HomeMy WebLinkAbout14-5264 Supri'me Cour"'. f.Pennsylvania
�Lour;i1wCM-oUbn Pleas
For Prothonotary Use Only: TIME STAMP
C' Ve 1_; " 'e t
Docket No:
cum County
The in formation collected on this form is used solely for count administration purposes. This form does not
supplement or replace thefiling and service of pleadings or otherpapers as required by law or rules of court.
Commencement of Action:
Sj [N Complaint E] Writ of Summons FlPetition
E n Transfer from Another Jurisdiction 0 Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T
PORTFOLIO RECOVERY ASSOCIATES,LLC TYLER PHILLIPS
0 Are money damages requested?19 Yes 0 No Dollar Amount Requested: X within arbitration limits
N I (Check one) outside arbitration limits
Is this a Class Action Suit? 0 Yes 0 No I Is this anAMJAppeal? DYes ®No
Name of PlaintifflAppeDants Attorney Robert N.Polas,Jr./Carrie Brown/Mark R.Garvey
[3 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
n Intentional E3 Buyer Plaintiff Adininistrative Agencies
M Malicious Prosecution n Board of Assessment
F-1 Motor Vehicle 0 Debt Collection:Credit Card n Board of Elections
F-1 Nuisance 0 Debt Collection:Other n Dept.of Transportation
M Premises Liability 0 Statutory Appeal:Other
E] Product Liability(does not include
S mass tort) El Employment Dispute:
E F-1 S hrider/LibeVDefamation Discrimimlion n Zoning Board
C F1 Other: E3 Employment Dispute:Other j-1 Other:
T
MASS TORT E] Other:
0 F1 Asbestos
N n Tobacco
E] Toxic Tort-DFS REAL PROPERTY MISCELLANEOUS
n Toxic Tort-Implant C3 Ejectment 0 Common Law/Statutory Arbitration
B r-1 Toxic Waste 0 Eminent Domairt/Conden-mation n Declaratory Judgment
r-1 Other: F-1 Ground Rent n Mandamus
Ei Landlord/Tenant Dispute E] Non-Domestic Relations
C3 Mortgage Foreclosure:Residential Restraining Order
• Mortgage Foreclosure:Commercial [I Quo Warranto
• Partition Cj Replevin
PROFESSIONAL LIABILITY 0 Quiet Title ri Other:
0 Dental F-1 Other:
E3 Legal
Fj Medical
n Other Professional:
16-37542
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 Ftcl]T14O� pT�'
Norfolk, VA 23502 SEP _9
TELE: 1-866-428-8102r
FAX: (757) 518-0860 CUt"L ERL IitiD C
Attorneys for Plaintiff EMYS YLV�rOUNT`r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502 No. � J
Plaintiff,
V.
TYLER PHILLIPS
208 S LOCUST ST y
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
Carlisle, PA 17013 5
(717) 249-3166 1 A
16-37542 � �A4 � �f S, 7S ?A
C'"%wq
?.* '-� 00035
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
1.20 CORPORATE BLVD
NORFOLK, VA 23502
Demandante, No.
V.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Demandado.
NOTICIA
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta]a demanda puestas
en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dial 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 or 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
16-37542 (717)249-3166
Esta co.mwucacion es de un cobrador de deudas y es un intent do cobrar una deuda.
Ctialquie.r.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 :
Plaintiff, No.
V.
TYLER PHILLIPS
208 S LOCUST ST
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, TYLER PHILLIPS, is an adult individual with last known address of 208 S LOCUST
ST, CAMP HILL PA 17011.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/WAL-MART on
November 15, 2012 with account number ************5893 (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 communication is from a debt collector and is an attempt to collect a debt.
Any inl:orrnation 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.
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$1,479.29.
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, TYLER PHILLIPS , in the am of$1,479.29, plus c o t action
and any other relief as the Court deems just and reas able
Carne A. Brown, Esquire, #94055
Robert N. Polas, Jr., Esquire, #201259
Mark R. Garvey, Esquire, #312686
Attorneys for Plaintiff
16-37542
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates,LLC,
hereby states that he/she is authorized to take this verification on
arty J. Andrews
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:
p,�G 14104
Larry J. Andrews
Custodian of Records
16-37542
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
XHIBI 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.
UgCI0o
330433 9612 GE CAPITAL RETAIL BAN
11:54:25a.m. 08-21-2013 4118
UO
GL Capital
BILL of SALE
PRA PLCC Fresh-July 2013
For value received and in further consideration of the mutual covenants and conditions set forth in the
Forward Flow Receivables Purchase Agreement(the"Agreements'),dated as of this l lt"day of July,2013 by
and between General Electric Capital Corporation,GE Capital Retail Bank,GEMB Lending,Inc.,Monogram
Credit Services,L.L.C.,RFS Holding,L.L.C.,and GEM Holding,L.L.C.(collectively"Seller")and Portfolio
Recovery Associates,LLC("Buyer"),Seller hereby transfers,sells,conveys,grants,and delivers to Buyer,its
successors and assigns,without recourse except as set forth in the Agreement,to the extent of its ownership,the
Receivables as set forth in the Notification Files(as defined in the Agreement);delivered by Seller to Buyer on
July 22,2013,and as further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: By: f
Ken WojciU-)�—&k. Attorney in Fa en Wojcik
Title: EVP Collections&Recovery,_., Date:
Date: - t ,{
RFS Holding,L.L.0
General Electric Capital Corporation By:
Attorney in Fact K n Wojcik
By: og.t�_t3
Attorney in Fact Wojcik Date:
Date: bg,!G -l75
GEM Holding,L.L.0
GEMB Lending,Inc. By: ---�—
Attomey�inFact en Wojcik
By WDate: 0$•r ,- {�_ �?
Attorney in Fact K Wojcik
Date: p8- b -t3
Portfolio Recovery Associates,LLC
By: Gs
Title: '
Walmart A�®.
Save money.Live better.
� A
Walmarto TYLER M PHILLIPS Visit us at walmart.com/credit
Discover Card AccountNumber�5893 Customer Service:/-866-314-9507
Summary of Account Activity Payment Information
Previous Balance $1,479.29 New Balance $0.00
-Other Credits $1,479.29 Amount Past Oua $0.00
New Balance $0.00 Total Minimum Payment Due $411.00
Payment Due Date 06/21/2013
Credit Limit $1.200 Late Payment Waming:lf 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 $240 fee up to$35.00.
Available Cash $0.00
Statement Closing Date 06/19/2013
Days in Billing Cycle 28
Cash Earned Summary Cash News
Previous Balance $0.00 Earning cash back with the Walmart®DiscoverO
(+)Earned This Period $0.00 is easy! Simply use your card everywhere
=Balance $0.00 Discover® is accepted.Remember every
time you earn just$10,you will receive a
check in your billing statement-it's automatic.
Transaction Summary
Tran Post
Date Date Reference Number Description of Transaction or Credit Amount
06/19 06/19 F6210005AO0999990 CHARGE OFF ACCOUNT-PRINCIPALS ($1,194.62)
06119 06/19 F6210005AO0999990 CHARGE OFF ACCOUNT*FINANCE ($284.67)
CHARGES`
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
06/19 06119 INTEREST CHARGE ON PURCHASES $0.00
06/19 06/19 INTEREST CHARGE ON CASH ADVANCES $0.00
TOTAL INTEREST FOR THIS PERIOD $0.00
2013 Totals Year-To-Date
Total Fees Charged in 2013 $105.00
Total Interest Charged in 2013 $131.09
Total Interest Paid in 2013 $0.00
Interest Charge Calculation
Your Annual Percentage Rate(APR)s the annual interest rate on your account.
Type of Balance Expiration Date Annual Percentage Balance Subject To Interest Charge
Rate Interest Rate
Regular Purchases NA 22.90%(v) $0.00 $0.00
Cash Advances NA 25.90%(v) $0.00 $0.00
(v)=Variable rate
Cardholder News and Information
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.
PAYMENT DUE BY SPM /FTI QtI THE DUE DATE.
NOTICE We may convert your payment into an electronic debit.See reverse for details,Billing Rights and other important
information.
5404 aGH 1 3 19 130619 Z X PAGE 1 of 1 6210 1.100 A403 OlDF5404 —I
Detach and mail this portion with your check.Do not include any correspondence with your check.
Account Numbe�1 $
5893
Walmart v e, Total Minimum Amount Payment Due Overlim
Save money.Live better. Payment Due Past Due Date Amou
$411.00 $0.00 06121/2013 $0.00
Payment Enclosed: $ ❑❑❑❑ ❑Please ■ ❑❑
I�I���IIIIIAIII�Il�ll6ll�Gl�����lll�l�llll�IIIIIII�II�IIIII use blue or black ink. New address or email?Print changes on back.
TYLER M PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011-6765 Make Payment To:WALMART DISCOVER/GECRB
PO BOX 960024
ORLANDO,FL 32896.0024
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF CF, OF 11*, SRER1FF
�1� -|•���`
HE.��DTi�������>�
71ri SFP 30 3: (7 CUMocR/I'M C�H�_v
PFNNS YLV8N)-� '
Portfolio Recovery Associates, LLC (et al.)
vs.
Tyler Phillips
Case Number
2014-5264
SHERIFF'S RETURN OF SERVICE
09M9C2014 04:25 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Nancy Click, N1other, who
accepted as "Adult Person in Charge" for Tyler Phillips at 208 S. Locust Sbeat, Lower Allen, Camp Hill,
PA 17011.
DAWN KELL, DEPUTY
09/22/2014 06:24 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Nancy Click, Defendant's Aunt,
who accepted as "Adult Person in Charge" for Tyler Phillips at 208 S. Locust Street, Lower Allen, Camp
Hill, PA 17011.
" ,.~~~_°L
DAWN KELL, DEPUTY
SHERIFF COST: $81.90 SO ANSWERS,
September 22, 2014
(h1CountySelie Sheriff, Toleosoft, inc.
RONNYRANDERSON, SHERIFF
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.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Defendant
Date: (l /,
16-37542.
No. 14-5264CIVIL
c).
n
PRAECIPE FOR DEFAULT c:. -„ -- 4
JUDGMENT -r
-It � r ` _ .
rn -,re�tri
7 C)
rJ -- C', i
Filed on Behalf of Plaintiff
Counsel of : _ : ,. for this Party
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
X1101� c631}
C�,1t loogS.3
"fzkt- 3i4o2a�
wAi_k
This communication is from a debt collector is an attempt to collect a debt.
Any information obtained will be used for that purpose.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff No. 14-5264CIVIL
v.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of. Plaintiff and against Defendant, TYLER PHILLIPS, for failure to
answer the Complaint.
(X) Amount Due $1,479.29
Less Credits $:00
TOTAL $1,479.29
(X
(X
(X)
16-37542
I certifythat the foregoing assessment of damages is for specified amounts alleged tobe
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 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 • - the default occurred an.. eas ten days
prior to the date of the filing of th. a e and a copy of e .,, ached.
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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
v.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Plaintiff No. 14-5264CIVIL
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 $1,479.29.
(X) A copy of all documents filed with the Prothonotary in support the wi
attached.
If you have any questions regarding this N
16-37542
BY:
contt t
Cs
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.
PORTFOLJO 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
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS.' TYLER PHILLIPS
14-5264CIVIL
Dear TYLER PHILLIPS:
Enclosed herein please find a 10 -Day Notice pursuant to Rule 237. I of the Pennsylvania
Rules of Civil Procedure.
16-37542
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
CML ACTION— LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff
v.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Defendant
TO: TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
DATE OF NOTICE: October 13, 2014
IMPORTANT NOTICE
No. 14-526401 VI L
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.
16-37542
Lawyer Referral Service - CUMBERLAND County Bar Association
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Robert N. Polas, Jr., Esquire
Carrie A Brown, Esquire
Mark R. Garvey, Esquire
Gregory J. Babcock, Esquire
Attorney ID #201259/94055/312686/205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff
v.
TYLER PHILLIPS
208 S LOCUST ST
CAMP HILL PA 17011
Defendant
No. 14-5264CIVIL
A1h'N'1RMATION 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
208 S LOCUST ST
CAMP HILL PA 17011
and is not in the military service of the United States or its Allies, or otherwise within the pr
the Service Members Civil Relief Act and its Amendments.
16-37542
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.
12-81569 -- Pleading Failed
Reason: XDISPUTE on account, no XDSPRSLV.
This communication is a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
Department of Defense Manpower Data Center
Status Report
Pursuant to Serviceinembers Civil. Relief Act.
Last Name: PHILLIPS
First Name: TYLER
Middle Name:
Active Duty Status As Of: Nov -07-2014
Results as of : Nov -07-2014 05:42:22 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 ..
.:14.....
NA
This response reflects the individuals' active duty status based on the'Active Duty Status Date
• Left Active Dirty Within 367 D of Active Duty Status Date
Active duty Start Date
Active Duty End Date
' Status
Service Component
- NA
i NA
... No ....
_. NA
This response reflects where the individual left active duty.status within 387days 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 .rJ%:, {
- NA
This response reflects whether the individual or hisTher unit has received early notifrcation'to 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 Uniformed'Services (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: httpl/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: 6FN6F166907A0C0