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HomeMy WebLinkAbout13-4570 , Supreme C Cour�yof Com `� n Pleas f±�.'` rl ', ; For Prothonotary Use Only: THME STAMP Ci IOV e,S�et Docket No: CUMB3A County The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace the filing and service of leadin s or other papers as required by law or rules of court. Commencement of Action: S j ® Complaint ❑ Writ of Summons ❑ Petition Transfer from Another Jurisdiction E ❑ ❑Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC DALE C JUDY T' Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits O (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 Sel 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: El Employment Dispute: Other ❑ Other: T I E] Other: MASS TORT _ Q ❑ Asbestos F Tobacco N REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑Ejectment E] Common Law /Statutory Arbitration B ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment E] Other: [3 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 -50456 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 fir .jn F (r r- #_a� -�.. Mark R. Garvey, Esquire PA Bar # 312686 t t1'0 l oP Portfolio Recovery Associates, LLC 120 Corporate Blvd 1 3 i Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 p�P AtiD FAX: (757) 518 -0860 YL VA NIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD / I.A No. NORFOLK, VA 23502 ` V 1 Plaintiff, V. DALE C JUDY 207 CONODOGUINET AVE 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 —7 13- 50456a This communication is from a debt collector and is an attempt to collect a debt. S _ 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. DALE C JUDY 207 CONODOGUINET AVE CAMP HILL PA 17011 Demandado. NOTICU LISTED 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 13 -50456 Esta con.un.icacioji 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. DALE C JUDY 207 CONODOGUINET AVE 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, DALE C JUDY, is an adult individual with last known address of 207 CONODOGUINET AVE, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to CITIBANK,N.A. / SEARS PREMIER CARD on October 5, 2008 with account number ************6464 (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 communication is from a debt collector an.d 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 July 19, 2011. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK,N.A. / SEARS PREMIER CARD 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 $1,079.76. 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, DALE C JUDY , in the amount of $1,079.76, plus co is 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 -50456 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, Larry J. Andrews hereby states that he /she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: 013 BY' Larry J. Andrews Custodian of Records 13 -50456 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 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 Norfolk, VA 23502 E Telephone: 1- 866- 428 -8102 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *6464 DALE C JUDY Account Holder: DALE C JUDY 207 CONODOGUINET AVE CAMP HILL PA 17011 Consumer Account Product Code: PVT Issuer: CITIBANK,N.A. / SEARS PREMIER CARD Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *6464 Date Account Opened: October 5, 2008 Date of Last Payment: July 19, 2011 Date of Charge Off: February 20, 2012 Balance at Purchase: $1,079.76 Purchase Date: May 18, 2012 Balance at Charge -Off: $1,079.76 Less Payments: $.00 Balance Due: $1,079.76 13 -50456 SRS063 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, Larry J. Andrews , 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 CITIBANK,N.A. / SEARS PREMIER CARD ( "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 May 18, 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 DALE C JUDY ( "Debtor ") to the Account Seller the sum of $1,079.76 with the respect to account number ending in * * * * * * * * * ** *6464, as of February 20, 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 $1,079.76 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 o active military service of the United States. Portfolio Recovery Associates, LLC --W � By: 1 arry J Andrews Custodian of Records s i ed and sworn to before me on J o` - 1 52013 ublic 13 -50456 This conAmunication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 595 663 Contract ID: PR I SP t EM08251 l Document ID: 051012PRISPIEMBI BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT dated May 18, 2012, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank ") to Portfolio Recovery Associates, LLC, organized under the laws of the Delaware, with its headquarters/principal place of business at 130 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 file. Citibank, N.A. By: (Signature) Name i ► c:s C- ifzr I I Title: A -t c.-F ( Yl PRA 08251 Ldoc SHERIFF'S OFFICE OF CUMBERLAND COUNTY '(----' Ronny R Anderson ^XM M C-- Sheriff Jody S Smith Chief Deputy Richard W Stewart C.) j=:z Solicitor OPME OF T�4,—Z SHERIFF Portfolio Recovery Associates, LLC Case Number vs. 2013-4570 Dale C Judy SHERIFF'S RETURN OF SERVICE 08/06/2013 07:33 PM- Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Jo Judy, wife, who accepted as "Adult Person in Charge"for Dale C Judy at 207 Conodoguinet Avenue#2, Hampden Township, Camp Hill, PA 17011. JE (5ADZI, DEPUTY C-0000 SHERIFF COST: $44.95 SO ANSWERS, August 07, 2013 RbNW R ANDERSON, SHERIFF fc)CokintySulio Sheriff,TrIcosoft,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. 13-4570 CIVIL Plaintiff . v. • DALE C JUDY •• 207 CONODOGUINET AVE PRAECIPE FOR DEFAULT r CAMP HILL PA 17011 JUDGMENT Defendant • 0--).3 _--. '\ t--, • () i '-,C-: .c *.-c--• y� I" Filed on Behalf of Plaintiff .i _ Counsel of record his Party "`` 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 13-50456 000A 10\kb.Scpci ct.thl e L 4 apEqg9 This communication is from a debt collector is an attempt to collect a debt, , C1' - Any inthrmation obtained will be used for that purpose. 1‘16 �V--1 ' 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. 13-4570 CIVIL v. DALE C JUDY •• 207 CONODOGUINET AVE CAMP HILL PA 17011 •• Defendant • • • PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,DALE C JUDY ,for failure to answer the Complaint. (X) Amount Due $1,079.76 Less Credits $•00 TOTAL $1,079.76 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237(Notice for Final Judgment or Decree),I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.231.1,I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of record,if any,after the default occurred and at least ten :. prior to the o the filing of this praecipe and a copy of the notice is attached. Robert N. Poasas, Jr., squire, # 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 13-50456 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. 13-4570 CIVIL v. DALE C JUDY 207 CONODOGUINET AVE 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$1,079.76. (X)A copy of all documents filed with the Prothonotary in support of the 'thin jut q ent i . attached. By: If you have any questions regarding this Notice,please c o e filing ..rty. Rob- 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 13-50456 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 DALE C JUDY 207 CONODOGUINET AVE CAMP HILL PA 17011 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DALE C JUDY 13-4570 CIVIL Dear DALE C JUDY: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, :.;, .: w a 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 13-50456 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. 13-4570 CIVIL • v. • DALE C JUDY • 207 CONODOGUINET AVE • CAMP HILL PA 17011 • Defendant TO: DALE C JUDY 207 CONODOGUINET AVE CAMP HILL PA 17011 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 13-50456 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. 13-4570 CIVIL • v. • • DALE C JUDY • 207 CONODOGUINET AVE • 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 207 CONODOGUINET AVE 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. f I 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 13-50456 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. Results as of:Sep-25-2013 02:42:03 SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: JUDY First Name: DALE C 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 Data 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. 41114110 • 411111110+47.„..„, Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 13-50456