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Home My WebLink About14-3472 Supreme Court-of.Pennsylvania r CouW1468"T�Co'1!46n Pleas ��,,�� f .. ��" \;��' For Prothonotar'Use nly: I7AiE S`l'A1ll' CMI�C�OVeI'"�6, et Docket No: CUM BU Count Y The it formation collected on this fonn is used solely for court administration purposes. This fonn does not supplement or replace thefifing and service ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: E [N Complaint E] Writ of� ❑ Transfer from Another Jurisdiction El Petition C ❑Declaration of Taking ,I Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC FLOYD FRY I O Are money damages requested? N Yes ❑ No Dollar Amount Requested: X within arbitration('trots N (Check one) outside arbitration limits i AIs this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ®No I Name of Plainti®Appellanfs Attorney.Robert N.Polas,Jr./Carie 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 clai n, 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 ❑ 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 Liability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: U MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-DES [j Ejectment E]❑ Toxic Tort-Implant ectment Common Law/Statutory Arbitration ❑ Toxic Waste E] Eminent Domain/Condemriation 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: 15-62310 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 8 FAX:(757) 518-0860 0860 f Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. 1 Plaintiff, V. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty(20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 15-62310 (717) 249-3166 o-o /U W)7.:? This communication 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 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Demandado. NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demands y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO,VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN 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 15-62310 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar una 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 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD : NORFOLK, VA 23502 Plaintiff, No. V. : FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 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, FLOYD FRY, is an adult individual with last known address of 22 GETTYSBURG PIKE, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/CARE CREDIT on May 25, 2012 with account number ************2119 (hereafter referred to as "Account"). 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned.Account to which there was no bonafide objection by Defendant. 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 January 9, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ CARE CREDIT and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiff s 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$1,672.29. 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, FLOYD FRY, in the amount of$1,672.29, plus costs of this action and any other relief as the Court deems just and reasonable. Carrie A. Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15-62310 This conitnunication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Tiffany(ka 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: MAY 0 8 2014 By: Qft Cus o cords 15-62310 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. X IBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. /JORANt I / GE C 1t i Grp a BILL of SALE ... PRA PSCC Fresh-September.2013 . . For value received and in further consideration of the mutual covenants and conditions set forth in the. Forward Flow Receivables Purchase Agreement(the"Agreement"};dated as of this 9`h day of July, 201313y and between General Electric Capital Corporation;GE Capital Retail Bank,GEMB Lending,Inc.;Monogram Credit Services,LLC;RFS Holding,L.L.C.,and GEM'Holdiag,:L.L.C.(collectively"Seller")and Portfolio Recovery Associates,:LLC("Buyer"},Seller hereby transfers;sells,conveys,grants;and delivers to Buyer,its successors and assigns,without recourse except as set forth in the Agreement;to the extent of its ownership,the. Receivables as:set forth in the Notification Files(as defined in the:Agreement),delivered by Seller.to Buyer on September 19,2413,and as further described inahe.Agreement: GE Capital Retail Bank ... Mono ai P � grain Credit Services;L.L.C. . . By: � _ By Ken Wojcik U Attorney in F,-Wt Ken Wojcik77 Title: EVP Collections&Recovery - Z-1 Date: [0 3 Date: jp . . : : _. RFS H:glding, I;.L.0 . .. . General Electric Capital:Corporatron By: . . Attorney in F t Ken Wojcik BY Attorney in Fac en Wojcik Date: 1 b-Z- 4 Date: .. .. .... . .. GEM Holding,'L.L.G GEMB Lending;Inc. By.. . Attorney By. r in F Ken Wojcik .. f Attorney in F t Ken Wojcik Date: Date: Portfolio , o alio Recovery Associates LLC :Title: CARECREDITIGECRB CardholderName: Y Account Number-. 119 GE Capital Retail Bank Statement Closing Date: s Previous Balance $1,637.29 New Balance $0.00 + New Purchases $0.00 Total Minimum Payment Due $439.00 - Payments $0.00 Payment Due Date 08/09/2013 +/- Credits,Fees&Adjustments(net) $1,637.29- PAYMENT DUE BY 5 P.M.EASTERN ON THE DUE DATE. +/- Interest Char (net) $0.00 We may convert your payment into an electronic debit. See New Balance $0.00 reverse side. Credit Limit $7,000.00 Available Credit $0.00 Late Payment Warning: If we do not receive your Total Days in Billing Period '28 Minimum Payment Due by the Payment Due Date listed above, you may have to pay a laze fee up to$35.00. Pay online for free at:gogecapital.com For GE Capital Retail Bank customer service or to report your card lost or stolen,call 1-866-8937864. Best timers to call are Wednesday-Friday. ° �t�**'��+*4h�f�tttttttt+++t+tttttt++tttttttttt+t+tt#tt+t++Tttttt+ YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULL BY ITS EXPIRATION DATE TO AVOID PAYINGDEFERRED INTEREST CHARGES PLEASE SEETHE PROMOTIONAL PURCHASE SUMMARY SECTION ON TIES STATEMENT FOR FURTHER DETAILS YOU HAVE A PROMOTION(S)EXPIRINGON 12/10/13 AND 08/10/14. tttitttttttttt++++tt++ttttt+++++t+tt++t+++++t++t+tt+ Promotional Promotional Deferred Tran Date Description Initial Expiration Balance Interest Charge Purchase - Daze Amount 12/10/2013 $61000 $0.00 05/25'2012 Deferred Interest/No Interest If Paid In $931.00 Full 08/10/2014 $650.00 $0.00 01/11/2013 Deferred Interest/No Interest If Paid In $65000 Full A summary of your promotional pwchase is provided above. Any promotion maybe terminated if youraccount goes 60 days past due. If you have a DEFERRED INTEREST/NO INTEREST IFPAID IN FULL promotion:To avoid paying Deferred Interest Charges on these promotion(s),you must pay the entire applicable Promotional Balance by the Promotional Expiration Date. On a Fixed Payment(Extended.Payment Plan)promotional purchase,the Interest Charge is billedmonthly and included as part of the Minimum Payment due. To make more than one payment see Make Payment To address or pay online at gogecapital.com. ------------ !1M*+#+++* Tran Date Post Date Reference Number Description Amount . 08/07/2013 08/07/2013 F9072006VO0999990 CHARGE OFF ACCOUNT-PRINCIPALS $1,260.00 CR 08/07/2013 08/07/2013 F9072006VO09,99990 CHARGE OFF ACCOUNT-FINANCE $41229 CR CHARGES* FEES 08/02/2013 08/02/2013 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INTEREST CHARGED 08/07/2013 08/07/2013 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 ttttttttttt Total Fees Charged in 2013 $245.00 Total Interest Charged in 2013 $35.71 Total Interest Paid in 2013 $6.58 *NOTICE:See reverse side and additional pages(if any)for important information concerning your account. - 5302 DF9 1 3 7 130807 ZD PAGE t of 3 9072 3200 X938 OIEJ5302 fP�aay�online at gogecapital.coom or enclose this coupon with your check.Please use blue or black ink. "'Q1`�°' "" `" ` - 31'1+ r*ttWP4rt rt + + +#+ rt#rt +# t+t+ Payment Enclosed: $ .... . .. . New address ore-mail? Payment due includes$0.00 past due.Please pay the past due amount PROMPTLY. Check the box at left and print changes on back If you only pay the Taal Minimum Due it may not pay off the Promotional Purchase by the Expiration Date. FLOYD FRY OTTFFFTFI'FFTAAFDDTFTDDDADFFDFTFAFFFFFATTAAFTFFTFATA FDA DTAFDDTFTTD 22 GETTYSBURG PIKE MECHANIGSBURGPA 17055-5601 Make Paymentto: GE CAPITAL RETAIL BANK PO BOX 960061 _ ORLANDO,FL 32896-0061 TADFAAFFAFAATTFAFDTAFDFFDDDTFTTFATDADTTTDFAFFFFFDFAAADFTFFDDDTTTA M2119 Customer Service/Questions:For account information,please call the toll free number on the front of this statement.Unless your name is listed on this statement,your access to information on the account may be li mited.You may also mail questions (but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account number on any correspondence you send to us. Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www. gogecapital.com. Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekiva Springs Road,Longwood,FL 32779. Notice:See belowforyour Billing Rights and other important information.Telephoning about billing errors will not preserve your rights underfederal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando, FL 32896-5035. Purchases,returns and payments made just prior to billing date may not appear until next month's statement.When you provide a check as payment,you authorize us either to use information from your check to make a one-time electronic fund transfer from your account ortoprocessthe payment asacheck transaction.When we use information from your check to make an electronic fund transfer,funds maybe withdrawn fromyour account as soon as the some day we receive your payment and you will not receive your check back from your financial institution.You may choose not to have your payment collected electronically by sending your payment(with the remittance coupon),In your own envelope-not the enclosed -remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address. What To Do If You Think You Find A Mistake On Your Statement: Ifyou think there is an error on your statement,write to us at GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035. In your letter give us the following information: •Account information:Your name and account number •Dollar amount:The dollar amount of the suspected error •Description of problem:If you think there is an error on your bill,describe what you believe is wrong and why you be- lieve it Is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing.You may call us,but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error.the following are true: •We cannot try to collect the amount in question or report you as delinquent on that amount. •The charge in question may remain on your statement and we may continue to charge you interest on that amount. But,if we determine that we made a mistake,you will not have to pay the amount in question or any interest or other fees related to that amount. •While you do not have to pay the amount in question,you are responsible for the remainder of your balance. •We can apply any unpaid amount against your credit limit. Information About Payments:You may at any time pay,in whole or in part,the total unpaid balance without any additional - charge for prepayment. Payments received after 5:00 PM(ETI on any day will be credited as of the next day.Credit to your account may be delayed up to five days if payment lal is not received at the pa ment address,Ib)is not made in U.S.dollars drawn on a U.S.financial institution located in the U.S.,(c)is not accompanied by the remittance coupon attached to your statement.Id)conta ins more than one payment or remittance coupon,(e)is not received in the remittance envelope provided or If)includes staples,paper clips,tope,a folded check or correspondence of any type.Conditional Payments:All written communications concerning disputed amounts,including any check or other payment instrument that(i)indicates thatthe payment constitutes'payment in full"or is tendered as full satisfaction of a disputed amount,or(ii)is tendered with other conditions or limitations 1"Disputed Payments"1,must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896.5035. Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits will be applied to your previous balance immediately upon receipt,but will not satisfy any required payment that may be due. Credit Reports and Account Information:Ifyou believe that we may have reported inaccurate information about you to a- consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the inaccurate information and tell us whyyou believe it is incorrect.Ifyou have a copy of the credit reportthat includes the inac- curate information,please include a copy of that report.We may report information aboutyour accountto credit bureaus. Late payments,missed payments,or other defaults on your account may be reflected in your credit report. Haw We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily bal- ance"of your account for each day in the billing cycle.We then add the interest to the daily balance. To get the"daily bal- once"we take the beginning balance of your account each day(which includes unpaid interest),add any new charges,and applicable fees,and subtractany payments orcredits.This gives us the daily balance.Any daily balance of less than zero will be treated as zero.A separate daily balance will be calculated for each balance type on your account.The balances)shown in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by the number of days in the billing cycle. Bankruptcy Notice:If ou file bankruptcy you must send us notice,including account number and all information related to the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell,GA 30076. Your account is owned and serviced by GE Capital Retail Bank. Hearing Impaired:TDD users call 1-877-448-8512 Use of Information About You and Your Account Our Privacy Policy describes our collection and disclosure of information aboutyou and your Account.Ifyou would like another copy ofthe Privacy Policy,please call us at the customer service tele- phone number indicated on the front ofthis statement. This is an attempt to collect a debt and any information obtained will be used for that purpose. OlEJ5302-12-03/05/12 By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of your account contacting you about your account,including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system and/or an artificial or rerecorded voice when contact- ing you,even ifyou are charged for the call under your phone plan. For changes of address or phone number,please check the box and print the changes below. Retail EN-OlEJ5302 Name ❑ Street Address city State Zip Code Home Phone# Business Phone# Cell#or other phone#we can use to contact you Email Address Remember,you can update the above information as well as your e-mail address online at www.gagecapital.com Cardholder Name: FLOYDFRY Account Number�119 - Statement Closing Date:O8/07/2013 t1Ult t:lRtlltlbRttttttttttF+ttttttttttttttttttttt+ttttttt+ttt+tttttttt Expiration Date Annual Balance Subject to Interest Charge Type of Balance Percentage Interest Rate Rate(APR) Purchases NA 26.99% $0.00 $0.00 Deferredlnterest/No Interest If Paid In Full 12/10'2013 26.99% $0.00 $0.00 Deferred Interest/No Interest lfPaid In Full 08110'2014 26.99% $0.00 $0.00 t+t++tttttttttttt+t+ttttttt+t+ttttttt+t+t+ttttttt++t - In order to protect your account privacy,we are unable to provide account information to anyone other than the cardholder(s)or an authorized party.If you wish to permit us to speak to an authorized party such as a spouse about your account,please send written authorization to the General Inquiries address 5302 DFR 1 3 7 130807 ZD PAGE 2 of 3 9072 3200 XB38 OlEJ5302 l 5302 DFH 1 3 7 130807 ZD PAGE 3 of 3 9072 3200 XB38 OIEJ5302 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of Cmo, Jody S Smithy �: , » al 20 \-11 Chief Deputyvv3 Richard W Stewarts 13 �� 11� Solicitor '` ` ' Portfolio Recorvery Associates, LLC Case Number vs. 2014-3472 Floyd Fry SHERIFF'S RETURN OF SERVICE 06/12/2014 04:36 PM- Deputy Amanda Ebersole, being duly sworn according to law, served the requested Complaint&Notice by handing a true copy to a person representing themselves to be Patsy Fry,wife, who accepted as"Adult Person in Charge"for Floyd Fry at 22 Gettysburg Pike, Upper Allen Township, Mechanicsburg, PA 17055. ,5AxThipsirke„,4-0 041_, AMANDA EBERSOLE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, June 13, 2014 RONR 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. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Defendant Date: 04 lUf 15-62310 No. 14-3472 PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf Counsel o ecord tiff this Party 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 .fin.. sold._. A-Ety eKlt ssgrL� jtAk31os8� A1oi�i�- rtai This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Defendant No. 14-3472 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, FLOYD FRY, for failure to answer the Complaint. (X) Amount Due $1,672.29 Less Credits $.00 TOTAL $1,672.29 (Xj (X (X 15-62310 I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. Pursuant to PARC.P.237 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her attorney of record. Pursuant to PARC.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the .., aunt whom judgment is e • - entered and to his/her attorney of record, if r the default occurred a' • . -ast ten days • .. .f n• r'at - • ed. prior to the date of the filing oft4110/.: praecis obert N. Polas, Jr., Esquire, # 201259 Carrie A Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from. a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. 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 FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. FLOYD FRY 14-3472 Dear FLOYD FRY: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-62310 Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Attorney ID #201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 14-3472 v. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Defendant TO: FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 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. 15-62310 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 111E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff V. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 Defendant No. 14-3472 AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for Plaintiff, herein affirms under the penalties of perjury that I am the attorney for the Plaintiff in the above -captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 and is not in the military service of the United States or its Allies, otf-rwise within the provisi the Service Members Civil Relief Act and its Amendments. 15-62310 Obert N. Polas, Jr., Esquire, #201259 Carrie A Brown, Esquire, #94055 Mark R. Garvey, Esquire, #312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) (866) 428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Department of Defense Manpower Data Center Status Report Pursuant to Servicernem%rs Civil Relief Act Last Name: FRY First Name: FLOYD Middle Name: Active Duty Status As Of: Aug -13-2014 Results as of : Aug -13-2014 03:47:10 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 367 days preceding the Active Duty Status Date The Member or HisiHer 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. r�- 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: PCBOU26790D9B00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 14-3472 v. FLOYD FRY 22 GETTYSBURG PIKE MECHANICSBURG PA 17055 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 $1,672.29. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. If you have any questions regarding this Noti 15-62310 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 :fiom a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose.