HomeMy WebLinkAbout14-1575 Suprreme +C,omrt of,.Pennsylvania
Cour 3of Comon Pleas
For Prothonotar Use Onl y
C llvi� 1. I'} t 1 _ 1 IME ST.aMP
A „ ove,�S ee Docket No:
CLIMB fi r`
county
The information collected on this form is used solely for court administration purposes. This form does not
supplement at- replace the filing and service of pleadings or other Papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiffs Name: i• Lead Defendant's Name:
PORTFOLIO RECOVERY ASSOCIATES, LLC SANDRA PRIVETTS
T
0 Are money damages requested? ® Yes El No. Dollar Amount Requested: X within arbitration limits
N (Check one) outside arbitration limits
Is this a Class Action Suit? ❑ Yes ®No Is this an MDJAppeal? ❑ Yes ®No
A 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
1 ❑ Malicious Prosecution
❑Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections
❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation
❑ Premises Liability _— __-- _ –_ - - -- p Statutory Appeal: Other
❑ Product Liability (does not. include
S mass tort) C3 Employment Dispute:
E ❑ Slander /Libel /Defamation Discrimination E3 Zoning Board
E3 Other:
C c3 Employment Dispute: Other ❑ Other:
I C] Other:
------ - - - - --
MASS TORT
0 ❑ Asbestos –` –
N ❑ Tobacco
❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Other: ❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations
— ❑ Mortgage Foreclosure: Residential Restraining Order
❑ Mortgage Foreclosure: Commercial
El Quo Warranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal -- — -- - - - - --
❑ Medical _ - - - - - -- - -- - - - --
❑ Other Professional:
15 -15981
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 w F fi
Norfolk, VA 23502
TELE: 1- 866 - 428 -8102
FAX: (757) 518 -0860 �C ;,' T Y
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD S S l U i
NORFOLK, VA 23502 No.
Plaintiff,
V.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
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
15 -15981
LJIVI 1^
#- 3e36 S
This communication is from a debt collector and is an attempt to coll ct a debt.
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 # 31.2686
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.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
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 dernandas 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 OFICINA 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
15 -15981 (717) 249 -3166
Esta comunicacion es de un cobrador de deudas y es un intent do cob.rar una deuda.
Cualquier infroinacio.n 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.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
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, SANDRA PRIVETTS, is an adult individual with last known address of 40
HARMONY HALL DR, CARLISLE PA 17015.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on
March 11, 2007 with account number * * * * * * * * * ** *0872 (hereafter referred to as "Account ").
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.
5. At all relevant times material hereto, Defendant has used said Account for the purchase of
products, goods and/or for obtaining services.
This communication is from a debt collector and is an attempt to collect a debt.
Any inforination obtained will be used for that purpose.
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 September 9, 2012.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK /
WAL -MART and Plaintiff is now the holder of the Account. A true and correct copy of the
Plaintiffs Bill of Sale 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
$3,569.60.
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, SANDRA PRIVETTS , in th ount of $3,569. , us costs of this
action and any other relief as the Court deems just and r as a
e A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
15 -15981
This communication is from a debt collector and is an attempt to collect a debt.
Any infonnatio.n obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Cynthia Clarke 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.
Date: FE B 2 8 20 14 By:
Cynthia Clarke
Custodian of Records
15 -15981
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
X IBIT 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.
.......................... ..... .
................... ... .......... .
f
GE Capital
BILL of SALE
PRA PLCC Fresh — May 2013
For value received and in further consideration of the mutual cove
set forth in the Forward Flow Receivables Purchase Agreem conditions
ent (the "Agreement nants and con dated
as of the 13 day of December, 2012 by and between General Electric Capital
Corporation, GE Capital Retail Bank, GEMS 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 May 20,
2013, and as further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By:
Glenn Marino By.
Glenn Marino
Title: EVP Title: _President
Date: Date:
General Electric Capital Corporation
RFS Holding, L.L.0
By:
Glenn Marino B y ,
Joseph Ressa
Title: _vice President
Title: _CFO
Date:
Date:
GEMB Lending, Inc, GEM Holding, L.L.0
By: >v
Stephen Matta B y :
Joseph Ressa
Title: —Director ----
Title; CFO
Date: W41 ► 3 —
Date:
...... ...............................
1 +
GE Capital
BILL of SALE
PRA PLCC Fresh — May 2013
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 13 day of December, 2012 by and between General Electric Capital
Corporation, GE Capital Retail 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 May 20,
2013, 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 g, L.L.0
By: By .
Glenn Marino Joseph Rcs _
Title: _Vice President Title: CFO
Date:
Date:
GEMB Lending, Inc. GE Wing, L.L.0
By:
Stephen Motta By.
Joseph s
Title: — Director Title: CFO
Date: Date:
.. .. .......... ..................... ... .........
GE Capital
BILL of SALE
PRA PLCC Fresh — May 20113
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 13` day of December, 2012 by and between General Electric Capital
Corporation, GE Capital Retail 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 May 20,
2013, 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
B y : By:
Stephen Motta Joseph Ressa
Title: _Director Title: _CFO
Date: 14 113 Date:
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
. .
THE u
2l111 APR -2 PM I 3
7,13I,13ERt_ AND [-;,-211,111-).'
PENNSYLVAN1
‘,01 OIL Ctlif0t,e4,40.
OPC-RW OF TKE sagRvF
Portfolio Recovery Associates, LLC
vs.
Sandra Privetts
Case Number
2014-1575
SHERIFF'S RETURN OF SERVICE
03/20/2014 10:54 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Nathan Black, husband of
defendant, who accepted as "Adult Person in Charge" for Sandra Privetts at 41 Ha ,tny Hall Drive,
Middlesex, Carlisle, PA 17015.
WO": CLIN 7DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
March 21, 2014 RoN R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Tele,osoft,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff
v.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
Date:
No. 14-1575
PRAECIPE FOR DEFAULT
Defendant JUDGMENT
15-15981
Fil
half of Plaint'
of Record for
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
OM1Ii1507'Th1CL{l49ay36-71-?
R
This communication is from a debt collector is an attempt to collect a debt. NO
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
v.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
Defendant
No. 14-1575
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, SANDRA PRIVETTS, for failure
to answer the Complaint.
(X) Amount Due $3,569.60
Less Credits $.00
TOTAL $3,569.60
(X
(X
(X
15-15981
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.
Pursuant to PARC.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.
Pursuant to PARC.P.231.1, I certify tha ritten notice of intenti• 1 file this
praecipe was mailed or delivered to the .. against whom jud . ► ent ' to be entered
and to his/her attorney of record, if y, . er the default occu ed . at least ten days
prior to the date of the filing of this . raecip d . cop o thi c = . ttached.
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
This communication is from a debt collector 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
v.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
Plaintiff No. 14-1575
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 $3,569.60.
(X) A copy of all documents filed with the Prothonotary in support .f the wn ju nt is/are
attached.
If you have any questions regarding this Noti
15-15981
rt . 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
This communication is from a debt collector is an attempt to collect a debt.
Any information obtained will 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)
April 17, 2014
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. SANDRA PRIVETTS
14-1575
Dear SANDRA PRIVETTS:
Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
15-15981
Sincerely,
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
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
v.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
Defendant
TO: SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
DATE OF NOTICE: April 17, 2014
IMPORTANT NOTICE
No. 14-1575
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.
15-15981
Lawyer Referral Service - CUMBERLAND County Bar Association
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
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
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
v.
SANDRA PRIVETTS
40 HARMONY HALL DR
CARLISLE PA 17015
Defendant
No. 14-1575
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
40 HARMONY HALL DR
CARLISLE PA 17015
and is not in the military service of the United States or its Allies
the Service Members Civil Relief Act and its Amendments.
15-15981
erwise within the
s of
' 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
This communication is a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
Walmart Q qa.
Save money. Live better.
Walmart®
Discover Card
SANDRA A PRIVETTS
Account Number:
Summary of Account Activity
Previous Balance
- Other Credits
$3,569.60
$3,569.60
New Balance
Credit Limit
Available Credit
Cash Advance/Quick Cash Limit
Available Cash
Statement Closing Date
Days in Billing Cycle
$0.00
$2,700
$0.00
$61
$0.00
04/17/2013
27
Cash Earned Summary
Previous Balance
(+) Earned This Period
= Balance
$0.00
$0.00
$0.00
Visit us at walmart.com/credit
0872 Customer Service: 1-866-314-9507
Payment Information
New Balance $0.00
Amount Past Due $0.00
Total Minimum Payment Due $832.00
Payment Due Date 04/19/2013
Late Payment Warning:If we do not receive your minimum
payment by the date listed above, you may have to pay a late
fee up to $35.00.
Cash News
Earning cash back with the Walmart® Discover®
is easy! Simply use your card everywhere
Discover® is accepted. Remember every
time you earn just $10, you will receive a
check in your billing statement - it's automatic.
Transaction Summary
Tran Post
Date Date Reference Number
04/17 04/17 F6210003600999990
04/17 04/17 F6210003600999990
Description of Transaction or Credit
CHARGE OFF ACCOUNT -PRINCIPALS
CHARGE OFF ACCOUNT *FINANCE
CHARGES'
FEES
TOTAL FEES FOR THIS PERIOD
INTEREST CHARGED
04/17 04/17 INTEREST CHARGE ON PURCHASES
04/17 - 04/17 INTEREST CHARGE ON CASH ADVANCES
TOTAL INTEREST FOR THIS PERIOD
2013 Totals Year -To -Date
Total Fees Charged in 2013
Total Interest Charged in 2013
Total Interest Paid in 2013
$35.00
$197.52
$0.00
Amount
($3,010.19)
($559.41)
$0.00
$0.00
$0.00
$0.00
Interest Charge Calculation
Your Annual Percentage Rate (APR)s the annual interest rate on your account.
Expiration Date Annual Percentage
Rate
22.90% (v)
25.90% (v)
0.00%
Type of Balance
Regular Purchases
Cash Advances
Quick Cash
(v) = Variable rate
NA
NA
NA
Balance Subject To Interest Charge
Interest Rate
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
Cardholder News and Information
If your account has a deferred interest promotion and you would like us to apply a payment on your account to a specific
balance, please call Customer Service to discuss 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 debit See reverse for details, Billing Rights and other important
information.
5409 BGH 1 3 18 130417 ZX PAGE 1 of 1 6210 1000 A323 01215404
Detach and mail this portion with your check. Do not include any correspondence with your check.
Walmart
Save money. Live better.
IQI
111111
III
111
II
III
SANDRA A PRIVETTS
2332 RITNER HWY
CARLISLE PA 17015-9316
Account Number 0872
Total Minimum
Payment Due
Amount
Past Due
Payment Due
Date
Overlim nce
Amount
$832.00
$0.00
04/19/2013
$0.00
$0.00
Payment Enclosed:
Please use blue or black ink.
IIIII II
New address or email? Print changes on back.
Make Payment To: WALMART DISCOVER/GECRB
PO BOX 960024
ORLANDO, FL 32896-0024
Department of Defense Manpower Data Center
Results as of : May -07-2014 04:00:37 PM
SCRA 3.0
Status Report
Pursuant to Servieemembers Civil. Relief Act
Last Name: PRIVETTS
First Name: SANDRA
Middle Name:
Active Duty Status As Of: May -07-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
:'Noy::
NA
This response reflect 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 ..:: _ ......
... No ..;. ,
NA
This response reflects where the individual left active duty status within 367 days preceding the ActiveDuty Status 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
NA
No
NA
This response reflects whether t e 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.
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 (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: M9J9NB6700B0PDO