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Home My WebLink About14-4020 Su��reme Cou o-f Pennsylvania Co urt�o f Common Pleas f,4 Q!r 1 4 ForProthonota Use Only: '1'wESTAMP Ci, I Cover,�S eet Docket No: CUMB :County The information collected on this fonn is used solely.for court administration purposes. This fonn does not supplement or replace thefiling and service ofpleadings or other a ers as required b;law or rules o court. S Commencement of Action: E M Complaint ❑ Writ of Sums ❑Petition C ❑Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Def'endant's Name: ,r PORTFOLIO RECOVERY ASSOCIATES,LLC KEVIN W KEADY I O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N .(Checkone) 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 Se]Litigant) 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) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T T ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco F1 Toxic Tort-DES REAL PROPERTY MISCIELLANDOLTS B ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Other: ❑ 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: 16-16096 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 /L Portfoli Recovery�AssociaABar#C312686 �3F TjIF- ��/CE- T„ 120 Corporate Blvd 2914 JUL _a � Norfolk, VA 23502 U� P'-' 1: 2 7 TELE: 1-866-428-8102 ERL,4 PjD FAX:(757) 518-0860 PEN, S}'L�COUNTY I Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC _ 120 CORPORATE BLVD I _ yva tyt NORFOLK, VA 23502 No. Plaintiff, V. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty(20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 S (717) 249-3166 16-16096 � & This communication is from a debt collector and is an attempt to collect a debt. 36 P193 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) 51.8-0860 Attorneys for Plaintiff IN TBE COURT OF COMMON PLEAS OF.CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK; VA 23502 Demandante, No. V. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Demandado. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted Aesea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar action 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 I.SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABA JO. 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 16-16096 Esta connu-ucacion es de un cobrador de deudas y es un intent do cobras Lina de.uda. C:ualquier infrom cion sera utilkida para ese proposito. • *tract ID:PRITH i MM082213 Document ID: 111113PR 1 TH 1 MMB l BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated November 27, 2013, 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 57117 (the 'Bank") to Portfolio Recovery Associates, LLC ("Buyer"), organized under the laws of Delaware, with its headquarters/principal place of business at 130 Corporate Boulevard,Norfolk,VA 23502. For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated August 22, 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 1 and the final electronic file. Citibank,N.A. By: (Signature) Name: Patricia Hall Title: Financial Account Manager PRA 082213.docx Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: HOME DEPOT CREDIT SERVICES PO Box 790328 St Louis MO 63179 r"P\'74SHOP amyhomedepotaccount.comANY TIME, P` Account Inquiries: x 4 i t s ANYWHEREI ONLINE MOME INSTORE 1-866-458-7683 ACCoI>If1t Nl Mbe(a 39: Summary of Account Activity Payment Information Previous Balance $1,448.76 New Balance $1,517.46 Payments -$0.00 Minimum Payment Due $572.00 Other Credits -$0.00 Payment Due Date April 18, 2013 Purchases +$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 +$33.70 Minimum Payment Warning: If you make only the minimum payment each New Balance $1,517.46 period,you will pay more in interest and it will take you longer to pay off your Past Due Amount $488.00 balance For example t x� Credit Limit $0.00 : . Available Credit $0.00 Only the minimum payment 13 years $3,103 Statement Closing Date 03/22/2013 $62 3 years $2,230 Next Statement Closing Date 04/21/2013 (Savings=$873) Das in Billing Cycle 31 it you would like information about credit counseling services,call 1-877-337-8188. Your minimum payment due is$572.00.To avoid interest charges on your non-promotional(revolving)balance and any expiring promotions,pay $1,517.46 by April 18,2013. If you pay your non-promotional balance in full every month,no additional billed interest charges will apply. Interest accrues daily from your statement closing date until we receive your payment,so please check your next statement for any additional interest you may have incurred. Please.see the enclosed privacy notice for important information. TRANSACTIONS Trans Date Description Reference# Amount FEES 03/18 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 03/22 INTEREST CHARGE ON PURCHASES $ 33.70 TOTAL INTEREST FOR THIS PERIOD $ 33.70 A HD td PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4 Page 1 of 6 This Account is Issued by Citibank,N.A. y Please detach and return lower portion with your payment to insure proper credit. Retain upper portion for your records. Your Account Number is-1739 P.O. Box 790393 St. Louis, MO 63179 Payment Due Date April 18,2013 New Balance $1,517.46 Past Due Amountt $488.00 Minimum Payment Due $572.00 Statement Enclosed Am 16 tPast Due Amount is included in the Minimum Payment Due Print address changes on.the reverse side Make Checks Payable tow HOME DEPOT CREDIT SERVICES KEVIN W KEADY PO BOX 182676 300 BEVERLY RD COLUMBUS,OH 43218-2676 CAMP HILL,PA 17011-2813 1739 - Information About Your Account. Proper Form.For a payment sent by mail or courier to be in proper form, How to Avoid Paying Interest on Purchases.Your payment due date you must: is at least 25 days after the close of each billing cycle.We will not charge Enclose a valid check or money order made payable to Home Depot you any interest on purchases if you pay your New Balance by the Credit Services.No cash,gift cards,or foreign currency please, payment due date each month.This is called a grace period on purchases• include your name and account number on the front of your cheek If you do not pay the New Balance in full by the payment due date,you or money order. will not get a grace period on purchases until you pay the New Balance in If you send an eligible check with this payment coupon,you authorize full far two billing cycles in a row. us to complete your payment by electronic debit.if we do,the If you have a balance subject to a deferred interest or 0%APR promotion checking account will be debited In the amount on the check.We and that promotion does not expire before the payment due date,that may do this as soon as the day we receive the check.Also,the check balance(the"excluded balance")is excluded from the amount you will be destroyed. must pay in frill to get a grace period.However,you must still pay any Copy Fee.We charge$5 for each copy of a billing statement that dates separately required payment ed the excluded balance.In billing cycles back 3 months or more.We add the fee to a balance of our choosing.We in(erre payments are allocated re deferred interest balances first,the reserve the right to add this fee to balances subject to a higher annual deferred interest balance will be reduced before e p other balances the percentage rate.We waive the fee it your request for the copy relates account.However,you will continue to get a grace period on purchases so long as you pay the New Balance less any excluded balances in full by the to a billing error or disputed purchase. payment due date each billing cycle.We may refer to deferred interest Payment Options Other Than Regular Mail. promotions as No Interest promotions. Online Payments.Visit m,y.hornedepotaccount.com and sign up for In addition,certain promotional offers may take away the grace period on free online payments.Enrollment may take a few days.If we receive purchases.Other promotional offers not described above may also allow your request to make an online payment by 5 p.m.Eastern time,we you to have a grace period on purchases without having to pay will credit your payment as of that day and it will post within three all or a portion of the promotional balance by the payment due date. business days.If we receive your request to make an online payment If either is the case,the promotional offer will describe what happens_ after that time,we will credit your payment as of the next day and it How We Calculate Your Balance Subject to Interest Rate.For each will post within three business days.For security reasons,you maybe . balance,the letter following the Annual Percentage Rate in the Interest unable to pay your entire New Balance with your first online payrnen£, Charge Calculation section on the front of the statement indicates the AutoPay Service.if you are enrolled in this service,your payment method we use to calculate interest charges.For Methods C,H and M, amount will be deducted automatically each month on your due date we use a daily balance method(including current transactions)to from the bank account you select. calculate interest charges.For Methods I and L,we use an average Pay by Phone Service.You may use this service any time to make daily balance method(including current transactions)to calculate a payment by phone,if your account is eligible.You will be charged interest charges.For Method K,we use an average daily balance method $14.95 to use this service if a representative of ours helps expedite (excluding current transactions)to calculate interest charges.To find your payment.Call by 5 p.m.Eastern time to have your payment out more information about the balance computation method that credited as of that day and posted within three business days.if you applies to your account and how the resulting interest charges were tali after that time,your payment will be credited as of the next day determined,contact us at Customer Service number on the front. and posted within three business days.We may process your payment Important Payment instructions. electronically after we verify your identity. Right to Prepay Your Account.You may pay all or part of your account Express Payments.You can send payment by courier or express balance at any time.However,you must pay,by the payment due date,at mail to the Express Payments Address.This address is:Customer least the minimum payment due. Service Center,Attention:Payment Mail Opening,1500 Boltonfield St., Columbus,OH 43228.Payment must be received in proper form at the Crediting Payments.If we receive your mailed payment in proper form proper address by 5 p.m.Eastern time to be credited as of that day. at our processing facility by 5 p.m.local time there,it will be credited as All payments received in proper form at the proper address after that of that day.A payment received there in proper form after that time will time will be credited as of the next day. be credited as of the next day.Allow 5 to 7 days for payments by regular in-Store Payments.For your added convenience,payments can be mail to reach us.There may be a delay of up to 5 days in crediting a made at The Home Depot stores,with no service fee.Any payment payment we receive that is not in proper form or is not sent to the correct in proper form accepted in-store will be credited as of that day. address.The correct address for regular mail is the address on the front However,credit availability may be subject to verification of funds. of the payment coupon.The correct address for courier or express mail is the Express Payments Address in the Express Payments section. PLEASE_SEE IMPORTANT INFORMATION ON PAGE 4 HD-2 JAN13 Page 2 of 6 Change of Address Print address changes in blue or black ink. VE `AMPS PS, Tfl . AND TREE Register now for Paperless Statements and more at myhomedepotaocoount.00m Account: *'`** **** *'`** 1739 'v M'fp La { 4'" r e+'„yds,y,.r. it�1S,* t' 4VTL �.. �:..��19...�._t��+i�.L'_:.•�s!dd'i`4.f r�.:i: Total Fees Charged in 2013 $105.00 Total Interest Charged in 2013 $94.38 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your,account. -64 ew♦ ,.�..k�y ..^.r 4 w X,.".U�$�( CB ..4 .:rtV..+..f �i.f '`'� A� .�+t�'i �fi�V1' Yti' ^�;ta'.ke' . 'f 4k..•h j'-R7F�1a GMli �i, G5 11W b t17. PURCHASES Revolving Balance 26.99% M $1,470.59 $33.70 Page 3 of 6 Credit Reporting Disputes.If you think we reported inaccurate After we finish our Investigation,one of two things will happen: information to a credit bureau write us at the Customer Service address If we made a mistake:You will not have to pay the amount in question shown on Page 1. or arty interest or other fees related to that amount. Report a Lost or Stolen Card Immediately.Call the Account Inquiries If we do not believe there was a mistake_You will have to pay the number shown on Paqe 1. arnount in question,along with applicable interest and flees.We will What To Do If You Find A Mistake On Your Statement send you a statement of the amount you owe and the date payment If you think there is an error on your statement,write to us at the is due.We may then report you as delinquent if you do not pay the address for billing inquiries and correspondence shown on Page I amount we think you owe. of your statement. If you receive our explanation but still believe your bill is wrong,you In your letter,give us the following information: must write to us within 10 days telling us that you still refuse to pay. If you do so,we cannot report you as delinquent without also reporting • Account information:Your name and account number. that you are questioning your bill.We must tell you the name of Dollar amount:The dollar amount of the suspected error. anyone to whom we reported you as delinquent,and we must let those • Description of problem:If you think there is an error on your bill, organizations know when the matter has been settled between us. describe what you believe is wrong and why you believe it is a mistake. If we do not follow all of the rules above,you do net have to pay the You must contact us: first$50 of the amount you question even if your bill is correct. Within 60 days after the error appeared on your statement. Your Rights if You Are Dissatisfied With Your Credit Card Purchases At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goods or services that you have,purchased if you want to stop payment on the amount you think is wrong, with your credit card,and you have tried in good faith to correct the You must notify us of any potential errors in writing.You may call us, problem with the merchant,you may have the right not to pay the but if you do we are not required to investigate any potential errors and remaining amount due on the purchase. you may have to pay the amount in question. To use this right,all of the following must be true: What Wlil_Hap n After We Receive Your Letter 1. The purchase must have been made in your home state or within 100 When we receive your letter,we must do two things: miles of your current mailing address,and the purchase price must 1sof receiving have been more than$50.(Note:Neither of these are necessary it . Within 3Q days g your letter,we must tell you that your purchase was based on an advertisement we mailed to you,or we received your letter.We will also tell you if we have already if we own the company that sold you the goods or services.) corrected the error. 2.Within 90 days of receiving your letter,we must either correct 2.You must have used your credit card for the purchase-Purchases made with cash advances from an ATM or with a check that accesses the error or explain to you why we believe the bill is correct. your credit card account do not qualify. While we investigate whether or not there has been an error: 3.You must not yet have fully paid for the purchase. We cannot try to collect the amount in question, if all of the criteria above are met and you are still dissatisfied with the or report you as delinquent on that amount. The charge in question may remain on our statement, purchase,contact o in writing at the address for billing inquiries and 9- Y Y correspondence shown on Page 1 of your statement. and we may continue to charge you interest on that amount. While we investigate,the same rules apply to the disputed amount as While you do not have to pay the amount in question, discussed above.After we finish our investigation,we will tell you our you are responsible for the remainder of your balance. decision.At that point,if we think you owe an amount and you do not We can apply any unpaid amount against your credit limit. pay,we may report you as delinquent. KEY CREDIT TERMS-NO INTEREST IF PAID IN FULL WITHIN 6 MONTHS*.$299 minimum purchase required.Minimum payments required. Interest will be charged to your account from the purchase date if the purchase balance(Including premiums for optional credit insurance)is not paid in full within 6 months or if you make a late payment. "With credit approval for qualifying purchases made on The Home Depot or EXPO Design Center Consumer Credit Card,17.99%-2699%APR. Minimum interest charge$2.See card agreement for details including APR applicable to you.Offer is only valid for consumer accounts and is subject to change without notice. T02918-9196-0400.0001-E-9-X--09/01/01-52-116-P-B-0--7-8-0-NOPLAY-TE-02/21/12-HAMB-February 19,2013-0-0 N--- PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 HP-4 JAN13 Page 4 of 6 01/13 075 M A, U WHAT DOES CITIBANK DO WITH 3YOUR PERSONAL INFORMATION? 6 _ .. ........ .... .. .. ..._. ......... ... ...... .... . <, Financial companies choose how they share your personal information. �i n.• Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect R your personal information. Please read this notice carefully to understand what we do. ... .... r 'x The types of personal information we collect and share depend on the product or service you have with us. This information can include: j • Social Security number and income •account balances and employment information •credit history and transaction history All financial companies need to share customers' personal information 4 to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information;the i reasons Citibank chooses to share, and whether you can limit this sharing --Ex —El-ME�M, I M 01 1��M�M- M �M For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court Yes No orders and legal investigations, or report F to credit bureaus For our marketing purposes — to offer our products and services to you Yes No _..._.. -- --- _..._ . For joint marketing with other Yes No financial companies ............ .... .... .... .... .>......._......._.. ..._. __ . .. .__. ._.. For our affiliates'everyday business purposes — information about your Yes No transactions and experiences _..._.. _ ... ................ ............ _. _. ............ ............ ........... .... .... ........ . . For our affiliates' everyday business purposes — information about your Yes Yes creditworthiness 'For our affiliates to market to you Yes Yes ....._................................................. ..................... ._................................................................ ....:........ .............. ....................................................._.... .... ................................................................................ : For our nonaffiliates to market to you Yes Yes .... ...... ......... .... ..... u � Call ...1-877-491-0607...—.our menu will prompt .you .through your choice(s). Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we i continue to share your information as described in this notice. However, you can contact us any time to limit our sharing. ' "a Call 1-877-491-0607 or call the Customer Service number on the back of � your credit card or on your billing statement. ............ . ... ........ . ...................... ..........................-................ ............. ..... Page 5 of 6 01113 076 Who is providing You are receiving this notice from the retail partner cards group of this notice? 'Citibank, N.A., the bank that issues your credit card. ........... ............ ...... . . ......_. __ .... How does Citibank 1 To protect your personal information from unauthorized access and use, we protect my personal �use security measures to comply with federal law. These measures include Information? computer safeguards and secured files and buildings. How does Citibank We collect your personal information,for example, when you collect my personal • provide account information or give us your contact information information? • provide employment information or apply for a loan • use your credit or debit card i We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. Why can't I limit 'Federal law gives you the right to limit only ;all sharing? • sharing for affiliates'everyday business purposes — information about your creditworthiness •affiliates from using your information to market to you • sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. ;Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. •Our affiliates include companies with a Citi name,financial companies such as Citigroup Global Markets Inc. and Banamex USA. ...... .. ........................ .._. .... ....... ..... ...._._.... . . ................... .... ...... .. . ..... ......., Nonaffiliates Companies not related by common ownership or control.They can be financial and nonfinancial companies. •Nonaffiliates we share with can include companies engaged in direct marketing and the selling of consumer products and services. ......... .. ........................................ . ...... ...................................... Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products and services to you. ....... _. ...._. ......... ......... .. . ........ .... ....... .. ._......... _ I For Vermont Residents: We will not share information we collect about you with nonaffiliated third; parties, except as permitted by Vermont law, such as to process your transactions or to maintain your; account. In addition,we will not share information about your creditworthiness with our affiliates except with your authorization. For California Residents: We will not share information we collect about you with nonaffiliated third parties,except as permitted by California law, such as to process your transactions or to maintain your ;account. ............. .......... _. .................. .. ........ __.. ............... ......... .. . .... We may share your personal information, as permitted by law,with the retailer whose name is on your card and with the companies related to the retailer.You cannot limit this sharing. _....... .......... .... ....... .. . ..... .. ........ _ _..... . . . ....... _ . ....... . Important Information about Credit Reporting We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. ............ ................................. .......... .. .. ...... .. ........ ....................... ............. . . ...... . ................................... Page 6 of 6 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY y-,} F !C. O! ,l HE PROT HONOTAR 'i` OFF!GE OF THF EHFRJFF 2614 JUL 31 All 10: 38 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Kevin Keady Case Number 2014-4020 SHERIFF'S RETURN OF SERVICE 07/18/2014 07:16 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Kevin Keady at 300 Beverly Road, Camp Hill Borough, Camp Hill, PA 17011. DENN FRY, DEPU't SHERIFF COST: $44.95 SO ANSWERS, July 21, 2014 (r.) Couf:tySuile Sheriff: Teieoso`t Inc. RONW 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. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Date: IOPP 16-16096 No. 14-4020 CIVIL PRAECIPE FOR DEFAULT Defendant : JUDGMENT Filed on o Co f Plaintiff ecord for this Party ///. Ro.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) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff C) (of a 60 44( alf-J Ses0 7y)/ 3 111 sa 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. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Defendant No. 14-4020 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, KEVIN W KEADY, for failure to answer the Complaint. (X) Amount Due $1,517.46 Less Credits $.00 TOTAL $1,517.46 (X) (X) (X) 16-16096 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 PA.RC.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 party _.m:t whom judgment is to be red and to his/her attorney of record, if any, . • e the default occurred and at ten days prior to the date of the filing of this prco o e + ice shed. 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 used for 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. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Plaintiff No. 14-4020 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 $1,517.46. (X) A copy of all documents filed with the Prothonotary in suppo7tSof the jnt is/are attached. If you have any questions regarding this Notice, p 16-16096 R6rt 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. 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 2, 2014 KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. KEVIN W KEADY 14-4020 CIVIL Dear KEVIN W KEADY: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 16-16096 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 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. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Plaintiff No. 14-4020 CIVIL Defendant TO: KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 DATE OF NOTICE: September 2, 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. 16-16096 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. KEVIN W KEADY 300 BEVERLY RD CAMP HILL PA 17011 Defendant No. 14-4020 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 300 BEVERLY RD CAMP HILL PA 17011 and is not in the military service of the United States or its Allies, or o within the provisions of the Service Members Civil Relief Act and its Amendments. 16-16096 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) (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 Sta.tus Report t to Servicernembers Civil Relief Act Last Name: KEADY First Name: KEVIN Middle Name: W Active Duty Status As Of: Sep -17-2014 Results as of : Sep -17-2014 04:06:32 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .. .. ...::;.No. NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Adige Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA . . :NA .. No NA This response reflects where the individual left active duly 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 fire individual or his/her unit has received early notifu:atianit, 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 Soldiersand 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.milffaq/pis/PCO9SLOR.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: CDE4W7F710CBQD0