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HomeMy WebLinkAbout14-4448 Supreme Co�ttgo sylvama CourOf. ,Comm n Pleas f��s!� r -�f For Prothonotary Use Only: 1'(ti(I.S"fANIP CiV11¢ O Veet Docket No: CUMB $ County The inforination collected on this form is used solely for court administration purposes. This form does not supplement or replace the lin and set-vice ofpleadings or other a ers as required by law or rules o court. Commencement of Action: S ®Complaint ❑ Writ of Summons ❑Petition E ❑ Transfer fromAnotherJurisdiction El Declaration of Taking C Lead Plaintift Name: Lead DeEndant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC CASEY J HAGMIER T I O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits (Checkone) outside arbitration limits N Is this a Class Action Suit? ❑Yes ® No Is this an MDJAppeal? ❑Yes ®No A Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you ham 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 0 Debt Collection:Other [I Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S E] Product Liability(docs not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: E3Employment Dispute:Other E] Other: T ❑ Other: I MASS TORT U ❑ Asbestos N ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ To)ac Tort-DES ❑ Toxic Tort-Implant El Ejectment E] Common Law/Statutory Arbitration B f-1 Toiac Waste ❑ Enrinent Domain/Condemnation ElDeclaratory 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: 16-09029 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 r; Er -O f 1+ }-. Portfolio Recovery Associates, LLC O !HE PR0TF,ON0 ►AR 120 Corporate Blvd Norfolk, VA23502 251li JUL 30 FM 12' 12 TELE: 1-866-428-8102u�1�E CUMBERLAND COUNTY (757) 518-0860 PENNSYLVANIA- 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 No. Plaintiff, V. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty(20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER- IF AWYERIF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 16-09029 (717)249-3166 e9 /l 3 ri'2S—yd 3oy'i9,3 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. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Demandado. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 16-09029 Esta conlUnicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier n�fron acion sera utilizAda para ese proposito. Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX:(757) 518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 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, CASEY J HAGMIER, is an adult individual with last known address of 60 PEACHY ANN DR, NEWVILLE PA 17241. 3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on October 4, 1999 with account number ************0745 (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. 1111s cornniunication is fi-orn a debt collector and .is an attempt to collect a debt. ,4Wy information obtained will be used for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A" 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on August 3, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. /SEARS and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiff s Bill of Sale is attached hereto and collectively marked as Exhibit"A" 9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of$2,223.63. 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, CASEY J HAGMIER, in the amo of$2,223.63, plus costs of t action and any other relief as the Court deems just and re on arrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, #312686 Attorneys for Plaintiff 16-09029 This corm-mmication is Born a debt collector and is an.attempt to collect a debt.. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Shirley Garcia 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 belied based upon information provided by the Plaintiff The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: JUN 17 2014 Shirley Garci d U Custodian of Records 16-09029 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. ConbutID. ' v Document ID: Document ID: BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT dated April 25, 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 headquartersi'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 February 25, 2013, between-Buyer and the Bank(the"Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and-deliver to Buyer, and to Buyer's successors and assigns,the Accounts described in Exhibit 1 and the final electronic file. Citibank,N.A. By: `. (Signature) Narne: t" c�fl `ill Title: PRA 022513 . . . . . . . . ; . . , :ntrac: . . ... 'Document ID: _. _.. . : . ...: •� ocument . , SSZ!:T SCHEDUEE The individual A cctsunts-transferred are described�in'the:final:electronic.file azid deliveted by,the' Bankto Bi' er,ihe'sanie'deemed attached hereto:b this refeiin'ce: Y. Y: #'o Side'. ' Cut-OfU. :Lot :: :Sale:ID -.A,ccouiM :. . :,Rote's.' . . -Sate.Balance : :pate .. : ::' : : � •::-: :Sears.Early:�..'- . .. . .. � �. :'• .. _ �,�df101�.3' � "�•'Out . mast4clid.: .. :.: Sears Early. ': _ . __ _ 44/101. 3:. , : .: LatieZ :.. :: . -PRA Q2251. Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: SEARS T CARDS searsSears MasterCardm C11 PO Box 6282,searscard.comSioux Falls,SD 57117-6282 aAccount Inquiries: 1-800-669-8488 ACcotmt'Nulnber 07445 Summary of Account Activit -Payment Information Previous Balance $2,146.63 New Balance $2,223.63 Payments -$0.00 Minimum Payment Due $716.63 Other Credits -$0.00 Payment Due Date March 25,2013 Purchases +$0.00 Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$42.00 Minimum Payment Warning: If you make only the minimum payment each New Balance $2,223.63 period,you will pay more in interest and it will take you longer to pay off your balance.For example: Past Due Amount $616.63 If you make no:addifid rial Youwfll pay off the, And you yvltl charges using this card balance shown on ikis end up paying ar Credit Limit $0.00 and each rtlonth':y9u pay_: sfatemertt in about estimated totaf of -' Available Credit $0.00 Cash Advance Limit $0.00 Only the minimum payment 10 years $4,269 Available Cash Limit $0.00 $89 3 years $3,193 Amount Over Credit Limit $0.00 (Savings=$1,076) Statement Closinq Date 02/26/2013 If you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 03/29/2013 Das in Billing Cycle 28 Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. Please see the enclosed privacy notice for important information. TRANSACTIONS Trans Date Description Reference# Amount FEES 02/25 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 8ME19 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 6 This Account is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.T Sears MasterCard tPast Due Amount is included in the Minimum Payment Due. Your Account Number Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed MARCH 25,2013 $2,223.63 $616.63 $716.63 $ SAVE STAMPS, TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, Paperless Statements and More. 0745 Make Checks Payable to: SEARS CREDIT CARDS PO BOX 183082 CASEY J HAGMIER COLUMBUS,OH 43218-3082 60 PEACHY ANN DR NEWVILLE,PA 17241-9314 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your Letter How to Avoid Paying Interest on Purchases.Your payment due date is at least When we receive your letter,we must do two things: 25 days after the close of each billing cycle. We will not charge you any interest on 1. Within 30 days of receiving your letter,we must tell you that we received purchases if you pay your New Balance by the payment due date each month. your letter.We will also tell you if we have already corrected the error. This is called a grace period on purchases. If you do not pay the New Balance in 2. Within 90 days of receiving your letter,we must either correct the error or full by the payment due date,you will not get a grace period on purchases until explain to you why we believe the bill is correct. you pay the New Balance in full for two billing cycles in a row. We will begin charging interest on cash advances and balance transfers(if available on your While we investigate whether or not there has been an error: account)on the transaction date. • We cannot try to collect the amount in question,or report you as delinquent on If you have a balance subject to a deferred interest promotion and that promotion that amount. does not expire before the payment due date,that balance(the"excluded The charge in question may remain on your statement,and we may promotional balance")is excluded from the amount you must pay in full to get a continue to charge you interest on that amount, grace period. However,you must still pay any separately required payment on the While you do not have to pay the amount in question,you are responsible excluded promotion.In billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first,the deferred interest balance will be reduced before any We can apply any unpaid amount against your credit limit. other balance on the account.However,you will continue to get a grace period on After we finish our investigation,one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional If we made a mistake:You will not have to pa the amount in question or an balances in full by the payment due date each billing cycle. Y q Y In addition,certain promotional offers may take away the race period on Interest or other fees related to that amount. p Y Y 9 p if we do not believe there was a mistake:You will have to pay the amount purchases. Other promotional offers not described above may also allow you to in question,along with applicable interest and fees.We will send you a have a grace period on purchases without having to pay all or a portion of the statement of the amount you owe and the date payment is due.We may then promotional balance by the payment due date. If either is the case,the report you as delinquent if you do not pay the amount we think you owe. promotional offer will describe what happens. How We Calculate Your Balance Subject to Interest Rate.We use a daily u you receive our explanation but still believe your bill is wrong,you must write to balance method(including current transactions)to calculate interest charges.To within 10 days telling us that you still refuse to pay.If you do cannot st on re find out more information about the balance computation method and how the report you as delinquent without also reporting that you are questioning your bili. We must tell you the name of anyone to whom we reported you as delinquent,and resulting interest charges were determined,contact us at the Account Inquiries number on the front. we must let those organizations know when the matter has been settled between US. Balance Transfers.Balance transfer amounts are included in the"Purchases"line If we do not follow all of the rules above,you do not have to pay the first$50 of in the Summary of Account Activity(if balance transfers are available on your account). the amount you question even if your bill is correct. Transaction Date.The Transaction Date shown on the statement is also the Sale Your Rights If You Are Dissatisfied With Your Credit Card Purchases Date. If you are dissatisfied with the goods or services that you have purchased with Credit Reporting Disputes.If you think we reported inaccurate information to a Your credit card,and you have tried in good faith to correct the problem with the credit bureau write us at the Customer Service address shown on the front. merchant,you may have the right not to pay the remaining amount due on the Report a Lost or Stolen Card Immediately.Call the Account Inquiries number purchase. shown on the front. To use this right,all of the following must be true: 1. The purchase must have been made in your home state or within 100 What To Do If You Find A Mistake On Your Statement miles of your current mailing address,and the purchase price must have If you think there is an error on your statement,write to us at the address for been more than$50.(Note:Neither of these are necessary if your billing inquiries and correspondence shown on the front of your statement. purchase was based on an advertisement we mailed to you,or if we own In your letter,give us the following information: the company that sold you the goods or services.) 2. You must have used your credit card for the purchase.Purchases made with • Account information:Your name and account number. cash advances from an ATM or with a check that accesses your credit card Dollar amount:The dollar amount of the suspected error. account do not qualify. • Description of problem:If you think there is an error on your bill, 3. You must not yet have fully paid for the purchase. describe what you believe is wrong and why you believe it is a mistake. if all of the criteria above are met and you are still dissatisfied with the purchase, You must contact us: contact us in writing at the address for billing inquiries and correspondence shown • Within 60 days after the error appeared on your statement. on the front of your statement. • At least 3 business days before an automated payment is scheduled,if you want While we investigate,the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. above.After we finish our investigation,we will tell you our decision.At that point, You must notify us of any potential errors in writing.You may call us,but if you do if we think you owe an amount and you do not pay, we may report you as delinquent. we are not required to investigate any potential errors and you may have to pay the amount in question. EM SM0GI-SCC-SU-1-1I1's 07/12 T02388-1238-5300-0031-9-E-9-D--10/01/99-15--P-B-0--7-402-0-0-SRSCHMSG---01/30/13-GDWB-January 29,2013-0-0-V N--- Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance In-Store Payments(Where Available).Any payment in proper form accepted at any time.However,you must pay,by the payment due date,at least the in-store will be credited as of that day.However,credit availability may be minimum payment due, subject to verification of funds.Not all stores accept payments.Contact your Crediting Payments.If we receive your payment in proper form at our processing local store to see if in-store payments are accepted at that location. facility by 5 p.m.local time there,it will be credited as of that day. A payment Online Payments.Visit the web address on the front and sign up for online received there in proper form after that time will be credited as of the next day. payments. Enrollment may take a few days. If we receive your request to make Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay an online payment by 5 p.m.Eastern time,we will credit your payment as of of up to 5 days in crediting a payment we receive that is not in proper form or is that day.If we receive your request to make an online payment after that time, not sent to the correct address. The correct address for regular mail is the we will credit your payment as of the next day.For security reasons,you may be address on the front of the payment coupon.The correct address for courier or unable to pay your entire New Balance with your first online payment. express mail is the Express Payments Address shown below. AutoPay Service.If you are enrolled in this service,your payment amount will be deducted automatically each month on your due date from the bank account Proper Form.For a payment sent by mail or courier to be in proper form,you must: you select. Enclose a valid check or money order.No cash,gift cards,or foreign Pay by Phone Service.You may use this service any time to make a payment currency please. by phone.You will be charged$14.95 if a representative of ours helps expedite • Include your name and account number on the front of your check or money your payment.Call by 5 p.m.Eastern time to have your payment credited as of order. that day.If you call after that time,your payment will be credited as of the next If you send an eligible check with this payment coupon,you authorize us to day.We may process your payment electronically after we verify your identity. complete your payment by electronic debit.If we do,the checking account will Express Payments.You can send payment by courier or express mail to the be debited in the amount on the check.We may do this as soon as the day we Express Payments Address.This address is: Payments Department,1500 receive the check.Also,the check will be destroyed. Boltonfield Street,Columbus,OH 43228. Payment must be received in proper Copy Fee.We charge$3 for each copy of a billing statement that dates back 3 form at the proper address by 5 p.m.Eastern time to be credited as of that day. months or more.We add the fee to the regular purchase balance.We waive the tee All payments received in proper form at the proper address after that time will if your request for the copy relates to a billing error or disputed purchase. be credited as of the next day. Page 2 of 6 Account: **** **** **** 0745 TRANSACTIONS(cont.) Trans Date Description Reference# Amount INTEREST CHARGED 02/26 INTEREST CHARGE ON PURCHASES $ 42.00 TOTAL INTEREST FOR THIS PERIOD $ 42.00 203`I`fltals Year—to-date Total Fees Charged in 2013 $70.00 Total Interest Charged in 2013 $88.31 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type of Batiirtce AnnualPercenat ge Rate(APA) Balance:t.5ubject;to lr"tterest Rath:;. Inter : :Charge PURCHASES REGULAR 25.24%(D)(V) $2,169.27 $42.00 CASH ADVANCES REGULAR 27.15%(D)(V) $0.00 $0.00 =Variable Rate D =Daily REWARDS SUMMARY Previous Points Balance 0 Points Earned 0 Points Adjusted 0 Points Redeemed 0 Ending Points Balance 0 Page 3 of 6 Account: **** **** **** 0745 Page 4of6 01/13 075 UM ,WHAT DOES CITIBANK DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. z. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. # ,v The types of personal information we collect and share depend on the product or service you have with us. This information can include: ` r � • Social Security number and income •account balances and employment information credit history and transaction history All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information;the f reasons Citibank chooses to share;and whether you can limit this sharing. rcn � JY.'t•_ � e,l _ .: � _. .. .c... i- i- # �a A„ ,��:... `'1Mb :� ,i'l.Pd' .. 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 to credit bureaus For our marketing purposes — to offer our products and services to you Yes No For joint marketing with other financial companies Yes No ....... . . ....... _ . ... ... . ...... . . _... . . 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 ......... ............. __.... _. Call 1-877-491-0609 — our menu will prompt you through your choice(s). Please note: ! i s 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 continue to share your information as described in this notice. However, you can contact us any time to limit our sharing. rPkCall 1-87"7-491-0609 or call the Customer Service number on the back of :_.. your credit card or on your billing statement. Page 5 of 6 01/13 076 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. _. .... .. _.._ �j 5 ry S � ,�'mra4%^r. •2 r .x"�" .x. �31 .2�.t' Nx .. . 'lt• .. .T., .. .. .. Ffw'.ti.,' 4 How does Citibank 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 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. ...E! ...... .... ..... ........... . ......... ............ _ ......... 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. ........ ........_. ......I... ... . . ... . ....... .... 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. _.... ........ ......... _.........._. 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 6of6 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY . THE P ROT HO NO 2G1ti AUG 12 PM 12: 3L4 GU PENNSY�LVAN A COUNTY Portfolio Recorvery Associates, LLC vs. Casey J Hagmier Case Number 2014-4448 SHERIFF'S RETURN OF SERVICE 08/04/2014 03:45 PM - Deputy Jason Kinsler, 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: Casey J Hagmier at 60 Peachy Ann Drive, Lower Mifflin, Newville, PA 17241. — SON KINSLER, DEPUTY SHERIFF COST: $42.05 SO ANSWERS, August 05, 2014 RONNfY R ANDERSON, SHERIFF Vic) CouncvSuite Sherit:, Telaosoft. Inc. 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. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Date: /z3/f/'' 16-09029 Defendant : No. 14-4448 PRAECIPE FOR DEFAULT -t, rn JUDGMENT rn z=) Zc tnr- -<> r-= cp Filed on 13ha1f of Plaintiff Cou cord for this Party Robert N. Polas, Jr., Esquire, # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This commmicati on. is from a debt collector is an attempt to collect a debt. Anv 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. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Defendant No. 14-4448 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, CASEY J HAGMIER,for a' u e to answer the Complaint. (X) Amount Due $2,223.63 Less Credits $.00 TOTAL $2,223.63 (X) 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. (X) Pursuant to PA.R.C.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. (X) Pursuant to PA.R.C.P.231.1, I certify that a written notice of intention to file this 16-09029 praecipe was mailed or delivered to and to his/her attorney of recordyt prior to the date of the filing o411. against whom judgmen after the default occurre e and a co.y o be entered st ten days ched. Robert N. Polas, Jr., Esquire, # 201259 Carrie A. Brown, Esquire, # 94055 • Mark R. Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector i.s an attempt to collect a debt. Anv information. obtained will be usedfor 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) September2, 2014 CASEY J HAGMTFR 60 PEACHY ANN DR NEWVILLE PA 17241 : PORIE.OLIO RECOVERY ASSOCIAthS, LLC VS. CASEY J HAGMIER 14-4448 Dear CASEY J HAGMIFR: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 16-09029 Sincere 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 CML ACTION — LA W PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Plaintiff No. 14-4448 Defendant TO: CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 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 AC 1 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. 16-09029 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Rar 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. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Defendant No. 14-4448 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 60 PEACHY ANN DR NEWVILLE PA 17241 and is not in the military service of the United States or its Allie the Service Members Civil Relief Act and its Amendments. 16-09029 rwise within the pro 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. A.ny information obtained will be used for that purpose. Department of Defense Manpower Data Center Status Report Pursuant to Servicernetabeis Civil Relief Act Last Name: HAGMIER First Name: CASEY Middle Name: J Active Duty Status As Of: Sep -19-2014 Results as of : Sep -19-2014 06:03:23 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ' • No NA , .• . ... .. This response reflects the'individualsactive duty status based on the'ActiVe Duty Status Date Left Active Duty Within 367 0 s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ' • No NA This response reflects wheiestite individual ;eft active duty.status within 38i days preceding the ActiveDuty Status Dale .. • 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 ,.. NA This response reflects wttether the individual or his/her unit has received early notificationto report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center 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 UniOrriled•SerViC:ei (Army, Navy, Marine Corps, Air Force, NOM, 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: httpi/www.defenselink.mil/faq/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: 6DIAQAE86008D60 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. CASEY J HAGMIER 60 PEACHY ANN DR NEWVILLE PA 17241 Plaintiff No. 14-4448 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 $2,223.63. (X) A copy of all documents filed with the Prothonotary in support of -the withiadgment is/ar attached. If you have any questions regarding this Notice, 16-09029 o.ert . 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.