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HomeMy WebLinkAbout12-2071Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC ) li ti i' S' 140 Corporate Blvd. TELE k1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff 2RLUHT e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant NOTICE No. d (?- - c-)6-)l Civil 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 Q,?a?b3.?spd a? This communication is from a debt collector and is an attempt to collect a debt. L+? SaaUS t Any information obtained will be used for that purpose. SS(gD? " ?? a73ayl 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. KULWANT K KAUR 44 BAYBERRY DR 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 obej ciones 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 hiiis communication is from a debt collector acid is an atte cnlit to collect a debt. Anv information oLitained will be Used for that purp6se. 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. KULWANT K KAUR 44 BAYBERRY DR 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. Defendant KULWANT K KAUR, is an adult individual with last known address of 44 BAYBERRY DR, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / SEARS on May 15, 2009 with account number ************6892 (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. Ibis communication is from a debt collector and is an attempt to collect a debt. Any inibriiiat:ion 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. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / SEARS 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." 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 $935.92. 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 ofPlaintiff and against Defendant, KULWANT K KAUR, in the amount of $935.92, pjasNsts 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 11-43432 Hiis communication is from a debt collector and is an attempt to collect a debt, Any information obtained will be ti.4ed for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cristina Patterson 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 falsifrcationto MAR 01 2012 Date : 11-43432 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Custodian of Records 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: ************6892 KULWANT K KAUR Account Holder: KULWANT K KAUR 44 BAYBERRY DR 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: 11-43432 HSBI70 Product Code: MC HSBC BANK NEVADA N.A. / SEARS Portfolio Recovery Associates, LLC ************6892 May 15, 2009 N/A January 30, 2010 $935.92 July 27, 2010 $935.92 $.00 $935.92 This communication is from a 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. Cdstina Patterson I, the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm 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 HSBC BANK NEVADA N.A. / SEARS ("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 July 27, 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 KULWANT K KAUR ("Debtor') to the Account Sellerthe sum of $935.92 with the respect to account number (************6892), as of January 30, 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 $935.92 as due and owing as of the date of this affidavit. LLC Cristina PaTWZWn , Custodian of Records Subscribed and sworn to before me on L_ek;:4 A & V Notary Public 11-43432 of MAR 01 201 012 ?i Kristie A. Chapman Commonwealth of Vlrginla Notary Public Commission My Commission Expires 12131 014 This cornmumcation is from a debt collector and is an attempt to collect a debt.. Any in1_ormation obtained will. be used for that purpose, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Kulwant K. Kaur ?attttlt? ?1 411.i,i,r.i?r r? G a s s ; k. a.t A IN ,? M Case Number 2012-2071 SHERIFF'S RETURN OF SERVICE 04/03/2012 04:12 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 3, 2012 at 1612 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kulwant K. Kaur, by making known unto Gurdeeb Kaur, adult in charge at 44 Bayberry Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. J -, S N TSHAL , DEPUTY SHERIFF COST: $38.00 April 10, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant Date: No. 2012-2071 CIVIL Filed on Behalf of Plaintiff CounseRofrd for this Part Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff - S-17 C?? 183.2ge /Z ?6 ??O i.liis communication is from a debt collector is a"' dttemht: tO C011cct <' (!"'Ot. ?+rl?c?se. .env in formation c>btai.ned will he Used t' r it ai 1-) IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard : Norfolk, VA 23502 Plaintiff No. 2012-2071 CIVIL V. KULWANT K KAUR : 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, KULWANT K KAUR , for failure to answer the Complaint. (X) Amount Due $935.92 Less Credits $.00 TOTAL $935.92 Date: (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.231.1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to b ntered and to his/he ttorney of record, if any, after the default occurred and at least ten da pri r to the date of fil' g of this praecipe and a copy of the notice is attached. •A ?/2 Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff i Iris commi,inication is from a debt collector is rte attecnl t to collect l<lit. An irrlonnation obtaiticd l ill be rIsuc.l l'Z)r that I°mrpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATE, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant No. 2012-2071 CIVIL urn AFFIRMATION OF NON-MILITARY SERVICE CID is The undersigned counsel, as attorney for plaintiff, herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 44 BAYBERRY DR MECHANICSBURG PA 17050 and is not in the military service of the United States or its Allies, or otherwise within the provisions of the Service Members Civil Relief Act and its Amen('mentc- Date: 11-43432 Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff This c0111111 Lill ie"ltIon Ia debt collector and is an attempt to collect l,3 d,jit. AM' 111iortn;ation obtalned will he used for that purpose, Department of Defense Manpower Data Center Rules as of May-24.2012 03 12 20 SCRA 2.2 Stat" xtpoft Pursuant to S cememben Civd Rehef Act Last Name: KAUR First Name: KULWANT K Active Duty Status As Of, May-24-2012 Al,t a Duty Start Data Ac" Duty End Date Status Ser +ca Conaponnnl On Act" Duty On Active Duty Stalin Dale ..NA NA ..<.? ....ma?.m - _ Nd -.®-.......«.. NA This response reflects the individuals' active duty status based on the Active Duty status bate ®. .®.w?.._....m.»..,,?„,._. Leh Active Duty Within 367 Days of AcKv Duty Status Date Actrm Duty Start Date Active Duty End Die status Service Component NA NA No NA Thre response reRedts where the ind€viduai left active duty status Milan 367 days preceding the Active Duty Status Date The Member or K &+W Unit Was Noblod of a Future Cal-Up to Acb" Duly on Active Duty Status Date flrdM Notitkaibw Biwt DeM Order Nrriflcadan Ern1 Date _. Status vlce C.Moonertt ? NA _. _...._. ? , This response reflects whether the individual or hWher unit has received early nottra:aaoo to report Yor active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future order; to report for Active Duty. 41 e Mary M. Snavely-Dixon, Director I Department of Defense - Manpower Data Center 4800 Mark Center Drive,. Suite 04E25 "n f4 jF350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty` responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mir URL: http:/lwww.defenselink.mil/faglpls/PCOgSLDR.htmi, If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Tide 10 and Title 14 active duty records for all the Uniformed Services periods. Tide 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: FS39Q7M10T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 2012-2071 CIVIL V. KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $935.92, plus interest, on. (X;) A copy of all documents filed with the Prothonotary in s rt of t g 3 ment is/ ched. .av: q , If you have any questions regarding this Notice, please conta a ling party. Date: Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff }1 s communication is from a debt collector is aii attennix t?' colleet ti debt .?Nriv lnf'oruial.iorr obtained will be Lined liar that pu:q)ose. 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. 2012-2071 CIVIL V. KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 Defendant TO: KULWANT K KAUR 44 BAYBERRY DR MECHANICSBURG PA 17050 DATE OF NOTICE: May 2, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 Robert N 'Volas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff U, _ t ,, from it &N . , t oll ci 7 debt_ -wation obtaincd will 611