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Home My WebLink About12-6525Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #3093'70 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. MICHAEL TALLMAN 102 SPRUCE ST CARLISLE PA 17013 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION ' _ ,,`: i ~-- l.p S ,`,- 4,.. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (~'.0) days after this complaint and notice are served, by entering a written appearance personally or by attorney and 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 32 SOUTHI BEDFORD STREET CARLISLE, PA 17013 r'~~. 2772128 ~ ~.~ ~ Q 5 ~ I PPTCPADI ~l $ a ~(~~ CJc AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes Para usted. LLEVE ESTA DEMANDA A UN ABC)GADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO~ DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-;?032 Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC vs. MICHAEL TALLMAN 102 SPRUCE ST CARLISLE PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION No. Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), MICHAEL TALLMAN , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE CAPITAL RETAIL BANK, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on 'the account. There is a balance due and owing of $3084.55. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2772128 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY' ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), MICHAEL TALLMAN in the amount of $3084.55, plus; costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC i 1 ,-~~ One f its A orneys Morris Scot Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: October 16, 2012 Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #3093'70 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. MICHAEL TALLMAN 102 SPRUCE ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Morris Scott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made sut~ject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworrl falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: October 16, 2012 2772128 PPTJCAM I iIIIIIIIIIIIIIIIIIVIIIIIIIIIIIIVIIIVIIIVIIIVIIIVIIIVIIIIIIIVIIIIIII ,~ ,,, By: ~~ `~~ ~~~ Morris Sc tt Syretta actin VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. --~~~ -- . PPTXVERI Exhibit "A" PPTXEXP_I ~`~ ~12.~ VERIFICATION jT~ be used, t~iy a person associated with the present creditorl I, Evita R°driyuex ,hereby verify that: 1. tam employed by Portfolio Recovery Associates, LLC as Custodian of Records and am authorized to make this Verification on behalf of Portfolio Recovery Associates, LLC. Portfolio Recovery Associates, LLC is the successor in interest to GENERAL ELECTRIC CAPITAL CORP/CARS CREDIT. 2. I reviewed the following ( ](a) computerized documents; [ ](b) hard copy documents; and (x] (c} other (specify)Account Records relating to Account number: ending in 5144. The foregoing Account of Gffi3BRAL ELECTRIC CAPITAL CORP/CARS CREDIT was opened on 6/6/2006 in the name of MICAA$L TALLMAN. The accounts/documents that I reviewed were produced by GENERAL ELECTRIC CAPITAL CORP/CARE CRBDIT. 3. Based on my review of the foregoing documents, there is due and payable the principal sum of $3,084.55. This sum includes the fallowing (check all that are appropriate): [x] interest; [x) late fees; ] collection fees; and [x] any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and GENERAL ELECTRIC CAPITAL CORP/GARB CREDIT. This sum does not include the following (check ail that are appropriate): [ ]interest; [ ] {ate fees; (x] collection fees; and [ ]any other additional fees permitted under the terms of the agreement with the debtor named in paragraphs 2 above and GENERAL $LSCTRIC CAPITAL CORD/CARS CREDLT. 4. Based an my review of the foregoing documents, there are no payments that have not been credited. 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification to authorities in violation of 18 Pa. C.S. §49D4. ~c'~ I Z DATE `~ Evita Rod~i,ez ,CUSTODIAN f ~,`.. ' s...,. {,;. Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaini:iff, vs. MICHAEL TALLMAN 102 SPRUCE ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL A*C~TION ,.. - ~.;: PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 Dated: October 16, 2012 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC i% By. 4 ~~~ ~/lorri Scott Attorney Syr to Martin Attorney 2772128 PPTXPEAI I Illillll IIII III IIIIII VIII VIII VIII VIII VIII VIII IIIIII III IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTI~ 3 ~ ,~ -~ ~ ~` Ronny R Anderson ~ p e - ~-- Sheriff ~ttr at ~air,~r,,~ ~~ - ~ Jody S Smith i~,r~ ~4vt ~- ~x "~ ~ .~~ Chief Deputy ~ ~ ~ ~, ~ ~ ~..% Z,. ~~,, Richard W Stewart r '~ ~~~ D~ ~ ~ ~~ Solicitor ~~~ ~ - _ Portfolio Recovery Associates, LLC Case Number vs. 2012-6525 Michael Tallman SHERIFF'S RETURN OF SERVICE 10/26/2012 03:00 PM -Stephen Bender, Deputy Sheriff served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Tallman at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. STEPHEN BENDER, DEPUTY SHERIFF COST: $34.00 November 07, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF iC) Q;un:y5ude She;~zt "fFe;ns^it: Inc. Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CZ CIVIL ACTION -lu 7 x' vs. rrj Co � No. 12-6525-CIVILr = MICHAEL TALLMAN QD 2436 B ELM ST HARRISBURG PA 17103 '=- = Defendant(s). > PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant MICHAEL TALLMAN in this matter in the amount of $2922.30 plus court costs. also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 11/21/2012 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: May 29, 2013 By: Morris Scott 416-50 pp qTq Syretta Martin e*8q3qq �� a9�3ao 2772128 PPTJPFJI Tt 1111111111111 illl IIIII III 111111 IIIII IIIII IIIII IIIII 1111111111 IN 11111 IN Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. 12-6525-CIVIL MICHAEL TALLMAN 2436 B ELM ST HARRISBURG PA 17103 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA:County of Chester: I, Morris Scott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements.herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: May 29, 2013 By: Morris Scott Syretta Martin 2772128 PPTJCAMI (05/01/2013) 1 1111111 11111 1111111111 I I 1 1111 11111 11111 11111 11111 11111 11111 11111 1111 IN SCRA 3.0 Staff Report Pursuant�to SerVicernemben Civil,itzlief Act j Last Name: TALLMAN First Name: MICHAEL Middle Name: Active Duty Status As Of: May-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - - - No- NA This response reflects where itie Individual left active duty status within 367 days preceding the Active;Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA-' No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. - rM 6' _ 41wiwwli _ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Reporting System(DEERS)database which is the official source of data on 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 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family 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 the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the 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(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some 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 be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA 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 SCRA 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 will cause an erroneous certificate to be provided. Certificate ID: 33E8Q14010A3KA0 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY, PA MICHAEL TALLMAN CIVIL ACTION 102 SPRUCE ST CARLISLE PA 17013 No. 12-6525-CIVIL Defendant(s). TO: MICHAEL TALLMAN Date of Notice: November 21, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE 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 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, LEIBSKER &MOORE, LLC wt"ud '4 scw By: Morris Scott Syretta Martin 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2772128 PPTNLRSI 1111111111111111111111111111111111111111111111111111111110111 IN PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. MICHAEL TALLMAN CIVIL ACTION 2436 B ELM ST No. HARRISBURG PA 17103 Defendant(s). No. 12-6525-CIVIL TO: MICHAEL TALLMAN NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. P THO AR Dated: By. IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker& Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2772128 PPTNDJNI 1111111111111 IIII IIIII III IIIII!IIIII IIIII IIIII IIIII IIIII 111111!11 11111 IIII