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Home My WebLink About13-3267 Supreme C; ; Pennsylvania Cour f Cam n Pleas TIME STAMP Ci ox `et s zss CUM County `: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: � ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking 3 Lead Plaintiffs Name: Lead Defendant's Name: M PORTFOLIO RECOVERY ASSOCIATES, LLC PATRICIA GOTTSHALL c Are money damages requested? ®Yes El No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Fis this an MDJAppeal ?. ❑ Yes ® No Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr. /'Carrie Brown/ Mark R. Garvey ❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) z Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim check the one that you consider most important. a TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS o i ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ' E] Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle o Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability — ❑ Statutory Appeal: Other ❑ Product Liability (does not include — mass tort) ❑ Employment Disputer ❑ Slander /Libel /Defamation, Discrimination p Zoning Board Other: _ ❑ ❑Employment Dispute: Other C] Other: ❑ Other: t MASS TORT ❑ Asbestos ❑ Tobacco ❑Toxic Tort =DES . REAL PROPERTY MISCELLANEOUS E] Toxic Tort - Implant O Ejectment p Common Law /Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment - F E] Other: ❑ Ground Rent E] Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations — ❑ Mortgage Foreclosure: Residential Restraining Order — ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto '- ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: _ ❑ Legal - -- — _.� ❑ Medical — — ❑ Other Professional: R 13 -13122 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 - ,. ._ t. t� - C- £, , Mark R. Garvey, Esquire PA Bar # 312686 F(7 7 f 'h'( Portfolio Recovery Associates, LLC 2013 4" , t ��1ta' ' 120 Corporate Blvd �H 1 : 0 7 Norfolk, VA 23502 CUM BEE ND TELE:1- 866 - 428 -8102 ' �NSY lU TY FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD No. NORFOLK, VA 23502 Plaintiff, V. PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17050 Defendant. 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 a written appearance, personally or by an 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 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 13 -13122 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 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17050 Demandado. 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 esta 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, 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 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 13 -13122 Esta comunicacion es de un cobrador d.e deudas y es an intent do cobrar una deuda. Cuaiquier infro .acion sera utilizada para. ese propos.ito. Robert 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 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. V. PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17050 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, PATRICIA GOTTSHALL, is an adult individual with last known address of 5169 E TRINDLE RD LOT 2, MECHANICSBURG PA 17050. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on November 17, 2005 with account number * * * * * * * * * ** *8953 (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. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained 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 the Account. The last payment made on this Account was on June 28, 2011. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / WAL -MART and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs verification 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 $929.15. 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, PATRICIA GOTTSHALL , in the amount of $929.15, plus costs of this action and any other relief as the Court deems just and reasonable. / z< Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -13122 This communication is from a debt collector and is an attempt to collect a debt. An.y information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, ,Anita Bray 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: MAY 2 4 2013 By: 4 C&S:� Anita Bray Custodian of Records 13 -13122 4 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. X IBIT 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 120 Corporate Blvd Norfolk, VA 23502 a Telephone: 1- 866 - 428 -8102 %mac* f ✓A , Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *8953 PATRICIA GOTTSHALL Account Holder: PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17050 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *8953 Date Account Opened: November 17, 2005 Date of Last Payment: June 28, 2011 Date of Charge Off: January 29, 2012 Balance at Purchase: $929.15 Purchase Date: February 29, 2012 Balance at Charge -Off: $929.15 Less Payments: $.00 Balance Due: $929.15 13 -13122 GECN78 This communication is from a debt 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, Prow , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as o ows: 1. 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, 120 Corporate Blvd, Norfolk, VA 23502. 1 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 GE CAPITAL RETAIL BANK / WAL -MART ( "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 29, 2012. 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 PATRICIA GOTTSHALL ( "Debtor ") to the Account Seller the sum of $929.15 with the respect to account number ending in * * * * * * * * * ** *8953, as of January 29, 2012 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 $929.15 as due and owing as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. Portfolio Recovery sociates, LLC J (P 6Q By: Anita Bray , Custodian of Reco s Subscr' nd o to before me on S 2 4 20 13 2013 W., Lucretia Ann Etheridge Notary P Commonweolth of Virginia Notary Public 13 -13122 y Commission No. 7042513 My Commission Expires 9/30/2014 This communication is from. a debt collector and is an attempt to collect a dent. Any information obtained will be used for that purpose. GECN78. ' GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending. Inc. B y: r r,,, ,/ �- --- - -- - By Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Seri ices, L.L.C. Title: Glenn (Marino -EVP Title: Glenn \Marino- President RFS Holding. L.L.C. GEM Holding, L.L.C. By: By: Title. Vishal Gulati -CFO Title: Vishal Gulati -CFO ' GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement'), dated as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By: — T — Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Ban]: Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. By: B Title: Vishal Gulati -CFO Title: Vishal Galati -CFO GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement'), dated as of the 20 day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By: By: Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. r By: B - i Title: � �.Ctt Title: �Gu, , �.� 5�IWI Z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f-/LED-UFI'ICE Sheriff 01F THE PROTHONOTARY Jody S Smith Chief Deputy y� 2013 JUN 26 PM -2: f I Richard W Stewart 6 4,4yE ,: ; T .µ. r , CUMBERLAND COUNTY Solicitor PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Number Patricia Gottshall 2013-3267 SHERIFF'S RETURN OF SERVICE 06/19/2013 12:00 PM - Deputy Jamie DiMartle, 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: Patricia Gottshall at 5169 E. Trindle Road', Lot 2, Hampden Township, Mechanicsburg, PA 17050. (I AW Wmx��D J IE DIMARTLE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, x �Xj� June 21, 2013 RbNtV R ANDERSON, SHERIFF (c)County&uite Sheriff,Teleosoft.Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 No. 13-3267 CIVIL ` Plaintiff c. v. CIVIL ACTION - LAWS f ,_'t PATRICIA GOTTSHALL r -7, c' 5169 E TRINDLE RD LOT 2 C'05 MECHANICSBURG PA 17050 °c. T` p �. Defendant SUGGESTION OF BANKRUPTCY AND NOW, comes Plaintiff by and through its attorney, Robert N. Polas, Jr., and would show the Court: 1. A petition has been filed for relief under Title 11,United States Code, in the United States Bankruptcy Court which bears the case number 1303723. 2. Relief was ordered on July 19, 2013. 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on the property of the estate. 4. This is for informational purposes only, and does not constitute a Notice of Appearance by the undersigned. WHEREFORE, Plaintiff suggests that this action has been stayed by operation of 11 U.S.C. § 362. Respect 41' bmitt/ /V By: flr / Robert N. Polas, Jr., Esquire#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 13-13122 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this day of October, 2013 by depositing same in the Post Office, first class mail,postage prepaid, addressed as follows: PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17 J Robert N. Polas, Jr., Esquire#201259 Carrie A. Brown, Esquire, #94055 Mark R. Garvey, Esquire#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff 13-13122 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. , MAKE ALL CHECKS PAYABLE TO: Portfolio Recovery Associates,LLC SEND ALL PAYMENTS TO: Portfolio Recovery Associates,LLC,P.O.Box 12914,Norfolk,VA 23541 COMPANY ADDRESS:Portfolio Recovery Associates,LLC, 120 Corporate Blvd,Norfolk,VA 23502 DISPUTES CORRESPONDENCE ADDRESS:PRA Disputes Department, 140 Corporate Boulevard,Norfolk,VA 23502 DISPUTES DEPARTMENT E-MAIL ADDRESS: PRA_Disputes@portfoliorecovery.com DEBIT CARD TRANSACTION FEES: Third party vendors may charge a transaction fee for processing payments made by debit card;however,PRA does not charge or accept any fees. Please discuss this option with our staff if you have any questions. QUALITY SERVICE SPECIALISTS AVAILABLE Mon.—Fri.8 AM to 5 PM(EST) Not happy with the way you were treated?Our company strives to provide professional and courteous service to all our customers. Contact one of our staff to discuss issues related to our quality of service to you by phone at(866)925-7109 or by e-mail at qualityservice@portfoliorecovery.com PRIVACY NOTICE: We collect certain personal information about you from the following sources: (a)information we received from you; (b)information about your transactions with our affiliates,others,or us;(c)information we receive from consumer reporting agencies. We do not disclose any nonpublic personal information about our customers or former customers to anyone,except as permitted by law. We restrict access to nonpublic information about you to those employees and entities that need to know that information in order to collect your account. We maintain physical,electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. NOTICE: We are required under state law to notify consumers of the following rights. This list does not include a complete list of rights consumers have under state and federal laws: CALIFORNIA:The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances,collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part,collectors may not tell another person,other than your attorney or spouse,about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities,you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov. Nonprofit credit counseling services may be available in the area. COLORADO: Office located at 4600 South Syracuse Street,Suite 938,Denver,CO 80237.Telephone 1-866-508-4751.FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT,SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA.A consumer has the right to request in writing that a debt collector or collection agency cease further communication with the consumer. A written request to cease communication will not prohibit the debt collector or collection agency from taking any other action authorized by law to collect the debt. MAINE: Telephone number at licensed location is(800)772-1413. Hours of operation at licensed location are 7:30 AM to 11 PM EST Monday through Friday, 8 AM to 5 PM EST Saturday,and 2 PM to 9 PM EST Sunday. MASSACHUSETTS: Office located at 49 Winter St.,Weymouth,MA 02188. Telephone(800)772-1413. Hours of operation are 9 AM to 6 PM EST Monday through Thursday.NOTICE OF IMPORTANT RIGHTS:YOU HAVE THE RIGHT TO MAKE A WRITTEN OR ORAL REQUEST THAT TELEPHONE CALLS REGARDING YOUR DEBT NOT BE MADE TO YOU AT YOUR PLACE OF EMPLOYMENT. ANY SUCH ORAL REQUEST WILL BE VALID FOR ONLY TEN DAYS UNLESS YOU PROVIDE WRITTEN CONFIRMATION OF THE REQUEST POSTMARKED OR DELIVERED WITHIN SEVEN DAYS OF SUCH REQUEST. YOU MAY TERMINATE THIS REQUEST BY WRITING TO THE DEBT COLLECTOR. NEW YORK CITY: City of New York License Numbers 1096994, 1394695, 1394697, 1394696, 1394698, 1394700, 1394699, 1394694. NORTH CAROLINA:Collection Agency Permit No.4132. TENNESSEE: This collection agency is licensed by the Tennessee Collection Service Board of the Department of Commerce and Insurance.(#00000770) 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 4Robei-1 N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID #94055/201259/312686 Portfolio Recovery Associates, LLC 1 ° ';) ➢ HC:'5-17„ 120 Corporate Blvd , , Norfolk, VA 23502 +- f t,u‘ Pr 2C Attorneys for Plaintiff L,tj 33Ef L Alqn lUNd T Y PENNSYLVANIA 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. 13-3267 CIVIL v. PATRICIA GOTTSHALL 5169 E TRINDLE RD LOT 2 MECHANICSBURG PA 17050 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. 0 Respectfu .mitted t Robert 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 13-13122 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. 13-3267 CIVIL v. • • PATRICIA GOTTSHALL • 5169 E TRINDLE RD LOT 2 • MECHANICSBURG PA 17050 • Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon PATRICIA GOTT ALL,by First Class Mail, Postage Pre-Paid, a copy thereof on this day of 1 , 2 _, to: PATRICIA GOTTSHALL, 5169 E TRINDLE RD LOT 2, MECH S®BURG ' • 150 13-13122 Robert 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.