HomeMy WebLinkAbout12-4102Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie A. Brown, Esquire PA Bar # 94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: 757-518-0860
Attorneys for Plaintiff
2012 JUN 29 PM 1: 14
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.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
Defendant
NOTICE
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 / J
This communication 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.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
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 SERV ICIOS 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
1-1hi.s cunrimunication is ffil m. a d6t collector anti is an attempt to collect ',I
Any inliornnation obtained % ill lie Lr?c l i()r dint pin-pose.
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.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
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 JOSE MARI, is an adult individual with last known address of 512 W MAIN ST,
WALNUT BOTTOM PA 17266.
3. It is averred that Defendant was indebted to GE MONEY BANK F.S.B. / JC PENNEY on October
31, 2004 with account number ************2995 (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.
011117azzic.zti(III is froil a debt collector ill is an £zitezrzpt ttz ollec' <:z s.l l f,
j,11y iziformation obttzil)ed %vill lie tl?;Cd 166 t:lzat purpose.
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 January 24, 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
$1,534.32.
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, JOSE MARI, in the amount of $1,534.32, plus costs of this action and any
other relief as the Court deems just and reasonable.
J
Robert N. Polas Jr., Esquire # 201259
Carrie A. Brown, Esquire # 94055
12-05480
This c;ort municatioii is from a debt collector°laid is W1 attempt to Collect f.I dJ)t.
:\ny Mformation ohtaliie l will be tiscd for 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 unworn falsification to authorities.
Date : JUN 14 202
By: l/
Mary L. Moore
Custodian of Records
12-05480
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: ************2995
JOSE MARI
Account Holder:
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
Consumer Account Product Code: PVT
Issuer: GE MONEY BANK F.S.B. / JC PENNEY
Assignee: Portfolio Recovery Associates, LLC
Account Number: ************2995
Date Account Opened: October 31, 2004
Date of Last Payment: January 24, 2010
Date of Charge Off: September 7, 2010
Balance at Purchase: $1,534.32
Purchase Date: July 29, 2011
Balance at Charge-Off: $1,534.32
Less Payments: $.00
Balance Due: $1,534.32
12-05480
GECL92
This communication is from a collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
AFFIDAVIT
State of Virginia
City of Norfolk ss.
I, the undersigned, Mary I.. Moore
depose, affirm and state as follows:
Custodian of Records, for Portfolio Recovery Associates, LLC hereby
I am competent to testify to the matters contained herein.
2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing
business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and
practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit
is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account
Assignee's records, including a review of the business records transferred to Account Assignee from GE MONEY BANK
F.S.B. / JC PENNEY ("Account Seller"), which have become a part of and have integrated into Account Assignee's
business records, in the ordinary course of business.
3. According to the business records, which are maintained in the ordinary course of business, the account, and all
proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account
having been sold, assigned and transferred by the Account Seller on July 29, 2011. Further, the Account Assignee has
been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement,
satisfaction, compromise, collection or adjustment of said account, and the Account. Seller has retained no further interest
in said account or the proceeds thereof, for any purpose whatsoever.
4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the
ordinary course of business by the Account Assignee, there was due and payable from JOSE MARI ("Debtor") to the
Account Seller the sum of $1,534.32 with the respect to account number (************2995), as of September 7, 2010
with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale.
5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs
occurring subsequent to the date of sale, Account Assignee claims the sum of $1,534.32 as due and owing as of the date
of this affidavit.
o folio Recovery Associates, LLC
L. MOM
Custodian of Records
Sub bed and sworn to before me on
Not ublic
12-05480
JUN 14 2012
of_ 1 2012
Jason Vita
Commonwealth of Virginia
Notary Public
Commission No. 7509710
My Commission Expires 1/31/2015
lliis conw-itinication is 11-oni a debt collector and I's arl attcnipt to Collect a deN,
?y i tlol-1111ition obta'ne€1 Nvill be: used I'-)r tl?at pLJl'l1 'SC.
GE Money Bank
BILL of SALE
PRA 120-day Mid Prime - July 2011
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated
the 20th day of December 2010 by and between General Electric, Capital Corporation, a
Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit
Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery
Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement), delivered by Seller to Buyer on July 19, 2011, and as further
described in the Agreement.
GE Mone Bank
r
By:? --
Title: CFO
Retailer Credit Serv'c?es Inc
By: : ,
Title: President
General Electric Capital Corporation
By:
Title: Vice President
92w I oft
?r
GE Money Bank
BILL of SALE
PRA 120-.lay Mid Prime - July 2011
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated
the 20th day of December 2010 by and between General Electric Capital Corporation, a
Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit
Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery
Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement), delivered by Seller to Buyer on July 19, 2011, and as further
described in the Agreement.
GE Money Bank
By:
Title: CFO
Retailer Credit Services Inc
By:
Title: President
General Electric Capital Corporation
By: IL
Title: Vice President
GECL9Z z.r;
G&601TE
all energy-saving draperies
II february 7-18, 2010 /??
® StUalaD Cindy a. CnrisModden. ANOaSA JCP
ACCOUNT SH IPARY
Account Number 1111IF99-5 Minimum Payment Due $60.00
Previous Balance $1,242.96 Payment Due Date 03/02110
(-) Payments & Credits $65.00 Credit Limit $1,400.00
(+? Charges $0.00 Available Credit $197.00
Billing Date 02/07/10
(+? FINANCE CHARGES (NET) $24.93 Days in Billing Period 31
New Balance $1,202.89
PAGE 01 OF 01 For account information CeIL 1-800527-0881 Write* P.O. BOX 981131 EL PASO. TX 79998-1131 Online, jcp. com
TRANSACTION SUMMARY
Tren Reference Numb. I Balance Type Item Descnpiion Charges
ate 1'eGa?:yments
i 1- -a
01-24 P911900D900YZVOGN PAYMENT - THANK YOU 65.00
FINANCE CHARGE COMP
ANNUA B'TYPE E I I AVERAGE DAILY BALANCE PERIODIC RATE(S)% I C PERCENTAGE RATE(S) %L
REGULAR E 1223.69 .06573 dally 23.99
d. Your Balance Computation Method Is indicated above. Sea reverse side for an explanation.
ANNUAL PERCENTAGE RATE FOR THIS BILLING PERIOD 23.990% TOTAL PERIODIC FINANCE CHARGE 24.93
JCP REWARDS
EARN $10 REWARDS MONTH AFTER MONTH
SIGN UP FOR YOUR FREE MEMBERSHIP
GO TO JCPREWARDS.COM
JCPENNEY PRIVILEGE GOLD UPDATE.
YOUR 2010 JCPENNEY PRIVILEGE GOLD CARD
PURCHASES ARE $.00
S500 IN JCPENNEY CARD PURCHASES AND TWO VISITS FROM
1/1110-12131/10 RE-QUALIFIES YOU FOR JCPENNEY PRIVILEGE GOLD
BENEFITS THROUGH DEC 31, 2011.
Please note your mailed payment must be received by 5PM (ET) or your In-store payment must be received during store hours on
the due date. Your payment may be convertsd into an electronic debit. See reverse for details.
GET THE NEW WOMENS CATALOG. CHECK
BOX, LOGON TO JCP.COM OR CALL
1-80C-222-6161 & ORDER TAO01-6048
(1604)
g ca ct ncnru weal aanww twc enw wm? vnrw aavuwrr m rxaw
Payawrt Due <'. MtMrppn 1*W :... _ A7ntiQ it
03t02/2010 $60A0 $1,202.89 1
951 TOTAL PMD $ E D 0 7 1 a EJ F]
I- IN
JOSE M MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266-9606 P.O. BOX 960090
ORLANDO, FL 32896.0090
543 0000 T9D 1 7 7 100207 Page 1 Of 1 9114 3400 M175
text
CR10 get coupons sent to your phone,
t°s ` quick. easy, paperless,
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XPenney
Summary of Account Activity Payment Information
Previous Balance $1,534.32 New Balance $0.00
- Other Credits $1,534.32 Minimum Payment This Period $557.00
New Balance $0.00 Amount Past Due $0.00
Total Minimum Payment Due $557.00
Credit Limit $1,329.00 Payment Due Date 09/0912010
Available Credit None
Late Payment Warning: If we do not receive your minimum
Statement Closing Date 0910 7/2 01 0
payment the date listed above, you may have to pay a late
Days in Billing Cycle 28 fee up to $3 $35.00.
JOSE M MARI Yrit us at jcp.com/credit
Account Number: -9 51 Customer Service: 1-B00-527-3369
P.O. Box 981131 £I Paso TX 7999&1131
Tran Balance
Date Reference Number Type Description of Transaction or Credit Amount
09107 F911900LAOD999990 R CHARGE OFF ACCOUNT-PRINCIPALS ($1,177.96)
09/07 F911900LAOD999990 R CHARGE OFF ACCOUNT `FINANCE CHARGES' ($356.36)
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
09107 INTEREST CHARGE ON PURCHASES $0.00
TOTAL INTEREST FOR THIS PERIOD $0.00
2010 Totals Year-to-Date
Total Fees Charged in 2010 $156.00
Total Interest Charged in 2010 $226.05
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Annual Balance
Expiration Percentage Subject To Interest Balance
Type of Balance Date Rate Interest Rate Charged Method
Current Transactions
Regular NA 29.99% $0.00 $0.00 E
(Continued on next page)
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 debit. 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: 51
Total Minimum Amount Past Due Payment New a ante
-Payment Due Due Date -?
$557.00 $0.00 09/09!2010 j $0.00
FILL IN TOTAL PAID $ ? ? ? ? ? a ? ?
111111111111111101111111 New address or email? Print changes on the back.
JOSE M MARI
512WMAIN ST
WALNUT BOTTOM PA 1728&9606
P.O. Box 960090
Orlando FL 32896-0090
5433 ASH 1 5 7 100907 Z X PAGE 1 0£ 3 4119 3400 MI'5 OIDJ5433
The JCPenney Rewards Gold I Platinum Credit Card Program"'
The JCPenney Rewards Gold I Platinum Credit Card Program offers many special benefits exclusively for our JCPenney Rewards
Gold / Platinum cardmembers, including Special Savings CergflcaU(s) and a Birthday Reward Certificate.
Please visit jcp.corrdcredit to learn more about ftle JCPenney Rewards Gold i Platinum Credit Card Program
Spend 5500 or more on merchandise or services with your JCPenney Rewards Credit Card over 2 or more unique shopping days in each calendar year to
earn or maintain JClanney Rewards Gold status. Spend 51,000 or moreon merchandise or services with your JCPenney Rewards Credit Card over 2 or
more unique shopping days in each calendar year to earn or maintain JCPenney Rewards Platinum status. We reserve the i ght to change or cancel the
JCPenney Rewards Gold / Platinum Program or any orall of its benefits at any time without notice. If your account is hot in good standing and/oryou no
longer meet our credit criteria, you may be ineligible for the JCPenney Rewards Gold I Platinum Program andlor unabletotakeadvardage of JCPenney
Rewards Gold / Platinum Program promotions. The JCPenney Rewards Gold I Platinum Program is available only while you are a resident of the
contiguous 481-Inited Slates, Puerto Rico and Alaska.
Credits To YourAccount: An amount shown in parenthesis or preceded by a minus (-) sign is a creditorcredil balance unless otherwise indicated. Credits
will be applied toyour previous balance immediately upon receipt, but will not satisfy any requirements that maybe due
Bankruptcy Notice: 9 you file bankruptcy you must send us notice, including account number and all information related to the proceeding to the following
address: GE Money Bank, Attn: Bankruptcy Dept., PO Box 103104, Roswell, GA 30076.
Your Account is owned and serviced by GE Money Bank.
Hewing Impaired: TDO users Gall 1.800-444-1732.
CustomerServlcarQuesttons: For account information, please call the loll tee number on the front of this statement. Unless your name is listed on this
statement, your access to information on the account may be limited. You may also mail questiors (foul not payments) to P.O. Box 981131, El Paso, TX
7999E-1131 Please include your account numberonanycorrespondenceyousend tous.
Payments: Send paymerds to PO Box 960090, OrlandoFL 328176 0090orpay online.
Notkw: See below favour Billing Rights and other important information. Telephoning about bilking errors oil not preserve your rights under federal law To
preserve yourr la pease write to our Billing Inquiries Address: P.O.Box961403,EIPeso,TX79996.1403,
Purchases, returns, and paymentsmadejustprlortobilling date maynitaprumfirrerdmonth'sstatement When you provides check as payment you
authonzeusedhertousein rmationfromyourchecktomakeaone-time a adronicfund transfer from youraccauntortoprocessthepayment asacheck
rom urcheckfomakeanelectronicfundtransfer,,WMsmaybewithdrawnfromyouraccount asso
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What To Dolt You Think You nad A Mistake On Your Statement remittance coupon, (e) is not recelved in the remittance envelope provided
If you think tee is an error on your statement write to us at
GE Money Bank P0. Box 981403, El Paso. TX 7§998-1403
Or, complete and matt or tax the Dispute Form found at or (f) Includes sitaples, paper clips, tape, a folded check, or
correspondence of a type. Under ordinary circumstances any
payments made al a JC nney store will be credited as of the d you
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cf is ailenoe Then, we addupo alltfiedaiybalancesbrthebiNngcycleand
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1 The
wrhome state orwithin 100
urchase m
st have bow made in section of this statement A y average daily balance of less than zero will be
treat as zero Ase
araieavera
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balancew8becalculafedforeach
p
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miles o your current mad rig address
and the purchase price must have y
p
g
balaricetypeon youraccount
,
been more than $50. (Note: Neither of these are necessary if your
T .
B. The same as Method A. except unpaid Interest Charges are not
h
purchase was based on an advertisement we mafied to you, or i
we own
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C
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,
p
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made with cash acivances from an ATM or with a choc k that accesses your D. The same as Method C, except unpaid Interest Charges are not
credit card account do not quality included inthe begin?ningg balance.
3 You must not yet have fully paid for the purchase E. (Daly Balance NNhod) We fgure the merest charge on your a=rq
If all of the criteria above are met and you are still dissatisfied with the
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and app fable tees
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balance
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lnTornmtion About Payments: You may pay more than the Total (
)
g
g
oflfredaitybalancsforeachdayinlhebitkngcycledwdedbythenumberof
MMlmumlatanytlme.Mailedpaymerdsreceivedafter500PM
(ET}onarry aywillbecreditedasofthenezldav.Cred'dloyourAG.counl
f
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ayment
Address, (b snot made in U.S. ddlars drawn on a U,S. financial institution
h
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harge; M Major
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egular
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You can request to receive statements in Spanish by Galling customer
i
tl
600
542
0600
in
., (c)
oca
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.
s not accompan
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ance coupon
attached to your statement, II contains more than one payment or serv
cenumbera
-
-
.
-
01 CJ5433 - 7 111022010
This is an attempt to collect a debt and any information obtained will be used lor that purpose.
'By providing a telephone number onyour accouht, you consent to GE Money Bank and any othe r owner or servicer of your account contacti ng you about
your account including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing
system andlor an artificial or prerecorded voice when contacting you, even it you are charged for the call under your phone plan.
For changes of address, phone number andlor email, please check the box and print the changes below.
Name
Street
Address
City State,
17 Zip
Phone #
E-mail
Home Phone # Business Phone # "Cell If or other phone # we Email Address
can use to contact you
By providing your email address, you agree to receive email communications about your account and also give permission
for us to share your email address to JCPenney so you can receive special offers and updates.
The JCPenney ?
Gift Card ?
give them something to remember! .
in stores, jcp.com &
1-800-222-6161
Terms and conditions are applied to Gift Cards/e-Gift Cards.
Interest Charge Calculation (Continued)
Annual Balance
Expiration Percentage Sub*d To Interest Balance
Type of Balance Date Rate Interest Rate Charged Method
Transactions on or before 0412312010
Regular Purchases NA 29.99% $0.00 $0.00 E
DECREE
My Life. My World. My Decree.
Discover what's new this season with Decree.
5433 A1H 1 5 7 10)907 Z X PAGE 2 of 3 9119 3400 M175 o1DJ5433
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Portfolio Recovery Associates, LLC
VS.
Jose Mari
44tt?wtp cal ?:i?»??f,?tdl?
C,. - : ;F
2012 JUL -9 AM 8: 44
CUMBERLAND COUH Y
PENNSYLVANIA
Case Numb
2012-4102
SHERIFF'S RETURN OF SERVICE
07/02/2012 02:26 PM - William Cline, Corporal, who being duly sworn according to law, states that on July 2, 201 at
1426 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant,
to wit: Jose Mari, by making known unto Lucinda Mari, Wife of Defendant at 512 W. Main Street, Waln it
Bottom, Cumberland County, Pennsylvania 17266 its contents and at the same ' e handing to her
personally the said true and correct copy of the same.
CLINE,
SHERIFF COST: $42.00
July 05, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
.=i.+"~iC` ~` ~~.~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; ~!~!;(,',~.; t Lt ~~'~ j~j: <• 4
CIVIL ACTION -LAW
,.,~ .~~~ ~g ~ pan 'OUNT'f
PORTFOLIO RECOVERY ASSOCIATES, LLC ~ ~-~~~Y~ ~~ ~j~
120 Corporate Blvd
Norfolk, VA 23502
Plaintiff
v.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
Defendant
___.~
Date:
No. 12 4102
PRAECIPE FOR DEFAULT
JUDGMENT
Filed
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
Q,~{- el lo. SCY~ a
e~. ~ any ~~~
~.~a~ ~~
i.I~~is u~i~~u~~nzr~icatic3n is 1~rc>rrr a debt ~ c>Ilectc~~~ ~5 ~~n :~tierxrl3t tc~ L{~llect ~~ ci~;.ht. ( (.~t~~~
,~rzy info~~r~~atiun oi~tai~~ed ti~-ill he t~,ed ti>r that ~~iarposc;. ~~~
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 4102
v.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, JOSE MARI ,for failure to answer the
Complaint.
(X) Amount Due $1,534.32
Less Credits $.00
TOTAL $1,534.32
(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.23? (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 fi 's praecipe was
mailed or delivered to the party against whom judg n is to be entere nd his/her Attorney of
record, if any, after the default occurred and at le t ten ays prior to a da of the filing of this
praecipe and a copy of the notice is attached. ,
Date:
Robert N. Polas, Jr., Esquire # 201259
Carrie A. Brown, Esquire, #94055
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
(T)1-866-428-8102
(F)(757)518-0860
Attorneys for Plaintiff
L'~~~i~; Lx>i~~~t~~~~ar~icatic3r~ is frorrr ~~ ~lek}t ~a~llectt~t~ i5 ~~« ~~thntl~t tc~ ccsl'l~ct a ciel~t.
~Xa~ infc~t7aiatic~r~ t~btai~~td ~-ili he ~.~s,°~1 i~~~r th~~l ~~ur}~c~s~:.
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 4102
v.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
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 $1,534.32, plus interest, on . ~
(X) A copy of all documents filed with the Prothonotary in support of the w
sy:
If you have any questions regarding this Notice, please contact t lin party.
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
.l~ii~ ~~o~~~n~rta€~ic~~tion is l~roru zi debt ec>llectot~ is ~~il attempt to cE+lle~a <~ cl~~t.
~n~ iniori~~atio~t obtained will he ~~se+a for that }n~rpo~e.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIV[L ACTION -LAW
PORTFOLIO RECOVERY ASSOCIATES,
LLC
120 Corporate Blvd
Norfolk, VA 23502 No. 12 4102
Plaintiff
v.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
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
512 W MAIN ST
WALNUT BOTTOM PA 17266
and is not in the military service of the United States or its Allies, or otherwise within the pro 'ions of
the Service Members Civil Relief Act and its Amendments.
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
12-05480
l~}~i~ ccsrr~riiur~ication is a cle;ht c-c>llect«r <~z~d i~ are ~~tte;rr~pt tt:~ collect ~ cEebt.
:~ ~~v ~i~~i~orrnaticm obtained u ill be ~~secl lo~~ that pu~r-hose.
e~,,~F;: ~~ ot: n„y-~ ~-2oi ~ os,~s:aa
Department of Defense Manpower Data Center
SGPiA 2.]
~tatt,L~ ~.~t@i't
~ursnt ~o ~er~r~~n~m Civic .eief ~.ct
Last Dame: MART
First Name: JOSE
Middle Name:
Active Duty Status As Of: Aug-13-2012_
_ ~, ~~uff ~ ~ Av~va o~„ s~,~ ~~te
Aclrve OutX SEan Da?e .~.. _ ~ Adrve Duty 6rM Dafe .. _._ $taRis~~ ~,_ __ -...,~....,._Servlce ComPGn nt ~_.__._.
NA NA 'ko NA .~
This respansa rae-oNSthe {ndivk7uals ac3rvo duty status based ~;v the Fu:tNO Duty StaWs bate ,
left Actwe Ftuty YT3Nn361 (}aye dt Active pittY $iadus Date
Act ~ Ds~iy Burt Da;g - -- ActWrr Duty End Deie Status uerviCa Ct+m{k>oent
_..._ -. _-_ __.... ...___ ______ ,._ .._.. _ .e,. ~__ _- _ _- _- ..... _....,., ___ ._..
K.A t NA Nu . __ NA
This ~~sponsa mfleats wtlBre the "sndrvt~htai I~sft aUrva duty statui+ wtNKn 38'F 8ayy pra_cedinp me A~diuft DuDr Status Date
The Mer+~Aer Ar k®sM@t Untt Was tlWdisd W a Future GalE33p to Acttve Duly ott Active ik~ty Status Date
Ortter Nalific,~Goe Start Data 6i~NgitkBfio(t ErW Date Status ServkN CwnFwnent
NA NA i Mu 41A
77*"ss response reRects whek#eer the individua6 ~ hiNher unit has rece(ved s~rA` rWyfapa60+f to report for acWte duri/
I
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the lnfonnafion that you provided, the above is the stet s of
the individual on the acfive duty status date as to all branches of the Uniformed Services {Army, Navy, Marina Corps, Air Force, NOAA, Public Health, at~d
Coast Guard). This stains Includes information an a Servicemember or his/her unit receiving natlficatlon of future orders to report for Active Duty.
~'"
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
480t) Mark Censer Drive, Suite t)4E25
Arlington, VA 2235p
12-054$0
The Defense Manpower Data Center {OMDC} is an organlzatian of the Department of pefense (DaD} iha# maintains the Defense Enrollment and Eligibility
Report[ng System (DEERS) database which is the affreial source of data an eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended} (SCRA} (formerly known ads
the Soldiers' and Sailors' Civil Relief Act of 1940}. DMOC has issued hundreds of thousands of "does not possess any information indicating that the I
individual is currently on active duty" responses, and has experienced only a smolt errpr rata. in the avant the individual referentetl above, or any famiiy~
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to Uhe
protections of the SCRA., you are strongly encouraged to obtain further verification of the person's status by contacting that person's Servile via the
"defenselink.mil" URL: http:Jtwww.defenselink.mil/faglpts1PC09S~DR.htmf. If you have evidence the person was an active duty fiar ttte active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(x), i
This response reflects the following irrformatian: {1}The individual's Active Duty status on the Active Duty Status Date (2} Whether the individual left
Duty status within 387 days preceding the Active Duty Status Date (3} Whether the individual or hislfter unit received early notification to reparE for a
duty on the active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accwdance with 10 USC § 101'(d} {1 }. Prior to 2010 only some of the active duty periods Ir
than 30 consecutive days in length were. available. in the case ai a member of the National Guard, this includes service under a call tp active service
authorized by the President. or the Secretary of Defense under 32 USG § 502{f} for purposes of resppnding to a national emergency declared by the
President and supported by Federal funds, All Actve Guard Reserve {AGR}members must be assigned against an authorized mobilization position in
unit they support. This includes Navy Training and Administration of the Reserves (TARS}, Marine Corps Active Reserve {ARs} and Coast Guard Rase
Program Administrator (RDAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned offioer of the U.S.
public Health Service or the National Oaeanit and Atmospher9c Administration (NOAH Commissioned Corps}.
Coverage Under the SCRA i;~ Broader in Same Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not
reported as on Active Duty under this certificate. SCRA protections are for Tile 10 and Title 14 active duty records for all the Uniformed Services peria
7iNe 32 periods of Active Duty are not covered by SCRA, as tlefined in actardance with 10 USC § 101(d}(1 }.
Many #imes orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely an this website
certification should check to make sure the orders on which SCRA protections era based have not been amended to extend the inclusive dates of servi
Furthemwre, same protections of the SCRA may extend to persons who have received orders to report for active duty ar to be inducted, but who have
actually begun active duty or actually repnrted fpr induction.. The Lask Date on Active Duty entry is irnpartant because a number of protections of the Si
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SC'.
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information wilt cause an erroneous certificate to be provided.
Certificate ID: 2Q1RP03OPJ
PORTFOLIO RECOVERY ASSOGIATES, 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
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
12-05480
r
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. JOSE MARI
12 4102
I
Dear JOSE MARI:
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
Sincerely,
t 4 . _ = ,.
r. ~ ~ ~ .. >
-y. f
Robert N. Polas, Jr., Esquire
Carrie A. Brown, Esquire
Attorney ID# 201259/94055
Portfolio Recovery Associates, LLC
140 Corporate Blvd.
Norfolk, VA
Attorneys for Plaintiff
r+;r5:
This ~:o~~~mt~nic~~i:ion is fru~~7 z~ t3el~t collector is a~~ :ittetnl?t to ~ollc~t ~1 ii~~~i.
;k~~ti~ inion~iatit.>n obtained will. 1~~:~ tGr~ca t+~r that ~~~rl~o•c.
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 4102
v.
JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
Defendant
TO: JOSE MARI
512 W MAIN ST
WALNUT BOTTOM PA 17266
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 WITHOUT 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 WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIlZE 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 a
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Pennsylvania Lawyer Referral Service
(800)692-7375
Robe~l'~Polas, Jr., Esquire
Carrie A. Brown, Esquire
Attorney ID # 201259/94055
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
i~1L~ ~t~pllltii111C<tiilll l;+ fl(~[t1 Ft (jt~?t C{~~~iCh~H~ 71 ;iil~ll~l'd i(~ ~'~?11eti'l 1 iiC~~[
~~[l'd 7Dft?1~Ti1:311t111 t~I)1.HiRf.'(~ t~l^I~ ~~~~. ~.. ,' #~'~~" I~IE![ ?111 jTt`S.a..