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Home My WebLink About12-6528Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #30937() 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. SANG A LY 3 SYCAMORE CT ENOLA PA 17025 Defendant. Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC ., ..'~ IN THE COURT OF COMMON PLEAS., -- .~ CUMBERLAND COUNTY, PA '~ ,:. CIVIL ACTION ` ~~ NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and 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 for any money claimed in the complaint nor for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. 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 32 SOUTFi BEDFORD STREET CARLISLE=, PA 17013 2780802 PPTCPADI <^ (,._~.~ ~~~~_~5 a 8~~~ S~~ ~,~ ,;~ ~~ ~ ~ a2 dg "~-. AVISO Le han demandado a usted en la torte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte digs de plazo al partir de la fecha de la demanda y la notification. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la torte tomara medidas y puede continuar la demanda en contra suva sin previo aviso 0 notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE= DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA. AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY' ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. SANG A LY 3 SYCAMORE CT ENOLA PA 17025 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff PORTFOLIO RECOVERY AS90CIATES LLC, claims as follows: 1. The Defendant(s), SANG A LY , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with HSBC BANK NEVADA N.A, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2899.86. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2780802 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), SANG A LY in the amount of $2899.86, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC ,. s ~~ One o its ttorneys Morris Sc tt Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LL.C 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: October 16, 2012 Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY' ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. SANG A LY 3 SYCAMORE CT ENOLA PA 17025 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Morris Scott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least '18 years of age and not in the Military Service of the United States, nor any State or Terrii:ory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: October 16, 2012 -l~~ By: Morris Cott Syrett Martin 2780802 PPTJCAMI I IIIIIII IIIIII IIII VIII III IIIIII VIII VIII VIII VIII VIII VIII IIII VIII IIII VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. ~~ /. PPTXVERI Exhibit "A" PPTXEXAI ~.~BC~OZ VERIFICATION (To be used bw a person associated with the present creditors I, M0"~' Zem~ ,hereby verify that: 1. I am employed by Portfolio Recovery Associates, LLC as Custodian of Records and am authorized to make this Verification on behal# of Portfolio Recovery Associates, LLC. Portfolio Recovery Associates, LLC is the successor in interest to HSBC Bl~NR NEVADA, N. A. /BEST BUY OR S&H GREENPOINTS. 2. I reviewed the following [ j(a) computerized documents; [ ](b) hard copy documents; and [x] (c) other (specify)Account Records relating to Account number: ending in 1799. The foregoing Account of HSBC BANK NEVADA, N. A. /BEST BUY OR S&H GR88NPOINTS was opened on 4/11/2008 in the name of SANG A LY. The accounts/documents that I reviewed were produced by HSBC BANK NEVADA, N.A./BEST BUY OR 3&H GREENPOINTS. 3. Based on my review of the foregoing documents, there is due and payable the principal sum of $2,899.86. This sum includes the following (check all that are appropriate): [x] interest; [x] late fees; [ j collection fees; and [x] any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and HSBC BANK NEVADA, N. A. /B83T BOY OR S&H GREENPOINTS. This sum does not include the following (check all that are appropriate): [ ]interest; [ ]late fees; [x] collection fees; and [ ]any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and HSBC BANK NEVADA, N.A. /BEST BUY OR S&H GREENPOINTS. 4. Based on my review of the foregoing documents, there are no payments that have not been credited. 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification tv authorities in violation of 18 Pa. C.S. §4904. g ~ iZ DATE -. MoniceZanwra ,CUSTODIAN ~~~;.~ Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #30937() 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. SANG A LY 3 SYCAMORE CT ENOLA PA 17025 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA - CIVIL ACTION ~~.~~ No. ~ ~ ~ ~~ ~ -, PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-21 Vii-564-1567 Dated:. October 16, 2012 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC ,~ ~ , By: -- ------ rris cott Attorney Syret Martin Attorney 2780802 PPTXPEAI I IIIIIIII IIII III IIIIII VIII Ilill VIII (IIII VIII VIII IIIIII III IIII Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~,L~D-OFi= I~ ~~ ~~~~ a~a~~aNaa;~~,; ~~ytt~sn of ~'u+hbr~,~~~~ ,~ ,~ ~0l2 NOU -9 AM $~ ~b ~+ ,' -~, ~'- ~ CUMBERLAN[~ COUN~'Y ~~~~~~ : -~-FSr:~ai~€ P~NNSYLVaNIA Portfolio Recovery Associates, LLC Case Number vs. 2012-6528 Sang A. Ly SHERIFF'S RETURN OF SERVICE 11/06/2012 07:24 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Sang A. Ly at 3 Sycamore Court, East Pennsboro Township, Enola, PA 17025. r DE S FRY, DEP SHERIFF COST: $58.00 November 07, 2012 SO ANSWERS, r RON R ANDERSON, SHERIFF (cj CountySuite ShPfi!T, Te!eosoft, Inc. Blatt, Hasenmiller, Leibsker&Moore, LLC Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC Morris Scott Attorney I.D.#83587 Syretta Martin Attorney I.D.#309370 1835 Market Street,Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC TIN HE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker&Moore, LLC MBERLAND COUNTY, PA Plaintiff, IL ACTION vs. No. 12-6528-CIVIL SANG A LY - 3 SYCAMORE CT ENOLA PA 17025 - Defendant(s). WOODFOREST NATIONAL BANK , 6520 Carlisle Pike Ste 55 , Mechanicsburg,PA 17050 Garnishee y' Interrogate les to Garnishee To WOODFOREST NATIONAL BANK, Garnishee: You are required to file Answers to the following Interrogatories within 20 days after service upon you. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant? 2. At the time you were served or any subsequent time thereafter,was there in your possession, custody,control or in joint possession,custody and control, any property of the defendant? 3. At th` i time you were served or any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s)or in which the defendant held or claimed an Interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had any interest? 2780802 PPTGBKCI 5. At any time before or after you were served did the defendant(s)transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? NIA 6. At any time after you were served did you pay,transfer or deliver any money or property to the defendant(s�or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s)against you? t,.,iI (� 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or Federal law? If so, identify each account and state the reason for the exemption and the entity electronically depositing those funds on a recurring basis. K► /o 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general exemption under 42 Pa.C.S Sec.8123? If so, identify each account. w I Ar 9. How much is the value of any property in your possession belonging to the defendant(s)? W I A 10. In the space below,the plaintiff may set forth additional appropriate interrogatories. IV I Morris Scott, Attorney No. 83587 Syretta Martin, Attorney No. 309370 Verification I,0 V_71110&the undersigned representative of WOODFOREST NATIONAL BANK, hereby verify that the answer to interrogatories are true and correct to the best of my knowledge, information, and belief based upon information I have. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. �-� --' LIAR 19 2013 Woodforest National Bank Legal Dept Bryan Abraham 832.375.28598 phone VJessica Black 832.375-3071 FIX Cedrick Frazier 25231 Grogans Mill Rd., Sui8 100 The Woodlands, TX 77380 Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D.#83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1635 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, Vs. CUMBERLAND COUNTY, PA SANG A LY 3 SYCAMORE CT CIVIL ACTION ENOLA PA 17025 Defendant(s). No. 12-6528-CIVIL =Mw AND cry I waodrore5A pna c'k (0590 C4rll5lle FdCz--*ss- �c1 "eChQn i Abu.-3,Pl4 /'1050 y c Garnishee -S PRAECIPE TO DISSOLVE ATTACHMENT To the Prothonotary. Kindly mark the Writ of Execution against as DISSOLVED, and the attachment as DISSOLVED. Respectfully submitted, Morris oft Syretta Martin 49.50 pa &85-5f 2780802 PPTXWPDI u SHERIFF'S OFFICE OEICUMBERLAND COUNTY Ronny R Anderson "`'r +TILED 0 Ff:11C_ Sheriff �t et r,trt U 1 HF FPQOTH0 N iA.RY Jody S Smith ,. Chief Deputy 2913 SEP --5 PP1 2: 54 Richard W Stewart � ' "°' CUMBERLAND COUNTY Solicitor OFFICE OF THE$4,ER'rf< PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. 2012-6528 Sang A. Ly SHERIFF'S RETURN OF SERVICE 02/22/2013 01:13 PM -William Cline, Deputy Sheriff,who being duly sworn according to law, states that on February 22, 2013 at 1313 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Sang A. Ly, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, by handing to Jenny Peck, Teller, 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 February 26, 2013 to Sang A. Ly at 3 Sycamore Court, Enola, PA 17025. 09/04/2013 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: $88.40 SO ANSWERS, September 04, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc.