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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 czn cti) ts'°r l .:4 C, -71 f 11 _4. tea tea' C) _i.. —f s-; -.0 • ' :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.