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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. iA y6y 14� 4A4— Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 13-09954