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HomeMy WebLinkAbout12-0902Robert 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 Attornevs for Plaintiff FILL'D-Or FTE T9E PROTHMOTARu ?0!? FEB 13 AM 11: 31 CUMBERLAND Cffl]NT4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. O `Y 1 1 Norfolk, VA 23502 : No. Plaintiff V. JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG PA 17240 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 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. © ?p3,7Sp4 ct 5 G. 13 -70(0 '1 4" Af] J1 Ll 9 M 4 Iw Z 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. JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG PA 17240 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 JESSTIN D HOLTRY, is an adult individual with last known address of 15599 CUMBERLAND HWY, NEWBURG PA 17240. It is averred that Defendant was indebted to CAPITAL ONE BANK, N.A. on September 25, 2008 with account number ************4568 (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. Hiis communication is from a debt collector and is an attempt to collect a debt. Any infimt nation obtained will be used fior 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 April 4, 2011. 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 collectivelymarked 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 $914.93. I O.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. I I.The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfullyrequests this Honorable court enter Judgment in favor ofPlaintiff and against Defendant, JESSTIN D HOLTRY, in the amount of $914.93, 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 11-39547 "Fliis comniunieation is from. a debt collector and is an attempt to collect a debt. '.'any info rnation obtained. will be Used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Tanya Hollenbeck 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 unswom falsification to authorities. Date By: Custo ' of ecords 11-39547 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 coinmunication 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: ************4568 JESSTIN D HOLTRY Account Holder: JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG PA 17240 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase: Purchase Date: Product Code: MC CAPITAL ONE BANK, N.A. Portfolio Recovery Associates, LLC ************4568 September 25, 2008 April 4, 2011 April 20, 2011 $925.39 May 16, 2011 Balance at Charge-Off: $914.93 Less Payments: $.00 Balance Due: $914.93 11-39547 CAPL 10 This communication is from a collector and is -fin attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. TanyaHollenbeck I the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affum 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, 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 May 16, 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 JESSTIN D HOLTRY ("Debtor') to the Account Seller the sum of $914.93 with the respect to account number (************4568), as of April 20, 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 $914.93 as due and owing as of the date of this affidavit. Portfolio Rec y Associates, LLC JAIn, on ?f ( „ By: Custodian of Records ;SHIM 2 4 201? Subscribed orn to before me on of 12012 ____ --- Notary u is _............ 1 t l i 1 I.l?' 4 ....v ?Y k2 {lt t 11-39547 ±_jnia 4 h , (?; i t n.ur.c? ill>. ?! This communication is frtnn a debt collector and is an attempt to collect a debt. Any information obtained will be used for that lzrpose. Capitaft, N.A. 15000 Capital One Drive ALM* Richmond, VA 23238 Exhibit 1 to Forward Flow Receivable Sale Agreement dated June 30*, 2010 BELT, OF SALE Clow Deft: Mky 16*, 2011 Capital One Bank (USA), Ngional A i`a ("Selle;r" ), in consideration of a Purchase Price of and o a 'on, the receipt of which is hereby acknowledged, hereby sells, aw4w and uvn&m all right, title and interest in the Accounts identified in the Sale File en*W 20110511.P 53CP.SLDFLEI.TXT (which may be in electronic form) to pm1&11o Romvery Asso es, LLC ("Buyer"), without recourse or represent* a cqk as exprenly • or on the terms, and subject to the conditions, set forth in the Avvement (as defined below). This Bill of Sale is defivemd want to t1W cerWn Forward Flow Receivable Sale Agreement, dAed as of June 30'x, 2010, by and betwm Sew and Buyer (the "Agreement"). All capitalized tames und, but not deiced, in this Bill of Sale shall have the meanings assigned to such terms in the Agreement. The Cutoff Date for the Sale File was May 116', 2011. The aggregate Unpaid Balance of the Accounts as of the Cutoff Date was CAPITAL ONE BANK (USA), NATIONAL ASSOCIATION By: - Name: nathan Stalls -4 Title: SVP CAFL 10 500343 C __7 ap? W_ Your account works differently now that you're 7 payments late. Please see the next page for important account information. Page 1 of 2 1-800-258-9319 www.capitalone.corrNsolutions Mar. 20 -Apr. 19, 2011 31 Days in Billing Cycle IMPORTANT ACCOUNT UPDATES IPfatinam MasterCard 568 Your full balance is due. Any payment you make wit reduce your balance and help payoff NEW BALANCE PAYMENT DUE DUE DATE your debtfaster The amount you owe may d rer 4 you've entered into a separate payment agreement. $914.93 $914.93 PAST DUE Available Credit: SO 00 Previous Balance Payments and Credits Fees and Interest Charged Transactions New Balance ...... -,. 5833.30 - S500.00 I t S8163 } 5500.00 J' 5914.93 - ---.i ..- - -' TRANSACTIONS PAYMENTS, CREDITS & ADJUSTMENTS FOR JESSTIN D HOLTRY #4568 1 04 APR CAPITAL ONE ONLINE PYt9TAuthDate 02-APR (S500 OM TRANSACTIONS FOR JESSTIN D HOLTRY #4568 1 Oc APR Returned Online ACH Payment $500.00 01 Total Transactions This Period $500.00 FEES 1 08 APR OVERLIMIT FEE APR 08, 2011 $25.00 2 t6 APR PAST DUE FEE $35.00 3 19 APR CAPITAL ONE MONTHLY MEMBER FEE $5.00 Total Fees This Period $65.00 Total Fees This Year S192.10 INTEREST CHARGED INTEREST CHARGE. PURCHASES S16.63 Total Interest This Period S16.63 Total Iri erest This Year $58.42 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 Subject to Interest Charge Rate (APR) Interest Rate Purchases 23.15%D S845.95 $16.63 Cash 23.15% 0 $O,DO 50.00 You current have over-the-credit lima coverage on your account, which means that we may process transactions that cause you to go over your credit limit. 0 you do ge over your credit limit, we ?.vill charge you a tee of up to S29. To remove over-the-credit-limit coverage from your account, call us at 1-800-955-7070. 568 19 0914930500000914931 C"Wa Account Number: 568 Due Date New Balance Amount Enclosed Past Due $914.93 - - ------.._-- Manage your account online. Visit www.capitalone.com/solutions to manage your account online. Have information at your fingertips 24/7 without picking up the phone. auooaa JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG, PA 17240-9687 II'I'Illllllll'IlI'111'Il'1'Il'111'IIIIII'Ill'Irlll'Illllllllll'I Capital One Bank (USA), N.A. P.O. Box 71083 Charlotte, NC 28272-1083 ulllllrlllrrnldrhrhlhllrrllnll?rllrlrlllrllrrllllllllrlnl 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 transfers, 3) specie purchases and 4) other charges. It you have been paying your account in full with no interest charges applied and you do not pay your next bill it full, prorated interest 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 bIl How lathe 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 pened Interest charges accrue on every unpaid amount until it is paid in full. Tha means you may owe Irtemst charges even if you pay the entire "New Balance° one month, but did not do w 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 anytime . Do you assess a Minimum Interest Charo e? Yes. A minim Um INTEREST CHARGE of 50 50 will be assessed for each billing period your account is subject to an interest charge How 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, if 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 Alto, transactions that are subject 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 periodic 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 va ry from the interest charge actually assessed. Is the -Paymem 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. Forexample, it you pay the amount stated in this statement, youraccount might still have a balance after your payment a received. Also note that the amount you owe may differ 0 you've entered into a separate payment arrangement Please call the number on the front of the statement for an exact payoff amount. How can my variable Annual Percentage Rate (APR) change? Your APR may increase or decrease based on one of seven standard morels reported in The W fi StreetJournal. To find which index is used for your account, look for a code (P, L, C, 5, D or F) on the front of this statement next to the APR(s). Then check the table below Code next = When ygur Annual g Annual Po1 Index which your rate. are based on Percentage Rate Rate (APR) .11 charge P the "Prime+ margin pmiously disclosed to you The first day of the L Quarterly LIBOR+ margin prevously d%o,I-.d to you billing Periods that C Quarterly CO + margin previously disclosed to you end in January. April, S Bankcard Prime + margin previously disclosed to you July and October. O Monthly Prime+ margin previously dl6tlosed to you The first day of each F Monthly LIBOR + margin previously disclosed to you monthly billing G Treasury LIBOR + margin previously disclosed to you period Are then Additional Feas associated with my account? Yes, under certain circumstances, you may be assessed a Late or Returned Payment Fee. You may also be assessed overlimit fees if permitted by law. You will also be required to pay all of our actual collection expenses, attorneys' fees and court costs unless the law does not allow us to collect these amounts we •eserve the right to not assess fees without prior notice and without waiving our right to assess a alrnldf fee later Whathappens if my Account is Susoended7 We may close or suspend your account and your nght to obtain credit at anytime and forany reason, even if you arc not in default. Account suspension can be permanent or temporary . If 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 if they were charged after the account was closed or suspended. How do I Make Pair erds7 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 loca? time. Please allow at least seven (?) business days for mail dell 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 Pro-st 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 transfer, funds may be withdrawn from your deposit account as won as the same day we receive your payment and you will not receive your check back from your financial institution. Your autfiorization is not limited by the date on the check. We may resubmit and electronically collect the returned payments. What 61 file for @ankrualcy d 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 # you have questions about your account or bankruptcy proceeding, please have your attorney contact us. d you or your attorney would like to contact our bankruptcy claims servicer directly, please contact Capital one PO Box 30285 Salt Lake City, UT 84130-0285 BILLING RIGHTS SUMMARY (Does Not Apply to Small BUalness 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 Capital One P O. Box 30285 Salt Lake City, UT 84 1 30-02 85 In your letter, give us the following information. Account intgmetion. Your name and account number _Dpllar amount: The dollar amount of the suspected error. - Description of pr2 of ; If you think there is an error on your biil, describe what you believe is wrong and why you believe it is a mistake. You most contact us within 60 days after the error appeared on your statement You most notify us of any potential errors m writing You may call us or notify us electronically, but if you do we are 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. The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if 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 until we send you a notice about the outcome of our investigation, you are responsible for the remainder of your balance. Your Rights It You Are Dissatisfied With Your Credit Card Purchases, If you are dissansfud with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase To use this right, all of the following must be true 1 The purchase must have been made in your home state orwithin 100 miles of your current mailing address, and the purchase price must have been more than 650. (Note. Neither of these are necessary If your purchase was based on an advertisement we marled to you, or if we own the company that sold you the goods or services.) 2. You most 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 criminal above are met and you are still dissatisfied with the purchase, contact us In writlnp at capita) One PC Box 30285 Salt Lake City, UT 841 30-02 85 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, B 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 caplelone com capital One is a federally registered service mark of capital one Financial Corporation All rights reserved E 2010 Capital One TC-10 0510-11? 0 To change or update your address please call 1-800-258-9319 or visit www.capitalone.com/solutions 200866 Now that your account is 7 payments past due, the changes detailed below will apply to your account. Hopefully, these changes will make it easier for you to take control of your finances again. Cq~ Your balances still due and you'll be contacted soon 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 as provided in your customer agreement, unless the law where you reside does not allow us to collect such expenses. 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 will also report when your account is paid off. Help is available. We understand that it can be challenging to manage your finances. Here are three important facts about your account that may help make it easier for you to repay your balance: 1) Highest interest balances are paid first: You will no longer be charged past due, over limit, or membership fees. 2) No more compound interest: Future interest charges will never accrue interest-making it easier to pay down your debt faster. 3) Regular payments will resolve your debt: Since your interest doesn't compound, making regular payments will get your balance paid. Call 1-800-258-9319 to discuss your options. If a third-party agency is already managing your account, your call will be automatically routed to them. Remember, you can check your balance and make payments online any time at www.capitaIone.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. CL 2011 Capital One. Capital One is a federally registered le7vire mark. All rights nsetved. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t J; Jody S Smith ' o Chief Deputy ^ Z F_ ! 23 All IS,: 7 t.t, ? Richard W Stewart ('I1M3rFKi x vC C0UAT Solicitor OFF, PENMSYLVAA'41A Portfolio Recovery Associates, LLC Case Number vs. Jesstin D. Holtry 2012-902 SHERIFF'S RETURN OF SERVICE 02/15/2012 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: Jesstin D. Holtry, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jesstin D. Holtry. Request for service at 15599 Cumberland Highway, Newburg, Pennsylvania 17240 is located in Franklin County. SHERIFF COST: $53.00 SO ANSWERS, February 15, 2012 RON r R ANDERSON, SHERIFF Carrie A. Brown, Esquire t` J) Robert N. Polas Jr, Esquire Attorney ID # 94055/201259 R Portfolio Recovery Associates, LLC 4 /C E. 140 Corporate Blvd. "U116c Norfolk, VA 23502 PEPOC$ Y D COIJNT y 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. 2012-902 CIVIL V. JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG PA 17240 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respectfull miffed, 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 11-39547 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. 2012-902 CIVIL V. JESSTIN D HOLTRY 15599 CUMBERLAND HWY NEWBURG PA 17240 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dismiss upon JESSTIN D HOLTRY, b First Class Mail, Postage Pre-Paid, a copy thereof on this day of'/ ( , 20/, to: JESSTIN D HOLTRY 15599 CUMBERLAND HWY, NEWBURG PA 17240 Date: 11-39547 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.