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Home My WebLink About12-3490Rabert 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 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 No. Plaintiff V. THOMAS J STRICKLE 5217 E TRIINDLE RD ' „- MECHANICSBURG PA 17050 l .' Defendant +< 77 _r NOTICE - c 3 - 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. QS C.L 110 Cpl i?Sas/ / ?164b 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. THOMAS J STRICKLE 5217 E TRINDLE RD MECHANICSBURG PA 17050 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguiedtes 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 cue 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 A.BOGADO, 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 I'liis communication is from a debt collector and is an attempt to collect a debt:. :Any in fionnation obtaitied will be used tor that purpose. Rdbert 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. THOMAS J STRICKLE 5217 E TRINDLE RD MECHANICSBURG PA 17050 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. Defendant THOMAS J STRICKLE, is an adult individual with last known address of 5217 E TRINDLE RD, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to HSBC BANK NEVADA. N.A. / AMERITECH / NON PRIME on November 28, 2006 with account number ************0245 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A.11 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. This communication is frorn a debt collector and is <ur attempt to collect a debt. Any in-f-orination obtained will be used ("Or that purliose. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 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 December 22, 2008. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / AMERITECH / NON PRIME 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 $1,166.46. 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, THOMAS J STRICKLE, in the amount of $1,166.46, 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 11-73436 TMs coinn1LITlication is From a debt collector and is azi attempt to collect a debt. Anv information obtaiiied will be used (or that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, 4M L. Monre 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 : _ MAY 10 2017 ?4 cp-) By? Mary Moore Custodian of Records 11-73436 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: ************0245 THOMAS J STRICKLE Account Holder: THOMAS J STRICKLE 5217 E TRINDLE RD 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: Product Code: MC HSBC BANK NEVADA N.A. / AMERITECH /NON PRIME Portfolio Recovery Associates, LLC ************0245 November 28, 2006 December 22, 2008 July 31, 2009 $1,166.46 January 26, 2010 Balance at Charge-Off: $1,166.46 Less Payments: $.00 Balance Due: $1,166.46 11-73436 HSBH26 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, Matt' L. Moore , 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. / AMERITECH / NON PRIME ("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 January 26, 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 THOMAS J STRICKLE ("Debtor") to the Account Seller the sum of $1,166.46 with the respect to account number (************0245), as of July 31, 2009 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 $1,166.46 as due and owing as of the date of this affidavit. folio Recovery Associates, LLC Nc/ G-- y: Mary L. Mborc , Custodian of Records Subscribed and s ern to before me on MAof 1 2012 , 2012 Notary Public 11-73436 iem"aAsA r?sweU Commonwea?th of Virginia Notary Public commission No. 7509732 My ?Orttnission Expires 1113012015 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. RILL OF SALE HSBC CARD SERVICES (III) INC. (f/k/a HOUSEHOLD CARD SERVICES INC.) ("Seller'), for value received and pursuant to the terms and conditions of the Receivables Purchase A t ("A a t'l did October 26, 2009 between Seiler and HSBC CARD SERVICES (III) INC. and Polio Recovery Associates, LLC, ("Purchaser"), does hereby sell, assign and convey to Purchaser, its suet sor and assigns, all right, title and interest of Seller in and to thud ceftin Powhased Receivaab (as defined in the Agreement) listed on the attached ..aMbit A ( Fi ), without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Agreement. EXECUTED this 29`" day of January, 2010. HSBC CARD SERVICES (III) INC. By: Name: Title: Vice Pros' Assistant Secret HSBC BANK NEVADA N.A. By: Name: Susan Sol n Title: Senior Vice President 11CA N26i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith r Chief Deputy -- Richard W Stewart = Solicitor F=e = ? - r' R Portfolio Recovery Associates, LLC Case Number vs. Thomas J. Strickle 2012-3490 SHERIFF'S RETURN OF SERVICE 06/11/2012 10:30 AM - Jason Vioral, Sergeant, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2012 at 1030 hours, he served a true copy of the within Complaint and Notice upon the within named defendant, to wit: Thomas J. Strickle, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. JASO IO L, DEPUTY SHERIFF COST: $38.00 June 12, 2012 _(:X .. ------- RONR ANDERSON, SHERIFF