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HomeMy WebLinkAbout14-1047 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only. Civil Cover Sheet Docket No: Cumberland County l / III / The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace the fifinjq and service of pleadihjgs or other papers as required bv law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction E] Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: ANGELA CHRISTOPHER C PORTFOLIO RECOVERY ASSOCIATES LLC I Are money damages requested? ® Yes[] No Dollar Amount Requested: ® within arbitration limits (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 PR /MARY 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 d 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: 0 N C3 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 2836320 PPTXSCPI (1/15/2014) 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 to No. ANGELA CHRISTOPHER r y 509 W NORTH ST CARLISLE PA 17013 -2223' = Defendant(s). "` CD;- 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: February 6, 2014 By: Morris cott Attorney Syretta Martin Attorney 2836320 PPTXPEAI (11/18/2013) 11111111111111 IN 11111111111111111111111111111 I11l l 11111111111111111111111 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 M t� No. f I r— N3 ,..7 ANGELA CHRISTOPHERc�: 509 W NORTH ST CARLISLE PA 17013 -2223 C— 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 am4 2836320 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 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. ANGELA CHRISTOPHER 509 W NORTH ST CARLISLE PA 17013 -2223 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), ANGELA CHRISTOPHER, 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 $3591.23. 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. 2836320 PPTCDBCI (01/14/2014) 111111111111111 11111111111111111 HE 1111111111111111111111111111111111 IN I WHEREFORE the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), ANGELA CHRISTOPHER in the amount of $3591.23, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of its Aft Morris Scott Attorney I.Q. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: �- Verification Merari Drearlo I, , 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 penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: FED 10 2014 S 2836320 PPTXVR11 (01/14/2014) 1111111111 111 111111111 1111111111111111111111111111111111111111 IN I Exhibit " A " PPTXEXAI Lowe'e Credit ANGELA D CHRISTOPHER Card Account Account Number �35 9 Visit us at www.lowes.com/credit Customer Service: 1- 800 -568 -0158 Summary of Account Activity Payment Information Previous Balance $3,591.23 New Balance $0.00 - Payments 10.00 Amount Past Due $0.00 - Other Credits $3,591.23 Total Minimum Payment Due $778.00 + Purchases/Debits $0.00 Payment Due Date 08/17/2012 + Fees Charged $0.00 Late Payment Warning:lf we do not receive your i Interest Charged $0.00 minimum payment by the dale listed above, you may have New Balance $0.00 to pay a late fee up to $35.00. Credit Limit $3,060.00 Available Credit $0.00 Statement Closing Date 08/15/2012 Days in Billing Cycle 28 Promotion Expiration Notification YOU HAVE A DEFERRED INTEREST PROMOTION(S) EXPIRING ON 07118113. YOU MUST PAY EACH DEFERRED INTEREST PROMOTIONAL BALANCE IN FULL BY ITS EXPIRATION DATE TO AVOID PAYING ACCRUED INTEREST CHARGES. PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT FOR FURTHER DETAILS. Promotional Purchase Summary The terms that apply to your promotional purchase(s) are as follows: DEFERRED INTEREST: To avoid paying Accrued Interest Charges on a DEFERRED INTEREST promotion, you must pay at least your minimum payment due, if any, each month and the entire applicable Payoff Amount by the promotion Expiration Date. For each promotion, after a promotion ends or is terminated, non - promotional account tens will apply. To make more than one payment, you can pay online at the online address stated above or you can mail in your payment to the address on the remit stub. This address is also available from our automated customer service system. Accrued Billed Purchase Purchase INTEREST INTEREST Payoff Expiration Date Amount Promotion Type CHARGES CHARGES Amount Date 01 /1 21201 2 $408.04 Reg Deferred Interest/With Pay $0.00 $0.00 $408.04 07/18/2013 Transaction Summary Tran Date Post Date Reference Number/ Description of Transaction or Credit Amount Invoice Number 06115 08115 CHARGE OFF ACCOUNT- PRINCIPALS ($2.95018) 08/15 08115 CHARGE OFF ACCOUNT *FINANCE CHARGES' ($841.05) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 08/15 08/15 INTEREST CHARGE ON PURCHASES $0.00 Continued on next page PAYMENT DUE D) L5 P M (ET) ON THE DUE DATE. NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information. 7009 x5G 1 3 15 120815 Z X PAGE 1 of 3 9294 0010 5001 OICX7009 Detach and mall this portion with your check. Do not Include any correspondence with your check. —� Account umborIMEJEW5 9 Total Minimum Amount Payment New a ance Payment Due Past Due Due Date $778.00 $0.00 08/17/2012 $0.00 Payment Enclosed: (e F1 F1 ❑ F1 a ■ F] F1 I�Blll�Blll�lllhlll i�lllll I II�III�III6l� III Please use blue or black ink. New address or email? Print changes on back. I ANGELA D CHRISTOPHER 8 KINGSBRIDGE CIR CARLISLE PA 170134808 Make Payment to: LOWE'S /GECRB P.O. BOX 530914 ATLANTA, GA 30353 -0914 Transaction Summary(Contlnued) Tran Date Post Date Reference Number/ Description of Transaction or Credit Amount Invoice Number TOTAL INTEREST FOR THIS PERIOD $0.00 2012 Totals Year -to -Oats Total Fees Charged in 2012 $130.00 Total Interest Charged in 2012 $511.05 Total Interest Paid in 2012 $25.01 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 24.99% $0.00 $0.00 2D Reg Deferred InterestlWth Pay 07/1732013 24.99% $0.00 $0.00 20 Important Account Information 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. 7009 XSG 1 3 15 120815 Z X PAGE 2 of 3 9294 0010 5001 01CX7009 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �yyt�ty �i qteh Jody S Smith PM 2: 142 Chief Deputy Richard W Stewart C�UMBERLANU CCUN I `` Solicitor o=F klf.'Or'P.F PENNSYLVANI Portfolio Recovery Associates, LLC Case Number vs. Angela Christopher 2014-1047 SHERIFF'S RETURN OF SERVICE 03/07/2014 03:00 PM- Deputy Michelle Gutshall, 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:Angela Christopher at 509 W. North Street, Carlisle Borough, Carlisl PA 17013. MIC ELLE GUTSHALL, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, March 10, 2014 RONNK R ANDERSON, SHERIFF Te•nct 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 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. ANGELA CHRISTOPHER 509 W NORTH ST CARLISLE PA 17013 -2223 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14 -1047 CIVIL s .4 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 ANGELA CHRISTOPHER in this matter in the amount of $3,591.23 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 03 -28 -14 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: April 8, 2014 By: 3620 P28PTJ3PFJI 11111111111111111111111 I I 1 111111 I I I I I 11111 1 I I 1 1 I I I I 1 11111 I I I I I 1111111111111 Respectfully submitted, BLATT, HASENMILLER . LEIBSKER & MOORE, LLC Mo s Scott Syretta Martin 0,015' 1(.03Gai c4-14 ��yy� PORTFOLIO RECOVERY ASSOCIATES LLC VS: ANGELA CHRISTOPHER 509 W NORTH ST CARLISLE PA 17013-2223 Plaintiff, Defendant(s), IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 14-1047 CIVIL TO: ANGELA CHRISTOPHER 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. Dated: PROTHO TAFIY%, ‘k, 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 1 835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 1P 2836320 M 1111111111111113111111111111111111111111111111111111111111111111111111111 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 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. ANGELA CHRISTOPHER 509 W NORTH ST CARLISLE PA 17013 -2223 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14 -1047 CIVIL 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.miVappj/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. Dated: April 8, 2014 2836320 PPTJCAMI (06/28/2013) 1111111111111111111111111111811 IIIIVI11111111111111111111111111111111111 Bv: BLATT, HASEN R, LEIBSKER & MOORE, rris Scott yretta Martin Department of Defense Manpower Data Center Results as of : Apr-08 -2014 06:04:47 AM SCRA 3.0 Status Rapart Pursuant to Servicentembers Civil. Relief Act Last Name: CHRISTOPHER First Name: ANGELA Middle Name: Active Duty Status As Of: Apr -08 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NAV`i "'c" f ` Nd ,, . NA This response reflects the Md ais' active 4 status based on the Active Duty Status Date R 5J Left Active Duty Wdhln 367 Da f Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA -NA ... ... 'No . i.. -j,. NA This response reflects vfiere.the individual left active duty status within 367` days preceding the Active DutvStatus Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA "'NAa 'L c. -No .. NA This response reflects whether the individual or.hlslh tutu* t has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower, Data Center ;based on the information that you provided, the above Is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, 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. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 7 tThe DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as he 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: /Iwww.defenselink .mil /faq /pis /PCO9SLDR.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). efense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility porting Systerf (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. 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 SCFtA 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: A8534ADC4OFETAO PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, VS. ANGELA CHRISTOPHER 509 W NORTH ST CARUSLE PA 17013-2223 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14.1047 CIVIL TO: ANGELA CHRISTOPHER Date of Notice: March 28, 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 800 - 990 -9108 By: BLATT, HASENMILLE: EIBSKER & MOORE, LLC Morris o Syrett artin 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. 26320 P83PTNLRSI 111111111111111111111111111111111 11111 11111 11111 1111111 111111