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Home My WebLink About13-5113 Supreme C. . Pennsylvania Cour� f Gem n Pleas r ;1 .g 1 �� CUMB wCounty 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. 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 DEBRA KAIL 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 PRIMARY CASE. If you are making more than one type of claim Y g Yp , 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 E] Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation \" ❑ Premises Liability — _ _ y pp - - - - - - - ❑ Stat Appeal: s „ ❑ Product Liability (does not include _ \ mass tort) [I Employment Dispute _ —_ —_— _ —_ -- — ❑ Slander /Libel/Defamation Discrimination ❑ Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: MASS TORT ❑Other ❑ Asbestos ` ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES [ E J El Common Law /Statutory Arb itration ❑Toxic Tort - Implant ❑Toxic Waste L] Eminent Domain /Condemnation El Declaratory Judgment ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations - - - - -- ❑ Mortgage Foreclosure: Residential Restraining Order - - - - -- -- - - - - -- ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto IM, ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: _— ____-- _ - -_ —_— ❑ Legal -- ------ - - - - -- -------- - - - - -- ❑ Medical y ❑ Other Professional: MAN; t } 13 -54643 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 No . Sl NORFOLK, VA 23502 J .� Plaintiff, coo — ' X V. Tt � r- ;* G7 'L7 DEBRA KAIL rr 848 LINSEY RD �� -n CARLISLE PA 17013 =.o c 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 s 13 -54643 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. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 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. Sl 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 -54643 Esta co:rnu:nicacio:n es de u:n cobrador de deudas y es un intent do cobrar una deuda. Cualquier nfi-ornacion 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. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 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, DEBRA KAIL, is an adult individual with last known address of 848 LINSEY RD, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / JC PENNEY on February 5, 2004 with account number * * * * * * * * * * * * 1641 (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 co►nmuni.cati.on is from a debt collector and is an. attempt to collect a debt. Any infort nation 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 2, 2009. 8. Plaintiff is the purchaser, assignee and /or successor in interest GE MONEY BANK, F.S.B. / JC PENNEY 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 $779.54. 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, DEBRA KAIL , in the amount of 7 .54, plus cost 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 -54643 This corniT. unication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purliose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cristina Patterson 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. JUL 8 2013 Date: Y A-4L 4�7�� C:ristina r attepe ry Custodian of Records 13 -54643 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 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: * * * * * * * * * ** *1641 DEBRA KAIL Account Holder: DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 Consumer Account Product Code: PVT Issuer: GE MONEY BANK, F.S.B. / JC PENNEY Assignee: Portfolio Recovery Associates, LLC Account Number: ************1641 Date Account Opened: February 5, 2004 Date of Last Payment: October 2, 2009 Date of Charge Off: May 11, 2010 Balance at Purchase: $779.54 Purchase Date: March 31, 2011 Balance at Charge -Off: $779.54 Less Payments: $.00 Balance Due: $779.54 13 -54643 GECK76 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. Cristina Patterson 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. 1 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 GE MONEY BANK, F.S.B. / JC PENNEY ( "Account Seller "), which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on March 31, 2011. 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 DEBRA KAIL ( "Debtor") to the Account Seller the sum of $779.54 with the respect to account number ending in * * * * * * * * * * ** 1641, as of May 11, 2010 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 $779.54 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. P tfoli ecovery ss ciates L C By: cdstinn Patterson , Custodian of Records JUL 31 2013 sZ?' d nd sworn to before me on of ' 2013 is _ Susan W Teach 13 -54643 4 commonwealth of Virginia Notary Public Commission No. 29236 qty commission ExPires 0313112014 This communication Is from a debt collector and is an. attempt to cotlect a debt. Anv inf:onnation obtained will be used for that purpose.. GE Money Bank BILL of SALE PRA 120 -day Mid Prime — March 2011 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 the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (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 March 19, 2011, and as further described in the Agreement. GE Money .Bank A By: Michael Lagn es . Title: CFO Retailer Credit' . ices Inc By : Brent Wallace Title: President General Electric Cap' al rporation By: Title: Vice . resid t � 7 The JCPenney Gift Card give them something to remember! • _ _ in stores, jcp.com & 1 -800- 222 -6161 Terms and conditions are applied to Gift Cards /e-Gift Cards. V JCPenney DEBRA K KAIL Visit us at jcp.com /credit Account Number. _16411 Customer Service: 1- 800 -527 -3369 P.O. Box 961131 El Paso TX 79998 -1131 Summary of Account Activity Payment Information Previous Balance $779.54 New Balance $0.00 - Other Credits $ 779.54 Minimum Payment This Period $270.00 New Balance $0.00 Amount Past Due $0.00 Total Minimum Payment Due $270.00 Credit Limit $570.00 Payment Due Date 05/13/2010 Available Credit None Statement Closing Date 05/11/2010 Late Payment Warning: If we do not receive your minimum Days in Billing Cycle 28 payment by the date listed above, you may have to pay a late fee up to $39.00. Transaction Summary _ Tran Balance Date Reference Number Typ Description of Transaction or Credit Amount 05/11 F911900GKO0999990 R CHARGE OFF ACCOUNT- PRINCIPALS ($503.21) 05/11 F911900GK00999990 R CHARGE OFF ACCOUNT *FINANCE CHARGES` ($276.33) Fees TOTAL FEES FOR THIS PERIOD $0.00 Interest Charged 05/11 Interest Charge on Purchases $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2010 Totals Year -to -Date Total Fees Charged in 2010 $78.00 Total Interest Charged in 2010 $68.12 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Balance Expiration Percentage Subject To Interest Balance Type of Balance Date Rate Interest Rate Charged Method Regular . NA 29.99% $0.00 $0.00 E PLEASE NOTE YOUR MAILED PAYMENT MUST BE RECEIVED BY 5 P.M. (ET) OR YOUR IN-STORE PAYMENT MUST BE RECEIVED DURING STORE HOURS ON THE DUE DATE. NOTICE: Your payment may be convened into an electronic debit. See reverse for details, Billing Rights Information and other important information. PLEASE DETACH AND RETURN THIS STUB WITH YOUR CHECK PAYABLE TO GEMB. — I - Account Numbe 64 11 Total Minimum Amount Past Due Payment New Balance Payment Due Due Date $270.00 1 $0.00 OSI13'2010 $0.00 FILL IN TOTAL PAID s ❑ ❑ [11111. ❑ ❑ II IIII II II III Ilill I IIIIIIII III III New address or email? Print changes on the back. DEBRA K KAIL 848 LINSEYRD CARLISLE PA 17013 P.O. Box 960090 Odando FL 32896 -0090 5433 A1H 1 5 13 100511 ZXPAGE 1 of 1 9119 3400 0175 OICW5433 • The More You Shop, The More Privileges You Earn JCPenney Privilege' Gold Card' JCPenney Privilege* Platinum Card' • JCPenney Privilege Savings Certificate(s) ID Theft Protection • Birthday Reward Certificate • jcp.com &catalog Free Shipping Event(s)" 'S end 5500 or more on merchandise or services with your JCPenney Card over 2 or more uni ue sho n da • • JCPenney Privilege Gold status. S end $1,D00 or more nn merchandise or services with our J�Penne Card aver each t uniqu sho n days p y PPi A Ys in each calendar year to earn or maintain 2 more calendar year to earn or maintain JCPenney Privilege` Pitinum status. We reserve the right to change of cancel the JCPenney niqu e slo T ing r any or all of its benefits at any time without notice. If your account Is not in good standing and /or you no longer meet our credit criteria, you may be ineligible for the JCPenney Privilege` Program and /or unable to lake advantage of JCPenney Privilege` Program promotions. The JCPenney Privilege' Program is available only while you are a resident of the contiguous 48 United Slates, Puerto Rica and Alaska. 'ID Thep Proteeiian: Identity theft insurance underwritten by subsidiaries or affiliates of Chartis, Inc. The description herein is a summary and intended for informational purposes only and does not include all terms, conditions and exclusions of the policies described. Please refer to the actual Policies for terms, conditions, and exclusions of coverage. Coverage is not available in New York and may not be available in o th er j ur is dictions. Call 1 -800- 527 -7717 to learn more and receive a summary description of this benefit. — jcp.yom & catalog Free Shippping Event(s): Residents of Alaska and Puerto Ricu are not eligible for the icp.com $ catalog free shipping benefit. Other restrictions apply, see specific offer for complete details. Cardmember benefits are subject to change or cancellation at any time without notice. 8anknrptcyNotice: Ifyou file bankrupicyyou must send us notice, including account numberam, all information related lathe proceeding tothe olbwing address: GE Money Bank, Atin: Bankruptcy Dept., P.O. Box 103104, Roswell, GA 30076. Youraccount is owned and serviced byGEMoney Bank: For completeterms and conditions of your account, consult yourCredit Card Agreement. =es ervce ue infor tion untm rmahon,peaseca eto reenum eI I a on o thlstal, I inl. nlessyournameisliste coot is ouraoess fat information on the *count maybe limited. You may also mail questions (but of payments) to: P.O. Box 981131, EI Paso, TX Please include youracount numberon any correspondence you sendto us. end payments to the address listed on the remit Portion of this statement or online elowforyourBillingRighisandotherimportantinormation .ox981403,EIPaso,TX79998 -14Telephoningabouib Ingo rrorswillnoipreserveyourrightsunderfeder allow. ourri hts, Ieasewriletocur8illin In uiriesAddress ,P.O.B0 3. g electronically forany check or other instrument that you send t by 1nRlei ng en ACH (electronic) d st the amount t heck ar tnshumem to your account. Your check or instrument will not be returned to you by us or your bank. Your bank account may be debited as early as the same day we receive your payment. You may choose not to have your payment collected electronically by sendingg our ppaayyment (w8h the ppay Do addressed to: ment stub), in your own envelope— notthe enclosed window envelope ' P.O.Box53 . Atlanta,GA 0353 .0945andnotthePaymenlAddress. What To 03 El if You Think You FindA Mistake On Yo urStatement: If you tthink there is an error on your statement, write to us at: GE Money Bank, P.O. uteFormfoundat information: - Account r nt .,Yournametanda countrnumlherD•sDol /aramountThe paramount r dit e l su u t n llowi o daysaftertheerrorappearedon you problem: If you think there is an you erro on yyour bill, describe what believe is wrong and why you believe It is a mistake. You must contact us fi 60 rstaCe you ment. Youmustnotiffyyusofanypotentialerrors orelectronicallYoumaycallus,butifyoudowe are not required to investiggateanyppotentialerrorsandyoumayhavetopaytheamountinquesrft Whilectinvestiggy ). atewhetherornottherehasbeen an error, the following are rue • We cannot try to collect the amount in question, or report you s delinquent on the amount • The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made a mistake, you will not have top? the amount in question or any interest or other fees related to that amount. • While you do not have to pay the amount in question, you are r credit responslbl6 for the remainder o fyourbalance. -We can a g YourRi g htsif YouA reDissatisfied gg WithYourCredit CabPurchases ' lfy a mou n t uaredissatisedwitththetggoodsorservicesthatyouhavegppurchasedwith the purchase, T6 use this rig alll of tha following mu t be t o pr :1Te purcch se must have been n your home state or ithin 100 miles due our current mailingg address, and the purchase price must have been more than S50. (Noe: Neither of these are necessary if your purchase was based on an advertisemenfwemailedtoyou ,orifweownthecom anythatsoldyout hegodaoyrservices.); 2) Youmusthaveusdyourcreditcardorthepurchase. UpcIfiorthepuprchase hlfalloIthecritena boveareMmtandyouarestilldssatissfiedwiththepurchasecontactus a (oeletronically)etP.O.Bolx 981403,EIPas ,TX79998-1403(www com /credit. While we investiggate, the same rules apptyto the dispute amount as discussed above, Afte'r we finishourirnestigaton ouourdeciSion.At tpoint ,ifwethinkyou owe anamountand oudonot lnformafionAbout Pa wewlltelly yments:Youm paymomthanfheTotal MiMmumpaymentatanytime:Payments eceived 5 00PM((ET)onanyday m n U.S. c as dol l a rs drawn on ay. Cre . fine 0yourAccount maybe delayed up to hvd days if payment (a Sin received at the Pa mentAddress, (b) Is not written lcommunilcafion sconcemng s gdispputed factionofadls l amounts r includ glany checkorotherpalyymentm° sirumenfthatP )a)lndcattesuhattnepomf -Pa msnrtules payment in full" oris tendered asfullsatisda mount; or( n) istenderedwitholherondtonsorlimilalions (`Disputedayments "),must be mailed ordel vered to us at P.O. Box 981403 El Paso, , TX 7 ute 9998-1403. Credits To YourAccount: An amount shown in parenthesis is a credit or credit balance unless otherwise indicated. Credits will be applied to your previous balance immediately upon receipt, but will not satisfy any required payment that maybe due. Telephone Monitoring: To ensure that you receive accurate and c customer service, your telephone calls with us may be monitored by our o courteous Cre Repots and AecounI Information: If g y r ou believe that w monitorin have reported inaccurate information about you to a consumer reporting agency, incorrect. If you US have a of the credit ditreport that e In i accurate mation, please include a copy of that a eport. to why s well, We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account maybe reflected I credit report. Information About erect Char Charrgg Returned Check Fees, Late Pa ent Fees and insurance premiums, if applicable, are not included in the balance subject iolnterestCharrg arge rMethdsA,B CandD. Returned CheckFeesandLatePaymen( Fees( butnotinsurancepremiums )areincludd in the balance subject to Interest Ch or M �. taking the balance each daay inc includes any unpaid pre oil cgInterest bala esubtcraacct any payments and creddits, ° su m o t rthe e II be no balance su6jed to Interest d ivid e Charge for a bi l cycl nu mber f there s no pp balance on g us forthe bit I aicclyyy Be lance. sumof ourpateda zeroceditsonyouraccountduringI ebillingeyeasatleastequalt othepreviousbalance. AnyAverageDailyBalance oflessthan A rggexcePtnew treated a are of includ d in the daily balance. e. D. The same as Metho except unpaiidlnterest Charg are not Included in the that and it o he dailp balancehThis g us day's COS ng ba wiltbe the peaing olio ing daInterest tt end of the billingcycle, we�laydduot hedailylnteresiChargestoget thetotalperiodiclnterea- ChargeforthebdI cycle. YOU Candeterminet his Interest Chargeby than II befreatd as ze�ote the halance subject to Interest Charge m ultiplied by the number of days in the billingcycle. Any Daily Balance of less BalanceTypeontheface0ffhisstatementrefemtothe followinggpaymentmethed Siig JarChar e;M= MajorPuchaseCharge;C= Commercial. You can request to receive statements in Spanish by calling customer service numbera11- 800 - 542800. Neaninglmpaire f. TOD users cal11�00-444 -1732. OICW5433 - 10- 03/192010 Use of Information About You and Your Account: Our Privacy Policy describes or collection and disclosure of information about you and your Account. If you would like another copy of the Pr Policy, please call us at the customer service telephone number indicated on the front of this statement. In addition, information about you and yourAccounl is furnished to JCPenney (and 8s affiliates and licensees) as provided in your Credit Card Agreement. This is an aftemptto collect a debt and any information obtained will be used forthat purpose. By providing a telephone number on my account, I consent to GE Money Bank and any other owner or servcer of my account contacting me about my account, including using any contact information or cell phone numbers I provide, and I consent to the use of any automatic telephone dialing system and /or an artificial or prerecorded voice when contacting me, even if I am charged forthe call under my phone plan. Please print changes of address, phone number and /or email below. Name Street Address City, State ❑ Zip Phone # E -mail Home Phone # Business Phone # Cell NO or other phone # we Email Address can use to contact you BY PROV YOUR EMAIL ADDRESS, YOU AGREE TO RECEIVE EMAIL COMMUNICATION ABOUT YOUR ACCOUNTAND ALSO GIVE PERMISSON FOR US TO PROVIDE YOUR EMAIL ADDRESS TO JCPENNEY SO YOU CAN RECEIVE SPECIAL OFFERS AND UPDATES. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff `i Jody S Smith3�xx to Ii Chief Deputy 7Hirh, 3 SEP 23 PH 3, 1 c `tea Richard W Stewart � �� :;fit .k - A ,T': Solicitor PENNSYLVAN1 Portfolio Recovery Associates, LLC Case Number vs. Debra K. Kail 2013-5113 SHERIFF'S RETURN OF SERVICE 09/06/2013 11:41 AM - Deputy Jeff Kolodzi, 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: Debra K. Kail at 848 Lindsey Road, South Middleton Township, Carlisle, PA 17013. 41111,7—S J. ? KOLODZI, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, September 09, 2013 RONNY R ANDERSON, SHERIFF (-,C.GLI-'i u e '•h3fifi if,.?OSOf' ''.; 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. 13-5113 CIVIL V. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 PRAECIPE FOR DEFAULT ; G Defendant JUDGMENT = m _ s �✓ CD VVI Filed on Behalf of Plaintiff =nsl rd r th 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 13-54643 ��o�gy33 This communication is front a debt collector is aza attempt to collect a debt. Any information obtained will be used for that pu fl--)ose. 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. 13-5113 CIVIL V. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,DEBRA KAIL , for failure to answer the Complaint. (X) Amount Due $779.54 Less Credits $.00 TOTAL $779.54 (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 a o his/her Attorney of record,if any, after the default occurred and at least d ys prior to a date f the filing of this praecipe and a copy of the notice is attached. Robe 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 13-54643 111s communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that ptlrl-sose. 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. 13-5113 CIVIL V. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 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$779.54. (X)A copy of all documents filed with the Prothonotary in support a wit dg is/are attac 1� 1i3 By: -- - _ ------ � If you have any questions regarding this Notice,please contact e fil ng 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 13-54643 This connniunication 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) October 15,2013 DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DEBRA KAIL 13-5113 CIVIL Dear DEBRA KAIL: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Rob ert 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 13-54643 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. 13-5113 CIVIL V. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 Defendant TO: DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 DATE OF NOTICE: October 15,2013 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 13-54643 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. 13-5113 CIVIL V. DEBRA KAIL 848 LINSEY RD CARLISLE PA 17013 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 848 LINSEY RD CARLISLE PA 17013 and is not in the military service of the United States or its Allies, or o rwise within the provisions of the Service Members Civil Relief Act and its Amendments. /J1 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 13-54643 Attorneys for Plaintiff This conimunication is a debt collector ai d is an attempt to collect a debt. Any information obtained will.be used for that purpose. 4 Results as of:Oct-22-2013 04:45:17 SCRA 3.0 Statue Report Pursuant,to Servicernembers Civil Relief Act Last Name: KAIL First Name: DEBRA Middle Name: Active Duty Status As Of: Oct-22-2013 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 mdrviduaW active duty status based on the Ac bury 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 ActiveDuty 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 mdivi"ior:his/her unit has received earty 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,NOAH,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. 6 �' 04f*444 4��_ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 13-54643 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). 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. In the event the individual referenced above,or 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 by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active 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 on 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 to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). 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 SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered 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 to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or 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 of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: N5FCSAD2HOB8L50