HomeMy WebLinkAbout13-2888 Supreme C,or Pennsylvania
Court f Caml' n Pleas
]:. n ` . For Prothonotary Use Only: I'lIME STAA1f
Civ . VeIit Docket No:
CUMB' .,County
The information collected on this form is used solely for court administration purposes. This form does not
r—�
supplement or replace the fi ling and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T PORTFOLIO RECOVERY ASSOCIATES, LLC BRIGITTE EVANS
I �
' 0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
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)
i
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
S mass tort) ❑ Employment Dispute:
` C] Slander /Libel /Defamation Discrimination C] Zoning Board
E
I { ❑ Other: ❑ Employment Dispute: Other ❑ Other:
C
T
T { ❑ Other:
I O I MASS TORT
❑ Asbestos
N ❑ Tobacco
C:] Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
i ❑ Toxic Tort - Implant C:1 Ejectment ❑ Common Law /Statutory Arbitration
❑Eminent Domain /Condemnation ❑Declaratory Judgment
B El Toxic Waste
1
E] Other: ❑ Ground Rent E] Mandamus
I ❑ 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:
i ❑ Legal
❑ Medical
❑ Other Professional:
I
13 -16104
J Robert N. Polas, Jr., Esquire PA Bar # 201259 O f= (- PI£ R O F'FIC
Carrie Brown, Esquire PA Bar # 94055 ,�OVQ rAR `t
Mark R. Garvey, Esquire PA Bar # 312686 2003 t1A Y 2 ! t
Portfolio Recovery Associates, LLC �i7 10: 0$
120 Corporate Blvd CUi~ BERLAND COUNTY
$Y�V A N�
Norfolk, VA 23502 P� A
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 n Q J
120 CORPORATE BLVD J✓ a 0 0 C ( - v
NORFOLK, VA 23502 No. I
Plaintiff,
V.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
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, 17013
(717) 249 49 -3166
Pennsylvania Lawyer Referral Service
13-16104
(800) 692 -7375 Iv3. Pdar�
CY
n yi -�•-
*a goM
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.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
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 -16104
Esta comunicacion es de un cobrador de deudas y es un intent do cobras una deuda.
Cualquier in.tromacion sera utilizada para ese propos.ito.
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.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
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, BRIGITTE EVANS, is an adult individual with last known address of 3910 CHURCH
ST, CAMP HILL PA 17011.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / DICK'S SPORTING
GOODS on August 10, 2010 with account number * * * * * * * * * ** *4634 (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 communication is fron.i. a debt collector and is aa.a. attenxpt to collect a debt.
Any information obtained will be used for 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 November 22, 2011.
8. Plaintiff is the purchaser, assignee and /or successor in interest GE CAPITAL RETAIL BANK /
DICK'S SPORTING GOODS 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
$992.64.
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.
I LThe 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, BRIGITTE EVANS , in the amount of $992.64, plus costs of this action
and any other relief as the Court deems just and reasonable. /�
Carrie A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
13 -16104
This communication is from a debt collector and is an. attempt to collect a debt.
Any information obtained will be used for. that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Ricky L. Vaughan 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: MAY 0 6 2013 By:
Ricky L. Vaughan
Custodian of Records
13 -16104
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
r
XHIBIT 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: * * * * * * * * * * * 4634
BRIGITTE EVANS
Account Holder:
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
Consumer Account Product Code: PVT
Issuer: GE CAPITAL RETAIL BANK / DICK'S SPORTING GOODS
Assignee: Portfolio Recovery Associates, LLC
Account Number: * * * * * * * * * ** *4634
Date Account Opened: August 10, 2010
Date of Last Payment: November 22, 2011
Date of Charge Off: May 28, 2012
Balance at Purchase: $992.64
Purchase Date: June 28, 2012
Balance at Charge -Off: $992.64
Less Payments: $.00
Balance Due: $992.64
13 -16104
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, Ricky L. Vaughan 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 /
DICK'S SPORTING GOODS ( "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 BRIGITTE EVANS ( "Debtor ") to the
Account Seller the sum of $992.64 with the respect to account number ending in * * * * * * * * * ** *4634, as of May 28, 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 $992.64 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 Recove s, LLC
B Rid , Custodian of Records
ubscri d an o t for m on of MAY Q S ,aan 4
Notary Public WMYwldFa [_ ROMA =slues
ommonwealth Virginia
13 -16104 Notary Public
Commission No. 349865
Commission Expires 01!31/2017
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used :for that ptupose.
GECPO4
GE Capital
BILL of SALE
PRA Fresh — ,Tune 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 Gulati -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:
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
GE Capital
BILL of SALE
PRA Fresh — .Tune 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.
By: By:
Title: Glenn Marino -EVP Title: Glenn Marino - President
RFS Holding, L.L.C. GEM , L .
By: By: _
Title: � �� C�� IZ _ Title: 3 "1 G?
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff "��,
Jody S Smith
Chief Deputy $
Richard W Stewart
SolicitorFr�
Portfolio Recovery Associates, LLC
vs. Case Number
Brigitte Evans 2013-2888
SHERIFF'S RETURN OF SERVICE
05/24/2013 07:26 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: Brigitte Evans at 3910 Church Street, Hampden Twp, Camp Hill, PA 17011.
NOAH CLINE, DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
May 29, 2013 RON � R ANDERSON, SHERIFF
(c)County Suite Shenft,Ioleosoft.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. 13-2888
V.
rnCO L-
BRIGITTE EVANS r
3910 CHURCH ST tj
CAMP HILL PA 17011 PRAECIPE FOR DEFAULT
Defendant JUDGMENT
:z b ES
r-- rn
:z
Filed on Behalf of Plaintiff
Counsel of record f/o <i's-yarty
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
OLW
This come-mmication is fi-om a debt collector is an attempt to collect a debt.
Any information obtained will be used for that put-pose.
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. 13-2888
V.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant,BRIGITTE EVANS for failure to
answer the Complaint.
(X) Amount Due $992.64
Less Credits $.00
TOTAL $992.64
(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.
W 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.
W Pursuant to Pa.R.C.P.23 1.1,1 certify that a written notice of intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be en�tpr
and to his/her Attorney of
record,if any,after the default occurred and at le ten days pri o th date of the filing of this
praecipe and a copy of the notice is attached.
Date: I 'e —
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
"Mis comin'tmication is from a debt collector is an attempt to collect a debt.
Anv intonnation obtained will. be used for that pm-pose.
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. 13-2888
V.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
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$992.64,plus interest,on .
(X)A copy of all documents filed with the Prothonotary in support o e withi dgm stare attache
By:
If you have any questions regarding this Notice,please co a the filing pa y.
Date: - 4
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 from a debt collector is an attempt to collect a debt.
Any information 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
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
RE: Portfolio Recovery Associates, LLC
VS. BRIGITTE EVANS
13-2888
Dear BRIGITTE EVANS:
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
13-16104
This conitnunication 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. 13-2888
V.
BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
Defendant
TO: BRIGITTE EVANS
3910 CHURCH ST
CAMP HILL PA 17011
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
kotreff 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 co.inmunicatioil is from a debt collector is an aiterript to collect debt.
Any itiforin-ation obtained will be used for that purposie,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA
CIVIL ACTION -LAW
PORTFOLIO RECOVERY ASSOCIATES,
LLC
120 Corporate Blvd
Norfolk,VA 23502 No. 13-2888
Plaintiff
V.
BRIGITTE EVANS
3 910 CHURCH ST
CAMP HILL PA 17011
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
3910 CHURCH ST
CAMP HILL PA 17011
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:
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
13-16104
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-01-201302:26:16
SCRA 3.0
Status Report
Pursuant to Scry cemembers Cif Relief Act
Last Name: EVANS
First Name- BRIGITTE
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 Individuals'active duty status based on the Fictive 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 duly stetus within 367 days preceding the Acdve,Duty Status Date
The Member or HWHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date 0 Notification End Date Status Service Component
NA NA - No NA
This response reflects whether the ihdividual 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.
.�
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
13-16104
a 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:hftp:/twww.defenselink.mil/faq/pistPC09SLDR.htmf. 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: L307R9B8W0A1E10