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Home My WebLink About14-3551 Supreme Court-.of Pennsylvania Courof Common Pleas j ,! tyr ► h>; ForProthonota U e Only: TlM1?STAMP Ci �Cover,,�hlret Docket No: rj CUNME L., County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service gfpleadings or other a ers as required by law or rules o court. S Commencement of Action: E ®Complaint ❑ Writ of Summons ❑Petition C ❑Transfer from Another Jurisdiction ❑Declaration ofTaking Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES,LLC JASON D ROBERTS Q Are money damages requested? N Yes ❑ No Dollar Amount 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 Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you haw no attorney(are a Self-Represented[Pro Sel Litigant) Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRMMY 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 0 Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other ❑ 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: 0 MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY NUSCFLLANEOUS ❑ Toxic Tort-DES � El Toadc Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration F-1 Toxic Waste ❑Eminent Domain/Condetrnation ❑ Declaratory Judgment E] Other: ❑ 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: 15-84451 s Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 OF 71��f fi� OFF IC�- Portfolio Recovery Associates, LLC 120 Corporate Blvd. �� Norfolk, VA 23502 CU+�'� JUN ' 4M TELE: 1-866-428-8102 P�V8LAtvD CpU FAX:(757) 518-0860 ° T Attorneys for Plaintiff S)'��A N/A 1 IN THE COURT OFCOMMON PLEAS`OF CUMBERLAND COUNTY, PA CIVIL ACTION-'LAW ' PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVDIq NORFOLK, VA 23502 No. Plaintiff, V. JASON.D,ROBERTS 507 MILLER AVE 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, personalty 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,'OOR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE.OFFICE SET FORTH BELOW TO1FIND OUTjWHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH { INFORMATION ABOUT HIRING A LAWYER. IF YOUC. ANNOT AFFORD TO HIRE A LAWYER, THIS.OFFICE MAY BE ABLE TO PROVIDE_ YOU WITH INFORMATION ABOUT AGENCIES TAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS-AT A REDUCED FEE OR NO FEE. `Y Lawyer Referral Service—CUMBERLAND County Bar Association 4 Cumberland.County Bar Association' N 32'South Bedford Street . Carlisle, PA 17013 (717) 249-3166,, 15-84051 �a t i 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. JASON D ROBERTS 507 MILLER AVE 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 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 1701.3 (717) 249-3166 15-84051 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar Urm deuda. Cualquier infronucion 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. JASON D ROBERTS 507 MILLER AVE 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, JASON D ROBERTS, is an adult individual with last known address of 507 MILLER AVE, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to CITIBANK, N.A. /GORDONS on December 1, 2008 with account number ************5414(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 cor ixunication is fi-orn a debt collector and is an attempt to collect a debt. Any inforination obtained Nvill be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Itina Spellman hereby states that he/she is authorized to take this verification on behalf of said Plaintiffin 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 belied 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 3 0 2014 By: Itina Spellman Custodian of Records 15-84051 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBIT 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. BILL Of SALE AND ASSIGNMENT .. ..THIS BILL OF: SALE AND ;ASSIGNMENT; dated June 27, 2413, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th.Street North; Sioux Falls, SD 5.7117 (the "Bank").to Portfolio. Recovery Associates, LLC, organized under the laws of.theState of Delaware, with its headquarters/principal P lace of business at 130 Corporate Boulevard; Norfolk,VA 23502:{"Buyer"). For value received and.subject.to.the terms and conditions of the.Purchase and Sale Agreement dated June 25; 2013, between Buyer and the Bank (the "Agreement"), the:Bank does hereby transfer, sell, assign, convey,: grant, bargain, set over and deliver to Buyer; and to Buyer's successors and assigns,:the.Accounts described in Exhibit l and the final electronic file. Citibank,N. q. By: (S Name: ou ugJas C. Morriso . Tittle: --Director_ 44 PRA 062513A,doc Account Statement Send Notice of c Sioux Falls SD,Errors and Customer Service Inquires to: Gordon's Customer Service: gordons.accountonline.com x7117-6403 177777777777777--7... CREDIT PLAN... ..... Billing GORDON S C PO Box 6403 Account Inquiries: J E W E L E R s- 1-888-316-8480. Accourtt'(Vumber.s 541.4_` Summary of Account Activity Payment Information Previous Balance $1,244.60 New Balance $1,308.76 Payments -$0.00 Minimum Payment Due $536.00 Other Credits -$0.00 Payment Due Date November 9, 2011 Purchases +$0.00 Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$29.16 Minimum Payment Warning: If you make only the minimum payment each New Balance $1,308.76 period,you will pay more in interest and it will take you longer to pay off your balance For example Past Due Amount $458.00If you make nd'addltional You wr4'pay off the And you'will charges using this card balance showt.n oh"t-iis end up paying an Credit Limit 0.00 and each on you:`you pay_ statement in about `. eafiitiated total Available Credit $0.00 Only the minimum payment 6 years $2,144 Cash Advance Limit 0.00 Available Cash Limit 0.00 $54 3 years $1'927 Statement ClosingDate 10/13/2011 (savings=$217) Next Statement Closing Date 11/ /2011 If you would like information about credit counseling services,call 1-877-337-8188. Das in Billing Cycle 31 You may pay all or part of your account balance at any time.However,you must pay,by the payment due date,at least the minimum payment due. TRANSACTIONS Trans Date Description Reference# Amount FEES 10/09 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 10/13 INTEREST CHARGE ON PURCHASES $ 27.26 10/13 INTEREST CHARGE ON CASH ADVANCES $ 1,90 TOTAL INTEREST FOR THIS PERIOD $ 29.16 MANAGE YOUR ACCOUNT ONLINE . . . ANYTIM -Access current and past statements -Set up email alerts -Pay your bill online 24/7 with same day posting" -View recent activity -. Register now at gordons.accountonline.com •If payment is received by Spm ET. 8ZG7 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank,N.A. -------------- -- ------------------------------------------------------------------------------------------------ +Please detach this porion and return with your payment to insure proper credit. Retain upper porion for your records.+ Gordons' Make Checks Payable to: GORDON'S CREDIT PLAN E w F L N r: W t Past Due Amount is included in the Minimum Payment Due. Your.Account Number ,7 Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 5414 NOVEMBER 9,2011 $1,308.76 $458.00 $536.00 $ SAVE STAMPS, TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, Paperless Statements and More. 5414 GORDON'S CREDIT PLAN PO BOX 183015 JASON D ROBERTS COLUMBUS,OH 43218-3015 507 MILLER AVE MECHANICSBURG, PA 17055-4043 Print address changes above in blue or black ink. Information About Your Account. What To Do if You Think You Find a Mistake on Your Statement How to Avoid Paying Interest on Purchases.Your payment due date is at If you think there is an error on your statement,write to us at the Billing least 25 days after the close of each billing cycle. We will not charge you any Errors address shown on the front. interest on purchases if you pay your New Balance by the payment due date In your letter;give us the following information: each month- This is called a grace period on purchases. If you do not pay Account information:Your name and account number. the New Balance in full by the payment due date,you will not get a grace Dollar amount:The dollar amount of the suspected error. period on purchases until you pay the New Balance in full for two billing Description of Problem.If you think there is an error on your bill,describe cycles in a row.We will begin charging interest on cash advances(if available what you believe is wrong and why you believe it is a mistake. on your account)on the transaction date. You must contact us within 60 days after the error appeared on your If you have a balance subject to a deferred interest promotion or a 0% statement. promotion and that promotion does not expire before the payment due date, You must notify us of any potential errors in writing.You may call us,but if that balance (an"excluded balance")is excluded from the amount you must you do we are not required to investigate any potential errors and you may pay in full to get a grace period on a purchase balance other than an have to pay the amount in question. excluded balance. In addition,if you have a major purchase plan balance, that balance(an"excluded balance")is excluded from the amount you must While we investigate whether or not there has been an error,the following pay in full to get a grace period on a purchase balance other than an are true: excluded balance. However;you must still pay any separately required We cannot try to collect the amount in question,or report you as payment on the excluded balance. In billing cycles in which payments are delinquent on that amount. allocated to deferred interest balances first,the deferred interest balance will The charge in question may remain on your statement,and we may be reduced before any other balance on the account. However, you will continue to charge you interest on that amount.But,if we determine that continue to get a grace period on purchases,other than an excluded balance, we made a mistake,you will not have to pay the amount in question or any so long as you pay the New Balance(less any excluded balance,plus any interest or other fees related to that amount. separately required payment on an excluded balance)in full by the payment While you do not have to pay the amount in question,you are responsible due date each billing cycle.We may refer to deferred interest promotions as for the remainder of your balance. No Interest or No Monthly Interest promotions. We can apply any unpaid amount against your credit limit. In addition,certain promotional offers may take away the grace period on Your Rights if You Are Dissatisfied With Your Credit Card Purchases purchases. Other promotional offers not described above may also allow you If you are dissatisfied with the goods or services that you have purchased to have a grace period on purchases without having to pay all or a portion of with your credit card,and you have tried in good faith to correct the problem the promotional balance by the payment due date. If either is the case,the with the merchant,you may have the right not to pay the remaining amount promotional offer will describe what happens. due on the purchase. How We Calculate Your Balance Subject to Interest Rate.For each To use this right,all of the following must be true: balance,the letter following the Annual Percentage Rate in the Interest 1. The purchase must have been made in your home state or within 100 Charge Calculation section on the front of the statement indicates the miles of your current mailing address,and the purchase price must have method we use to calculate interest charges. For Methods B and E,we use an been more than$50.(Note:Neither of these are necessary if your average daily balance method(including current transactions)to calculate purchase was based on an advertisement we mailed to you,or if we own interest charges.For Methods C, D and M,we use a daily balance method the company that sold you the goods or services.) (including current transactions)to calculate interest charges.To find out 2.You must have used your credit card for the purchase.Purchases made more information about the balance computation method that applies to with cash advances from an ATM or with a check that accesses your credit your account and how the resulting interest charges were determined, card account do not qualify. contact us at the Account Inquiries number on the front. 3.You must not yet have fully paid for the purchase. Credit Reporting Disputes.If you think we reported inaccurate information If all of the criteria above are met and you are still dissatisfied with the to a credit bureau write us at the Customer Service address shown on the purchase,contact us in writing at the Billing Errors address shown on the front. front. Report a Lost or Stolen Card Immediately.Call the Account Inquiries While we investigate,the same rules apply to the disputed amount as number shown on the front. discussed above.After we finish our investigation,we will tell you our decision.At that point,if we think you owe an amount and you do not pay we may report you as delinquent. FMJ/Zales/Gordon MPP CIT 07/11 Important Payment Instructions. Payment Options Other Than Regular Mail. Crediting Payments. If we receive your payment in proper form at our Online Payments.Visit the web address on the front and sign up for processing facility by 5 p.m.local time there,it will be credited as of that day. online payments.Enrollment may take a few days. If we receive your A payment received there in proper form after that time will be credited as request to make an online payment by 5 p.m.Eastern time,we will credit of the next day.Allow 5 to 7 days for payments by regular mail to reach us. your payment as of that day.If we receive your request to make an online There may be a delay of up to 5 days in crediting a payment we receive that payment after that time,we will credit your payment as of the next day. is not in proper form or is not sent to the correct address. The correct For security reasons,you may be unable to pay your entire New Balance address for regular mail is the address on the front of the payment coupon. with your first online payment. A payment made in-store is not sent to the correct address. The correct Pay by Phone Service.You may use this service any time to make a address for courier or express mail is the Express Payments Address shown payment by phone. You will be charged$14.95 if a representative of ours below. helps expedite your payment.Call by 5 p.m.Eastern time to have your Proper Form.For a payment sent by mail or courier to be in proper form, payment credited as of that day. If you call after that time,your payment you must: will be credited as of the next day. We may process your payment • Enclose a valid check or money order.No cash,gift cards,or foreign electronically after we verify your identity. currency please. Express Payments.You can send payment by courier or express mail to Include your name and account number on the front of your check or the Express Payments Address.This address is:Customer Service Center, money order. Dept.CCS 911,4740 121st Street,Urbandale, IA 50323.Payment must be received in proper form at the proper address by 5 p.m.Central time to be If you send an eligible check with this payment coupon,you authorize us credited as of that day.All payments received in proper form at the proper to complete your payment by electronic debit.If we do,the checking address after that time will be credited as of the next day. account will be debited in the amount on the check. We may do this as soon as the day we receive the check. Also,the check will be destroyed. Copy Fee.We charge$5 for each copy of a billing statement that dates back T01285 X-E-12/01/08-30- -000-0-ZADB-04/30/11-E-P-7-8-9194-0503-0006-N 3 months or more. We add the fee to the regular purchase balance.We waive the fee if your request for the copy relates to a billing error or disputed purchase. Page 2 of 4 Account: '*** **** **** 5414 2011 Totals Year-to-Date Total Fees Charged in 2011 $296.00 Total Interest Charged in 2011 $238.44 INTEREST CHARGE CALCULATION PercentageRatet rate on your account. Type•of Balance A'nnuaLPercenta e::Rate ppAnnuaBalance Sub eatao interest Rate interest rate I PURCHASES REGULAR 26.99%(M)(V) $818.82 $18.77 REGULAR ON OR BEFORE 06/13/10 26.99% M $370.70 $8.49 CASH ADVANCES REGULAR 29.95%(M)(V) $0.00 $0.00 REGULAR ON OR BEFORE 06/13/10 29.95% M $74.70 $1.90 V =Variable Rate Page 3 of 4 Account: **** **** **** 5414 Page 4 of 4 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 April 15, 2011. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. /GORDONS 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$1,308.76. 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, JASON D ROBERT59iF flu o is of this action and any other relief as the Court deems just a4055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 15-84051 `Phis corrnnunication is fi-or.n.a debt collector and is an attempt to collect a debt. Any infori ation obtained will be used for that purpose. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HE P OTI-i01iU 20.14 JUN 17 PM 3: 05 CUMBERLAND COUNTY PENNSYLVANIA „or o{ CIIIItheor Portfolio Recovery Associates, LLC vs. Jason Roberts Case Number 2014-3551 SHERIFF'S RETURN OF SERVICE 06/13/2014 06:11 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Amanda Updegrave, Girlfriend, who accepted as "Adult Person in Charge" for Jason Roberts at 507 Miller Avenue, pper Allen, Mechanicsburg, PA 17055. LLIAM CLINE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, June 16, 2014 (c) CountySuite Sheriff, Teleosoft, Inc RON�R 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. JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 Defendant Dated 15-84051 No. 14-3551 CIVIL : PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf Counsel of Plaintiff d for this Party 77. CD UD 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 t' :317*, C, CD 2) sl .So�� CL6 54(4430 looaLi This communication is from a debt collector is an attempt to collect a debt. ,n t b(1/10-tIoil Any infonnation obtained will be used for that purpose. Y V 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. JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 Defendant No. 14-3551 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, JASON D ROBERTS, for failure to answer the Complaint. (X) Amount Due $1,308.76 Less Credits $.00 TOTAL $1,308.76 (X) (X (X 15-84051 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 p. .. ainst whom judgment is to . - = ed and to his/her attorney of record, if an • the default occurred and en days prior to the date of the filing of this • . % . e c •,� o� hno ached. 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. 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. 14-3551 CIVIL v. JASON D ROBERTS 507 MILLER AVE 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 $1,308.76. (X) A copy of all documents filed with the Prothonotary in suppo f the ,'N ' in judgment is/are attached. If you have any questions regarding this N 15-84051 Robert 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 7, 2014 JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. JASON D ROBERTS 14-3551 CIVIL Dear JASON D ROBERTS: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-84051 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. 14-3551 CIVIL v. JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 Defendant TO: JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 DATE OF NOTICE: July 7, 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 FRF OR NO FEE. 15-84051 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. JASON D ROBERTS 507 MILLER AVE MECHANICSBURG PA 17055 Defendant No. 14-3551 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 507 MILLER AVE MECHANICSBURG PA 17055 and is not in the military service of the United States or its Allie the Service Members Civil Relief Act and its Amendments. 15-84051 ise within the provision Robert 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 Servicemembers Civil Relief Act Last Name: ROBERTS First Name: JASON Middle Name: D Active Duty Status As Of: Jul -25-2014 Results as of : Jul -25-2014 07:05:24 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 o., NA This response reflects the individuals' active duty status based on the �A.b6e,buty 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 leftaclive 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 T. .,>. No NA This response reflects whetherthe 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 . 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: HBK6T38E60CFKE0