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Home My WebLink About14-1533 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only. Civil Cover Sheet Docket No: Cumberland County 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 papers as required b law or rules of court. Commencement of Action: ❑ Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S Lead Plaintiff's Name: Lead Defendant's Name: SUSAN BRADY C PORTFOLIO RECOVERY ASSOCIATES LLC T Dollar Amount Requested: ® within arbitration limits I Are money damages requested? ® Yes[:] N (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? El Yes ® No Is this an MDJ Appeal? El Yes [K No A Name of Plaintiff /Appellant's Attorney: Morris Scott /S rettaMartin ❑ 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 0/13uyer Plaintiff Administrative Agencies ❑ Malicious Prosecution SA Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections El Dept. of Transportation 13 Nuisance 1:1 Statutory Appeal: Other S 13 Premises Liability El Product Liability (does not include E mass ton) E3 Employment Dispute: C ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board ❑ Other: U N MASS TORT ❑ Other: ❑ 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 2836411 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 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, ACTION CIVIL , r �s. SUSAN BRADY� rtz T-"_ 123 NITTANY DR MECHANICSBURG PA 17055' —a ` Defendant. r, w _` -4 f CD CD C . NOTICE TO DEFEND r r' 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 2836411 lJ"' "" PPTCPADI �UJ� 7/ ?30,�y 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 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. SUSAN BRADY 123 NITTANY DR MECHANICSBURG PA 17055 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), SUSAN BRADY, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GENERAL ELECTRIC CAPITAL CORP, (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 $989.17. 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. 2836411 PPTCDBCI (01/14/2014) 111111111 VIII 11111111111111111111111 VIII VIII VIII VIII VIII 111111 III 1III WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), SUSAN BRADY in the amount of $989.17, plus costs. Respectfully submitted, PORTFOLIO RECOVERY AS ATES LLC One of ' ttorneys Morris Scott Attorney I.D. 483587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: 314 l Verification I, Way 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. MAR 07 2014 Date: 4 Si 2836411 PPTXVRII (01/14/2014) 11111111111 IN Exhibit " A " PPTXEXAI CARECREDIT /GECRB Cardholder Name: SUSAN M BRADY GE Done Account Number: _6107 Money Statement Closing Date: 07/012012 Summary of Account Activity Payment information Previous Balance $954,17 New Balance $0.00 + New Purchases $0.00 Total Minimum Payment Due $283.00 - Payments $0 Payment Due Date 07/02/2012 +/- Credits, Fees & Adjustments (net) $954.17- PAYMENT DUE BY 5 P.M. EASTERN ON THE DUE DATE. +/- Interest Charge net $0.00 We may convert your payment Into an electronic debit. See New Balance $0.00 reverse side. Credit Limit $1 000,00 Available Credit $0.00 Late Payment Warning: If we do not receive your Total Days In Billing Period 28 Minimum Payment Due by the Payment Due Date listed above, you may have to pay a late fee up to $35.00. Pay online for free at: gogecapital.com For GE Capital Retail Bank customer service or to report your card lost or stolen, call 1- 866 - 893.7864. Best times to call are Wednesday - Friday. Promotional Purchase Summary Promotional Promotional Deferred Tran Date Descdptlon Initial Expiration Balance Interest Charge Purchase Date Amount 0710212012 $825.00 $0.00 12/13/2010 Deferred interest/No Interest If Paid In $1,000.00 Full A summary of your promotional purchase Is provided above. Any promotion may be terminated if your account goes 60 days past due. If you have a DEFERRED INTEREST /NO INTEREST IF PAID IN FULL promotion: To avoid paying Deferred Interest Charges on these promotion(s), you must pay the entire applicable Promotional Balance by the Promotional Expiration Date. On a Fixed Payment (Extended Payment Plan) promotional purchase, the Interest Charge is billed monthly and included as part of the Minimum Payment due. To make more than one payment see Make Payment To address or pay online at gogecapital.com. T ransaction Summary Tran Date I Post Date Reference Number Description Amount 07/01/2012 07/01/2012 F90720OJ700999990 CHARGE OFF ACCOUNT - PRINCIPALS $625.00 CR 07/01/2012 07/01/2012 F9072DOJ700999990 CHARGE OFF ACCOUNT *FINANCE $364.17 CR CHARGES' FEES 06/26/2012 06/262012 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INTEREST CHARGED 07/01/2012 07/01/2012 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2012 Totals Year -to -Date T otal Fees Charged in 2012 $245.00 Total Interest Charged in 2012 $27.17 T otal Interest Paid in 2012 $0.00 Interest Charge Calculation Expiration Date Annual Balance Subject to Interest Charge Type of Balance Percentage Interest Rate Rate (APR) Purchases NA 26.99% $0.00 $0.00 Deferred Interest/No Interest If Paid In Full 07/02/2012 26.99% $0.00 $0.00 NOTICE: See reverse side and additional pages (if any) for important information concerning your account. 5302 DrH 1 3 3 120701 Z D PAGE 1 of 3 9072 3000 xa37 Ol EJ5302 Pay ordim at gopecw tal.com or enclose this coupon with your check. Please use blue or black ink. C +� MA�pp/�,} Total Minimum Past Due Payment New Account Number Qr ei a vM ` Payment Due Amount Due Date Balance $283.00 $0.00 07/02/2012 $0.00 6107 Payment Enclosed : $ 000D]. ❑ New address or e-mail? Payment due includes $ 0.00 past due. Please pay the past due amount PROMPTLY. Check the box at left and NOTE: You have a Promotional Purchase Expiring. See Promotional Purchase Summary For Details. print changes on back SUSAN M BRADY ME CHANIC HANK SBURG PA 17055 -5562 Y DR ME Make Payment to: GE CAPITAL RETAIL BANK PO BOX 960061 ORLANDO, FL 32896-0061 Qrstomer ServleetQmstions: For account bm/ormation, pease cab the ION free number on the front of this statement. Unless your name is fisted on this statement, your access to Infomraton on the account may be linked You may also mail questions ibut not paymerds)to.P.O Box981127,BPaso, 7X79998. 1127. Peasehtdudeyouraoeamtnumberonanyearespondenceyousendtous Payments Sand payments to the aftess Msed on the remittance coupon portion of this statement or pay onion at vvvemg moneycom PT-30he2 n dght ibymfs er paymentscannotbemadelnperson, magpaymentsto: GEMoney Bank 140 K4eW2 Sprhtgslbad Longwood Notice: See belowforyourB'gbg 17ghtsandotherhnportantlnfavna0m 7blephmkrgabowbMngenmwNnot preserm yoirdphis underfedemilaw.7b preserveyomNHht%PkasewNfetoouriVgbVlt par ,HesAddv -q%P Box98f438, 81bsq 7X79998.1438. Purchase; mtwmandpaymentsmade)vg priortobaBngdate may notappearumlinextmomh We reserve the right to obtain payment efecuun epy for any check or other Instrument that you send to us by Initiating an ACH Plectrordc) debit In the amountofyotvdhedkorksavmenttoyour .16rrdneck nm? entwMnotberetunedInyoubyusoryourbardc bank account may be debited as early as the same day we receive your payment. )Wt may chose not to have your payment collected electronically by sendng your payment (with the remittance coupon), in your own envelope — not the enclosed remittance envdope, addressedto .FOBmx530960,Atlanta, 64 303 53- 09 60andnot thepaymentaddress What To Do If You Think You Rnd AMistake On Your Ratement: if you thk* there Is an error on Your statement, write to us at: GE Money Bank, PQ Box 981438, B Paso, 7X79998.1438. In your lettergi a us the followhg IMormation:. Account Inkrmatkon: )bur name and accountnumber . Doflaranxxmt. 7he dodaramount of the suspectedertw . Descdptkon ofproblem: t youtt**them isen evroron yourbig desafre what you believe Iswnohgand why you believe h isa m(take. You must rhrhtac ca within 60 days efferthe error appeared on your statement. You must notify us of any potential errors lft3Yt)lIIJg )bu may cab us but If you do we are not regtrbed to Investigate any potential mars and you may have to pay the amount In question, While we instigate whether or not there hasbeenanerror, the fe6owkrg .We cannot try tocof d the amount In question orreportyouas delinquent on that amount.. The charge In question maymmalnonyourstatement andwemayconthwetodnargeyouhmemstonthatamount . But, n we determine that we made a mkt8ke, you WWI have topay the amount in question orany keenest or other fees related to that amount. . While you do not have to pay the amount In questiM you are m*onsble for the ternslnderof your balance.. We can app fyanyunpa idamountagahutyourcmdltlink. )bur R'ghts If VbuAre Dlssetlsl7ed Wkh )burOrOdIt Card Pwr hasewffyou are dlssatWW with thegoodsorseMces that you have pwdhasedwtthyouram tcard, andyouhahe oconecttheproblemwiththemerchant,youmayhom to pay the remafrdrgamount due on the purchase. 7b use this right, agofthe fdlowing must be true: l) The purchase must have been made In yowhame state orwithhn100 address, andthe purchaseptke must have been more than $50. &te. Nekherofthese are necessary IF YOUr purchase wasbasedon an adventisemem we mailed to you, orliwe own the company that sokf you the goods or servlces) $) )fee must have used your crept card for the purchase. Hnchases made with cash advances from anATMorwkha dnedkdmtacceswsyouraMt caniaccountdonot quagy.3) lbumustnot yet havefully paldforthe purchase. ffaMof the akeria above are metand yousm sW tAmdsfied with the purchase, contact usfn w *1ng atP.Q Box 98143A B Pasq 7X 79998.1438. While- we investigate, the some rulesappy to the d)sputedamountesduamedebove. Afnxwe rhnM ourbrvest/gatkmr% we widieffyououra�. Vfhatpafnt, Mwethknkyouowe enamountandyoudonotpay we mayreportyouasdefrnquem • Information About Payments: You may pay more than the ibtal MlNmum Payment at any time Paymentsneceked after5A0 PM (E7)on any day wfffbe cred/tedasofthe next day. Qedk to yotvaccornt maybe delayed up to INe dayst payment (a)isnot mcehedat thepaymentaatbes%(b)lsnotmade In U.S dollarsdrdwnona U.S flnandalinstfttMonlocatedln the U.S. (c)isfht accanpamedbythe remittance coupon attached to yourstatemem, (d) ahntakksmore than one payment orrernttance coupon, (e) Is not recel edin the remittance envelope prwlded or in includes staples, paper con tape, a folded cnecir or cone Paymen All written communications spondrpa pa yment type. enional oonoemYng dLspxuted amount; dmdrroFrg airy check or other payment bInstrum d thhat: m /rxmcates that the payment ccnst/tutes'payment In hrg"oris tendetedas fu7setstactlon ofa dlsputedamoum, or JW Is tendered with othercondW= crknttaUons malledordelketedto usat PQ Box981438, BPasq 7X79998.1438. Ovdts to ibur Account An amount shown with a CRnext to the amount Is a credit or aedk balance unless otherwise hhdkated Qccftswgl beappfledtoyourpmWousbalancehnmed lateytq)onmcefpt, butwOnot sadsfyany regWredpaymentthatmay be due. Telephone Monitoring: Forquagy control purposes, you permit us to ffsten to ormeord telephone calls between you and us Q-edlt I4aportsandAecarnt information: Ifyoube8eve that wamayhavemportedinaecurate lnformatkmabout youtoa consrmer- reportingagency, pksase contact usatPQBox981439, 7X79998 - 1439. ndoingsgpk-aseldentllythehnaocuratekdamatfon andteMuswhy youbefi6mit Lshmeonea. tyouhavea copyofthe aedkreport dmtkchedesthelnaccuratelnfommatb a pkraseInchrde a copy of that repot. We may report Information about youraccount to credt bureaus Latepayment4 missed payment; or other defaultson yorvaccamtmaybemfkcted in youraeditreport. Variable Rate information: if any ofyourAPRs are variable, that AFRwM vary with the mar*et based on the Afte Itte. Now Long Wlll thellenaitylt teAppW tyourAP care ktawsedbecauseyoumadea latepaynxw, the PenakyAPRwg/appfy wO you make sfx cmwamve mhtmrrn payments when due. How We talarlateinterest: We use a methodcalled' dagybafarce". Duringbfl (hgcydesin which finerestis charged foreachbafance type on your account we fiklore the Interest charge on your account by appyl g the pertoaac rate to the 'daly balance "of your account for each day In the bfflhg cycle. A separate daffy balance wig be calculated for the fogowlng balance types as applicable: purchases, balance transfers, cash advances and other balances that are arb)ect to dlkftent Interest rate; plans or spectal promotion&Ahl,wedetemYnethe dalybal afce". TbdetemNnethedaflybaianee, wetakethebegInnhgbalanceeachday ,addany new charges and fees posted that day, and subtract any payments and credits posted that day. This gives us the dally balance. Second we calculate the amount ofinterest charged Tb do this, we mu#Vy the applicable daffy rate by each daly balance on your account. Thuµ we add the Interest amount to the dagybalarce, and the sum wilbecome the begimhgbalance for the Rftwfng day. lbrvInterest charge forthe b'iftcycle is the sum ofthekderestamounts the I were chargedeach day diving the Whig cycle foreach balance type. We charge a minimum of $2ofimerestfn any bOng cycle In whic you owe Interest. Paying Interes lbur due date is at least 23daysaRerthe close ofeachbM gcycle. Wew9 not charge you anyheemstonpurchases al b eyo ret beta n ebyt due date each month. Wewi l begin charging heereslon cash advancesandbalarcetmnsfemIf Bankruptcy Notice: If you file bankruptcy you must send in notice, Including account number and all Information related to the prooeeding to fix following address: bn eyBankA'tn: BandvuptcyDept, PO Box 103106, Fbsve4 6430076. Your account isownedandservicedby6EMoneyBank. Far complete terms amdea> dkfonsofyavaccoum , consult your Ovdk tardAgreement. Hearing impaired• 7DD users call 1- 877 - 448.8512 orac n02• a o&2vio Woflnformati onAbout You and YowAccountOtffFhVacyPoB a h ewgmsourcdkctionanddsebsweofkftmadonaboutyou and your Account. t you would Mite anther copy of the Aivacy agcy please call us at the arstomer service telephone number indcatedon the fromoft isstatemem. This Is an attempt to collect a debi and any information obtaIned wog be used for thatpurpose. E p r s rh ngg a telephone number on aocount, I consent to GEMoney Bank and any other owner or servker of my account ng myaaoounr, lnchtdlrguslganyconfactkhfamatonorcegpharenwnwm iprovfde.andloahsernrrotheuseaf my auiornatic teiephone dialing system arxYor anartllclalarrereaoudedwJce when axdactingme, even lllamehargedfor the caM undermyphhone n. For charges of address, phone number andror ema$ please check the box and print the charges below or visit us on-fine at wwwaemmevcom Name ❑ Street Aatbess aP ,Sr, Aline M &ME raanrrvaw a+>acnmwror aspnneaanerorwier aM1YAY!!n w.v,mmwrfaayau BYPRWDM XXMBK4LAOD R= )ouacREroRUBWBMLOM uNrCRMABOUnanzAOMUNTiwDALSOGM Pt3MSI NFORUS roPROWDEMER&MLADDFEWTOTHE KMGgFa Cardholder Name: SUSAN M BRADY Account Number. 6107 ' Statement Closing a e: M2 ff rd older News 8r Information o protect your account privacy, we are unable to provide account information to anyone other than the cardholder(s) or rized party, If you wish to permit us to speak to an authorized art such as a s use about thorization to the General Inquiries address. p y pO your account, please send 5302 DFa 1 3 3 120701 Z D PAGE 2 of 3 9072 300D XB37 OIEJ5302 5302 DFN 1 3 3 120701 2 D PAGE 3 of 3 9072 3000 %B37 OlE05302 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 FTHER OMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 TY, Plaintiff, S SUSAN BRADY CD D . 123 NITTANY DR y MECHANICSBURG PA 17055 ° _ - Defendan,t(s). v r y �t 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 28, 2014 B Morris ott Attorney Syreffa Martin Attorney 2836411 PPTXPEAI (11/18/2013) IIIII IIIII IIIII IIIIII III IN Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY f)ROTHON0A:"6' In If OIL 20114HAR 24 AM 11: 23 OFF1OE OF THE $HEFZ1FF CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Susan Brady Case Number 2014-1533 SHERIFF'S RETURN OF SERVICE 03/18/2014 08:33 PM - Deputy Tim Black, 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: Susan Brady at 123 Nittany Drive, Upper Allen, Mechanicsburg, PA 17055. TI BLACK, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, March 19, 2014 RONNY R ANDERSON, SHERIFF (c) CounwSuite Sheriff, Teleoscf:, Inc. Blatt, Hasenmiller, Leibsker & Moore, LLC 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. SUSAN BRADY 123 NITTANY DR MECHANICSBURG PA 17055 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-1533CIVIL .101 ..* .•■• 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 SUSAN BRADY in this matter in the amount of $989.17 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 04-10-14 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: April 22, 2014 By: 2836411 PPTJPFJI 111111111111111111111111111111111111111111111111111111111111111111111111111 Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Syretta Martin (I' qyr 11- 014, No-ticc ,,„( Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney Y.D.#309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOUO RECOVERY ASSOCIATES LLC c/o Blatt, HaawnnmU|e,'Leibsker& Moore, LLC 1835 Market Stvoed. Suite 501 Phi|ade|phia, PA 19103 VS. SUSAN BRADY Plaintiff, 123 NITTANY DR MECHANICSBURG PA 17055 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-1533CIVIL AFFIDAVIT OF NON-M1LITARY 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 Stateo, 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. Dated: April 22, 2014 By: �83841 1 P�Q�AM| (06/28/2013) |U0|U|||U|UUU0||0UU�NUNU�UN00�0NN0|�0 |NUNNNUU�UNNUUUNNNNUNNNUNUNN|UUNN & MOORE, LLC Syretta Martin Department of Defense Manpower Data Center Results as of : Apr -22 -2014 05:29:52 AM SCRA 3.0 Status Report Pursuant to Servicentembers Civil Relief Act Last Name: BRADY First Name: SUSAN Middle Name: Active Duty Status As Of: Apr -22 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA?... No , ' NA f This response reflects the Individuals' 'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA i No NA This response reflects where the individual left active-duty status within 367 days preceding the Active Duty Status Date The Member or HislHer 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 NA No NA This response reflects whether the individual or his/her unit 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. v�. 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 abov , or any family member, friend, or representative asserts in any manner that the individual wa on active duty for the active duty status date, or is otherwis 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 ^uomnnunnx.mirunL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 day 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 accordanc with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty period 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 supporte by Federal funds. All Active Guard Re erve (AGR) members must be assigned against an authorized mobiliza on position in the unit they support. This includes Navy Training and Administration of the Reserve (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). e 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 Activ 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 servic . 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: L9|222E1A044L[JO PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, Vs. SUSAN BRADY 123 NITTANY DR MECHANICSBURG PA 17055 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14- 1533CIVIL TO: SUSAN BRADY Date of Notice: April 10, 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, HASENMILLER, LEIBSKER & MOORE, LLC Morris Scoff 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. 2836411 PPTNLRSI 11111111111111111111111111111111111111111111111111111111111111111 PORTFOLIO RECOVERY ASSOCIATES LLC VS. SUSAN BRADY Plaintiff, 123 NITTANY DR MECHANICSBURG PA 17055 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 14-1533CIVIL TO: SUSAN BRADY 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: By: PROTHONOTARY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2836411 PPTNDJNI 11111111111111111111111 111111111111111111111111 11111 1111111111 1111 111111111