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HomeMy WebLinkAbout14-2710 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only., Civil Cover Sheet Docket No: Cumberland County `7 Jv 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 bylaw or rules of court. Commencement of Action: Rl Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking SLead Plaintiff's Name: Lead Defendant's Name: JENNIFER A FREEDMAN C PORTFOLIO RECOVERY ASSOCIATES LLC T Dollar Amount Requested: ® within arbitration limits I Are money damages requested? ® Yes❑ N (Check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No FIs this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: 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 'K 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 C3 Product Liability (does not include E ❑Employment Dispute: mass tort) C ❑ Slander/LibeUDefamation Discrimination T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board 1 ❑ Other: U N MASS TORT ❑ Other: ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/20 2837166 PPTXSCPI (1/15/2014) Rim" aihakar_R_M/lore, LLC Attorney for Plaintiff, _ 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. a 71 JENNIFER A FREEDMAN 4 E WOODLAND DR �j, ; MECHANICSBURG PA 17055 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 800-990-9108 o 2837166 PPTCPADI (03/04/2014) /�,yL �b S �?S C) 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(alta 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 5yretta 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. JENNIFER A FREEDMAN 4 E WOODLAND DR MECHANICSBURG PA 17055 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), JENNIFER A FREEDMAN , 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 Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $866.80. 4. Plaintiff is the successor in interest of said account from CAPITAL ONE, N.A. HHB/US WEST having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendants)to be in default and demands payment of the balance. 2837166 PPTCDBCI (04/02/2014) I IIIIIIII VIII IIII IIIIII II IIIIII VIII VIII VIII VIII VIII VIII IIIIIII II IIII WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), JENNIFER A FREEDMAN in the amount of$866.80, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One of its At neys Syretta Martin Attorney w. #3uv370 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: 2-- Verification 1, Joann F. Cuffee , 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 12 2014 0 . Cuffee Sig to 2837166 PPTXVRII (01/14/2014) 1111111111111111111111111111111111111111111111111111111111111 IN Exhibit " A" PPTXEXAI Orchard AMF VISA GOLD JENNIFER A FREEDMAN V Orchard AMF V isa Gold Account Statement ` Attount Number-7668 Page 1 of 2 From Apri16 2012 to May 7,2012 Previous Balance New Balance $866.80 Payments Minimum Payment Due $ 189.00 Other Credits Payment Due Date June 1,2012 Purchases/Debits 7+ . 7so.00 Balance Transfers + $0.00 Late Payment Waning:If we do not receive your minimum payment by the Cash Advances + $0.00 date listed above,you may have to pay a late fee of up to $35.00 and your Past Due Amount $164.00 APRs may be increased to the Penalty APR of 29.99%. Fees Charged + $0.00 Interest Charged + $9.44 Minimum Payment Warning:If you make only the minimum payment each New Balance $866.80 period,you will pay more in interest and it will take you longer to pay off your balance.For example: Credit Limit $700.00, Credit Available $0.00 Cash Limit t $175.00 if you make no additional You will pay off the And you will end up paying charges using this card balance shown on an estimated total of.. Cash Available 50,00 May 7 2012 and each month you this statement in Statement Closing Date y about... Days in Billing Cycle 31 pay... tCash Limit is a portion of Total Credit Limit. Only the minimum 5 Years $1,138 Payment —,i $29�V J 3 Years $1,050 (&tongs=$88) if you would like information about credit counseling services call 1-866-569-2227. - Questions? Payment Address:Orchard Bank,PO Box 17051,Baltimore,MD 21297 -1051 24-Hour Customer Service 1-800477-1024 Billing Inquiries:HSBC Card Services,PO Box 81622,Salinas,CA Lost or Stolen Card 1-800-395-7555 93912-1622 Outside USA Collect 1-757-523-3880 Manage Your account online at www.orchardbank.com TDD/Hearing Impaired 1-800-395-9020 The HEXAGON DESIGN®(AND VARIATIONS),HSBC®,THE WORLD'S LOCAL BANK®,HOUSEHOLD®(AND DESIGN)and HOUSEHOLD BANK®° are registered trademarks of HSBC Holdings plc or HSBC Finance Corporation and are used by Capital One by permission.Capital One Is the Issuer of this account. Any references to"Cash Limit","Cash Available","Cash"credit plans,or"Cash Fee Finance Charge"transactions that may appear on this statement refer to the Cash Advance feature of your account. As a reminder,you may Pay your credit card bill online or through our automated phone system for no fee. Your account is over the credit limit.Please pay your total due of$191.80,which includes any additional over due credit limit annOmH and your Minimuu Payment Due,minus any Past Due amount. ji =TransDatoPost Date Description of Fees Reference Number Amount $0.00 Total Fees For This Period Amount Description of Interest Charge INTEREST CHARGE ON CASH ADVANCES $0.00 $9.44 INTEREST CHARGE ON PURCHASES INTEREST CHARGE ON BALANCE $0.00 TRANSFERS . $9.44 Total interest For This Period Ntmh and tet=bet o u porbm with y=pay—,t. Oam52 41 06 Oaooaoa331 STbM6 D H BOAS 2817 MM I See reverse side for Important Infortnaiion ------------------- -------_-------------------------------------------------------------- _ _ _ Account Number: 7668 ORC aRD&NK New Balance $866.80 Minimum Payment Due $189.00 Payment Due Date 06/01/2012 �• include account number on check to Orchard Bank.Do not send cash.Please send your payment 7 to 10 days prior to the payment due date to ensure timely delivery. 080 AMOUNT ENCLOSED Orchard Bank JENNIFER A FREEDMAN PO BOX 17051 4 E WOODLAND DR BALTIMORE MD 21297-1051 MECHANICSBURG PA 170553370 IIIIIIIIIIIIIIIIIIIIIIIIIIIII�IIIIIIIIIIIIIIIIPIIIIIIIIIIIIIIIII 66� r - Orchard AMF VISA GOLD JENNIFER A FREEDMAN =VISA Orchard AMF Visa Gold Account Statement Account Numba�7668 Page 2 of 2 From April 6,2012 to May 7,2012 Total fees charged in 2012 $45.91 Total interest charged in 2012 $38.93 Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type of Balance Annual Percentage Rate(APR) Balance Subject to Interest Rate Interest Charge PURCHASES 00001 12.90%(v) $861.85 $9.44 CASH ADVANCES 80001 28.99°.6(v) $0.00 $0.00 BALANCE TRANSFER 12.90%(v) $0.00 50.00 71111 v=Variable Rate osw5241 06 0000000331 OMr36 D HBOACNFHFXXX WQKXM 7817 MNN1 Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, �1 rl y 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 CUMBERLAND COUNTY, PA Philadelphia, PA 19103 �-,- Plaintiff, CIVIL ACTION � ,� ..f•; vs. u a� ( � I 1 r (/ JENNIFER A FREEDMAN . 4 E WOODLAND DR MECHANICSBURG PA 17055 © 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. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker&Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENIBSKER & MOORE, LLC Dated: April 16, 2014 By'- sy a Martin Attorney 2837166 PPTXPEAI (11/18/2013) IIIIIIIIIIIIIIIIIIIIIIIIIIIIIII I IIIIIII I VIII IIII IIIIII II IIIIII VIII VIII II Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oi c1 2214 MAY 28 PH 2: 5 7_.‘ CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Jennifer A Freedman Case Number 2014-2710 SHERIFF'S RETURN OF SERVICE 05/19/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Ashley Freedman, Daughter, who accepted as "Adult Person in Charge" for Jennifer A Freedman at 4 Woodland Drive, Mechanicsburg Borough, Mechanicsburg, PA 17055. Lo DAWN KELL, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, May 20, 2014 ((;) CourdySuil.e. -1",ieosoFt. RONNY R ANDERSON, SHERIFF Blatt, Hasenmiller. Leihnkar x. nn.,.,.4LLC Attorney for Plaintiff, 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 ACTIONcn _ vs. c No. 14-2710 CIVIL ae_ JENNIFER A FREEDMAN 313E MAIN ST MECHANICSBURG PA 17055 - Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant JENNIFER A FREEDMAN in this matter in the amount of $866.80 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 06-13-14 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMIL EIBSKER & MOORE, LLC Dated: June 26, 2014 By: Syretta Martin 2837166 ALA/1y PPTJPFJI C Kms` / i9/ I1111111111111liii11111III 111111 11111 11111 11111 11111 11111 11111 1111 1 1 111 1111 X2 . .308`'7 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. 14-2710 CIVIL JENNIFER A FREEDMAN 313 E MAIN ST MECHANICSBURG PA 17055 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/scra/). I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILL -, L- =SKER & MOORE, LLC Dated: By: Syretta M-I '., sq. PA Bar#309370 Frank Janello, Esq. PA Bar#315643 Beth Arnold Howell, Esq. PA Bar#203606 Greg Dye, Esq. PA Bar#205316 2837166 PPTJCAMI (06/02/2014) 11111111111011111111111111111111111111111111111111113111111111 Department of Defense Manpower Data Center Results as of:Jul-11-201409:11:19 AM SCRA 3.0 4 g?' tai .y status 1 . tart Pursuant to Servicemombers Civil Relief Act Last Name: FREEDMAN First Name: JENNIFER Middle Name: Active Duty Status As Of: Jul-11-2014 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'activeduty 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 theindividual 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 notificationto 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. f s 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: GB531165U06CT10 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY, PA JENNIFER A FREEDMAN CIVIL ACTION 4 E WOODLAND DR MECHANICSBURG PA 17055 No. 14-2710 CIVIL Defendant(s). TO: JENNIFER A FREEDMAN Date of Notice: June 13)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, HASENMILL - EIBSKER &MOORE, LLC By: Syrett• artin, 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. 2837166 PPTNLRSI (05/13/2014) 111111111111111111111111111111111111111111111311113 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA VS. JENNIFER A FREEDMAN CIVIL ACTION 313 E MAIN ST No. MECHANICSBURG PA 17055 Defendant(s). No. 1 4-271 0 CIVIL TO: JENNIFER A FREEDMAN 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: 7//$/iy By: w 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 1 91 03 TELE: 215-564-1567 FAX: 215-564-3818 2837166 PPTNDJNI (05/13/2014) 11111111111111 I I I 111111 I I 1111111111111111111111111111111111111 I I I 111 I I 11111