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HomeMy WebLinkAbout12-4736Robert 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 UMSERLAN COgN Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. n- u ??? 6-011 Norfolk, VA 23502 No. I Oc Plaintiff V. PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Defendant C?.= THE FROTH NOTARY 2912 OR) 1- ? 0 1. M 10: 4 I NOTICE 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 2 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 Qom} ??p3 7Slt it 1 4(? 3(0 This communication is from a debt collector and is an attempt to collect a debt. A x-78(1 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. PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda pues as en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Dema a y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archiv o 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 co to usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro recl no o alivio solicitado por Demandante. usted puede perder dinero o propiedad o otros derechos importante p ra usted. 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 OFICIIS A PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEEF INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONS 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 Thi; CotnMU11icatio ll is f.i?01-t a debt collector and i5 an "Ittcrnpt to collect a ?.li?}at. Any jifl6nnation obtained Will bC 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 V. PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Defendant No. 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 PEARL E SHIELDS, is an adult individual with last known address of 2 W PENN APT 201, CARLISLE PA 17013. 3 4 5 It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on June 1, 1996 with account number ************6270 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A." 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. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. I'11is communication is f-oni a debt collector ai-id is an attevnpt to coltect a debi. `mly information obtaMQd will be used for that purpose, 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 Account. The last payment made on this Account was on November 4, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. / SEARS 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 $6,512.39. 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 Plaintiff and against Defendant, PEARL E SHIELDS, in the amount of $6?5?12.39, plus costs of this and any other relief as the Court deems just and reas na le. e ; ? J n R Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-90107 [Ills COn MUllication is from a debt collector rand is an attetript to collect a (left. any in.fonnation obtained will be !iscd for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Joann F. Cuffee 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 I'I 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 1 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date : JUL 12 2012 11-90107 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: 1-86 428-8102 Fax: 1-75?-518-0860 Statement of Account Account: ************6270 PEARL E SHIELDS Account Holder: PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Consumer Account Product Code: PVT Issuer: CITIBANK, N.A. / SEARS Assignee: Portfolio Recovery Associates, LLC Account Number: ************6270 Date Account Opened: June 1, 1996 Date of Last Payment: November 4, 2010 Date of Charge Off: June 19, 2011 Balance at Purchase: $6,512.39 Purchase Date: September 21, 2011 Balance at Charge-Off- Less Payments: Balance Due: 11-90107 SRSM32 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. 1, the undersigned, Inann F Olff'e , Custodian of Records, for Portfolio Recovery Associates, 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 d business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the p practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This is based upon my personal knowledge of Account Assignee's record keeping system and my review of Accourn Assignee's records, including a review of the business records transferred to Account Assignee from CITIBAN SEARS ("Account Seller"), which have become a part of and have integrated into Account Assignee's busine: in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the accoL proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such having been sold, assigned and transferred by the Account Seller on September 21, 2011. Further, the AccoLu has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no fur 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 ordinary course of business by the Account Assignee, there was due and payable from PEARL E SHIELDS (". the Account Seller the sum of $6,512.39 with the respect to account number (************6270), as of June with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date ( 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or occurring subsequent to the date of sale, Account Assignee claims the sum of $6,512.39 as due and owing as of this affidavit. Po io Re ry ssociates i By: Jo ee Custodian of Records ibed d swItbefore me on Notary Public 11-90107 JUL 12 2012 of , 2012 Erin L. Carr Commonwealth of Virginia NOWN Pubtic COMMission Nos 7609898 J rnmmission boirlg_713112015 hereby )licies and affidavit ,N.:?./ s records, and all count Assignee ;ttlement, er interest ebtor") to 9, 2011 the sale. the date 1 lri?; communication is roni it delft collector and i ; do lattempt to collect a debt. Artv irttcortmitiora obtained will be used for that purposc;. 0 9 Contract ID: PRISP1ER408251 t Document ID; 091211 PR I SP I EMB1 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated September 21, 2011, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank") to Portfolio Recovery Associates, LLC, organized under the laws of the Delaware, with its headquarters/principal place of business at 130 Corporate Boulevard, Norfolk, VA 23502 ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated August 25, 2011, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit l and the final electronic tile. Citibank, N.A. By, (Signatur ie ?1x Name: Patricia Hall Title: Financial Account Manager PRA 08251 L&c SKSM ?2 lit, TASa3iE $ ,j?.?R 11IR `a aR?n 47 gig t;a a?a gHaQe?? Is s # a ba still R pp?? qc $ g =!g gggt?{ga IiY1 6agtg SIT R?R,?a,?6??aq???i ag R?•?R ??i ??c?p? '?8??s?? ?? ? ?? ?nq r ?a3g5 ? €a g c 89 R s ?fQN I IQ i KalglCo I R I I IQ. g i_: U Olt fill HIM 1111111:1 I alas W 1 1 9 YSRR .. Eb? ??p?#f????.??i??4:?q?¦??i?9?.xs?! ?3?b??xxr???g'>? c????;.*r?Q?? ! 99?$ Rd it"pt a Hit 12 I R I y . If a 111111111 1 It if -1oll, [Fri, is ir ITS It 14 fill It I I: , of 1 1W r f If 3Qs?sas s I d i g it 1 I'll $i +T fill if.I Ija' I; A T Q. RAI Jill [a p's tit it I fQY F p.11 I 1R d? P dg' ?, gN N5 , 115 Of I I u q Ell I 34 a e ? x a g ? ?• g' ?? 2-1 CL Q ? °E ?s bb??? ?g g! a S a 6 LOT! ?1 e 4 .?RRS° = Sears Card* Call us at 1-800-917-7700 Manage your account and pay your bill at wwwAmwvcard.com Write to us at PO Box 6288 Sioux Fells, SO 57117-6283 PEARL E SHIELDS Account Number. 111111111111111111111111111116270 Page 1 of 2 -Summary of.Account Activity Previous Balance $6,369.64 Payments $0.00 Other Credits $0.00 Purchases $0.00 Fees Charged +$35.00 Interest Charged +$107.75 New Balance $6,512.39 Past Due Amount $1,316.35 Credit Limit $5,750.00 Available Credit $0.00 Amount Over Credit Limit $762.39 Statement Closing Date 06/17/2011 Days in Billing Cycle 30 Transactions Trans Date Post Data Fees 06/14/11 06/14/11 Interest Charged 06/17/11 06/17/11 Pa meot Due Date L07/14/2011 Information the address for payments by the payment due dt New Balance $6,512.39 Minimum Payment Due $1,527.10 Payment Due Date 07/1412011 Late Payment Waming: if we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to $35. Minimum Payment Warning: If you make any 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 additional You willpay off the And you will charges using this card balance shown on this end up paying an and each month you pay-.. statement in about,. estimated total ,of. Only the minimum payment 19 years $13,961 $243 you would like information 3 years 1 $8,761 (Savings= $5,200) Amount LATE FEE TOTAL FEES FOR THIS PERIOD INTEREST CHARGE ON PURCHASES INTEREST CHARGE ON CASH ADVANCES TOTAL INTEREST FOR THIS PERIOD 2011 Totals Year-to-Date Total Fees Charged in 2011 _....-- _.... __.._.._ __._..-.-__ ..__..__... $210.00 Total Interest Charged in 2011 $618.10 YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. 35.00 35.00 107.75 0.00 107.75 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION This Account Is Issued by Citibank (South Dakota), N.A. Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records Sears Card® Account Number. -6270 New Balance Due Dee Payment Due Amount Enclosed $6,512.39 07/14/11 $1,527.10 0041665 EX 11 B 11168 1 TRH ae FXG 001 7 N 11rI1rIr111111111111111111111111111111111111111111111111111111111 Make Check payable to PEARL E SHIELDS SEARS CREDIT CARDS 2 W PENN ST APT 201 PO BOX 163081 CARLISLE PA 17013-2357 COLUMBUS, OH 43218-3081 Please make address changes on reverse side. Jill l1inr11111111111111111111111111u111111lllmllr1n1111 1 . 270 Information About Your Account. How to Avoid Paying Interest on Purchases Your payment due date is at least 25 days after the close of each billing cycle. We will not charge you any interest on purchases 0 you pay your New Balance by the payment due date each month. This is called a grace Deriod on purchases. If you do not pay the New Balance in full by the payment due date. you will not get a mace period on purchases until you pay the New Balance in full for two billing cycles in a row. We will begin charging interest on cash advances and balance transfers (it available on your account) on the transaction date. If you have a balance subject to a deferred interest promotion and that promotion does not expire before the payment due date, that balance (the "excluded promotional balance's is excluded from the amount you must pay in full to get a grace period. However, you must still pay any separately required payment on the excluded promotion In billing cycles in which payments are allocated to deferred interest balances first, the deferred interest balance will be reduced before any other balarce on the account. However, you will continue to get a grace period on purchases so long as you pay the New Balance less any excluded promotional balances in full by the payment due date each billing cycle In addiNOn. certain promotional offers may take away the grace period on purchases. Other promotional offers not described above may also allow you to have a grace period on purchases without having to pay all or a portion of the promotional balance by the payment dire date If either is the case, the promotional offer will describe what happens Now We Calculate Your Balance Sul*d to Interest Rate. We use a daily balance method (including current transactions) to calculate interest charges. To find out more information about the balance computation method and how the resulting interest charges were deternnined, contact us at the "Call us at" number on the front. Balance lteosfers. Balance transfer amounts are included in the "Purchases" line in the Summary of Account Activity (if balance transfers are available on your account). Transaction Date. The Transaction Date shown on the statement is also the Sale Date. Credit (deporting Disputes. It you think we reported inaccurate information to a credit bureau write us at "Write to Ls at"address shown on the front Report a Lost or Stolen Card Immediately. Cal the "Call is at" number shown on the front. What 1b Do If You Think Yom Find a hMstake on Your Statement If you think there is an error on your statement, write to is at the address shown on the front where it says "Write to us at." In your letter give us the following information A r Your name and account number. Dollar amount: T e dollar amount of the suspected error. Descriotlon of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing You may call us, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question While we investigate whether or not there has been an error, the following are true: We cannot try to collect the amount in question, or report you as delinquent on that amount The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made a mistake. you will not have to pay the amount in question or any interest or other fees related to that amount. While you do not have to pay the amount in question, you are responsible for the remainder of your balance. We can apply any unpaid amount against your credit limit. Your Rights M You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant. you may have the right not to pay the remaining amount due on the purchase To use this right, all of the following must be true: 1. The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than S50. (tote: Neither of these are necessary N your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services) 2. You must have used your credit card for the purchase Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at the address shown on the front where it says "Write to us at" While we investigate, the same rules apply to the disputed amount as discussed above. After we finish air investigation, we will tell you our decision At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Important Payment Instructions. Crediting Payments. If vie receive your payment in proper form at our processing facility by 5 p.ra local time there, it will be credited as of that day. A payment received there in proper form after that time will be credited as of the next day. Allow 5 to 7 days for payments by regular mail to reach us There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form or is not sent to the correct address. The correct address for regular mail is the address on the front of the payment coupon. A payment made in-store is not sent to the correct address The correct address for courier or express mail is the Express Payments Address shown below Proper Form. For a payment sent by mail or courier to be in proper form. you must Enclose a valid check or money order No cash, gift cards, or foreign currency please Include your name and account number on the front of your check or money order. SMC/TGI/SCC/SCP/HIPS 01/11 011 WOW 1- 02/?!)0011 If you send an eligible check with this payment coupon, you &Abaft us to complete ygmr payment by electronic debtL If we do, the checking account will be debited In the amount on the check. We may do this as soon as the day we receive the cbKL Also, the check will be destroyed. Copy Fee. We large $3 for each copy of a billing statement that dates back 3 months or more. We add the fee to the regular purchase balance We waive the fee if your request for the copy relates to a billing error or disputed purchase. Payment Options Other Than Regular Mall. Odw Payments. Visit www.SmsCard.com and sign up for onine payments Enrollment may take a few days If we receive your request to make an online payment by 5 p.m. Eastern time, we will credit your payment as of that day. If we receive your request to make an ovine payment after that time, we will credit your payment as of the next day. For security reasons you may be unable to pay your entire New Balance with your first online payment Pay by Phone Service. You may use this service any time to make a payment by phone. You will be charged $14.95 if a representative of ours helps expedite your payment. Call by 5 p.m. Easter time to have your payment credited as of that day. If you call after that time. your payment will be credited as of the next day. We may process your payment electronically after we verity your identity. Express Payments You can send payment by courier or express mail to the Express Payments Address This address is: Payments Department. 1500 Boltonfield Street. Columbus, OH 43228. Payment must be received in proper form at the proper address by 5 p.m. Easter time to be credited as of that day All payments received in proper form at the proper address after that time wig be credited as of the next day. New Address If your address has changed, please print any changes below. Name: Street Address: City, State, Zip: Phone: SMC/TGI/SCC/SCP/HIPS 01111 Sears Card* Call us at 1-800-917-7700 Manage your account and pay your bill at wwwAearward.com Write to us at PO Box 8283 Sloux Falb, SD 57117-6283 PEARL E SHIELDS Account Number. XXXX XXXX XXXX 6270 Page 2 of 2 41685 Payment Due Date 07/14/2011 Interest Charge Calculation Your Annual Percentage Rate APR is the annual interest rate on your account Annual Percentage Balance Subject to Type of Balance Rate (APR) Interest Rate Interest Charge PURCHASES Regular 20.40% (d)(v) $6,426.20 $107.75 CASH ADVANCES Regular 21.40% (d)(v) $0.00 $0.00 (v) = Variable Rate (d) = Daily (m) = Monthly SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4~ytitr of ~u~~,~t/~ ~r ,,_ QF+ ICE 0- 7~+E SrBRi~F E..;~.~~1-lal~~ i~,, ` ~i' 2 AUG 17 AM 9= I I ~'t~M~~~LANC~ C~{Vi}i T't' P~N~SY~VAWfA Portfolio Recovery Associates, LLC Gase Numbe vs. Pearl E. Shields 2012-4736 SHERIFF'S RETURN OF SERVICE 08/06/2012 07:05 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on Auc 6, 2012 at 1905 hours, he served a true copy of the within Complaint and Notice, upon the within nan defendant, to wit: Pearl E. Shields, by making known unto herself personally, at 2 W. Penn Street, Apartment 201, 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. TIM SHERIFF COST: $34.00 August 09, 2012 SO ANSWERS, (~ ` RON RANDS SHERIFF (c) CountySuite Sheriff, 1'aleosoft, In:. t Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC ' PROT F�� 120 Corporate Blvd �J� T�fiE f'�i07�Qt�QTAI� Norfolk, VA 23502. 1013 MAY 29 AM If: 0 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUI� W W B bUNTY PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD . NORFOLK, VA 23502 Plaintiff No. 12-4736 CIVIL V. PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respe ly Submitted, Ro ert N. 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 11-90107 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. 12-4736 CIVIL V. PEARL E SHIELDS 2 W PENN ST APT 201 CARLISLE PA 17013 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon PEARL E SHIELDS, by First Class Mail, Postage Pre-Paid, a copy thereof on this day of 203 to. PEARL E SHIELDS, 2 W PENN ST APT 201, CARLISLE P 7013 11-90107 Ro eft N. 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.