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Home My WebLink About13-3606 Supreme Comk of Pennsylvania Cour o thon Pleas ;J `! t For Prothonotary Use Only: Tlyi E STAMP Cl �OVC'�et Docket No: CUMBF >County The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace thefiling and service of leadin s or other a ers 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 1 Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC JIM DRASHER T I Dollar Amount Requested: X within arbitration limits O Are money damages requested. ®Yes ❑ No q (Check one) outside arbitration limits N! 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 Se] 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 S mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: [3 Employment Dispute: Other E] Other: T E] Other: MASS TORT Q ❑ Asbestos N ❑ Tobacco C] Toxic Tort -DES REAL PROPERTY MISCELLANEOUS C] Toxic Tort - Implant ❑ Ejectment E] Common Law /Statutory Arbitration B ❑ Toxic Waste C3 Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Other: E] 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: 13 -13203 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 , 7 '11 ` r_ Mark R. Garvey, Esquire PA Bar # 312686 i i t PRO � �7'�� Portfolio Recovery Associates, LLC rat rti 'i Norfolk, VA Blvd ��I� J ��;�;' 21 �� IC: TELE: 1- 866 - 428 -8102 "'I't- TERLANp COUP4r y FAX: (757) 518 -0860 PENNSYLVAN Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC n 120 CORPORATE BLVD 3- NORFOLK, VA 23502 No. J �Ll/ �(� l• Plaintiff, V. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 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 13 -13203 (800) 692 -7375 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. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 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 -13203 Esta cotnunicacion es de un. cobrador de deudas y es un intent do cobrar una deuda. Cualquier .in.from.acion sera util.irada 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. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 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, JIM DRASHER, is an adult individual with last known address of 222 CHESTER RD, ENOLA PA 17025. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on November 14, 2007 with account number * * * * * * * * * ** *9476 (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. Thi.s communication is from a debt collector and is an attempt to collect a debt. Any information 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 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 October 21, 2010. 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 $871.50. 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, JIM DRASHER , in the amount $871.50, plus os 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 -13203 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, odicole J. M 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. MAY 21 2013 Date: By: Nicole J. Moore Custodian of Records 13 -13203 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 t� Norfolk, VA 23502 Telephone: 1- 866 - 428 -8102 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *9476 JIM DRASHER Account Holder: JIM DRASHER 222 CHESTER RD ENOLA PA 17025 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *9476 Date Account Opened: November 14, 2007 Date of Last Payment: October 21, 2010 Date of Charge Off: May 26, 2011 Balance at Purchase: $871.50 Purchase Date: March 29, 2012 Balance at Charge -Off: $871.50 Less Payments: $.00 Balance Due: $871.50 13 -13203 GECO02 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. Nicole J. Moore 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 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 March 29, 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 JIM DRASHER ( "Debtor ") to the Account Seller the sum of $871.50 with the respect to account number ending in * * * * * * * * * ** *9476, as of May 26, 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 $871.50 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. rtfolio Recovery Assoc tes, LC FViCOIe J. mow dy: Custodian of Records MAY 212013 Subs a d sworn to before me on of , 2013 V NL Notary Public ---_ ' Tavana C. Uzzle Commonwealth of Virginia 13 -13203 Notary Public Commission No, 302460 My Commission Expires 113112017 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used fdr• that purpose. GECO02 GE Money Bank BILL of SALE PRA 120 -day Mid Prime — March 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 each Transfer Date, and as further described in the Agree -tent. General Electric Capital Corporation GEN19 Lendin -. Inc. Title: Gicun Marino -Vice President Title: Stephen Motta- Director GC Capital Retail Bunk Monogram Cr(fdit Sen ices, L.L.C. B 'n iJ — _ _.__ ...._ Title: Glenn Marino -EVP Title: Gl,,,,n \- Iarino- President RFS Holding, L.L.C. GEM Holding, L.L.C. By: B Title: Vislial Gulati -CFO Title: Vishal Gulati -CFO GE Money Bank BILL of SALE PRA, 120 -day Mid Prime — March 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 each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By.) Title: Glenn Marino -Vice President Title: Stephen Motta- Direr +or GE Capital Retail Bank - vl.onogram Credit Services, L.L.C. By: By: Title: G!ej: 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 Money Bank BILL of SALE PRA 120 -dav Mid Prime — March 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 each Transfer Date, and as farther described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc:. By: v By: Title: Glenn Marino -Vice President Title; Stephen i'vlotta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: _- 1 isle: Glenn Marino -EVP Title: Glenn Marino - President RFS Holdine, ? .L.C. CEtv1 Holding, L.L.C. B - � ,t Title: . Title: �Gw �� 5c1G z SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ r ii�r Ronny RAndersonR ��L cw i�-vr=f(� 1NCIO�tJ� `,, Sheriff ,�v.�tix�r aC�`orurifrr�{jar Jody S Smith 2313 JUL 10 AM 9: 4 9 Chief Deputy } Richard W Stewart CUMBERLAND COUNTY Solicitor Of OF TH1VERIFF PENNSYLANIA Portfolio Recovery Associates, LLC Case Number vs. 2013-3606 Jim Drasher SHERIFF'S RETURN OF SERVICE 07/01/2013 07:18 PM- Deputy Shawn Harrison, being duly sworn according to law, s th req ested Complaint &Notice by"personally" handing a true copy to a person representing t e el to b the Defendant, to wit: Jim Drasher at 222 Chester Road, East Pennsboro, Enola, PA 1 0 SH AR , DEPUTY SHERIFF COST: $44.95 SO ANSWERS, fry �•� 2�"----`'""`" July 05, 2013 RON W� R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. t ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES,LLC ' 120 Corporate Blvd : Norfolk, VA 23502 f Plaintiff No. 13-3606 CIVIL ,,.r�•,1', � �, V. JIM DRASHER -37 C--) s- 222 CHESTER RD -, ENOLA PA 17025 PRAECIPE FOR DEFAULT - Defendant JUDGMENT Filed on Behalf of Plaintiff nsel of rec or is Party Date: 4 I�- 0 Robert N. Polas, 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 a� (2�Qc?(4 This commu-nication is from a debt collector is an attempt to collect a debt. Any information obtained.will be used for that purpose. � � C L ��► LE 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. 13-3606 CIVIL V. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 Defendant : PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, JIM DRASHER , for failure to answer the Complaint. (X) Amount Due $871.50 Less Credits $.00 TOTAL $871.50 (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 bee Thyd to his/her Attorney of record, if any, after the default occurred and a e st ten days or to the ate of the filing of this praecipe and a copy of the notice is attache . Date: Robert N. Polas, Yr., Esquire, #201 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 conirnunication is from a debt collector is an. attempt to collect a debt. Any infonuation 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. 13-3606 CIVIL V. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 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$871.50,plus interest, on . c , (X)A copy of all documents filed with the Prothonotary in suppoLof i in ju in t i attached./-' , If you have any questions regarding this Notice,pleas4ct the fili g rty. 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 cornlnimi.cation is from a debt collector is an. attempt to collect a debt. Any in.forination 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) July 25, 2013 JIM DRASHER 222 CHESTER RD ENOLA PA 17025 RE: Portfolio Recovery Associates, LLC VS. JIM DRASHER 13-3606 CIVIL Dear JIM DRASHER: 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 13-13203 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. 13-3606 CIVIL V. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 Defendant TO: JIM DRASHER 222 CHESTER RD ENOLA PA 17025 DATE OF NOTICE: July 25, 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 Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 kei ��, 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 Ibis communication is from a debt collector is an attempt to collect a debt. rkny information obtained will be used for that puiT)ose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk,VA 23502 No. 13-3606 CIVIL Plaintiff V. JIM DRASHER 222 CHESTER RD ENOLA PA 17025 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 222 CHESTER RD ENOLA PA 17025 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: Ro ert 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 13-13203 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:Aug-05.2013 02:54:01 SCRA 3.0 Plursumt to Setvicememben Civil Relief Apt Last Name: DRASHER First Name: JIM Middle Name: Active Duty Status As Of Aug-05-2013 On Active Duty On Active Duty Status Date Action 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 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or.histher unit has received party 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. aFJT' A► M_ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 13-13203 ^ . ^ The Defense Manpower Data Center(DMDC)is an organization wthe 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 000strongly 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 v,1mwo). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently rn active duty"responses,and has experienced only x small error rate. m the event the individual referenced above,nv 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 u/the scRA.you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "domnxvonxmirunL:hftpmwvw.upmnaennx.mixmq/pisipconaLDn.mm|. n you have evidence the person was cn 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 awuscApp.§uu1<v>. This response reflects the following information: (1)The individual's Active Duty status vn the Active Duty Status Date(2)Whether the individual left Aunwa Duty status within 367days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty vn the Active Duty Status Date, More information qn "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior m2o1n only some v,the active duty periods less than su 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 uy 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 m the Reserves(T»Rs).Marine Corps Active Reserve(`ns)and Coast Guard Reserve Program Administrator(RPxo). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service n,the National Oceanic and Atmospheric Administration(wo^A Commissioned Corps). Coverage Under the SCRAiQ 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 ason 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 byscRA,as defined m accordance with 10 uscO101WX1>. Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this wmuane 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 o,mup inducted,but who have not actually begun active duty m 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 o«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. pnovm/no erroneous information will cause an erroneous certificate mm,provided. Certificate |D: T4K8A1000Y055C70