HomeMy WebLinkAbout14-6318 Supreme .Co,��of Pennsylvania
Court•'of Common Pleas
j.,/ -N11 u I °;: For Prothonotary Use Only: •IT\.I E STA:A P
CivilCover S fhe.et Docket N
CUMBERLAiD Count
Y
The infonnation collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefilh!g and service ofpleadings or other a ers as required by law or rules of court.
S Commencement of Action:
E ® Complaint ❑ Writ ofSti morons ❑Petition
C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking
k Lead Plaintiffs NamNan
e: Lead Defendant's Nae:
{ T PORTFOLIO RECOVERYASSOCIATES,LLC ILANA BOYUM
I` I
O Are money damages requested? ® Yes 11 No Dollar Amount Requested: X within arbitration limits
N f (Check one) outside arbitration limits
A Is this a Class Action Suit? ❑Yes ® No Is this an AMJAppeal? ❑Yes ®No
Name of PlainttffAppellant'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)
i
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 ® Debt Collection Other ❑ Dept.of Transportation
❑ Premises Liability ❑ Statutory Appeal:Other
S ❑ Product Liability(does not include
E mass tort) ❑ Erriployment Dispute:
❑ Slander/Lbel/Defamation Discrimination ❑ Zoning Board
C ❑ Other: Cl Employment Dispute:Other ❑ Other:
T
I ❑ Other:
O MASS TORT
N ❑ Asbestos
❑ Tobacco
F1 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS
B I ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration
❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Other: ❑ Found Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations
❑ Mortgage Foreclosure:Residential Restraining Order
❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto
❑ Partition ❑ Replevin
C PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
17-02248
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 r,
Norfolk, VA 23502 ` ' s
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 2V
VA 23502
NORFOLK, � 1
P laintiff,
V.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
Defendant.
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the following pages,
you must take action withing twenty (20) days after this Complaint and Notice are served, by entering a
written appearance, personally or by an attorney, and filing in writing with the Court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so, the case may
proceed without you and a judgment may be entered against you by the Court without further notice of
any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or
property rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service - CUMBERLAND County Bar Association
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 1
17-02248Z#- 3
This communication is from a debt collector and is an attempt to collect a deb4PR
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.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
Demandado.
NOTICIA
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas
en ]as siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda
y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando
por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es
advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta
usted por ]a Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo
o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para
usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI LISTED NO TIENE UN
ABOGADO,VAYA O 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 APERSONAS
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
17-02248
Esta comtniicacion es de un cobrador de deudas y es Lin intent do cobras 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
Plaintiff, No.
V.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
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, ILANA BOYUM, is an adult individual with last known address of 8 DOGWOOD
CIR, SHIPPENSBURG PA 17257.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/LOWE'S on
October 14, 2007 with account number ************4919 (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 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 August 3, 2012.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/
LOWE'S 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$2,706.56.
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, ILANA BOYUM, in the amount of$2,706.56, plus co of his action
and any other relief as the Court deems just and reasona
rrie A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, #201259
Mark R. Garvey, Esquire, #312686
Attorneys for Plaintiff
17-02248
This conununication is from a debt collector and is an attempt to collect a debt.
Anv information obtained will be used for 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: SEP 3 0 2014 By:
r �(
Y
Elaine Freeman-Lark
Custodian of Records
17-02248
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.
............. .............. ... . ..... ... ............. .. ........ .... ......... ......... . .. .... ...... ........... . . ......
GE Capital
BILL of SALE
PRA PLCC Fresh--Apri12013
For value received and in further consideration of the mutual covenants and:conditions
set forth in the Forward Flow Receivables Purchase Agreement(the "Agreement"), dated
as of the 13` day of- December; 2012- 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 April
22,2013,and as further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: P T By:
Glenn Marino Glenn Marino
Title:_EVP Title:_President
Date: —5 -�` - 13 Date: ! ' •�--(3
General Electric Capital Corporation RFS Holding,L.L.C.
By: By
Glenn Marino Joseph Ressa.
Title: _Vice.President Title: CFO
Date: Date:
GEMB Lending, Inc, GEM Holding,L.L.0
By: By:
Stephen Motta Joseph Ressa
Title: Director Title:_CFO
Date: Date:
f GE Capital
BILL of SALE
PRA PLCC Fresh—April 2013
For value received and in further consideration of the mutual covenants and conditions
set forth in the Forward Flow Receivables Purchase Agreement(the "Agreement"), dated
as of the 13"' day of December, 2012 by and between General Electric Capital
Corporation, GL Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services,
L.L.C., RES 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 April
22, 2013, and as :further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: By.
Glenn Marino Glenn Marino
Title:_EVP Title: President
Date: Date:
General Electric Capital Corporation RF ming, L.L.0
By: By=
Glenn Marino Joseph Re a
Title:_Vice President Title: CFO
Date: Date: r �
GEMB Lending, Inc. GEM ing, L.L.0
By: By:
Stephen Motta Joseph Ress
Title: Director Title:_CFO
Date: Date: _ 5i. ! V 13
Lowe's®Credit ILANA C BOYUM
Card Account Account Number �91 9 Visit us at www.lowes.com/credit
Customer Service: 1-800-568-0156
Summary of Account Activity Payment Information
Previous Balance $2,706.56 New Balance
- $0.00
Payments
$0.00 Amount Past Due $0.00
-Other Credits $2,706.56 Total Minimum Payment Due $730.00
+Purchases/Debits $0.00 Payment Due Date 03/22/2013
+Fees Charged $0.00 Late Payment Warning:lf we do not receive your
+Interest Charged $0.00 minimum payment by the date listed above,you may have
New Balance $0.00 to pay a late fee up to$35.00.
Credit Limit $2,100.00
Available Credit $0.00
Statement Closing Date 03/20/2013
Days in Billing Cycle 28
Transaction Summary
Tran Date Post Date Reference NLmber/
Invoice Number Description of Transaction or Credit Amount
03/20 03/20 CHARGE OFF ACCOUNT-PRINCIPALS ($2,182.50)
03/20 03/20 CHARGE OFF ACCOUNT*FINANCE CHARGES" ($524.06)
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
03/20 03/20 - INTEREST CHARGE ON PURCHASES $0.00
TOTAL INTEREST FOR THIS PERIOD $0.00
2013 Totals Year-to-Date
Total Fees Charged in 2013 $0.00
Total Interest Charged in 2013 $119.34
Total Interest Paid in 2013 $0.00
Interest Charge Calculation
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Expiration Annual Balance Subject Interest Balance
Type of Balance Date Percentage Rate To Interest Rate Charge Method
Regular Purchases NA 26.99% $0.00 $0.00 2D
Important Account Information
Please Note:Enclosed is the Privacy Policy for this account.Please take a moment to read it,then keep it with other financial
documents.If you have previously opted-out,you do not need to do so again.
If your account has a deferred interest promotion and you would like us to apply a payment on your account in a different
way,please call Customer Service to discuss other options that may be available.
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 Information and other
important information.
7009 X5G 1 3 20 130320 ZX PAGE 1 of 1 9294 0010 D002 OICX7009
Detach and mail this portion with your check.Do not include any correspondence with your check. —I
Account Number: 91 9
Total Minimum Amount Payment New Balance
Payment Due Past Due Due Date
$730.00 $0.00 03/22/2013 I $0.00
Payment Enclosed: s a[I F1[10.
❑
�I IIIINIIIIIIIII�IIIIIIIIIIIIId IIIA�I III III Please use blue or black ink. New address or email?Print changes on back.
]LANA C BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257-9446 Make Payment to:LOWE'S/GECRB
P.O.BOX 530914
ATLANTA,GA 30353-0914
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson EIL[D -OFFICE:
SheriffL
. , I.1i�. THE r`1�O j l iUiiO !ARta
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OP,CICE OF THE iRIFF
1014 NOV 17 PM 3: 06
'CUMBERLAND COUNTY
PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs.
liana C. Boyum
Case Number
2014-6318
SHERIFF'S RETURN OF SERVICE
11/04/2014 08:37 PM - Deputy Christopher Sharpe, 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: liana C. Boyum at 8 Dogwood Circle, Shippensburg Township, Shippensburg, PA
17257.
CHRISTO ER S RPE, DEPUTY
SHERIFF COST: $50.60 SO ANSWERS,
November 05, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuito Sheriff, Teieosofi, 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
No. 146318civil
v.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257 •PRAECIPE FOR DEFAULT
Defendant •JUDGMENT
Date:
17-02248
/1fAr
Filed on Behalf of Plaintiff
Counsel of -Record for this P
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
OM 1ip sold aMI
ele (097/933
NO-b(e ,., at
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. 146318civil
v.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, ILANA BOYUM, for failure to
answer the Complaint.
(X) Amount Due $2,706.56
Less Credits $.00
TOTAL $2,706.56
(X
(X)
(X
17-02248
I certify that the foregoing assessment of damages is for specified amounts alleged to be
due in the complaint and is calculable as a sum certain from the complaint.
Pursuant to PARC.P.237 (Notice for Final Judgment or Decree), I certify that a copy of
this praecipe has been mailed to each other party who appeared in the action or to his/her
attorney of record.
Pursuant to PAR.C.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, ate. - . the default occurred and at least ten days
prior to the date of the filing of this pr. ; e and a copy of the j,: v is attached.
,///
obert N. Polas, Jr., Esquire, # 201259
Carrie A Brown, Esquire, # 94055
Mark It 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 infonnation 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. 146318civil
v.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
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 $2,706.56.
(X) A copy of all documents filed with the Prothonotary in support o the Alf j
attached.
If you have any questions regarding this Noti
17-02248
BY:
t is/are
r
vF�
contact the f
Robert N. Polas, Jr., Esquire, # 201259
Carrie A. Brown, Esquire, # 94055
Mark R Garvey, Esquire, # 312686
Gregory J. Babcock, Esquire, #205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
(T) 1-866-428-8102
(F) (757) 518-0860
Attorneys for Plaintiff
This communication is from. a debt collector is an. attempt to collect a debt.
Any information obtained will be used for that purpose.
PORTFOLIO RECOVERY ASSOCIATES, LLC
Litigation Department
120 Corporate Blvd Norfolk, VA 23502
Telephone: 1-866-428-8102 Fax (757) 518-0860
Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM,
Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST)
November 25, 2014
ILANA BOYUM
8 DOGWOOD CIR
SHIPPEl SBURG PA 17257
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. ILANA BOYUM
146318civil
Dear ILANA BOYUM:
Enclosed herein please fmd a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of
Civil Procedure.
17-02248
Sincerely,
Robert N. Polas, Jr., Esq. / Carrie A. Brown, Esq.
Mark R Garvey, Esq. / Gregory J. Babcock, Esq.
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 TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION — LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff No. 146318civil
v.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
Defendant
TO: ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
DATE OF NOTICE: November 25, 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.
17-02248
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., Esq. / Carrie A Brown, Esq.
Mark R. Garvey, Esq. / Gregory J. Babcock, Esq.
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.
ILANA BOYUM
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
Defendant
No. 146318civil
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
8 DOGWOOD CIR
SHIPPENSBURG PA 17257
and is not in the military service of the United States or its Allies, or otherwise within the provisions of
the Service Members Civil Relief Act and its Amendments.
17-02248
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 Report
Pursuant to Servicemembers Civil. Relief Act
Last Name: BOYUM
First Name: !LANA
Middle Name:
Active Duty Status As Of: Dec -15-2014
Results as of : Dec -15-2014 02:46:31 PM
SCRA 30
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA .•: ,:.'
.
NA
..No
This response reflects thelndivicnalsactive duty status based on the:ActiveDuty 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
-- ' No
NA
This response reflects wheieiile individual left active duly.status within 367 days preceding the Active Duty Status Date
The Member or HistHer 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
NANA
. . . .
This response reflects whether.the individual or his/her unit has received early notifiCation'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.
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Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
-110140.-