HomeMy WebLinkAbout13-2777 Supreme C Fluc" tPennsylvania
Courf� '� n Pleas
):,� s For Prothonotary Use Only: TIME STAMP
Civ� vel>� et
x �� Rocket No:
��'pt'I77 IVIfh
CUMB L®I County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required by law or rules o court.
S Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
' E 1 ❑ Transfer from Another Jurisdiction
i ❑Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T PORTFOLIO RECOVERY ASSOCIATES, LLC DEBORAH CAMPBELL
I
Q Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
t N (Check one) outside arbitration limits
Is this a Class Action Suit? ❑ Yes ®No Is this an MDJAppeal? ❑ Yes ®No
A 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)
f
t
t 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.
j 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
S mass tort) ❑ Employment Dispute:
E C] Slander /Libel /Defamation Discrimination C] Zoning Board
❑ Other: ❑ Employment Dispute: Other ❑ Other:
C
I I � E3 Other:
MASS TORT
U ❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration
i B [J Waste ❑ Eminent Domain /Condemnation C3 Declaratory Judgment
❑Other: ❑ Ground Rent E] Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
t ❑ Mortgage Foreclosure: Residential Restraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
13 -09954
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COVER SHEET
Plaintiff(s)
PORTFOLIO RECOVERY ASSOCIATES, LLC Case Number:
assignee of GENERAL ELECTRIC CAPITAL CORP /
PREFERRED VET
120 CORPORATE BLVD
NORFOLK, VA 23502
Type of pleading:
Civil Complaint
Code and Classification: Commencement of Action
Filed on behalf of:
Portfolio Recovery Associates, LLC
assignee of GENERAL ELECTRIC CAPITAL
CORP /PREFERRED VET
(Name of the filing party)
Vs ® Counsel of Record
❑ Individual, If Pro Se
Defendant(s) Name, Address and Telephone Number:
DEBORAH CAMPBELL Carrie A. Brown, Esq., PA Bar 94055
1322 1/2 SPRING RD B Robert N. Polas, Jr., Esq., PA Bar 201259
CARLISLE PA 17013 Mark R. Garvey, Esq., PA Bar 312686
120 Corporate Blvd
Norfolk, VA 23502
Telephone: 1 - 866 - 428 -8102
Attorney's State ID:
Attorney's Firm ID:
13 -09954
c:)
C
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar# 94055 r''m :a- M r
Mark R. Garvey, Esquire PA Bar # 312686
Portfolio Recovery Associates, LLC c3� �: I
120 Corporate Blvd C-) -.1
Norfolk, VA 23502 s==ue
TELE: 1- 866- 428 -8102 —`� � (11.) --i
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. i3- arl7 1 Y1 � �Pi
Plaintiff,
V.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
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 O
(800) 692 -7375
13 -09954 4183.r75 PO PLR:
L# aga318
R #aqo &yy
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
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.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
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
13 -09954
Esta con..m.)icaci.oti. es de u.n cobrador de deudas y es un .intent do cobrar u.na deuda.
Cualquier infromac.ion sera utilizada para ese proposito.
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.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
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, DEBORAH CAMPBELL, is an adult individual with last known address of 1322 1/2
SPRING RD B, CARLISLE PA 17013.
3. It is averred that Defendant was indebted to GENERAL ELECTRIC CAPITAL CORP /
PREFERRED VET on December 13, 2007 with account number * * * * * * * * * ** *2800 (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.
This corn.mu.nication is fron.i. a debt collector and is ai.a attempt to collect a debt.
Any in.forinatioia. obtained will be used far that purpose.
5. At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and /or for obtaining services.
6. Defendant was provided with copies of the Statements of Account showing all debits and credits
for transactions on the aforementioned Account to which there was no bonafide objection by
Defendant. `
7. Defendant was in default with respect to that debt for failure to make the required payments on the
Account. The last payment made on this Account was on February 17, 2011.
8. Plaintiff is the purchaser, assignee and /or successor in interest GENERAL ELECTRIC CAPITAL
CORP / PREFERRED VET 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
$964.83.
I O.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.
1 I. 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, DEBORAH CAMPBELL , in the amou t of $964.83 us c is of this
action and any other relief as the Court deems just and reasonabl
Carrie A. Brown, Esquire, # 94055 /
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
13 -09954
This communication .is fron.i. a debt collector and is an atten.ipt to collect a debt.
Any information obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Larry J. Andrews hereby states that he /she is authorized to take this verification on
behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing
Complaint are true and correct to the best of his/her knowledge, information, and belief, based
upon information provided by the Plaintiff.
The undersigned understands that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date:
Larry J. Andrews
Custodian of Records
13 -09954
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
X IBIT 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
r� \ Norfolk, VA 23502
' Telephone: 1- 866 - 428 -8102
� Fax: (757) 518 -0860
Statement of Account
Account: * * * * * * * * * ** *2800
DEBORAH CAMPBELL
Account Holder:
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
Consumer Account Product Code: PVT
Issuer: GENERAL ELECTRIC CAPITAL CORP / PREFERRED VET
Assignee: Portfolio Recovery Associates, LLC
Account Number: * * * * * * * * * ** *2800
Date Account Opened: December 13, 2007
Date of Last Payment: February 17, 2011
Date of Charge Off: September 30, 2011
Balance at Purchase: $964.83
Purchase Date: October 24, 2011
Balance at Charge -Off: $964.83
Less Payments: $.00
Balance Due: $964.83
13 -09954
GESM67
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. Larry J. Andrews
I, the undersigned, , 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 GENERAL ELECTRIC
CAPITAL CORP / PREFERRED VET ( "Account Seller "), which have become a part of and have integrated into
Account Assignee's business records, in the ordinary course of business.
3. According to the business records, which are maintained in the ordinary course of business, the account, and all
proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account
having been sold, assigned and transferred by the Account Seller on October 24, 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 DEBORAH CAMPBELL ( "Debtor ") to the
Account Seller the sum of $964.83 with the respect to account number ending in * * * * * * * * * ** *2800, as of September
30, 2011 with there being no known un- credited payments, counterclaims or offsets against the said debt as of the date of
the sale.
5. According to the records of said Account Assignee, after all known payments, counterclaims, and /or setoffs
occurring subsequent to the date of sale, Account Assignee claims the sum of $964.83 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 overy lssociates, L
By: ar Custodian of Records
Subsc ' d n to before me on of , 2013
Notary Pidlic
13 -09954 Tavana C. Uzzle
Commonwealth of Virginia
Notary Public
Commission No. 302460
My Commission Expires 1/31/2017
This comma ucation is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
8664201312 `_..'' ' :53:10 10 -26 -2011
2 12
A
BELL OF SALE
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Purchase Agree me),
dated as of October 19, 2010 by and between GE Capital Corp. (oollectively "Seller") and
Portfolio Recovery Associates, LLC ("Huy V), Seller hereby transfers, sells, conveys, grants,
and delivers to Buyer, its successors and assigns, without recourse except as set forth in the
Purchase Agreement, to the extent of its ownership, the Receivables as set forth in the
Notification Files (as defined in the Purchase Agreement), delivered by Seller to Buyer on each
Transfer Date, and as further described in the Purchase Ageettent.
GE Capital Corp.
By: ��'�__
Glenn Marino
Title: VP
Date. IO 2,6 • -�
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronn y R Anderson I'll ED Ot �JCE
7 i 'EOT,' ONO T'AF ',,.
Sheriff
CO - art�erar,���,#2rr��
Jody S Smith �, . 2043 MAY 30 AM 1 j: 03
Chief Deputy
Richard W Stewart
CUMBERLAND COOT'
Solicitor s .: T :s#w Efr PENNSYLVANIA
Portfolio Recovery Associates, LLC
Case Number
vs.
Deborah Campbell 2013-2777
SHERIFF'S RETURN OF SERVICE
05/23/2013 07:19 PM - Deputy Noah Cline, 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: Deborah Campbell at 1322 1/2 Spring Road- B, Carlisle Borough, Carlisle, PA 17013.
NOAH CLINE, DEPUTY
SHERIFF COST: $34.78. SO ANSWERS,
-
May 24, 2013 RON R ANDERSON, SHERIFF
(c)CountySuito Sheriff,Toleosoft,Inc.
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. 2013-2777
V.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B n '
CARLISLE PA 17013 PRAECIPE FOR DEFAULT
C--- ,
Defendant JUDGMENT p C= m F:
-<37 °3
D C
° 7
=C:) C)
Filed on Behalf of Plaintiff
C nsel of reco for this Party
Date:
Robert N. Polas, Jr., Esquire,#2012
Carrie A. Brown,Esquire,#94055
Mark R. Garvey, Esquire,#312686
Portfolio Recovery Associates,LLC
120 Corporate Blvd
Norfolk, VA 23502
(T) 1-866-428-8102
(F) (757) 518-0860
Attorneys for Plaintiff
aT 1
(?
This communi.cati.on i.s from a debt collector i.s an.attempt to collect a debt.
Any in.forniation obtained will be used for that purpose.
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. 2013-2777
V.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant,DEBORAH CAMPBELL ,for failure to
answer the Complaint.
(X) Amount Due $964.83
Less Credits $.00
TOTAL $964.83
(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 entered and to his/her Attorney of
record, if any, after the default occurred and at le n days prior to e ate 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
Mark R. Garvey, Esquire,#312686
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 l.rom a debt collector i.s 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. 2013-2777
V.
.DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
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$964.83,plus interest, on .
(X)A copy of all documents filed with the Prothonotary in support of t within gment re attached.
By:------ -- ------- —
� 'n
If you have any questions regarding this Notice,please co ct h'-filing par
Date: ( J
Robert N. Polas, Jr., Esquire, #201259----
Carrie A. Brown,Esquire, #94055
Mark R. Garvey, Esquire,#312686
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 fion1 a debt collector is an attempt to collect a debt.
Any inforniation obtained will be 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)
June 20, 2013
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
RE: Portfolio Recovery Associates, LLC
VS. DEBORAH CAMPBELL
2013-2777
Dear DEBORAH CAMPBELL:
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
Sincerely,
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
13-09954
This communication is front a debt collector is an attempt to collect a debt:.
Any information obtained will be used for that purj)ose.
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. 2013-2777
V.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
Defendant
TO: DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
DATE OF NOTICE: June 20,2013
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
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 communicition,is from a debt collector is nn attempt to collect 1 debt.
Any inforimition obtained will be used foi,tli-m 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. 2013-2777
Plaintiff
V.
DEBORAH CAMPBELL
1322 1/2 SPRING RD B
CARLISLE PA 17013
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
1322 1/2 SPRING RD B
CARLISLE PA 17013
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:
4obertolas, Jr., Esquire,#20125
Carrie A. Brown,Esquire,#94055
Mark R. Garvey, Esquire,# 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk,VA 23502
(T) 1-866-428-8102
(F) (757) 518-0860
Attorneys for Plaintiff
13-09954
This communication is a debt collector and :is an attempt to collect a debt.
Any Information obtained will be used for that purpose.
Results as of:Jul-01-2013 02:44:50
SCRA 3.0
Status Report
P sumt to SeMcemembm Civil Relief Act
Last Name: CAMPBELL
First Name: DEBORAH
Middle Name:
Active Duty Status As Of Jul-01-2013
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 ndividuals'active duty status based on the. tity Status Data
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 tndlvidual left active duty status wlthtn 367"days preceding the AcIti-Puty 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
This response reflects whether the Mdual 4or,hisfher unit has received earfy 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,NOAH,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.
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Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
13-09954