HomeMy WebLinkAbout13-4947 Supreme C. o Pennsylvania
Cava f Qom n Pleas y
nr rut n ttryyse l _ ]v <i X11'
C>< ova" a `et
CLIMB s 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 leadings or other a ers as required by law or rules of court.
r Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
Lead Plaintiffs Name: Lead Defendant's Name:
' PORTFOLIO RECOVERY ASSOCIATES, LLC JEANNETTE JORICH
Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
(Check one) outside arbitration limits
ti Is this a Class Action Suit? []Yes ®No Is this an MDJAppeal? ❑ Yes ®No
Name of Plaintiff /A el Y�
's Attorne Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey
PP
❑ 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
a 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
O
G
- 1 Premises Liability — _ —_— —_ [3 Statutory Appeal: Other
❑ Product Liability (does not include —
mass tort) ❑ Employment Dispute:
�, ❑ Slander /Libel /Defamation Discrimination ❑ Zoning Board
❑ Other: ❑ Employment Dispute: Other ❑ Other:
❑ Other:
MASS TORT
---------------------
❑ Asbestos
❑ Tobacco
Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
❑ Ejectment Common Law/Statutory Arbitration
F Toxic Tort - Implant J rY
E] Eminent Domain /Condemnation ❑ Declaratory Judgment
❑Toxic Waste
❑ Ground Rent ❑ Mandamus
❑ Other:
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
0\ ❑ Mortgage Foreclosure: Residential Restraining Order
ea t ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
M ❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
1A I
z: ❑Legal -------- - - - - --
❑Medical
�` ❑ Other Professional:
- - - -- - - - - - -- 13 -57589
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 E ^:
120 Corporate Blvd
Norfolk, VA 23502 `�a;� fir.,
TELE: 1- 866 - 428 -8102 ✓U 1'��I.yp CCI
FAX: (757) 518 -0860 UN3 `,' hds'�'
Attorneys for Plaintiff ANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502 No.
Plaintiff,
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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 A
(717) 249 -3166 1 I /� //
13 -57589 6W / � `'
c �
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
Cafrie 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.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249 -3166
13 -57589
Esta co n es de L111 cobrador de d.eudas y es wi intent do cobras una deuda.
Cualquier in:liromacion sera utilirada 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
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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, JEANNETTE JORICH, is an adult individual with last known address of 82
COUNTRY VIEW EST, NEWVILLE PA 17241.
3. It is averred that Defendant was indebted to GENERAL ELECTRIC CAPITAL CORP / CARE
CREDIT on March 6, 2012 with account number ************1774 (hereafter referred to as
"Account "). A copy of the account history is attached here to and collectively marked as Exhibit
"
4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to
the Account pursuant to the terms and conditions governing said Account. Failure to pay
Defendant's incurred charges on the Account is considered a default.
This communication is from a debt collector and is an atteinpt to collect a debt.
ADY infornrat:ion obtained will be used for that purl -)ose.
5. ' At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and/or for obtaining services.
6. Defendant was provided with copies of the Statements of Account showing all debits and credits
for transactions on the aforementioned Account to which there was no bonafide objection by
Defendant.
7. Defendant was in default with respect to that debt for failure to make the required payments on the
Account.
8. Plaintiff is the purchaser, assignee and /or successor in interest GENERAL ELECTRIC CAPITAL
CORP / CARE CREDIT 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
$945.75.
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, JEANNETTE JORICH , in the amount of $945.75, plus costs of this
action and any other relief as the Court deems just and rea le.
Carrie A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
13 -57589
This comrnun ratio r is from a debt col lector- and is an atternpt to collect a cleft.
Any information obtained will be used for fliat pwl-)ose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Yvette M. Stephen hereby states that he /she is authorized to take this verification on behalf of
said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are
true and correct to the best of his/her knowledge, information, and belief, based upon information
provided by the Plaintiff.
The undersigned understands that false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date: JUL 2 6 2013 By: �Y
Yvette M. S
Custodian of Records
13 -57589
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
XHIBI 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: * * * * * * * * * ** *1774
JEANNETTE JORICH
Account Holder:
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
Consumer Account Product Code: PVT
Issuer: GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT
Assignee: Portfolio Recovery Associates, LLC
Account Number: ************1774
Date Account Opened: March 6, 2012
Date of Last Payment:
Date of Charge Off. October 22, 2012
Balance at Purchase: $945.75
Purchase Date: November 21, 2012
Balance at Charge -Off: $945.75
Less Payments: $.00
Balance Due: $945.75
13 -57589
GESQ78
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, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby
depose, affirm and state as 9110 ws:
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 GENERAL
ELECTRIC CAPITAL CORP / CARE CREDIT ( "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 November 21, 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 JEANNETTE JORICH ( "Debtor ")
to the Account Seller the sum of $945.75 with the respect to account number ending in * * * * * * * * * ** *1774 as of
October 22, 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 $945.75 as due and owing as of the date of
this affidavit.
6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant
is not on active military service of the United States.
Portfolio Recovery Associates, LLC
By: Yvette M. Stephen , Custodian of Records
Subsc ' and sworn to before me on of JUL 2 6 20i 3 2013
S ` U pN W, IEACHOUI
K4 NOTARY PUB' 3C
13 -57589 REGISTRATION * 29236
r COMMONWEALTH OF VIRGINIA
MY MARCH 311, IRES
2014
This corns- nunication. is from a debt collector and is an. attempt to collect a debt.
Any in. ormation obtained will be used for that p iliose.
GE Capital
BILL of SALE
PRA PSCC Fresh — November 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 25 day of June, 2012 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 November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By: 1
Glenn Marino Glenn Marino
Title: _EVP Title: _President
Date: � 1 ( 3 - Date: 11 1 !Z,
General Electric Capital Corporation RFS Holding, L.L.0
By: I �f'7 B
Glenn Marino Y
Joseph Ressa
Title: _Vice President Title: CFO
Date: t Z M 12. Date:
i
GEMB Lending, Inc. GEM Holding, L.L.0
B y : By:
Stephen Motta Joseph Ressa
Title: _Director Title: SFO
Date: Date:
GE Capita!
BILL of SALE
PRA PSCC Fresh — November 2412
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 25 clay of June, 2012 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 November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By:
Glenn Marino Glenn Marino
Title: _EVP Title: President
Date: Date:
General Electric Capital Corporation RFS Holding, L.L.0
By: By:
Glenn Marino Joseph Ressa
Title: Vice President Title: CFO
Date: Date:
GEMB Lending, Inc. GENT Holding, L.L.0
By: By:
Stephen M Joseph Ressa
Title: _Director Title: CFO
Date: jZ Date:
GE Ca ital
_ p
HILL of SALE
PRA PSCC Fresh - November 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 25` day of June, 2012 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 November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By. B y : -
Glenn Marino Glenn Marino
Title: _EVP Title: President
Date: - - - -- - - Date:
General Electric Capital Corporation RF Iding, L.L.
By. By
Gleiui Marino Joseph e a
Title: _Vice President Title: CFO
Date:
Date:
GEMB Lending, Inc. GEM ding4L,L.
Ste -#.
Stephen Mona Joseph Re s
Title: _Director y_ _ Title: - CFO
—
Date: ^ - -^ - - y Date:
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy 2 013 SEP 2 7 AM 10: I
Richard W Stewart
Solicitor « O15 iLANU CO uN M.
PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs. Case Number
Jeannette Jorich 2013-4947
SHERIFF'S RETURN OF SERVICE
09/13/2013 10:45 AM - Deputy Shawn Gutshall, 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: Jeannette Jorich at 82 Country View Est, Upper Frankford, Newville, P;, 4 .
AWRY-SH PUTY
SHERIFF COST: $41.56 SO ANSWERS,
September 23, 2013 RONIR ANDERSON, SHERIFF
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. 13-4947 CIVIL
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241 PRAECIPE FOR DEFAULT
Defendant JUDGMENT
m CD
4 = 7• ,t
�
Filed Behalf of Plaintiff
Co se of record f thi Part
Date:
Robert N. Polas, Jr., Esquire,#20159
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
13-57589
Root act-2131
This communication is from a debt collector is an attempt to collect a debt.
Any information obtained will be used for that purpose.
IV4 � ��.
n =
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. 134947 CIVIL
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant,JEANNETTE JORICH ,for failure to
answer the Complaint.
(X) Amount Due $945,75
Less Credits $.00
TOTAL $945.75
(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
--T-- 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 jud nt is to be entere nd to his/her Attorney of
record,if any,after the default occurred 4aa�sstl ys prior the ate of the filing of this
praecipe and a copy of the notice is attac
Robert N. Polas,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
13-57589
This communication is from a del)t collector is an attempt to collect a debt.
Any i.nforarlation 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. 13-4947 CIVIL
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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$945.75 . ,
(X)A copy of all documents filed with the Prothonotary in support of the i in ju m t it attached.
By:---- °—'�
– ---
If you have any questions regarding this Notice,please co act e filing p rty.
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
13-57589
This communication is from a debt collector is an attempt to collect a debt.
ADy 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. 13-4947 CIVIL
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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
82 COUNTRY VIEW EST
NEWVILLE PA 17241
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 4� 4 1 —____
l
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
13-57589 Attorneys for Plaintiff
This communication is a cleft collector and is an attempt to collect a debt.
Any information obtahied 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)
October 11,2013
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
RE: PORTFOLIO RECOVERY ASSOCIATES,LLC
VS. JEANNETTE JORICH
13-4947 CIVIL
Dear JEANNETTE JORICH:
Enclosed herein please find_a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
Sincerely,
C k-)
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
13-57589
MONA
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. 13-4947 CIVIL
V.
JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
Defendant
TO: JEANNETTE JORICH
82 COUNTRY VIEW EST
NEWVILLE PA 17241
DATE OF NOTICE: October 11,2013
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
13-57589 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.
Results as of:Oct-21-2013 02:50:42
SCRA 3.0
Status Report
Pursuant to Servicememben Civil Relief Act
Last Name: JORICH
First Name: JEANNETTE
Middle Name:
Active Duty Status As Of Oct-21-2093
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component ,
NA NA ENO; NA
This response reflects the ipdfviduals'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 felt active duty_siatus uriihin 367.days preceding the Aclivis Duty Status Date
The Member or HisfHer 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 NANO NA
This response reflects whether the-mdmdual 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' r,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
13-57589
^ . .
The Defense Manpower Data Center(DMDC)uan organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source mdata on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemernbers Civil Relief Act(50 USC App.§501 at seq.mv amended)(xCRA)(formerly known ms
the mpm/mm/0000wilors'ow/Relief Act m1ewo). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. m the event the individual referenced above,m any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status or contacting that person's Service via the
"defense|mxmirunL:httpmxww.dmwnsexnx.uxvfaqfpisIPummuon.xm"/. n you have evidence the person was on active duty for the active duty status
date and you fail m obtain this additional Service verification,punitive provisions of the uonA may ue invoked against you. See onumoApp.§sz1(").
This response reflects the following information:\1>The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Avum
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty*o the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior m2u10 only some of the active duty periods less
than oo consecutive days m 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]l for purposes of responding to a national emergency declared by the
President� pnusurpurteauvpomara|mouu. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
|
unit they support. This includes Navy Training and Administration of the Reserves(TxRs).Marine Corps Active Reserve(ARa)and Coast Guard Reserve
Program Administrator(RpAa). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U'S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRAis Broader in Some Cases
Coverage under the aoeA/s broader m some cases and includes some categories of persons vn active duty for purposes m the sunx who would not ma
reported uavn Active Duty under this certificate. eoRx protections are for Title 1n and Title 14 active duty records for all the Uniformed Services periods,
Title nu periods m Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check m make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates mservice,
Furthermore,some protections of the aoRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty v,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 m active duty.
Those who could rely an this certificate are urged to seek qualified leoo =ouvsumenmuriamat all rights guaranteed m Service members unde mencn*
are protected
wARw|wo: This certificate was provided based ono last name,SSNmate of birth,and active duty status date provided by the requester. Providing
erroneous information will cause wn erroneous certificate toumprovided.
Certificate ID: |5W174E2A]52WBO '