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Home My WebLink About14-1768 Supreme Coy of Pennsylvania Cour =o#' Com� on Pleas /� fi ,F1 �' For Prothonotary Use Only: TIME. STAMP CUMBi *il Gover4Sb"County et Docket No: ? U ,A The information collected on this form is used solely for court administration purposes. This form does not _ l supplement or replace the Cling 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 E] Transfer from Another Jurisdiction E] Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC HOPE PARKS, LARRY M PARKS j Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits O - -- (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: 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. I I TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability __— — _ ❑ Statutory Appeal: Other ❑ Product Liability (does not include S mass tort) ❑ Employment Dispute: - - - -- E ❑ Slander /Libel /Defamation Discrimination ❑ Zoning Board 4 ❑ Other: ❑ Employment Dispute: Other ❑ Other: T ------ - - - - -- - I C] Other: MASS TORT ` I Q ❑ Asbestos I N ❑ Tobacco F Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment I B ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations i -- - -`–`— ❑ Mortgage Foreclosure: Residential Restraining Order - - - - - -- ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ----- - - - - -- -- ❑ Medical - - -- ❑ Other Professional: 15 -28197 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 (;. 11 i f` P 7't;D ;(i il,tc i 120 Corporate Blvd Z 014 f ?IR 2b Norfolk, VA 2350231 it: . TELE: 1- 866 - 428 -8102 CUMBERIAND COUNTY FAX: (757) 518 -0860 PENNSYLVANIA 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 No. jj iJ f Plaintiff, V. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Defendants. 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 -28197 This communication is from a debt collector and is an attempt to collecleff Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Demandados. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORRE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OTRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 15 -28197 Fsta comunicacion. es de un cobrador de deudas y es un intent do cob.rar una deuda. Cualquier inf omacion 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. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Defendants. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendants, HOPE PARKS and LARRY M PARKS, are adult individuals with last known address of 406 MOHAWK RD, NEWVILLE PA 1.7241 and 224 BRICK CHURCH RD, NEWVILLE PA 17241. 3. It is averred that Defendants were indebted to GE CAPITAL RETAIL BANK / LOWES on November 30, 2008 with account number * * * * * * * * * ** *4164 (hereafter referred to as "Account "). 4. By using the Account, Defendants 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, Defendants have used said Account for the purchase of products, goods and /or for obtaining services. This comm tin ication is from a debt collector and is are attempt to collect a debt. Any inforni tion obtained twill. be used for that purpose. 6. Defendants were 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 Defendants. 7. Defendants were 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 August 22, 2011. 8. Plaintiff is the purchaser, assignee and /or successor in interest GE CAPITAL RETAIL BANK / LOWES 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 $1,863.42. l O.Despite reasonable and repeated demands for payment. Defendants have 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. I LThe 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 Defendants, HOPE PARKS and LARRY M PARKS, in the amount of $1,863.42, plus costs of this action and any other relief as the Court deems just and aso ble. Ca rown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15 -28197 This comniL mication is fi - om a debt collector and is an attempt to collect a debt. .Any ixrl:ormation obtained vvi.11. he used for that purpose. . a VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Elonda Sherman 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: FEB 2-8 2014 B Elonda Sherman am& --&Max? Custodian of Records 15 -28197 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 !BIT 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. GEC041 j GE Ca pital BILL of SALE PRA Fresh — April 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on April 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: �� B Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: Title: Vishal Gulati -CFO Title: Vishal Gulati -CFO GE Capita! BILL of SALE PRA Fresh — April 2012 For value received and in fizrther consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on April 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMS Lending, Inc. By: By: S=4L Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: Title: Vishal Gulati -CFO Title: Vishal Gulati -CFO ! t GE Capital BILL of SALE PRA Fresh — April 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20` day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on April 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By: Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: _... Title: Title: �� — 0 Ronny R Anderson Sheriff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY /HE: PRO THONG T4:'. contot,.4 °. rnY APR —2 PM L/ / ' CUMBERLAND CUUM|Y Portfolio Recovery Associates, LLC vs. Hope Parks (et al.) Case Number 2014-1768 SHERIFF'S RETURN OF SERVICE 03/27/2014 07:58 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Hope Parks at 406 Mowhawk Road, Upper Frankford, Newville, PA 17241. S-3.0-1,1 VIA DAWN KELL, DEPUTY 03C27C2014 08:07 PM - Deput Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Larry M Parks at 224 Brick Church Road, Upper Frankford, Newville, PA 17241. g m ��^ » DAWN KELL, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, March 28, 2014 R N R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Date: Defendants 15-28197 No. 14-1768 PRAECIPE FOR DEFAULT JUDGMENT Filed o p 4;1f of Plaintiff Co el f' ecord for this P. ' . 'olas, 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 n . 4 .gYp..9) pd 1- Cri4a°53 pi-, '115-09 This communication is tiom. a debt collector is an attempt to collect a deb Q plailp 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. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Defendants : No. 14-1768 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendants, HOPE PARKS and LARRY M PARKS, for failure to answer the Complaint (X) Amount Due $1,863.42 Less Credits $.00 TOTAL $1,863.42 (X) (X (X) 15-28197 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 PA.RC.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 that a w ' en notice of intention to file this praecipe was mailed or delivered to the p. - ag. Inst whom judgment is o b: entered and to his/her attorney of record, if any after , e default occurred . d at . t ten days prior to the date of the filing of this p .ecipe .y;I ��y y the oched. 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. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Plaintiff No. 14-1768 Defendants 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 $1,863.42. (X) A copy of all documents filed with the Prothonotary in suppo •f the in ' = -nt is/are attached. If you have any questions regarding this N 15-28197 Robert N. Polas, Jr., Esquire, # 201259 Carrie A. Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is fio.m 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 HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. HOPE PARKS 14-1768 Dear HOPE PARKS: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 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 15-28197 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. HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 Defendant TO: HOPE PARKS 406 MOHAWK RD NEWVILLE PA 17241 DATE OF NOTICE: April 17, 2014 IMPORTANT NOTICE No. 14-1768 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. 15-28197 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. 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 LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. LARRY M PARKS 14-1768 Dear LARRY M PARKS: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 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 15-28197 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. LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 Defendant TO: LARRY M PARKS 224 BRICK CHURCH RD NEWVILLE PA 17241 DATE OF NOTICE: April 17, 2014 IMPORTANT NOTICE No. 14-1768 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. 15-28197 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 OURT OF COMMON PLEAS OF CUMBERLAND CO NI Y, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 14-1768 v. • HOPE PARKS -406 MOHAWK RD •. NEWVILLE PA 17241 LARRY M"PARKS 224 -BRICK CHURCH RD P+ � NEWVILLE PA 17241 h; i .:s Defendants 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:elinforination and belief, theabove named Defendants_, are-over'21 years of age; are last known to reside at, 406 MOHAWK RD NEWVILLE PA'17241 and• 224 BRICK CHURCH RD NEWVILLE PA 17241 and are not ;n the military service of the United States or its Alli the Service 'Members Civil Relief Act and its Amendments. 15-28197 erwise within the L ovi 'ons of Robert N. Polas, Jr., Esquire, #201259 Carrie A Brown, Esquire, #94055 Mark R Garvey, Esquire, #312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) (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. Department of Defense Manpower Data Center Results as of: May -07-2014 06:41:28 PM SCRA 3.0 Status Report Pursuant to Servicernembers Civil Relief Act Last Name: PARKS First Name: HOPE 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 ..No NA This response reflects the individualsactive duty status based on the AdiVe'Dubj 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 reftects where the individual left active duty status within 367 -days preceding the Active Duly Status Date The Member or His/Her Unit Was Notified of a Future Cell -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA . . NA This . ..-.. .. response reflects wtiether 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 -1311(yph- 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: C9C52C87N008F60 Department of Defense Manpower Data Center Results as of : May -07-2014 06:56:53 PM SCRA 3.0 Report t to Servieemembers Civil Relief Act Last Name: PARKS First Name: LARRY 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 No -�.�.. NA This response reflects the individuals' active duty status based on the Active DutyStatus Date Left Active Duty Within 367 Das 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 Active Duty 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 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. rh 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/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 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: P9CBJC37Z028FAO