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Home My WebLink About12-0898Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC -Or F I C E 140 Corporate Blvd. # TEL }?NaNQ?AR` Norfolk, VA 23502 TELE: 1-866-428-8102 2012 FEB 13 Ali 11: 25 FAX: 757-518-0860 Attorneys for Plaintiff M E R (_ ` VANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. a-o?a- n 3 Ckvt ? 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. C) O,Mk a 103 S pd a Ckl+ l3?c,?g ti4o(o(Dy 60 ?2 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. LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 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 action dentro veinte (20) dial 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 this communication is from a debt collector and is an attempt to collect a debt. Any infbnnation 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. LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. Defendant LISA GIRTON, is an adult individual with last known address of 72 OLD BARN LN, NEWVILLE PA 17241. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / OLD NAVY on August 20, 2003 with account number ************2303 (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. l ii,s communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for 'that purpose. 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 14, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK, F. S.B. / OLD NAVY and Plaintiff is now the holder of the Account. A true and correct copy of the affidavit is attached hereto and collectivelymarked 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 $1,037.53. 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 respectfullyrequests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, LISA GIRTON, in the amount of $1,037.53, plus costs of this action and any other relief as the Court deems just and reasonable. Robert N. Polas Jr., Esquire # 201259 / Carrie A. Brown, Esquire # 94055 11-39052 This communication is from a debt collector and is an attempt to collect a debt. :Any inferrnation obtained will be used fix- that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, TaM Hollenbeckhereby 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 unworn falsificationto authorities. Date gy; llen eck roRecords Custodi11-39052 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 This communication is from a debt collector and is an, attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************2303 LISA GIRTON Account Holder: LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 Consumer Account Product Code: PVT Issuer: GE MONEY BANK, F.S.B. / OLD NAVY Assignee: Portfolio Recovery Associates, LLC Account Number: ************2303 Date Account Opened: August 20, 2003 Date of Last Payment: July 14, 2010 Date of Charge Off: February 23, 2011 Balance at Purchase: $1,037.53 Purchase Date: March 31, 2011 Balance at Charge-Off: $1,037.53 Less Payments: $.00 Balance Due: $1,037.53 11-39052 GECK78 This communication is from a cgllector and is an attempt to collect a debt. Any information obtained will be used for that purpose. State of Virginia City of Norfolk ss. AFFIDAVIT 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. 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. / OLD NAVY ("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 March 31, 2011. 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 LISA GIRTON ("Debtor') to the Account Seller the sum of $1,037.53 with the respect to account number (************2303), as of February 23, 2011 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 $1,037.53 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC 1 By: HOU , Custodian of Records JAN 24 2012 Subscribed an orn to before me on Notary Public 11-39052 of , 2012 CiII I:,toplicr Oaves r:nmom?calp? or Virginia N.tity Ychh,c 'X 73',Q05 r, ?i rnra;; 3t12?)14 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY s= 1 r D-0H-- #Gt 4,1a, ? ur ??nG?rf, T?jj - PR01:I0N'0 i ZN? FEB 23 AM FF a «€ 1UMBERLA14VAN4 A T ". pEN?SYt Portfolio Recovery Associates, LLC vs. Lisa Girton SHERIFF'S RETURN OF SERVICE Case Number 2012-898 02/14/2012 01:09 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 14, 2012 at 1309 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lisa Girton, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $40.00 SO ANSWERS, &"Z' February 15, 2012 RON R ANDERSON, SHERIFF Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID#94055/201259/312686 Portfolio Recovery Associates, LLC I'HE PROTHO NO T,�'if*'f 120 Corporate Blvd Norfolk,VA 23502 20 13 AUG 20 AM H: Attorneys for Plaintiff 70mbEtiLANU WON I Y IN THE COURT OF COMMON PLEAS OF CUMBERLKW V PA CIVIL ACTION- LAW -PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. 2012-898 CIVIL Plaintiff V. LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. Respec full su itted, Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff 11-39052 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#9405512012591312686 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. 2012-898 CIVIL V. LISA GIRTON 72 OLD BARN LN NEWVILLE PA 17241 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Dis retinue and End upon LISA GIRTON,by First Class Mail, Postage Pre-Paid, a copy thereof on this day of 2013,to: LISA GIRTON 72 OLD BARN LN,NEWVILLE PA I Robert N. Polas, Jr.,Esquire PA Bar#201259 7 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 11-39052 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for this purpose.