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HomeMy WebLinkAbout12-3491Robert N. Polag, 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. 6,, L Plaintiff -. r., , MCC, ANTHONY R STILES c{ , . 313 W SHADY LN -° . ENOLA PA 17025 - Defendant = E - . . , NOTICE 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 S Carlisle, PA 17013 ' (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 C44' 1291,97 /rr&q3 This communication is from a debt collector and is an attempt to collect a debt. - =,6 r7 Any information obtained will be used for that purpose. h? 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. ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 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 communication is from a debt collector and is an att nipt to collect a debt. Afiv infonnation. obtained will be used f?ot 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. : ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 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 ANTHONY R STILES, is an adult individual with last known address of 313 W SHADY LN, ENOLA PA 17025. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / BEST BUY / MBNA OR S&H GREENPOINTS on August 26, 2008 with account number ************9402 (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. This C0111rI7unication is from a debt collector and is aii attempt to collect a debt. Anv inl'onnation obtained will be Lised for dWt purpose. 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. 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 20, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / BEST BUY / MBNA OR S&H GREENPOINTS 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 $1,023.46. 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, ANTHONY R STILES, in the amount of $1,023.46, 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 11-73733 " hIS colnnLill ication is from a debt collector and is all atterript to collect zi t cast. Any irrfonnation obtained will he cased 601- that pclq ose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, MMryL Mnnre 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 MAY 10 2012 Mal y Mnore Custodian of Records 11-73733 This communication is from a debt 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, MM 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 RiversideCommerce 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. / BEST BUY / MBNA OR S&H GREENPOINTS ("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 22, 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 ANTHONY R STILES ("Debtor") to the Account Seller the sum of $1,023.46 with the respect to account number (************9402), as of June 30, 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 $1,023.46 as due and owing as of the date of this affidavit. Portfolio Recovery Associates, LLC (),2 cr ? Mary Moore , Custodian of Records Subscribed and syorn to before me on MAY 0 2012 1 2012 Notary Public eamada An Gil Bfil"ll ean+mam a ? of Yir9lnla 11-73733 Notary Public Commission No. 7509792 My Commission Expires 1113012015 This communication is from a debt collector and is an attempt to collect a debt. any intormation 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: ************9402 ANTHONY R STILES Account Holder: ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA N.A. / BEST BUY / MBNA OR S&H GREENPOINTS Assignee: Portfolio Recovery Associates, LLC Account Number: ************9402 Date Account Opened: August 26, 2008 Date of Last Payment: October 20, 2010 Date of Charge Off. June 30, 2011 Balance at Purchase: $1,023.46 Purchase Date: July 22, 2011 Balance at Charge-Off: $1,023.46 Less Payments: $.00 Balance Due: $1,023.46 11-73733 HSBL69 This communication is from a collector and is an attempt to collect a debt. Any information obtained will be used for 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 22"d day of July, 2011. HSBC Bank Nevada, N.A. HSBC Ba USA, N.A. Signed By: By: David Nauman Title: Vice President 11r"QJ/10 ) " 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 SelleelIs 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 22nd day of July, 2011. HSBC Receivables Acquisition Company 1, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporati . SA) IV Signed By:? By: David Nauman Title: Vice President RS94449 2 * 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY;= a Ronny R Anderson Sheriff ?. Jody S Smith co Chief Deputy Richard W Stewart -` Solicitor Portfolio Recovery Associates, LLC vs. Case Number Anthony R. Stiles 2012-3491 SHERIFF'S RETURN OF SERVICE 06/07/2012 03:50 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2012 at 1550 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Anthony R. Stiles, by making known unto Nancy Simpson, adult in charge at 313 W. Shady Lane, Apartment F, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $43.00 June 08, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF C Cou+i' , ?? „r, ~ II-Ea-Q~ FfC ,,: .~ 1ic ~i20 i ~~ONf?TA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW ~~~~ ~~~ `ZD ~~{ ~ ~ ~ I E PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff v. ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 Date: Defendant ~b i ~-2 No. 2012-3491 ~~- ~'FN~dSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Filed on Behalf of Plaintj' Co~e'~ of record for tl~s Robert N. Polas, Jr., Esquire # 201259 ~---- Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This comt~lunicatiai~i is fro~In a debt collector is an attempt to collect a debt. .Any infoi-~natian <:~btained. Will be used :far that purpose. 1~U~ ~- , Sv ~ Q Q~~ ~~99 9 ~ a?9S~0D 'No`d ~ ~YI~I.~ IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Plaintiff No. 2012-3491 v. . ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, ANTHONY R STILES ,for failure to answer the Complaint. (X) Amount Due $1,023.46 Less Credits $.00 TOTAL $1,023.46 (X) (X) (X) Date: 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. Pursuant to PA.R.C.F.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. Pursuant to Pa.R.C.P.231.1, Icertify that a written notice of intention to file mailed or delivered to the party against whom judg is to be entered a record, if any, after the default occurred and at le t to days prior to the at praecipe and a copy of the notice is attached. ~ ~aecipe was Sher Attorney of e filing of this Robert N. Polas, Jr., Esquire # 20125 Carrie A. Brown, Esquire, #94055 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 fro~ti~ a debt collector is an attempt to collect a debt. AIIy itrfarlxl~tion obtained. will. be used :for that 17rupose. 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. 2012-3491 v. ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 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 $1,023.46, plus interest, on . (X) A copy of all documents filed with the Prothonota If you have any questions regarding this Notice, please Date: _ ~ e1 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 is an attempt to collect a debt. Any information obtained. will be used :for that pulpase. Robert N. Poles, Jr., Esquire # 201259-- Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC . 120 Corporate Blvd Norfolk, VA 23502 No. 2012-3491 Plaintiff v. ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 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 313 W SHADY LN ENOLA PA 17025 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. Date: Robert N. Polas, Jr., Esquire, #201259 ""- Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F)(757)518-0860 Attorneys for Plaintiff 11-73733 This communication is a debt collector and is an attempt to collect a debt. An.y infornlatiou abtai.necl will be used for that purpose. De rtment of Defense Man R°'~"'°"~'°''1°10'°~" pa power Data Center scru zs-r '~~ p111'tt7YtR~ ~ ~tGEtIiC1~~fC'1'lt CiV11)~1l~Ef ACt Last Name: STILES First Name: ANTHONY R Active Duty Status As Of: Jul-03-2012 .ewc wt awt or xaw we tsr ar yr ~ ~„~ a, yaw. ai tlnear. Merawa ow w~ w an riw..ye~.. r~ s.. mast. wow e+Maw e.w a, e~. ~m~.. pq tww bw 4A Morn Oh'Ya'M YMllwillG4'111fb+Wr_ - - ~ ran. oq a.n or ~ awr er tom. er. s~.,~. ~+r~~ tLl tM NO' tLl ltd~nayorrr eslleea ufwn Ow NkN6aM Na WM duy rOAe wsain 9e7 bgsgsalWq ar Atew WY MN n. uwn.. c~H.w wwrr~aNNr/w+w,Crtala oete.~.tw~w o.r< oew ~~ ~. ow. o y. wrrr~ w or. sr„ a.~w c„w,w„ "" ru ~ rm ru r~rmpmMSrMk1. t~aMrrawexr~ami«tpNwumk~naF~dwynoMtorXOnbnpanwr.aweA~ Upon serdrnp the data Aardro of rile Deparanent a[ tlefaree Manpower Data Center, Fated on tl» intamedon d+atyou pravfdad, fhe abew is the statue of fhe lndhridual on tM active duty stator date as to aN btarxktes ~ ttM Uniformed Servicsa (Army, Navy, Marine Caps. Air Pone, NOAA, PuDNo Health, tnd Coast Ouardi. This ttaun includeslnform~ion on a 3ervkemsmbar or hblhar unit fecefWrg nodtkMion of future orde's to report for Active Duty. Mary M. Snavely-Dixon, Director DapeMnent of Detenae -Manpower Date Center 4800 Metk Carper DrNe, Stah fME25 ~~'235a This cainmunicatian is a debt calleetar and is an attempt to called a debt. ,~.ny information abtai.ned will be used :far that purpose. This communication is a debt collector and is an attempt to collect a debt. An.y information obtained ~;vil.l be used Far that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 140 Corporate Boulevard Norfolk, VA 23502 Telephone: (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) June 29, 2012 ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 11-73733 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. ANTHONY R STILES 2012-3491 Dear ANTHONY R STILES: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Rules of Civil Procedure. Sincerely, Robert N. Polas, Jr., Esquire Carne A. Brown, Esquire Attorney ID# 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA Attorneys for Plaintiff ~~;~. This carrununication is from a debt collector is an attempt to collect a debt. .Any information obtained will be used far that purpose. 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. 2012-3491 v. ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 Defendant TO: ANTHONY R STILES 313 W SHADY LN ENOLA PA 17025 DATE OF NOTICE: June 29, 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 C OTHER Il~IPORTANT 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 Rdbdit~N")~olas,'Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff "Phis communication is froat~ a debt collector is an attempt to collect a debt. Any information obtained will be used fo~~ that purpose,