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Home My WebLink About14-3269 Supreme Court of Pennsylvania COur,6 t=4 ComlNion Pleas For Use Only: TIML S"TAM P / r � rY y� Civ4Cove�,Sh+eet Docket No: County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. S Commencement of Action: E M Complaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T, PORTFOLIO RECOVERY ASSOCIATES,LLC ALAN E BOTH I O Are money damages requested? S Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A Is this a Class Action Suit? ❑ Yes S No Is this an MDJAppeal? ❑Yes S No 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 Se]Litigant) i 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 Mars 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 S ❑ Product Lability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toiac Tort-DES B F-1 Toadc Tort-Ii�ilant E] Ejectment E] Common Law/Statutory Arbitration F-1 To)ac Waste E] Erninent Domain/Condemnation El Declaratory Judgment ❑ Other: El Ground Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 15-76009 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 " F! Portfolio Recovery Associates LLC {'r r, 'r`..i•0 Q 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX:(757) 518-0860 Cv Ri��` ; Cil"JPdTY LV Attorneys for Plaintiff ` S�' ' � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Cf\,TL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. 14- ��rq 011 i Meryw Plaintiff, V. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Defendant. NOTICE .You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty(20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association Q 32 South Bedford Street Carlisle, PA 17013 103'?� Pp A (717)249-3166 15-76009 This comnamication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX:(757) 518-0860 Attorneys for Plaintiff IN TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Demandado. NOTICIA LISTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta ]a 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 LAMIVIE POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 15-76009 Esta conanicacion es de un cobrador de deudas y es un intent do cobras Uru deuda. Cualquier infromacion 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 TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC- 120 LC120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, ALAN E ROTR is an adult individual with last known address of 8 RAILROAD AVE APT 4, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to HSBC BANKNEVADA, N.A /CAPITAL ONE, N.A. /UNION PRIVILEGE on October 24, 2006 with account number ************4220 (hereafter referred to as "Account"). 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. ` 1iis coin-nuiication is firo3n a debt collector and .is an attempt to collect a debt. Any information obtained will be rased for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was.no bonafide objection by Defendant. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A" 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on September 15, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA, N.A. / CAPITAL ONE, N.A. /UNION PRIVILEGE 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$1,400.89. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, ALAN E ROTH, in the amount of$1,400.89, plus costs action and any other relief as the Court deems just and reasonk02 Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259. Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 15-76009 This communication is fi-orn a debt collector and .is an.attempt to collect a debt. Any infortintion obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Anila Bray 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: APR 2 9 2014 By: Anita Bray Custodian of Records 15-76009 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. This comnnuiication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. I l�li : .it 1 , . .: . :. Forward'Flow:Receivable:Sale'A ent dated : greem'.... ,.. 01/1;0120.13:.' : .: BILLO1F SALE ... . . .' .... osing:Date:03/1512013 : -- Capital-One; rational".Association:(".Mke?); in consideration of.a Purchase mice :of ' aad o err va a consideration; the:�eoeipt of which-is'16reby. acknowledged;: :: .:: : :. hereb' sells asci s and transfers at ri ..y . gn ..... ght;title and interest.in:the Accounts identified in the& : File enti#led` -- which trig be.:in..electronic. forin to-.Portfolio. .: : Recovery. Associates;. LLC'-aiid. its iffi atei'.-and its 'subsidiary-':entities::(°°Btu ier"� without recourseorreiiresentatibi ex&Tt.as.expressly-prnvided'herein'or:onthe terms;:and'subject'to:the' ,. .. ... coiidit. .... et forth in the greement-(as:defined below):. 'This.Bill.of Salee'is'dd1ivered;.pursuant'to . that certai Forward Flow R....: , abl Sal : .. n.. . . a ..: ' "'Agreement,:dated.as:of'0.1/10/2013,':by.a44;betvveen Seller:and:Buyer.(the:"Agteehient"):..All . ... capitalized-terms:used;-but not defined; in-this.Bill of Sale'shall.have' .the meanings assigned�to - .'such terms:iti-the'A . : •' :: : :: : -..-.The Cutoih:Date-for the'Sale Filemas.03/12/2013. Thera' g. ate Un aid Balance of'the Accounts.asof the Ciiteff'Date was p C I'�'AL ONE;NATIONAL ASSOCIATION.: : :. : .. . :. Name:Joliii:H''lVSaurer,..�. . . .. . .. . . . . .Title::Vice President'... . . .. . . ... : Exhibit 2 . Forward.Flow Receivable Sale Agreement dated 01A 0/2- 0i, '. . . BILL OF SAi,E :. Closing Dater 0A 5J20.13 .. ; Capital One Bank'(USA),'National Association.("Seller"},.in:ca'nsideraiion-ofa' 'Purchase:'. Price :of' :other:'valuable--cozisideratiou- -the.-receipt:�:of-which• is::.hereby ac�owled ' ged, bereliy:sells,. assigns and ixansfers all.right;: tttle: d interest in the:Account§: :. identified in the-Sate.,File: entitled _ _ (which inay be.iii electronic .: foixn}: fo :Portfolio Recovery :Associates; :LI,C .and :its:affiliates 'arid'-its.•subsidiary ;entities:. (`Buyer'),. without rec6uise. oir:representation-except as:expressly:pzovided:.herein::ox terms ect to the conditions,and sub' set forth.in th . J ,. a.Agreerneiit(as defined below). This-Bill-.ofSale.:is'.delivered:puisitaiif to that;certain Forivarii:.Elaw Receivable:Sale :- -o . . .... .. .. . :Agreement;:dated:as of.411101.2013, liy and between Seller:and Bii er the "A :. y .. . . greement ). All: capitalized.terms used,:but:not defin � -:iu this.Bill of Sale shalt have the.meanin �, g's assigned to::: such:terms:in.the-Agrement. . ' -The:Cutoff'Date for the gale' File:was 03/12%2013: The:aggregate:Vnpaid;Balance of the Accounts:as of the Cutoff Date was ...:CAPTTALONE:BAN.K(USA:);.NATI4NAL : . :.. :. A55t3CIATIO�T ��' .. .. ... .. . . .. . . .. . . .. .. .....'... ... . . .- : �Name-John H. Maurer . . vice President.:- . hLEU l KIUAL W VKKLKa MAJ l hK(-AKL) ALAN E ROTH c ELECTRICAL WORK Account Numbc 220 Page 1 of 2 From January 13,201 to c ruary ,,2013 S "o6lCczotirtt Activity Psymert 1 oir Previous Balance $1,345.04 New Balance $1,400.89 Payments - $0.00 Minimum Payment Due 5495.00 Other Credits - $0.00 Payment Due Date March 7,2013 Purchases/Dcbits + $0.00 Balance Transfers + $0.00 Late Payment Warning: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 APRs Past Due Amount $425.00 may be increased to the Penalty APR of 24.99%. Fees Charged + $35.00 Interest Charged + $20.85 New Balance $1,400.89 Minimum Payment Warning:If you make only the minimum payment each period,you will pay more in interest and it will take you longer to payoff your Credit Limit $1,000.00 balance.For example: Credit Available $0.00 Cash Advance Limit t $250.00 Cash Advance Available $0.00 If you make no additional You will pay off the And you wil I end up paying Statement Closing Date February 10,2013 charges using this card balance shown on an estimated total of.. Days in Billing Cycle 28 and each month you this.statement in tCash Advance Limit is a portion of Total Credit Limit. pay... about... Only the minimum 9 Years $2,339 Payment 552 3 Years $1,874 (Savings=$465) If you would like information about credit counseling services call 1-866-569-2227. Questions? Payment Address:UNION PLUS Credit Card,PO Box 71104,Charlotte,NC 24-Hour Customer Service 1-800-622-2580 28272-1104 Lost or Stolen Card 1-800.651-5116 Billing Inquiries:UNION PLUS Credit Card,PO Box 80027,Salinas,CA Outside USA Collect 1-702-243-1575 93912-0027 TDD/Hearing Impaired 1-800-395-9020 Manage Your account online at www.unionpluscard.com i I 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. As a reminder,you may pay your credit card bill online or through our automated phone system for no fee. Trans Date Post Date Description of Transaction or Credit Purchase Type Reference Number Amount F Trans Date Post Date Description of Fees Reference Number Amount 02/07/13 02/07/13 LATE CHARGE ASSESSMENT 10000030000207999962790 $35.00 Total Fees for This Period $35.00 U I Description of Interest Charge Amount INTEREST CHARGE ON CASH ADVANCES $0.00 INTEREST CHARGE ON PURC14ASES $20.85 INTEREST CHARGF ON BALANCE $0.00 TRANSFERS Total Interest For This Period $20.85 Detmh and reavn boaom portion with ymn payment 01010351 12 0000003000 STMT57 D 6 UNKA 811XXXXf tEMBXX'X.X 17840 M See reverse side for important information ----------------------------------------------------------------------------------------------------------------------------------------- oAccount Number. -4220 y+ m New Balance $1,400.89 �c Minimum Payment Due $495.00 Payment Due Date 03/07/2013 Include account number on check to UNION PLUS Credit Card. Do not send cash. Please send your payment 7 to 10 days prior to the payment due date to ensure timely delivery. 010 AMOUNT ENCLOSED UNION PLUS CREDIT CARD ALAN E ROTH PO BOX 71104 8 RAILROAD AVE CHARLOTTE NC 28272-1104 SHIREMANSTOWN PA 17011-6348 tll�l�llll��llllll��lll��ll�lll��lll��l�lllll�l�l�l�l��l�l�l� ELEU l XIUAL W VKKtKJ MAJ L tsKUAKLJ ALAN E ROTH � ELECTRICAL WORKERS MasterCard Account Account Number 220 Page 2 of 2 From January 13 2013 013 • 2ob Totals Y'art Rafe Total fees charged in 2013 S70.00 Total interest charged in 2013 543.03 I'Ker"� urge Cat¢ul�a>f�oir Your Annual Percentage Rate(APR)is the annual interest rate on your account. i i Type of Balance Annual Percentage Rate(APR) Balance Subject to Interest Rate Interest Charge PURCHASES 00001 19.99%(v) $1,360.02 $20.85 CASH ADVANCES 80001 23.99%(v) $0.00 50.00 BALANCE TRANSFER 19.99%(v) $0.00 $0.00 71111 v=17arfable Rale t:�tsto 'r N' Avoid being a victim of identity theft.Manage your account online and enroll in paperless statements.Sign Up at unionpluscard.comlregister Custlijrier Netais Whether you're 18 or 60,there are steps you can take to plan for your retirement...starting today!Visit the Union Plus Retirement Planning Center at UnionPlusRetirement.org to Team about planning for retirement and how to manage your money and lifestyle afterwards.Plus get the latest information on social security and pensions and other retirement topics.Offered through Union Privilege. 6u r►dews The Union Plus Moving Van Discount offers savings on interstate moving,packing and in-transit storage from two of the most trusted names in moving—Allied and North American Van Lines.Plus,get increased insurance coverage;waiver of increased summer rates;and on-time delivery guarantee.Visit UnionPlus.org/Moving or call 1-800-871-8864(Allied Van Lines)and 1-800-524-5533(North American Van Lines)and reference"Union Plus"to use the discount.Offered through Union Privilege. 01010351 12 0000003000 STMT57 D 6 UNPIAOBHXXXXMEMHXCXX 17840 UPI __________________________________________________________________________________________________________________________________________ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF TRE THE PR O T HONO_. 14JUN 13 PH 2: 51 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Alan E Roth Case Number 2014-3269 SHERIFF'S RETURN OF SERVICE 05/30/2014 09:27 AM - Deputy Jeff Kolodzi, 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: Alan E Roth at 8 Railroad Ave Apt. 4, Shiremanstown, Camp Hill, PA 17011. ODZI, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, June 04, 2014 (c) CountySutte Sheriff, Teleosof, lrc RONRR 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. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 eq M 15-76009 No. 14-3269 PRAECIPE FOR DEFAULT Defendant JUDGMENT Filed on Beha Counsel • f Plaintiff rd for this Party 2 • 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 L.' ii fit... so -AL A -14y ssei`7 Rte. 3/os-co /llo�rcE. � �'�� This communication is from. a debt collector is an attempt to collect a debt, Any information obtained will be used tib 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. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Defendant No. 14-3269 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, ALAN E ROTH, for failure to answer the Complaint. (X) Amount Due $1,400.89 Less Credits $.00. TOTAL $1,400.89 (X) 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. (X) Pursuant to PAR C.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. (X) 15-76009 Pursuant to PARC.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is be entered and to his/her attorney of record, if a . ' er the default occurred. • east ten days prior to the date of the filing of th.: pra- i. - and a copy oft - j u ,ched. //'/ 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 con]munication. is from a debt collector is an. attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) July 23, 2014 ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. ALAN E ROTH 14-3269 Dear ALAN E ROTH: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-76009 Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Attorney ID #201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION — LA W PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Plaintiff No. 14-3269 Defendant TO: ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 DATE OF NOTICE: July 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. 15-76009 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Robert N. Polas, Jr., Esquire Carrie A Brown, Esquire Mark R Garvey, Esquire Attorney ID #201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff V. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Defendant No. 14-3269 AIIIIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for Plaintiff, herein affirms under the penalties of perjury that I am the attorney for the Plaintiff in the above -captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 and is not in the military service of the United States or its Allies •r ot rwise within the provis. the Service Members Civil Relief Act and its Amendments. 15-76009 ert 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 Status Report Pursuant to Servicernembers Civil Relief Act Last Name: ROTH First Name: ALAN Middle Name: E Active Duty Status As Of: Aug -13-2014 Results as of : Aug -13-2014 04:02:23 PM SCRA 3.0 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 Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA : -NA - - •- No NA This response reflects where the individual left active duty status within' 36i 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 acti 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: NC98L25700DBNBO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. ALAN E ROTH 8 RAILROAD AVE APT 4 CAMP HILL PA 17011 Plaintiff No. 14-3269 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above -captioned matter has been entered against you in the amount of $1,400.89. (X) A copy of all documents filed with the Prothonotary in support of the within ' dgment is/are attached. `� If you have any questions regarding this Not' 15-76009 o.ert 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 Ibr that purpose.