The URL can be used to link to this page

Home My WebLink About12-2555Robert N. Polas, Jr.,,Esquire °A Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. - p`?????,?,( - Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 % Attorneys for Plaintiff "It"? ER1 ?+{ tS pr4j,- tiSYLVASIA 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. LAUREN C SUMMERS 219 W LOCUST ST MECHANICSBURG PA 17055 Defendant NOTICE No. ) a • aSSS a-vi( 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. Q Ib3,7S Pd 0'4? Ck.# 14F&Z15 12,1 47qO9h 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. LAUREN C SUMMERS 219 W LOCUST ST MECHANICSBURG PA 17055 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 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 coin jy iiication is Frotri a debt collector and is an atten pt to colle a a dcb ,fin int6rination obtainc d will be used t6r that purl)ose. 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. LAUREN C SUMMERS 219 W LOCUST ST MECHANICSBURG PA 17055 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 LAUREN C SUMMERS, is an adult individual with last known address of 219 W LOCUST ST, MECHANICSBURG PA 17055. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / GM on March 4, 2008 with account number ************0592 (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. Thi<;, communication is 1i-o n a debt collector and is all attenlpt to collect a debt, Any iaalorrnation obtained will be used 14 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 October 5, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / GM 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 $2,581.26. 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, LAUREN C SUMMERS, in the ount of $2,581.26, plus costs of this action and any other relief as the Court deems just and reasonabl Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-59269 This commurucahon is from a debt collector and is an attempt to collect a debt. Any inlorniation obtained will be used for that purpose, VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, La!TY J. AndreWWreby 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 : A Q Nil B J. Andrews Custodian of Records 11-59269 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: ************0592 LAUREN C SUMMERS Account Holder: LAUREN C SUMMERS 219 W LOCUST ST MECHANICSBURG PA 17055 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 HSBC BANK NEVADA N.A. / GM Portfolio Recovery Associates, LLC ************0592 March 4, 2008 October 5, 2010 May 31, 2011 $2,581.26 June 24, 2011 Balance at Charge-Off: $2,581.26 Less Payments: $.00 Balance Due: $2,581.26 11-59269 HSBL37 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. I, the undersigned, Larry J. Andrews depose, affirm and state as follows: Custodian of Records, for Portfolio Recovery Associates, LLC hereby 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. / GM ("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 June 24, 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 LAUREN C SUMMERS ("Debtor") to the Account Seller the sum of $2,581.26 with the respect to account number (************0592), as of May 31, 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 $2,581.26 as due and owing as of the date of this affidavit. Portf? Recovery Associates, LLC By: LEWO, A dreWustodian of Records and sworn to before me on Public 11-59269 APR 10 2012 of 1 2012 Jean "te commonwealth of Vl?glnla Notary Public a ?. Commission No. 7509710 My Commission Expires 1/31/2015 This contmunicatioti is from a debt collector attcl is an attempt to collect a debt. Aii int urination obtained will be usod f >t° that purpose.. ASSIGNMENT AND BILL OF SALE HSBC Bank Nevada, N.A. and HSBC Bank USA, N.A., (hereinafter called "Seller") has entered into a Purchase and Sale Agreement as of May 16, 2011 ("Agreement") for the sale of Accounts and Account Documents described therein to Portfolio Recovery Associates LLC, (hereinafter called "Purchaser"), upon the terms and conditions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in each and every one of the Accounts described in the Agreement and in Exhibit A attached hereto. Purchaser and Seller agree that the Purchase Price shall be as stated in Paragraph 3 of the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 29th day of June, 2011. HSBC Bank Nevada, N.A. HSBC Bank USA, N.A. Signed By G'•?^-?? By: David Nauman Title: Vice President OSOL37 lof Z ASSIGNMENT AND BILL OF SALE HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporation (USA) IV (hereinafter collectively called "Seller") has entered into a Purchase and Sale Agreement as of May 16, 2011 ("Agreement") for the sale of Prime Fresh Charged Off Receivables described in Paragraph 1 thereof to Portfolio Recovery Associates, LLC, (hereinafter called "Purchaser"), upon the terms and conditions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in each and every one of the Prime Fresh Charged Off Receivables described in the Agreement and in Exhibit A attached hereto. Purchaser and Seller agree that the Purchase Price shall be as stated in Paragraph 3 of the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 29th day of June, 2011. HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporation (USA) IV Signed By. ?-? By: David Nauman Title: Vice President R56Z37 z oft SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of u+r,r,? Lt-D-0F Jody S Smith HF PR0TH0?;?° Chief Deputy 21? 12 MAY -8 AM 9:55 Richard W Stewart Solicitor BERLAND COUNTY CUPENNSYLVANIA Portfolio Recovery Associates, LLC vs. Lauren C. Summers Case Number 2012-2555 SHERIFF'S RETURN OF SERVICE 05/03/2012 03:50 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 3, 2012 at 1550 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lauren C. Summers, by making known unto Jamie Johnson, Mother of Defendant at 219 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 May 04, 2012 RYAN BURGETT, DEP SO ANSWERS, RON R ANDERSON, SHERIFF c' Ccuwysul.e She'l f, f elecso't. Inc.