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HomeMy WebLinkAbout12-4671Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 1LEO-Or"r 1CIE Portfolio Recovery Associates, LLC T; I FIR E Q ; ; ;i TAR'( 140 Corporate Blvd. Norfolk, VA 23502 ? 1 g 1i!' 26 AM 11: 44 TELE: 1-866428-8102 FAX: 757-518-0860 1.'UMBERLAND COUNTY Attorneys for Plaintiff Pti-N N S Y LVA N I A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. tq'q v 6'1A 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 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. 3.7s?d A 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. JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043 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, V AYA 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 i.i?is colltmuraicatioll is from a deli( collector and is an atletnht to collw ") debt, Aiiv inlOnnat%ori obtaitieti kill be used I'M that purposc. 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. JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043 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 JOAN M DOMINIANI, is an adult individual with last known address of 352 MARKET ST FL 2, LEMOYNE PA 17043. 1 It is averred that Defendant was indebted to CHASE BANK USA N.A. / HERITAGE BANK ONE on September 9, 2005 with account number ************6046 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A.11 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. `1111, COM111unication is 1iotn a debt collector and is an attempt to cotlect a debt. i iv int01-mation obtained will be USCd tZw that purpose. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 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 January 3, 2010. 8. 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." 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 $21,257.67. 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, JOAN M DOMINIANI, in the amount of $21,257.67, plus costs of this action and any other relief as the Court deems just and reasonable. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 12-15676 CO Mr Ullication i:-, €rom a debt collector aril is aai attempt to coHect a debt. Airy it 601-mation ob1W11Cd W111 bC LISCd.1 t0l' drat l)url10SC. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry J. Andrews 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. Date : a _ .1 lu JUIII IV 11 12-15676 By Ldity U. Andrew 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: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************6046 JOAN M DOMINIANI Account Holder: JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043 Consumer Account Issuer: Assignee: Account Number: Date Account Opened: Date of Last Payment: Date of Charge Off: Balance at Purchase: Purchase Date: Product Code: VISA CHASE BANK USA N.A. / HERITAGE BANK ONE Portfolio Recovery Associates, LLC ************6046 September 9, 2005 January 3, 2010 August 31, 2010 $21,257.67 February 16, 2011 Balance at Charge-Off: $21,257.67 Less Payments: $.00 Balance Due: $21,257.67 12-15676 CHSK36 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, Larry S. Andrews 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 CHASE BANK USA N.A. / HERITAGE BANK ONE ("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 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 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 JOAN M DOMINIANI ("Debtor") to the Account Seller the sum of $21,257.67 with the respect to account number (************6046), as of August 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 $21,257.67 as due and owing as of the date of this affidavit. folio Recovery Associates, By: ustodian of Recai'ds N 2.5 loll ?U Subscribed and sworn to before me on 12-15676 of , 2012 l Lucretia Ann Etheridge Commonwealth of Virginia Notary Public Commlaslon No. 7042513 My Commbolon EVIrm 613012014 ill C01MI iz6L160[l is lr4?Jn <I debt ccjil :ctc r and i4 an attempt to collect 4 clcl t. \n-v in6orniation obtalne(l will lie used for dint purpo,,e. o??.,, n* n„o r1a.r, \'?.1 on'P„ e easr Dje A-cur _ . ' M;nrmum °aymer.r 09114/10 $21,257.6)7 0 1 $1,850.00 111 I r $5,635.00 ? 111 _ _ __ _ Account number: 6046 Make your check Payable to: Chase Card Services. Please.vnfe amount encosed New address or e-rnail? Print on owl , 046 47093 EEX 222910 D Irf.IIlr II I It LL tl It 16u111still /11lilt 11111.1 111 111 JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043-1632 CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 I..,Ilf?rrlllrfrflrrltril1711111ll rrrtllrrrlrl,lflrrrlrlrllrrl 6046 . CHASE O ® Manage your account online: Additional contact information www.chase.corn redifcards conveniently located on reverse side ACCOUNT SUMMARY Account Number 6046 Previous Balance Fees Charged $20,685.18 +$39.00 Interest Charged +$533.49 New Balance $21,257.67 Opening/Closing Date 07118/10 - 08/17/10 Total Credit Line $17,600 Available Credit $0 Cash Access Line $3,520 Available for Cash $0 PAYMENT INFORMATION New Balance $21,257.67 Payment Due Date 09114/10 Minimum Payment Due $5,635.00 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 $39.00 and your APR's will be subject to increase to a maximum Penalty APR of 29.99%. 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 your balance. For example: If you make no You will pay off the And you will end up additional charges balance shown on paying an estimated using this card and this statement in total of... each month you about... pay... Only the minimum 41 years $73,570 payment $907 3 years $32,637 (Savings=$40,933) If you would like information about credit counseling services, call 1-866-797-2885. The outstanding balance on your credit card account is scheduled to be written off as a bad debt shortly. As a result, your credit bureau will be updated with a negative rating that could last for up to seven years. We can still help, but you need to call us now at 1-888-792-7547 (Collect 1-302-594-8200)- Important Message: You Are Overlimit! Your statement balance exceeds your credit line. You should make a payment that includes the ovedimit amount to bring the balance under your credit line. This account is dosed and not available for new transactions. If there is a balance please continue to make payments by the due date. CASH PLUS REWARDS SUMMARY 71 Previous Points Balance 0 Thank you for using the credit card that earns Points Earned at Gas, Grocery & Drug Stores 0 rewards that can be used for your choice of gift Points Earned on Other Purchases 0 cards, cash or statement credits. Remember, Points Earned from Chase Rewards Plus 0 you can cam points by using your Cash Plus Points Redeemed This Period 0 credit card for your everyday purchases like Current Points Total 0 gas and grocery purchases. Your Chase Cash Plus credit card allows you to earn 5 points for every eligible $1 you spend on gas, grocery and drug store purchases and 1 point on all other eligible purchases. Earn additional points by shopping online through www.chase.com/rewardsplus, adding authorized users, and signing up to have your monthly bills charged to your card. Why not get pants for all those purchases too? Redeem your points anytime, or just check out new offers at www.chase.oem/rewards. ACCOUNT ACTIVITY Date of Transaction Merchant Name or Transaction Description $ Amount a - y -' _..Y,.' :..tk......?...51.:..: r '... Rff4&....,! .. _. ,..... .i4 ', ul i, LYS (§.... ' ` ? ?t?. 08/15 LATE FEE 39.00 TOTAL FEES FOR THIS PERIOD $39.00 u8i17 PURCHASE INTEREST CHARGE 309.39 08/17 CASH ADVANCE INTEREST CHARGE 224.10 TOTAL INTEREST FOR THIS PERIOD $533.49 This Statement is a Facsimile - Not an original 0000001 FIS33338 D 5 000 N Z 17 10108117 Page 1 of 2 05888 MAMA 47093 22910000050004709301 J,' 0294 Address Change Request Please provide information below only if the address information on front is incorrect. Street Address: -_-_---.---------------- City: -------- State: - Zip: - Home Phone: --- --- - - - - Work Phone: - E-mail Address: ------ -- --- - - - - -- ----- --- --- - To service and manage any of your account{s), we, our representatives, JPMorgan Chase representatives, and/or affiliates, may contact you at any telephone number you provide to us. Please refer to your Cardmember Agreement for additional details about the use of your personal information L arld/or visit our website shown below to provide us with additional contact information. To contact us regarding your account: By Telephone: ® In U.S. 1-800-945-2000 ' e 2 JYU Espanol 1-888-446.3308 Send Inquiries to: Mail Payments to: TOD 1-800-955-8060 Visb Our Website: Pay by phone 1.800436.7958 P.O. Box 15298 P.O. Box 15153 yr y c_ha_com/creditcards Outside U.S. call collect Wilmington, DE 19850-5298 Wilmington, DE 19886-5153 1-302-594-8200 information About Your Account Cretlfllag of Faymeds: You may make payments by ani of me options listed delew. Tire amo , of of your payment should be al least you mis Drum payment due, payable in t S. del:acs and drawn or isayab;e through a h,9. Wandell trial toth n or the 11.5. err-ncn cf a fnreign f lemejal insuhmon. 'too may make payments by mgulat U s- mall. seed your payment to the. Payments address show" ou this salemeM. your Payments by mail must comply w.'h the instructions on ills statement De rmt writ cash. Write Your Account pointer on your oheEk o, money order. Payments must be accompanied ay toe payment coupon in the envelope provided with our address visible Ihmui h me envelope vandOw; the envelope cannot contain more than one payment Or coupon: and there can be o0 ,rani paper clps, tape or correspondence Incuded rulm your payment D your payment is in eCGOrdaace wh{l our payment'dSffuCCAi1send is made avanat a to Its i4 any ray by 5:00 tiro. I[a ll tune at cur Faynta;rt5 address an this slafemenL wm will moot 1"e payment h; your Accc ut as of spat day if your payment is in. accordmu:e elm nu- baymcnl iosl%cbmi but is matte avallable to its after 5: Do p. m. local time at the Payments address on this staleru n, we ii cmdd it to your Account as of the not calendar day. YOU may make daymeotseledforl ilylindgbcurwebsuesbowmonthisstatement. V we receive year completed feateSl on cor wehshe III p m. Laster , Time, we, will c edit your barman! as of that day. if we receive your raoaest after 5 p in Fastern Time, we v: i'I credit your payment as of the pax: calonda• day. f you specify a future date in VOLt regccst we will credit your payment as of dud day For all ur.ar payments or for any paymentrype above not styli- you do of-al:ow cur payment instructions, crediting of your payments may be celayed'or up to 5 days. Account IMmmatlam Repotted to CredN 8anatle We navy lepdrl information about ymr Account to uedlt bureaus. Late payments, rnissa ulibmwms or other defaults an your Appoint nay be retfected im your credit report, it fall mink we have mf ored In alurale into, nation to a credit biretta, you may -16 It us at the'ne ovies address shown on :his statement To Service and Manage Jury of Your Acaoont(ak We cur repmenclalhms, JPMorgan Cnasp reprranat-is and/or affiliates, may canact yea at any mlephenn number y'or Vallee to os. Please ni W your Cludntemhu Adopt w1 for adatlonal dames tapes the use o' ycur pef sonal information. Notice About Eteelrnnts Check Coraimbin: When you „vy by check, you authorize us either to tae mtbrmatldn from your Check 10 make a One-time aP,elmn,a turd Iran3ler from your account or Id process aid payment as a check Vanarroa e. W1em we use olon-!al an hour your cheM 10 make ar vlectroni c fund transfer, funds may fin withdrawn fron, your account as as., as the sad:: ay we eceive your revival, ;and loo wil nor •eceive your Vii tack from your lirtmPal metituliorr. Call the Cus!emM Service camber on urns salarnem it you iota questions about thecponic check collection or do hat want your payments collected a ecfronioalFy CPIdiffonel Payments: Any payment check o' Dri form at caymans that you send us for less Ilan the full hfu21C dale drat is marked -paid in tuh° or cements a similar rotation, an :hat yuu others, se lender rn full selisractic, of a disuuted amount. ri on sent to Card services, P0. Box 15619, Warrington. DE 191 Wo serve au mar rights regarding these payments {a.g., r it h din em irrad there Is no ,,alto dispute or if dry such check's relieved at any, odar address. we may accept the stuck no pot, will still owe any romemyota 6atarapi We Itay'e!dse id accept any s,ich payment by returning a to you, pal eastd'g it er destroying 1. Al short payments that you make s1101110 be Sent to the regular Payment address shown on this statement. Annual Renewal Notice: it your Account Agraemort has a 1 annual merloersrip tee anduorsimilar c-:age fa Issuance a attain at yolarcnwt, hwill he billed each year or In monlily or quavery instel:mtems This fee Moiler charge are owed la ether Jr tadt yaD ase, qar Account, and you agree to pay them Mier boiled. The aitnaal fee arm charge are non refundan'e IiMes9 you aptly is [hid you wish to close year account with :130 days of one hithllg eye a (ahiehever is less) after we provide -tae statement on oni she annul fee or charge 5 billed art at the same ame, you pay vour outstanding be Onto In full P you do this, for a mbar,'[, bated and, otter Iran annually "Dort as a monthly service charge, you two rot eve the last allied ordrge; however, prior Whip charges are !wit-rvlundab:a elo must be paid as all or paying your ontchinding haWcce In I'll. Your pay!nant of the a:lord fee or charge does not Fifert I'll ,ighcs In cbae your ACerw and to limit you- right -D Make tmnsaofiri on MII Account II ycur AWOUni Is GOSeC py yon yd us, w0 a19 CGftinue r0 impose the annual tee andror odarge undl you pay valor oulsland'mg bahuCe in full aid terminate your Ali relationship Cakulatron pt Balance Sab)ect to Mternt Hate To hgae your periodic interest charges for each tiding cycle vdlen a daily pere is rile(s) :applies, we use the daily haance ,nettled including current harmadices). To figul i your penal interest charge for each hil'.Ing cycle when a will periodic ralets) applies, we use ire "ali,ga daily paancer method (Including current haapsabaion;). For an exptaoahen of aline, method, w sueshols abpm a Dartk.ular itAwest charge calculi lmt on your statelunl. Please call (s at the roll lope Cdstomef fan') to Phi number listed above. We catculals periodic intamst charges. using the applicable periodic rates shown on in 5 statement seParatey for each'eeture (a. g_ palaces transfer checks and cash advanes checks ("check Vansuc'lipd'), purchai "use l;:l fels, rosin advances, promohomi halances or overdra8 advances) -m- ralenlatbrre nay Combine different Gatagoreas with Ow same periodic rates. Varwlue Islas will vary with toff market based on the Prime Rate for such index described in Your Account Agreasibrol There is a mmirrum interest anarrie 0ii;or such antrum described in your Account Agreamen) in airy bi:lord cycle in which gau awe any de,106tc I=,termet charges, and a transaction tee for each car Its transfer, cash adval,ce, or check hansacOmt in ore amuUnls sated ul you, Account Agreenood, as !I !nay be reoded. There is a foreign iTiosachom fee cf !t% of the If $. dollar a:imam of ani foreign transact: on or such amoum desc bed in your Account Agreement). Pow to Owed Paying Interest on purchases. We begin assessing periodic interest charges on a transaction, tee, Or interest charge from the data it is added to your dairy baance unlit your Aacounl is paid m IA, as des:kPOed th your Accon rl Agreement. Your due dale will be a rnininum of 21 days following that close of each tenting eych. You can avail per 'odic interest charges en new othetures when may am firs- brled to a statement as described tallow. but Sus does rut apply to balance Dar stars, cash advances or overdralt advarces. if you receives current mortthm statumem that !rolkii new prldheri and make a payment that" reeewe by it. date and time the Minimum Pavment is due'or that statement, vac will not charge penedic interest on any Doi of those new purchases that we allocate Such payment to, sal long as 1) ycur current statement else an- that we received payment of lire end ng hasare for your prev:pps morl statement by me date and Its, is Minmum Payment was are OR 21 mat the antl'mg balance for ya'ar previous month's Sha em&N was zero. It you have a balance atnsr loan a pirdass balance and mat balance anus a higher periodic merest rate. you may not be able to avcid periods: interest cnazges an new purchases if you do not pay your balance in full earn month, because we generally allocate payments prat to Ile balance with the filthiest pcirki interest rate. What To 0o R You Think You Find A Atildi On Your Wfinneat I you think there is an error or your stalanlad, write to us or a separate sheet at Customer Services P.O. Box 15299 Wilmington, DE 1985Di '.n ydbr IetteC give us the fokuwlng lolirmatiom • Accord lrformatOn. Your name and Account number • DOIk'r ame i 'no Collar amount of the scratched sure • Description Of Proohem'. It You think Caere i5 an end On y0pr bill, therenre what you believe is wrong ant, why you believe it is a mistake. You must contact us worm 60 dart alter it. nom appeared on your s lours t You must nOniy us of airy 110111 ewers it, vinfing. You may call ui our f you do 'we are not retuned Io imesbgdle any opientol errors and you may Nye to pay the amount in auestion. While we investigate whether or rut there as heart an i the fnitowing are tine. • We cannot try to coupt the amoum m spostrion Cr fepOff you as delirpueM can that am0uns • The dirge is gacstort may remain can. your 51a(ement, erect wm dry ccrlUlue to merge you :Merest on that amount But. '.f we eeiermine mat wa made a mistake, you vAh not have to pay Ble amount in okeslion or any lrete•est or tire, tees rotated 10 Bad am", • Wrdle you do nor 111 10 Pay Ine amount In question, yod P.M. responsible Pot the ten'aitWp u1 your balance. • We wit apply any unpaid amount against you ctedrt'.ima, Year Rights If You Are Dissatisfied With Year Credit Cad Purehaaa it yqJ are dissatlsfird with me goods or serVicas final you taus purchased with your credit ard, and you have !rsd Ill good fall to earned ifat problem will the ns,re^allt, you may have tie right not to pay the remaining anal, dim on Yre aurchasa. TO Ja tit! s dill, all cal tree tollovnng .,at hetrue 1 The purchase must have been made in your tromp state or within 100 miles of your cu:4ant willing adcress, and dW purchase after mast lave been more than S50. (Nate: ke8her of Thiess We tlecessary l your porchaso was based On an adveniserrcent we mailed to you, an River own the company mm saki you the goods or services.) 2. vau must have used your cro It card for me purchase. Pumhases made with ash advances from an ATM or with a check ther recesses your cradle raid account do not cualfy. 3. You pus: nol yat hatre faly paid for the humanism If ail of lire crhar!a above are met and you are said dfssaan pad will no purchase, m^tccl n ion writing at Customer Sari PO. Pqx 15799 Wlm ogivon, DF 19850-5299: W.'IIIe, we investigate, the same rules apply to the d aduled amoose as discussed above. After we finish cur imreringalion, we will let you our decision. At their point l we think you owe or amoum eat ycu do not pay wannary 'court you as ill! Indolent. NIA5292010 Statement Date: 07/18110 - 08117/10 Account Number: 1111WO46 of 2 Year-lo-date totals reflect all charges minus any refunds appted to your account on or after January 31, 2010. 2010 Tgtals Year-to-Date Total fees charged in 2010 $31200 Total interest charged in 2010 $3,370.95 INTEREST CHARGES Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Balance Percentage Rate (APR) Balance Subject To Accrued Type 31 Days In Cycle Interest Rate Interest Charges Interest Purchases 29.99% (v) Cash Advances $12,147.29 $309.39 Charges 00 $0 29.99% (v) Balance transfer 29 99% (v) $8,798.63 $224.10 . $0 00 . $0.00 $0.00 $000 (v) = Variable Rate Please see Information About Your Account section for the Calculation of Balance Subject to Inter t R t A How to Avoid Interest on Purchases, and other import ant information, as applicable. es a e, nnua l Renewal Notice, This Statement is a Facsimile - Not an original X 0000001 FIS333W n 5 000 N Z 17 10/08/17 Pegs 2 Of 2 0.5888 MAMA 47093 229100000.50004708302 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ;y K r HE' PRO., T[04t) Jody S Smith Chief Deputy Richard W Stewart Solicitor :t.? _. 2012 SEP -6 AM 10: 14 "UMBE LANU €>t?UNT', PE-aSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Joan M. Dominiani 2012-4671 SHERIFF'S RETURN OF SERVICE 08/28/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 28, 2012 at 121$ hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joan M Dominiani. After six attempts Deputies were unable to find anyone at the residence of 352 Market Street, Floor 2, Lemoyne, Pennsylvania 17043 before the Complaint and Notice expired. SHERIFF COST: $60.00 SO ANSWERS, ,-/ August 28, 2012 RON R ANDERSON, SHERIFF ru^tySuite She:•'f, Tal?sFt Ir.- Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Attorney ID # 94055/201259 Portfolio Recovery Associates, LLC 120 Corporate Blvd ~ ~, ,_ -~ ~ ' ` ~ Norfolk, VA 23502 't Attorneys for Plaintiff r~.-~r ~~'- ~~ ~/,, ~,,~ r 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. JOAN M DOMINIANI 352 MARKET ST FL 2 LEMOYNE PA 17043 Defendant No. 12-4671 CIVIL PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. 12-15676 Respectfully Submitted, ,y ~r ~~~ Carrie .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 This letter is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.