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HomeMy WebLinkAbout12-0612Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. FILED-OFFICE Norfolk, VA 23502 0I If"E* 'Fh0TH Qr°30TAFi)/ TELE: 1-866-428-8102 FAX: 757-518-0860 23 12 FEE - I tM 10: 4 r5 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMB&M, -COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. JANICE R MILES ASSOCIATES, LLC Plaintiff 6811 SALEM PARK CIR MECHANICSBURG PA 17050 Defendant NOTICE No. ?V?l 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. QMA 103. 7SP4 Lilo 1311 S7 s? 2 It oys? 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. JANICE R MILES 6811 SALEM PARK CIR MECHANICSBURG PA 17050 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 1NFORMACION 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 f l2ia comnrnUDiC alikAl is frc na a debt collector and is an attc?n ht to c olle(t a clchl, Any inforntatioaa obtained gill be ii??ed itzr° tljza€ ???€t?ac3sc. Robert N. Pola,s, 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. JANICE R MILES 6811 SALEM PARK CIR MECHANICSBURG PA 17050 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant JANICE R MILES, is an adult individual with last known address of 6811 SALEM PARK CIR, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to CAPITAL ONE BANK, N.A. on April 11, 2009 with account number ************5549 (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. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. ('0 1,11n lication i:? i.rom a debi collector ,end is x) .w rapj io collt:ct a debt tr y i fonuAition obtained will be tt ,cd t r rlio4c;. 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 July 18, 2009. 8. Plaintiff is the purchaser, assignee and/or successor in interest CAPITAL ONE BANK, N.A. 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." 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 $1,021.85. 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, JANICE R MILES, in the amount of $1,021.85, plus costs of this action and any other relief as the Court deems just and reasonable. 11-20145 Robert N. PolVIr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 t.1?€ o to ra?araiuatic at is front a debt colle=ctor and is an :auentg- t to collect n debt, An iu.for€taation obtained will be uscd 16 ilt;at 1-uxlas>4e_ VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, TanyaHoUwbeck 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 By: an Hollenbeck _ C todia of Records 11-20145 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: ************5549 JANICE R MILES Account Holder: JANICE R MILES 6811 SALEM PARK CIR MECHANICSBURG PA 17050 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase Purchase Date: Balance at Charge-Off.- Less Payments: Balance Due: 11-20145 CAPH91 Product Code: MC CAPITAL ONE BANK, N.A. / Portfolio Recovery Associates, LLC ************5549 April 11, 2000 July 18, 2009 March 8, 2010 $1,041.90 April 19, 2010 $1,021.85 $.00 $1,021.85 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, _ Tanya Hollenbeek 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 CAPITAL ONE BANK, N.A. ("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 April 19, 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 JANICE R MILES ("Debtor") to the Account Seller the sum of $1,021.85 with the respect to account number (************5549), as of March 8, 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 $1,021.85 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC A 1A °` C? By: Hollenbeck , Custodian of Records JAN 12 2012 Subscribed and sworn to before me on of , 2011 4 Notary Public 11-20145 This c(: k,nwi " ?i is fz-on) a debt collector and is an attc:nipt to collect a debt, Aii iW- hiai <d :.01 be used for that purpose, 0 • Exhibit 1 to Forward Flow Receivable Sale Agreement dated December 18th, 2009 BILL OF SALE Closing Date: April 19", 2010 Capital One Bank (USA), National Association ("Seller"), in consideration of a Purchase Price of .. and other valuable consideration, the receipt of which is hereby acknowledged, hereby sells, assigns and transfers all right, title and interest in the Accounts identified in the Sale File entitled 20100413.PS40CP.SLDFLEl.TXT (which may be in electronic form) to Portfolio Recovery Associates, LLC (`Buyer"), without recourse or representation except as expressly provided herein or on the terms, and subject to the conditions, set forth in the Agreement (as defined below). This Bill of Sale is delivered pursuant 'to that certain Forward Flow Receivable Sale Agreement, dated as of December 18'", . 2009, by and between Seller and Buyer (the "Agreement"). All capitalixed terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such terms in the Agreement. The Cutoff Date for the Sale File was April 13s", 2010. CAPITAL ONE BANK (USA), NATIONAL ASSOCIATION By: V - Name: 3omLiam Stalls Title: Recoveries MVP CAP H 91 Sonia ca?; ?'- Your account works differently now that you're 7 payments late. Please see the next page for important account information. Page 1 of 2 1-804258-9319 ? WwW.Capitalone.Conysolutions Feb. 07 - Mar. 06, 2010 28 Days in Billing Cycle j IMPORTANT ACCOUNT UPDATES MASTERCARD PLATINUM 5549 your full balance is due. Any payment you make will reduce your balance and help pay off NEW BALANCE PAYMENT DUE DUE DATE I your debt faster. The am)unt you owe may differ 4 you've entered into a separate payment $1,021.85 $0.00 PAST DUE 1 agreement Available Credit: 50.00 Previous Balance Payments and Credits Fees and Interest Charged 5965.415 _ 50.00 I t $5639 I Transactions 50.00 0 TRANSACTIONS _ PAYMENTS, CREDITS & ADJUSTMENTS FOR JANICE R MILES #5549 FEES i 1 03 MAR PAST DUE FEE $39.00 Total Fees This Period 539.00 Total Fees This Year $146.00 INTEREST CHARGED INTEREST CHARGE: PURCHASES 515.50 INTEREST CHARGE CASH Sl 99 Total Interest This Period $17,39 Total Interest This Year 549.99 You were assessed a past due fee because your minimum payment was not i received by the due date. To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Capital One. I New Balance $1,021.85 Help is Available. Just pick up the phone, Call 1.800-258-9319 and a specially trained agent will be happy to help you check your balance and make payments. INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual interest rate on your account. Type of Balance Annual Percentage Balance Subjed to Rate (APR) Interest Rate Interest Charge Purchases 23.15%D 5873.11 $15.50 Cash 23.15%D 5106.23 $1.89 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.CONySOLUTIONS TO MAKE YOUR PAYMENT ONLINE. 5549 G Account Number: 549 Due Dale New Balance used I Past Due - S1,021.85 ? --- - JANICE R MILES 26 24 NW 8TH PL CAPE CORAL, FL 33993-8608 Il 1,I1-IIIII111111111-111111-llllllllllrllllrrllllll1-III1ll-rll manage your account online. AQ Visit www.capitalone.com/solutions to manage your account online. Have information at your fingertips 24/7 without picking up the phone. Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 26272-1083 1111111 111, - II111r11'III lllll.-111111,-11-1-III-II"IIIIII11-IIII Please make checks payable to Capital One Bank (USA), N.A. and mail with this coupon in the enclosed envelope. How can I avoid paying Interest Charges? Each month you pay your "New Balance" in full, you will have a minimum grace period of 25 days with no interest charge on all new 1) purchases, 2) balance traoders, 3) special purchases and 4) other charges. f you have been paying your account in full with no interest charges applied and you do not payyour next bill in full, prorated mtereat charges will be assessed. There is no grace period on cash advances, special transfers, or on any new transaction when there is an unpaid balance from a previous bill How is the Interest Charge applied? Interest charges accrue from the 1) date of the transaction, 2) date the transaction is processed or 3) first calendar day of the billing period Interest charges accrue on every unpaid amount until it is paid in full. This means you may owe interest charges even it you pay the entire *New ealance- one month, but did not do so for the previous month. Unpaid interest charges are added to the proper segment of your Account However, we reserve the right to not assess interest charges at any time. Do you assess a 141 n'rnum 1 t est Charge? Yes. A minimum INTEREST CHARGE Of $0 50 Will be assessed for each billing period your account is subsea to an interest charge flow did you calculate the Interest Charge? There are several calculations that are used to determine your total interest charge. 1. To get your Daily Balance for each segment, 1) take the beginning balance and add in new transactions and the periodic interest charge on the previous day's balance. 2) subtract any payments and credits for that segment as of that day. The result is the daily balance for each segment. However, it you paid your previous month's balance in full (or it your balance was zero or a credit amount), new transactions which post to your purchase or special purchase segments are not added to the daily balances. Alw, transacticns that are sub)ect to a grace period are not added to the daily balances. 2. To find your Average Daily Balance: 1) add the daily balances together and 2) divide the sum by the umber of days in the billing cycle. 3. Estimate your Total interest Charge: 1) multiply your average daily balance by the daily peen is rate and 2) multiply the result by the number of days in the billing period. NOTE- Due to rounding or a minimum interest charge, this calculation may vary from the interest charge actually assessed. Is the -Payment Due' a Payoff Amount? No. All stated amounts are owed on the date of the statement However, because interest, late charges and other charges might change from day to day as provided in your customer agreement, the amount due on the day you pay may be larger for example, if you pay the amount stated in this statement, your account might still have a his ance after your payment is received Also note that the amount you owe may offer d you've entered into a separate payment arrangement Please call the number on the front of the statement for an exact payoff amount. Flow can my variable Annual Percentage Rate (APR) change? Your APR may increase or decrease based on one of seven standard indices reported in The Wall Street Journal. To find which index is used for your account, look for a code IF, L, C, S, D or F) on the front of this statement next to the APR(s). Then check the table below Code next to your Annuaf Percentage Rate (APR) Index which your rates are based on When your Annual Pace Wage Rah will change P Quarterly Prime+ margin previously disclosed to you The first day of the L Quarterly LIBOR+ margin previousy disclocea to you billing periods that C Oulutery CD+ margin previously disclosed to you and in January. April S Banlrcard Rime+ margin previously disclosed to you , July and October . D MONray Preis + margin Previously disclosed to you The first day of each F Monthly LIBOR + margn previously disclosed to you morally billing G Treasury LIBOR + mergin previously disclosed to you period. ss i-so wIM my account? Yes, under certain circumstances, you may be assessed a Late or Returned Payment Fee. You may also be assessed overlimit fees d you have chosen to accept them. You wig also be required to pay all of our actual collection expenses, attorneys' fees and court cons unless the law does not allow us to collect these amounts We reserve the right to not assess fees without prior notice and Without waiving our right to assess a similar fee later . What happens if my P_count j%ggh ndadp We may close or suspend your account and your right to obtain credit at any time and for any reason, even it you are not in default. Account suspension can be permanent or temporary. It your account is closed or suspended you must 1) stop using your credit card and account, 2) cancel all automatic payments, 3) destroy all credit cards and access checks, and 4) pay all amounts you owe us, even it they were charged after the account was dosed or suspended. How do I Make Pavngms? Payments you mail us will be credited to your account as of the business day we receive them, as long as 1) you send the bottom portion of this statement and your check in the enclosed remittance envelope, and 2) your payment is received in capital one's processing centers by Spm local time. Please allow at least seven (7) business days for mail delivery . Mailed Payments received by capital One at any other location or in any other form may not be credited as of the day they are received. Do you Process Paper Checks as an Electronic Funds Transfer? When you provide a check as payment, you authorize us and our agents either to use information from your check to make a one-time electronic fund transfer from your deposit account or to process the payment as a check transaction. When we use information from your check to make an electronic fund trarafer, funds may be withdrawnfrom yourdeposit account as soon as the same day we receive your payment and you will not receive your check back from your financial institution. Your authorization is not limited by the date on the check. We may resubmit and electronically collect the returned payments. what if I file for 9lBkrpptc if you are entitled to bankruptcy protection, this communication is for information only, it is not an attempt to collect, assess or recover a debt or claim. Do not send us payments without speaking with your bankruptcy attorney or the Bankruptcy Court. if you have questions about your account or bankruptcy proceeding, please have your attorney contact us. if you or your attorney Would like to contact our bankruptcy claims Servlcer directly, please contact: Capital One PO Box 85167 Richmond, VA 2 32 85 51 6 7 BILLING RIGHTS SUMMARY (Does Not Apply to Small Business Accounts) What To Do If You Think You Find A Mistake On Your Statement: if you think there is an error on your statement, write to us at'. Capltal One PC Box 30285 Salt Lake City, UT 84 1 30-02 55 In your letter, give us the following information. Account information. Your name and account number Dollar amount The dollar amount of the suspected error. Description of Problem: if you think there a an error on your hill, describe what you believe is wrong and why you believe it is a mistake You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing. You may call us or notify us bywebsite, but f you do mare not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error, the following are true: We cannot try to collect the amount in question, or report you as delinquent on that amount. YOU do not need to pay any disputed amounts and related interest charges or fees until we send you a notice about the outcome of our investigation. The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, d we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. While you do not have to pay the amount in question, you are responsible for the remainder of your balance. Your Rights M You Are Dissatisfied With Your Cradil Card Purchases. It you are dissatisfied with the goods or services that you have purchased with yourciedit ca"""d you have tried in good faith to correct the problem with the merchant, you may have the night not to pay the remaining amount due on the purchase To use this right, all of the following mug be true 1 The purchase must have been made in your home state or wahm 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note. Neither of these are necessary d your purchaaewaa based on an advertisement we ma0ed to you, or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM orwith a check that accesses your credit card account do not quality. 3 You must not yet have fully paid for the purchase. if all of the criteria above are met and you are still cinutdied with the purchase, contact us in writing at: Capital one P.O. Box 30285 Salt Lake City, UT 84130-0235 while we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, If We think you owe an amount and you do not pay we may report you as delinquent. Capital one supports information privacy protection: see our websne at www.capitalonecom capital one is a federally registered service mark of Capital One Financial Corporation All rights reserved . i- 2010 Capital One TC-10 01j30710 To change or update your address please call 1-800-258-9319 or visit www.capitalone.com/solutions M777 Now that your account is 7 payments past due, the changes detailed below will apply to your account. Hopefully, these will make it easier for you to take control of your finances again. G- Your balance is still due and we'll contact you soon (directly or through a collection agency) to discuss options for resolving your debt. You are responsible for paying the full balance on your account as well as any associated collections expenses, attorney fees and court costs unless the law does not allow us to collect these amounts, as provided in your customer agreement. If we continue to send you statements, you'll now receive them quarterly instead of monthly. We may continue to report the status of your account to the credit bureaus, unless prohibited by law. We may also report when your account is paid off. Help is available. We understand that it can be challenging to manage your finarces. Here are three important facts about your account that may help make it easier for you to repay your balance: 1) No more compound interest: This means that future interest charges will never accrue interest-- making it easier to pay down your debt faster. 2) Highest interest balances are paid first: Your payments will go toward the balance with the highest interest rate first-automatically saving you money whenever you make a payment. 3) Regular payments will resolve your debt: Since your highest interest balances get paid first and your interest doesn't compound, making regular payments will get your balance paid. Call 1-800-258-9319 to discuss your options. And remember, you can check your balance and make payments online any time at www.capitalone.com/solutions. W Help is available. Just pick up the phone. Call 1-800-258-9319 and a specially trained agent will be happy to help you check your balance, make a payment and answer any questions you may have. C1)2010 Capital Onr. Citpital One i; a federally registered "we mark. All rigiw reserved Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 41 1 L, P?, ? 'f1T 16trJ If/?, t?l a ?Qtx?wtr? of 4aara?irr?E;rlb ??? `.? r ???:, r AND COUN7 „a iiA roc; 'r; a !Portfolio Recovery Associates, LLC Case Number vs. Janice R. Miles 2012-612 SHERIFF'S RETURN OF SERVICE 02114/2012 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: Janice R. Miles, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Janice R. Miles. Request for service at 6811 Salem Park Circle, Mechanicsburg, Pennsylvania 17050 the Defendant was not found. Deputies were advised the Defendant is thought to be residing in Florida. However, The Mechanicsburg Postmaster is still delivering her mail to this address. SHERIFF COST: $43.00 SO ANSWERS, r? February 14, 2012 RON R ANDERSON, SHERIFF Carrie A. Brown, Esquire .? i - Robert N. Polas Jr, Esquire Attorney ID # 94055/201259 [`u/t°si i Portfolio Recovery Associates, LLC j 140 Corporate Blvd. '?(??j 3EF L AliQ Norfolk, VA 23502 PEN'S CpU?yT Attorneys for Plaintiff YLVANI4 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. 2012-612 CIVIL V. JANICE R MILES 6811 SALEM PARK CIR MECHANICSBURG PA 17050 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respectfully bmitted, Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff 11-20145 This letter 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 Attorney ID # 94055/201259 Portfolio Recovery Associates, LLC 140 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 140 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 2012-612 CIVIL V. JANICE R MILES 6811 SALEM PARK CIR MECHANICSBURG PA 17050 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dismiss upon JANICE* MILES, by F' st Class Mail, Postage Pre-Paid, a copy thereof on this day of 20?to: JANICE R MILES 6811 SALEM PARK CIR, MECHANICSBURG PA 17050 Date: 11-20145 Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff This letter is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.