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Home My WebLink About11-8232Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, VS. JAMESON E CHRISTOPHER 821 FACTORY ST CARLISLE PA 17013 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - ss No. {. NOTICE TO DEFEND 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 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 C19) 2669523 CLV 9 a Pd PPTCPADI 5°1 971 F- a route lY AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas [as provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, VS. JAMESON E CHRISTOPHER 821 FACTORY ST CARLISLE PA 17013 Defendant(s). Attorney for Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. I I- Ka-3d COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), JAMESON E CHRISTOPHER, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with NON PRIME, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $1074.53. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2669523 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), JAMESON E CHRISTOPHER in the amount of $1074.53, plus costs. Respectfully PORTFOLIO One dWd Attorneys/ Daniel Santucci, Attorney No. 92800 Gregory R. Dye Attorney No. #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: October 14, 2011 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 PORTFOLIO RECOVERY ASSOCIATES LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, Vs. JAMESON E CHRISTOPHER 821 FACTORY ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASILLER, LISKER & MOORE, // Dated: October 14, 2011 By: R. Dye 2669523 PPTJCAM I 181 VIII I??f III III I VIII VIII VIII INNI I II IN VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to au PPTXVERI Exhibit "A" PPTXEXAI State of Virginia AFFIDAVIT City of Norfolk ss. I, the undersigned, Tanya Hollenbeck , 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, and I am authorized to make the statements, representations and averments herein, and do so based upon a review of the business records of the Account Assignee and those records transferred to Account Assignee from HSBC BANK NEVADA, N.AJORCHARD BANK(NON PRIME ("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 1/26/2010. 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 JAMESON E CHRISTOPHER ("debtor and co-debtor") the Account Seller the sum of $1,074.53 with the respect of account number ending in 1046, as of 7/31/2009 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, there is currently due and owing the sum of $1,07453 as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. Portfolio Recovery Associates, LLC By: Holl ftustodianof Records Subscribed sworn to before me on (SEP 0 8O 2011 Notary blic '1,6101. "'Irginia Cornn:om•,;cetllh o ' t L I ul Nota,y 14 J;y Cumm:?U This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 610-902-0644 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. JAMESON E CHRISTOPHER 821 FACTORY ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLE4S ;_, CUMBERLAND COUNTY, PA , M r CIVIL ACTION c? ?, cm s++fe 6 7 _ No. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-610-902-0644 Dated: October 14, 2011 By: BLATT, HA & MOORE Gregory R. Dye 2669523 PPTXPEAI IIIII 111111111 IN IN 011111111111111111111111111 IN I In the court of common Pleas In and for the county of Cumberland Civil Action -Law 11-8232 Civil c-? P.R.A, LLC Zr67 CI?T' IN tr VS. N rr, Jameson E. Christopher q c Entry of Appearance To the Clerk of Said Courts: Enter My Appearance as Pro Se For Me as Defendant. Dated: 11/21/2011 Jameson E Christopher Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSLYVANIA CIVIL ACTION - LAW PORTIFOLIO RECOVERY ASSOCIATES; LLC 140 Corporate Blvd Norfolk, VA 23502 Plaintiff V. Jameson E. Christopher 821 Factory Street Carlisle, Pa. 17013 Defendant Notice To Plead To: Portfolio Recovery Associates, LLC You are hereby notified a Witten response to enclosed answer within twenty (20) Days from service hereof or a judgment my be entered against you. Jameson E. Christopher Answer and Affirmative Defenses Defendant, Jameson E. Christopher, answers the Complaint filed in this action as Follows: 1. Defendant Admits everything is True 2. Defendant object to this allegation on the grounds that it is vague, ambiguous and unintelligible in that Defendant has to speculate as to the meaning of the "Account." 3. Defendant has no way to determine if the information is true or false. Defendant was not given any documention pertaining to repayment rules or regulations. Defendant has no way to determine if the information is true or false, Defendant denies that the information is true. 4. Defendant does not know if the information in paragraph 4 of the complaint is true or false. Defendant has no way to determine if the information is true or false. Since Defendant does not know if the information is true or false, Defendant denies that the information is true. S. Defendant does not know if the information in paragraph 5 of the complaint is true or false. Defendant has no way to determine if the information is true or false. Since Defendant does not know if the information is true or false, Defendant denies that the information is true. FURTHERMORE, Defendant denies every other allegation not previously admitted, denied or controverted. A Affirmative Defenses 1. Defendant repeats all the statements in the previous paragraphs as if typed I full here. 2. Plaintiffs fail to state the basis of the lawsuit and have not cited any actual state laws which have been violated. 3. The action is barred by the Statute of Frauds. 4. The court would unjustly enrich the Plaintiff by granting the relief sought herein. 5. The plaintiff has not proven the debit is valid or the amount of the dept is accurate. The Plaintiff must prove that the principal, interest, collection costs and attorneys fees are all correct, agreed to in its contract and lawfully charged. Defendant also insists that the Plaintiff produce the contract, account statement and purchase receipts to prove the amount of the dept. WHEREFORE, Defendant, Jameson E. Christopher asks the Court to: A. Enter a judgment in the Defendant's Favor and against Portfolio Recovery Associates, LLC; B. Grant any other relief as the Court deems just and proper; and C. Dismiss the Complaint herein with prejudice. Verification I verify that the facts stated in this Answer and Affirmative Defenses are true and correct to the best of my knowledge, information and belief. I understand that false statements in this Motion are subject to the penalties of 18 Pa. C.S.A..4904, relating to unsworn falsification to authorities Date: //1,9 //Qdf / Jameson E. Christopher 821 Factory Street Carlisle, Pa. 17013 IN THE COURT OF COMMON PLEAS OF l? CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 600 ;t' , ? 'v I 20 vs, 6-5 r47 cr) Defendant - -' r RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially rtte Following form.: c. PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: N ?11,6 1 Scl ?1 "T'? <_ L J counsel for the Gi?? efendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ ?LI - ?? /6' 5 C'za The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully sub ed, I ) L. -'t1i'el tIt4t_ ?r ORDER OF COURT AND NOW, j / 209W , in consideration of the foregoing petition, Esq., and Qt/1? Q d I 4V Esq., and Esq., are appointed arbitrators in the above 'r -- >-captioned action (or actions) as prayed or. CD= By the Court, eC 0. CJ r",`y N all = `?'?-- ? rt .? I SQ M?k CC i5. O Q K m A. Hess, P. J. Lutes w= m t'SOrt W PA ATry _. t*- ?? c, ?? a?3893 ?0?-4 I ?o R ?ssoc? a LLCM. Ck- Plaintiff Defendant We do solemnly swear (or affirm) that we and the Constitution of this Commonweal) In the Court of Common Pleas of County-, Pennsylvania No. Civil Action - Law. Oath art, oy and defend the Constitution of the Uni we 4111 discharge the duties of our office with States Ktr?,*(JU.4"', '?? 21?? Y' . %--- L I - - A A j Ir-6 rl A V Cl%-% I?CLPZI Name (Chairman) Name Name k?s -,2Ltj GA-10-? Moms / aia (AAA P 't Law Firm Law Firm Law Firm VO 122-° Address Address Address t -7ct3 (rqo „-c I ?a?t 3 a, Y, k,- A & / d 13 City, zip city, Zip City, ip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following k award, ote: If damages for delay are awarded, they shall be separately stated.) clc, l re-, +Z) 44?-e.- a w «Qw-, - recd to vrd.e.,? ? (? ? , _,A44itrator, dissents. (Insert name if ap licable.) Date of Hearing: 7! / l/ Z ??,fC.??? Date of Award: 7/Zl / 12 Notice of Entry of Award Now, the day of 20 /,;' 2 . ?,> , at _K, M., the award was entered upon the docket afii/d no ice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ Prothonotary By: Deputy -7I2 JUL 31 PIS 2: 2 CUM& P hgaLiA N U 6, tj J!, YLVANIA yes Ixa led 8/lA. Aa-