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Home My WebLink About14-4018 Supreme Courto Pennsylvania 7 urtiaf Com n Pleas °� ,.C,! r*, u` Vii . For Prothonotary Use Only: TIME STAMP CIv �Co very��heet Docket No: CUMB ;County The information collected on this form is used solely for court administration purposes. This fonn does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. S Commencement of Action: E M Complaint ❑ Writ of Summons ❑Petition C E] Transfer fromAnother Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: ,r PORTFOLIO RECOVERY ASSOCIATES, LLC DEBRA CUMMINGS I O Are money damages requested? ® 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 JPro Se]Litigant) i Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include 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 mass tort) El Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Other: O Ground Rent ❑ 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: 16-07547 k• RobertN. Polas, Jr., Esquire PA Bar#201259 C,,A,•ie Brown, Esquire PA Bar#94055 ;;1� Mark R Garvey, Esquire PA Bar#312686 OF Portfolio Recovery Associates, LLC � � 120 Corporate Blvd C.� h Norfolk, VA 23502 ` �� pty f, TELE: 1-866-428-8102FAX 757) 518-0860 Attorneys for Plaintiff NS YL V,f ' T Lit 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD _ ! I NORFOLK, VA 23502 No. Ci 1, �i I Plaintiff, V. DEBRA CUMIVIINGS 108 E PENN ST APT 1 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 AWYERIF 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 7�`_/ 16-07547 a OA� �a8r0 0 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. DEBRA CUMMINGS 108 E PENN ST APT 1 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) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMIVIE POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 16-07547 Esta connanicacion es de un cobrador de deudas y es un intent do cobras tna deuda. Cualquier infron-inion 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. DEBRA CUMMINGS 108 E PENN ST APT 1 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, DEBRA CUMNIINGS, is an adult individual with last known address of 108 E PENN ST APT 1, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to CITIBANK,N.A. / SEARS on June 23, 2009 with account number ************6805 (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 commMunication is from a debt collector and is an.attempt to collect a debt:. Any infonTkition 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 April 2, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBV K, N.A. / SEARS 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$999.08. 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, DEBRA CUM IINGS , i the ount of$999.08, plus co o this action and any other relief as the Court deems just d re nab . ie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-07547 `11.1is comnlUnication is from a debt collector and is an.attempt to collect a debt. Any information obtained will be used for that purpose. r VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cdstina Patterson 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 unswom fals' tion to authorities. MAY 2 9 2014 Date: By: Crisfina Patterson Custodian of Records 16-07547 This comnRn nication 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. D ' urict ID;O p�cum�ti�T!}-01 • A211;T:OF'SALF,AND AS ftGNMENT ' ;BIIy :b t L'E :�� x',. a .. a?fi t y� 7;• b:1 3 is:by 'an"N i .,Ar _!q4t�oQa1 bA*og assn"a.'O' ani ed under flip Inm gf#(O�Udtedftfes,.jacated at`'70 t eos `asD -. - kPtint59th Sutt Ndfai, S71 : -fiei �Associsfes, 4tei� VWOZ tf[e_ IYW y df•1��I:�;v�rarte,, i h ip :hWquarfe`rs pri is pal. puce b. vsess.ar 13.x}:C.6>csaa $iu��v&rd, Ta` o11 ,; !A: 23542, Tor v�ludvccdved land sub ectlb lh&Aertns anti--ond ""m.,!D e;PFur�hase:anti `Av Ag�re ,en d2�t d. ebraar 2S 2 2 �het it;Bud%e, : i 'die.Bz�itf:(#h '{A rceir� nt" the B�a�&0hekeby tlatlef', I�r: �ssigif,. bnyey;.. rtiil#,.. igainx sef over fid.zleh'ver to Buyez��•: nato�:l3a�yetrs: ucceso anc sign , ,` s � s's.. _ .'r��,A�at��c� �rib;ed fl�:E �i�t:1.end t��•;�rta�;�lgctrp e. Citi [. 'daHall. T .riff mcfal Agg�� K pl�:Q?:2si3 Contract M Document TD; WcuicriC;It�: : EXIUBIT 1 . .. The individual-AAccoimts:transferred-are'dbkribed in'' final.electronic:file and--deliv�red.by#he: :• :.. . . 'Hauk toBuyer,the'saine:de6m6d'a#tacked:hereto:iiy'this:refeieiice.: . :'. #Of Sale Cat-Off Lot Sale ID Accounts Rates Sale Balance- Date -' Sears Early 02/20/13 Out MasterCard : Sears Early z 02/20/13 Out Private Label PRA- X22513 Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: SEARS CREDIT CARDS searsd searscard.com PO Box 6282,Sioux Falls,SD 57117-6282 Sears MasterCard Account Inquiries: a 1-800-669-8488 ACcoltrtt NuttSber.: 8fJ5.' Summary of Account Activit -Payment Information Previous Balance $947.98 New Balance $999.08 Payments -$0.00 Minimum Payment Due $518.66 Other Credits -$0.00 Payment Due Date December 4,2012 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 +$16.10 Minimum Payment Warning: If you make only the minimum payment each New Balance $999.08 period,you will pay more in interest and it will take you longer to pay off your balance.For example: Past Due Amount $358.48 If yow make no:addfUoriat You wtlt pay Off.the And you wdl; charges using this card 7.15alaticO,Shown on this' end uppajti,ng an Credit Limit $0.00 ;and each t 14.0.you pay statement:i about estimated total of Available Credit $0.00 Cash Advance Limit $0.00 Onlythe minimum payment 3 years. $1,190 Available Cash Limit $0.00 If you would like information about credit counseling services,call 1-877-337-8188. Amount Over Credit Limit $99.08 Statement Closing Date 11/07/2012 Next Statement Closing Date 12/07/2012 Days in Billing Cycle 30 Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. We are here to support our customers affected by Hurricane Sandy. Above all, we hope you and your family are safe. If you have been impacted by the storm and need assistance, please call us at the customer service number listed on your statement. We will work to help with your individual needs during this challenging time. 8ME3 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Pagel of 4 This Account is Issued by Citibank,N.A. ------------------------------------------------------------------------------------------------------------------------------ +Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.'t' Sears MasterCard" tPast Due Amount is included in the Minimum Payment Due. Your Account Number Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 6665`:.` DECEMBER 4,2012 $999.08 $358.48 $518.66 $ SAVE STAMPS TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, Paperless Statements and More. 6805 Make Checks Payable to: SEARS CREDIT CARDS PO BOX 183082 DEBRA CUMMINGS COLUMBUS,OH 43218-3082 108 E PENN ST APT 1 CARLISLE,PA 17013-2434 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your tetter How to Avoid Paying Interest on Purchases.Your payment due date is at least When we receive your letter,we must do two things: 25 days after the close of each billing cycle. We will not charge you any interest on 1. Within 30 days of receiving your letter,we must tell you that we received purchases if you pay your New Balance by the payment due date each month. your letter.We will also tell you if we have already corrected the error. This is called a grace period on purchases. If you do not pay the New Balance in 2. Within 90 days of receiving your letter,we must either correct the error or full by the payment due date,you will not get a grace period on purchases until explain to you why we believe the bill is correct. you pay the New Balance in full for two billing cycles in a row. We will begin charging interest on cash advances and balance transfers(if available on your While we investigate whether or not there has been an error: account)on the transaction date. • We cannot try to collect the amount in question,or report you as delinquent on If you have a balance subject to a deferred interest promotion and that promotion that amount. does not expire before the payment due date,that balance(the"excluded The charge in question may remain on your statement,and we may promotional balance")is excluded from the amount you must pay in full to get a continue to charge you interest on that amount, grace period. However,you must still pay any separately required payment on the While you do not have to pay the amount in question,you are responsible excluded promotion.In billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first,the deferred interest balance will be reduced before any • We can apply any unpaid amount against your credit limit. other balance on the account.However,you will continue to get a grace period on After we finish our investigation,one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional If we made a mistake:You will not have to pa the amount in question or an balances in full by the payment due date each billing cycle. Y q Y interest or other fees related to that amount. In addition,certain promotional offers may take away the grace period on If we do not believe there was a mistake.You will have to pay the amount purchases. Other promotional offers not described above may also allow you to in question,along with applicable interest and fees.We will send you a have a grace period on purchases without having to pay all or a portion of the statement of the amount you owe and the date payment is due.We may then promotional balance by the payment due date. If either is the case,the report you as delinquent if you do not pay the amount we think you owe. promotional offer will describe what happens. How We Calculate Your Balance Subject to Interest Rate.We use a daily u you receive our explanation but still believe your bill is wrong,you must write to balance method(including current transactions)to calculate interest charges.To re within 10 days telling us that you still refuse to pay.If you do cannot find out more information about the balance computation method and how the report you as delinquent without also reporting that you are questioning dli your bail. resulting interest charges were determined,contact us at the.Account Inquiries We must tell you the name of anyone to whom we reported you as delinquent,and number on the front. we must let those organizations know when the matter has been settled between US. Balance Transfers.Balance transfer amounts are included in the"Purchases"line If we do not follow all of the rules above,you do not have to pay the first$50 of in the Summary of Account Activity(if balance transfers are available on your account). the amount you question even if your bill is correct. Transaction Date.The Transaction Date shown on the statement is also the Sale Your Rights If You Are Dissatisfied With Your Credit Card Purchases Date. If you are dissatisfied with the goods or services that you have purchased with Credit Reporting Disputes.If you think we reported inaccurate information to a Your credit card,and you have tried in good faith to correct the problem with the credit bureau write us at the Customer Service address shown on the front. merchant,you may have the right not to pay the remaining amount due on the Report a Lost or Stolen Cana Immediately.Call the Account Inquiries number purchase. shown on the front. To use this right,all of the following must be true: 1. The purchase must have been made in your home state or within 100 What To Do If You Find A Mistake On Your Statement miles of your current mailing address,and the purchase price must have If you think there is an error on your statement,write to us at the address for been more than$50.(Note:Neither of these are necessary if your billing inquiries and correspondence shown on the front of your statement, purchase was based on an advertisement we mailed to you,or if we own In your letter,give us the following information: the company that sold you the goods or services.) 2. You must have used your credit card for the purchase.Purchases made with • Account information:Your name and account number. cash advances from an ATM or with a check that accesses your credit card Dollar amount:The dollar amount of the suspected error. account do not qualify. • Description of problem:If you think there is an error on your bill, 3. You must not yet have fully paid for the purchase. describe what you believe is wrong and why you believe it is a mistake. If all of the criteria above are met and you are still dissatisfied with the purchase, You must contact us: contact us in writing at the address for billing inquiries and correspondence shown • Within 60 days after the error appeared on your statement. on the front of your statement. • At least 3 business days before an automated payment is scheduled,if you want While we investigate,the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. above.After we finish our investigation,we will tell you our decision.At that point, You must notify us of any potential errors in writing.You may call us,but if you do if we think you owe an amount and you do not pay, we may report you as delinquent. we are not required to investigate any potential errors and you may have to pay the amount in question. EM SMC-TGI-SCC-SCP-HIPs 07112 T02388-1238-5300-0018-9-E-87-X--06/01/09-86--P--0--7-402-0-0-SRSCHFEE---02/07/12-GDZB-October 8,2012-0-0-V N--- Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance • In-Store Payments(Where Available).Any payment in proper form accepted at any time.However,you must pay,by the payment due date,at least the in-store will be credited as of that day.However,credit availability may be minimum payment due. subject to verification of funds.Not all stores accept payments.Contact your Crediting Payments.If we receive your payment in proper farm at our processing local store to see if in-store payments are accepted at that location. facility by 5 p.m.local time there,it will be credited as of that day. A payment Online Payments.Visit the web address on the front and sign up for online received there in proper form after that time will be credited as of the next day. payments. Enrollment may take a few days. If we receive your request to make Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay an online payment by 5 p.m.Eastern time,we will credit your payment as of of up to 5 days in crediting a payment we receive that is not in proper form or is that day.If we receive your request to make an online payment after that time, not sent to the correct address. The correct address for regular mail is the we will credit your payment as of the next day.For security reasons,you may be address on the front of the payment coupon.The correct address for courier or unable to pay your entire New Balance with your first online payment. express mail is the Express Payments Address shown below. AutoPay Service.If you are enrolled in this service,your payment amount will be deducted automatically each month on your due date from the bank account Proper Form.For a payment sent by mail or courier to be in proper form,you must: you select. Enclose a valid check or money order.No cash,gift cards,or foreign Pay by Phone Service.You may use this service any time to make a payment currency please. by phone.You will be charged$14.95 if a representative of ours helps expedite • Include your name and account number on the front of your check or money your payment,Call by 5 p.m.Eastern time to have your payment credited as of order. that day.If you call after that time,your payment will be credited as of the next If you send an eligible check with this payment coupon,you authorize us to day.We may process your payment electronically after we verify your identity. complete your payment by electronic debit.If we do,the checking account will Express Payments.You can send payment by courier or express mail to the be debited in the amount on the check.We may do this as soon as the day we Express Payments Address.This address is: Payments Department,1500 receive the check.Also,the check will be destroyed. Boltonfield Street,Columbus,OH 43228. Payment must be received in proper Copy Fee.We charge$3 for each copy of a billing statement that dates back 3 form at the proper address by 5 p.m.Eastern time to be credited as of that day. months or more.We add the fee to the regular purchase balance.We waive the fee All Payments received in proper form at the proper address after that time will if your request for the copy relates to a billing error or disputed purchase. be credited as of the next day. Page 2 of 4 Account: **** ***' **** 6805 TRANSACTIONS Trans Date Description Reference# Amount FEES 11/04 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 11/07 INTEREST CHARGE ON PURCHASES $ 16 10 TOTAL INTEREST FOR THIS PERIOD $ 16.10 „ 2012 i'otals Year-to-bate Total Fees Charged in 2012 $235.00 Total Interest Charged in 2012 $145.17 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type of Bajnce ArinuatPerc+ntage;Rate_(APR);a:; ;Salarite.Sutiect to Interest Rate Ira'terest Cliarg PURCHASES REGULAR 20.40%(D)(V) $960.36 $16.10 CASH ADVANCES REGULAR 27.15%(D)(V) $0.00 $0.00 =Variable Rate D =Daily REWARDS SUMMARY Previous Points Balance 0 Points Earned 0 Points Adjusted 0 Points Redeemed _ 0 1,Ending Points Balance 0 Page 3 of 4 Account: ***" **** **** 6805 Page 4 of 4 t. 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. DEBRA CUMMINGS 108 E PENN ST APT 1 CARLISLE PA 17013 Date: Defendant 16-07547 : No. 14-4018 CV PRAECIPE FOR DEFAULT Ti JUDGMENT Filed on Behalf of Plaintiff Co - • R=cord for this P obert N. Polas, Jr., Esquire, # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff Ck-� gt/440 Z*L-3nsen) This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. Noht.c 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. DEBRA CUMIvIINGS 108E PENN ST APT 1 CARLISLE PA 17013 Defendant No. 14-4018 CV PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, DEBRA CUMMINGS, for failure to answer the Complaint. (X) Amount Due $999.08 Less Credits $.00 TOTAL $999.08 (X) (X (X) 16-07547 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 PAR.C.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the p gainst whom judgment is ► e - : tered and to his/her attorney of record, if r afte he default occurred . s . - . ten days prior to the date of the filing oft p sec'. d a cosy o the • ched. Robert N. Polas, Jr., Esquire, # 201259 Carrie A Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Gregory J. Babcock,' Esquire, #205061 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 v. DEBRA CUMMINGS 108 E PENN ST APT 1 CARLISLE PA 17013 Plaintiff No. 14-4018 CV 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 $999.08. (X) A copy of all documents filed with the Prothonotary in suppo of th 'thin :;ent is/are attached. If you have any questions regarding this Notic 16-07547 Obert N. Polas, Jr., Esquire, # 201259 Carrie A. Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 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 tised 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) September 17, 2014 DEBRA CUMMINGS 108 E PENN ST APT 1 CARLISLE PA 17013 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DEBRA CUMMINGS 14-4018 CV Dear DEBRA CUMMINGS: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID #201259/94055/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff 16-07547 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. DEBRA CUMMINGS 108 E PENN ST APT 1 CARLISLE PA 17013 Defendant TO: DEBRA CUMMINGS 108 E PENN ST APT 1 CARLISLE PA 17013 DATE OF NOTICE: September 17, 2014 IMPORTANT NOTICE No. 14-4018 CV 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. 16-07547 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 Gregory J. Babcock, Esquire Attorney ID #201259/94055/312686/205061 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. DEBRA CUMIVIINGS 108 E PENN ST APT 1 CARLISLE PA 17013 Defendant No. 14-4018 CV AT+}IRMATION OF NONMILITARY 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 108E PENN ST APT 1 CARLISLE PA 17013 and is not in the military service of the United States or its Allies other ise within the prov the Service Members Civil Relief Act and its Amendments. 16-07547 ert N. Polas, Jr., Esquire, #201259 Carrie A Brown, Esquire, #94055 Mark R Garvey, Esquire, #312686 Gregory J. Babcock, Esquire, #205061 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 State Report Pursuant to Servicernernbers Civil Relief Act Last Name: CUMMINGS First Name: DEBRA Middle Name: Active Duty Status As Of: Sep -29-2014 Results as of : Sep -29-2014139-19:07 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 theindividuals' active duty status based on the'Active Duty Status Date Left Active Duty Within 367 D s 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 dutystatus within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ::NA :. .. .No :. : .: NA This response reflects whether the individual or his/her unit has received early 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 itaierp1/4-