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Home My WebLink About12-4094Robert 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 Attornevs for Plaintiff 7 HE PRO TtiONb 28t2 JUN 29 ply l : 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW A PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. LOUISE G WHITE 724 KENT DR MECHANICSBURG PA 17050 Defendant NOTICE No. 12, - el?,Z 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 G?' 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 V- F e? ??'as 8? a 773,- ? 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. LOUISE G WHITE 724 KENT DR MECHANICSBURG PA 17050 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 so] icitado 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 31is CO nn Uniczrtit n is from a debt collector and is au atiempt to collect _ 't. env Hitoniiation obtained Will l-)e Ll-:c:d ]csr ghat 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. : LOUISE G WHITE 724 KENT DR 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 LOUISE G WHITE, is an adult individual with last known address of 724 KENT DR, MECHANICSBURG PA 17050. It is averred that Defendant was indebted to HSBC BANK NEVADA N.A. / AMERITECH on December 9, 2006 with account number ************2280 (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`1ri; co>inmwitcation is from a debt collector Atid is all ailerrlpt to Collect a =1v illtormation obtaaired N ill be , tl i6r 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. 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 16, 2010. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA N.A. / AMERITECH 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 $2,895.78. 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, LOUISE G WHITE, in the amount of $2,895.78, plus costs of this action and any other relief as the Court deems just and reason le. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-99517 Pi IS, musiicatioii is from a debt collector rid is W1 aitempt to collect a dc-bt obtai ied %011 be pis d icer :bat J)Lirpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mary L. Moopo _ 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. JUN 14 2012 Date : By - MMY L. Moore Custodian of Records 11-99517 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 : ************2280 LOUISE G WHITE Account Holder: LOUISE G WHITE 724 KENT DR MECHANICSBURG PA 17050 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA N.A. / AMERITECH Assignee: Portfolio Recovery Associates, LLC Account Number: ************2280 Date Account Opened: December 9, 2006 Date of Last Payment: October 16, 2010 Date of Charge Off: May 31, 2011 Balance at Purchase: $2,895.78 Purchase Date: June 24, 2011 Balance at Charge-Off: $2,895.78 Less Payments: $.00 Balance Due: $2,895.78 11-99517 HSBL37 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. / AMERITECH ("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 LOUISE G WHITE ("Debtor") to the Account Seller the sum of $2,895.78 with the respect to account number (************2280), as of May 31, 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 $2,895.78 as due and owing as of the date of this affidavit. Po folio Recove Associates, LLC By, Mary L. Moore , Custodian of Records ibed and sworn to before me on 1 F--99517 JUN 14 2012 of 1 2012 Jason Vita Commonwealth of Vlrglnla Notary Public " Commission No. 7509710 My Corr, missior, Expires 1!31/2015 ,I> a,0r1 l"T1Ul11C1'1[1 )11 Is fi'or[2 a debt c{}ileclor atld 9s d1l 111A 111pt to coiLct a do hl, ?=lz°> lti, i it obt?lil-ied will be used for drat PLI1' )OSC, ASSIGNMENT AND BILL OF SALE HSBC Bank Nevada, N.A. and HSBC Bank USA, N.A., (hereinafter calked "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, (h6reina#ter caged "Purchase'), upon the terms and condkions set forth in that Agreement. NOW THEREFORE, for good and valuable consideration, Seller hereby sells, ass", and transfers to Purchaser, its successors and assigns, all of Setter's rifts, 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 29th day of June, 2011. HSBC Bank Nevada, N.A. HSBC Bank USA, N.A. Signed By: -? 4::?L . `- By: Devid Nauman Title: Vice President OSBL37 lof Z ASSIGNMENT AND BILL OF SALE HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSOC Receivables Acquisition Corporation (USA) IV ( her, ' et}r caUd "Seller") has entered into a Purchase and Sale Agr as of KUy 16, 2011("A eernent") for the sale of Prime Fresh Chwged Off Receivables described in Paragraph 1 thereof to Portfolio Recovery Associates, LLC, (her ' er called "Purchase"), upon the terms and conditions set forth in AW . NOW THEREFORE, for good and valuable consideration, Seller hereby se=lls, assess, and transfers to Purchaser, its successors and assigns, all of Seller's 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 29th day of June, 2011. HSBC Receivables Acquisition Company I, HSBC Receivables Acquisition Corporation (USA) III, and HSBC Receivables Acquisition Corporation USA) IV Signed By: By: Davits Nauman Title: Vice President H56Z37 z ort HOUSEHOLD BANK PLATINUM MASTERCARD LOLIISE G WHITE Household Bank Platinum NjastS6ard Accommt Account Number 80 Page 1 of 2 From April 2 2011 Previous Balance $2,844.27 $0 00 . New Balance $2,895.78 Minimum Payment Due $593.00 Payments Other Crediu . - - $0.00 i i Payment Due Date June 19, 2011 Purchases/Debits + $0.00 Balance Transfers + $0.00 f late Payment Waming: If we do not receive your minimum payment by the Cash Advances + $0.00 date listed above, you may have to pay a late fee of tip to $35.00 and your APRs Past Due Amount $512.00 I may be increased to the Penalty APR of 29.99%. Fees Charged + $0.00 1 i Interest Charged + _ $51.51 New Balance $2,895.78 i j Minimum Payment Warning: It you make only the minimum payment each period, you will pay more in interest audit will take you longer to payoff your '.. Credit Limit $1505.00: ;balance. For example: Credit Available $0.00 € Statement Closing Date May 25, 2011 I if you make no additional You will pay off the And you will end up paying Days in Billing Cycle 31 1 charges using this card balance shown on an estimated total of.. and each month you this statement in ''. I pay... about._ i i Only the minimum 18 Years $7.492 `. Payment .. ._._... $109 3Years ($3.936 (5mings = 53,556) If you would like information about credit counseling services call i1-866-569-2227. Questions7 Payment Address: HSBC Card Services, PO Box 1705 L Baltimore. MD 24-Hour Customer Service 1-800-462-2016 21297-1051 Lost or Stolen Card 1-800-3954500 Billing Inquiries: HSBC Card Services. PO Box 81622, Salinas. CA Outside LISA Collect 1-757-523-3880 93912 -1622 TDDiBearing Impaired I-800-395-9020 Manage Your account online at www.househoidbank.com As a reminder, you may pay your credit card bill onlime of through our automated phone system for no fee. Trans Date Post Date Description of Fees Reference Number Amount Description of Interest Charge Amount INTEREST CHARGE ON CASH ADVANCES $0.00 INTEREST CHARGE ON PURCHASES $51.51 INTEREST CHARGE ON BALANCE $0.00 TRANSFERS Total Interest For This Period $51.51 Total fees charged in 2011 $35.00 j Total interest charged in 2011 $243.04 ------------ -- ------------ Your Annual Percentage Rate (APR) is the annual interest rate on your account. D-h vd r. butt- portico wah Your Pxweal. ------------------------------------------------- 090750 5 1 24 ODODOMI03 SrMT06 D 8 12636 nDPi See revere sine for important infomiali rl ------------------------------------------------.--------------------------------------- Account Number 280 New Balance $2,895.78 Minimum Payment Due $593.00 Payment Due Date 06/19/2011 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 timely delivery. 090 AMOLTIT ENCLOSED #BWNHYTS #303015372285# HSBC CARD SERVICES LOUISE G WHITE PO BOX 17051 724 KENT DR BALTIMORE MD 21297-1051 MECHANICSBURG PA 17050.2221 II II I?I?IIII? ?II III?? I? I I I ?? I I I?II?'IIIIIIIIIIIIII?IIIIIII6glll?I??IIII??IJIli6l?llll?6 I I II I ?II ? '??II?II? II I II?I? I ?'I?I'II l?i 00289578000593000005491100015372280000909 HOUSEHOLD BANK PLATINUM MASTERCARD LOUISE G WHITE Household Bank Platinum MasterCard Account Account Number 5491-1000-1537-2280 Page 2 of 2 From April 24, 2011 to May 25, 2011 Type of Balance Annual Percentage Rate (APR) Balance Subject to Interest Rate Interest Charge PURCHASES 00001 19.99% (v) $2,540.27 S4313 PURCHASES 00001 29.99% (v) $328.83 S8"18 CASH ADVANCES 80001 29.99% (v) $0.00 50.00 BALANCE TRANSFER 29.99% (v) $0.00 50.00 71111 v=Variable Rate Online Account Access lets you take control of your Account anytime, anywhere. Registration is easy, secure and waiting for you at go.househoidbank.com. 090750 51 24 0000000103 STMr08 D 8 12836 HDPI SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t; t(}{{'f Jody S Smith Chief Deputy 2012 JUL 12 AM 8: 03 Richard W Stewart Solicitor E- CUMSERLAND COUNTY PENMSYLVANIA Portfolio Recovery Associates, LLC vs. Case Numb Louise G. White 2012-4094 SHERIFF'S RETURN OF SERVICE 07/06/2012 03:49 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on J ly 6, 2012 at 1549 hours, she served a true copy of the within Complaint and Notice, upon the within na ed defendant, to wit: Louise G. White, by making known unto herself personally, at 724 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing t her personally the said true and correct copy of the same. COBALIGH, D SHERIFF COST: $38.00 July 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c:) CcuntySuitF sh.c' r,ff _ Ttaleosoti, ic.. Carrie A. Brown, Esquire Robert N. polas Jr, Esquire Mark R. Garvey, Esquire L Attorney ID # 94055/201259/312686 ;, �r f ,` Portfolio Recovery Associates, LLC 120 Corporate Blvd t ¢ ' � ' Q: Norfolk, VA 23502 CUMBERLAND COURT' Attorneys for Plaintiff PENNS Yl VA NIA 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 4094 Plaintiff v. LOUISE G WHITE 724 KENT DR MECHANICSBURG PA 17050 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. Res.-ct 10 bmitted, 4 .- �► . olas, 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 11-99517 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 4094 v. • LOUISE G WHITE • 724 KENT DR • • MECHANICSBURG PA 17050 • Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Disco ti e and End upon LOUISE G WHITE, by First Class Mail, Postage Pre-Paid, a copy thereof on this day ofU e74 , 2013 to: LOUISE G WHI • 724 KENT DR, MECHANI :>� ' _ PA 17050 `� ► . 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 11-99517 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for this purpose.