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Home My WebLink About14-2415 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only. Civil Cover Sheet Docket No: Cumberland County ayes 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 by law or rules of court. Commencement of Action: El Complaint ❑ Writ of Summons Cl Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: TIFFANY J POMEROY C PORTFOLIO RECOVERY ASSOCIATES LLC Are money damages requested? ® Yes❑ N Dollar Amount Requested: ® within arbitration limits (Check one) ❑ outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: Morris Scott/Syretta Martin ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your 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 ❑ Malicious Prosecution .Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability (does not include ❑ Employment Dispute: mass tort) C 1:1 Slander /Libel/Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board I ❑ Other: O 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 1/1/20 2927694 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, CIVIL ACTION VS. n r TIFFANY J POMEROY 1422 3RD ST ENOLA PA 17025 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff- You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET - _- CARLISLE, PA 17013 t < 800 - 990 -9108 � n �, 3. 7SIL cK�' 487y3 2927694 3oyr /0 PPTCPADI (03/04/2014) 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 800- 990 -9108 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Frank Janello Attorney I.D. #315643 Beth Arnold Howell Attorney I.D. #203606 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. TIFFANY J POMEROY 1422 3RD ST ENOLA PA 17025 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), TIFFANY J POMEROY , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) opened an extension of credit agreeing to make monthly payments for the purchases charged to the account and /or cash advanced. 3. The Defendants) 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 $3162.13. 4. Plaintiff is the successor in interest of said account from CITIBANK/HOME DEPOT 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. i 2927694 PPTCDBCI (04/02/2014) I IIIIIIII VIII IIII IIIIII II IIIIII VIII VIII VIII VIII VIII VIII IIII VIII IIII WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), TIFFANY J POMEROY in the amount of $3162.13, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of its Attorneys Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Frank Janello Attorney I.D. #315643 Beth Arnold Howell Attorney I.D. #203606 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: Verification I, Samaria Braswell , am an authorized agent and /or employee of Plaintiff. I am authorized to make this verification on behalf of Plaintiff. The statements of facts set forth in the complaint are true and correct based upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: APR 112014 Signature Samaria Braswell Custodian of Records 2927694 PPTXVRII (01/14/2014) I VIII IIIIIII III IIIIII VIII IIII) VIII VIII VIII VIII IIII VIII IIII Exhibit " A " PPTXEXAI Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: ll Customer Service: HOME DEPOT CREDIT SERVICES myhomedepotaccount.com PO Box 790326, St. Louis, MO 63179 Account Inquiries + 1 "J i �asowsry ws sr "� sssati 1- 866 -458 -7683 Summary of Account Ac(N t Payment Information Previous Balance $2,851.02 New Balance $3,162.13 Payments -$0.00 Minimum Payment Due $765.00 Other Credits -$0.00 Payment Due Date January 4, 2013 Purchases +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above, you may have to pay a late fee up to $35. Interest Charged +$276.11 Minimum Payment Warning: If you make only the minimum payment each New Balance $3,162.13 period, you will pay more in interest and it will take you longer to pay off your Past Due Amount $631.00 balance For example Credit Limit $0.00` Available Credit $0.00 Only the minimum payment 20 years $7,975 Statement Closing Date 12/07/2012 $129 3 years $4,661 Next Statement Closing Date 01/08/2013 1 1 (Savings = $3,314) Days in Billing Cycle 30 it you would like Information about credit counseling services, call 1 -877- 337 -8186. Your minimum payment due is $765.00. To avoid Interest charges on your non - promotional (revolving) balance and any expiring promotions, pay $3,162.13 by January 4, 2013. If you pay your non - promotional balance in full every month, no additional billed Interest charges will apply. Interest accrues dally from your statement closing date until we receive your payment, so please check your next statement for any additional Interest you may have Incurred. You must pay your promotional balance of $66.99 in full by 01/04/13 to avoid paying deferred interest charges. 8HD3 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, N.A. ----------------------------------------------------------------------------------------------------------------------------- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. T tPast Due Amount is Included in the Minimum Payment Due. et Payment Due Dat® New Balance Past Du ®Amounts Minimum Payment Due Amount Enclosed JANUARY 4, 2013 $3,162.13 $631.00 $765.00 $ ` µ 5813 Make Checks Payable to: HOME DEPOT CREDIT SERVICES PO BOX 182676 TIFFANY J POMEROY COLUMBUS, OH 43218 -2676 1422 3RD ST ENOLA, PA 17025 -2392 Print address changes above in blue or black ink. i Information About Your Account. How to Amid Paying Interest on Purchase urchases. Your payment due date Is at least 25 days after the Whet Will Happen Alter We deceive Your Letter close of each billing cycle. We will not chrarge ou any interest t on purchases if you pay your New When we receive your letter, we must do two things: Balance by the payment due date each month. Wis is called a grace period on purchases. If you do 1 Within 30 days of receiving your letter, we must tell you that we received your fetter, We will also not day the New Balance In full by the payment due date, you will not get a grace period on purchases tell you it we have already corrected the error. unti you pay the New Balance in full for two billing cycles in a row. 2. Within 90 days of receiving your letter, we must either correct the error or explain to you why we If you have a balance subject is a deferred interest or 0% APR promotion and that promotion does not believe the bill is correct. expire before the payment due date, that balance (the "excluded balance") is excluded from the While we investigate whether or not there has been an error: amount you must pay in full to get a grace pperiod. However, you must still pay any separately reqquired Payment c n the excluded balance. In briling cycles in which payments are allocated to daierred • We cannot try to collect the amount In question, or report you as delinquent on that amount, interest balances Ifrst, the deferred interest balance will be reduced before any other balance on the • The charge In question may remain on your statement, and we may continue to charge you interest account. However, you will continue to gel a grace period on purchases so long as you pay the New on that amount Balance less any excluded balances in toil by the payment due date each billing cycle. We may refer . While you do not have to pay the amount in question, you are responsible for the remainder of to deferred interest promotions as No Interest promotions, your balance. In addition, certain promotional offers may take away the grace period on purchases. Other • We can apply any unpaid amount against your credit limit promotional offers not described above may also allow you to have a grace period on purchases After we finish our investigation, one of two things will happen: without having to pay all or a portion of the promotional balance by the payment due data, if either is the case, the promotional offer will describe what happens. • b w mado a mistake. You will not have to pay the amount in question or any interest or other fees related to that amount How We Calculate Your Balance Subject to Interest Rate. For each balance, the letter . p we do not belleve theta vas a mistaka: You will have to pay the amount in question, along with following the Annul Percent a Rate in the Interest Charge Calculation section on the front of the applicable interest and fees. We will send you a statement of the amount you ows and the date statement indicates the method we use to calculate interest charges. For Methods C, H and M, we use payment is due. We may then report you as delinquent if you do not pay the ammount we think you ow& a dally balance method (including current transactions) to calculate interest charges. For Methods I If y ou receive our explanation but stilt believe Your bill is wren g. s iQ and L, we use an average daily balance method, including current transactions) to calculate interest you must write to us within *' charges. For Method K, we use an average daily lance method (excluding current transactions to telling us that you still refuse to pay. If you do so, we cannot report you as delinquent without also calculate interest charges. To find out more Information about the balance computation method Uat y reporting that you are questloning your bf il. We must tell you the name of anyone to whom we reported applies to your account and how the resulting interest charges were determined, contact us at be as delinquent, and we must let those organizations know when the matter has been settled Customer Service number on the front � us. Credit Reporting Disputes. If you think we reIpoded inaccurate information to a credit bureau write If we do not follow all of the rules above, you do not have to pay the first $50 of the amount you us at the Customer Service address shown on the front. question even if your bill is correct. Report a Lost or Stolen Card Immediately. Call the Account Inquiries number shown on Your Rights N You Am DlssaNslied With Y our Credit Cent P'umheses the front. i If you are dissatisfied with the goods or services that you have purchased with your credit card, and What To Do If You Find A Mistake On Your Statement you have triad in good faith to correct the problem with the merchant, you may have the right not to It you think there is an error on your statement, write to us at the address for billing inquiries and pay the remaining amount due on the purchase. correspondence shown on tha front of your statement. To use this right, all of the following must be true: In your letter, give us the following information: 1. The purchase must have been made In your home state or within 100 miles of your current • Account information: Your name and account humor. mailing address, and the purchase rice must have been more than $50. (Note: Neither of these • DaI(aramaurtt The dollar amount of the suspected error. are necessary d your purchase was based on an advertisenment we mailed to you, or it we own the company that sold you the goods or services.) • Description ofproblem : If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. 2. You must have used your credit card for the purchase. Purchases made with cash advances from You must contact us: an ATM or with a check that accesses your credit card account do not qualify. • Within 60 days after the error appeared on your statement. 3. You must not yet have fully paid for the purchase. • At least 3 business days before an automated payment is scheduled, if you want to stop payment on the amount you think is wrong. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at the You must notity us of any potential errors in writing. You may call us, but d you do we are not required You for billing Inquiries and correspondence shown on the front at your statement. to investigate any potential errors and you may have to pay the amount in question. While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay, we may report you as delinquent. KEY CREDIT TERMS — NO INTEREST IF PAID IN FULL WITHIN 6 MONTHS'. $299 minimum purchase required. Minimum payments required. Interest will be charged to your account from the purchase date if the purchase balance (Including premiums for optional credit Insurance) is not paid In full within 6 months or if you make a late payment. 'With credit approval for qualifying purchases made on The Horne Depot or EXPO Design Center Consumer Credit Card, 17.99% - 26.99% APR. Minimum Interest charge: $2. See card agreement for details including APR applicable to you. Offer fs only valid for consumer amounts and is subject to change without notice. Important Payment instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account. You ray pay all or part of your account balance at any time. • Dnllne Payments. Visit myhornedepohaccountcom and sign up for free online payments. However, you must pay, by the payment due date, at least the minimum payment due. Enrollment may take a few days, It we receive your request to make an online payment by 5 M. Crediting Payments. No receive your mailed p in proper format our processing facility by Eastern time, we will credit your payment as of that day and it will post within three business days. 5 p.m. local time there, it will be credited as of that day. A payment received there in proper form after If we receive your request to make an online payment after that time, we will credit your payment as that time will be credited as of the next day. Allow 5 to 7 rays for payments by regular mail to reach of the next day and it will post within three business days. For security reasons, you may be unable us. There may be a delay of up to 5 days In crediting a payment we receive that Is not in proper form to pay your entire New Balance with your first online payment or Is not sent to the correct address. The correct address for regular mail is the address on the front of . AutuPay Service. If you are enrolled in this service, your payment amount will be deducted the payment coupon. The correct address for courier or express mail is the Express Payments Address automatically each month on your due date from the bank account you select. shown below. . Pay by phone Servitor. You may use this service an time to make a payment by phone, if your Proper Form. For a payment sent by mail or courier to be in proper form, you must: account is eligible. You will be charged $14.95 to use this service if a representative of ours helps • Enclose a valid check or money order made payable to Hums Depot Credit Services. No cash, expedite your payment. Call by 5 p.m. Eastern time to have your payment credited as of that day and gift cards, or foreign currency please. I posted within ttiree business days. If you call after that time, your payment will be credited as of the • Include your name and account number on the front of your check or money order. next day and posted within three business days. We may process your payment electronically after If you send an elfaible cheek with this payment coup you authorize us to complete we verity your idenhry. your payment by electronic debit. It we do, the checking account will be debited in the • Express Payments. You can send payment by courier or express mail to the Express Payments amount on the check. We may do this as soon as the day we receive the chock. Alto, Address. This address is: Customer Service Cents Attenhon: Payment Mail Opening, 1500 the check will be destroyed. i Boitontieid St., Columbus, OH 43228. Payment must be received in proper form at the roper Copy Fee. We charge $5 for each copy of a billing statement that dates back 3 months or more. We address by 5 pm. Eastern time to b e credited as of that day. All payments received in proper form at add the fee to a balance of our choosing. We reserve the right to add this fee to balances subject to a the proper address after that time will be credited as of the next day. higher annul percentage rate. We waive the tee if your request for the copy relates to a billing error or . In-Stem Payments. For your added convenience, payments can be made at The Home Depot® disputed purchase. stores, with no service fee. Any payment In proper form accepted In -stare will be credited as of that day. However, credit availability may be subject to verification of funds. T02354- 9196 -0400-0005- E -9-X -- 08/01/08 -70- 192- P- E- 0- 7-8 -0- NOPLAY -TE -07 /13/12 -HAMB- November 7,2012-0-0 N -- HD/EX JUL12 Page 2 of 4 Account: * * ** * * ** * * ** 5813 TRANSACTIONS Trans Date Description Reference # Amount FEES 12/04 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 36.00 INTEREST CHARGED 12/07 INTEREST CHARGE ON PURCHASES $ 276.11 TOTAL INTEREST FOR THIS PERIOD $ 276.11 Total Fees Charged in 2012 $235.00 Total Interest Charged in 2012 $622.12 Original Previous Payments Billed New Promo Deferred Trans Trans Promotion and Interest Promotion Monthly Interest Expiration PROMOTIONS Amount Date Balance Credits Charges Balance Payment Charges Date NO INT FOR 6MOS -PMT REQ $66.99 06/11/12 $66.99 - $66.99 - $9.53 01/04/13 NO INT FOR 12MOS -PMT REQ $2,039.83 11/29/11 $428.80 - $223.20 $652.00 $208.91 exp'd12/05 /12 INTEREST CHARGE CALCULATION Your Annual Percent a Rate APR / is the annual Interest rate on your account ....,...,......_.... ... .. _... War• sw�• y.y..a..y._.a...y..:.s.. „:.._ I A x:.r�: '•rVt „ F�a�f” , . 1 W bAl .I, fit 6• -F J� _ i'. P PURCHASES Revolving Balance 26.99% M $2,385.32 $52.91 NO INT FOR 6MOS -PMT REQ 26.99% M NO INT FOR 12MOS -PMT REQ 26.99% M 644.58 $223.20 Page 3 of 4 Account: * * ** * * ** * * ** 5813 Page 4of4 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I .D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215 - 564 -1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION n VS. No. Iq TIFFANY J POMEROY 1422 3RD ST ENOLA PA 17025 Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above - captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. c rn Papers may be served at the address set forth below: rn Blatt, Hasenmiller, Leibsker & Moore, LLC -<> c 1835 Market Street, Suite 501 <t". ' Philadelphia, PA 19103 AC W _. Telephone Number: 1- 215 - 564 -1567 —t rr) Y� C -..,! BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: April 3, 2014 By: M cott Attorney Syretta Martin Attorney 2927694 PPTXPEAI (11/18/2013) IIIIIIII VIII IIII IIIIII II IIIIII VIII VIII VIII VIII VIII VIII IIII VIII IIII -SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 7LED-(fit=s (CE Sheriff ' THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor di Citlaterttz 28l1I MAY 13 PH 3: 05 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Tiffany Pomeroy Case Number 2014-2415 SHERIFF'S RETURN OF SERVICE 05/02/2014 07:51 PM - Deputy Jason Kinsler, 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: Tiffany Pomeroy at 1422 Third Street, East Pennsboro/W. Fairview, Enola, PA 17025. JASO KINSEE DEPUTY SHERIFF COST: $44.95 SO ANSWERS, May 06, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySuite Sheriff, "G!eosoft. Inc. Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D.4309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. 14-2415 TIFFANY J POMEROY rTi 1422 3RD ST � ~^' U>f~ " - ENOLA PA 17025 C)N: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT -w ' 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 TIFFANY J POMEROY in this matter in the amount of $3,162.13 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 05-23-14 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER KER & MOORE, LLC Dated: June 5, 2014 By: -Syretta Martin .� alio 2927694 ej ' - 1 PPTJPFJI IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII �-.��7c�sa � IIIIIIII (�l�.l�� PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA VS. TIFFANY J POMEROY CIVIL ACTION 1422 3RD ST No. ENOLA PA 17025 Defendant(s). No. 14-2415 TO: TIFFANY J POMEROY 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. PROTHONOTARY Dated: By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Syretta Martin, Esq. PA Bar#309370 Frank Janello, Esq. PA Bar#315643 Beth Arnold Howell, Esq. PA Bar#203606 Greg Dye, Esq. PA Bar#205316 Blatt, Hasenmiller, Leibsker& Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 2927694 PPTNDJNI (05/13/2014) 111111111111111111 VIII III 111111 VIII VIII VIII VIII VIII 11111 VIII 1111 IIII Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. 14-2415 TIFFANY J POMEROY 1422 3RD ST ENOLA PA 17025 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Cumberland: I, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant(s) is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. See Defendant(s) Military Status Report pursuant to 50 U.S.C. App. Section 521, 525 which was obtained from the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scrap. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILL , LEIBSKER & MOORE, LLC Dated: C r By: Syretta k4affin, Esq. PA Bar#309370 Frank Janello, Esq. PA Bar#315643 Beth Arnold Howell, Esq. PA Bar#203606 Greg Dye, Esq. PA Bar#205316 2927694 PPTJCAMI (06/02/2014) 1111111111111 111111 1111111111111111111111111111111111111111111111111111 IIII Depertment of Defense Manpower Data Center Results as of:Jun-20-2014 04:34:56 AM SCRA 3.0 Stan is Report Pursuant to SeMce memben Civil Relief Act, Last Name: POMEROY First Name: TIFFANY Middle Name: Active Duty Status As Of: Jun-20-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA N No ,, NA This response reflects the individuals'active duty'status based on the Active Duty Status Date It Left Adive Duty Within 367 Das of Active Duty Status Date AdNe Duty Start Date Adive Duty End Date Status Service Component NA NA - Z '`a 'No t. r NA This response reflects where the individual left active du status within 367 da remdin the Active Duty Status Date t ��c 1 The Member or HIstHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notili tion End Date Status Service Component NA r.NA '4 No NA a. 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. Y)W� 1� ' JM4.�A - 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: 4AT5S44C209B3E0 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS Vs. CUMBERLAND COUNTY, PA TIFFANY POMEROY CIVIL ACTION 1422 3RD ST ENOLA PA 17025 No. 14-2415 Defendant(s). TO:TIFFANY J POMEROY Date of Notice: May 23,2014 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 BLATT, HASENMILLE IBSKER &MOORE, LLC By: Syretta rtin, Esq. PA Bar#309370 Frank Janello, Esq. PA Bar#315643 Beth Arnold Howell, Esq. PA Bar#203606 Greg Dye, Esq. PA Bar#205316 Blatt, Hasenmiller, Leibsker&Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE:215-564-1567 FAX: 215-564-3818 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. 2927694 PPTNLRSI (05/13/2014) 1111111IIHill II11111111111111111111111111111111111IIII11111111