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Home My WebLink About12-4322Robert 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 Attnmevs for Plaintiff FILED-OFFICE Or THE PROTHONOTARY 2012 JUL 12 AM 10: 4 5 RL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. RICK PARDO 2863 RUSSELL RD CAMP HELL PA 17011 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. Civil 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 WIT H 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 _7C ? Q 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: 1-866428-8102 FAX: 757-518-0860 AttnrnPVC fnr 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. RICK PARDO 2863 RUSSELL RD CAMP HILL PA 17011 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda pue en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Dema y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando escrito con la Corte sus defensas o obejciones a las demandas puestas en esate contra usted. usted es adver que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o al solicitado por Demandante. usted puede perder dinero o propiedad o otros derechos importante para u, USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFIC PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A 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 ["Ols communication is from a cleft collector and is an attempt to collect ?1 olei` L Ariv in. innnation obtained Will be Used ?f'or 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 Attnmevs 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. RICK PARDO 2863 RUSSELL RD CAMP HILL PA 17011 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. Defendant RICK PARDO, is an adult individual with last known address of 2863 RUSSELL CAMP HILL PA 17011. It is averred that Defendant was indebted to CHASE BANK USA N.A. / HERITAGE BANK on October 7, 2007 with account number ************1137 (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 Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. ThIS is lnnaLill ication is fro n a cleft collector Und is aia attempt to collect ?I debt, ll be cIse(l [')I' tlaGat hu a5e.. gray int6rination ?ahta1.necl 1 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 February 28, 2010. Plaintiff is the purchaser, assignee and/or successor in interest CHASE BANK USA N.A. / HERITAGE BANK ONE 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 $7,306.83. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of 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 and against Defendant, RICK PARDO, in the amount of $7 306.83, plus costs of relief as the Court deems just and reasonable. c Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 12-13773 and any This comillLill ication is from a debt collector and is kin attempt to collect zi debt. any int'ri-nation obtained will be used R-11- that purl)ose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry E. Whitaker hereby states that he/she is authorized to take this verification on behalf of Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date : 29 + By: of Records 12-13773 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: 1-7571518-0860 Statement of Account Account: ************1137 RICK PARDO Account Holder: RICK PARDO 2863 RUSSELL RD CAMP HILL PA 17011 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase: Purchase Date: Balance at Charge-Off- Less Payments: Balance Due: 12-13773 CHSK36 Product Code: VISA CHASE BANK USA N.A. / HERITAGE BANK ONE Portfolio Recovery Associates, LLC ************1137 October 7, 2007 February 28, 2010 August 31, 2010 $7,306.83 February 16, 2011 $7,306.83 $.00 $7,306.83 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. Larry E. Whitaker I, the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is do g business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the poll ies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This a !davit 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 CHASE BANK USA N.A. / HERITAGE BANK ONE ("Account Seller"), which have become a part of and have integrated into Account A signee'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, d 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 February 16, 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 set ement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no furthell 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 th ordinary course of business by the Account Assignee, there was due and payable from RICK PARDO ("Debtor") to the count Seller the sum of $7,306.83 with the respect to account number (************1137), as of August 31, 2010 wi h 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 $7,306.83 as due and owing as of he date of this affidavit. Portfolio By: // Larry h: Wh1taWustodian of Records and swom to before me on J UN 4 9 2012 2012 Not y ublic Jason Mts Commonwealth of Virginia Notary Public 12-137 Commission No. 7509710 T1. My Commission Expires 1/3112015 This COMMLill icat] on is from a cleft collector and is an attempt to collect a debt. Anv intbrination obtained will be ulsed for that purpose. SHERIFF'S OFFICE OF CUM13 RLAND COUNTY Ronny Sheriff R Anderson Fik-0-Off YA Jody S Smith +„?,± •t Curr?? z ?? Chief Deputy 9' 02 Rich ?0 aM Solicitor W rt gFFtCE OF THE "RIFF Portfolio Recovery Associates, LLC VS. Rick Pardo Case Numb) 2012-4322 SHERIFF'S RETURN OF SERVICE 07/18/2012 08:47 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, stapes th on Juty 18, 2012 at 2047 hours, he served a true copy of the within Complaint and Notice, upon the in named defendant, to wit: Rids Pardo, by making known unto himself personally, at 2863 RusseN oard, Camp Cumberland County, Pennsylvania 17011 its contents and at the same time handing to hi personally said true and correct copy of the same. SHERIFF COST: $43.00 July 23, 2012 SO A.N-SEWERS, /? X• (r (c) CountySuite Shenft, Teleosoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 °. PLAINTIFF G —; ACV � :T,,:_ vs. NO. 12-4322 CIVIL Z�' G-3 t?: —t RICK PARDO CD 2863 RUSSELL RD ,e - —,- CAMP HILL PA 17011 DEFENDANT(S) ��Fy PRAECIPE FOR WRIT OF EXECUTION -MONEY JUDGMENTS ,; t ` TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Direct to the Sheriff of CUMBERLAND County,PA; (2) against RICK PARDO Defendant(s); (3) and against BELCO COMMUNITY CU Garnishee(s); (4) And index this writ (A) against RICK PARDO Defendant(s) (B) and against BELCO COMMUNITY CU Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the garnishee(s). Specifically describe the property per attached property description. All accounts including but not limited to all savings,checking and other accounts,certi cates of eposit,notes re eivab s,collateral, pledges,documents of title,securities,coupons and safe deposit boxes. (5) Amount Due: $7,306.83 Signature/ID Number Interest From December 26,2012: $163.35 Robert N.Polas,Jr.,Esq.#201259 (At an interest rate of 6% per year) Print Name Total: $7,470.18 Plus costs& interest Carrie A.Brown,Esq.#94055 (Total includes post judgment credits) 120 Corporate Blvd Address agso /y Norfolk,VA 23502 3. oo C,�r �U 3, Z5' ICn• Sl� << ., aa5 �� 12-13773 of-Iff 3 350 f*aqu �� This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-4322 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC Plaintiff(s) From RICK PARDO,2863 RUSSELL ROAD,CAMP HILL,PA 17011 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: BELCO COMMUNITY CU,5304 CARLISLE PIKE,MECHANICSBURG,PA 17050 and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$7,306.83 Plaintiff Paid$ Interest FROM DECEMBER 26,2012-$163.35(AT AN INTEREST RATE OF 6%PER YEAR) Attorney's Comm. % Law Library$.50 Attorney Paid$191.75 Due Prothonotary$2.25 Other Costs$ Date: AUGUST 20, 2013 1 J ) David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name : ROBERT N.POLAS,JR.,ESQUIRE Address: 5425 ROBIN HOOD ROAD,SUITE 201 NORFOLK,VA 23513 Attorney for: PLAINTIFF Telephone: 1-866-428-8102 Supreme Court ID No.201259 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _ i",�.�0�'CF F I�: �.: Jody S Smith `# I` Chief Deputy 1 10- 3 Richard W Stewart Solicitor OFFICE V ,f E .�ER!cg CUMBERLAND C0€ TY PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number VS. 2012-4322 Rick Pardo SHERIFF'S RETURN OF-SERVICE 0812612013 01:45 PM-William Cline, Deputy,who being duly swom according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, BELCO Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Emily Garofalo, Branch Manager, personally three copies of interrogatories together with.three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 27,201'�,to Rick Pardo at 2863 Russell Road, Camp Hill, PA 17011. 4VIKIAM CLINE, DEPUTY SO ANSWERS, August 27,2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teieosoff,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES,LLC • No. 12-4322 CIVIL Plaintiff • c.1 r VS. -C3 rr't rf RICK PARDO • • cam' ry cam; Defendant • J.-, `' VS. C BELCO COMMUNITY CU • Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the writ of attachment filed against the Garnishee only in the above-entitled matter, without prejudice. Robert N. Polas, Jr., Esquire#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff $9.sd?c.C_ Ct( 963 5 12-13773g� This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. All IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC . 120 CORPORATE BLVD No. 12-4322 CIVIL NORFOLK,VA 23502 Plaintiff vs. RICK PARDO •• 2863 RUSSELL RD CAMP HILL PA 17011 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dissolve ttachment u n RICK PARDO and,by First Class Mail, Postage Pre-Paid, a copy thereof on thil ) day of , 2013,to: RICK PARDO BELCO COMMUNITY CU 2863 RUSSELL RD 5304 CA0• f LE PIKE CAMP HILL PA 17011 ME P,.�,I BURG,P : 0 Date: 'obert N. Polas, Jr., Esquire#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 12-13773 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY r2onny R Anderson Sheriff 0s r 4thai •pr�tb !; ? i bbl: Jody S Smith ::. 2014 HA -4 PM 2: 2`r°. Chief Deputy ' Richard W Stewart CUMBERLAND CQU' Pf Solicitor -'`P - PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Rick Pardo 2012-4322 SHERIFF'S RETURN OF SERVICE 08/26/2013 01:45 PM- William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, BELCO Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Emily Garofalo, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 27, 2013 to Rick Pardo at 2863 Russell Road, Camp Hill, PA 17011. 03/03/2014 Ronny R. Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $94.33 SO ANSWERS, March 03, 2014 RON R ANDERSON, SHERIFF - SI) G -pd '!i 9sas4' .3& %'-is- ii .