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HomeMy WebLinkAbout13-7343 Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or re lace the filing 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: C PORTFOLIO RECOVERY ASSOCIATES LLC DANIELLE VARNER T I Are money damages requested? X No Dollar Amount Requested: N within arbitration limits O (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? YQ X NE] 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 Cas e: 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 ❑ uyer Plaintiff Administrative Agencies El Malicious Prosecution WDebt Collection: Credit Card B6alyd of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other BUrd of Elections ❑ Nuisance Dqt. of Transportation S ❑ Premises Liability Sfalit tory Appeal: Other E ❑ Product Liability (does not include C mass tort) El Employment Dispute: ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other Zing Board I OUT: N El Other; MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort - DES ❑ Toxic Tort - Implant 1:1 Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation DBaratory 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 2804880 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 g CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION 0 5 Q CM1 vs. 2 r"� t't ~. I No. CC DANIELLE VARNER -* w rp � T I- 887 ACRI RD a . MECHANICSBURG PA 17050 �. Defendant. NOTICE TO DEFEND 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 s 2804880 p, PPTCPADI � 1 ydv AVI 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 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. DANIELLE VARNER 887 ACRI RD MECHANICSBURG PA 17050 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1 . The Defendant(s), DANIELLE VARNER , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE CAPITAL RETAIL BANK/ LOWE'S, (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 $ 1578.15. 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. 2804880 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), DANIELLE VARNER in the amount of $ 1578.15, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of its Attorneys 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: November 12, 2013 Verification I Michael LaDorc= , 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. DEC 0 6 2013 ustodian of Records Signatu e 2804880 PPTXVR 11 111111111111111111111111111111111111111111111111111111111111 Exhibit "A" PPTXEXAI Lowe'O Credit DANIELLE L VARNER Card Account Account Number 9048 Visit us at www.lowes.com /credit Customer Service: 1- 800 - 568 -0156 Summary of Account Activity Payment Information Previous Balance $1,578.15 New Balance $0.00 - Payments $0.00 Amount Past Due $0.00 Other Credits $1,578.15 Total Minimum Payment Due $394.00 + Purchases/Debits $0.00 Payment Due Date 03/15/2012 + Fees Charged $0.00 Late Payment Warning: if we do not receive your + Interest Charged $0.00 minimum payment by the date listed above, you may have New Balance $0.00 to pay a late fee up to $35.00. Credit Limit $1,000.00 Available Credit $0.00 Statement Closing Date 03/1312012 Days in Billing Cycle 29 Transaction Summary Tran Date Post Date Reference Number/ Invoice Number Description of Transaction or Credit Amount 03/13 03/13 CHARGE OFF ACCOUNT- PRINCIPALS ($928.83) 03/13 03113 CHARGE OFF ACCOUNT `FINANCE CHARGES' ($649.32) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 03/13 03113 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2012 Totals Year -to -Date Total Fees Charged in 2012 $0.00 Total Interest Charged in 2012 $68.47 Total Interest Paid in 2012 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Expiration Annual Balance Subject Interest Balance Type of Balance Date Percentage Rate To Interest Rate Charge Method Regular Purchases NA 26.99% $0.00 $0.00 2D Important Account 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 in a different way, please call Customer Service to discuss other 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 deb@. See reverse for details, Billing Rights Information and other important information, Detach and mail this portion with your check. Do not include any correspondence with vnur check_ —� Account Number: 9048 Total Minimum Amount Payment New Balance Payment Due Past Due Due Date $394.00 $0.00 03/15/2012 $0.00 Payment Enclosed: $ ❑ ❑ [] [] ❑ ' ❑ ❑ I111 Jil n III Please use blue or black ink. New address or email? Print changes on back. DANIELLE L VARNER 887 ACRI RD MECHANICSBURG PA 17050 -2231 Make Payment to: LOWE'S /GECRB P.O. BOX 530914 ATLANTA, GA 30353 -0914 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. DANIELLE VARNER 887 ACRI RD MECHANICSBURG PA 17050 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 Defendants) 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, LEIBSKER & MOO , LL Dated: November 12, 2013 By: Morris Scott Syretta Martin 2804880 PPTJCAMI (06/28/2013) 111111111111111111111111111111111111111111111111111111111111111111111111111 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. �� 7J �� v C-) -s s DANIELLE VARNER 887 ACRI RD �p MECHANICSBURG PA 17050 Defendant(s). r �+y r' PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: 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: November 12, 2013 By: Morri ott Attorney Syretta Martin Attorney 2804880 PPTXPEAI (11/12/2013) 1 1111111111111 111111111111111111 111111111111111111111111111111 1111 VIII IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ' Chief Deputy u F DPC 23 f „ : Richard W Stewart Solicitor UMb r i ila'1 PENNSYDiA-il''� Portfolio Rocovery Associates LLC c/o Blatt, Hasenmiller, Leibsker&M Case Number vs. Danielle Varner 2013-7343 SHERIFF'S RETURN OF SERVICE 12/19/2013 03:29 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint &Notice by handing a true copy to a person representing themselves to be Donald Varner, Husband , who accepted as"Adult Person in Charge"for Danielle Varner at 887 Acri Road, East Pennsboro, Mechanicsburg, PA 17055. 13RIAN GRZyp6SkT, PUTY SHERIFF COST: $39.30 SO ANSWERS, December 20, 2013 RONNY R ANDERSON, SHERIFF • ' f 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. -n • No. 13-7343 CIVIL rn r rrl DANIELLE VARNER 887 ACRI RD Ca C MECHANICSBURG PA 17050 y n -#": - Defendant(s). � c.n 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 DANIELLE VARNER in this matter in the amount of $1,578.15 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 01-21-14 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: Februa y 3, aoi By M•rris Scott Syretta Martin 61 � � 44 .50 2804880 CP—VE 3D)1,N L' PPTJPFJI CQ d {111111(IIIII 1111 IIIII 111111111 IIIII IIIII IIIII IIIII IIIII{1111 IIII IIIII IIII HO d PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. DANIELLE VARNER CIVIL ACTION 887 ACRI RD No. MECHANICSBURG PA 17050 Defendant(s). No. 13-7343 CIVIL TO: DANIELLE VARNER 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. PROTHONO RY Dated: C2 I� I' �, r.. „•12) 74111) L B y. 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 2804880 PPTNDJNI 1 1111111111111 I I I 1 11111 I I 1 111111 111 1111111111 I I I I 1 11111111 f f I I I 1 11111 I I I I 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. 13-7343 CIVIL DANIELLE VARNER 887 ACRI RD MECHANICSBURG PA 17050 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, IBSKER & MOORE, LLC Dated: FPL6ruary 31 °topT By: Mor ' Scott Syretta Martin 2804880 PPTJCAMI (06/28/2013) 1111111111111111111111111111111111111111111110111111 M1100111111 Department of Defense Manpower Data Center Results as of:Feb-03-201406:05:38 AM • SCRA 3.0 � sas Status Report 1.! Pursuant to Servicenterobers Civil.Relief Act Last Name: VARNER First Name: DANIELLE Middle Name: Active Duty Status As Of: Feb-03-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty Date Status Service Component NA NA 1NQ NA This response reflects the individuals'active duty status based on the Aotlea Dull Status Date Left.Active Duty Within 387 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 wtthi n 367`days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cat-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 indMdual or his/her unit has received early nOtifteation to report for active duty Upon searching the data banks of the Department of Defense Manpower Data` enter,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. rilt)/// YA* )111111111141U4 4".Etif,;"7/44040, 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/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(NOM 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: 17412622Y0EFKB0 tt Eh PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY, PA DANIELLE VARNER CIVIL ACTION 887 ACRI RD MECHANICSBURG PA 17050 No. 13-7343 CIVIL Defendant(s). TO: DANIELLE VARNER Date of Notice: January 21, 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER BSKER & MOORE, LLC By: Morris S t 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. 2804880 PPTNLRSI 111111111011111111111110111111111111111111111111111111111101