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Home My WebLink About12-4083,Robert 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 J N 0 TA R",/ JUN 2 9 AM to: t CUMI LAND AC ".CC.OUNTY cyrrsPORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 ASSOCIATES, LLC No. /a?- ?Og3 ?Jw V. Plaintiff VALERIE RHONE 513 E LOCUST ST MECHANICSBURG PA 17055 Defendant 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 3:?_ South Bedford Street 0--s Carlisle, PA 17013 03. r7s/oo%4 j (717) 249-3166 Pennsylvania Lawyer Referral Service C. (800) 692-7375 - 772 7 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for 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. VALERIE RHONE 513 E 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 1NFORMACION 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 T'ris ColY1111umcati{art is ffinI Ll debt collector drtd is all attempi to collect a ?hwl?7t? 1n i it 6rl7:ztion obtained w ilI lie u-,: i for drat 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. VALERIE RHONE 513 E 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. Defendant VALERIE RHONE, is an adult individual with last known address of 513 E LOCUST ST, MECHANICSBURG PA 1705.5. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / UNION TRUST on September 27, 2007 with account number ************8658 (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 i- coT11lT1Lill" C"Itioll is tion-la debt collector and i_s W1 allempt to collect =.1 dc,t, rte- Hil'onnation obtailied vJ11 be LiQcci list- 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 July 5, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / UNION TRUST 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 $824.52. 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, VALERIE RHONE, in the amount of $824.52, plus costs of this action and any other relief as the Court deems just and reasonable. 7 Robert N. Polas Jr., Esquire # 201259--- Carrie A. Brown, Esquire # 94055 11-99711 Fhi:.: cofnmumcAion is froin a debt collector aildl is an attempt to collect a debt, 'Any Information ohtaii od will be ?iscd [or 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 unworn falsification to authorities. Date : _ 14 2912 gy L%? J ` Mary L. Moore Custodian of Records 11-99711 This communication is from a debt collector and is an attempt to collect a debt. Any infonnation 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: ************8658 VALERIE RHONE Account Holder: VALERIE RHONE 513 E LOCUST ST MECHANICSBURG PA 17055 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA N.A. / UNION TRUST Assignee: Portfolio Recovery Associates, LLC Account Number: ************8658 Date Account Opened: September 27, 2007 Date of Last Payment: July 5, 2010 Date of Charge Off: October 30, 2010 Balance at Purchase: $824.52 Purchase Date: April 25, 2011 Balance at Charge-Off: $824.52 Less Payments: $.00 Balance Due: $824.52 11-99711 HSBK92 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 , 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 HSBC BANK NEVADA N.A. / UNION TRUST ("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 April 25, 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 VALERIE RHONE ("Debtor") to the Account Seller the sum of $824.52 with the respect to account number (************8658), as of October 30, 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 $824.52 as due and owing as of the date of this affidavit. 0 olio Reco Associates, LLC Maly L. oore Custodian of Records JUN 14 2012 and sworn to before me on of , 2012 Jason Vita N t lic taamf®r?womith of Virginia Notary Public ` Commission No. 7509"110 1 I 9711 My Commission Expires 1131!2015 I .. 1is c;oniinuiZic ation i ; from a debt collector and is to attempt to collect a dc(it. nv: ili1i)rfnmon obtained will be used l?or that s 0 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 February 7, 2011 ("Agreement") for the sale of Secondary 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 Secondary 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 18th day of April 2011. HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporation (USA) IV Signed By: By. Paul Stanborou9h Title: Senior Vice President H50K 9 z UNITE HERE MASTERCARD VALERIE RHONE F-1 rC UNITE HERE MasterCard Account Statement Account Number Page I of 2 From September 7 201 to to 010658 Previous Balance Payments Otter Credits PmehasesDebits Balance Transfers Cash Advances Past Due Amount Fees Charged Interest Charged S782.62 - $0.00 _ $000 $0.00 - $0.00 - $0.00 $329.81 - $25,00 $16.90 New Balance _ $824.52 Credit Limit $500.00 Credit Available $0.00 Cash Limit t $125.00 Cash Available $0.00 Statement Closing Date October 8, 2010 Days in Billing Cycle 31 tCash Limit is a portion of Total Credit Limit. Questions? 24-Hour Customer Service 1-800-622-2580 Lost or Stolen Card 1-800-651-5116 Outside USA Collect 1-702-243-1575 TDD1Hearing Impaired 1-800-395-9020 New Balance $824.52 Minimum Payment Due $380.81 Payment Due Date November 2, 2010 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee from $15.00 to $39.00 and your APRs may be increased to the Penalty APR of 24.99%. Minimum Payment Warning: if you make only the minimum payment each period., you will pay more in interest and it will take you longer to pay off yon balance. For example: If you make no additional charges using this card and each month you pay... You will pay off the balance shown on this statement in about... And you will end up paying ! an estimated total of.. . Ottly the minimum 4 Years $1.112 Payment $33 3 'Years $1,180 (Savings =-568) If you would like information about credit counseling services call 1-866-569-2227. Payment Address: UNION PLUS Credit Card, PO Box 5222, Carol Stream, IL 60197-5222 Billing Inquiries: UNION PLUS Credit Card, PO Box 80027, Salinas, CA 93912 -0027 Manage Your account online at www.unionpluseard.com As a reminder, you may pay your credit card bill online or through our automated phone system for no fee. Trans Date Post Date Description of Transaction or Credit Trans Date Post Date Description of Fees 10/02(10 10/02/10 LATE CHARGE ASSESSMENT Total Fees For This Period Description of Interest Charge INTEREST CHARGE ON CASH ADVANCES INTEREST CHARGE ON PURCHASES INTEREST CHARGE ON BALANCE TRANSFERS Total Interest For This Period Amount $0.00 $16.90 $0.00 $16.90 D-h and M- boftan portion -dh Poet p -I 010103 5 I 07 0000003000 C STMT57 D E UNPL00HA D0Du EMB) 7IX 33959 UPI See reverse sine fa important in o ofion TT __-________._________________________-.________-______-____-_______________--____-_._______________________________-_________ utum Account Number 658 JJ New Balance $824.52 Minimum Payment Due $380.81 Payment Due Date 11/0212010 include account number on check to UNION PLUS Credit Card. Do not send cash. Please send yoturpayment 7 to 10 days prior to the payment dune date to ensure timely delivery. 010 AMOUNT ENCLOSED UNION PLUS CREDIT CARD VALERIE RHONE PO BOX 5222 8606 CROSS CREEK RD CAROL STREAM IL 60195222 POLK CITY FL 338682603 idIP4pBigliulpi11111114h?hd16dllglaliiullliilm I I d i l l II i d dl i i h dll I I I Purchase Type Reference Number Amount Reference Number Amount 10000030000000999943250 $25.00 $2-5.00 658 UNITE HERE MASTERCARD VALERIE RHONE UNITE HERE MasterCard Account Statement Account Number 5480.4200-3265-8658 Page 2 of 2 From Septelnber 7, 2010 to October 8 2010 Total fees charged in 2010 $238.95 Total interest charged in 2010 $118.59 Your Annual Percentage Rate (APR) is the annual interest rate on your account. Type of Balance Annual Percentage Rate (APR) Balance Subject to interest Rate Interest Charge PURCHASES 10001 24.99% $796.37 $16.90 CASH ADVANCES 20001 19.99% $0.00 S0.00 BALANCE TRANSFER 21.99% $0.00 S0.00 41111 -Variable Rate UnionDebtHelp.org is an information resource for union families concerned about managing debt wisely. The site features debt assessment calculators; credit education and tips; and inspirational stories from fellow union members who found help when they needed it. Plus, get information about Union Phis programs that could provide help to those already facing debt issues. UnionDebdielp.org was created with all levels of credit questions or concerns in [Hind. Visit today and get on your way to being a more credit savvy union member. Offered through Union Privilege. Protect the drivers in your household with roadside assistance you can afford The Union Phis Motor Club costs less than AAA and offers 24-7 nationwide roadside service for a family at only $5.40 a month. And as a boron, sign up for a new fill]-year membership at only $64.80 and receive. a set of gas vouchers worth $40. Call 1-800-454-8722 or visit UnionPhis.org;/MotorClub for details and to sign up. Offered through Union Privilege. 010103 51 07 0000033000 G STMT57 D E UNPLOOBA3JDOOMASXXXX 33859 UPI ------------------------------ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Starart solicitor 4100P Ot Icumbe"44# A OFFICE G' , 74E SKERIFF FILED-OFF ICU ;-jam pRCTFiONOTARY 2 12 jut 3o AM 9.03 CUFIBERLAW COUNTY ?Zj4NSYLyAN1A Portfolio Recovery Associates, LLC Case Number vs. 2012-4083 Valerie Rhone SHERIFFS RETURN OF SERE 07/2512012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made diligent sea h and inquiry for the within named defendant to wit: Valerie Rhone, but was unable to ioct her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the tvaleria Rhone. Request for service at 513 E. Locust Street, Mechanics , Pennsylvania 1 the Ewe t was not found. Deputies were advised the current resident has reside at this address for the plant two months and does not know the Defendant. The Mechanicsburg Postmaster has confirmed Valerie Rh ne has moved and left no forwarding address. SHERIFF COST: $43.00 July 25, 2012 (c) CountySude Sheriff, Teleosoft, Inc. SO ANSWERS, 6z 4 WON R ANDI y ,_ Carrie A. Brown, Esquire ~, ~ r"~ f -~`~ ~,~~ ~ t" ~' 1G ~:~ Robert N. Polas Jr, Esquire N~~(J ~'~~~ ~j: Attorney ID #94055/201259 ~Q~Z Portfolio Recovery Associates, LLC ~U~ ~~ Q~ ~Q: ~$ 120 CorpoA 23502 ~~~~'~'~~~~~fl Cp Norfolk, pl~VNS YI.V~~fi~' Attorne 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 v. VALERIE RHONE 513 E LOCUST ST MECHANICSBURG PA 17055 Defendant No. 12 4083 PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respectfull ubmitted, Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #201259 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F)(757) 518-0860 Attorneys for Plaintiff 11-99711 This letter is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. _- - T Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Attorney ID #94055/201259 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 4083 v. VALERIE RHONE 513 E LOCUST ST MECHANICSBURG PA 17055 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dismiss upon VALERIE RHONE, by F~st~Class Mail,~ ,,//~~ Postage Pre-Paid, a copy thereof on this ~Z day of ~,~?`~'~" , 28"~,'to: VALERIE RHONE 513 E LOCUST ST, MECHANICSBURG PA 17055 Date: 11-99711 Came A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #2012: Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This letter is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.