HomeMy WebLinkAbout13-4199 Supreme C ": ,Pennsylvania
Cour f m n Pleas s
i Nel 1 5 A M F
CLIMB County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other a ers as required by law or rules of court.
��\ x Commencement of Action:
Complaint ❑ Writ of Summons
p El Petition
\�
\�
F1 Transfer from Another Jurisdiction ❑Declaration of Taking
" 3 Lead Plaintiffs Name: Lead Defendant's Name:
V` PORTFOLIO RECOVERY ASSOCIATES, LLC MARGARET A BAUM
Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
(Check one) outside arbitration limits
Is this a Class Action Suit? ❑ Yes ®No Is this an MDJAppeal? []Yes ®No
Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey
❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
z �\ 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 E] Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections
❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation
❑ Premises Liability — _ —_ - - -_ _ ❑ Statutory Appeal: Other
�� ..
\ ❑ Product Liability (does not include
mass tort) ❑ Employment Dispute:
❑ Slander /Libel /Defamation Discrimination
El Zoning Board
\?so ❑ Other:
❑ Employment Dispute: Other E] Other:
t
❑ Other:
MASS TORT -- - - - - -_
Q ❑ Asbestos
❑ Tobacco
❑Toxic Tort -DES
REAL PROPERTY MISCELLANEOUS
Toxic Tort - Implant El Ejectment E] Common Law /Statutory Arbitration
❑
❑ Toxic Waste ❑ Eminent Domain /Condemnation [I Declaratory Judgment
E] Ground Rent
Mandamus
1\ \ \\ F-1 Other: ❑ 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 -50200
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686 F` r L4
Portfolio Recovery Associates, LLC u
120 Corporate Blvd �°
Norfolk, VA 23502t�- ,` }
TELE: 1- 866 - 428 -8102 'UMBERLAN -D COUt' j
FAX: (757) 518 -0860 PENNSYLVi\N'A
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD No. /3 .. �I / � 6
N ORFOLK, VA 23502 7 % (�
Plaintiff,
V. /
MARGARET A BAUM
31 S WASHINGTON ST
SHIPPENSBURG PA 17257
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 ^ � 139 9 0
(800) 692 -7375 (� /?
13 -50200
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.
MARGARET A BAUM
31 S WASHINGTON ST
SHIPPENSBURG PA 17257
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 action dentro veinte (20) dias despues que esta Demanda
y Aviso es servido, con entrando por escrito una aparencia personalmerite 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. S1 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 -50200
Esta comunicacion es de un cobrador de deudas y es un. intent do cobrar una deuda.
Cualquier infromacion 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.
MARGARET A BAUM
31 S WASHINGTON ST
SHIPPENSBURG PA 17257
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, MARGARET A BAUM, is an adult individual with last known address of 31 S
WASHINGTON ST, SHIPPENSBURG PA 17257.
3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on July 27, 2006 with
account number * * * * * * * * * ** *8385 (hereafter referred to as "Account "). A copy of the account
history is attached here to and collectively marked as Exhibit "A."
4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to
the Account pursuant to the terms and conditions governing said Account. Failure to pay
Defendant's incurred charges on the Account is considered a default.
5. At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and/or for obtaining services.
This cornaiL mication 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 5, 2011.
8. Plaintiff is the purchaser, assignee and /or successor in interest CITIBANK, N.A. / SEARS and
Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs verification is
attached hereto and collectively marked as Exhibit "A."
9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's
Account, as a result of Defendant and /or any authorized user's use of said Account is in the sum of
$1,275.73.
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, MARGARET A BAUM , in the a t of $1,275. , p s costs of this
action and any other relief as the Court deems just and reas nab
Came A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
13 -50200
This comtnuwii.cation is .fiom 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,
T 19MOM 13 0nd 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 t thorities.
Date: JUN 13 2013 By:
Tamara Bond
Custodian of Records
13 -50200
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
i
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: * * * * * * * * * ** *8385
MARGARET A BAUM
Account Holder:
MARGARET A BAUM
31 S WASHINGTON ST
SHIPPENSBURG PA 17257
Consumer Account Product Code: PVT
Issuer: CITIBANK, N.A. / SEARS
Assignee: Portfolio Recovery Associates, LLC
Account Number: * * * * * * * * * ** *8385
Date Account Opened: July 27, 2006
Date of Last Payment: October 5, 2011
Date of Charge Off: May 15, 2012
Balance at Purchase: $1,275.73
Purchase Date: September 17, 2012
Balance at Purchase: $1,275.73
Less Payments: $.00
Balance Due: $1,275.73
13 -50200
SRSP90
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.
Tamara Bond
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. 1 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 CITIBANK, N.A. /
SEARS ( "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 September 17, 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 MARGARET A BAUM
( "Debtor ") to the Account Seller the sum of $1,275.73 with the respect to account number ending in * * * * * * * * * ** *8385,
as of September 17, 2012 with there being no known un- credited payments, counterclaims or offsets against the said debt
as of the date of the sale.
5. According to the records of said Account Assignee, after all known payments, counterclaims, and /or setoffs
occurring subsequent to the date of sale, Account Assignee claims the sum of $1,275.73 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 milita a of the United States.
Portfolio Recove ociates, C
By: Tamara 13 , Custodian of Records
13 2013 2013
Subscribed and sworn to before me on JU q of ,
Tracy Nicole Parker
;ta bl Commonwealth of Virginia
u Notary Public
m , Commission No. 7509731
13 -50200 My Commission Expires 2/28/2015
This communication is from a debt collector and is an. attempt to collect a debt.
Any info oration obtained will. be used for that purpose.
Contract ID: ?
Document ID:
BILL OF SALE AND ASSIGNMENT
THIS BILL OF SALE AND ASSIGNMENT, dated September 17, 2012, is by Citibank, N.A., a
national banking association organized under the laws of the United States, located at 701 East
50th Street Furth, Sioux Falls, SD 57117 (the 'Bank ") to Portfolio Recoven Associates, LLC,
organized under the laws of the Delaware, with its headquarters/principal place of biuiness at
L30 Corporate Boulevard, Norfolk, VA 23502 ( "Buyer ").
For value received and subject to the terms and conditions of the Purchase and Sale Agreement
dated August 25, 2011, between Buyer and the Bank (the "Agreement "), the Bank does hereby
transfer, sell, assign, convey, grant, . bargain, set over and deliver to Buyer, and to Buyer's
successors and assigns, the Accounts described in Exhibit 1 and the final electronic tile.
Citibank, N.A.
,�-
Bv:
(Signature)
Name: Patricia Hall
Title: Financial Account Manaizr
PRA OS251 Ldoc O
Ronny R Anderson SHERIFF'S OFFICE OF CUMBERLAND COUNTY
'i
Sheriff 1. D- ,F-t=l i F
Jody S Smith �,qyx3gtw C''druubr,"14,+r� -
Chief Deputy
R
13 AUG
ichard W Stewart ,
Solicitor OFT kOFTi� tt€ CUMBERLAND C #tJ x Y
H-NNSYLVANIA
Portfolio Recovery Associates, LLC
vs.
Margaret A Baum Case Number
2013-4199
SHERIFF'S RETURN OF SERVICE
07/29/2013 04:08 PM- Deputy Jason Kinsler, 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: Margaret A Baum at 636 A Walnut Bottom Rd, Shippensburg, PA 17257.
JA ON KINSLER, DEPUTY
SHERIFF COST: $73.20
SO ANSWERS,
July 30, 2013
RON R ANDERSON, SHERIFF
(C)CountySuite Sheriff,Teleosoff.Inc.
.. . :: ,
, ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA
CIVIL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, ••
LLC ••
120 CORPORATE BLVD ••
NORFOLK, VA 23502 No. 13-4199 CIVIL
Plaintiff .
v. ••
MARGARET A BAUM ••
636 A WALNUT BOTTOM RD PRAECIPE FOR DEFAULT
SHIPPENSBURG PA 17257 JUDGMENT
Defendant ----0 "..1`.---=
•
T.... t"3 ;
p (xi _. S,,
r3 Cl �` '
--G •
- LA
Filed on Behalf of Plaintiff .
Counsel of recor or his Party
.4
,0_23_ .3
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
13-50200
a„,,161t,,so,,,g,
CJ 9
ei_ aci -)?, I
This communication is from a debt collector is an attempt to collect a de t.
helititatk' i
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. 13-4199 CIVIL
v.
•
MARGARET A BAUM
•
636 A WALNUT BOTTOM RD
•
SHIPPENSBURG PA 17257
•
Defendant
•
•
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant,MARGARET A BAUM ,for failure to
answer the Complaint.
(X) Amount Due $1,275.73
Less Credits $.00
TOTAL $1,275.73
(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.•: • his/her Attorney of
record,if any,after the default occurred and at least to ays prior to e data of the filing of this
praecipe and a copy of the notice is attached.
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
13-50200
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. 13-4199 CIVIL
v.
MARGARET A BAUM
636 A WALNUT BOTTOM RD ••
SHIPPENSBURG PA 17257 ••
Defendant •
•
•
NOTICE OF JUDGMENT
(X)Notice is hereby given that a judgment in the Bove-captioned matter has been entered against you in
the amount of$1,275.73,on 'eo PS 3 .
re 0
(X)A copy of all documents filed with the Prothonotary in support of the with' j dgnen is/ att d
By: *'=
If you have any questions regarding this Notice,please contact g party.
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
13-50200
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)
September 10,2013
MARGARET A BAUM
636 A WALNUT BOTTOM RD
SHIPPENSBURG PA 17257
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. MARGARET A BAUM
13-4199 CIVIL
Dear MARGARET A BAUM:
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
13-50200
This communication is from a debt collector and 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. 13-4199 CIVIL
•
v.
•
MARGARET A BAUM
•
636 A WALNUT BOTTOM RD
•
SHIPPENSBURG PA 17257
•
Defendant
TO: MARGARET A BAUM
636 A WALNUT BOTTOM RD
SHIPPENSBURG PA 17257
DATE OF NOTICE: September 10,2013
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
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
13-50200 Attorneys for Plaintiff
This communication is from a debt collector and 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. 13-4199 CIVIL
v.
•
•
MARGARET A BAUM
•
636 A WALNUT BOTTOM RD
•
SHIPPENSBURG PA 17257
•
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
636 A WALNUT BOTTOM RD
SHIPPENSBURG PA 17257
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.
Ati
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) (866) 428-8102
(F) (757) 518-0860
13-50200 Attorneys for Plaintiff
This communication is a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
I Results as of:Sep-25-2013 02:50:54
SCRA 3.0
Status Report
Pursuant to Servicernembers Civil Relief Act
Last Name: BAUM
First Name: MARGARET A
Middle Name:
Active Duty Status As Of: Sep-25-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA )No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA -No NA
This response reflects where the individual left active duty status within 367 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 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.
Yhrthy,
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
13-50200