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Home My WebLink About14-5069 Supreme Cou=roof.Pennsylvania X I Court- f Common Pleas Y�7 ,- V' For Prothonotary Use Only: T I M ti STAMP t Ci v11�V&elVjQS et Docket No: CLIMB �-- , D/County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: E ® Complaint ❑ Writ of Summons ❑Petition ❑ Transfer from Another Jurisdiction E]Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Nacre: T PORTFOLIO RECOVERYASSOCIATES,LLC DEBRA LFULLER I 0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration In*s 1 A Is this a Class Action Suit? ❑Yes ®No Is this an MD.I Appeal? []Yes ®No Name of Plaintiff7Appellarifs Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you have 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 Toil) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board ofAssessment ❑ Motor Vehicle ❑ Debt Collection:Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S ❑ Product Liability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrirr>ination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: TI I ❑ Other: U MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Ejectment ❑ Common Law/Statutory Arbitration E3 Toxic Tort-Implant n' ❑ Toxic Waste ❑ Eminent Domain/Condemnation ElDeclaratory Judgment ❑ Other: ❑ Found 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: 16-05683 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar# 94055 Mark R. Garvey, Esquire PA Bar# 312686 ,, . .r Portfolio Recovery Associates, LLC 120 Corporate Blvd' TAP, Norfolk, VA 23502 28 TELE: 1-866-428-8102 PS Y FAX: (757) 518-0860 �()��,�. ENNL� Attorneys for Plaintiff L ti,- A NIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC I 120 CORPORATE BLVD NORFOLK, VA 23502 No Plaintiff, V. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty(20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED-FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association �+ 32 South Bedford Street J Carlisle, PA 17013 16-05683 (717) 249-3166 n SSg1CQ 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 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 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 16-05683 Esta con-imicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier infroniacion 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. : DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, DEBRA L FULLER, is an adult individual with last known address of 2217B ORCH RD, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on September 21, 2007 with account number************5190 (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 cornmunication is frorn 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 May 25, 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 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$1,900.31. 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, DEBRA L FULLER, in theib f$1,900.31, plus c s of his action and any other relief as the Court deems just an eas Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, #312686 Attorneys for Plaintiff 16-05683 This communication is from a debt collector and is an attempt to collect a debt. Any inlormation obtained will. be used l:or that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Elaine Freeman-Lark 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 belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: jilt -, By: /Elaine Freeman-Lark Custodian of Records 16-05683 This communication is from a.debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ,. yi -.�< - .1. ... e•b.., i... � .,.. ». -L - T 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. ' r • Contract K : . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . Document ID;t : '. ' . . ..: . . . . . . . . . . . . . . . . . . . . . . • ' ' Ijocu•ent;ID.' • :��XI�BiiT 1 . ASSET•SCHEDM-E .':::�.::' :.. . The individual.:A,rcounts-transferred are:cles bed icy:the final.Weetrgnicifle and,-deliverediby:the: . -94A.to-Buyer the'saine:deemcii`attached:hereta b'y'this.reference..'. #of Sale Cut-Off Lot Sale ID Accounts Rates Sale Balance Date 'Sears Early Out 02/20113 : :. MasterCard Sears Early 82120/13 Out Private Label 1_jR.AA2251.3---:-- • : ' 7 iF �:. Account Statement Send Notice of Billing Error Inquiries to: sears Customer Service: Po Box 6283,Sioux DS Sears Card SEARS CREDITCARDS CustomerServicen w I searscard.com SD 57117-6283 Account Inquiries: ; 1-800-917-7700 Acco-Wit Num#a 5190 Summary of Account Activity Payment Information Previous Balance $1,829.95 New Balance $1,900.31 Payments -$0.00 Minimum Payment Due Other Credits -$0.00 Payment Due Date $635.18 Purchases +$0.00 y January 25,2013 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 Char ed +$35.36 Minimum Payment Warning: If you make only the minimum payment each New Balance $1,900.31 period,you will pay more in interest and it will take you longer to pay off your balance For example Past Due Amount $545.82 tf you make ho addittonal ;You wifl pay Off tt�e And you will charges using this card balanee.shown on., en; up paying an'- QV n'aeh r>ionth you pay statemeit to about e'sttmated'totaf of:-; Credit Limit $0.00 Only the minimum payment 8 years $3,285 Available Credit $0.00 $74 3y ears $2,657 Amount Over Credit Limit $0.31 (Savings=$628) Statement Closing Date 12/28/2012 If you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 01/29/2013 Das in Billing Cycle 30 Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. TRANSACTIONS Trans Date Description Reference# Amount FEES 12/25 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 12/28 INTEREST CHARGE ON PURCHASES $ 35.36 TOTAL INTEREST FOR THIS PERIOD $ 35.36 8 SE 19 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION- YPage 1 of 4 This Account is Issued b Citibank,N.A. ----------------------------------------------- - - ------------------------------------ Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.+ Sears Card® tPast Due Amount is included in the Minimum Payment Due. Your Account Number j Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 519A.>'',:` JANUARY 25,2013 $1,900.31 $545.82 $635.18 $ SAVE STAMPS, TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, Paperless Statements and More. 5190 Make Checks Payable to: SEARS CREDIT CARDS PO BOX 183081 DEBRA L FULLER COLUMBUS,OH 43218-3081 2217 B ORCHARD RD CAMP HILL,PA 17011-7442 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your tetter 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 balances in full by the payment due date each billing cycle. If we made a mistake:You will not have to pay the amount in question or any In addition,certain promotional offers may take away the grace period on interest or other fees related to that amount. purchases. Other promotional offers not described above may also allow you to If question, st not believe there was a mistake:You will have will pay the amount Y Y 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 If 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 re within 10 days telling us that you still refuse to pay.if you do st on cannot find out more information about the balance computation method and how the report you ll delinquent without also reporting that you are questioning your bill, resulting interest charges were determined,contact us at the Account Inquiries We must tell you the name of anyone w whom m reported you as delinquent,and 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 the amount y account). you question even if our bill is correct. Transaction Date.The Transaction Date shown on the statement is also the Sale Your Rights/f 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: What To Da If You Find A Mistake On Your Statement 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 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 we are not required to investigate any potential errors and you may have to pay delinquent. the amount in question. EM SK-MI-SCC-SU-HIPS 07/12 T02388-9351-5000-0020-9-E-9-X--09/01/07-46--P--0--7-402-0-0----02/28/12-PDXB-November 28,2012-0-0-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 fee 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 4 Account: **** **** **** 5190 20i 2 TotalsYear';to date Total Fees Charged in 2012 $270.00 Total Interest Charged in 2012 $368.32 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type o`fBafance A'nnuatPercentage Rate.(AP�i) j ,. Balahce Sub ect to Ir'iterest Rite ...:Interest_Charge;:';:, PURCHASES REGULAR 23.24%(D)(V) $1,851.61 $35.36 =Variable Rate D =Daily Page 3 of 4 Account: **** **** **** 5190 ^ n Page 4 of 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FiLaiJi- ii Sheriff or of CUMbot T PRO-11-10NOIAR Jody S Smithip.ci • -44 2N) SEP 22 PM 2: 30 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor outCE OF THF ;HFRIFF; PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Debra Fuller Case Number 2014-5069 SHERIFF'S RETURN OF SERVICE 09/03/2014 03:25 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Herbert Barnhardt, boyfriend, who accepted as "Adult Person in Charge" for Debra Fuller at 2217B Orchard Road, Lower Allen Township, Camp Hill, PA 17011. SHERIFF COST: $45.44 September 04, 2014 f,c) CountySuite Sheriff, Telf.:oscit, Inc. '°--117E IS FRY, DEPU SO ANSWERS, RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATE, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Date: 16-05683 I(( Defendant No. 2014-05069 . PRAECIPE FOR DEFAULT . JUDGMENT Coun e Filed onalf of Plaintiff o ecord for this P. r A////' Pes 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 - LP .t ''7 Q 01 -)1k Ta gdWd This communication is from a debt collector is an attempt to collect a debf- Any information obtained will be used for that nurnose. • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Defendant No. 2014-05069 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, DEBRA L FULLER, for failure to answer the Complaint. (X) Amount Due $1,900.31 Less Credits $.00 TOTAL $1,900.31 (X) (X) (X 16-05683 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 PA.RC.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 p. .gainst whom judgme is to be entered and to his/her attorney of record, if . aft the default occ• 'eat least ten days prior to the date of the filing of thi .ra:��; � , a co.y • f �. ic= is attached. /// 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. MI THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Plaintiff No. 2014-05069 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 $1,900.31. (X) A copy of all documents filed with the Prothonotary in support otf ire wit ° d a „' /are attached. If you have any questions regarding this N 16-05683 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 conununicatio.n. is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOUO 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 DEBRA L FULLER 22178 ORCH RD CAMP HILL PA 17011 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DEBRA L FULLER 2014-05069 Dear DEBRA L FULLER: Enclosed herein please find a l0 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules ofCivil Procedure. 16-05683 Sincere Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID #201259/94055/312686/20506I 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. 2014-05069 v. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Defendant TO: DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 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. 16-05683 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. Anv information nhtainPri will k' 'Kori fnr fk,s .+. ..++ IN ME COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. DEBRA L FULLER 2217B ORCH RD CAMP HILL PA 17011 Defendant No. 2014-05069 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 2217B ORCH RD CAMP HILL PA 17011 and is not in the military service of the United States or its Alli the Service Members Civil Relief Act and its Amendments 16-05683 otherwise within the p s of 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) (866) 428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This conununication is a debt collector and is an attempt to collect a debt. Any information obtained will be used for that pumose. Department of Defense Manpower Data Center tatus Report uant to Servicenieribers Civil Relief Act Last Name: FULLER First Name: DEBRA Middle Name: L Active Duty Status As Of: Oct -15-2014 Resutls as of Oct -15-2014 03:3802 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA :'.' NA . • No NA ....... ,, This response reflects the indiviituats' active duty status based on the'Actiiie Duty Status Date Left Active Duty Within 387 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA :'.' NA . • No NA This response reflects mii4e-tile individual tett active dutystatus within 38i days Preceding the Activ' e'Duty Status Date The Member or His/Her Unit Was Notified of a Future CaB-Up to Active Duty on Achy' e Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA •:.NA %:.. NA . ,,,,... This response reflects w ethe'thit.dividuaIorhislher unit has raseived eudy notification'to report for active duly Upon searching the data banks of the Department of Defense Mahpower Data'penter; basad 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 UnifOrrakiSerViiiei (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 I C 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:/twww.defenselink.mil/faq/pis/PC09SLDR.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. Tale 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: NEFCZ007M07E4A0