HomeMy WebLinkAbout13-3542 Supreme Co rat; of Pennsylvania
Cour - mton Pleas
y For Prothonotary Use Only: l 1 �9 L 51 A "t 1'
C1 iIUV.e+eet Docket No:
CLIMB ='RLNCount '
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadin s or other a ers as required by law or rules of court.
S Commencement of Action:
E ® Complaint ❑ Writ of Summons ❑ Petition
C ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
, Lead Plaintiffs Name: Lead Defendant's Name:
PORTFOLIO RECOVERY ASSOCIATES, LLC CHARLENE SHIELDS
O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
N (Check one) outside arbitration limits
A Is this a ClassAetion Suit? ❑ Yes ®No Is 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 Se] Litigant)
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.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional [:3 Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Board of Assessment
❑ Motor Vehicle o Debt Collection: Credit Card ❑ Board of Elections
❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation
E] Premises Liability ❑ Statutory Appeal: Other
S ❑ Product Liability (does not include
j mass tort) ❑ Employment Dispute:
E
f p Sian der/Libel/D efamation Discrimination
C] Zoning Board
C ❑ Other:
El Employment Dispute: Other ❑ Other:
T
I ❑ Other:
0 MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
B ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Other: ❑ Ground Rent ❑ 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:
12 -35567
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055 f 'ILED . �.
Mark R. Garvey, Esquire PA Bar # 312686 1 f SRC) Tfi�
,
Portfolio Recovery Associates, LLC f . ' Q TAR(
`(
120 Corporate Blvd 2d j3 •.,0U,
Norfolk, VA 23502 `�; 4
TELE: 1- 866- 428 -8102 C ` 1 116 ER Att o COU
FAX: (757) 518 -0860 P EN"S YLyAN lA �Y
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 No.
Plaintiff,
V
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 17257
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
12 -35567
Pennsylvania Lawyer Referral Service fi�
(800) 692 -7375 x' � t6' V,�, �I
00
cX -fT �
�
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.
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 17257
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
12 -35567
Esta coinunicacio:n es d.e un. cobrador de deudas y es un intent do cobrar una deuda.
Cualquier infromacion. sera uti9izada para ese, proposito.
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. :
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 17257
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, CHARLENE SHIELDS, is an adult individual with last known address of 15
CHEROKEE DR, SHIPPENSBURG PA 17257.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / JC PENNEY on
August 21, 2005 with account number * * * * * * * * * ** *4428 (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 18, 2011.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / JC
PENNEY 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
$4,120.11.
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, CHARLENE SHIELDS , in the amount of $4,120.11 plus costs of this
action and any other relief as the Court deems just and reasonable.
A I le,
Carrie A. Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R. Garvey, Esquire, # 312686
Attorneys for Plaintiff
12 -35567
This conu is from. a debt collector and is an attenipt to collect a debt.
Any in.fornzation obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
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.
MAY 2 4 2013
Date: B
Le vin Shipmon- Walker
Custodian of Records
12 -35567
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
u. Norfolk, VA 23502
Telephone: 1- 866 - 428 -8102
f Fax: (757) 518 -0860
' Statement of Account
Account: * * * * * * * * * ** *4428
CHARLENE SHIELDS
Account Holder:
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 17257
Consumer Account Product Code: PVT
Issuer: GE CAPITAL RETAIL BANK / JC PENNEY
Assignee: Portfolio Recovery Associates, LLC
Account Number: * * * * * * * * * ** *4428
Date Account Opened: August 21, 2005
Date of Last Payment: June 18, 2011
Date of Charge Off: December 28, 2011
Balance at Purchase: $4,120.11
Purchase Date: January 31, 2012
Balance at Charge -Off: $4,120.11
Less Payments: $.00
Balance Due: $4,120.11
12 -35567
GECN51
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.
Lecinda Shipmon- Walker
I, the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby
depose, affirm and state as follows:
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 / JC PENNEY ( "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 January 31, 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 CHARLENE SHIELDS
( "Debtor ") to the Account Seller the sum of $4,120.11 with the respect to account number ending in * * * * * * * * * ** *4428,
as of December 28, 2011 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 $4,120.11 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 Associates LC
( /��l
By: i ecind todian of Records
Subscribed and sworn to before me on M A W 2 4 2013 , 2013
Notary Pu c Rh, Lucretia Ann Etheridge
Commonwealth of Virginia
Notary Public
12 -3556 �.,, , �, Commission No. 7042513
My Co mmissio n ExAiTs 9/30014
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.
330 GE MONEY 8 p.m. 01 -30 -2012 3112
0 cstNSi
GF Money Bank
BILL of SALE
PRA Fresh — January 2013
For value received and in further consideration of the mutual covenants and
conditions set forth in the Forward Flour Receivables Purchase Agreement (the
"Agreement "), dated as of the 2CP day of December, 2011, by and between General
Electric Capital Corporation, GE Capital Retail Bank, GEMB Lending, Inc., Monogram
Credit Services, L.L.C., RFS Holding, L.L.C„ and GEM Holding, L,L.0 (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.
GE Capital Retail Bank
By:
Title:
General Electric Capital Corporation
By: � f
Title: V C, E j
GEMB Lending, Inc.
By:
Title:
Monogram Credit Services, L.L.C.
By:
Title:
01/91/2012 16:39 6785761 GL BAS SQLU'iTI%* PAGE 15/15
GB Money Bank
DILL , of SALE
P-R-A ,j [ph January 20
For value received and in finther consideration of the mutual covenants and
conditions set forth hi the'Porward Flow Reaelvebles Purchase Agroemcat (the
"ASmement "), dated as of the 20 day of December, 2011, by and between General
Electric Capital Corporation, GE Capital Retail-BOX GEMB Lending, Inc., Monogram
Credit Services, L.I.Q. RFS Holding, L.L.C., and OEM Holding, T,.I..0 (collectively
"Solles'l and Portfolio Recovery Associates, LLC. (Buyer'), Seller hettby ttansfem,
j lolls, convoys, grants, and delivers to Buyer, its successors and assigns, without recours
except as set fbr& in the Agm mer t, to the extft of its ownership, the Receivables as set
} fordt in the Notification Filos (as defined in the Agmernent)� deliveted by Seller to Buyer
on each Tmafer Date, and as Further described in the Agreanimt.
1
OR Capital Retail Bank
<
1 3y:
Title, iyla
General lEleetrie Capital Corporation
r
By:
Title:
GRUB Lending, Inc.
By: ��►
Monogram Credit Services, L.L.C.
G ECA/6 7/
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson �,�- ����F11LED-OFFICE
HUN�}���y�
Sheriff 4t�:pertt��
Jody S Smith 2613,.w 'x 2613 JUN 26 PM 2: 1 I
Chief Deputy " }
Richard W Stewart CUMBERLAND COUNTY
Solicitor arriCEOFT;�= Fig= PENNSYLVANIA
Portfolio Recovery Associates, LLC
vs. Case Number
Charlene Shields 2013-3542
SHERIFF'S RETURN OF SERVICE
06/21/2013 12:13 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: Charlene Shields at 15 Cherokee Drive, Southampton Twp., Shippensburg, PA 17257.
J IE DIMARTLE, DEPUTY
SHERIFF COST: $50.60 SO ANSWERS,
June 24, 2013 RON R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,In.
In the Court Of Common Pleas Of Cumberland County, PA
Portfolio Recovery Associates, LLC No. 13T 25L)�
120 Corporate BLVD J
Norfolk,VA 23502 Plaintiff
V. ,r
Charlene Shields
15 Cherokee Drive c> Cz;
3> CD t�'
Shippensburg PA, 17257 Defendant =
Defendant answer the complaint as follows:
1. Lack of Knowledge
2. Affirm
3. Deny
4. Lack of Knowledge
5. Affirm
6. Deny
7. Affirm
8. Deny
9. Deny
10. Deny
11. Lack of Knowledge
The undersigned enters a appearance in this action.
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.
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 17257
Defendant.
COMPLAINT
I. Plaintiff,Portfolio Recovery Associates,LLC is a Delaware Limited Liability Company with
offices located at 120 Corporate Blvd,Norfolk,VA 23502.
2. Defendant,CHARLENE SHIELDS,is an adult individual with last known address of 15
CHEROKEE DR, SHIPPENSBURG PA 17257.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/JC PENNEY on
August 21,2005 with account number************4428 (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.
Any1n.formation obtained will be used for that purpose.
Y i
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 18,2011.
8. Plaintiff is the purchaser,assignee and/or successor in interest GE CAPITAL RETAIL BANK/JC
PENNEY 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
$4,120.11.
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, CHARLENE SHIELDS ,in the amount of$4,120.11,plus costs of this
action and any other relief as the Court deems just and reasonable.
Came A. Brown,Esquire,#94055
Robert N.Polas,Jr.,Esquire,#201259
Mark R. Garvey,Esquire,#312686
12-35567 Attorneys for Plaintiff
This cornmun.ication is from a dent collector and is an atten'pt to collect a debt.
Any.inkmiation obtained Will be used for that purpose.
y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502 No. 13-3542 CIVIL
Plaintiff
C
V. CIVIL ACTION - LAW
rnC0 z"
CHARLENE SHIELDS N
15 CHEROKEE DR z,
SHIPPENSBURG PA 17257 �a v
):;PC) M XF
Defendant D z '`
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 1303937.
2. Relief was ordered on July 30, 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 1.1
U.S.C. § 362.
Respect 11 ubmitted,
By:
Robe olas, Jr., Esquire # 201.259
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
12-35567
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 th' day of August,
2013 by depositing same in the Post Office, first class mail, postage prepaid, addressed as follows:
CHARLENE SHIELDS
15 CHEROKEE DR
SHIPPENSBURG PA 1725
obert 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) 5.18-0860
Attorneys for Plaintiff
12-35567
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.COLORADOATTORNEYGENERA:L.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 1 1 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.