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HomeMy WebLinkAbout13-5433 Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland Count/ /3 -54 Civil _IEfm The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the flling and service of leadin s or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S El Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: ERIC FRY C PORTFOLIO RECOVERY ASSOCIATES LLC T I Are money damages requested? X NE] Dollar Amount Requested: E] within arbitration limits 0 (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? Y40 X NFL] A Name of Plaintiff /Appellant's Attorney: Morris Scott /Syretta Martin ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] 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 D B�er Plaintiff Administrative Agencies ❑ Malicious Prosecution LerDebt Collection: Credit Card Bad of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other Bad of Elections ❑ Nuisance Dqt. of Transportation S ❑ Premises Liability SGItory Appeal: Other E ❑ Product Liability (does not include C mass tort) ❑ Employment Dispute: ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other Zing Board I Ofh&r: O N El Other: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort - DES ❑ 1:1 Toxic Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS E] Other: Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation DEaaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non- Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1 11120 2804361 PPTXSCPI Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800- 850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. C'7 No. 13 -5433 ivi��F�t )N C� _ ERIC FRY 't7 M c/) rT'7 250 FRANKLIN ST CARLISLE PA 17013 -2206 -< Defendant. =7 NOTICE TO DEFEND i NO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 O IGa 75 P IMTIV 0698x7 2804361 PPTCPADI AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267 -2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800 -850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. ERIC FRY 250 FRANKLIN ST CARLISLE PA 17013 -2206 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), ERIC FRY , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE CAPITAL RETAIL BANK - WALMART, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $1521.98. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2804361 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), ERIC FRY in the amount of $1521.98, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of its At 6rneys Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: July 19, 2013 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800 - 850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. ERIC FRY 250 FRANKLIN ST CARLISLE PA 17013 -2206 Defendant(s). AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Cumberland: I, Morris Scott /Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant(s) is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. See Defendant(s) Military Status Report pursuant to 50 U.S.C. App. Section 521, 525 which was obtained from the Department of Defense Manpower Data Center ( https: / /www.dmdc.osd.mil /appj /scra /). I also herby certify that the statements made in the foregoing Affidavit of Non - Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, L IBSKER & MOORE, LLC Dated: July 19, 2013 By: Morris S ott Syretta Martin 2804361 PPTJCAMI (06/28/2013) 11111111 VIII 111111 IIII III 111111 VIII VIII VIII VIII VIII VIII IIII 11 III IIII Verification I, Larry J. Andrews , am an authorized agent and /or employee of Plaintiff. I am authorized to make this verification on behalf of Plaintiff. The statements of facts set forth in the complaint are true and correct based upon my information and belief and are made subject to the penalities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Sig ture Larry . ry Andrews 2804361 PPTXVR 11 I VIII IIIIIII III IIIIII VIII VIII VIII VIII VIII VIII IIIIIII II IIII AFFIDAVIT State of Virginia City of Norfolk ss. Larry J. Andrews 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 Boulevard, Norfolk, Virginia. 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 GE CAPITAL RETAIL BANK - WALMART ( " 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 04- 30 -12. 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 ERIC FRY ( "Debtor and Co- Debtor ") to the Account Seller the sum of $ 1521.98 with the respect to account number ending in XXXXXXXXXXXX7121 as of the date of 04 -08 -12 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 account 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 $1521.98 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 arry ndr ws By: , Custodian of Records S s ed and savor to efore me uG 3 0 2013 Tavana f "y C. Uzzle Commonwealth of Virginia Notary Public Notary Public Commission No. 302460 -ay J _My Commission Expires 1/31/2017 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 2804361 APTXPRAI 111111111111 III 11111111111 IIIII IIIII IIIII 11111 IIIII IIIII 11 II IN Exhibit "A" PPTXEXAI Walmart Save money. Live better. Wal ma rtO ERIC C FRY Visit us at walmart.com/credit Cr edit Card Account Numbei 1 7121 Customer Service: 1- 800.41-4526 Summary of Account Activity Payment information Previous Balance $1,521.98 New Balance $0.00 - Other Credits $1,521.98 Amount Past Due $0.00 New Balance $0.00 Total Minimum Payment Due $466.00 Payment Due Date D4 110/2012 Credit Limit $1,000 Late Payment Warrling:if we do not receive your minimum Available Credit $0.00 payment by the date listed above, you may have to pay a late Cash Advance /Quick Cash Limit $200 fee up to $35.00. Available Cash $0.00 Statement Closing Date 04/08/2012 Days in Billing Cycle 28 Transaction Summary Tran Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount 04108 04108 F911200FK00999990 CHARGE OFF ($935.61) ACCOUNT - PRINCIPALS 04108 04108 F911200FK00999990 CHARGE OFF ACCOUNT'FINANCE ($586.37) CHARGES' FEES TOTAL FEES'FOR THIS PERIOD $0.00 INTEREST CHARGED 04/08 04108 INTEREST CHARGE ON PURCHASES $0.00 04108 04108 INTEREST CHARGE ON CASH $0.00 ADVANCES TOTAL INTEREST FOR THIS PERIOD $0.00 2012 Totals Year -To -Date Total Fees charged in 2012 $35.00 Total interest charged in 2012 $81.49 Total Interest Paid in 2012 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APR)s the annual interest rate on your account. Annual Percentage Balance Subject to Type of Balance Expiration Date Plan Type Rate Interest Rate Interest Charge Current Transactions Regular Purchases & Cash NA REG 22.90% (v) $0.00 $0.00 Advances Transactions on or before 121262010 Regular Purchases N/A REG 22.90% $0.00 $0.00 (v) = Variable rate Cardholder News and Information Please Note: Enclosed is the Privacy Policy for this account Please take a moment to read it then keep it with other financial documents. If you have previously opted-out, you do not need to do so again. If your account has a deferred interest promotion and you would like us to apply a payment on your account to a specific balance, please call Customer Service to discuss options that may be available. PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE_ NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights and other important information. ueiam anu man rots pomon wart your check. Do not include any correspondence with your check. — I Account Number 7121 Walma A TotalMlnlmum Amount Payment Due Overllmlt I NewSala on nce Save mey. Llvelrefter. Payment Due Past Due Date Amount $466.00 $0.00 04/10/2012 $0.00 $0.00 � InnIpd� Payment Enclosed: ❑ [I [I [I ❑ . F1 F1 u se blue or black ink. New address or email? Print changes on back. Please ERIC C FRY WW 248 FRANKLIN ST ft 1 CARLISLE PA 17013 -2206 Make Payment To: WALMART /GECRB P.O. BOX 530927 ATLANTA, GA 30353 -0927 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215- 564 -1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. �3- 533 Ivt�TE'�I� ERIC FRY C 250 FRANKLIN ST CARLISLE PA 17013 -2206 �M + - •` Defendant(s). _r PRAECIPE TO ENTER APPEARANCE > _ . TO THE PROTHONOTARY: �, 17.0 Kindly ENTER my appearance in the above - captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1- 215 - 564 -1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: July 19, 2013 By: orris Scott Attorney Syretta Martin Attorney 2804361 PPTXPEAI 111111111 IIII III 111111 VIII VIII VIII VIII VIII VIII VIII IIII IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff y 3xt� of t turibo �`' 1 ( _) ... : Jody S Smith Chief Deputy P13 OCT I AM 10: 25 Richard W Stewart Solicitor OFF CE it.E CUMBERLAND iCUkiii PENNSYLVANIA, Portfolio Recorvery Associates, LLC vs. Case Number Eric Fry 2013-5433 SHERIFF'S RETURN OF SERVICE 09/18/2013 10:55 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be John Nguyen- Roommate, who accepted as"Adult Person in Charge"for Eric Fry at 250 Franklin Street, Carlisle Borough, Carlisle, PA 17013-2206. _d/ tl1 - 'AW1 SHALL_ ' TY SHERIFF COST: $34.78 SO ANSWERS, September 20, 2013 RONNW ANDERSON, SHERIFF ;e,herrf 'e=oseft.'a 1 w Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. -5433 ` --1, ERIC FRY -rn C-) .) _4 250 FRANKLIN STS- CARLISLE PA 17013-2206 .< ' {-4C Defendant(s). Ica -a co-,. c-) (1- PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT < IN) FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant ERIC FRY in this matter in the amount of $1,521.98 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2)was mailed separately to each defendant on 10-09-13 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASEN ER, LEIBSKER & MOORE, L Dated: October 21, 2013 By: Y Morris cott Syretta Martin Qu 2804361 /� b/ f! Oj i a PPTJPFJI jJr--C`t I1111111111111IIII111111111111111111111111111111111111111111111III111111III 091 .131/4) 1\)\6-469 j PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA VS. ERIC FRY CIVIL ACTION 250 FRANKLIN ST No. CARLISLE PA 17013-2206 13 Defendant(s). No. 1,-5433 TO: ERIC FRY NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHON• ARY to) Dated: By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker& Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2804361 PPTNDJNI 1 1111111111111 I I I 1 11111 I I 1 111111 11111 11111 11111 11111 1111111111 I I I 1 11111 1111 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. -5433 ERIC FRY 250 FRANKLIN ST CARLISLE PA 17013-2206 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Cumberland: I, Morris Scott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant(s) is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. See Defendant(s) Military Status Report pursuant to 50 U.S.C. App. Section 521, 525 which was obtained from the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scra/). I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HAS LER, LEIBSKER & MOOR- Dated: October 21, 2013 By: ArAd Y Morris Scott Syretta Martin 2804361 PPTJCAMI (06/28/2013) 1111111111111111111 I I I I I I 11111111111111111111111111111111111111111111 11 1111 — Department of Defense Manpower Data Center Results as of:Oct-21-2013 07:54:37 SCRA 3.0 Status Report $" ' Pursuant to Servieemenibats Civil Relief Act Last Name: FRY First Name: ERIC Middle Name: Active Duty Status As Of: Oct-21-2013 On Active Duty On Active Duty Status Data Active Duty Start Date - Active Duty End Date Status Service Component NA NA ..,, r ..i,t+ki. NA This response refleote fft divtr s'ts active duty etetuelsased on the AOtiveDuty Status Date • tAitACGve putty WANO W:Days A Ye-L t SStatutTfato Active Duty Start Data_.._.. Active Dray End Date J _ Statue Service Component NA ANA ., r e ;into �: i, NA This response reflects v1,eret a individual left activ 'iretus'W441T6ays 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 Statue Data Order Notification Start Data Order Notification End Date Status Service Component NA NA No NA This response reflects whether Mee viedual Kn'ttlather unit has received v a «noGflcaGorf to report for active duty JJ £W f�"-m .k* Upon searching the data banks of the Department of Defense Manpower Da ter-baked 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. r• Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 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:http://www.defenselink.mil/faq/pis/PCO9SLDR.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: U5A6X392M0A3Y20 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY, PA ERIC FRY CIVIL ACTION 250 FRANKLIN ST CARLISLE PA 17013-2206 )3 No. S-5433 Defendant(s). TO: ERIC FRY Date of Notice: October 9, 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, L KER & MOORE, LLC By: Morris ott Syretta Martin 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2804361 PPTNLRSI 1111111111111111011111111111111111101111111111111111111