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Home My WebLink About11-7153Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff j- E P OTIHONOTAR'i IN I I S E 0 15 Ilei I I. 10 PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. JACK WRIGHT 839 PENNSYLVANIA AVE LEMOYNE PA 17043 Defendant NOTICE No. `I- l 1 s S OVI, 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, an 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 Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 aM?- ?ga.cbpd aN? 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 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. JACK WRIGHT 839 PENNSYLVANIA AVE LEMOYNE PA 17043 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 esate 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 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 I his c ontintinication is f'vnxi a debt collec°tot, and is all allempt tc3 collec! a zic:bt. nv intbrnzation obtained will be w-ed 100- dint purpose, Robert N. Polas, Jr., Esquire PA Bar # 201259 Came Brown, Esquire PA Bar # 94055 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. JACK WRIGHT 839 PENNSYLVANIA AVE LEMOYNE PA 17043 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. Defendant JACK WRIGHT, is an adult individual with last known address of 839 PENNSYLVANIA AVE, LEMOYNE PA 17043. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / CARE CREDIT on January 22, 2008 with account number ************2040 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively 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. I his c°onaminicatioxt is fz°om a dobt collector waci is an atttempi to collect a &N, Am,, infortnacioci obtained will be Li,,e(i 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 March 5, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK, F.S.B. / CARE CREDIT and Plaintiff is now the holder of the Account. A true and correct copy of the affidavit 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 $2,940.81. 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, JACK WRIGHT, in the amount of $2,940.81, plus costs of this action and any other relief as the Court deems just and Robdrt N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 10-89720 "[ his communication is 1-rocn 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, Chela Wise 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 : 2 20 By: -C- Custodian of Records 10-89720 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT A PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************2040 JACK WRIGHT Account Holder: JACK WRIGHT 839 PENNSYLVANIA AVE LEMOYNE PA 17043 Consumer Account Product Code: PVT Issuer: GE MONEY BANK, F.S.B. / CARE CREDIT Assignee: Portfolio Recovery Associates, LLC Account Number: ************2040 Date Account Opened: January 22, 2008 Date of Last Payment: March 5, 2010 Date of Charge Off: October 13, 2010 Balance at Purchase: $2,940.81 Purchase Date: October 26, 2010 Balance at Charge-Off: $2,940.81 Less Payments: $.00 Balance Due: $2,940.81 10-89720 GESJ44 THIS COMMUNICATION IS FROM 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, Chela Wise , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 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, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from GE MONEY BANK, F.S.B. / CARE CREDIT ("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 October 26, 2010. Further, 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 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 JACK WRIGHT ("Debtor") to the Account Seller the sum of $2,940.81 with the respect to account number (******"""2040), as of October 13, 2010 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, Account Assignee claims the sum of $2,940.81 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC ?t. By: Chela Wise Custodian of Records Subsc *bed and sworn to before me on A?- of , 2011 Not Pu is q10-89720 r r 441ry ...? Margie Camper Snoody mo^wea to of Virginia 9 My commission Expires y2 2956 015 'Chi, con mm)ication as from a debt collector and is art attempt to cofle,-[ a deNb AnY ini ,, ,,, ,- , =btained -will be used for that purpose, 1 8664 201 31 2 GE Card Services 0 0908 a.m. 10-29-2010 212 EXHIBIT A BILL OF SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Purchase Agreement), dated as of October 19, 2010 by and between GE Capital Corp. (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 Purchase Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Purchase Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Purchase Agreement. GE Capital Corp. By: Title: 1//0 Date: 7 Cut-off Date i 10/19/10 GE5J4* SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?,??~~v?tr of ?urrtbr?????d OPc!CE -T TkE `i-ERIFF t^- , If°?? Ir 1"jI I SEI' 26 PM 2: 23 PENNSYLI/AVIA Portfolio Recovery Associates, LLC I vs. Jack Wright Case Number 2011-7153 SHERIFF'S RETURN OF SERVICE 09/19/2011 08:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 19, 2011 at 2002 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jack Wright, by making known unto himself personally, at 839 Pennsylvania Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $44.00 September 22, 2011 DE S FRY, DEP SO ANSWERS, RON R ANDERSON, SHERIFF (0) CountySulte Shenff, Teleos, tt. Ir;; Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 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. 11-7153 CV V. (Z- �S JACK WRIGHT -T-3 ' Z: 839 PENNSYLVANIA AVE LEMOYNE PA 17043 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END = : PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, = F DISCONTINUED AND ENDED. Res ct itted, 7 R rt . 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 10-89720 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 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. 11-7153 CV V. JACK WRIGHT 839 PENNSYLVANIA AVE LEMOYNE PA 17043 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End up JACK WRIGHT by First Class Mail, Postage Pre-Paid, a copy thereof on this Aday of , 2014, to: JACK WRIGHT 839 PENNSYLV EMO 7043 obert 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 10-89720 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for this purpose.