HomeMy WebLinkAbout13-7302 Supreme Co»r A . Pennsylvania
Court. f Gom b.n Pleas
``' ,. For Prothon Use Only: T1 X11' STAMP
C i ever S et Docket No: ll
CUMB : JCounty
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
' Et ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T PORTFOLIO RECOVERY ASSOCIATES, LLC JAMES TAYLOR
I
U Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
N (Check one) outside arbitration limits
A 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, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections
❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
❑ Product Liability (does not include
S mass tort) ❑ Employment Dispute: _
E ❑ Slander/Libel /Defamation Discrimination ❑ Zoning Board
❑ Other: ❑ Employment Dispute: Other ❑ Other:
C
T
I ❑ Other:
MASS TORT
0 ❑ Asbestos
N C3 Tobacco
• Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
• Toxic Tort - Implant ❑ Ejectment E] Common Law /Statutory Arbitration
B E] Toxic Waste ❑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
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
14 -28129
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055 _ 1 ; 1- 0 -OFFI CE
Mark R. Garvey, Esquire PA Bar # 312686 '- f HE PROTHONOTAiiY
Portfolio Recovery Associates, LLC
120 Corporate Blvd P 2.
Norfolk VA 23502 (:t COUNTY
TELE: 1- 866 - 428 -8102 PENNSYLVANIA
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 lU�
NORFOLK, VA 23502 No.
Plaintiff,
V.
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
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
14 -28129 os
OA4
This communication is from a debt collector and is an attempt to collect a deb app 3 � S
Any information obtained will be used for that purpose.
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1- 866 - 428 -8102
FAX: (757) 518 -0860
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Demandante, No.
V.
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
Demandado.
NOTICIA
USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas
en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda
y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por
escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido
que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por
la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio
solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO.
SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICIIVA 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
14 -28129
Esta. comunic:acion es de un cob.rador de cl.euclas y es un intent do cobrar una de;uda.
Cualquier irltroniacion 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.
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
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, JAMES TAYLOR, is an adult individual with last known address of 532 BEDFORD
CT, MECHANICSBURG PA 17050.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / GENERAL
ELECTRIC CAPITAL CORP / CARE CREDIT on May 15, 2008 with account number
************6551 (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.
This com.rnunication .is :from. a debt collector and is an attempt to collect a debt.
,env information obtained will be used for that purpose.
5. At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and /or for obtaining services.
6. Defendant was provided with copies of the Statements of Account showing all debits and credits
for transactions on the aforementioned Account to which there was no bonafide objection by
Defendant.
7. Defendant was in default with respect to that debt for failure to make the required payments on the
Account. The last payment made on this Account was on March 9, 2012.
8. Plaintiff is the purchaser, assignee and /or successor in interest GE CAPITAL RETAIL BANK /
GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT and Plaintiff is now the holder of the
Account. A true and correct copy of the Plaintiffs verification is attached hereto and collectively
marked as Exhibit "A."
9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's
Account, as a result of Defendant and /or any authorized user's use of said Account is in the sum of
$2,218.78.
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, JAMES TAYLOR , in th4amot ,218 .78, pl osts of this action
and any other relief as the Court deems just and reasonab
J �
Carrie A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
14 -28129
This comrnunicat:ion is from. a debt collector and is ati attempt to collect a debt.
Any information obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
l
___ a 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.
NOV 2 9 2013
Date: BY:
Samaria Braswell
Custodian of Records
14 -28129
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: * * * * * * * * * ** *6551
JAMES TAYLOR
Account Holder:
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
Consumer Account Product Code: PVT
Issuer: GE CAPITAL RETAIL BANK / GENERAL ELECTRIC CAPITAL CORP / CARE
CREDIT
Assignee: Portfolio Recovery Associates, LLC
Account Number: * * * * * * * * * ** *6551
Date Account Opened: May 15, 2008
Date of Last Payment: March 9, 2012
Date of Charge Off: October 16, 2012
Balance at Purchase: $2,218.78
Purchase Date: November 21, 2012
Balance at Charge -off: $2,218.78
Less Payments: $.00
Balance Due: $2,218.78
14 -28129
GESQ78
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
GE Capita!
BILL of SALE
PRA PSCC Fresh — November 2812
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated
as of the 25 day of June, 2012 by and between General Electric Capital Corporation, GE
Money Bank, GEMB Lending, Inc., Monogram .Credit Services, L.L.C., RFS Holding,
L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery
Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement), delivered by Seller to Buyer on November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: B
Glenn Marino Glenn Marino
Title: _EVP Title: _President
Date: I a I f3 1L Date: 1
General Electric Capital Corporation RFS Holding, L.L.0
By: By:
Y
Glenn Marino Joseph Ressa
Title: _Vice President Title: CFO
Date: 12. Ul IT-- Date:
GEMB Lending, Inc. GEM Holding, L.L.0
By: By:
Stephen Motta Joseph Ressa
Title: _Director Title: CFO
Date: Date:
GE Capital
BILL of SALE
PRA PSCC Fresh — November 2012
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated
as of the 25 clay of June, 2012 by and between General Electric Capital Corporation, GE
Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding,
L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and Portfolio Recovery
Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement), delivered by Seller to Buyer on November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By:
Glenn Marino Glenn Marino
Title: EVP Title: President
Date: Date:
General Electric Capital Corporation RFS Holding, L.L.0
By: By:
Glenn Marino Joseph Ressa
Title: Vice President Title: CFO
Date: Date:
GEMB Lending, Inc. GEM Holding, L.L.0
By: By:
Stephen M Joseph Ressa
Title: Director Title: CFO
Date: Date:
GE Capital
BILL of SALE
PRA PSCC Fresh - November 2012
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated
as of the 25` day of June, 2012 by and between General Electric Capital Corporation, GE
Money Bank, GEMB Lending, Inc., Monogram Credit Services, I,. X., RFS Molding,
L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and .Portfolio Recovery
Associates, LLC (`Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to
Buyer, its successors and assigns, without recourse except as set forth in the Agreement,
to the extent of its ownership, the Receivables as set forth in the Notification Files (as
defined in the Agreement), delivered by Seller to Buyer on November 21, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By
Glenn Marino Glenn Marino
Title: _EVP Title: President
Date: - - - - -- — Date:
General Electric Capital Corporation RF lding, L.L.C�
By: By :t'e,�'
Glenn Marino Joseph I e a
Title: _Vice President Title: CFO
Date: _ Date:
GEMB Lending, Inc. GEM ding, L.L.
By: B
Stephen Motta Joseph Re ff
Title: _Director _ Title: CFO
Date: _._ Date: _ t-
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson I
Sheriff j
Jody S Smith .
Chief Deputy
E ,
Richard W Stewart EiR LAN D i ,Wji
Solicitor j-E `i`LVgw
Portfolio Recovery Associates, LLC Case Number
vs.
James Taylor 2013-7302
SHERIFF'S RETURN OF SERVICE
12/12/2013 04:20 PM- Deputy Dawn Kell, 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: James Taylor at 532 Bedford Court, Hampden Township, Mechanicsburg, PA 17050.
DAWN KELL, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
December 13, 2013 RONW R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES,LLC :
120 CORPORATE BLVD .
NORFOLK, VA 23502 .
Plaintiff : No. 2013-7302
v. .
JAMES TAYLOR :
532 BEDFORD CT :
MECHANICSBURG PA 17050 : PRAECIPE FOR DEFAULT
Defendant JUDGMENT --
r) o
•
7;;>C') :Tr-
Filed on B- if of Plaintiff "_a
Counsel .f cord for this Par,
/1 /// / -<,
Date: OVH a/ /
Ro.ert 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
14-28129
co_ gico.styi la ibi
eke gicoq(/)
g_ 1 _ r:ifeci 6
&)e.,X j
This communication is from a debt collector is an attempt to collect a debt. �/�c - �
Any inlb n ition 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. 2013-7302
v.
JAMES TAYLOR •
532 BEDFORD CT •
MECHANICSBURG PA 17050
Defendant •
•
•
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, JAMES TAYLOR, for failure to
answer the Complaint.
(X) Amount Due $2,218.78
Less Credits $.00
TOTAL $2,218.78
(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 agai . om judgment is . b, entered and to
his/her attorney of record, if any, after e ►�-fault occurred a•,d east ten days prior to
the date of the filing of this praecipe 4ny�..p 6 :; tacked.
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
14-28129
This communication is from a debt collector is a n 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. 2013-7302
v. .
JAMES TAYLOR :
532 BEDFORD CT :
MECHANICSBURG PA 17050 :
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$2,218.78,plus post judgment interest from the date of the
judgment.
(X)A copy of all documents filed with the Prothonotary in suppo of th 'thin u ent is/are
attached. ir
• '' ` el
: tee '
/
/If you have any questions regarding this No• c�6 �/ ta, t �o n• •arty.
1 a����
i
•obert 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
14-28129
1`his communication is from a debt collector is an attempt to collect a debt.
Any, information obtained vvill 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)
January 2, 2014
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. JAMES TAYLOR
2013-7302
Dear JAMES TAYLOR:
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
Sincerely,
C_06'
Robert N. Polas,Jr., Esquire
Carrie A. Brown, Esquire
Mark R. Garvey, Esquire
Attorney ID#201259/94055/312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
14-28129
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. 2013-7302
v.
JAMES TAYLOR
•
532 BEDFORD CT
MECHANICSBURG PA 17050
•
Defendant
TO: JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
DATE OF NOTICE: January 2, 2014
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
0 3
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
14-28129 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. 2013-7302
v. .
•
JAMES TAYLOR .
532 BEDFORD CT :
MECHANICSBURG PA 17050 :
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
532 BEDFORD CT
MECHANICSBURG PA 17050
and is not in the military service of the United States or its Al .-s or otherwise wit .1 he provisions of
the Service Members Civil Relief Act and its Amendments
/ / ,
r
'obert 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
Attorneys for Plaintiff
14-28129
This communication is a debt collector and is an attempt to collect a debt,
Any information obtained will he 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)
January 2, 2014
JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. JAMES TAYLOR
2013-7302
Dear JAMES TAYLOR:
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
Sincerely,
C013--
Robert N. Polas,Jr., Esquire
Came 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
14-28129
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. 2013-7302
v.
•
JAMES TAYLOR
•
532 BEDFORD CT
•
MECHANICSBURG PA 17050
Defendant
TO: JAMES TAYLOR
532 BEDFORD CT
MECHANICSBURG PA 17050
DATE OF NOTICE: January 2, 2014
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
CO/3"
Robert N.Polas,Jr., Esquire
Came A. Brown, Esquire
Mark R.Garvey,Esquire
Attorney ID#201259/94055/312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk,VA 23502
14-28129 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.