q,lrt SQf Oete of M'~vtA+lY~11Wk UMbr AtYhe ANY 3t,rf Pa1r F.cMre R(y End t7rR- atYLx tirrria (.OrrponM TTda tafponae ralleCq r'f+M ttN u'dMdi~N test +rc Wt duy''~M, 9?7 den ixaradinp Me kcgwih+~Y Stalut Date tifr MeraperOr}~iM t11+N Waa EroylyCtfi Pyl!r1C:,IHtrY-M.1+r1~g1~7 pff>Ilda-UA~;lilM Opts lM1er rloUlutlf~ e,.n Oete Order WotNluioo t°nd Dab serve tie.NC1 CongMV++t NA NA ND NA t'hia reapaxro relRerAa wheM+er rfyt~yf tMR~e. unit nrr received co report ~r ealNe duty ~_ Upon searching the data banks of the Department of Defense Manpower Ds€a t^etntar, based on the ittformatiatt that you pravfded, the above is the st of the individual on the active duty status date as to a8 britches of the Urdtarrned Services {Army, Navy, Matins Corps, Air i=arcs, NOAA, Public Health, a Coast Guard). Thisstains lrtcludes iMormation an a Servicemember or blather unit receiving notifiGaNon of future orders to report for Active Duty. a!lYaR Maty M. Snavely-Dixon, Dir~tor Department of Defense -Manpower Data. Center 4800 Marls Center Drive, Suite 04E25 Arlington, VA 22350 11-77172 The Defense Manpower Data Center {DMDC) is an organization of the Department of Defense {DoD) that maintains the Defense Enrolimemk and Reporting System {DEERS) database ~nfiich is the afficiel source of data on eligitrdky for military medical care and other eligibility systems. The DoD s#rongly support the enforcement of the Servicerrrembers Civil Relief Act {50 USC App. § 5a1 et seq, as amended) {SCRA} {farmerty known a~ the Soktiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicatkrg that the individual is rxtrrernly an active duty" responses, and has experienced only a smelt error rata, in the avant the individual referenced above, or any family member, friend, or reprexerr~tive asserts in any manner that the krdividr~l was an active duty for the active duty status date, or is otherwise entitled to th protections of the 5CRA, you are stranger encouraged to obtain further verfication of the pers~l's status by contacting that parson's Service via the "defenselink.mil" URL: http:/lwww.dafenseiink,miltfag/p~lPC09SL~.htmf. if yea have evidence the parson was on active duty for ties active duty status date and you fail to Main this additional Service verification, punitive provisions of the SCRA may be irn+aked against you. Sae 50 USC App. § 521(c). This response reflects the folkrxing kmformation: {1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual keft Duty status within 38i days preceding the Active Duty Status Date (3) Whettrer the individual ar his/her unit received early nodticatian to report far a duty on the Active Duty Statux Date. More information an '"Active Duty S#atus" Active duty status as reported in this certificate is detkred in accord~rce with 1 a USC § 1at(d} (1), Prior to 2010 only some of the active duty pedodx it than 3a cans~utive days in taragth wore avaNabbe. In the case of a member at the Natiorral Guand, this hrcludas service under a caH to active service authorized by the President ar the Secretary of Defense under 32 USG §502{f) far purposes of responding to a national emergency declared by the President and supported by Feder fursda. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilizatron position in unit they support. This includes Navy Treining and Administretion ~ the Reserves (TARs), Marine Corps Active Reserve (ARa) and Coast Guard Rese Program AdmsnisUator (RPAs). Active Duty status also apples to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service ar the National Oceanic and Atmospheric Administration (NOAA Commisskxred Corps}. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in same cases and includes earns categories of persons orr active duty for puryxoses of the SCRA who wauid nit reported as on Active Duty under this certificate. SCRA pn#ecKions era for Title 10 and Title 14 alive duly records for all the Unifarrred Services peria~ Tide 32 periods of Active Duty are not cxrvered try SCRA, as defined in arcardance with 10 USC § 1a1(d){1 ). Many times orders are amended to extend the period of active duty, which vrouk! extend SCRA proter~iorrs. Persons seeking to rely on this wetrxite asrtificatian atroukt check to make aura the Driers on which SCRA protactiorrs are based have not been amended to extend the inekrsNe dates d sarv Furthernore, same protections of the SCRA may extend to parsers who have received orders to report for active duty or to ba inducted, but who have actually begun active duty or actually reported for induction. The t.ast Date on Active Duty entry is important because a number of protections of the S extend beyorrd the last dates of active duty. Those who cook! rely an this certificate are urged to seek qualified legal counsel to ensure that aN rights guaranteed to SenAce members under the are protected WARNING: This certificate was provided based on a Isst name, SSN/date of birth, and alive duty status data provided by the requester. Providing erronaora7 information wNl canaase an erroneous certificate to be provided. Certificate iD: 34iC723O1 P PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 " Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) July 25, 2012 REBECCA BEAMER 37 CREED RD CAMP HILL PA 17011 11-77172 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. REBECCA BEAMER 12-3913 CIVIL Dear REBECCA BEAMER: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsyl Rules of Civil Procedure. Sincerely, 4 Robert N. Polar, Jr., Esquire Came A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff• ~~ This; c«mmunication is fro~r~ a debt collector is an attempt to collect a clc.bt. ~1ny information obtained will be used for that pu~t~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. 12-3913 CIVIL v. REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 Defendant TO: REBECCA BEAMER 37 CREEK RD CAMP HILL PA 17011 DATE OF NOTICE: July 25, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COUR'. YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WTTHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICI CAN PROVIDE YOU WTTH INFORMATION ABOUT HIlZING 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 Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff ~I-his coinmunicatio~~ is ti-om a debt collector is ar,~ attcm~it to collect a debt. Any inti~rmation obt~~ined will bt used for that putpn~s.