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Home My WebLink About14-5259 Su reme Court.-of_Pennsylvania Court-' f3 Co i6n Pleas V t{Cr. ' -1 N- et For Prothonotary Use Only. TIME STAMP CA' ove�Sfi Docket No: CUMBERLAND County The information collected on this form is used solely for court administration putposes. This fonn does not supplement or replace the alio and set-vice ofpleadings or other a ers as required by law or•rules of court. Commencement of Action: S ® Con plaint ❑ Writ of Sunumns ❑Petition E ❑ Transfer from Another Jurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC ERIN FERGUSON T I Dollar Amount Requested: X within arbitration limits � i Are money damages requested. ® Yes ❑ No q t (Check one) outside arbitration linuts N Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ®No Name ofPlaint0Appellant's 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 Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Credit Card ❑ Board of Elections ❑ Nuisance 0 Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other ❑ Product Liability(does not include S mass tort) ❑ Employment Dispute: E ❑ Slander/LibeliDefamation Discrimination ❑ Zoning Board ❑ Other: ❑ Employment Dispute:Other ❑ Other: CI T ❑ Other: MASS TORT Q ❑ Asbestos N ❑ Tobacco E] Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration B ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ 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: 16-41519 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 t rt � = 120 Corporate Blvd � � � `+� S ' Norfolk, VA 23502 TELE: 1-866-428-8102 860 CUR( Ailyo COU Attorneys or Plaint f �ff PENINS YLAN1,q;,T y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. _l/ Plaintiff, V. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 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 16-41519 (717) 249-3166 /, W�,,,"`•l Q SCS/�y� E)('?C? 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. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 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 caro 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 16-41519 Esta connnlicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier .infromacion 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 P laintiff, No. V. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 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, ERIN FERGUSON, is an adult individual with last known address of 323 BARNSTABLE RD, CARLISLE PA 17015. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/WAL-MART on October 11, 2005 with account number ************0411 (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. Tlus communication is from a debt collector and is an attempt to collect a debt. Any inlormation 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 March 24, 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$2,508.63. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, ERIN FERGUSON, in the amount f$2,508.63, plus cost t is ction and any other relief as the Court deems just and reason e� e A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 16-41519 This connnunication is frown a debt collector and is an attempt to collect a debt. Any i.n:l:ormation obtained will be used for ghat purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, LarryJ, And hereby states that he/she is authorized to take this verification on behalf of said Pla�in`'tifff. 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: AUG 14 2094 Larry J. Andrews Custodian of Records 16-41519 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ...................................... .... .............. . �.:. 9L L4 }q. . . . . GECapital .. . BILL of SALE. .: .. PRA PLCO Fresh:-�Deceiaber 2413 For value received'aiid in further consideration of the.mutual covtnants and conditions set.forth in:the Forward'Flow Receivables Purchase.Agreeni it(the Agreement.),dated as of this 9. da.:of July,2013 by and ::. , . lietween.General Electric Capital Corporation,GE Capital Retail 13s1X GE MB Lending,Inc:,Mono Credit . . l' :Services.;L.L.C.;RFS Holding,L:L:C:,:and'GEM Holding;L.L.C:{collectively"Se.11ee,):aiid:Portfoli0. Recovery Associates;LLC.("Buyer"),Seller hereby:transfers;sells,conveys,,gants;and:delivers to Buyer;its. .. . . successors and assigns;without recourse except asset forth in the Agreement;to tha extent of its ownership,the: . Receivables:as set forth in the Notification Files(as defined in the Agreement),delivered by:Seller_to Buyer oil December 10,:'2013,and:as:further described.in:the.Agreement; GE Capital Retail Bank. Monogram.Credit Services,:L.L.C: By... K'n:Wojcik Attorney in F Ken M"i'k........ Title: EVP:Collections&Reoove,.ry .. Dater ........................................... Date: k-,-OG :f {. . . :.:. . .. .. .. .. .. ding;I.I::C RFS HoT G-eneral.Eiectrie Capital Corporation Y. Attorney in.Factken Wojcik Attorney in_Fad Ken'Wojcik : :::: Date0&'-�( . ... ... .. Dat l` :.:. GEM Holding,L .L.0 :. : .. GEMB Lending'.Inc r Attorney in.FaW Ken Wojcik . . . . Attorney.in.Fact en Wo'cik. Date: ..0 Date:: OC. 00q . :(c(.... ares;LLC . Portfolio:Recovery Associ .. sy: Title:_ / `4w 414e� Walmart � x Save money.Live better. Walmart® ERIN MFERGUSON Visit us at Credit Card Account Number: —0411 Customer Service:1-800-641-4526 7AvailableCredit f Account Activity lance [Payment yment Information $2,508.63 w Balance $0.00 its $2,508.63 ount Past Due ce $0.00 $0.00 al Minimum Payment Due $640.00 Due Date 11/04/2013$5,000 e Payment Wamming:lf we do not receive your minimum edit Cash Advance/Quick Cash Limit $0.00$400 payment by the date listed above,you may have to pay a late Available Cash fee up to$35.00. Statement Closing Date $0.0011/03/2013 Days in Billing Cycle 30 FDatePost ary Reference Number Description of Transaction or Credit Plan Type AmountF9112009KO0999990 CHARGE OFFACCOUNT-PRINCIPALS ($2,061.07)F9112009KO0999990 CHARGE OFF ACCOUNT*FINANCE CHARGES' ($447.56) FEES TOTAL FEES FOR THIS PERIOD $0.00 11/03 11/03 INTEREST CHARGED 11/03 11/03 INTEREST CHARGE ON PURCHASES $0.00 INTEREST CHARGE ON CASH $0.00 ADVANCES TOTAL INTEREST FOR THIS PERIOD $0.00 2013 Totals Year-To-Date ETOWFeesarged in 2013 $251.36 charged in 2013 $441.48Paid in 2013 $245.67 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 Date 1 Interest Charge Regular Purchases&Cash Type Rate Interest Rate NA REG 22.90%(v) $0.00 Advances $0.00 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 Walmart®Credit Card or Walmart®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. PAYMENT DUE BY 5 P.M.(ET)ON 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 4 131103 Z D PAGE 1 of 1 9112 1900 0209 01D05409 Detach and mail this portion with your check.Do not include any correspondence with your check. —� Waimart#' '�, Account Number 0411 Total Minimum Amount Past Due Payment Save money.five better, # Payment Due Due Date New Balance $640.00 $0.00 1 11/04/2013 $0.00 Please Payment Enclosed: ❑❑❑❑ ❑■ ❑❑ IIIIIIIIIIIIIIIII�IIIIIIIInIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII�llllllllllllllllll�llllll use blue or black ink. New address or email?Print changes on back. ERINNM FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015-7402 Make Payment To:WALMART/GECRB P.O.BOX 530927 ATLANTA,GA 30353-0927 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson LtJOFFiCE__ Sheriff (,)- THE PROTHONO ol Climb Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF TRE SHE,RIFF 20I1ISEP 22 PM 2: 29 CUMBERLAND COUNTY PENNSYLVANiA Portfolio Recovery Associates, LLC vs. Erin Ferguson Case Number 2014-5259 SHERIFF'S RETURN OF SERVICE 09/11/2014 07:28 PM - Deputy Dawn Kell, 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: Erin Ferguson at 323 Barnstable Road, W. Pennsboro, Carlisle, PA 17015. ZclArn KiLQ.L DAWN KELL, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, September 16, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleoseit, 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. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 Date: /(/d Li/Ly 16-41519 No. 14-5259CIVIL . PRAECIPE FOR DEFAULT Defendant : JUDGMENT Filed on Behalf of Plaintiff Coups •' ecord for this P C7, - C=3 - rn -,- _ -74 ,1 1'-1 ' Pri --=- 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 *1(o. 5o po wiry e, &Di 13L) 3¢0(3 . mmi 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 v. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 Defendant No. 14-5259CIVIL PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, ERIN FERGUSON, for failure to answer the Complaint. (X) Amount Due $2,508.63 Less Credits $.00 TOTAL $2,508.63 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to 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. (X 16-41519 Pursuant to PARC.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 to be entered and to his/her attorney of record, if any, aft r the default occurred an. cast ten days prior to the date of the filing of this pr .%' and a copy of thenom ... ttached. //iii f 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 This communication. is iliom 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 ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. ERIN FERGUSON 14-5259CIVIL Dear ERIN FERGUSON: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 16-41519 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 '• JOS This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CML ACTION—LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 Plaintiff No. 14-5259CIVIL Defendant TO: ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 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. 16-41519 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 #201259/94055/312686/20506i Portfolio Recovery Associates, LLC 'rte 120 Corporate Blvd Norfolk, VA 23502 ' ` Attorneys for Plaintiff !" j" 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 COUNIY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 Defendant No. 14-5259CIVIL 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 323 BARNSTABLE RD CARLISLE PA 17015 and is not in the military service of the United States or its Allies, or otherwise within the provisis s of the Service Members Civil Relief Act and its Amendments. 16-41519 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 Repott Pursuant to Servicentembers Civil Relief Act Last Name: FERGUSON First Name: ERIN Middle Name: Active Duty Status As Of: Nov -03-2014 Results as of : Nov -03-2014 04:06:34 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA . - . No NA This response reflects theindividualsactive duty status based on the'ActiVe Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA . - . NA " • No NA This response reflects Ai:Tillie individual left active dutystatus within 367days 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 NA NA No NA This response reflects whether the individual or his/her unit has received early natifitiorfio 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 UniformedServices (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 cat 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: 1 FX39EE360D8C00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATFS, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. ERIN FERGUSON 323 BARNSTABLE RD CARLISLE PA 17015 Plaintiff No. 14-5259CIVIL Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above -captioned matter has been entered against you in the amount of $2,508.63. (X) A copy of all documents filed with the Prothonotary in sudgment is/ar attached. If you have any questions regarding this Notice, 16-41519 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 :fiom a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose.