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Home My WebLink About13-5583 Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: f Cumberland County I3_5 (ern The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other p apers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: WILLIAM B GINGHAM JR C PORTFOLIO RECOVERY ASSOCIATES LLC T Dollar Amount Requested: ® within arbitration limits . I Are money damages requested? [X] Yes ❑ No (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No 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 ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution .Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability (does not include mass tort) ❑Employment Dispute: C ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board I ❑ Other: O N ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory 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 111120 2804140 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. No. 13 - 5583 tvi� �ew WILLIAM B BINGHAM JR C) � } 3443 GREEN ST mco w lT1 a cn CAMP HILL PA 17011 Defendant. c� c1; NOTICE TO DEFEND Z: CD ' You have been sued in court. If you wish to defend against the claims set forth in the fouewing,pages, you must take action within twenty (20) days after this complaint and notice are served, bf. 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 \v (p3. 75 PO p 2804140 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 provisiones 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O 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 ,i 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. WILLIAM B BINGHAM JR 3443 GREEN ST CAMP HILL PA 17011 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: a 1. The Defendant(s), WILLIAM B BINGHAM JR , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with U.S. BANK NATIONAL ASSOCI U.S. BANK NATIONAL ASSO (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendants) 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 $1806.31. 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. 2804140 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), WILLIAM B BINGHAM JR in the amount of $1806.31, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of it ttor 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: August 20, 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. WILLIAM B BINGHAM J4 3443 GREEN ST CAMP HILL PA 17011 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 i attorney for Plaintiff and 1;.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 Defendants) 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, LEIBSKER & MOOR , Dated: August 20, 2013 By: Mor Syretta Martin 2804140 ' PPTJCAMI (06/28/2013)' I IIIIIII IIIII IIIIII IIII III 111111111111111111111111111111111111111111111 IN Verification I, Yvette M Stephen , 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. �.6 LA 16 -r, Signature Custodian of Records 2804140 PPTXVRI I VIII IIIIIII III IIIIII VIII VIII VIII VIII VIII VIII IIIIII III IIII Exhibit "A" PPTXEXAI Integrity H E` September Statement for activity from Aug. 24, 2011 through Sep. 30, 2011 Inquiries: 1- 800 - 558 -3424 WILLIAM B BINGHAM JR ELN 35 Page 1 of 2 YourYcsungAdult Vtsa Gard accountat a g3ancQ Accot 48t Activity Summary Payment Information Previous Balance .................... $1,520.18 New Balance ........................... $1,501.40 Payments .. ............................... $0.00 Minimum Payment Due (Current Month) $0.00 Other Credits ........................... $1,501.40CR Minimum Payment Due (Past Due) $0.00 Purchases . ............................... $0.00 Total New Minimum Payment Due $0.00 Balance Transfers ................... $0.00 Payment Due Date.................. Oct. 25, 2011 Advances.... ............................. $0.00 Other Debits ............................ $0.00 Late Payment Warning: If we do not receive your Past Due Amount .................... $0.00 minimum payment by the date listed above, you may have Fees Charged ......................... $210.000R to pay up to a $35.00 Late Fee. Interest Charged .................... $94.91cR New Balance ........................... $1,501.40 Credit Line ............................... None Available Credit ....................... None Statement Close Date ............. Sep. 30, 2011 Days in Billing Cycle ............... 38 To reduce or avoid paying additional fees and interest charges on your purchase balance, pay the total new balance of 31,501.40 by 10125111. Any cash balance or balance transferbalance wili continue to accrue dairy interest until the date your payment is received. Tran'sac #Iprs Post Trans Ref. Date Date Nbr Description of Transaction Amount Payments ancf Other Credits: 09/30 CHARGE OFF ... .. .. Fees;Cf�arged 09/30 REVERSAL OF LATE PAYMENT FEE... ..... $210.000R TOTAL FEES FOR THIS PERIOD ............ ............................... $210.00cR interest Charged 09130 INTEREST REVERSAL ............................. ............................... $94.91cR TOTAL INTEREST FOR THIS PERIOD ... ............................... $94.91cR Continued on Next Page Please detach and send coupon with check payable to: Cardmember Service 4907 �teglity Your Account Nu? _ _ _ _ _ 14907 �� "" a N K Total New Balance: $1,501.40 Minimum Payment Due. $0.00 To change your addressor for Paj!men# Due Hate EnEeo A7nouQZ of Paym -0 Eiicicaed ,, Cardmember Service please call: �* 1- 900 -558 -3424 Every Hour! Every Day! Oct 25, 2011 - Cardmember Service WILLIAM B BINGHAM JR P.O. Box 790408 3443 GREEN ST St. Louis, MO 63179 - 0408 CAMP HILL PA 170114420 II III i ICI n ul I lull I I u i IiE I Illlllllhlll��llll�nlllll�lll�llih�lhllull�l�llrl�ll�lrh, I II I In I IIII i d III II I II IIII rill I I I What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement, please call us at the telephone number on the front of this statement, or write to us at: Cardmember Service, P.O. Box 6335, Fargo, ND 58125 -6335. In your letter or call, give us the following information: ► Account information: Your name and account number. ► Dollar amount: The dollar amount of the suspected error. ► Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement. While we investigate whether or not there has been an error, the following are true: ► We cannot try to collect the amount in question, or report you as delinquent on that 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 to pay the amount in question or any interest or other fees related to that amount. ► White you do not have to pay the amount in question, you are responsible for the remainder of your balance. ► We can apply any unpaid amount against your credit limit. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: 1. The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact usin writing at: Cardmember Service, P.O. Box 6335, Fargo, ND 58125 -6335. While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Important Information Regarding Your Account 1. INTEREST CHARGE: Method of Computing Amount Subject to Interest: We calculate the periodic rate or interest portion of the INTEREST CHARGE by multiplying the applicable Daily Periodic Rate ( "DPR ") by the Average Daily Balance ( "ADB ") (including new transactions) of the Purchase, Advance and Balance Transfer categories subject to interest, and then adding together the resulting interest from each category. We determine the ADB separately for the Purchases, Advances and Balance Transfer categories. To get the ADB in each category, we add together the daily balances in those categories for the billing cycle and divide the result by the number of days in the billing cycle. We determine the daily balances each day by taking the beginning balance of those Account categories (including any billed but unpaid interest, fees, credit insurance and other charges), adding any new interest, fees, and charges, and subtracting any payments or credits applied against your Account balances that day. We add a Purchase, Advance or Balance Transfer to the appropriate balances for those categories on the later of the transaction date or the first day of the statement period. Billed but unpaid interest on Purchases, Advances and Balance Transfers is added to the appropriate balances for those categories each month on the statement date. Billed but unpaid Advance Transaction Fees are added to the Advance balance of your Account on the date they are charged to your Account. Any billed but unpaid fees on Purchases, credit insurance charges, and other charges are added to the Purchase balance of the Account on the date they are charged to the Account. Billed but unpaid fees on Balance Transfers are added to the Balance Transfer balance of the Account on the date they are charged to the Account. in other words, billed and unpaid interest, fees, and charges will be included in the ADB of your Account that accrues interest and will reduce the amount of credit available to you. Credit insurance charges are not included in the ADB calculation for Purchases until the first day of the billing cycle following the date the credit insurance premium is charged to the Account. Prior statement balances subject to an interest -free period that have been paid on or before the payment due date in the current billing cycle are not included in the ADB calculation. 2. Payment Information: Make checks payable to Cardmember Service. Use the enclosed return envelope to mail your payment to: Cardmember Service, P.O. Box 790408, St. Louis, MO 63179 -0408. All payments by check or money order, in U.S. dollars and accompanied by a payment coupon will be credited to your Account on the day of receipt if received at this address by 5:00 p.m. CST on any banking day. Banking days are all calendar days except Saturday, Sunday, and federal holidays. Payments due over a Saturday, Sunday or federal holiday and received on those days will be credited on the day of receipt. Other types of mailed payments will be processed within five banking days of receipt by Cardmember Service and credited to your Account on the day of receipt. 3. Credit Reporting: We may report information on your Account to Credit Bureaus. Late payments, missed payments or other defaults on your Account may be reflected in your credit report. �itegrity R N September Statement for activity from Aug. 24, 2011 through Sep. 30, 2011 Inquiries: 1- 800 - 558 -3424 WILLIAM B BINGHAM JR Page 2 of 2 2011 Totals Year-to Date__ Total Fees Charged in 2011 $35.00 Total Interest Charged in 2011 $12.41 Meets Charge C� #�rrl fl<nrt Your Annual Percentage Rate (APR) is the annual interest rate on your account. * * APR for current and future transactions. Balance Anna al t;xphes Balance Subject Percentage with tnteresi: 8alance::Type BY:Typ"a tolnterest `Varlable: Interest :Rafe Statement Free Period: •reAIANCETRANSFER $0.00 $0.00 YES $0.00 9.99% NO - PURCHASES $1,806.31 $1,806.31 YES $18.78 9.99% YES - ADVANCES $0.00 $0.00 YES $0.00 23.99% NO tmp�rft Mss ages _ ....... . We understand that our credit, cardmembers impacted by the recent hurricane and Floods have special needs during this difficult time_ If you are on of those affected, please call Cardmember Service for questions or assistance. We appreciate your business and'are here to support you. Each time you or a third party on your behalf, pays your bill by personal check, you authorize us to convert that payment into an electronic debit. If the check is processed electronically, the checking account will be debited for the amount on the check and the debit will appear on your account statement. If you have any questions, please contact us at the Inquiries phone number located on this statement. To _contactus_readny�ulracolnt...z - 4907 By Telephone: Send Inquiries to: ® Send Payments to: Online Every Hour! Every Day! Cardmember Service Cardmember Service visit our website: Voice: 1-800- 558 -3424 P.O. Box 6354 P.O. Box 790408 myaccountaccess.com TDD: 1- 888 -352 -6455 Fargo, ND 58125 -6354 St. Louis, MO 63179 -0408 Fax: 1- 866- 616 -1750 . rs End of Statement 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. 13- 5583 WILLIAM B BINGHAM JR 3443 GREEN ST CAMP HILL PA 17011 Defendant(s). ' PRAECIPE TO ENTER APPEARANCE E} TO THE PROTHONOTARY: Kindly ENTER my appearance in the above - captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. c Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC r— . 1835 Market Street, Suite 501 >{ Philadelphia, PA 19103 =� D C: tV c Telephone Number: 1- 215- 564 -1567 ^� BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: August 20, 2013 By: Morris Scott Attorney Syretta Martin Attorney 2804140 PPTXPEAI I IIIIIIII (III III IIIIII VIII VIII VIII VIII VIII VIII VIII IIII IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ClitkItyr Jody S Smith f,# Chief Deputy x, .2113 OCT E 7 AM Ili Richard W Stewart Solicitor, r t t :. .1 i`i B E ti L a�',1' PENNSYLVANIA Mark Garvey Case Number vs. William Bingham 2013-5583 SHERIFF'S RETURN OF SERVICE 10/14/2013 07:30 PM - Deputy Ryan Burgett, 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: William Bingham at 3443 Green St, Camp Hill Borough, Camp Hill, PA 17011. RYAN BURG , I EPU SHERIFF COST: $61.90 SO ANSWERS, October 16, 2013 RONNY ANDERSON, SHERIFF ;c)Ccu^ty of ah rif',Te!2oso`i Vin, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ., Sheriff ° ,LEO-OF ^'ice`~ tip„ i Di CeraaGtr,, C:1 I PFU.IHU� C.I.{r#i 'r Jody S Smith Chief Deputy 2013 DEC -6 PM 12: 02 Richard W Stewart cr- c4,T $t1.ER=F= CUMBERLAND COUNTY PENNSYLVANIA *AMENDED* Portfolio Recovery Associates, LLC Case Number vs. William Bingham 2013-5583 SHERIFF'S RETURN OF SERVICE 10/14/2013 07:30 PM—Deputy Ryan Burgett, 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: William Bingham at 3443 Green St, Camp Hill Borough, Camp Hill, PA 17011. RYAN BURGETT, DEPU SHERIFF COST: $61.90 SO ANSWERS, October 16, 2013 RONR ANDERSON, SHERIFF (c)CountySuito Sherif!,Teleosoft,pic. 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. 13-5583 ' r y== WILLIAM B BINGHAM JR t"? f'` Y�y 3443 GREEN ST CAMP HILL PA 17011 "} Defendant(s). ZCDy ? :, PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT 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 WILLIAM B BINGHAM JR in this matter in the amount of $1)5 0 *31 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 12-09-13 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: December 20, 2013 By: _zo_ Morris Scott Syretta Martin *6,5c) ATT t o'R41Q1 2$0140 ,� 4ASo l PPTJPFJI �� 11�cllecf 1111111111111111111111111111111111111111118N1111111111111111111111111 IN J� 1. i PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS Vs. CUMBERLAND COUNTY, PA WILLIAM B BINGHAM JR CIVIL ACTION 3443 GREEN ST CAMP HILL PA 17011 No. 13-5583 Defendant(s). TO: WILLIAM B BINGHAM JR Date of Notice: December 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 Sc 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. 2804140 PPTNLRSI 111111111 1111111 111111 1111111111 1111111111 11111 11111 111111 111 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. 13-5583 WILLIAM B BINGHAM JR 3443 GREEN ST CAMP HILL PA 17011 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, NMILLER, LEIBSKER & MO E, LL Dated: December 20, 2013 By: Lo�l Morris Scott Syretta Martin 2804140 PPTJCAMI (06/28/2013) 11111111111111111111111111111111 VIII VIII VIII VIII VII111111 III VIII IIII Department of Defense Manpower Data Results as of:Dec-20-20,306:33:30 Center SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: BINGHAM JR First Name: WILLIAM Middle Name: Active Duty Status As Of: Dec-20-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects the individuals!active duty status based on the:Active Duty Status Date Left Active Duty Within 367 Days Active Du Status Date _.Active Duty Start Date Active Duty End Date Status Service Component NA NA' No NA This response reflects where'tlfB individual left active du stitue*Rhin 367 days preceding the Active Duty Status Date The Member or HislHerUnit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ?No. NA This response reflects whether the indiuiduat"or Kist hunt leas recetvad Bart no*aton to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. oto 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 at 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.mii"URL:http://www.defenselink.mil/fagtpis/PC09SLDR.htmi. 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: 26CCC1 B4G04BXF0 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. WILLIAM B BINGHAM JR CIVIL ACTION 3443 GREEN ST No. CAMP HILL PA 17011 Defendant(s). No. 13-5583 TO: WILLIAM B BINGHAM JR 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. PROTHO TARY MAO Dated: . I Z 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 2804140 PPTNDJNI 1 11111111111111111 VIII III 111111 VIII VIII VIII VIII VIII VIII 111111111 IIII