The URL can be used to link to this page

Home My WebLink About10-5494 Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 F _ Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502' AM': 2q TELE: 1-866428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 No. ?y?f C1?- Plaintiff v. SHIRLEY M SUNKEL 21 FARM HOUSE IN 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 within 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 NO 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 Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (800) 692-7375 gQJ-,00/ d-?W/ & At" 3?6 a 7HT 'I his communication i from a debt collector is an attempt to collect a d +t. ,any information obtained will be used for that purpose. Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 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 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No V. SHIRLEY M SUNKEL 21 FARM HOUSE LN CAMP HILL PA 17011 Defendant 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 elate 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 Demands 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 AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Pennsylvania Lawyer Referral Service (800) 692-7375 I'his communication is front a debt collector is an attempt to collect a debt. An1v infonnation obtained will be used km- that purpose. Carrie Brown, Esquire PA Bar # 94055 Robert N. Polas, Jr., Esquire PA Bar # 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866428-8102 FAX: 757-519-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. SHIRLEY M SUNKEL 21 FARM HOUSE LN CAMP HILL PA 17011 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant SHIRLEY M SUNKEL, is adult individual with last known address of 21 FARM HOUSE LN, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to FIA Card Services/Bank of America/MBNA ************7262 on with account number ************2484 (hereafter referred to as "Account"). A copy of the account history is attached here to and marked as Exhibit "A." 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 in_fbmiation 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. 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 22, 2007. 8. Plaintiff is the purchaser, assignee and/or successor in interest to FIA Card Services/Bank of America/MBNA ************7262and Plaintiff is nwthe holder of the Account. A true and correct copy of the affidavit is attached hereto as Exhibit "B." 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 $11,679.05. 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. 12. The terms and conditions governing the underlying claim(s) contains a mandatory arbitration clause that requires the parties to conduct arbitration through the National Arbitration Forum (NAF). As of the date of this complaint, the NAF and other nationally recognized arbitration organizations with similar procedures are unwilling to act as arbitrator; thus this claim is being filed in the above-captioned court. Plaintiff will, upon the request of the Defendant or direction from the Court, proceed to an alternative dispute resolution program. See Exhibit "C." WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, SHIRLEY M SUNKEL, in the amount of $11,679.05, plus costs of this action and any other relief as the Court deems just and reasonable. 09-16549 Carrie A. Brown, Esquire # 94055 Robert N. Polas Jr., Esquire # 201259 This corm inication is from a debt collector is an attempt to collect a debt. Any in 6mnation obtained will be used for that purpose. National Arbitration Forum to Cease Administering All Consumer Arbitrations in Response to Mounting Legal and Legislative Challenges MINNEAPOLIS, July 19, 2009 American Consumers to Lose Affordable Access to justice through Nation's Largest Administrator of Consumer Arbitration Disputes BusinessWire -- The National Arbitration Forum (FORUM), the largest U.S. administrator of consumer arbitrations, today announced that it will voluntarily cease to administer consumer arbitration disputes as of Friday, July 24, 2009, as part of a settlement agreement with the Minnesota Attorney General. "The National Arbitration Forum remains committed to consumer arbitration as the best and most affordable option for consumers to resolve disputes quickly and efficiently. However, the FORUM lacks the necessary resources to defend against increasing challenges to arbitration on all fronts, including from state Attorneys General and the class action trial bar," said Forthright CEO Mike Kelly. "Mounting legal costs, a challenging economic climate, and Increased legislative uncertainty surrounding the future of arbitration have prompted the FORUM to exit the consumer arbitration arena. At this time, the costs of providing consumer arbitration services far exceed the revenue generated. Until Congress resolves the legal and legislative uncertainty the cost is simply too high for users and providers of consumer arbitration." Legislative proposals pending in both houses of Congress threaten to eliminate pre-dispute arbitration as an effective means of alternative dispute resolution. The Arbitration Fairness Act of 2009 (S. 931 /H.R. 1020) would invalidate every pre-dispute contractual arbitration agreement that is part of a consumer, financial or franchise dispute - in effect, every contract. The Fairness in Nursing Home Arbitration Act (S. 512/H.R. 1237) would eliminate pre-dispute mandatory arbitration In all nursing home contracts. Legislation before the House to create a new Consumer Financial Protection Agency (H.R. 3126) addresses arbitration and would give broad regulatory authority to restrict or eliminate all consumer arbitrations. "The National Arbitration Forum provides fair and affordable access to justice to American consumers regardless of size of their claims. Without access to arbitration, consumer disputes will now be forced into an overcrowded and underfunded legal system, where many consumers who cannot afford attorneys will have to navigate complex court procedures," continued Kelly. "The consequence to American consumers is that there will be no meaningful alternative to costly and unpredictable litigation." Notably, nothing in the Minnesota Attorney General's complaint alleges that arbitration proceedings administered by the FORUM are unfair; the fairness of arbitration is ensured by the independence of the neutral arbitrators. National Arbitration Forum consumer arbitration claims are decided by an independent panel of more than 1,600 highly experienced and impartial legal professionals, including former judges and experienced attorneys. FORUM neutrals are bound to a code of professional ethics, and decide cases outside of any influence from the FORUM or the other parties. About the National Arbitration Forum (FORUM) Founded in 1986, the National Arbitration Forum (FORUM) is a world leader in arbitration and mediation services. The FORUM provides accessible civil justice through the recruitment, selection, and management of a highly experienced and distinguished panel of over 1,600 former judges and seasoned lawyers. Now This communication Is from a debt collector an is an attempt to collect a debt. Any informet' obtained will be used for that purpose optimized by Forthright, the FORUM is the faster, lower cost, and superior alternative to litigation, that ensures parties receive the same outcomes they would in court. www.adrforum.com Media Contact Brian Kaminski 202-429-4942 briankamins ki®rational360.com This communloatlon ig from a debt collector ar. is an attempt to coiled a debt. Any information obtained will be used for that purposo National Arbitration Forum Barred From Credit Card And Consumer Arbitrations Under Agreement With Attorney General Swanson Swanson Also Wants Congress to Ban "Fine Print" Forced Arbitration Clauses Minnesota Attorney General Lori Swanson and the National Arbitration Forum-the country's largest administrator of credit card and consumer collections arbitrations-have reached an agreement that the company would get out of the business of arbitrating credit card and other consumer collection disputes. "I am very pleased with the settlement. To consumers, the company said it was impartial, but behind the scenes, it worked alongside credit card companies to get them to put unfair arbitration clauses in the fine print of their contracts and to appoint the Forum as the arbitrator. Now the company is out of this business," said Swanson. Swanson sued the National Arbitration Forum on Tuesday, alleging that the company-- which is named as the arbitrator of consumer disputes in tens of millions of credit card agreements-hid from the public its extensive ties to the collection industry. The lawsuit alleged that the Forum told consumers and the public that it is independent and neutral, operates like an impartial court system, and is not affiliated with and does not take sides between the parties. The lawsuit alleged that the Forum worked behind the scenes, however, to convince credit card companies and other creditors to insert arbitration provisions in their customer agreements and then appoint the Forum to decide the disputes. The suit also alleged that the Forum has financial ties to the collection industry. The suit alleged that the company arbitrated 214,000 consumer arbitration claims in 2006, nearly 60 percent of which were filed by laws firms with which the Forum is linked through ties to a New York hedge fund. Under the settlement, the National Arbitration Forum will, by the end of the week, stop accepting any new consumer arbitrations or in any manner participate in the processing or administering of new consumer arbitrations. The company will permanently stop administering arbitrations involving consumer debt, including credit cards, consumer loans, telecommunications, utilities, health care, and consumer leases. Credit card companies, banks, retail lenders, and cell phone companies increasingly place-in the fine print of their consumer agreements-what are known as "mandatory predispute arbitration clauses." Through these clauses, the consumers waive, in advance, their right to have their day in court if a dispute arises. Instead, the consumer agrees-usually without knowing it-that any dispute will be resolved by an arbitrator selected by the credit card company or other creditor. Credit card companies are among the most prolific users of mandatory arbitration clauses. Just by keeping a credit card, the consumer agrees to the terms and conditions of the card, even if the arbitration provision was sent to the consumer after the card was issued. As a result of mandatory arbitration clauses, which appear in tens of millions of consumer agreements, hundreds of thousands of consumer disputes are resolved each year not by a judge or jury, but by a private arbitration system. Swanson said that late this week she accepted an invitation from Congressman Dennis Kucinich, Chairman of the Congressional Committee on Oversight and Government Reform, to testify before the Committee this coming Wednesday in Washington, D.C. She said she will ask Congress to prohibit the use of mandatory pre-dispute arbitration clauses in consumer contracts. This I@Mfl Vfi1C * I# hpm a debt collector and I lHoa t@ good a VA Ned for ?" rmstion "The playing field is tilted against the ordinary consumer when credit card companies bury unfair terms like forced arbitration clauses in fine print contacts. Congress should change that,* said Swanson"" Swanson also announced that she sent a letter to the American Arbitration Association asking it to play a leadership role by ceasing to accept arbitration filings on consumer credit and collection matters arising out of mandatory pre-dispute arbitration clauses. Swanson noted that the City of San Francisco is in litigation with the Forum and that other state Attorneys General have contacted her about these issues since the announcement of the lawsuit. °I am very pleased with the results of our lawsuit. It is good for consumers that this company will no longer be able to administer credit card and consumer debt collection arbitrations. I hope other jurisdictions will use whatever authority they have to look at other possible remedial relief in this area," said Swanson. The settlement allows the Company to continue to arbitrate internet domain name disputes (which the company handles under an appointment from the Internet Corporation for Assigned Names and Numbers (ICANN)), personal injury protection claims (which the company performs under appointment and supervision under the New Jersey state government), and cargo disputes (which the company performs under rules established by the U.S. Department of Transportation). These areas were not part of the lawsuit, and the company performs the work under the supervision of government or non-government organizations (NGOs). Accordingly, the settlement does not affect this very limited activity. This communication Is from a debt colle,,tor.qr is an attempt to collect a debt. Any in obtained will be used for that purRr?f VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Kelly M. Roberts hereby states that she/he 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: Ulk {? By: PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************2484 SHIRLEY M SUNKEL Account Holder: SHIRLEY M SUNKEL 21 FARM HOUSE LN CAMP HILL PA 17011 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase: Purchase Date: Claim Amount: Less Payments: Balance Due: Product Code: MC FIA Card Services/Bank of America/MBNA ************7262 Portfolio Recovery Associates, LLC ************2484 April 1, 1972 October 22, 2007 May 30, 2007 $11,679.05 December 29, 2008 $11,679.05 $.00 $11,679.05 This communication is teom a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Kelly M. Roberts, Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing business at Riverside Commerce Center, 120 Corporate Boulevard, Norfolk, Virginia, and I am authorized to make the statements, representations and averments herein, and do so based upon personal knowledge and a review of the business records of the Account Assignee and those account records transferred to Account Assignee from FIA Card Services/Bank of America/MBNA ************7262("Account Seller"), which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on December 29, 2008. Further a review of the records reveals that the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the account records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from SHIRLEY M SUNKEL ("Debtor ") to the Account Seller the sum of $11,679.05 with the respect of account number 29, 2008 with there being no known un-credited payments, (************2484), counterclaims or offsets against the said debt as of the date of the sale. 5. According to the account records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, there is currently due and owing the sum of $11,679.05 . Portfolio Recovery Associates, LLC Kell . Roberts, Custodian of Records Subscribed and sworn to before me on o? f , 2010 Katherine Yolanda Muhammad otary Public Commonwealth of Virginia Notary Public Commission No. 272639 09-16549 My cammieslon Expires 09/30/2012 This communication is tirom a--K,5 collector and is an attempt to collect a debt. An1v inibrmation obtained will be rised for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC --..._ - -.....+.... .. • ... .." vn..N..WWW to % '-:11.. r • i f . f G~W In tf* Craft Geet ?+rNner>?, tht "and Your' refer to end and all of thO MOON er an ccq as who we hec Mt: 01ft COW I%$ CMft Issued by u; ? und oithie nent? 1410 A'l cota?eitr mow ttiM11dow set kart In the Regulmd ?Aicard a ? ?ctbe of the pen hgMW. The wag* O °WW herdr 'MWA ftW*e. 01W "we: *us.* "our` sib When rM scoRt or sae ** "elm.K ? N.A. t to, WOM ?. you uM It. you eh" eta YMN cold ="* to ad "WhO ?M%ANx*g MFWWC? to r ld ?! QiO arlt tt7r the oaf ?rq?oEthoecoam insul in R"UMW 1W'tM AM hsMe the ?_Yr fend on* mat Dleclaeurrs Ti omeefou Uari+h 7n 7nn7 tim ebm IN lhcl -?..... uP*id ttttorpte- . hr tA?eto?t ir. you Spud" &Nf with aiidit .l"e Alnd ttae iaiormIttlon Am t? 1rloE be *MAC MOW aka. ether ttan Eton PWW1Ur4 eoWy or Amerki Mwimm betty Yov end w loran MONA Inkrmatl pQ ? ft us at Mme, Jil?It?r jj%WN htclude yqw Wll?t)t on, De pJlM nUVOW end 41 '+ address. bone nooovnt numbKS. aY" t* kwounts or O'WW8MM1WbWdWWbyvswMN 1170 ab A044 amok "W Plat rromb4Keretec ,, Iftu m WM EfS16rr. i. r------ _ 81001 «h, This communication is from a debt collector a- is an attempt to collect a debt. Any inform,,` obtained will be used for that purpose. .F 03 }t HOW 7b US9 YOW Most You '' Use y" ft*W km ?t.crtrd to MrNW or tae or P"MM UM MW s6tn aea your card ho?a the crud: Y use $?A"KW .YOu Akm tn>dw s any otlfer Cant a= ?j you ? "M UM YOUt eOMW hr In MapoW C?tMa anae YOUt Pe>MW stied i upon of yout'plyd; In on event we atr rOWAvd. to pey isle of 4 dmdc cad,d M 04 we Waeaee da deck !e not pA*hw Oq Mv#W. WG w1U yoert aCCM* An M CAMW6 iM C11lt ifrlWi(? e ???tchge?as? 01'JtaGt?lOUttt twmb"Y Wftm W 10" 0=00 tO YOW cxttd dWM , M YOU My be Wft for &g dWfM merle l??I y OW Pdd M be 11 p1D?' !? nat hs,?e inconde The ft'seco" WhM ?*W= ???'? A>oh?enost and the dit 1s merle pry ? Or the WhM e s pg"1 s to hp +n dra a? ?? ? OAdv" Bank Pint Pa" to YO W ebe con+eei,v?rdI oua" Mpile a Stapp t art t hKi cam s? pnwftq ur with the rhedc nutnpec, doUu OW " am WkW for six Moat from the dirt' Pheda"PNYMG tton YOW etooeatt. YOU nW= Obtahl d+ee?R uarr a PWdmbd Chaff Geh 'M to y*WvWOUnt, !f Jru *Poetds(e a Ch" C" A*sm*6 We my want a 1r dw ?mot it Rpm Ar!'- it to us for peymeet, vjdjM In dtb CM Pnwnted (W# d nt an the OW6 CM6 A*4rjM ~kq dw t* we we root Rabic ? fm NY lgts arm IA?1aTiael ? ??NIf1? Otlt Of the afea ue elect to t Reptant fou Cbtiblj ra Includes us dw WWJM of hill a e&t you Pews. cash W"nM' ft" yY 2 This communication is from a debt collector is an attempt to collect a debt ? nv inform obtained will be used for tha c,L rr .- Ti ioariw U ar.+h )n ')nn-7 Nl,.. •ar•.•• ..•w .nr,rr "W I ms INh dYr ,L?'Kp U your sQ mat fend RnmChww ' You Mw Pay the *nth* mount tpaYmatt Am epn 6" I ;tta lydt>tAt?? A+aYor Mo crodlt VOW axmft Oft INK. it MOW fn w Ow. ywir : # WO WA not pay Pali" wilt be a e ttxgnal on such rutonttts. You r itoc?omd In a rnotlm wk datennfnt >n Mon k*xm we va wbofm ym I nts to Ii:ndtdny new tmmmdjam) wo ;OW App bwwa J bobtrs bafanais wait hfghar NHS, TWI will exult in now bol• anaas with a knrett teals off ltl tw= ' bft fmld befbne ate; YOUFS loount Foy the bUng qtb In *Wh t Is W *44 ham. VOW M98ble ave ntaY not be In, I NI by the am o t of the pqm" 40 ywr funds: bM dwwd• mb*M= 4WM* ? Co1i- j no b4bW t be strode In WMMI WW PW4116 node in mW nt ? *k#1 an gmaW &,ort da tttWqum p?qr- COW adahm m to rnsirs sub?e- PelMd Oadt tttotrtlt• Wh can low Pay"O 10 on d? N U.& doh or not dmn i an a i All personae wfia Mlge?ror sum 1 acmp or we the acc°wit an ita„h1uw4 a faRu"t er PUMM We any " b amp at ltl0f+e 1 MOM t ? ?fthe to tidwue any of tfw ft m !? u nu, sit tt uhf a any uncw the aaoow,t be" beat, Marred to w 814 the fmNnee i# pjld In Illll. R'' for RaWrWV 7 You wm be in dnftiolt and wr c?rut - Pgmm* of afl acnovnta ?iaint set d U" Us ! 1) YOu all to mdw Mnm* by tM t due Dft 111• YoUt Nenv Ybttd 40086 Y,m Cm* Wit or it we have etxabl a SMWM CMA Admnm aW t limit t for Cdr Yaw gyred t beknc+e soared, YOU, C Aflla. or (3) You toil to abidh by &?otha teeema Of ft eft ! If You dpruk unkm pojlbIwd by appk t csbfe law., we 3 This commi inf-fine s frnm a debt collector is ar obta.. Ti ioeris.r Uorr•k In 7nn*7 ? ?4g P. C MOO Ikur n ire M"I [nom to pay the aal aw Murt ?... ?? attar acllectlon pn04want and a rea. ? hee ff ? nab y,mr a?tatt lion aatte 0" to an attorney who is not uur 0'r hbre to Est any of our defauh door not moan tit we ? t WW& L hen you those flea upon ? de&Wt. ter' loot Ps we mew allow. YOU. f„,ntw r1 t'bne to i GM* ant;, we Wto Ohm to amIt • is naileWe, IrYWOM? YM Who this qM00 awaftkom"n your Nhow in #'?, if anyt ardi soma on WWWOM Y&J . ??? Mont, h'+! >?+Ar ptgrn?t ??lr you MW a *** In him the dwo 7411 be > dm UMERns"mcmdon Cd r in ap jh-e ea at +• .nci PIC"" & cum(*. those tan teas to 'tlmt tho lintel late or (2) ad M Wthur (t)' erlioiUrle ' one day.pft? tot me In elfga POcsnt in eadt c ,s ng date, tncemd by oft one P"*nt ar comma this Cnt?l0e1 The ?'?Ititi? the dtFllnOuftnq • eft on the pre w. eO n MG in tO"Iract[oo date of tile the we to !!?Mr t?aounj watt. so tb a ?Ov on OW d?.. t gr the cloet and +sndr on the M ? uwnd?ly? else ?? aaovunt'e for the sent ,(in Your a* NW 4W on so ft*k oft ace set fft billing qt4 In eieh gv& a yturhasai in the F": (2) Ifyouracrnunj h scc^+a' ovltfiit [ (a) a L+ka Cvu it tcse Or This communication is from a debt collector anc is an attempt to collect a debt. obtained will be used for that Any informatior Purpose. Ti ware., AA-%,m,,)n -)nn-7 ?. .. .. .•.. .v.w? •w.. vn...a. NY rM fem. axqlifp{?Q y(/ .••r r. ` Finance C1Mq p Tow d ?.? to MQW Potty kWO On tM YM maw test day of ae? i nne qde an Ore ND* Fee M as of do day in the billing ? ? g ? over I* credit limb; il) PNy am if pt ' melt on brow aaoouitt Is MtwAd • P 4" Oft reamt am It It 10 Pow ??c cba& am* 141 a Syrred Check Rte it we MW t check CM& Advance paid upon trotIP ern if th . meet: 0, "Ip1o'aaoo?mt.ls ? or if ? f?l?lnt aomunt belanpt, rhatJ,ar Y'? nMitrtaitt ?n Clang RM pt'JYi: 19W Or not. M AHMW tm has w ' aAgliahww?i. UrJM by et i PwrbaN, b1r anir tveq ! . as coil p?le? s etnoe e d rrk?t AddnewW DtbAe bye. theeR redeem! PJMQ review for O"U" roe Sw Of PM your tt ? pid . " at? to fetdz You tiriA be crud min banes whkh wiR bo sub;' sect m ft outiinod In die banefib btoehum PoWed tip you btr iIYlli m. Amart0. Mt31YA AMWI resetv?ea tla d* to Est, NW, cr cf kjw services at ant? wahotime d w NMI $ grid rejuM R r Yom Cam r or a e an! nit UsWe for am ? ny CM* AdrMCe 0r fur veil ? ?Or by us, any WW bank, of qM Your aprd IOR Of Yoar card or inner or laasor of Mods wl w@ my Depend of tai Your ryON to abwn out u t IY t for any topaA. Your obli"dons abtafn c * hu bam (M." ev" alter Yaw Nyht to Mult mtvM all vent Cift to w on equ"groett: You JlrrtepiM? ?auest, We MWamend th.. A s This communication is from a debt collector is an 7ttempt to collect a deb " ;nt r,-1, obtained will be used for that purpr T.......1.... \I.....4. 7A nf%A7 '-'no VMN M"4016 N Y t i i t i f t t i tY i ri'lA MWA 4W114I G M P. IT ddeft app aur deqW. Ana Jn o? the e.W Othmire Nan °p'W ? U* die"ow v you 'se, to MierdamG. WMhWft m YOt+r et• to 'A* tforl, m d ad k 4vk" os WW M' as OMWWW a0t?NOW ?( Inda" any Now ?ta the One gut Wk*4 aa kneg 64-6 a0kaied Wilk bit W41hw c4d am your ?aqr tlme. at ? on*, utd notlo! to Yft. ac W ? Ordwoil VW aM°Wa Or WS Amt a y Pwa vrsllMy Tb y tarml or en" to trli?oea ? " PoAOn or t dog be QQUI%d to a!) ,?, Of **hI NW Poch s11? Md& ? 1* Wit' to t! f t ° Nrlafone Cn*IA*4 Wally 4 M& Crodlt fJ? orp ?._,? Yoy'sifi w1 do. fta to %% arMv ,,aa yftr u 1Wt be Qf Mt Otidty we dcr a han IIW)pIff 0.0 Wt 11 a MI" "Mod Chita Caa ?+ICV balms ?y Jf over Your U N16 c„e4ft s i 11t ? "Uld MR* in 4OW YW t your C.A Aditnw t0[i#t tioru not M PaM Md ba'Wft Or tb ttdlsii? a ! your cyes it or yo yowuraO "'d' bet MM O*n one }fllBiltf, frvrit+ ' r44 ? ?„' ,' ? Or not so* t6 bsitf. i }r}' MpWjvv WWfthM rry the 1>R MOW Yft haunt whkh 1, 12J how i and but the a 'WO t t bn YM tradit Iffna 6 This communication Is from a debt collector an is an auernpt to collect a,,jdbj. nnj n obtained will be used for that purposo Ti.wndn•• IkA--b. 'fn 7nA7 as Immediately **. or l3l MAW by hQIM • the We may adv* the person who mad* the rcqucs his ban ^oqulrt chat Advano reused. if we ni"e to honor v Ch" cash tt?e " p tt Check May (109U by advistn _ 0*" ? Cash ?klvenpz or MV i?Ftleleat hrndssr tom ? ?'refttstad, A. the pay thQ ChMA Cnh 8SIM" Tonsk or in easy othet manner. Ad 4 A0"°a if re hs* pMVftWY Reif ' Y? cr%R Ifmlt, it dyes not ??w ?t ov'r r tttrther o'li!(iiamtt r'ne'an that MrQ will ia>oAa " . N wie dodde to hor?or arodh. rogmt, we n" a"eat an OvIturuit IP1tit as pt+cwided li . thb /laeernecst. Mr GIM . nn.udtotist.d"?waa ytitd1e ? ?, ur paw ?? l-eoa7eq?7ot, ?? Law . by ? h" CV the Aqwnwt h M86 in Ddewan, It Is the of 004"n. without rqMW ii o its Coilfitct of IM Principles, and by any eppllCSMe federal laws:. the It an port of this art Is bund to b¢ 1MVIlld. ranains etftc ft our fanfare or dviay in OW cisfns any of ovr 4" u this A dove riot mean that we are unat* to ararc3se then r%ht: lee", T kbKfition proyislp? ?io?y a*& to Yorr tinlaw Y ' Rh?ts the ?DPoKunity to tee the Atb""on Drovl?anas and Mi did so refect them; In wh" vary. Ydt? V" ftt any tit eedon bluv& by ym 901W us " bmught mini do aa?unt or tks Agmftent snail be m' C°'s't boated In the Stain of De iwar s. "b Any clelm or dtspute (• IVim-) by either YOU Omplow us aNlna L?nt olhatr or aealnst trio a"ni9 or rtssisris of the other, arising from or relatlno in any"to this prior t or Airveeaent or any rnvt? ? , Your eccou"t (Mrttrtire7 under a t?ngkmt, Or Oftflitft and klai doclsmto +uh?thu Ibr relief). inducing Cla)ma regetdlrtg the sp e of rhix arbitrot3on piluMbilIty ltty of 96c"on of the validity. of 0* endre This communication is from a debt collector an is an attempt to collect a debt. Any informati, obtained will be used for that purpos, Ti meei-mu RA? i% 7n gnn-7 AspearasK SW be sevokv AL- be 1eswv+! UN 1400" AOAkftm w :?belA& M? t orK 040400 we A illN?/IR ??Msl?? ewwlMirlr+„?, ar rt?ton. 71111 ? ? !'?M!?1?11M????MR?? ? ? ararrt bo dto hrary?*66WAM !• bm mullo !n a SW~ l16 Arv ?, ` t? ilerde?i ?* ' . , ilrt? ?+at ?. at d*V tb *An is ><kanMWItaa?1 It a 11110111311P in, WWWWWWOW ale. v t+ilh,C. !- , upon 01 Ww"MM a U' 1mIIli In a1a a rt tanla? , The -MM Qy** ?tYllvte t?ttt;tl?! ?E `UII??iAi . ?e of ?#?ll?i herwr ?t i ?ai? or ? ?? ? Nair r'? the ?t sb? +ne tlar?i??.?rwMld. No Clkn A*&Jftd to siitiftsow it load by a jury i arW no C am bo b mu* an a char swop or «a i W'iwMe ?iDr?eaM'- lbu ?D poh i?e?R, ? ?t d d rids mopm to fty CWm. TW AbIlto SoMp +M aU C!elllrae nc?w its. cx arwe ? cbefia?l. 7* AdW aWn &ftw abaci awn Ow tai 1 Of YM aoo AWt -"M vie of WA as WW PW r mw* of vW dek in hdi by vou. a* bodopq 1W This Communication is from a debt collector an is an attempt to collect a deht. Arnv inform.,,;- obtaineu will be used for that purpose i 0 BaekelAmodea? EXHIBIT C BILL OF SALE AND ASSIGNMENT OF LOANS The undersigned Assignor ("!fit") on and as of the dale hereof ereby absolutely sells, transfers, assigns, acts-over, quitclaims and am M to Portfolio Recovery AssocistM LLC., a limited liability c o mpamy arced order the laws of Delaware (" ") without recourse and withtm apr-m- Md. or warranties of my type, kind, c horedw or natm e, exlx?eas or implied, subject to Bayer's repurchase rights as set forth in Secdow S. I and 82, all of AssispWs right, tide and iztt- p a t in and to each of the loans identified in the loin sebakle ("j, ") attached hereto (the "jMM'), together with the right to all principal, interest or other proceeds of my land with respect to the Loans remaining due and oaring as of the Cut-Off Date applicable to such Loam as set forth in the Loan Sale Agreement puramm to which The Loans are being sold (including but not limited to proceeds derived from the conversion, voluntary or invohmtary, of any of the Loam into cash or other liquidated property). DATED: December 29, 2008. ASSIGNOR: FIA CARD SERVICES, N.A. A41 k*4 *. e" Name: Debra L. Pellieciaro Title: Assistant Vice'President P is sa 408.0ue 8" §(AMw& ,, AMA dr Daw" M, ON Pow ME RwA xe*nf. M MM ".'Pw M8K.ILF7 Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx:717.240.6397 Plaintiff/s: Court Number: PORTFOLIO RECOVERY Expiration Date: ASSOCIATES, LLC Type of Action: CIVIL Defendants: SHIRLEY M SUNKEL Serve Upon: SHIRLEY M SUNKEL Address for Service: 21 FARM HOUSE LN CAMP HILL PA 17011 Alternate Address for for Service: Type of Service: ? Adult in Charge ? Personal ? Deputize ? Certified Mail ? Posting **CWy of Court Ordc Required with Posting** Special Service Instructions: *If service is to be made by deputized service to another county please specify which county's Filing Attorney: Name: Robert N. Polas, Jr. Address: 140 Corporate Blvd. Norfolk, VA 23502 Phone Number: 1-866-428-8102 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F1~~"~-ri~'F a ~' ~ ~ ~, «r, ~ ,t, i ..~ ' '~v ! 0 SAP I.~ ~~:. ti ~~ :~ ~ aaF~ - ~ - 1.rVlr`~ '' ~~IVI f Portfolio Recovery Associates, LLC vs. Case Number Shirley M. Sunkel 2010-5494 SHERIFF'S RETURN OF SERVICE 09/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Shirley M. Sunkel, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Shirley M. Sunkel. Request for service at 21 Farmhouse Lane, Camp Hill, PA 17011 is located in York County. SHERIFF COST: $46.50 SO ANSWERS, September 10, 2010 RON , R ANDERSON, SHERIFF David -D. Bug - Prothonotary Office of the Prothonotary Cum 6erfancf County, Pennsylvania 7ir&S. Sohonage, ESQ, Solicitor lb -sy9y CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® Car[rsCe, PA 0 (Phone 717 240-6195 0 Far 717 240-6573