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Home My WebLink About14-4050 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: DV v Cumberland County lq� The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action- R] Complaint ❑ Writ of Summons ❑ Petition S ElTransfer from Another Jurisdiction E] Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: LOUIS KEPES C PORTFOLIO RECOVERY ASSOCIATES LLC T Dollar Amount Requested: ® within arbitration limits I Are money damages requested. Is Yes No (Check one) El outside arbitration limits 0 N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: Syretta Martin, Frank Janello, Beth Arnold Howell/Greg Dye ❑ Check here if you have 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 Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability (does not include ❑Employment Dispute: mass tort) C ❑ Slander/Libel/Defamation Discrimination T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board 1 ❑ Other: 0 N ElOther: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111120 2829906 PPTXCPRI(05/06/2014) 11111111111111 IIII 11111111111111 VIII VIII VIII VIII VIII VIII IIII VIII IIII Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, 1835 Market Street, Suite 501 PORTFOLIO RECOVERY ASSOCIATES LLC Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC r ,F c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEASO. 1835 Market Street, Suite 501 n, Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION C No. LOUIS KEPESi G '' 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 S �Id37S�a - 2829906 lmlxq PPTNPRAI (04/24/2014) 12 y- WzLi I IIIIIIII VIII IIII IIIIII II VIII)VIII VIII VIII VIII VIII VIII IIII VIII IIII AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 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. LOUIS KEPES 356 PARK AVE NEW CUMBERLAND PA 17070 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(s), LOUIS KEPES, is/are an adult individual with last known address of 356 PARK AVE NEW CUMBERLAND PA 1.7070. 3. It is averred that Defendant(s) opened an account on 10-24-07 with account number XXXXXXXXXXXX6442 (hereafter referred to as "Account"). A copy of the charge-off statement is attached hereto and collectively marked as Exhibit "A". 4. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 2829906 PPTCPRAI (05/27/2014) 1111111111111 IIII 11111111111111 VIII 11111 VIII VIII VIII VIII IIII VIII IIII 5. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 6. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 7. Defendant(s) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 12-04-2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest of GE CAPITAL RETAIL BANK and Plaintiff is now the holder of the Account. A true and correct copy of Plaintiff's Verification is attached hereto. 9. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $2000.59. 10. Despite reasonable and repeated demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) LOUIS KEPES, in the amount of $2000.59, plus costs of this action and any other relief as the Court deems just and reasonable. Respectfully Submi , ZZDated: yretta Marti sq. PA Bar 4#309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 Attorneys For Plaintiff BHLM REF #: 2829906 VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Yvette M.Stephen hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: By:MN 17 2014 ►�}'► , ,rl � Yvette M.Stephen. Custodian of Records BHLM REF #: 2829906 PPTXPVRI (05/27/2014) Exhibit " A " 2829906 PPTXEXAI ( 04/17/2014 ) PEACH DIRECT/GEMB Cardholder Name: LOUIS R KBPB GE Mone Account Ninber: 6442 Money Statement Closing Cote: 06/14/2011 Previous Balance $1,965.59 New Balance --------- $0.00 + New Purchases $0.00 Total Minimum Payment Due $506.00 Payments $0.00 Payment Due Date 06/15/2011 +y- Credits,Fees&Adjustments(rtet) $1,965.54 PAY1ENT DUE BY5P.M.EASTERN ONTHE MEDATE +/- Merest Charge net $0.00 We may convert your payment into an electronic debit.See New Balance $0.00 reverse side. Credit Limit $2,000.00 Available Credit $0.00 Late Payment Warning:y we do not receive your Total Days in Billing Period 29 Minimum Payment Due by the Payment Clue Date listed above, you may have to pay a late fee up to$35.00 and your APRs Pay online for free at:www.gemoney.com may be increased to the Penalty APR of up to 26.9909/6. For GE fvbney customer service or to report your card lost or stolen,call 1-866-3911 Best times to call are Wednesday-Friday. t*+l+ftItl+l+l+ftl+tt4+l+l+++l+l+l+l+l+l+i+l+l+lt4t! Tran Date Post Date Reference Number Description Amount 06/14/2011 06/14/2011 F9071005500999990 CFKRGEOFFAOCOLNT-PRNCPALS $1,423.60 OR 06/14/2011 06/14/2011 F9071005500999990 CHARGEOFF ACCOUNT*RNANCE $576.99 CR CIA RGW FEES 06/10/2011 06/10/2011 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INf6iEST CHARGED 06/14/2011 06/1412011 INTEREST CHARGEON PURCHASES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 !+l++tr+l+ Total Fees Charged in 2011 $210.00 Total Interest Charged in 2011 $162.22 Expiration Date Annual Balance Subject to Interest Charge Type of Balance Percentage Interest Rate Rate(AFF/) Purchases N4 21.981/6 $0.00 NOTICE:See reverse side and additional pages(if any)for important information concerning your account. 5302 cxR 1 5 13 110614 2x PAGE 1 of 1 9071 1200 PD03 OlEJ5302 Pay online at 9emoney.com or endose this coupon with your check.Phase use blue or black Irk. — + + + + +!+ +!+ +! ! $506.00 1 $0.00 06(1s2011 1 $0.00 6442 PaymentFndosed: $ 110000. ❑❑ ❑Nowaddrass or e-mall? Payment due includes$0.00 past due.Please pay the Pastdue amount PROMPTLY. Check the box at left and print than ges on back DFTFFAAAADDTDFFADFATFFDTDATDFAADFAFFFDADFAFTTDTTAFADFTDAFADTATTTF LOUIS R KEPES 358AVE Make Payment to: GEM(EY BAN( hEW CUfCUvHBaLAPD PA 17070-1338 fb BOX 960061 ORA NDO,FL 32896-0061 ADFDFDDAATAFAFADDATFDDDADATDFAAAFDADFAAFFFAFFTFDFFATTFFFIFFATAFDTA 6 442 Monte%rWoYQuestlonxlor acoount information,please call the toll free number on the front of this statement.Unless your names listed on this statement,your access to information on the account may be limited.lbu may also mail questions put not pay merns)to:P.O.Bot1181127,EI PBso,TX79998-11 D.Rease include your account numberon any correspondenceyou rend to us. F9ymentx Sind payments to the address iced on the remittance coupon portion of this statement or pay online at vvwwaerraneu.com Overnight Payments:payments cannot be made in person,mai payments to:GEMoney Bank.140 Welilva Sprin gs fbad,Longwood, FL32779 Notlw:See below for your B11 Ing Rg his and other Important tnformation.Telephoning about billing errors wli not preserve your rights under federal law.Topreserve you rrights,pleasewdtetoor rBding InquiriesAddress,PO.Box 981438,B Paim,TX79998-1438. Rachases,rerurns and pay meets made just prior to filling datemay not appear until next month's st element.We reserve the right to obtain payment electronically for any check or other instrument that you send to us by initiating an PGH(electronic)debit in the amount of your check or instrument to your account.lbur checkor instrument will not be returned to you by usor your bank.Your bank account maybe debited as early as the same day we receive your payment.You may choose rot to have your payment collected electronically by sending your payment(with the remittance coupon),in your own envelope Ono(the enclosed remittancoenvolope,addressed to:PO Box 640960,Atlanta,CCA 30353.0960 and not the payment address. WhW To Do ill Nur Th/t*You Hnd A Afstake On ibtr 3atemaniNt you think theta s an enc on your statement,write to us at GE Money Bank,P.O Box 981438,B Paso,lX 79998.1438.ln your letter give us the following Information:.Ancount informadom Ybur nameandaccoum number.War amount:Thedoiar amount ofthe snspecederrer.ibwiptionofprobtem1f youthinktheresan erroron your bill,descrbewhat you believe iswrong and why you bdieveit is a mistake.You must contact uswa hin 60 days after the error appeared on your statement.Ybu must ratify us of any potential enors in wriina.You may cal us,but it you do we are not required to investig ate any potential errors and you may have to pay the amount in question.While we investigate whether or not I herehasbeen an error,the f oll owing are true: We cannot try to ooiact the amount in question or report y cu as delinquent on that amount..The charge in question may remain on your statement and we may cont in ue to charge you interest on that amount.But,8 we determine that we made amistalaa,you will not have to pay the amount in question or any interest or other fees related to that amount..White yon do not have to pay the amount in question,you are responsible for the remainder of your balance..We can appy any unpai da mount against your crack limit. Your Aglhts N YouAneDlssaffstiod With Your Credit GbrdFirdnasec If you are dissatisfiedwith the gook or servicesthat you have purchasedwith you rcredit card,and you have Idedingood faith to correct the problem wk h the merchant,you may have the right not I o pay therema ining amount due on the purchase.To use t his right,al of t to following must betrue:1)The purchase must have been made in your lame state orwft hin 100 miles of your current malting ad dirmandthepurchase price must have been more than$50. (Note:Neither of these are necessary 8 your purchase was based on an advertisement we mailed to you,or Uwe own t he comparry Ihat sold y the ggoodsoservices.)2)Ybumust have used your credit card for the purchase.Wrchasesmade with cash advances from an A1M erwth a check that accesses your cred 4 card account do not quafrfy.3)You must not yet have fullyy paid fortheppuu rchase. If all of the criteria above are met and you are still dissadstiedwith thepurchase,contactusinwrn at:P.O.Bax981438,BPasoTX 79998-1438.While weinvest gate,the same rules appy to the disputed amount as discussed above.Paan wef idsh ours mast igRon, wewill tall you our dacision.At that point,ff wethinkyou owean amount and you do rot pay we may report you as dklnquem. Inlbmet/onAbout Flo yrrerdx Ibumay pay moa than the Tota/MlnlmumPaym nt,at any time Payments received after 500 PN1 FI)on any day will be credftedasof the next da Crerit to your account mayy beddayed up tofivedaysifpayment(a)srot received at Ihepaymentaddress,WsnotmadeinU.SdolffarsdrawnonaU.Sfhhancialinstitutionlocatedinthe 3,O)snotaocompanledbythe ramittance,cokpon attached to your statement,(d)containsmore than one payment or remittance coupon,(a)is riot received in the remittance envelope provided orb)includes staples,paper dps,tape,a folded check or correspondence of any typa Conditional At written conmunk:ations concerning disputed amounts,including any check or other payment Instrument that:() in dictates that the pay ment constitutes(payment in tui-br is tendered astuil satisfaction of a di uted amount,o(�i)sterdered with othercondtions o limitations COsputeclPayments'l must be mailed or delivered to us at PO Box 61438,8 Paso,1X79998-1438. C?edts to Your Accoknt:An amount shown with a CRnext to the amount isa credit or credit balance unless otherwise indicated. Oeditswill be applied toyour previousbelanceimmediately upon recefpt,but will not satisfy any required pay main that may be due. Telephone IWnitoring:For quality control purposes,you permit usto listen to or record telephone Cels between you and us. Credit Fieportsand Account Irhformation:lf you believe that wemay havereportad inaccu ratoinformation about you to a consumer- reporting agency,ploase contact u sat P.O.Box 981439,B Paso,TX79998-1439.In dicing so,pleasefdemiy,the inaccurate information and tell uswhy you believe it is incorrect.Ifyouhaveaonpyof the credit report that fnclydestheinamurateinfomation,please includo a copy of that report.We may retort information about your account to credit bureaus.Late payments,m&sad payments or other defaults on your account maybe reflected in your credit report. Variable Hato Information if any of your APFtsam variable,that APRwii vary with the market based on the Rime Rate. How Long WlllthaPartaltyFBteApply7l your APFtsare increasedbecause you made a Iatepayment,t he Fbnalry APRwill apply until you make saconsecutiveminimrm paymemswhendlue. Now We QvIculate Interest:We urea methodcaled-daily bale rce rOuring burg cycles in wh bhi merest I scharged,foreachbalanoe type on your account we figure the interest charge on your account by applying the periodic rate to the[daily balance:of your aco crit for each day in the billing cycle.A separate daily balance will be cakvtated for the foiowirig balance types as applicabla: purchases,balance transters.cash advances and dither balances that are subject to different interest rates plans or special promotions.First,wedetermfnethe-laitybefence 7Modeterminetledeiybalance,wetakelhebeginning balance each day,addafry new charges and fees posted That day,and subtract any payments and credits posted that day.This gives us the daffy balance. Second,we calculate the amount of Interest charged.To do this,we mut ipy the applicable daily rate by each dally balance on your account.Thid,we add the interest amount to the dallyy bala rce,andthe sum will becomethe beginning balance for the fdbwtng dlaYy. Yourinterest charge for thebi lig cycle sthe sum of the Interest amourttsthat warecharged each day during thebii ing cy deforeach baiancetype.We charge a minorum of$2 of interest in anybfn mg cycle in which you owe interest. Payfngfnteosl:Your due dateisat least 23 day safter theclose of each billing cy de.We will not ch ageyou any interest on purchases it you pay your entbebalanca by the duedateeach rnont h W ewii begin charging interest on cash advances and balance transfers If appicab lo,on tha transactiondate. Banlciptcy Notice If you file bankrWcy you must send us notice,including account number and all information related to the proceed rig tothef olowirg add rens:Cf Money Back,Atm:Bankruptcy Dept,PQ Box 103106,Fbsvei,GA30076. Your account IsovnedandmirdcedbyGEMoneyBar*. For complete terrrsand conditions ofyour account,consult your Credit CarclAgreement. Hearing Irrpalred:TDDusers call 1-877-448-8512 01615302-e•da/Ydte Lhe of InrtormationAbow lbuiend WurA000unw:Cir Rivacy Policy describes our collection and disclosure of information about you and your Account.If you would like another copy of the Privacy Policy,please call us at the customer service telephone number indicated on thefront oft his statement. TNsis an attempt to collect a debt and any Information obtained will be used for that purpose. By providing a telephone number on my account.I consent to(EMoney Bank and arry other owner or servicer of my account contacting meabolA my amount,includngusng any contact information orceiphone numbersl provide,and[consent totheuseof uyautryparie an.ne dialing_systemand/oranartifioalor rerecorded voicewhencontacting meevenifIamcharged for the call For changes of address,phone number and/or email,please check the box and print the changes below or visit us on-line at w.ttwgemoney ccm. gine ❑ 9ree Adder SYS. Rgnea Erna1 w,waw. ewn.sevn. kagmnoa aiorpve. en.n.aa.. r.an uwtomnrs,p. BYFiXMDNG1t7URBv1A1LADDRBiSKUAL#ifTOP� %EBMLCCWANIC411CNABCLITKXJRAOCXWANDAL90C9VE FB7v1S9CN FCR LJS10 PFKM DEYQJRBAAL ADDFE%101FE DBALIPMM134ANT/Rt0VDERRETNLBi AO>EPrIINGY1Ql1RCAFID Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 .�,. Greg Dye, Esq. PA Bar #205316 fJ PPS 110ti {Ait Blatt, Hasenmiller, Leibsker & Moore, LLC JUL 1835 Market Street, Suite 501 f Q PA 19103 C��B �,41� Philadelphia, ��i TELE: 215-564-1567 FAX: 215-564-3818 PENNsy � OUNTY PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION f� v l LOUIS KEPES vs. No. 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLER, EIBSKER & MOORE, LLC ZDated: ✓ / By:. retta Mar ' sq. PA Bar #309370 Ja Frank n Ilo, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 Attorneys For Plaintiff 2829906 PPTXPEAI (05/12/2014) 1111111111111 IIII 11111111111111 VIII VIII VIII VIII 11111 VIII IIII VIII IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson{ b—OF r i Sheriff (i f' THEPROTH0 0 i i ' q,tn of �irinLrr�� 2014 JUL 31 AM 10' 38 Jody S Smith Chief Deputy Richard W Stewart Solicitor } CUMBERLAND COUNTY OFF ICE OF THE SHERIFF PENNSYLVANIA Portfolio Rocovery Associates LLC c/o Blatt, Hasenmiller, Leibsker & M vs. Louis R Kepes Case Number 2014-4050 SHERIFF'S RETURN OF SERVICE 07/18/2014 05:45 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: Louis R Kepes at 356 Park Avenue, New Cumberland Borough, New Cumberland, PA 17070. DENNI FRY, DEPU SHERIFF COST: $47.21 SO ANSWERS, July 21, 2014 RONNY RR ANDERSON, SHERIFF (c) CountySuito Sheriff, Teleosoft. Inc. Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq, PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher Alan Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 L, ri,, 217P4 I' • cu 2• C • -4 ; is PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 VS. LOUIS KEPES Plaintiff, 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-4050 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant LOUIS KEPES in this matter in the amount of $2,000.59 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 08-19-14 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: November 17, 2014 By: 1P 2382J906 FJ I (09/16/2014) 11111111111111111111111111111111111111111111111111111111111111110111111 Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC S ret a Martin, sq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 4 (ifio paA, Ctlk /b(poSt -Nb.\\LeMa4el j4-3137/ PORTFOLIO RECOVERY ASSOCIATES LLC VS. LOUIS KEPES Plaintiff, 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 14-4050 CIVIL TO: LOUIS KEPES NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 1P 2:)8211I1\90D6JN I (09/16/2014) MEE 111111 1111HE III11111111111111111111111111111111111111111III1 1111 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. LOUIS KEPES Plaintiff, 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-4050 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE I, attorney for Plaintiff, states: 1. That the Defendant(s) is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; 2. The statement that Defendant(s) is not on active military service is based upon Defendant(s) Military Status Report pursuant to 50 U.S.0 App. Section 521, 525 which was obtained from Plaintiff's undersigned counsel's firms search of the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scra/scraHome.do). See Defendant(s) Military Status Report attached hereto. 3. That the Defendant(s) LOUIS KEPES is (are) older than eighteen (18) years of age. 4. That the employment status of the Defendant(s), LOUIS KEPES is (are) unknown. 5. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. 1P 2'821?J9,‘M I (09/05/2014) 1111111111111111111111111111111111111111111111111111111111111111111111 MI I affirm under penalties of perjury that the foregoing representations are true and correct. Dated: fRi SUBSCRIBED AND SWORN Before me this 17 day of A4uemker , 20 Pf Public 7661;) By: BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Sy etta Martin, sq. PA Bar #309370 Frank Janello, sq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kam i S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 COMMONWEALTH OF PENNSYLVAN NOTARIAL SEAL MATTHEW MAJESKI, Notary Public City of Philadelphia, Phila. County y COITIII3SiOil Expires June 27, 2018 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Department of Defense Manpower Data Center Stat R►l rt Prs�t is Se lean Cirri. Relief Act. Last Name: KEPES First Name: LOUIS Middle Name: Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17-2014 04:54:18 AM SCRA 3.0 On Active Duty On Active Duty Status Dale Active Duty Stsrt Date Active Duty End Date Status Service Component NA NA .: -"- - - No' ' . NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ._ - e_ / -No"' NA This response reflects where the IndMdual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu a Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .' NA, ' • NA This response reflects whether the individual or his/her unit has received early notlfication 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: TFP9564AX036C30 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, Vs. LOUIS KEPES 356 PARK AVE NEW CUMBERLAND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 14-4050 CIVIL TO: LOUIS KEPES Date of Notice: August 1% 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 This is a communication from a debt collector. obtained will be used for that purpose. 2829906 PPTNLRSI (05/13/2014) 1 11111111111E111111111111111111111111111111111111111111111111111 By: BLATT, HASENMILLER, ,Bj=T� ER & MOORE, LLC Syretta M - n, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 This is an attempt to collect a debt and any information