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HomeMy WebLinkAbout12-4084Robert 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 r ±Lk 1 C. f- ` t L TEE r R1Y E tl,, 2312 JUN 2 9 AH I C-' r l NO co UN 1. Pat- - 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. MARTHA W LUDWIG 409 S HIGH ST APT 2 MECHANICSBURG PA 17055 Defendant NOTICE No. /2 -//0,0/5/ 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 MAYBE 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. Robert N. 1?olas, 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 L V. MARTHA W LUDWIG 409 S HIGH ST APT 2 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) Bias 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 elate 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 CONSEGUIIZ UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERV ICIOS LEGAL A PERSONAS ELGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association P-Lz a27 73 76 r- -1`1F 1-leis coixi milcation is l?i-c)t't a debt, collector Ertel Is 'zrs attempt to collect ?1 1i"°t>t. \n Hil-6rmation obtained will he LIS4;"d 1'()r that l?rarpose, Court Administrator 3'? South Bedford Street 11 l <?3 d Al Carlisle, PA 17013 e > (717) 249-3166 C ?10 Pennsylvania Lawyer Referral Service (800) 692-7375 / 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. MARTHA W LUDWIG 409 S HIGH ST APT 2 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 MARTHA W LUDWIG, is an adult individual with last known address of 409 S HIGH ST APT 2, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / METRIS on June 8, 2007 with account number ************9949 (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. h14 communication is li•oru a (1011 collector and is an attempt to collect d clcht. ray i? [Orln:ttic?n obtained krill be 1' ?r that purpw 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 September 9, 2010. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / METRIS 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 $3,482.94. 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 respectfiilly requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, MARTHA W LUDWIG, in the amount of $3,482.94, plus costs of this action and any other relief as the Court deems just and r s able. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 12-03465 f'11i,? xornmunic hill Is Erred ; debt collector mild is an attempt to collc°ct `Tly 111f6rmation obtxziiied will be LINCd fcor 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. JUN,I 4 2012 Date : 12-03465 B: ?? -)'?- ary L. Moore 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: 1-866428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************9949 MARTHA W LUDWIG Account Holder: MARTHA W LUDWIG 409 S HIGH ST APT 2 MECHANICSBURG PA 17055 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. / METRIS Portfolio Recovery Associates, LLC ************9949 June 8, 2007 September 9, 2010 December 31, 2010 $3,482.94 June 24, 2011 Balance at Charge-Off: $3,482.94 Less Payments: $.00 Balance Due: $3,482.94 12-03465 HSBL39 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 HSBC BANK NEVADA N.A. / METRIS ("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 June 24, 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 MARTHA W LUDWIG ("Debtor") to the Account Seller the sum of $3,482.94 with the respect to account number (************9949), as of December 31, 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 $3,482.94 as due and owing as of the date of this affidavit. P lio Recovery Associates, LLC B} Mary L. Moore , Custodian of Records JUN 14 Z01Z and sworn to before me on of , 2012 Jason Vita (Vt onwealth of Virginia Nota b"if iC Notary Public ission No. 7509 710 ission Expims 1/31/2015 12-03 5 1 leis c ciminunication is li•oni a debt collector and is an attempt to collect a (Ic;l)t. UlY 1111'Or"I'Al n obtained will he used 16r tlMt purp04c;. ASSIGNMENT AND BILL OF SALE HSBC Sank Nevada, N.A. and HSBC Bank USA, N.A., (hereinafter called "SeW') has entered into a Purchase and Sale Agreement as of May 16, 2011 ("Agr W) for the sale of Accounts and Account Documents described therein to Porio Recovery Associates, LLC, (hereinafter called "Purchaser"), upon the to mid conditions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, a , 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 30*' day of June 2011. HSBC Bank Nevada, N.A. HSBC B SA, N.A. r Signed By: By: David Nauman Title: Vice President NSBL39 l.f s 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 Secondary Charged Off Receivables described in Paragraph 1 thereof to Portfolio Recovery Associates, LLC, (hereinafter called "Purchase"), 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 30th day of June 2011. HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporati USA) IV Signed By: "` By: David Nauman-14 Title: Vice President 14S Bt 39 2 .f 2 Page 1 of 1 DIRECT MERCHANTS BANK Account Statement Account Number 9 November 12, 2010 o ecem r 01D Previous Balance $3,410.48 Credit Limn $2,500.00 Payments - $0.00 Credit Available $0.00 Other Credits - $0.00 Cash Limit V $625.00 Purchases/Debits + $0.00 Cash Available $0.00 Cash Advances + $0.00 Statement Closing Date 12/14!2010 Past Due Amount $662.00 Days in Billing Cycle 32 Fees Charged + $0.00 Interest Charged + $72.46 New Balance $3,4!32.90 -,Cash Limit is a portion of Total Credit Limit New Balance $3,482.94 Minimum Payment Due $770.00 Payment Due Date 01/08!2011 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35. 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 your balance. For example: If you make no additicnN You will pay off the And you will end up charges using this card and balance shown on this paying an estimated each month you pay statement in about total of... Only the minimum payment 18 Years $8169.00 $137.00 3 Years $4918.00 If you would like information about credit counseling services, call 1$66.569-2227. Questions? Payment Address: Payment Center, PO Box 17313, Baltimore, MO 21297.1313 Customer Service: 800.379-7999 Billing Inquiries: Cardmember Services, PO Box 5894, Carol Stream IL Lost/Stolen Card: 800-379.7999 , 60197.5894 Outside USA Collect: 904-997-4997 Manage Your account online at www.AccountCentralOnline.com TOD/Hearing Impaired: 877402-0967 YOUR ACCOUNT IS CURRENTLY CLOSED. AS A REMINDER, YOU MAY PAY YOUR CREDITCARD BILL ONLINE DR THROUGH OUR AUTOMATED PHONE SYSTEM FOR NO FEE. xtst, s ' Trans Date Post Date Description of TransactlonMCreda Reference Number Amount ? • y .. ,I, ?. ?'IISK TOTAL FEESFORTHIS PERIOD $0 00 12114 12/14 Interest Charge on Purchases $37.y5 12!14 12/14 interest Charge on Cash Advances $34.51 Total Fees charged in 2010 $416.08 Total Interest charged in 2010 $811.88 ._ ,tee s 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 Promotional Balance Purchase 23.99% $1,804.43 $37.95 NIA Cash Advances 23.99% $1,641.01 $34.51 NIA (v) =Variable Rate 5991 DOH 1 7 8 101214 104 CX PAGE 1 of 1 10 6800 1500 T089 OICU5994 DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT. SEE REVERSESIDE FOR IMPORTANT INFORMATION 'To avoid additional late and?or ovenimit Account Number: g W feat, you must pay $1,090.94 New Balance 94 (which includes this Minimum Payment Due Minimum Payment Due $770.00• and any Past Due and/or Ovedimit Payment Due Date 0110812011 Amounts). -------- ----- - ------- -- --- Include account number on check to HSBC Card Services. Do not send cash. Please send your payment 7 to 10 days prior to the payment due date to ensure limey delivery. AMOUNT ?"-' C? ? ENCLOSED $ L MARTHA W LUDWIG 914 409 S HIGH STAPT2 MECHANICSBURGPA 17055-6447 PAYMENT CENTER IIIIIII'1??1?'??rIII'III" "II?I????I'??I'?IIIII?II'I'I?'I?I???I PO BOX 17313 BALTIMORE MD 21297-1313 '??III'1???9d11611'III'?'?I'll'?Il?hlll'I?Ilrl"Il?u1lrlllr New Atltlress M Phone Number? Please check tie box W)d order your new information on reverse side 949 What To Do it You Think You Find a Mistake on Your Statement If you think there is an error on your statement, write to us on a separate sheet of paper at the billing inquiries address listed on the front of this billing statement. In your letter, give us the following information: • Account information: Yarr name and account number: • Dollar amount The dollar amount of the suspected error. • Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the errorappeared on your statement. You must notify us of any potential errors in avriting. You may call us, but if you do we are riot required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error, the following are true: • We cannot try to collect the amount in question, or report you as delinquent on that amount. • The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made a mistake, you will not have to pay the arnount in question or any interest or other fees related to that amount. • While you do not have to pay the amount in question, you are responsible for the remainder of your balance. • We can apply any unpaid amount against your credit limit. Your Rights if You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with tihe merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: 1. The purchase must have been made in your hone State or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at the billing inquiries address on the front of this billing statement. While we investigate. the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. How to Avoid Paying Interest on Purchases (Grace Periods on Credit Card Purchases Periodic Interest Charges begin to accrue on the date of the transaction and continue to accrue until your balance is paid ih full. However, if you pay your entire New Balance shown by the Payment Due Date in the previous month, you can pay your current moxhth's New Balance by the Payment Due Date without being assessed an Interest Charge on your purchases. Paying Interest on Other Transactions (No Grace Period on other transactions): There is no Grace Period for other transactions including cash advances, balance transfers. and credit card checks. Periodic Interest Charges begin to accrue on the date of the transaction, and continue to accrue until payment in full is credited to your Account. How We Calcuk to Interest Charges: We calculate the periodic Interest Charge on your Account by multiplying the applicable Daily Periodic Rate by the Average Daily Balance for each category of bansactions shown on you billing statement (e.g., purchases, balance transfers, cash advances); the results are then multiplied by the number of days in the billing cycle. You can determine your Daily Periodic Rate by dividing the APR by 365. Determining the Daily Balance: We take the beginning balance for each category of transactions each day, add any new transactions, any previous day's periodic Interest Charges, any assessed fees and charges, and subtract any payments and/or credits. If your Account is subject to a grace period during the billing cycle, payments made during that cycle will be subtracted from all Daily Balances in the current cycle. If a transaction for a returned payment or a dispute resolved in our favor posts after the beginning of the billing cycle, the applicable Daily Balance(s) and any related Interest Charge calculations will be adjusted retroactively to include the transaction amount as of the date of the original transaction. 9 2010 Caro services Inc Calculating the Balance Subda to Interest Rate For each transaction category, we add all the divide e Daily Bnces for the billing cycle together and e bl lincycleThis is the Average th total by the number 4 in th Daily ance (nuding new pses) method. Annual Percentage Rate: lt your Account has a variable rate, your Annual Percentage Rate may vary . Penalty APR: Your APRs may increase to the Penalty APR if you fail to make a minimum payment to us when due. If your Account becomes subject to the Penalty APR, we will provide advance notice before tie new Penalty APR goes into effect. If you make the next six consecutive minimum payments once the Penalty APR goes into effect, your rates will return to the non- penalty APRs applicable to your Account. If you do not make these six consecutive minimum payments, we may keep the Penalty APR on your Account indefinitely. Foreign Transaction Fee: A 3% Foreign Transaction Fee will be assessed on the U.S. dollar amount on transactions made in a foreign currency. Card Renewal Annual Fee: An Annual Fee may apply to your Account. If your Annual Fee is billed annually, you can avoid paying the fee if you call and close your Account within 30 days of being billed. You may continue to use your Card during the 30 day period without paying the fee. If your fee is billed monthly., when you call and close your Account due to the Annual Fee charge, that month's fee will be credited back to your Account. About Your Payment: You agree to pay at least the Minimum Payment Due in time to be credited to your Account as of the Payment Due Date. You may pay more than the Minimum Payment Due, and you may pay the entire New Balance at any time. Payments should be mailed with a single coupon to the payment address shown on the front of this billing statement. Payments must be made by a single check or money order payable in U.S. dollars and drawn on a U.S. Institution. Payments may also be made using our optional payment by phone or ailine services using the phone number or Web address listed on the front of this billing statement. Payments received on any day at the payment address shown on the front by 5:00 p.m. in the time zone of such payment address will be credited to your Account as of the date of receipt. Payments submitted by phone or online by 5:00 p.m. Pack Time will be credited to your Account as of the date of receipt. All payments received after 5:00 p.m. of the time zone indicated will be credited the next day. A processing fee may apply to agent assisted phone payments. Crediting payments to your Account may be delayed up to, five days I the payment is not made as described above, or, is not mailed to and received at the address provided for remittance; is not accompanied by the payment coupon; is received in an envelope other than the envelope provided fa remittance; is stapled, folded, or paper clipped; or includes multiple payment coupons or checks. Requests for credit balance refunds should be mailed to the inquiry address shown of the front of your billing statement. By sending us a check for payment on your Account, you authorize us to make a one time dnitrock funds transfer ffT) from yourbank account or to process the payment as a check transaction. When we use information from your check to make an EFT, funds may be withdrawn from your account as soon as the same day we receive you payment, and you will not receive your check back from your financial institution. If you do not want your checks to be converted to an EFT, please call customer service at the phone number on the back of your card. Payment by Phone: When you use our optional payment by phone service, yen authorize us to initiate an electronic funds transfer from your designated bank account or to process the payment as a check transaction. You must authorize the amount and timing of each payment. Please retain this authorization for your records. Hearing Impaired: If you are hearing impaired, call Telecommunications Devices for the Deaf (TDD/ TTY) at the phone number listed on the front of this billing statement. Negative Credit Bureau Reporting: We may report information about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected in your credit report. If any specific information related to your Account, transactions or credit experience with us is inaccurate, you may notify us and request us to correct the inaccurate information (after confirmation of the alleged error) reported to any credit reporting agency by writing to us at P.O. Box 5253, Carol Stream, IL 60197-5253. Debt Collection: We are required by law, if applicable, to notify you that we are attempting to collect a debt, and any information obtained will be used for that purpose. 01 CU5994 - 4 - 01/19/11 To ensure accuracy, please print neatly using uppercase letters and numbers only! If you've filled in a new address and/or phone number, be sure to check the box on the reverse side of this payment coupon. Change of address form. Street Number (r arty) Street Name or the -is "PO Do,, LAN or PO Box Number 0EI[= ?? AI?y?r? Er?rr- I?y[]=?r ?El Ci????LJU??1L.J??JL_J??J?J???? S[aZ Email Address H I?' p?7? 'y-?? -T? MFIM7EUC1000?0000?mm?DJ Horne Pnor,e (Pr mary) Work Phone (Primary) 000/000-110DE-1 Nbbi18 Pnone Work Phone (Secondary) =/E11__10-00= ?O/OCIO-ODEC] Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 711- OF'rt F. r'HG'"ERIF Portfolio Recovery Associates, LLC vs. Martha W. Ludwig L " -? Pty 12: 5 CUMBCt"1!~AND Chi t ! PLC.'hNSYLVANIA Case Numbi 2012-4084 SHERIFF'S RETURN OF SERVICE 07/30/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 30, 2012 at 0 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Martha W. Ludwig. After several attempts the Complaint and Notice has expired. SHERIFF COST: $58.00 July 30, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c1 countysuite ShenN.. Teleosoft, Inc. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Attorney ID #94055/201259 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff ~'~ i ~i ; ZOtZ AU6 2$ AP4 IQ~ ;~Q ~UM6ER,~q~ CU~NTY PEMIVS YLV,~M1A 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. MARTHA W LUDWIG 409 S HIGH ST APT 2 MECHANICSBURG PA 17055 Defendant No. 12-4084 PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respectfull Submitted, 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 12-03465 This letter 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. Polar Jr, Esquire Attorney ID # 94055/201259 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attomeys 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. 12-4084 v. MARTHA W LUDWIG 409 S HIGH ST APT 2 MECHANICSBURG PA 17055 . Defendant . CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dismiss upon MARTHA W LUDWIG, First Class Mail, Postage Pre-Paid, a copy thereof on this ~ day of , 24~to: MARTHA W LUDWIG 409 S HIGH ST APT 2, MECHANICSBURG PA 17055 %.. Date: Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, #20125 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 12-03465 This letter is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.