HomeMy WebLinkAbout14-6320 Supreme,Cqqrt-pf Pennsylvania
Cou Mon Pleas TINIE STAI%4P
-I Y1 For Prothonotap31 Use Only.
V7A%r
I If
G Dver) bet Docket No:
, 1 G�j�
CUMB D County
The infonnation collected on this form is used solely for court administration ptuposes. 77iisfiornr does not
supplement or replace thefilitT and service ofpleadings or other papers as required by law or rules of court.
S Conunencernent of Action:
E EN Con-plaint E] Writ of Sumnons ❑Petition
n Transfer from Another Jurisdiction E]Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T PORTFOLIO RECOVERY ASSOCIATES,LLC LYNN SCOTT
I
0 Are money damages requested? 0 Yes 0 No Dollar Amount Requested: X within arbitration knits
N (Check one) outside arbitration knits
A is this a Class Action Suit? 0 Yes 0 No Is this an AMJAppeal? 0 Yes H No
Name offlaintifflAppellants Attorney.Robert N.Polas,Jr./Carrie Brown/Mark R.Garvey
D 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
El intentional n Buyer Plaintiff Admirfistrative Agencies
C] Malicious Prosecution n Board ofAssessment
F-1 Motor Vehicle 13 Debt Collection:Credit Card n Board of Elections
❑ Nuisance 9 Debt Collection:Other 0 Dept.of Transportation
Premises Liability 0 Statutory Appeal:Other
Sn Product Liability(doesnot include
E mass fort) 0 Employment Dispute:
E] Slander/Libel/Defamation Discrimination C3 Zoning Board
C y n Other. 0 Employment Dispute:Other El Other:
T
I n Other:
0 MASS TORT
N 0 Asbestos
n Tobacco REAL PROPERTY MISCELLANEOUS
ri Toxic Tort-DES 0 Ejectment E] Common Law/Statutory Arbitration
B n Toxic Tort-Implant [3 Eminent DomairXondemmtion El Declaratory Judgment
M Toxic Waste 0 Ground Rent 0 Mandamus
C3 Other Fi Landlord/Tenant Dispute r-1 Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
0 Mortgage Foreclosure:Commercial n Quo Warranto
0 Partition n Replevin
PROFESSIONAL LIABILITY CD Quiet Title F1 Other,
n Dental n Other:
E] Legal
n Medical
n Other Professional-
17-06613
RobdrtBlas, Jr., Esquire PA Bar#201259
Carrie B wn, Esquire PA Bar#94055
Mark R. Garvey, Esquire PA Bar# 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd r ;
Norfolk, VA 23502 - f
TELE: 1-866-428-8102
FAX: (757) 518-0860Tr
` ' r :f F;t•+
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 No.
Plaintiff,
V.
LYNN SCOTT
10 CARDINAL DR
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
17-06613
(717) 249-3166 ''S
3i�0a
This communication is from a debt collector and is an attempt to collect a deft:
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
1N 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.
LYNN SCOTT
10 CARDINAL DR
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 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 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 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
17-06613
Esta comunicacion es de un cobrador de deudas y es un intent do cobrar una deuda.
Cualquie.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.
LYNN SCOTT
10 CARDINAL DR
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, LYNN SCOTT, is an adult individual with last known address of 10 CARDINAL
DR, CARLISLE PA 17015.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/OLD NAVY on
April 13, 2006 with account number ************2474 (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 i_n1brmation obtained will be used i:or 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 October 27, 2011.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/
OLD NAVY 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$918.90.
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, LYNN SCOTT , in the amount-of$918.90, p s costs f this action and
any other relief as the Court deems just and reasonabl
Carrie A. Brown, Esquire, #94055
Robert N. Polas, Jr., Esquire, #201259
Mark R. Garvey, Esquire, #312686
Attorneys for Plaintiff
17-06613
This conununication 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,
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:
Elaine Freeman-.Lark
Custodian of Records
17-06613
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
I
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
GEC041
UIRGE Capital
BILL of SALE
PRA Fresh=April 2012
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 201h day of December, 2011 by and between General Electric Capital
Corporation, GE Money 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 19, 2012, and
as further described in the Agreement.
General Electric Capital Corporation GEMB Lending, Inc.
By.
By:
Title: Glenn Marino-Vice President Title: Stephen Motta-Director
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: V /f-�. �`,. By:
Title: Glenn Marino-EVP Title: Glenn Marino-President
RFS Holding,L.L.C. GEM Holding,L.L.C.
By: By:
Title: Vishal Gulati-CFO Title: Vishal Gulati-CFO
GE Capital
BILL of SALE
PRA Fresh—April 2012
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 20`x' day of December, 2011 by and between General Electric Capital
Corporation, GE Money 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 19, 2012, and
as fiuther described in the Agreement.
General Electric Capital Corporation GEMB Lending,Inc.
By: By:
Title: Glenn Marino-Vice President Title: Stephen Motta-Director
GE Capital Retail Bank Monogram Credit Services,L.L.C.
By: By:
Title: Glenn Marino-EVP Title: Glenn Marino-President
RFS Holding,L.L.C. GEM Holding,L.L.C.
By: By:
Title: Vishal Gulati-CFO Title: Vishal Gulati-CFO
GE Capital
BILL of SALE
PRA Fresh—April 2012
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 201h day of December, 2011 by and between General Electric Capital
Corporation, GE Money 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 1.9, 2012, and
as further described in the Agreement.
General Electric Capital Corporation GEMB Lending, Inc.
By: By:
Title: Glenn Marino-Vice President Title: Stephen Motta-Director
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By:
Title: Glenn Marino-EVP Title: Glenn Marino-President
RFS Holding,L.L.C. GEM Holding,L.L.C.
By: �G By:
Title: t �'""^'"" 1x-C v P Title: ���h Lee �/
„cs+�e�ae zli epana.,�
r102 reh
91 ol
f�
14 ?�! & F � ,0LYNN SCOTT
tr° '�'�°'k■x it Account Number Visit us at eservice.oldnavy.com
vv aw 2474 Customer Service:/-888-248-3182
Summary of Account Activity
Payment Information
Previous Balance $883.90
-Other Credits New Balance $0.00
+Fees Charged $918'90 Amount Past Due
$35.00 $0.00
New Balance Total Minimum Payment Due $290.00
$0.00 Payment Due Date
03/25/2012
Credit Limit $420.00 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
Statement Closing Date fee up to$35.00.
03/23/2012
Days in Billing Cycle 30
Your Rewards Summary
Beginning Points Balance Your Account News
Points Earned in Our Stores' 0 You're only 500 points away from earning a$5 Reward
Total Points 0 Card.Earn 5 points for every dollar spent at Gap,
POINTS TO NEXT REWARD 0 Banana Republic,Old Navy.Piperlime and Athleta.
500
Transaction Summary
Tran Date Post Date Reference Number
Description of Transaction or Credit
"'Purchases in Our Stores(Gap,Old Navy,Banana Republic,Piperlime and Athlete) Amount
03/23 03/23 F914300F300999990 CHARGE OFF ACCOUNT-PRINCIPALS
03/23 03/23 F914300F300999990CHARGE OFF ACCOUNT"FINANCE CHARGES* ($391.11)
($527.79)
03/17FEES
03/17 LATE FEE
TOTAL FEES FOR THIS PERIOD $35.00
$35.00
INTEREST CHARGED
03/23 03/23
INTEREST CHARGE ON PURCHASES
TOTAL INTEREST FOR THIS PERIOD $0.00
2012 Totals Year-To-Date $0.00
EFeesn 20125105.00
d in 2012 $35.45
2012
$0.00
[YPe
est Charge Calculation
Annual Percentage Rate(APR)is the annual interest rate on your account.
Annual Balance
f Balance Expiration Percentage Subject To interestDate Rate Balance
ases WA c Interest Rate Charge Method
ariable rate 26.24/o(v) $0.00 $0.00 2D
Cardholder News and 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.
PAYMENT DUE By 5 o M (ETA ON THE DLLE DATE
NOTICE:We may convert your payment into an electronic debit.See reverse for details,Billing Rights and other important
information.
6544 BTH 1 522 120323
I ZX PAGE 1 of 1 9143 1479 ND10 O1 F106599
Detach and mail this portion with your check.Do not include any correspondence with your check. —�
Account Number 2474
Minimum Past Due Payment Due Overlimit New Balin
�� V ce
* a- x.
6*#� � Payment Due Amount Date Amount
$290.00 $0.00 03/25/2012 $0.00
$0.00
Payment Enclosed: ❑ ❑ ❑ ❑❑
Please use blue or black ink.
OR pay on-line at ■
We currently do not accept eservice.oldnavy.com New address or email?Print changes on back.
payments in our stores.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 170154309 Make Payment To:OLD NAW/GECRB
PO BOX 530942
ATLANTA,GA 30353-0942
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff U THE TAFY
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
CIrmt,"
OFFICE OF "ME SH,ERIFF
?Oh NOV 17 PH
CUMBERLAND COUNTY
PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs.
Lynn Scott
Case Number
2014-6320
SHERIFF'S RETURN OF SERVICE
10/31/2014 08:40 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested
Complaint & Notice by handing a true copy to a person representing themselves to be Kathleen Marmo,
Mother, who accepted as "Adult Person in Charge" for Lynn Scott at 10 Cardinal Drive, South Middleton
Township, Carlisle, PA 17015.
CHRIST -HER ARPE, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
November 05, 2014 RONINN' R ANDERSON, SHERIFF
(c) countySuito sheriff, Teleosoft, c.
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.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
Date:
17-06613
g/6'
No. 2014-6320
PRAECIPE FOR DEFAULT
Defendant JUDGMENT
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
ado itp.pci
IL* Lo7vqY
iek sfs(pD1
This communication is from a debt collector is an. attempt to collect a debt. .
Any information obtained will be used for that purpose. 11/0'
r
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.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
Defendant
: No. 2014-6320
PRAECIPE FOR DEFAULT JUDGMENT
Please enter Judgment in Favor of Plaintiff and against Defendant, LYNN SCOTT, for failure to
answer the Complaint.
(X) Amount Due $918.90
Less Credits $.00
TOTAL $918.90
(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)
17-06613
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, a the default occurreeast ten days
prior to the date of the filing of this pr.: i . and a cop o _ t i r s is attached.
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
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.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
Plaintiff No. 2014-6320
Defendant
NOTICE OF JUDGMFNT
(X) Notice is hereby given that a judgment in the above -captioned matter has been entered
against you in the amount of $918.90.
(X) A copy of all documents filed with the Prothonotary in support of the(&ithinj dgment is/
attached. F ) f
BY:
If you have any questions regarding this Notice "/ e contact the f
17-06613
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
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
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
RE: PORTFOLIO RECOVERY ASSOCIATES, LLC
VS. LYNN SCOTT
2014-6320
Dear LYNN SCOTT:
Enclosed herein please fmd a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of
Civil Procedure.
17-06613
Sincere
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
v.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
Plaintiff No. 2014-6320
Defendant
TO: LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
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.
17-06613
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.
LYNN SCOTT
10 CARDINAL DR
CARLISLE PA 17015
Defendant
No. 2014-6320
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
10 CARDINAL DR
CARLISLE PA 17015
and is not in the military service of the United States or its Allies, o therwise within the . o isions of
the Service Members Civil Relief Act and its Amendments.
17-06613
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 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
Stats Report
Pursuant to Servicemembers Civil Relief Act
Last Name: SCOTT
First Name: LYNN
Middle Name:
Active Duty Status As Of: Dec -15-2014
Results as of : Dec -15-2014 02:37:30 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 .. ..
.. 'fNo..
NA
This response reflects theindividuals' active duty status based on ttie'Actrve Duty Status Date
1. Left Active Duty Within 387 Days of Active Duty Status Dam
Active Duty Start Date
Active Duty End Date I Status
Service Component
NA
. .•' NA No
NA
This response reflects .where the individual left active duty status within 387 days preceding the Active'Duty Status Date
The Member or HisMer Unit Was Notified of a Futu e Can -Up to Active Duty on Active Duty Status Date
Order Notificatien Start Date
Order Notification End Date . .
_ Status
Service Component
NA
`.NA'::
No ..: .:
NA
This response reflects whetherthe individual or his/her unit has received early notittcation'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 Uniforriied 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