HomeMy WebLinkAbout14-5005 Supreme Co rt'-of-Pennsylvania
Court f CROM an Pleas
For Prothonotary Use Only: TIME STAMP
C1fl V Docket No:
CUNMB ;.County
77ie 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 papers as required bylaw or rules o court.
Commencement of Action:
S ®Complaint E) Writ of Summons ❑Petition
E ❑Transfer from Another Jurisdiction ❑Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
PORTFOLIO RECOVERY ASSOCIATES,LLC KRYSTEN DEANER
T
I
O Are money damages requested? ® Yes 1i No Dollar Amount Requested: X within arbitration limits
(Check one) 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 haw 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
PREWARY 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(doer not include
S mass tort) ❑ Employment Dispute:
E ❑ Slander/Ubel/Defamation Discrimination n Zoning Board
❑ Other: ❑ Enployment Dispute:Other. ❑ Oiber:
T
❑ Other.
MASS TORT
O p Asbestos
N ❑ Tobacco REAL PROPERTY MISCELLANEOLS
❑ Toxic Tort-DES
E]C] Toxic Tort-implant Ejectment F1 Common Law/Statutory Arbitration
B E] Toxic Waste E3 Eminent Domain/Condemnati6n F1 Declaratory Judgment
❑ Other: [],Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations
❑ Mortgage Foreclosure:Residential Restraining Order
❑ Mortgage Foreclosure;Commercial ❑ Quo Warranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑Other Professional:
16-41539
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 "= +i�C°
120 Corporate Blvd l It ONorfol
TELE:1-866 428-810VA 235022 �� �f '
FAX: (757) 518-0860 P�'�Sy COON Y
Attorneys for Plaintiff LAU1141
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CML ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC ,
120 CORPORATE BLVD
NORFOLK, VA 23502 : No.
Plaintiff,
V.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
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
16-41539
Ot
C���SUla3C�0/
sS�oaB
This communication is from a debt collector and is an attempt to collect a debt Si �a
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
Attorne s for Plaintiff
IN TW COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC :
120 CORPORATE BLVD
NORFOLK, VA 23502 No.
Demandante,
V.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055 ;
Demandado.
NOTICIA
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 ]a 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 LISTED NO TIENE UN
ABOGADO, VAYA O LAmNffi 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 PD�ANC'0 RECER SERVICI S LEGALADO, ESTA OFICINA PERSONAS
PROVEERE
INFORMACION ACERCA AGENCIAS. QUEEi.J
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
16-41539
Esta coMunicacion es de un cobrador de deudas y es un intent do cobrar Lula deuda.
C:ualquier nifromacion 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
Attorne s 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.
KRYSTEN DEANER
1103 PARK PL :
MECHANICSBURG PA 17055
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, KRYSTEN DEANER, is an adult individual with last known address of 1103 PARK
PL, MECHANICSBURG PA 17055.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/WAL-MART on
December 19, 2010 with account number ************7110(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 coirnnenn.ication is fi-orn.a debt collector and is an attempt to collect a debt.
Any 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 April 13, 2013.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/
WAL-MART 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$3,362.04.
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, KRYSTEN DEANER, in the amou_ of$3,362.04, plus cost f t
action and any other relief as the Court deems just and r na
A own, Esquire, #94055
Robert N. Polas, Jr., Esquire, #201259
Mark R Garvey, Esquire, #312686
Attorneys for Plaintiff
16-41539
This corminumication is from a debt collector and is an.attempt to collect a debt.
Any infa7rution obtained will be used for that purpose.
• VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates,LLC,
Tamara Bond 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 /her knowledge, inforn�ation, 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.
JUL 2 8 2014
Date: By:
Tamara Bond
Custodian of Records
16-41539
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 wi l be used for that purpose.
.. ...............................................................
...Oft
d
ital.P
Lof
IL. SALE.
a
PItA CC Fresh:-- ecembeY 2013. .
.... ..
PL
lue received.arid:in further consideration of.the.mutual covenants and conditions .... .20 3 the
.For va �. t„ d 9�'day of July;,2013 by and :.. .� :.. ..
, .
at as o
f this
Forward Flow Receivables Purchase Agreement(the Agzeemen . , .
...
between General Electric Capital Corporation,:GE cap:tal:RetaiI Ban1c,GEMB Lending,Inc.,.M#
Credit
tietw "Sellet"):and Po olio:
Services;L.L.C.;RFS Holding,L:L:C:San hM °ltferLs sesnveysly ants,and:delivers.to Buyer;its.
Recovery;associates,
LLC.(`Biiyer"),. . Y ..... rhe. .
without recourse'except asaet forth in the Agreement,,o the
extent of its ovine p, .
successors and assigns
Receivables.as set forth in.the Notification Files'(as-defined in.the Agreement ,delivered by.Seller to Buyer on
December..14;2Q13,and:as:fizrtherdesc.. ..iathe.Agzee t.
. dit Servi
ccs,'t L.C:
Monogram Cre
G
E Cap
ital . ..
R
..etas
'1 Bank.
By: +"
BY.. Attorpey inF Kerr tilolmk
Ken:Wojcik
Title:_EVP:Collections&Recovery '
' D
ate:: Q
Date: �. US Hording;L.L,:C
General Electric Capital Corpora . . ::: By::
k
in Fac en woj
.. ... .. ., Attorney .
•
B
. . y: .' Date:. Ot oto
in Fa Ken Wojcik
Attorney:. ..
•
•
Date:
. . GEM Holding,'L.L.0 '
GEMB Lending;.Inc.
B
Attorney in... Ken'Wojcik
By r Date: t7� rfi ;r
Attorney.in.Fact en Woacik.
... ..
Date:
D
...........................................
....................................
Portfolioltocover Osociates;LLC'
+� .....
Walmart a:'%R
Save money.Live be
Wal mart® KRYSTEN A DEANER Visit us at walmart.comlcredit
Credit Card Account Number: -7110 Customer Service:1-800-641-4526
Summary of Account Activity Payment Information
Previous Balance $3.362.04 New Balance $0.00
-Other Credits $3,362.04 Amount Past Due $0.00
New Balance $0.00 Total Minimum Payment Due $806.00
Payment Due Date 11/12/2013
Credit Limit $3,300 Late Payment Warning:If we do not receive your minimum
Available Credit $0.00 payment by the date listed above,you may have to pay a late
Cash Advance/Quick Cash Limit $471 fee up to$35.00.
Available Cash $0.00
Statement Closing Date 11/10/2013
Days in Billing Cycle 28
Transaction Summary
Tran Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount
11/10 11/10 F9112009000999990 CHARGE OFF ($2,861.40)
ACCOUNT-PRINCIPALS
11/10 11/10 F9112009000999990 CHARGE OFF ACCOUNT*FINANCE ($500.64)
CHARGES'
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
11/10 11/10 INTEREST CHARGE ON PURCHASES $0.00
11/10 11/10 INTEREST CHARGE ON CASH $0.00
ADVANCES
TOTAL INTEREST FOR THIS PERIOD $0.00
2013 Totals Year-To-Date
Total Fees charged in 2013 $245.00
Total Interest charged in 2013 $585.71
Total Interest Paid in 2013 $269.70
Interest Charge Calculation
Your Annual Percentage Rate(APR)s the annual interest rate on your account.
Type of Balance Expiration Plan Annual Percentage Balance Subject to Interest Charge
Date Type Rate Interest Rete
Regular Purchases&Cash NA REG 22.90%(v) $0.00 $0.00
Advances
v =Variable rate
Cardholder News and Information
Statement not provided to customer.
If your account has a deferred interest promotion and you would like us to apply a payment on your account to a specific
balance,please call Customer Service to discuss options that may be available.
Important Information about the 5¢off per gallon gas discount available with the use of a consumer Walmarl®Credit Card or
WalmartO Discover®card at participating Walmart®gas stations:For purchases made in Alabama and Florida,the 5¢
discount will appear as a credit on your next statement.
PAYMEblJ QUE BY 5 P M (ET)QbI THE DUE DATE
NOTICE:We may convert your payment into an electronic debit.See reverse for details,Billing Rights and other important
information.
5404 BFH 1 3 10 131110 ZX PAGE 1 of 1 9112 1400 0203 OID05404 —I
' Detach and mail this portion with your check.Do not include any correspondence with your check.
� 7110
Walmart , Total Minimum Amount Pa�Acco�untNumb�err: �71
w a anteSavenwney.livebetter. Payment DuePast Due$806.00 $0.00 1 $0.00
Payment Enclosed:Please ❑[I[IF]
❑ ■ ❑0
I011ll��lull���ll��l�lll�u��l��l����lll�llll�I��I�IIW use blue or black ink. New address or email?Print changes on back.
KRYSTEN A DEANER
1103 PARK PL
MECHANICSBURG PA 17055-9506 Make Payment To:WALMART/GECRB
P.O.BOX 530927
ATLANTA,GA 30353-0927
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
L4- 1HE PROTHONCITARY
ZVI SEP -9 PH 3: 27
CUMBERLAND COUNTY
PENNSYLVANIA
OFFICE QF TN RIF
Portfolio Recorvery Associates, LLC
vs.
Krysten Deaner
Case Number
2014-5005
SHERIFF'S RETURN OF SERVICE
08/28/2014 08:32 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 Scott Deaner, husband, who
accepted as "Adult Person in Charge" for Krysten Deaner at 1103 Park Place, Moneroe Township,
Mechanicsburg, PA 17055.
SON KINSLER, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
August 29, 2014 RONFW R ANDERSON, SHERIFF
rri.) CountySuffe Sheriff, Teleosaff,
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.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
Defendant
Date:
16-41539
Filed
No. 2014-5005
PRAECIPE FOR DEFAULT
JUDGMENT
sel of
of Plaintiff
ecord for this Party
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cti)
ts'°r l
.:4
C,
-71
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tea'
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•
' :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
This communication is from a debt collector is an attempt to collect a debt.
Any information obtained will be used for that purpose.
$165oP' ArtY
60-604,731
ea 05
�Cei (ed
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.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
Defendant
No. 2014-5005
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, KRYSTEN DEANER, for failure
to answer the Complaint.
(X) Amount Due $3,362.04
Less Credits $.00
TOTAL $3,362.04
(X
(X)
(X
16-41539
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.RC.P.231.1, I certify that a written notice of intention to file this
praecipe was mailed or delivered to the party against whom judgment is t. be entered
and to his/her attorney of record, if .. er the default occurr-.. d at east ten days
prior to the date of the filing oft pra '. e and a copes of t
?pie attached.
ie
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 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)
October 13, 2014
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. KRYSTEN DEANER
2014-5005
Dear KRYSTEN DEANER:
Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania
Rules of Civil Procedure.
16-41539
Sincerely,
Robert N. Polas, Jr., Esquire
Carrie A. Brown, Esquire
Mark R. Garvey, Esquire
Gregory J. Babcock, Esquire
Attorney ID
#201259/94055/312686/205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION — LAW.
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff No. 2014-5005
v.
KRYSTEN DEANER
1 103 PARK PL
MECHANICSBURG PA 17055
Defendant
TO: KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
DATE OF NOTICE: October 13, 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.
16-41539
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 wAl be used for that purpose.
IN TIS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff
v.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
Defendant
No. 2014-5005
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
1103 PARK PL
MECHANICSBURG PA 17055
and is not in the military service of the United States or its Alli- , e otherwise within the
the Service Members Civil Relief Act and its Amendments
16-41539
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.
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 (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: HFJ753D2TO3BC40
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. 2014-5005
v.
KRYSTEN DEANER
1103 PARK PL
MECHANICSBURG PA 17055
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 $3,362.04.
(X) A copy of all documents filed with the Prothonotary in su
attached.
If you have any questions regarding this Noti
16-41539
BY:
rt of e with' • gment is/are
contact the f
I
overt 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.