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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