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Home My WebLink About12-1595Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #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. ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. /A - I-5g5 7 q Vi MCM ? cli? -<^' N r-- NOTICE TO DEFEND :2°' r?.a 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 5 *t03.?5 PA Ar%/ C*LU y-l3 0 d 7a3oy 2628610 PPTCPADI 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 las 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 PUEDF_ 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 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC vs. ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION No. Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), ALICE VANSCYOC , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE MONEY BANK, (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 $5463.64. 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. 2628610 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), ALICE VANSCYOC in the amount of $5463.64, plus costs. Respectfully submitted, PORTFOLIO RECOVER` One df its 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: March 8, 2012 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 aut PPTXVERI 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. ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 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. Dated: March 8, 2012 By: BLATT, HASENMI R, L & MOORE, LLC anieVoantucci regory R. Dye 2628610 PPTJCAMI 1111111111111 I I 11111111111111111111111111111111111111111111111111 Exhibit "A" PPTXEXAI D- Ca?61o VERIFICATION (To be used by a person associated with the present creditor) 1, Elaine Freeman-Lark , hereby verify that: 1. 1 am employed by Portfolio Recovery Associates, LLC as Custodian of Records and am authorized to make this Verification on behalf of Portfolio Recovery Associates, LLC. Portfolio Recovery Associates, LLC is the successor in interest to GE MONEY BANK, F.S.B./WAL-MART. 2. 1 reviewed the following [ ](a) computerized documents; [ ](b) hard copy documents; and [x] (c) other (specify)Account Records relating to Account number: ending in 8542. The foregoing Account of Seller/Merchant was opened on 6/8/1991 in the name of ALICE VANSCYOC. The accounts/documents that I reviewed were produced by GE MONEY BANK, F.S.B./WAL-MART. 3. Based on my review of the foregoing documents, there is due and payable the principal sum of $5,463.64. This sum includes the following (check all that are appropriate): [x] interest; [x] late fees; [ ] collection fees; and [x] any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and GE MONEY BANK, F.S.B./WAL-MART. This sum does not include the following (check all that are appropriate): [ ] interest; [ ] late fees; [x] collection fees; and [ ] any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and GE MONEY BANK, F.S.B./WAL-MART. 4. Based on my review of the foregoing documents, there are no payments that have not been credited. 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification to authorities in violation of 18 Pa. C.S. §4904. JAN 14 2012 DATE Elaine Freeman-Lark CUSTODIAN 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 215-564-1567 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. ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. !02 - /595 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: -70 f?J = rn rv 47 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: 1-215-564-1567 Dated: March 8, 2012 10 By: _ Da6?ia tu ccI Gregory R. Dye BLATT, HASEN R, LEI & MORE, L O r; ?;. tL, -?-r7 2628610 PPTXPEAI 1111111111111 I I 1111111111111111111111111111111111111111111 I I 11111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 3 Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Alice Vanscyoc SHERIFF'S RETURN OF SERVICE P ,. , -4 AM ? CUP BERLA",il PEIMSYL'%r'7kik!IA. Case Number 2012-1595 03/28/2012 11:38 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1138 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Alice Vanscyoc, by making known unto herself personally, at 139 Elm Street, 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: $34.00 March 30, 2012 GERALD WOR-THINGTO67 DEPUTY SO ANSWERS, 6??7 _ --- K ?6_a RON R ANDERSON, SHERIFF IN THE COMMON PLEAS COURT OF THE STATE OF PENNSYLVANIA IN AND FOR CUMBERLAND COUNTY o y PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC -OM 1835 Market Street, Suite 501 Philadelphia, PA 19103 a 3>C-, X C x..... rj v. Case Number: 12-1595 Civisjwm 9? c:) -77 -< ALICE VANSCYOC ANSWER OF DEFENDANT Pro Se Defendant Alice Van Scyoc hereby enters her appearance and answers the Complaint of Target National Bank as follows: 1. The Defendant admits the allegations of Paragraph 1 of the Complaint. 2. The Defendant admits the allegations of Paragraph 2 of the Complaint. 3. The Defendant admits in part and denies in part the allegations of Paragraph 3 of the Complaint. Defendant admits to making purchases and charging same to an account with GE Money Bank, however disputes owing a debt to Portfolio Recovery Associates, LLC, Plaintiff herein. The GE Money Bank account was settled and fully paid by an agreement dated April 29, 2010 between Leading Edge Recovery Solutions and Defendant in the amount of $3,900. (Attached Exhibit A) Cancelled checks have been ordered by the Defendant and will be delivered to the Court and Plaintiff upon receipt to supplement this answer. 4. The Defendant denies the allegations of Paragraph 4 of the Complaint. The Plaintiff herein has produced no evidence of a purchase or assignment of the account from GE Money Bank. The Defendant demands proof of such a sale or assignment. 5. The Defendant denies the allegations of Paragraph 5 of the Complaint. The Defendant disputes owing a debt to Portfolio Recovery Associates, LLC, Plaintiff herein. The GE Money Bank account was settled and fully paid by an agreement dated April 29, 2010 between Leading Edge Recovery Solutions and Defendant in the amount of $3,900. (Attached Exhibit A) Cancelled checks have been ordered by the Defendant and will be delivered to the Court and Plaintiff upon receipt to supplement this answer. WHEREFORE: The Defendant respectfully requests that Plaintiff's Complaint be dismissed and the relief requested in Plaintiff's Complaint denied. NEW MATTER AFFIRMATIVE DEFENSES 1. The Defendant alleges lack of standing of the Plaintiff to bring this action 2. The Defendant alleges that the complaint and each and every cause of action stated therein fails to state facts sufficient to constitute a cause of action against the Defendant. 3. The Defendant raises accord and satisfaction as a defense to this action. The Defendant disputes owing a debt to Portfolio Recovery Associates, LLC, Plaintiff herein. The GE Money Bank account was settled and fully paid by an agreement dated April 29, 2010 between Leading Edge Recovery Solutions and Defendant in the amount of $3,900. (Attached Exhibit A) Cancelled checks have been ordered by the Defendant and will be delivered to the Court and Plaintiff upon receipt, to supplement this answer. VERIFICATION The Defendant verifies that the statements made herein are true and correct based upon her knowledge, information and belief The statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Alice Van yoc 139 Elm St. Carlisle, PA 17013 (717) 243-1582 Pro Se Defendant CERTIFICATE OF SERVICE The Defendant(s) HEREBY CERTIFY that on this 0 day of , 20 a copy of the foregoing pleading was mailed, first-class, postage pre paid to: Daniel Santucci, Esq. Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market St., Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff l Alice Van Scy c Pro Se Defendant This document was prepared by, or with the assistance of Jonathan K Miller, Esq., an attorney licensed to practice law in the State of Maryland and Pennsylvania, Pa. Supreme Court number 50033, and employed by the Law Office of Persels and Associates LLC and Consumer Law Associates, LLC / Consumer Law Associates, LLP (CA, MI) / Consumer Law Associates, PLLC (NC), 972-239-4804. Persels & Associates, LLC, represents this client in out-of-court debt settlement negotiations, but no attorney from Persels & Associates, LLC, will be entering an appearance in this action sine counsel should send all communications related to this case directly to the Defendant, who is appearing pro se. To: Paoe 4 of 4 2010-04-29 14:24:08 EDT 14104232242 From: WENDY WOODS DRP 4292010 3:07 PM 'ER 4129/2010 2:30 PM Apr 29 2010 2:OOPM April 29, 2010 HP LASERJET FAX p.2 LEADING EDGE RECOVERY SOLUTIONS RECOVIRY LEADING PXGE LA N CUMBERLAND AVE S 300S' LI.C CHICAGO, rL 60656-1490 III 1111IN1111 1111h Ahte VanscyOc 139 ELM ST C*LISLE PA, 17013 RE: GE MONEY BANK / A--MART AcscountNumber: ********8542 LokS AccountNumber: 10821001 gent Balance: $9,363.64 Settlement Amount: $3,900.00 Dqar Alice Va mcYoc, ll This letter serves as confirmation that Leading Edge Recovery Solutions wi accept $1,900.00 as a fuel and final settlement on the above referenced account. The terms of the agreement are as follows: $2,000.00 due by 4/2912010 $950,00 due by 5/27/2010 $950.00 due by 6127/2010 Once the settlement amount ? been ?otant has been settle d vfuUea? thafor t yow credit v4e will then notify our ell Macau should be .Updated accordingly. You will then be released of any further liability tp GE MONEY BANK / WAL-MART and its agents in reference to this account. This agreement is in effect until the last payment date listed above and is void if the terms of this agreement are not met. Sincerely, 6ollections DspaAnient X866) 318-6742 Hours of oM+uon: "Qftday.Thurzday t3:00am - 9:eopm Car / Friday StOOMM - 5:0001111 CST / Saturday MCI - 12 Noon CST to colloct a debt by a debt collector. Any Information obtained wilt be used for that popose. Please be`led is aware t atthat any eny eforgivmoss above $60D.00 may be repotted to the IRS on a 10940 Form. ULAOaro: r .: ? t It Blatt, Hasenmiller, Leibsker & Moore, LLC A1to??ia for Plaintiff, Daniel Santucci Attorney I.D. # 92800 iP IaOVERY ASSOCIATES LLC Morris Scott Attorne I D #83587 Y 1835 Market Street, Suite 501 P'i'? tl< ?'``e Philadelphia, PA 19103 215-564-1567 i'U11BERLAND COUI ,i` PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 12-1595 CIVIL TERM 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: 1-215-564-1567 Dated: April 23, 2012 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: Morris Scott Attorney 2628610 PPTXPEAI 11111111 IN 11111111 IN 1111111111111111111111111111111111 I I I Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Morris A. Scott Attorney I.D. #83587 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 i r I. 7 Attorney for Plaintiff, PORTFOLIO REd&W?, l i ASSOCIATES, L119 PORTFOLIO RECOVERY ASSOCIATES, LLC cHo Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. ALICE VANSCYOC Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 12-1595 PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC, through its attorneys, Blatt Hasenmiller, Leibsker and Moore, LLC, does hereby answer the New Matter brought forth by the Defendant and states as follows: Denied. Plaintiff has proper standing to bring this action. Moreover, Defendant has failed to state any basis for her averment. 2. Denied. Plaintiff's complaint states sufficient facts to constitute a valid cause of action against Defendant. Moreover, Defendant has failed to state any basis for her averment. Denied. Plaintiff's claims are not barred by doctrine of accord and satisfaction. Moreover, Defendant has not presented any proof of payment of the amounts set forth in Plaintiff s Complaint. WHEREFORE, Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC, requests that this Honorable Court dismiss Defendant's New Matter, and render judgment in favor of Plaintiff and against Defendant, as set forth in Plaintiff's Complaint. Respectfully submitted, Morris A. Scott, Attorney No. 83587 Our File No. 2628610 VERIFICATION I, Morris A. Scott, am the attorney for the Plaintiff in the enclosed matter, and I have prepared the Answer to New Matter, after reviewing the file based upon my personal information and belief. I affirm that the facts asserted are true and correct to the best of my knowledge and belief. This verification is made subject to the penalties of 18 PA.C.s. Section 4904, relating to unsworn falsification to authorities. DATE: April 23, 2012 Morris .-Scott, Esquire Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Morris A. Scott Attorney I.D. #83587 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 Plaintiff, vs. ALICE VANSCYOC Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 12-1595 CERTIFICATE OF SERVICE I, Morris A. Scott, Esquire, counsel for the plaintiff, do hereby certify that I sent a true and correct copy of this Answer to New Matter, to the Defendant on April 24, 2012, at the below address. Alice Vanscyoc 139 Elm St Carlisle, PA 17013 Allvwltl?r? Morris A. Scott, Esquire Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC �_ c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLUS 1835 Market Street, Suite 501 r'lup Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, r_ -. CIVIL ACTION '.: vs. No. 12-1595 CIVIL TERMS — = i_C) fw, ALICE VANSCYOC z>C= 139 ELM ST CARLISLE PA 17013-1921 Defendant(s). PRAECIPE TO WITHDRAW COMPLAINT WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly WITHDRAW the Complaint filed in the above-captioned matter, WITHOUT prejudice. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: March 27, 2013 By: Mo riis Syretta Martin 2628610 PPTJPWCI 1 I 1l�1IIIIIII IIIN Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. 12-1595 CIVIL TERM ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 Defendant(s). CERTIFICATION OF SERVICE I, Morris Scott, attorney at Blatt, Hasenmiller, Leibsker and Moore, do hereby certify that I sent a true and correct copy of the WITHDRAW COMPLAINT via U.S. Regular Mail, to the DEF. ADDRESS on 3/28/13. PERSELS AND ASSOCIATES JONATHAN K MARSHALL, ESQ PO BOX 729 COLUMBIA, MD 21045 (-1---Morris Scott, Esq. yretta Martin, Esq. BHLM, LLC 2628610 PPTNCOSI