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Home My WebLink About12-4676Robert 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: 1-866428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. DENISE D GEORGE 150 S ENOLA DR ENOLA PA 17025 ASSOCIATES, LLC Plaintiff Defendant NOTICE No. Lam' c c' --+ V W Ti 73 ' f. -*7 Cast tz; . Ei t 7 '7 C-3 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 7s dt#Iy307Y 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. DENISE D GEORGE 150 S ENOLA DR ENOLA PA 17025 Defendant NOTICIA LISTED 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. LISTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI LISTED 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 LIN 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?liis comniunication is from a debt collectorand is an atterript to cotlect a del7t:. Any irflionlation. Obtained will be used tier 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. DENISE D GEORGE 150 S ENOLA DR ENOLA PA 17025 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 DENISE D GEORGE, is an adult individual with last known address of 150 S ENOLA DR, ENOLA PA 17025. 3. It is averred that Defendant was indebted to CHASE BANK USA N.A. /DISNEY on January 3, 2008 with account number ************3131 (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. I11T, communication is irom a debt collector and is all atte;tlpt to collect a debt, ,"Nn irdorination obtai.licd will be ctscd 601. that J)LWP SC. 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 September 24, 2009. Plaintiff is the purchaser, assignee and/or successor in interest CHASE BANK USA N.A. / DISNEY 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 $3,926.62. 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, DENISE D GEORGE, in the amount of $3,926.62, 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 12-17793 Ills, c€ ll lllulliczltion is troln a € ebt collector and is an attempt to collect a debt. .env inl6ri-nation obtallICd W111 he €Iscd fir 11Wt h€irpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry i. And rew--;? - 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 : ., 1.6 ?t113 12-17793 By: ndxews 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 : ************3131 DENISE D GEORGE Account Holder: DENISE D GEORGE 150 S ENOLA DR ENOLA PA 17025 Consumer Account Product Code: VISA Issuer: CHASE BANK USA N.A. / DISNEY Assignee: Portfolio Recovery Associates, LLC Account Number: ************3131 Date Account Opened: January 3, 2008 Date of Last Payment: September 24, 2009 Date of Charge Off: March 31, 2010 Balance at Purchase: $3,926.62 Purchase Date: April 26, 2011 Balance at Charge-Off: $3,926.62 Less Payments: $-00 Balance Due: $3,926.62 12-17793 CHSK93 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, (tarry I Andrews , 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 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. / DISNEY ("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 April 26, 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 DENISE D GEORGE ("Debtor") to the Account Seller the sum of $3,926.62 with the respect to account number (************3131), as of March 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 $3,926.62 as due and owing as of the date of this affidavit. Portfolio ecovery Associates, LLC 1 odian of Records Subscribed and sworn to before me on _ of JUN 15 ,02 NQta*-?'Public Lucretia Ann Etheridge Commonwealth of Virginia 12-17793 Notary Public Commission No. 7042513 My Commission Expires 9!30!2014 I his ?._:>n-lmunication is from a debt collector- rind is an attempt to collect ;a €.Icbt. ?Ily Int6rinal'on obtained will tae used ir)r that purpose, CHASE O BILL OF SALE Chase Bank USA, N.A. ("Seller"), for value received and pursuant to the terms and conditions of Credit Card Account Purchase Agreement dated December 10, 2010. between Chase Bank USA, N.A. ("Seller") and Portfolio Recovery Associates, LLC ("Purchaser"), its successors and assigns ("Credit Card Account Purchase Agreement"), hereby assigns effective as of the File Creation Date of April 20, 2011 all rights, title and interest of Seller in and to those certain receivables, judgments or evidences of debt described in Exhibit 1 attached hereto and made part hereof for all purposes. Amounts due to Seller by Purchaser in hereunder shall be paid U.S. Dollars by a wire transfer to be received by Seller on (the "Closing Date") April 26, 2011 by 2:00 p.m. Seller's time, as follows: Chase Bank USA, N.A. Beneficiary Name: Chase Bank USA, N.A. This Bill of Sale is executed without recourse except as stated in the Credit Card Account Purchase Agreement to which this is an Exhibit. No other representation of or warranty of title or enforceability is expressed or implied. Chase B S , N.A. By: Authorized Signatory Date: April 21, 2011 Portfolio Recovery Associates, LLC w Q By: Mc--w- Date: 41"111 Title: Team Leader Title f't•L CHSKR3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Portfolio Recovery Associates, LLC vs. Denise D. George ~4~~~y.,. ~~ ~rrr~ili~~~~~~t~ _ - -~~~-~ " FLT' .. ~~,,~.~ E '~' AUG 21 AM f0~ 14 ~~ Case Number 2012-4676 SHERIFF'S RETURN OF SERVICE 08/16/2012 04:46 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 2012 at 1646 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Denise D. George, by making known unto herself personally, at 150 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. ~ -~'i EN S FRY, SHERIFF COST: $43.00 August 17, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC t20 Corporate Blvd Norfolk. VA 23502 Plaintiff v. DENISE D GEORGE i >0 S ENOLA DR E NOLA PA 17025 Defendant ~'j= ~ ~- ~ Datc: No. 2012 4676 PRAECIPE FOR DF,FA[:"LT JUDGMENT Filed on Behalf of Plaintiff un el of record for thibw'~'arty~ ~'~°'.. q ° ~ id ~~ Robert N. Polas, Jr., Esquire # 201259 -~_,__ Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F)(757)518-0860 Attorneys for Plaintiff Q~~ $I~O. Sa~xl A \ C~~a33 sa3 tt ~~;~:_ ~~p~,~l~ IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 2350 • Plaintiff No. 2012 4676 v. • DENISE D GEORGE • I50 S ENOLA DR ENOLA PA 17025 • Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, DENISE D GEORGE ,tor failure to answer the Complaint. (X) Amount Due $3,926.62 Less Credits $.00 TOTAL $3,926.62 (,Xl (Xl IX)~ Date: Pursuant to Pa.R.C.P.231 1, I certify that a written notice of intention to til~h mailed or delivered to the party against whom ju ent is to be entered a d to record, if any, after the default occurred and at east en days prior to the ate c praecipe and a copy of the notice is attached. ~.~ ~'U c~ ~ ~~, J xobert N. Yolas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC' 120 Corporate Blvd Norfolk, VA 23502 (T)1-866-428-8102 (F) (75'1) 518-0860 Attorneys for Plaintiff I certify that the foregoing assessment of damages is for specified amounts alleged to he due in the complaint and is calculable as a sum certain from the complaint. Pursuant to PA.R.C.P.23 7 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. ectpe was er Attorney of tiling of this 3 . ` ~ ., ti „~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOC[ATES, LLC I20 Corporate Blvd Norfolk, VA 23502 Plaintiff No. 2012 4676 v. DENISE D GEORGE l ~0 S ENOLA DR ENOLA PA 17025 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $3,926.62, plus interest, on . i0~`~`"1 ~`,, ~/ (X) A copy of all documents filed with the Prothonotary in support of a ithin ~'udgment}s~r~ atta e B ~~1 ~ / "u [f you have any questions regarding this Notice, ple~e cont~lct the filing party Date: I ( I Robert N. Polas, Jr., Esquire # 201259 ~~_,_~ Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-~i66-428-8102 (F)(757)518-0860 Attorneys for Plaintiff g ,. RORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: '1-866-428-8102 Fax: (t57) 518-0860 Nours of Operation: Monday through Thursday $ AM to 11 PM, Friday 8 ANt to 9 PM, Saturday 8 ANI to 5 PM, Sunday 12 PM to 11 PM (EST) September 7, 2012 DENISE D GEORGE ISO S ENOLA DR ENOLA PA 17025 [~ -17793 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. DENISE D GEORGE 2012 4b7b Dear DENISE D GEORGE: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney iD# 201259!94055 Portfolio Recovery Associates, LLC 140 Corporate Bivd. Norfolk, VA Attorneys for Plaintiff r ~~ ~. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. NA 1N THE COURT OF COMMON PLF,AS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LA.W PORTFOLIO RECOVERY ASSOCIATES, LLC l20 Corporate Blvd Norfolk, VA 23502 Plaintiff No. 2012 4676 v. DENISE D GEORGE 1 ~0 5 ENOLA DR ENOLA PA 17025 Defendant "CO' DENISE D GEORGE i50 S ENOLA DR ENOLA PA 17025 DATE OF NOTICE: September 7, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN aPPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIiV TEN DAYS FROM THE DATE OF TH1S NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RiGH'TS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. [F YOU CANNOT AFFORD TO I{IRE 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 Robert N. Polas, Jr., Esquire Carrie A. Brawn, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff 't'his communication is fi•om a debt collcrtor is ran artempt to collect a debt. Any information obtained will be used t'or thnt purpose. IN THE COURT OF COMMON PLEAS OF CU_VIBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCL~TES, LLC l'0 Corporate Blvd Norfolk. VA 23502 No. 2012 4676 Plaintiff v. DEMSE D GEORGE 150 S ENOLA DR ENOLA PA 17025 Defendant AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for plaintiff, herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 150 S ENOLA DR ENOLA PA 17025 and is not in the military service of the United States or its Allies, or otherwise within theisions of the Service Members Givil Relief Act and its Amendments. ~' s' ~ ~* `* ~,~1\\~ .,.... Date: _ ~__ Robert N. Polas, Jr., Esquire, #201259 -~ Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, L:L(' 120 Corporate Blvd Norfolk. VA 23502 (T)1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 12-17793 .. _j l ~. iii... ~ e, ~ ~~tt ~z, Department of Defense Manpower Data Center ~ .. ~`~~ h jYr , ' Statt~ ~c~sczrt '~~ Ptcz~~acst to Servi~er~mbers Civic ~t~liet€.~ct ~ .< fast Name: G_EQRGE First Name: DENISE D ............................ _.. Middle Name: Active Duty Status As Of: Sep-18.-2012 Vn A46NAWy C:e KSWS fh.9y St%txf-Da1B.> ''~-' ...__ '•:Mn pury 5ls,+', pam ~ .+.9.•3 DwDt E.~+C paHe ~ ~_~} 'U+in4. ~ rm.. t.~mga..rne..^_._.... 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Di*ador GeoanmenY of pefensr; - °.`anpowar Dats~ Gen,er t a,Cm Mark Center Drive. 3;nte u4E25 .r.=-,.,tcn, v~ 22354 12-'47793 ~;. ~ I~l~is c~~rr~r~~tinicati~3n is a ctebr ct>llecti~r zinc{ is ar~_ aCternpt tc> ~:ollect~ a cl~a~t. .~,ny ix~tbrrriation ~~htairtecl ~~ill rx~ us~;d t~a~• that pureuse.