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HomeMy WebLinkAbout12-2904Robert 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 1a?s Attorneys for Plaintiff EN; ` IS`; LVAi 1A 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. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant NOTICE No. I d- D-9oq Nn-l 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 Gs) This communication is from a debt collector and is an attempt to collect a debt. Ctv?,A 8tom' s(? a Any information obtained will be used for that purpose. C, .,* 1 76 S0-`} 1P- -6 6 -XI q L/ 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,. ANITA ADAM 3620 GOLFVIEW 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 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 EST E 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 HONORAR.IO 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 LOMI IlliCation is l mi a debt collector wid is an :Itiempt to Collect a dcht. Any iiitbrmatioti obtained ?, ill he used 1-or that pm,po se. 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 Attornevs 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. ANITA ADAM 3620 GOLFVIEW 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. 2. Defendant ANITA ADAM, is an adult individual with last known address of 3620 GOLFVIEW DR, MECHANICSBURG PA 17050. 3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on May 31, 2003 with account number ************1340 (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. I`1 is communication is from a debt collector i-id is an attempt to collect a debt, Any infiormation obtaMed will be used for that purpo e. 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. 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 June 29, 2011. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, 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." 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 $4,001.38. 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., ANITA ADAM, in the amount of $4,001.38, plus costs of this action and any other relief as the Court deems just and reasons e. a Robert N. Polas Jr., Esquire # 201259; Carrie A. Brown, Esquire # 94055 11-74202 hl,i c:ojnniunlcation is from a debt collector and is an attempt to collect a debt, any information obtained will be Lised t1or that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Itina Spellman 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 falsification to authorities. Date : APR 112012 11-74202 By: ? /"'a " Iona SpgJb6W Custodian of Records 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: ************1340 ANITA ADAM Account Holder: ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Consumer Account Product Code: PVT Issuer: CITIBANK, N.A. / SEARS Assignee: Portfolio Recovery Associates, LLC Account Number: ************1340 Date Account Opened.: May 31, 2003 Date of Last Payment: June 29, 2011 Date of Charge Off: August 28, 2011 Balance at Purchase: $4,001.38 Purchase Date: October 18, 2011 Balance at Charge-Off: $4,001.38 Less Payments: $.00 Balance Due: $4,001.38 11-74202 SRSM61 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, itina Spellman 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 CITIBANK, 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. 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 October 18, 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 ANITA ADAM ("Debtor") to the Account Seller the sum of $4,001.38 with the respect to account number (************1340), as of August 28, 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 $4,001.38 as due and owing as of the date of this affidavit. Portfolio Rec very Associates, LLC By: tina Spellm Custodian of Records Subscribed and sworn to before me on Notary Public 11-74202 ?- APR 112012 of , 2012 -? 0 lonne F-, L&IBOY Commonwealth of Vlrglnle Notary Public Commission No. 7572855 My Commission Expires 1213112015 Hill communication is front a debt collwor a nd is an attempt to collect a debt. ?n,v int'Ornial-loo obtained ??ill be used tier that purpose. Contract ID: PRISPIEM082511 Document ID: 101011 PR 1 SP 1 EMB 1 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated October 18, 2011, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank") to Portfolio Recovery Associates, LLC, organized under the laws of the Delaware, with its headquarters/principal place of business at 130 Corporate Boulevard, Norfolk, VA 23502 ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated August 25, 2011, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 and the final electronic file. Citibank, N.A. By:_.. (Signature) Name: Patricia Hall Title: Financial Account Manager PRA 08251 Ldoc SM6! v5R SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 111EO-OF1= ICE Sheriff THE PROTHONOTAF Jody S Smith 2012 Chief Deputy MAY ZZM gt Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Number Anita Adam 2012-2904 SHERIFF'S RETURN OF SERVICE 05/17/2012 05:02 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on May 17 2012 at 1702 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Anita Adam, by making known unto herself personally, at 3820 GoMview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. u TY SHERIFF COST: $38.00 May 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. 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. 12-2904 CIVIL V. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 PRAECIPE FOR DEFAULT Defendant JUDGMENT Filed on Behalf of Plaintiff nsel of recor for this Party Date: Robert N. Polas, Jr., Esquire,#201259- Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire,#312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 11-74202 QuU-�- / 2 W This communication is from. a debt collector is an attempt to collect a debt, Any infon-natim obtained will be used for that purpose. Nof iCe- QA 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. 12-2904 CIVIL V. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,ANITA ADAM , for failure to answer the Complaint. (X) Amount Due $4,001.38 Less Credits $.00 TOTAL $4,001.38 (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 jud ment is to be entered and to his/her Attorney of record,if any, after the default occurred and at as ten days prio he date of the filing of this praecipe and a copy of the notice is attached. Robert N. Polas, Jr., Esquire,#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire,# 312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 11-74202 This communication is fron-i a debt collector is an attempt to collect a debt. Any information obtained will be used for that purl-rosy:. 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. 12-2904 CIVIL V. ANITA ADAM 3620 GOLFVIEW 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$4,001.38. (X)A copy of all documents filed with the Prothonotary in suppor the wi in udgment is/are att By.:; y ------ -------- �i�a51�3 If you have any questions regarding this Notice,please contact filing par Robert N. Polas, Jr., Esquire,#201259- Carrie A. Brown,Esquire,#94055 Mark R. Garvey,Esquire,#312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 11-74202 This communication is firom. a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM(EST) October 18, 2013 ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. ANITA ADAM 12-2904 CIVIL Dear ANITA ADAM: Enclosed herein please find a i 0-Day Notice pursuant to Rule 237.1 of the Pennsylvania. Rules of Civil Procedure. Sincerely, Re Robert N. Polas,Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff 11-74202 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 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. 12-2904 CIVIL V. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant TO: ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 DATE OF NOTICE: October 18,2013 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 Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 Robert N.Polas,Jr., Esquire Carrie A. Brown,Esquire Mark R. Garvey,Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 11-74202 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 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. 12-2904 CIVIL V. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant AFFIRMATION OF NON-MILITARY SERVICE 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 3620 GOLFVIEW 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 Amendments. rl� Rob 6t N. Polas,Jr.,Esquire,#201259 Carrie A. Brown,Esquire, #94055 Mark R. Garvey, Esquire,#312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk,VA 23502 (T) (866)428-8102 (F) (757) 518-0860 11-74202 Attorneys for Plaintiff "his communication is a cleft collector mid is an attempt to collect a debt. Any infior nation obtained will be ttse.d for that purpose, Results as of:Oct-21-2013 02:48:48 SCRA 3.0 Status Report Pursuant to Savicer embers Civil Relief Act Last Name: ADAM First Name: ANITA Middle Name: Active Duty Status As Of: 00-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or hisfher unit has received early notification to report for 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,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 11-74202 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. 12-2904 CIVIL v. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant. PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE -ENTITLED CAUSE AS SETTLED AND SATISFIED. 11-74202 fully Submitted, Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 04 L.Ps3,v/ This communication is from a debt collector and is an attempt to collect a deb '3 (/ S1 Any information obtained will be used for that purpose. 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. 12-2904 CIVIL v. ANITA ADAM 3620 GOLFVIEW DR MECHANICSBURG PA 17050 Defendant. CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle and Satisfy up ANITA ADAM by First Class Mail, Postage Pre -Paid, a copy thereof on this day of 11-74202 , 2014, to: ANITA ADAM 3620 GOL' V EW DR MECHANICS 1' G PA 170 ert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.