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Home My WebLink About12-4323Robert 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 rlr -VANIA 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. CHELSEA LENGEL 1134 NEWVILLE RD CARLISLE PA 17013 Defendant rflE PRO T O E nTqR 'Y 1112 JUL 12 All 1o= Sp NOTICE No. civil y 3 I p? ? JO` You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action wihing 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 WI 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. a??+ 109 -6(Q a??g? 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 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. CHELSEA LENGEL 1134 NEWVILLE RD CARLISLE PA 17013 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 us 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 PROVEE] INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSON, 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 f'his coninrunication is fironl a debt collector am is an at:tenipt to collect a Jcbt. Arrv intor-rnation obtained Will be rIsecl f6r 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. CHELSEA LENGEL 1134 NEWVILLE RD CARLISLE PA 17013 Defendant COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant CHELSEA LENGEL, is an adult individual with last known address of 1134 NEWVILLE RD, CARLISLE PA 17013. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL-MART on November 19, 2007 with account number ************9570 (hereafter referred to as "Accour. 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. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. " hi connnrinication is fro n. a cleft collector and is an attempt to collect it klcbt. Any in6ortrtation oblAitte(i Will be Used for tlWt PL1q)ose. 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 i Account. The last payment made on this Account was on April 18, 2011. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / WAL-MART 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 $2,737.32. 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, CHELSEA LENGEL, in the other relief as the Court deems just and reasonable. 32, plus costs of this action and Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 12-13470 This cr>mmLinication is from a debt collector and is an attempt to collect a debt. nY in 6ri- nation obtained will be USW 601- that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry E. Whital= nereby 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 Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 1 Pa. C.S. Section 4904, relating to unsworn falsification to Date JUN 2 9 2012 12-13470 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. nr\n'rrllT r/% TT/lllI ITiiII . -- - - - AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Larry E. Whitaker , 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 poi cies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This a idavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account As ignee's records, including a review of the business records transferred to Account Assignee from GE CAPITAL RETA14 BANK / WAL-MART ("Account Seller"), which have become a part of and have integrated into Account Assignee's bu iness 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 November 30, 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 se ement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no furthe 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 CHELSEA LENGEL ("Debtor") t the Account Seller the sum of $2,737.32 with the respect to account number (************9570), as of November 0, 2011 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of a sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or set( occurring subsequent to the date of sale, Account Assignee claims the sum of $2,737.32 as due and owing as of i this affidavit. Portfolio By: and sworn to before me on Not Public 1? 12-13470 of Records J UPI 29 2012 2012 Jason Vita Cornm"Malth of Virginia Notary public Commission No. 7509710 My Commission Expires 1/31/2015 date of Th?iS COMMLill icatioil is froin a debt collector and. is an attempt to collect a debt. '\ny iili«rnation obtained ? ill be used for that purpose. (?6c1V61 0 GE Money Bal nk BILL of SALE PRA 120-dav Mid Prime - November 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on November 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) / /7 By: If 148A //X L43, ' rl Title: CAA- S( I? Retailer Credit Services ?'In/Ic By: 16jk Title: President General Electric Capital Corporation By: Title: Vice President Ord 19 =C_ No GE Money Ba? k BILL of SALE PRA 120-day Mid Prime - November 2011 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated the 20th day of December 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (collectively "Seller") and Portfolio Recovery Associates, LLC (Buyer'), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on November 19, 2011, and as further described in the Agreement. GE Money Bank (Now GE Capital Retail Bank) By: Title: CFO Retailer Credit Services Inc By: Title: President General l?Electriicc Capital Corporation By: 4uu-I 4 ` T Title: Vice President O&ON01 . I &A to SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson a.' j `E Sheriff THE { Jody S Smith Chief Deputy 2012 JUL 23 AM 8: 31 Richard W Stewart CUMBERLAND COUNT` Solicitor PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Numbe Chelsea Lengel 2012-4323 SHERIFF'S RETURN OF SERVICE 07/16/2012 03:15 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Jul 16 2012 at 1515 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chelsea Lengel, by making known unto herself personally, at 1134 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. iJ HALL, ITE- PLITY SHERIFF COST: $34.00 July 17, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF