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HomeMy WebLinkAbout14-4443 S 'pmine Court Pennsylvania Cou f'omen Pleas ' a 1u\ For Prothonotary Use Only: TIME STAMI P Ci, 'lrfi,Sh�& eet Docket No: CUMBE' County �`/ ' 11V 6,441 3 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. Commencement of Action: S ®Complaint ❑ Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction ❑Declaration of Taking F C Lead Plaintiffs Name: Lead Defendant's Name: EPORTFOLIO RECOVERY ASSOCIATES,LLC PATRICIA REILLY T M I Are money damages requested`? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits O (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes N No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Came Brown/Mark R.Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Sel Litigant) Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your 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 ❑ Product Liability(does not include S mass tort) ❑ Employment Dispute: E ❑ Slander/LibeVDefamation Discrimination ❑ Zoning Board C E:] Other: ❑ Employment Dispute:Other E] Other: T I MASS TORT E] Other: O ❑ Asbestos N ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ To>dc Tort-DES ElE] Toxic Tort-Implant Ejectment ❑ Common Law/Statutory Arbitration B ❑ Toxic Waste E] mElEminent Domain/Condenation Declaratory Judgment E] Other: C] Ground Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONALLIABILTTY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 16-13523 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 ° i_w -(3 F 1 C Portfolio Recovery Associates, LLC 0€ T H E PR 0 T H O.N 0 TA]R%vi 120 Corporate Blvd Norfolk, VA23502 2014 JUL 30 PM 12` 10 TELE: 1-866-428-8102 FAX:(757) 518-0860 CUMBERLAND ������ PENNSYLVANIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CML ACTION-LA W PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. i1W3 Plaintiff, V. PATRICIA REILLY 208 ALLENDALE WAY 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 (717) 249-3166 16-13523 3 Of/ 7-2 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 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. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Demandado. NOTTCIA LISTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA,OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 16-13523 Esta conlunicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier infromacion sera utilizada para ese proposito. Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX:(757) 518-0860 Attorneys for Plaintiff IN TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA23502. 2. Defendant, PATRICIA REILLY, is an adult individual with last known address of 208 ALLENDALE WAY, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/CARE CREDIT on November 19, 2009 with account number ************7429(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 conn anication is frorn a debt collector-and is an attempt to collect a debt' Any information obtained will be used for that plu-pose. 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 March 4, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ CARE CREDIT 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$2,748.13. 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, PATRICIA REILLY,?inthe t of 2,748.13, plus costs of t action and any other relief as the Court deems just ann Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-13523 This connllrunication is from a debt collector and is an.attempt to collect a debt. Any infor7nation obtained will be med for that pLupose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, hereby states that he/she is authorized to take this verification on a'ley Garcia 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: JUN 17 2014 JU Shirley Garcia Custodian of Records 16-13523 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. .. . t�pJ B ILL 4 SALE .. ... .: PRA PSCC Fresh-:1Voyemiher 2013 For value received and'in.further consideration the mutual:covenants and.conditions set forth;in the. l+orward Flow Receiyaliles Purchase.Agreement(the"Agreement'');dated,as ofthis 9`�:day of July,2013 by and between Gene'' Electric Capital Co oration,GE Capital Retail Bank,,GEM9 LendingInc.;Mono am Credit :... .. Services;L.L:C.,RFS Holding,L;L.C.,,and GEM Holding,:LLC.*(collectively"Seller")and.Portfolio :.Recovery Associates,.LLC C'Buyer),S:eller.hereby transfers,sells;,conveys;grants;:and delivers to Buyer,At successors and assigns,Without recourse except as set forth in the Agreement,to the extent of its ownership;the Receivables as set.forth hi the.NotificatioriFiles(as defined in the Agreement);delivered:by;Seller to Buyer on. :.November 19,:2013,:and.as fiuther�described in the Agreement.: GE Ca' itai.RetailBank MonograM Credit-Services,- L.L.C'. By U� Ken Wojcik . Attorney in Fac en Wojcik: Title:- EVPCollections Recovery Date: Date: �0�. i a:-.( .: RF5:Hold ing;L.L.0 : General Electric Ca 'i a1;Corporation By: . .... . A . .. orney in Wojciit. . ... . . Attorney. Favi n Attorney,tn:Fact.. Wojcik Date:: :: Date: . . . GEM.Holding,L•L:C ; : . ... _ . .EMB Lending, . . Attorney in FacWojcik. :' ' Attorney in Fact n:Wojcik'. Date:. .. Date: ... . . . . . . . Fo rtfolio Recovery.Associates,LLC By: Title: :1'0y7/iP.+ . . M ,. . CARECREDIT/GECRB Cardholder Name: PATRICIA A REILLY Account Number:111.11IM7429 GE Capital Retail Bank Statement Closing + ++++++++++++++++++ +++++++++++++++++++++++ 9g� �i'++++++++++++:+�+orf i���1�ya.,.,..r..�...........,r,.,.,,t. Previous Balance $2,713,13 New Balance $0,00 + New Purchases $0.00 Taal Minimum Payment Due $801.00 Paymuents $0.00 Payment Due Date 10/11/2013 +I- Credits,Fees&Adjustments(net) $2,713.13- PAYMENT DUE BY 5 P.M.EASTERN ON THE DUE DATE. +/- Interest Char (net) 50.00 We may convert your payment into an electronic debit. See New Balance $0,00 reverse side. Credit Limit $4,00000 Available Credit $0.00 Late Payment Wanting If we do not receive your Total Days in Billing Period 28 Minimurn Payment Due by the Payment Due Date listed above, you may have to pay a late fee up to$35.00. Pay online for free at:gogecapital.com For GE Capital Retail Bank customer service or to report your card lost or stolen,call 1-866-89378W. Best times to call are Wednesday-Friday. Tom Date Post Date Reference Number Desdxiption Amount 10/09/2013 10/09/2013 F9072008000999990 CHARGE OFF ACCOUNT-PRINCIPALS S1.387.49 CR 10/09!2013 10/09/2013 F907200SUG0999990 CHARGE OFF ACCOUNT-FINANCE S1.360b4CR CHARGES" FEES 10/042013 10/04/2013 LATE FEE S35.00 TOTAL FEES FOR THISPERIOD $35.00 INTEREST CHARGED 10//92013 10/092013 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FORTHISPERIOD $0.00 t t t t t t t t t t ++++++i tM�Y+W'WYtiMlvht *;+;*++;+ ++++ 'i�1'i W Total Fees Charged in 2013 $235.00 Total Interest Charged in 2013 $416.90 Tom]Interest Paid in 2013 $300.00 ++ +t + +++++++++++++++++++++++++++++++++++++++++++t++++++++++ Expiration Date Annual BalanceSubject to !merest Charge Type of Balance Percentage Interest Rate Rate(APR) Crrent Transactions Purchases NA 26.99%(v) SO.001 $0.00 Tmnsactior on or before 12/282010 Regul.Traosactions I NA 22.98% 1 $0.001 $0.00 (v)=Variable rate .+.3.* tttt+itt+ttttttttttttttttttttttt+t+t+ttttttt tttttttt In order to protect youraccount privacy,we are unable to provide account information to anyone other than the cardholder(s)or an authorized party.If you wish to permit us to speak to an authorized party such as a spouse about your account,please send written authorization to the General Inquiries address •NOTICE:See reverse side and additional pages(if any)for important information concerning your account. 5302 DFH 1 3 9 131009 ZDPAGE 1 of 1 9072 3000 xA08 OIEJ5302 Pay online at gogecapital.com or enclose this coupon with your check.Please use blue or black ink. ; reCredit : •+ + + + +++ +++ +• 4• Payment Enclosed: $ .... . .. . New address ore-mail? payment due includes$0.00 past due.Please pay the past due amount PROMPTLY. Check the box at left and print changes on back PATRICIAA RE[LLY FFDFAFAFATDDAFTDDFFFDFATFAFFADATDDDFADFTDTFTATATAFTFFDAAFDDAFDTTA 208 ALLENDALE WAY CAMP HILL PA 1 701 1-8402 Make Paymentto: CE CAPITAL RETAIL BANK PO BOX 960061 ORLANDO,FL 32896-0061 TDFTFAFDATDFDTFAFFFAFATTDTAAFFADAAAFFDTTFTDFDTAFDFATAFAAAAFAAFDAD 7 429. Customer Service/Questions:For account information,please call the toll free number on the front of this statement.Unless your name is listed on this statement,your access to information on the account maybe limited.You may also mail questions (but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account number on any correspondence you send to us. Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www. gogecapital.com. Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekiva Springs Road,Longwood,FL 32779. Notice:See belowforyour Billing Rights and other important information.Telephoning about billing errors will not preserve your rights underfederal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando, FL 32896-5035. Purchases,returns and payments made just prior to billing date may not appear until next month's statement.When You provide a check as payment,you authorize us either to use information from your check to make a one-time electronic fund transferfrom youraccount or to processthe paymentasacheck transaction.When we use information from your check to make an electronic fund transfer,funds may be withdrawn from your account as soon as the same day we receive your payment and you will not receive your check back from your financial institution.You may choose not to have your payment collected electronically by sending your payment(with the remittance coupon),in your own envelope-not the enclosed remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address. What To Do If You Think You Find A Mistake On Your Statement: If you think there is an error on your statement,write to us at GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035. In your letter give us the following information: •Account information:Your name and account number •Dollar amount:The dollar amount of the suspected error •Description of problem:If you think there is an error on your bill,describe what you believe is wrong and why you be- lieve it iso mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing,You may callus,but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error,the following are true: •We cannot try to collect the amount in question or report you as delinquent on that amount. •The charge in question may remain on your statement and we may continue to charge you interest on that amount. But,if we determine that we made a mistake,you will not have to pay the amount in question or any interest or other fees related to that amount. •While you do not have to pay the amount in question,you are responsible for the remainder of your balance. •We can apply any unpaid amount against your credit limit. Information About Payments:You may at anytime pay,in whole or in part,the total unpaid balance without any additional charge for prepayment. Payments received after 5:00 PM(ET)on any day will be credited as of the next day.Credit to your account may be delayed up to five days if payment lal is not received at the payment address,Ib)is not made in U.S.dollars drawn on a U.S.financial institution located in the U.S..Ic)is not accompaniedbythe remittance coupon attached to your statement,(d)contains more than one payment or remittance coupon,(e)is not received in the remittance envelope provided or If)includes staples,paper clips,tope,a folded check or correspondence of any type.Conditional payments:All written communications concerning disputed amounts,including any check or other payment instrument that(1)indicates that the payment constitutes"payment in full"or is tendered as full satisfaction of a disputed amount,or fill is tendered with other conditions or limitations I"Disputed Payments"),must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896-5035. Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits will be applied to your previous balance immediately upon receipt,but will not satisfy any required payment that may be due. Credit Reports and Account Information:Hyou believe that we may have reported inaccurate information about you to a consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.in doing so,please identify the inaccurate information and tell us why you believe it is incorrect.If you have a copy of the credit report that includes the inac- curate information,please include a copy of that report.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. How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the'daily bal- ance"of your account for each day in the billing cycle. We then add the interest to the daily balance. To get the"daily bal- ance"we take the beginning balance of your account each day(which includes unpaid interest),add any new charges,and applicable fees,and subtract any payments or credits.This gives us the daily balance.Any daily balance of less than zero will be treated as zero.A separate daily balance will be calculated for each balance type on your account.The balances)shown in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by the number of days in the billing cycle. Bankruptcy Notice:If you file bankruptcy you must send us notice,including account number and all information related to the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell,GA 30076. Your account is owned and serviced by GE Capital Retail Bank. Hearing Impaired:TDD users call 1-877-448-8512 Use of Information About You and Your Account:Our Privacy Policy describes our collection and disclosure of information aboutyou and your Account.Ifyou would like another copy ofthe Privacy Policy,please call us at the customer service tele- phone number indicated on the front ofthis statement. This is an attempt to collect a debt and any information obtained will be used for that purpose. OlEJ5302-12-03/05/12 By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of your account contacting you about your account,including using anycontact information or cell phone numbersyou provide, and you consent to the use of any automatic telephone dialing system and/or an artificial or rerecorded voice when contact- ing you,even ifyou are charged for the call under your phone plan. For changes ofaddress or phone number,please check the box and print the changes below. Retail EN-OlEJ5302 Name ❑ Street Address City State Zip Code Home Phone# Business Phone# Cell It or other phone#we can use to contactyou Email Address Remember,you can update the above information as well as your e-mail address online at www.gogecapital.com Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F'!LED-OF FIC;L ;,,« [1F THE PROTHONO IAR ©FFiCE QF THE SRF.RIFF 2014 AUG -8 AN 1102 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Patricia Reilly Case Number 2014-4443 SHERIFF'S RETURN OF SERVICE 08/04/2014 04:54 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice and Scheduling Order by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia Reilly at 208 Allendale Way, Lower Allen, Camp Hill, PA 17011. DAWN KELL, DEPUTY SHERIFF COST: $45.44 SO ANSWERS, August 05, 2014 (C) CauftySuite Shoritt, Toleosofi. Inc. RON Z' 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. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Date: 16-13523 Defendant : No. 14-1113 Filed on Beh Counse PRAECIPE FOR DEFAULT JUDGMENT laintiff for this Party 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 CD 'yr 7-7 This communication. is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that pumose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW POR 11,OLI 0 RECOVERY ASSOCIA1ES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Defendant : No. 14-4443 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, PATRICIA REILLY, for failure to answer the Complaint. (X) Amount Due $2,748.13 Less Credits $.00 TOTAL $2,748.13 (X) (X) (X) 16-13523 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 PA R C.P.231.1, I certify that a written notice of intention to file thi praecipe was mailed or delivered to the party aga t whom judgment is to b ed and to his/her attorney of record, if any, afte default occurred and a en days prior to the date of the filing of this praec 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 corrununicationis from a debt collector is an attempt to collect a debt. Any information obtained will be used for that nurnose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Plaintiff No. 14-4143 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 $2,748.13. (X) A copy of all documents filed with the Prothonotary in suppoof th •ty • attached. If you have any questions regarding this No 16-13523 Robert N. Polas, Jr., Esquire, # 201259 Carrie A. 13rown, 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 PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 RE: PORIP OLIO RECOVERY ASSOC IES, LLC VS. PATRICIA REILLY 14-4443 Dear PATRICIA REILLY: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 16-13523 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 COUNFY, PA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Plaintiff No. 14-M13 Defendant TO: PATRICIA REILLY 208 ALLENDALE WAY 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. 16-13523 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Rqr 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. PATRICIA REILLY 208 ALLENDALE WAY CAMP HILL PA 17011 Defendant No. 14-1143 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 208 ALLENDALE WAY CAMP HILL PA 17011 and is not in the military service of the United States or its the Service Members Civil Relief Act and its Amendments. 16-13523 herwise within th ions of 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 Star R It Purse~ to Service -members +Civil. Relief Act Last Name: REILLY First Name: PATRICIA Middle Name: Active Duty Status As Of: Sep -17-2014 Results as of : Sep -17-2014 04:38:04 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA "' ...::. • o.. NA This response reflects the individuals' active du - status based on the'Active Du Status Date Left Active Duty Within 367 Days of Active Dirty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA "• No NA This response reflects where £he individual teti active duty status within 367 -days preceding the ActiveDuty Status Date The Mernber or HislHer 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 he individual or his/her unit has received early nolification 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 • TheDetense 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.milifaq/pis/PCO9SLDR.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: HDX8W727SOCDT40