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Home My WebLink About12-3443Robert N. Polas, Jr., Esquire PA Bar # 201259 Came A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC - 140 Corporate Blvd. Norfolk, VA 23502 '*, r 1 . 1 TELE: 1-866428-8102 ; . i ' ' FAX: 757-518-0860 0 ?, Attorneys for' Plaintiff P1l???t??? 1 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. I D - ?N3 G Vi I V. SARA GREENBERG 833 ACRI RD MECHANICSBURG PA 17050 Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must tape 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 S' ,? ?1b3° ?SPa °` ?I This communication is from a debt collector and is an attempt to collect a debt. C? ?-? c17p S Any information obtained will be used for that purpose. y2?a7sq?3 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. SARA GREENBERG 833 ACRI RD MECHANICSBURG PA 17050 Defendant NOTICIA USTED HA ISIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguie4tes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es sejrvido, 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 elate contra usted. usted es advertido que si falla dje 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 pot Demandante. usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DE13E LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADOI: 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 INFORMAC,ION 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 communication is from a debt collector and is an attempt to collect a debt. An.v inlorination obtained will be used (or that purpose. 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. SARA GREENBERG 833 ACRI RD 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 SARA GREENBERG, is an adult individual with last known address of 833 ACRI RD, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / THE GAP on April 30, 20102 with account number ************5175 (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. This communication is from a debt collector and is an attempt to collect a debt. .any inforrn.at_ion obtained will be used 6or that purpose. 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 May 13, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / THE GAP 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 $1,232.70. 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, SARA GREENBERG, in the amount of $1,232.70, 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 11-82195 This coxr1aLill ication is from a debt collector and is an attempt to collect a debt. Ariv information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mary L. Moore 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 : APP $ 0 2012 '--- By. ) mar Dore Custodian of Records 11-82195 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 : ****'********5175 SARA GREENBERG Account Holder: SARA GREENBERG 833 ACRI RD MECHANICSBURG PA 17050 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / THE GAP Assignee: Portfolio Recovery Associates, LLC Account Number: ************5175 Date Account Opened: April 30, 2002 Date of Last Payment: May 13, 2010 Date of Charge Off December 24, 2010 Balance at Purchase: $1,232.70 Purchase Date: October 28, 2011 Balance at Charge-Off- $1,232.70 Less Payments: $.00 Balance Due: $1,232.70 11-82195 GECM68 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, Mary L. MOOre 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 GE CAPITAL RETAIL BANK / THE GAP ("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 October 28, 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, comprorhise, 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 SARA GREENBERG ("Debtor") to the Account Seller the sum of $1,232.70 with the respect to account number (************5175), as of December 24, 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 $1,232.70 as due and owing as of the date of this affidavit. P lio Recovery Associates, LLC I ) ?, -4 /yA 4-?- ) B A_ O_: re , Custodian of Records APR 8 0 2012 to before me on of \ . 2012 11 -11 V Notary-Public gyiesha N. King Commonwealth of Vlrgirna 11-82195 Notary Public Commission c).7509711 +my Commission Expires 0513112015 "T"his comnltmication is froin a debt collector and is an attempt to collect a debt. Any information obtained will be used for that lxu-pose. BILL of SALE GE Money Bank PRA 120-day Mid Prime - October 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on October 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) 1 By: 4-1? - Title: Manager Finance Retailer Credit Services Inc By: Title: President General Electric Capital Corporation By: Title: Vice President I&ECM 68 1 •F 4 GE Money Bank BILL of SALE PRA 120-day Mid Prime - October 2011 For value received and in further consideration of the mutual covenants and conditions set forth inl the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Iic, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates; LLC (`Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on October 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) By: Title: CFO Retailer Credit Services Inc By: Title: President General Electric Capital Corporation By: 1 --1 " ??L Title: Vice President (76CM64? 2,0-F 2- d SHERIFF'S OFFICE OF CUMBERLAND COU 19 '`Y Ronny R Anderson Sheriff -- ?``? r/,T'rv Jody S Smith Chief Deputy Richard W Stewart , Solicitor Portfolio Recovery Associates, LLC vs. Case Number Sara Greenberg 2012-3443 SHERIFF'S RETURN OF SERVICE 06/01/2012 03:43 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 1, 2012 at 1543 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sara Greenberg, by making known unto Susan Greenberg, Mother of Defendant at 833 Acri Road, 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. iAH CLINE, DEP SHERIFF COST: $38.00 June 06, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF .,O13:^;• J 1'EE bhE'r ( TE. ?DtT. [eC Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC y �'�IE ;1O'N0 TA 120 Corporate Blvd 2013 AUG 20 11: 22 Norfolk,VA 23502 Attorneys for Plaintiff uU� C�i� n ly�r ;tf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. 12-3443 CIVIL Plaintiff V. SARA GREENBERG 833 ACRI RD MECHANICSBURG PA 17050 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. Res ect y s mitted, Rob rt N. Polas, Jr., Esquire PA Bar#201259 / Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar# 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff 11-82195 This communication 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 Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC 120 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 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 12-3443 CIVIL V. SARA GREENBERG 833 ACRI RD MECHANICSBURG PA 17050 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discoqtir= and End n SARA GREENBERG, by First Class Mail, Postage Pre-Paid, a copy thereof on this day of , 2013, to: SARA GREENBE G 833 ACRI RD, MECHANIC RG PA 17050 / obert N. Polas, Jr., Esquire PA Bar#20125 Carne Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 11-82195 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 this purpose.