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Home My WebLink About14-4449 Supreme Cour a(Pennsylvania Court-of Common Pleas � �� For ProthonotaryU.seOnly: 'I'1M[?STr1141P Cl. . COveif§ eet Docket No: CUMBET�I�A�1*ounty /y �y� 7 cod The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the film and service ofpleadings or other a ers as required by law or rules o court. Commencement of Action: S N Complaint ❑ Writ of Summons ❑Petition E ❑ Transfer fromAnotherJurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC DONALD ZEEK T I I Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits N Is this a Class Action Suit? o 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 haw no attorney(are a Self-Represented[Pro Se]Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S ❑ L Product iability(does not include mass tort) ❑ .Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C F-1Other: ElEmployment Dispute:Other ❑ Other: T I ❑ Other: MASS TORT O ❑ Asbestos N ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ To)ac Tort-DES E] Toadc Tort-Implant ❑ Ejectment E] Common Law/Statutory Arbitration B ❑ To?ac Waste ❑Eminent Domain/Condemnation ElDeclaratory Judgment F1 Other: E] Ground Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Watranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 15-99946 r Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 �F;;^- ; Portfolio Recovery Associates, LLC •r -{E 3 o q} o' I Ari 120 Corporate Blvd Norfolk, VA 23502 2G14 JUL 30 Ph 0 .t 2 TELE: 1-866-428-8102 FAX:(757) 518-0860 ZUMBERLAND COUNTY Attorneys for Plaintiff PENNSYLVANIA 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. ��✓ /��fy' &tJ Plaintiff, V. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG PA 17257 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 f 3 -2s- Carlisle, PA 17013 Fd (717)249-3166 15-99946 25U4 70 0 %� This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX:(757) 518-0860 Attorneys for Plaintiff IN TIDE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG PA 17257 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 ]a 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 15-99946 Esta corma-icacion es de un cobrador de deudas y es rut intent do cobras wia deuda. Cualquier infronucion sera utilizada para ese proposito. s` 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 Plaintiff, No. V. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG PA 17257 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, DONALD ZEEK, is an adult individual with last known address of 688 BRITTON RD, SHIPPENSBURG PA 17257. 3. it is averred that Defendant was indebted to U.S. BANK NATIONAL ASSOCIATION on June 1, 2012 with account number ************0800(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 corn nunication is fi-otn a debt collector and is an.attempt to collect a debt. Any inforiTkition 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 1, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest U.S. BANK NATIONAL ASSOCIATION and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs 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$1,192.09. 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, DONALD ZEEK, in the amount $1,192.09, plus costs th' action and any other relief as the Court deems just and reason e. ie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, #312686 Attorneys for Plaintiff 15-99946 This cor n iunication is from 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 2014I I I 0� 'Q' I I 1;--� �. Shirley Garcia Custodian of Records 15-99946 E 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 conmmication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT B BILL OF SALE AND ASSIGNMENT OF ASSETS The undersigned Assignor ("Assi nor') hereby absolutely sells, transfers, assigns, sets-over, quitclaims and conveys to Portfolio Recovery Associates, LLC, a limited liability company organized under the laws of Delaware ("Assignee") on an "AS IS" and "WITH ALL FAULTS" basis, without recourse and without representations or warranties of any type, kind, character or nature,express or implied,all of Assignor's right,title and interest in and to each of the assets identified in the Asset Schedule ("Asset Schedule") attached hereto as Exhibit A (the "Assets"), together with the right to collect all principal, interest or other proceeds of any kind with respect to the Assets remaining due and owing as of the date hereof(including but not limited to proceeds derived from the conversion, voluntary or involuntary, of any of the Assets into cash or other liquidated property, including, without limitation, insurance proceeds and condemnation awards), from and after the date of this Bill of Sale and Assignment of Assets. DATED:October 25,2013 ASSIGNOR: U.S. ank National Association By: Ll NameeicePresident Rebmann Title: By: e(PAO: r Clue Title: tC0 USB PRIME APPROVED 10/10/2013 Susquehanna Bank April 2013 Statement Page 1 of 2 Open Date: 03/08/2013 Closing Date: 04/05/2013 Account: 0800 Visa®Platinum Card Cardmember Service ( 1-800-558-3424 DONALD ZEEK ELN 4 IVew Balance $g9g„$ Activity Summary Minimum Payment Due $Q 0a Previous Balance + $996.85 Paymeht Due'Uate B51b /2ti'13 Payments $0.00 Other Credits - $996.85cR Late Payment Warning Ifwe do nct receive your Purchases $0.00 minimum paymentty the date Ilstedatlovt you mar have: Balance Transfers $0.00 today up to-a$35 D0 Late Fee Advances $0.00 . _...:.. Other Debits $0.00 Fees Charged - $173.00CR Interest Charged - $22.24CR New Balance = $996.85 Past Due $0.00 Minimum Payment Due $0.00 Credit Line None Available Credit None Days in Billing Period 29 Pay online at Pay by phone Payment Options: With a check payment coupon myaccountaccess.com (1 1-800-558-3424 Please detach and send coupon with check payable to:Cardmember Service 0800 Susquehanna Bank Account Number 0800 Payment Due Date 5/03/2013 24-Hour Cardmember Service: 1-800-558-3424 New Balance $996.85 CMinimum Payment Due $0.00 .to pay by phone y .to change your address Amount Enclosed $ 000001838 1 SP 000638015525810 S Cardmember Service DONALD ZEEK P.O. BOX 790408 688 BRITTON RD St. Louis, MO 63179-0408 SHIPPENSBURG PA 17257-9522 What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement,please call us at the telephone number on the front of this statement,or write to us at: Cardmember Service,P.O.Box 6335,Fargo,ND 58125-6335. In your letter or call,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 believe it is a mistake. You must contact us within 60 days after the error appeared on your statement.While we investigate whether or not there has been an error,the following are true: No.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. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card,and you have tried in good faith to correct the problem with the merchant,you may have the right not to pay the remaining amount due on the purchase. 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 miles of your current mailing address,and the purchase price must have been more than$50.(Note:Neither of these are necessary if your purchase was based on an advertisement we mailed to you,or if we own the company that sold you the goods or services.) 2.You must have used your credit card for the purchase.Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3.You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase,contact us in writing at:Cardmember Service,P.O.Box 6335, Fargo,ND 58125-6335.While we investigate,the same rules apply to the disputed amount as discussed above.After we finish our investigation, we will tell you our decision.At that point,if we think you owe an amount and you do not pay we may report you as delinquent. Important Information Regarding Your Account 1.INTEREST CHARGE:Method of Computing Balance Subject to Interest Rate:We calculate the periodic rate or interest portion of the INTEREST CHARGE by multiplying the applicable Daily Periodic Rate("DPR")by the Average Daily Balance("ADB")(including new transactions)of the Purchase,Advance and Balance Transfer categories subject to interest,and then adding together the resulting interest from each category.We determine the ADB separately for the Purchases,Advances and Balance Transfer categories.To get the ADB in each category,we add together the daily balances in those categories for the billing cycle and divide the result by the number of days in the billing cycle.We determine the daily balances each day by taking the beginning balance of those Account categories(including any billed but unpaid interest,fees,credit insurance and other charges),adding any new interest,fees,and charges,and subtracting any payments or credits applied against your Account balances that day.We add a Purchase,Advance or Balance Transfer to the appropriate balances for those categories on the later of the transaction date or the first day of the statement period.Billed but unpaid interest on Purchases,Advances and Balance Transfers is added to the appropriate balances for those categories each month on the statement date.Billed but unpaid Advance Transaction Fees are added to the Advance balance of your Account on the date they are charged to your Account.Any billed but unpaid fees on Purchases,credit insurance charges,and other charges are added to the Purchase balance of the Account on the date they are charged to the Account.Billed but unpaid fees on Balance Transfers are added to the Balance Transfer balance of the Account on the date they are charged to the Account.In other words,billed and unpaid interest,fees,and charges will be included in the ADB of your Account that accrues interest and will reduce the amount of credit available to you.Credit insurance charges are not included in the ADB calculation for Purchases until the first day of the billing cycle following the date the credit insurance premium is charged to the Account.Prior statement balances subject to an interest-free period that have been paid on or before the payment due date in the current billing cycle are not included in the ADB calculation. 2. Payment Information:You must pay us in U.S.Dollars with checks or similar payment instruments drawn on a financial institution located in the United States. We will also accept payment in U.S.Dollars via the Internet or phone or previously established automatic payment transaction. We may,at our option,choose to accept a payment drawn on a foreign financial institution. However,you will be charged and agree to pay any collection fees required in connection with such a transaction. The date you mail a payment is different than the date we receive that payment. The payment date is the day we receive your check or money order at Cardmember Service,P.O.Box 790408,St.Louis, MO 63179-0408 or the day we receive your electronic or phone payment.All payments by check or money order accompanied by a payment coupon and received at this payment address will be credited to your Account on the day of receipt if received by 5:00 p.m.CT on any banking day. Mailed payments that do not include the payment coupon and/or are mailed to a different address will be processed within 5 banking days of receipt and credited to your Account on the day of receipt.In addition,if you mail your payment without a payment coupon or to an incorrect address,it may result in a delayed credit to your Account,additional INTEREST CHARGES,fees,and possible suspension of your Account. Internet and telephone payment options are available,and crediting times vary(but generally must be made before 5:00 p.m.CT to 8 p.m.CT depending on what day and how the payment is made). If you are making an internet or telephone payment,please contact Cardmember Service for times specific to your Account and your payment option. Banking days are all calendar days except Saturday,Sunday and federal holidays.Payments due on a Saturday,Sunday or federal holiday and received on those days will be credited on the day of receipt. 3.Credit Reporting:We may report information on your Account to Credit Bureaus.Late payments,missed payments or other defaults on your Account may be reflected in your credit report. Susquehanna Ban4 April 2013 Statement 03/08/2013-04/05/2013 Page 2 of 2 DONALD ZEEK Cardmember Service {1 1-800-558-3424 mpvrtarat Messages Each time you or a third party on your behalf, pays your bill by personal check, you authorize us to convert that payment into an electronic debit. If the check is processed electronically, the checking account will be debited for the amount on the check and the debit will appear on your account statement. If you have any questions, please contact us at the Inquiries phone number located on this statement. Transactions Payments and Other Credits Post Trans Date Date Ref# Transaction Description Amount 03/29 CHARGE OFF $996.85CR TOTAL THIS PERIOD $996.85CR Fees Post Trans Date Date Ref# Transaction Description Amount 03/29 REVERSAL OF LATE PAYMENT FEE $163.00CR 03/29 REVERSAL OF OTHER FEES AT CHARGE OFF $10.00CR TOTAL FEES THIS PERIOD $173.00CR Interest Charged Post Date Transaction Description Amount 03/29 INTEREST REVERSAL $22.24CR TOTAL INTEREST THIS PERIOD $22.24CR .......... 2013 Totals;bear to # atai Total Fees Charged in 2013 $103.00CR Total Interest Charged in 2013 $13.39CR nW gtest ChargeiCalccila#lon Your Annual Percentage Rate(APR)is the annual interest rate on your account. **APR for current and future transactions. Balance Annual Expires Balance Subject to Interest Percentage with Interest Balance Type By Type Interest Rate Variable Charge Rate Statement Free Period —BALANCE TRANSFER $0.00 $0.00 $0.00 0.00% NO "'PURCHASES $1,038.10 $0.00 $0.00 0.00% YES '"ADVANCES $153.99 $0.00 $0.00 0.00% NO End of Statement Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of CPA 'PRQ11-10K 314 x611 4 AUG " 2 Pii •,. r .�r._ pp�',,��ttB RLAp(CSO OFFICE OF THE SHERIFF �+' ` `HNSY �v' `� Portfolio Recorvery Associates, LLC vs. Theresa Stum Case Number 2014-4445 08/04/2014 SHERIFF'S RETURN OF SERVICE 06:02 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Doug Stum, Husband, who accepted as "Adult Person in Charge" for Theresa Stum at 37 Blue Pond Road, Penn Township, Newville, PA 17241. A . — — 1C> ON KINSLER, DEPUTY SHERIFF COST: $36.40 SO ANSWERS, August 05, 2014 RONNY R ANDERSON, SHERIFF (c)CountySuae Sheriff, Teleosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson LLD—C , " iUL Sheriff " THE PROTHONOTARY Jody S Smith Qtr Qt (Arm Chief Deputy 2014 AUG 12 PM 12: 34 Richard W Stewart Solicitor oFFiCE OF rUE SHERIFF C0 PENNSY! COIA A T Portfolio Recorvery Associates, LLC vs. Donald Zeek Case Number 2014-4449 SHERIFF'S RETURN OF SERVICE 08/04/2014 04:20 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: Donald Zeek at 688 Britton Road, Southampton, Shippensburg, PA 17257. ‘4,2/----e' SON KINSLER, DEPUTY SHERIFF COST: $51.09 SO ANSWERS, August 05, 2014 RONfR ANDERSON, SHERIFF cc) County.Su !o Sheriff, Teleosoft, 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. DONALD LEEK 688 BRITTON RD SHIPPENSBURG PA 17257 Date: 15-99946 /0-// No. 14-4449 PRAECIPE FOR DEFAULT Defendant JUDGMENT Filed on Be Couns of Plaintiff ord for this Party rt 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 ry ri2.4 Sin This communication is ilom a debt collector is an attempt to collect a debt. flljijp 1i Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORIDOLIO RECOVERY ASSOCIATES, t I,C 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. DONALD LEEK 688 BRITTON RD SHIPPENSBURG PA 17257 Defendant No. 14-1119 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, DONALD ZEEK, for failure to answer the Complaint. (X) Amount Due $1,192.09 Less Credits $.00 TOTAL $1,192.09 (X) (X (X 15-99946 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 PAR.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. Pursuant to PAR.C.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the pst whom judgment isty .. entered and to his/her attorney of record, if any, . ter t e default occurred a east ten days prior to the date of the filing of this p .eci. J� (a Jry�• t� fir ttached. obert N. Polas, Jr., Esquire, # 201259 Carrie A Brown, Esquire, # 94055 Mark R. Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 Portfolio Recovery Associates, LLC, 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 14-4449 V. DONALD ZEEK 688 BRITTON RD SHIPPENSBURG PA 17257 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above -captioned matter has been entered against you in the amount of $1,192.09. (X) A copy of all documents filed with the Prothonotary in support of the within 'udgment is/are attached. If you have any questions regarding this Not 15-99946 ert N. Polas, Jr., Esquire, # 201259 ie A Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Gregory J. Babcock, Esquire, #205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax (757) 518-.0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) September 2, 2014 DONALD ZEEK 688 BRITI ON RD SHIPPENSBURG PA 17257 RE: PORIt OLIO RECOVERY ASSOCIAI ES, LLC VS. DONALD ZEEK 14-4449 Dear DONALD ZEEK: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-99946 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 111E COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 14-4449 V. DONALD LEEK 688 BRITTON RD SHIPPENSBURG PA 17257 Defendant : TO: DONALD ZEEK 688 BRITTON RD SHIPPENSBURG PA 17257 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. 15-99946 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Robert N. Polas, Jr., Esquire Carrie A Brown, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID #201259/94055/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN 111E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff V. DONALD ZFEK 688 BRITTON RD SHIPPENSBURG PA 17257 Defendant No. 14-4449 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 688 BRITTON RD SHIPPENSBURG PA 17257 and is not in the military service of the United States or its Allies, or the Service Members Civil Relief Act and its Amendments. 15-99946 erwise within the ons 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 Status Report Pursuant to Servicemen Civil Relief Act Last Name: ZEEK First Name: DONALD Middle Name: Active Duty Status As Of: Sep -15-2014 Results as at: Sep -15-2014 09:1411 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 i. -..f.:....7', NA This response reflects 'i ' ' active duty status based on the'Actiieiity Status Date Left Active Duty Within 367 Oys of Active Duty Status Date Active Duty Start Date 'Active Duty End Date Status Service Component NA — No i. -..f.:....7', NA This response reflects wfie:ieliie individual left active duty.slatus within 313i. days preceding the Active:Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NANA . This „,. response reflects whett4iThe individual or hisMer unit has received early notifiCition-lo 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 UnifOriheifSeniibei(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/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 (NOM 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: EDR06856J0B8UE0