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Home My WebLink About14-3489 Supreme Court,of Pennsylvania Nz Courts f Com' on Pleas f. ,r 'F;v For Prothonotary Use Only. T7MFSTAAiP CMI §Ove)SWeet Docket No: 1".!r . CUMBE --Count Y The information collected on this forni is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a er s as required by law or rules of court. S j Commencement of Action: E IN Complaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Nacre: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES,LLC TRACYMARTINI I O Are money damages requested? ® Yes ❑ No Dollar Arnount Requested: X within arbitration limits N I (Check one) outside arbitration limits A Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ®No Name of PlaintifDAppellanfs Attorney.Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) A 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 ❑ 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) ❑ E,rrployment Dispute: ❑ Slander/LbellDefamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: 0 MASS TORT N El Asbestos ❑ Tobacco F-1 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS Bi ❑ Toxic Tort-Implant ❑ Ejectment E] Common Law/Statutory Arbitration ❑ Toxic Waste E] Eminent Domain/Condemnation ElDeclaratory Judgment ❑ Other: ❑ Found Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Corrinercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 15-62964 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 n / FAX: (757) 518-0860 � Attorneys for Plaintiff yt✓f!/00 zz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC ' 120 CORPORATE BLVD No NORFOLK, VA 23502 P laintiff, V. TRACY MARTINI 57WIST CARLISLE PA 17013 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 (717)249-3166 014+ 15-62964 1 10 3. 7S�d Q� 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. TRACY MARTINI 57WIST CARLISLE PA 17013 , 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) dial despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN. ABOGADO,VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN 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 15-62964 Esta coniwlicacion 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. TRACY MARTINI 57WIST CARLISLE PA 17013 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, TRACY MARTINI, is an adult individual with last known address of 57 W I ST, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/WAL-MART on April 26, 2010 with account number ************7867 (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 con-ununication 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 July 16, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ WAL-MART 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$1,675.67. 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, TRACY MARTINI , in the amount of$1,675.67, 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 15-62964 This com nuni.cation is from a debt collector and is an attempt to collect a debt. Any i.nfor.mation obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, TAY 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 08 2014 By: Tiffany O iffw I cords 15-62964 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. 1 . QZ90 GE Capita! PRA PLCC Fresh—March 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 13`s day of December, 2012 by and between General Electric Capital Corporation,GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on March 26,2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. Glenn Marino Glenn Marino Title:EVP Title:President Date: `Y -�J l 3 Date: General Electric Capital Corporation RFS Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Title: Vice P esident Title:CFO Date: w Date: GEMB Lending,Inc. GEM Holding,L.L.0 By: By: Stephen Matta Joseph Ressa Title:Director Title: CFO Date: Date.• Flo 1 GF Capital PRA PLCC Fresh—March 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 13`x' day of December, 2012 by and between General Electric Capital Corporation, GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files(as defined in the Agreement), delivered by Seller to Buyer on March 26,2013,and as further described in the Agreement, GE Capital Retail Bank Monogram Credit Services,L.L.C. By: By: Glenn Marino Glenn Marino Title: EVP Title: President Date: Date: General Electric Capital Corporation RFS Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Title: Vice President Title:CFO Date: Date: GEMB Lendin , Inc. GEM Holding, L.L.0 By: By: StephenWatfa Joseph Ressa Title: Director Title:CFO Date: 4hl,43Date: c zoor 3 1 1 - GE Capita! PRA PLCC Fresh—March 2013 For value received and in further consideration of the mutual-.,'c'ovenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated:. as of this 13th day of December, 2012 by and between-.General Electric: Capital Corporation, GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services, ' L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C.'(collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys,- grants, onveys;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 March 26, 2013,and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services,U.C. By: By: Glenn Marino Glenn Marino Title:EVP Title:President Date: Date: General Electric Capital Corporation RFWing;L.L.0 By: By; Glenn Marino Joseph R s Pali FICA, Title: Vice President Title:CFO Date: Date: �/ 7.L•I GEMB Lending,Inc. GEM olding L:L.0 . By: By: Stephen Motta Joseph R s , Title: Director Title:CFO Date: Date: c 3 #v 3 X90 Walmart . Save money.Live better. Wa'ma• • TRACYMARTINI Visit mat walmart.com/credit Credit Card Account Number: 867 Customer Service:1-800-6414526 ffNcyoEr}7tdti►eiftft}tttft?tftftf %)ttlytftdAttlnFdf.tftf t t tf t}tf t tt Ft}tft Previous Balance $1,675.67 New Balance $0.00 -Other Credits $1,675.67 Amount Past Due $0.00 New Balance $0.00 Total Minimum Payment Due $462.00 Payment Due Date 03/01/2013 Credit Limit $1,400 Late Payment Warning If we do not receive your minimum Available Credit $0.00 payment by the date listed above,you may have to pay a late Cash Advance/Quick Cash Limit $200 fee up to$35.00. Available Cash $0.00 Statement Closing Date 02/27/2013 Days in Billing Cycle 26 }ttt}tttttttttftftttttttftttit}t}tttttttttftttttttttttf Tran Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount 02/27 02/27 F9112001 000999990 CHARGEOFF ($1,114,65) ACCOUNT-PRINCIPALS 02/27 02/27 F9112001000999990 CHARGE OFF ACCOUNT-FINANCE ($561.02) CHARGES- FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 02/27 02/27 INTEREST CHARGE ON PURCHASES $0.00 02/27 02/27 INTEREST CHARGE ON CASH $0.00 ADVANCES TOTAL INTEREST FOR THIS PERIOD $0.00 +# #(#fdtlallldrfb�alei+#+#+i+#_tit_ Total Fees charged in 2013 --- - --------- - $0.00 Total Interest charged in 2013 $59.41 Total Interest Paid in 2013 $0.00 Your Annual Percentage Rate(APR) is the annual interest rate on your account. Annual Percentage Balance Subject to Type of Balance Expiration Date Plan Type Rate Interest Rate Interest Charge Current Transactions Regular Purchases&Cash NA REG 22,90%(v) $0.00 $0.00 Advances Transactions on or before 05/18/2011 RegularPurchases N/A REG 22.90% $0.00 $0.00 (v)=Variable rate If your account has a deferred interest promotion and you would like us to apply a payment on your account to a specific balance,please call Customer Service to discuss options that may be available. PAYMFNT DIJF AY S P.M.(FT)0N TEFF DUF DATE NOTICE:We may convert your payment into an electronic debit.See reverse for details,Billing Rights and other important information. - 5404 HFH 1 3 1 130227 ZX PAGE 1 of 1 9112 1400 0204 01ODS404 Detach and mail this portion with your check.Do not include any correspondence with your check. W��iu4 rl, Account Number'. 867 �" "+t., fctfilMieilrArrf tftMrebdtlFtt #afrteEtOAtf f t + +# +i+ + tit#tit# Save money.Llve better. $462.00 $0.00 03/01/2013 $0.00 $0.00 Payment EncSEEMS E E Please use blue or blackk ink. $ *6032201440577867- New address or email?Print changes on back. - TRACY MARTINI FFFAATDDDFATFFDDTATDATFAFrFATDAFTFFAAFFFFFTATTDFDDATDTDFAFFATTDTA 57 W I ST CARLISLE PA 17013-1419 Make Payment To: WALMART/(;ECRB . P.O.BOX 530927 AFDTADAFFDDTAFAFTFATTTDDTAAATAATTDDFDTDFATTFATDDTA'ffAWWg F'f -0927 7 867 CustomerService7Questions:For account In formation,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 maybe limited.You may also mail questions(but not payments)to:P.O.Box 965023,Orlando,FL . 32896.5023.Please includeyouraccount number on any correspondence you send to us. Payments:Send payments to the address listed on the remit portion of this statement or pay online. Notice:See below foryour Billing Rights and other important information.Telephoning about billing errors will not preserveyour rights under federal law. To preserveyour rights,please write to our Billing lnquiriesAddress,PD,Box 965023,Orlando,FL 32696-5023. Purchases,returns,and payments made just prior to billing date may not appear until next month's statement.When you provide check as payment, you authorize us either to use information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction,When we use inforniation from your check to make an electronic fund transfer.funds maybe withdrawn from youraccount as soon as the same 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 payment stub),in your own envelope—not the enclosed window envelope,addressed to:P.O.Box 960098,Orlando,FL 32896-0098 and notthe Payment Address. What To Do It You Think You Find A Mistake On Your Statement including any check or other payment instrument that:(i)indicates that the If you think there is an error on your statement,write to us at the Billing payment constitutes"payment in full'or is tendered as full satisfaction of a Inquiries Address of: disputed amount:or(it)is tendered with other conditions or limitations GE Capital Retail Bank ("Disputed Payments"),must be mailed or delivered to us at P0.Bou P0.Box 965023,Orlando,FL 32696-5023 965023,Orlando,FL 32896-5023. In your letter,give us the following information: Credits To Your Account:An amount shown in parenthesis or preceded •Account information.,Your name and account number. by a minus(-)sign is a credit orciedftbalance unless otherwise indicated. •Dollaramounf:The dollar amount of the suspected error Credits will be applied to your previous balance immediately upon receipt, •Description of Problem:If you think there is an error on your bill, butwilinotsatisfyany required payment that maybe due. describe whatyoubelieve iswrongand why you believe itisamistake. Credit Reports And Account Information:If you believe that we have You must contact us within 60 days after the error appeared on your reported inaccurate information about you to a consumer-reporting statement agency,please contact us at PO.Box 965024,Orlando,FL 32896-5024.In You must notify us of arrypotential errors in writing You may callus,but doing so,please identify the inaccurate information and tell us why you If you do we are not required to investigate any potential errors and you believe it is incorrect.If you have a copy of the credit report that Includes may have to pay the amount In question. the inaccurate information,please include a copy of that report.We may While we investigate whether or not there has been an error,the report information about your account to credit bureaus.Late payments, following are true: missed payments,or other defaults on your account may be refterted In •We cannot try to collect the amount in question,or report you as yourcredit report. delinquent on thatamount. BalanceSub/ed To Interest Charge Calculation • The charge in question maysemain on your statement,and we may Method 2D(Daily Balance method):We figure the interest chargeon your continue to charge you interest on that amount.But.if we determine that account byapplying the periodic rateto the"dailybalance"of your account for we made a mistake,you will nothave topay the amount inquestion orany each day in the billing cycle.We then add the interest to the daily balance.To interest or other fees related to that a mount. get the"daily balanc we take the beginning ba lance of your account each • While you do not have to pay the amount in question,you are day(which includes unpaid interest),add any new charges,and applicable responsible for the remainder of your balance. fees,and subtract any payments or credils.This gives us the daily balance. • We can apply any unpaid amount against your credit limit. Any daily balance of less than zero will be treated as zero,A separate daily Your Rights If You Are Dissatisfied With Your Credit Card balance will be calculated for each balance type on your account.The Purchases balances)shown in the Interest Charges section of this statement Is the sum If you are dissatisfied with the goods or services that you have of the daily balances for each day inthe billing cycle divided bythe romberof purchased with your credit card,and you have tried in goad faith to days inthebillirgrycle. correct the problem with the merchant,you may have the right not to pay Method 2M(AverageDaily Balance Including current transactions): the remaining amount due on the purchase. We figure the interest charge on your accourr by applying the periodic rate to To use this right,all of the following must be true: the"average daily balance"of your account,To get the"average daily 1.The purchase must have been made in your home slate orwilhin 100 balance'we take the beginning balance of your account each day,which miles of your current mailing address,and the purchase price must have includes any unpaid interest charges from the previous billing cycle,add any been more than W.(Nolo:Neither of these are necessary if your new charges,and applicable fees and subtract any payments or credits,This purchase was based on an advertisement we mailed to you,or if we own gives us the daily balance.Then,we add up all the daily balances for the the company that sold you thegoodsorservices,) hilling cycle and divide the total by the numberof days in the billing cycle,This 2.You must have used your credit card for the purchase.Purchases gives us the'average daily balance,"which is the balance shown in the made with cash advances fronanATM orwith acheck that accesses your Interest Charges section of this statement Any average daily balance of less credit card account donolqualiy. than zero win be treated as zero.A separate average daily balance will be 3,You must not yet have fully paid for the purchase. cakulatedforeachbalancetypeonyouraccount. If all of the criteria above are met and you are still dissatisfied with the BankruptryNotice:If you file bankruptcyyou must send us notice,including purchase,contact us in wrrtingal: account number and all information related to the proceeding to the following GE Capital Retail Bank address:GE Capital Rata#Bank,Attn:Bankruptcy Dept.,P.O.Box 103104, . P0.Box 965023,Orlando.FL 32896-5023 Roswell,GA 30076. White we investigate,the same rules apply 10 the disputed amount as YouraccoumfsownedandservicedbyGECapitalRefaiiBank discussed above.After we finish our investigation,we will tell you our Hearing lmpaired:TODusers call 1-800-444.1732. decision.Al that point,if we think you owe an amount and you do not pay we may report you as delinquent. Information About Payments:You may at any time pay,in whole orin parr,the total unpaid balance without any addfffonal charge for prepayment Payments received after 5:00 PM(ET)on any day will be credited as of the next day.Credft toyourAocouni maybe delayed upto We days if payment(a)is not received atthe Payment Address,(b)is not made _ in U.S.dollarsdrawn on a U.S.financial institution located in the U.S.,(c)is not accompanied by the remittance coupon attached to your statement.(d) contains more than one payment or remittance coupon,(e)is not received in the remittance envelope provided or(f)includes staples,paper clips, tape.a folded check, or correspondence of any type. Conditional Pavnnents:All written communications concerning disputed amounts, 01 DD5404-2-07/132011 This is an attempt to collect a debt and any information obtained will be used for that purpose. 'By providing a telephone numberon your account,you consent to GE Capital Retail Bank and anyotherowner orservicer of your accounloontacting you about your account,including using arty 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 prerecorded voice when contacting you,even If you are charged for the call underyour phone plan. For changes of address,phone number and/or email,please check the box and print the changes below. Street Address Ciy,State, ❑ Zip Phone# E-mail Home Phone# Business Phone# 'Cell#or other phone#we Email Address can use to contact you By providing your email address,you agree to receive email communications about your account and also give permission for us to share your email address to Walmarl. I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson = Sheriff „vo of Gnat iot,„ Jody S Smith . (�`, Chief Deputy 4'. Richard W Stewart BERL,�t-,iU Solicitor �,E ti S.Y L` Portfolio Recorvery Associates, LLC vs. 2014- Tracy Martini Case Number SHERIFF'S RETURN OF SERVICE 06/12/2014 07:29 PM- Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Billy Martini, Husband,who accepted as"Adult Person in Charge"for Tracy Martini at 57 West I Street, Carlisle Borough, Carlisle, PA 17013. C ISTOP R HARPE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, June 13, 2014 RONNY ANDERSON, SHERIFF sour ...e t c. )ser ...,_ 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. TRACY MARTINI 57WIST CARLISLE PA 17013 Date: No. 14-3489 CIVIL 4) -7"4 ---t "4c -z G G T-11 .-Cyr.- PRAECIPE FOR DEFAULT G.--) Defendant JUDGMENT n c �---',.„.?,- ...z..,-.; o =' N 37 G y -v 'o i 15-62964 Filed on • f Plaintiff Couns - of R: ord for t obert N. Polas, J ., Esquire, # 201259 arrie 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 oisvA %110A alb -t 0)C,# Sys 9e y p#3 --)&6, r\io&‘e /Y2Jd 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. TRACY MARTINI 57WIST CARLISLE PA 17013 Defendant No. 14-3489 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, TRACY MARTINI, for failure to answer the Complaint. (X) Amount Due $1,675.67 Less Credits $.00 TOTAL $1,675.67 (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 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. (X) Pursuant to PARC.P.231.1, I certify that a written notice of intention to file this 15-62964 praecipe was mailed or delivered to the party a and to his/her attorney of record, if any, aft prior to the date of the filing of this .raeci t whom jud efault occ copy of e noti t is to be entered d at least ten days is attached. Ror-rt N. Polas, Jr., Squire, # 20125 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 tier that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATFS, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. TRACY MARTINI 57WIST CARLISLE PA 17013 Plaintiff : No. 14-3489 CIVIL 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 $1,675.67. (X) A copy of all documents filed with the Prothonotary in support of th attached. If you have any questions regarding this Notice, 15-62964 Robert N. Polas, Jr., Esq e, # 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 born a debt collector is an attempt to collect a debt. Any information obtained will be used lbr 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 3, 2014 TRACY MARTINI 57 W I ST CARLISLE PA 17013 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. TRACY MARTINI 14-3489 CIVIL Dear TRACY MARTINI: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-62964 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 v. TRACY MARTINI 57WIST CARLISLE PA 17013 Plaintiff No. 14-3489 CIVIL Defendant TO: TRACY MARTINI 57WIST CARLISLE PA 17013 DATE OF NOTICE: July 3, 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. 15-62964 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bat 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. TRACY MARTINI 57WIST CARLISLE PA 17013 Defendant No. 14-3489 CIVIL 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 57WIST CARLISLE PA 17013 and is not in the military service of the United States or its Allies, the Service Members Civil Relief Act and its Amendments. 15-62964 erwise within e nrov'. ions of 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 iintbnnation. obtained will be used for that purpose. Department of Defense Manpower Data Center Results as of : Jul -18-2014 05:52:22 PM SCRA 3.0 Status Report Pursuant to ,Servicenaembers Civil. Relief Act Last Name: MARTINI First Name: TRACY Middle Name: Active Duty Status As Of: Jul -18-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA `Nn ' NA This response reflects the individuals' active duty status based on the Active DutyStatus Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty -status within 367'days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the iindividual 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: DBH9F89A307FK00