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Home My WebLink About13-1810 ,Sup reme Co f Pennsylvania Cou n Pleas Ci. et CUM County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other a ers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC KATHLEEN WITT Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes ®No Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey ❑ Check here if you have no attorney (are a Self- Represented (Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ___ —_� - -_ ❑ Statutory Appeal: Other ❑ Product Liability (does not include —� —__ — _— --------- _ — mass tort) ❑ Employment Dispute: __ _ ------- ______ ❑ Slander /Libel/Defamation I Discrimination Cl Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑Ejectment El Common Law /Statutory Arbitration ❑ Toxic Waste [] Eminent Domain /Condemnation E3 Declaratory Judgment E] Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations - ------ - - -- - -- ❑ Mortgage Foreclosure: Residential Restraining Order --- - - - -- ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal _ _ - - - - - ------- ❑ Medical ❑ Other Professional: him VWN ----------- - - - - -- 12 -86263 LISM Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 FILED - OFFICE THE PROTHONOTARY Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 2013 APR " 8 120 Corporate Blvd a 23 Norfolk, VA 23502 CUMBE COUNT TELE: 1- 866 - 428 -8102 YL ANIA FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 NO' Plaintiff, V. KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 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, 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 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 1 _7S (800) 692 -7375 � a &; 12 -86263 CJ Wars o This communication is from a debt collector and is an attempt to collect a debt. d 9 Any information obtained will be used for that purpose. - Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 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 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 Demandado. 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 esta 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 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 12 -86263 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar Una deauda. C'ualquicr infrornacion sera util.izada Para eye propositc�. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 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 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, KATHLEEN WITT, is an adult individual with last known address of 36 LILAC DR, MECHANICSBURG PA 17050. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on May 19, 2010 with account number * * * * * * * * * * * * 9143 (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 communication is from. a debt collector and is an attempt to collect a debt. Any inforination 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 bonafrde 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 January 11, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / WAL -MART and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs verification is attached hereto and collectively marked as Exhibit "A." 9. 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 $1,889.36. 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, KATHLEEN WITT , in the amount 1,889.36, p co s of this action and any other relief as the Court deems just and reasonab Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 12 -86263 I`his communication is frorn. a debt collector and is an attempt to collect a debt. Any infornation obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Rolle V. McNeal 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: MAR 19 2013 B Rorie V. McNeal Custodian of Records 12 -86263 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBI 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 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1- 866 - 428 -8102 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *9143 KATHLEEN WITT Account Holder: KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *9143 Date Account Opened: May 19, 2010 Date of Last Payment: January 11, 2012 Date of Charge Off: May 18, 2012 Balance at Purchase: $1,889.36 Purchase Date: June 28, 2012 Balance at Charge -Off: $1,889.36 Less Payments: $.00 Balance Due: $1,889.36 12 -86263 GECPO4 This communication is from a debt 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, R08bV. McNeal , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. 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, 120 Corporate Blvd, Norfolk, VA 23502. 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 / WAL -MART ( "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 June 28, 2012. 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 KATHLEEN WITT ( "Debtor ") to the Account Seller the sum of $1,889.36 with the respect to account number ending in * * * * * * * * * ** *9143, as of May 18, 2012 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 $1,889.36 as due and owing as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. Portfolio Recovery Associates, LLC By: Rollie V. MCNeaI , Custodian of Records MAR 19 2013 m d and sworn to befopp ine on of , 2013 jrm� kt? Notary ublic Tavana C. Ozzie NOTARY PUBLIC 12 -86263 Commonwealth of Virginia Reg. # 302460 R My Commission Expires ]an. 31, 2017 This conirn un i cation is froth a debt collector and is ari attempt to collect a cleft. Any information obtained will be used for that purpose. ...... . ... ................. GECPO4 GE Capital BILL of SALE PRA Fresh — June 2012 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 as of the 20` day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (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 June 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: —� `� "'-- By: Title: Glenn Marino -Vice President Title: Stephen Motta - Director GE Capital Retail Bank Monogram Credit Services, L.L.C. Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: Title: Vishal Gulati -CFO Title: Vishal Galati - CFO GE Capital BILL of SALE PRA Fresh — June 2012 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 as of the 20` day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (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 June 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By: a� I 0 Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: Title: Vishal Gulati -CFO Title: Vishal Gulati -CFO UO GE Capital BILL of SALE PRA Fresh — ,iune 2012 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 as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (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 June 1.9, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By: Title: Glenn Marino -Vice President Title: Stephen Motta - Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding, L.L.C. GEM , By: By: Title: �(�,tila( L> Title: _)"I G� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson rl, ED-OvFICE Sheriff L A OF THI PROTHONOT RY Jody S Smith Chief Deputy 2013 APR 23 A 10: 21 Richard W Stewart MBERLAN[ItOUHTY Solicitor OFFICE OF THE SREIRIP: W PERNSYL'VAN'A Portfolio Recovery Associates, LLC Case Number vs. 2013-1810 Kathleen Witt SHERIFF'S RETURN OF SERVICE 04/15/2013 04:48 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Kathleen Witt at 36 Lilac Drive, Silver Spring Township, Mechanicsburg, PA 17050. DENNI-115'FRY, DEPUO, SHERIFF COST: $38.00 SO ANSWERS, April 16, 2013 RON R ANDERSON, SHERIFF (C)CountySuite Sheriff,TefeoWt,Inc. 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. 13-1810 KATHLEEN WITT • e , = 36 LILAC DR ~cy y i --• MECHANICSBURG PA 17050 _ Defendant �'r- r:� k ;• • <:c; -- rr a rQ PRAECIPE FOR DEFAULT JUDGMENT _< '` - Please enter Judgment in Favor of Plaintiff and against Defendant,KATHLEEN WITT ,for failure to answer the Complaint. (X) Amount Due $1,889.36 Less Credits $.00 TOTAL $1,889.36 (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,I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to be e -red and to his/her Attorney of record,if any,after the default occurred and at least ten days p '. . the date of the filing of this,i praecipe and a copy of the notice is attached. Date: k.1(3 AIII- Robert N. Polas, Jr., squire#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 a4 16.STC):114.1 C V4 31 W! This communication is from a debt collector is an attempt to collect a debt. 3 I Q Any information obtained will be used for that purpose. gil_o/CIPLDS / ■ ofiLt Olje a 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. 13-1810 v. • KATHLEEN WITT • 36 LILAC DR MECHANICSBURG PA 17050 PRAECIPE FOR DEFAULT Defendant JUDGMENT • • Filed on Behalf of Plaintiff Cou el of record f. Party 3 Date: Ro ert 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 This communication is from a debt collector is an attempt to collect a debt. Any 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. 13-1810 v. KATHLEEN WITT • 36 LILAC DR MECHANICSBURG PA 17050 • 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$1,889.36,plus interest,on. (X)A copy of all documents filed with the Prothonotary in support of th- 'thin ju ent i a attached. a By: If you have any questions regarding this Notice,please co ct the filing .. I Date: 1 a >l3 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 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will he used for that purpose. 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) May 7,2013 KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 RE: Portfolio Recovery Associates, LLC VS. KATHLEEN WITT 13-1810 Dear KATHLEEN WITT: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, ( � .►v PLC Robert N. Polas,Jr., Esquire Carrie A. Brown, Esquire Mark R.Garvey, Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff 12-86263 • This communication is from a debt collector is an attempt to collect a debt. Any 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. 13-1810 v. KATHLEEN WITT 36 LILAC DR • MECHANICSBURG PA 17050 •• Defendant • TO: KATHLEEN WITT 36 LILAC DR MECHANICSBURG PA 17050 DATE OF NOTICE: May 7,2013 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 Court Administrator 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 Pennsylvania Lawyer Referral Service (800)692-7375 L) C)(9-4: 5 Robert N.Polas,Jr., Esquire Carrie A.Brown, Esquire Attorney ID#201259/94055 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk,VA 23502 Attorneys for Plaintiff This communication is from a debt collector is an attetnpt to collect a debt. Any information obtained will be used Ibr 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. 13-1810 Plaintiff v. • • KATHLEEN WITT • 36 LILAC DR • MECHANICSBURG PA 17050 • 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 36 LILAC DR MECHANICSBURG PA 17050 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: _77119-4-42° 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 12-86263 This communication is a debt collector and is an attempt to collect a debt. Any information obtained \k ill be used for that purpose. Results as of:May-27-2013 02:56:56 SCRA 3.0 .+ ` Status.l .ePOt't r - Pursuant to Servieentembers Civil Relief Act Last Name: WITT First Name: KATHLEEN Middle Name: Active Duty Status As Of: May-27-2013 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 the individual left active duty status within 367 clays 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. Alty. )1111A. 11414. Ellie. 11/4„... Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 12-86263 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility 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:http://www.defenselink.mil/faq/pis/PCO9SLDR.html. 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: A2FEACBFP02EJF0