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HomeMy WebLinkAbout13-3604 Supreme Colurt'. Pennsylvania Cour :"'f Com on Pleas For Prothonotary Use Only: 1 l.M L S I A %4 P Ci. •ove�leet Docket No: � ^ CUMB . 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 of pleadings or other papers as req uired by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC SUZANNE LINDERMANN I U Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes ®No Is this an MDJAppeal? ❑ Yes ®No A Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey t ❑ 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 ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other E3 Premises Liability ❑Dept. of Transportation ❑ Statutory Appeal: Other ❑ Product Liability (does not include S mass tort) ❑ Employment Dispute: C3 Slander /Libel/Defamation Discrimination E E3 Other: ❑Zoning Board C ❑ Employment Dispute: Other ❑ Other: T MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ 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: 13 -14397 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 0 T, Mark R. Garvey, Esquire PA Bar # 312686 �' jA'�r Portfolio Recovery Associates, LLC , i'PI 2 120 Corporate Blvd jQ� Norfolk, VA 23502 C Eit- �BE RLAN D �Of1P�T TELE: 1- 866- 428 -8102 IENNS YL' COUNT 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 � � C NORFOLK, VA 23502 No. / Plaintiff, V. SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 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 ( Pennsylvania a Lawyer Referral rral Service 13 -14397 (800) 692 -7375 O, V* 103.75 Q Gi#- 36 aq H This communication is from a debt collector and is an attempt to collect a debt. `` n a C l 91 S (A 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. SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 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 j uzgamiento 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 -14397 Esta coniunicacion es de un cobrador de deudas y es 11D. intent do cobras una deuda. Cualquier inf:rornaci.on sera utilizada prara 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. SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 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, SUZANNE LINDERMANN, is an adult individual with last known address of 45 VINE DR, CARLISLE PA 17015. 3. It is averred that Defendant was indebted to GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT on May 30, 2007 with account number * * * * * * * * * ** *2343 (hereafter referred to as "Account "). A copy of the account history is attached here to and collectively marked as Exhibit 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. This communication is from. a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 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 March 11, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT 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 $1,292.93. 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, SUZANNE LINDERMANN , in the amount of $1,292. , plus costs of this action and any other relief as the Court deems just and reasonab Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201 �--" Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -14397 This communication is from a debt collector and is an attempt to collect: a debt. Any information obtained w.11.1 be used far that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Dwayne E. Davis 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: By: Dwayne E. Davis Custodian of Records 13 -14397 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBIT 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 L 120 Corporate Blvd <° Norfolk, VA 23502 Telephone: 1- 866- 428 -8102 ti Fax: (757) 518 -0860 "T Statement of Account Account: * * * * * * * * * ** *2343 SUZANNE LINDERMANN Account Holder: SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 Consumer Account Product Code: PVT Issuer: GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *2343 Date Account Opened: May 30, 2007 Date of Last Payment: March 11, 2012 Date of Charge Off: October 14, 2012 Balance at Purchase: $1,292.93 Purchase Date: October 23, 2012 Balance at Charge -Off: $1,292.93 Less Payments: $.00 Balance Due: $1,292.93 13 -14397 GESQ45 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 undersignedJD 1L E. WAS , 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 GENERAL ELECTRIC CAPITAL CORP / CARE CREDIT ( "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 October 23, 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 SUZANNE LINDERMANN ( "Debtor ") to the Account Seller the sum of $1,292.93 with the respect to account number ending in * * * * * * * * * ** *2343, as of October 14, 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 $1,292.93 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, LLC B Dwayne E. Da V1 S Custodian of Records Su ri a and sworn to before me on (MAy 9 A� 13 Notary Public Tavana C. Uzzle NOTARY PUBLIC 13 -14397 Commonwealth of Virginia Reg. # 302460 MY Commission Expires Jan. 31, 2017 This conatnun.ication is from a debt collector and is an attempt to collect a debt. Any infonnation obtained will be used for that purpose. GE Capita! BILL of SALE PRA PSCC Fresh — October 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 25` day of June, 2012 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 October 23, 2012, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: /''`�° By: Glenn Marino Glenn Marino Title: _EVP Title: _President Date: Date: General Electric Capital Corporation RFS Holding, L.L.0 By: r By: Glenn Marino Joseph Ressa Title: _Vice President Title: CFO Date: Date: GEMB Lending, Inc. GEM Holding, L.L.0 By: By: Stephen Motta Joseph Ressa Title: _Director Title: _CFO Date: Date: 1 � GE Capital BILL of SALE PRA PSCC Fresh – October 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 25` day of June, 2012 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 October 23, 2012, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Glenn Marino Glenn Marino Title: EVP Title: President Date: Date: General Electric Capital Corporation RFS Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Title: Vice President Title: CFO Date: Date: GEMB Lending, Inc. GEM Holding, L.L.0 By: � —- By: Stephen Motta Joseph Ressa Title: – Director Title: CFO Date: L6 v Date: r GE Capital BILL of SALE PRA PSCC Fresh — October 2012 For value received and in fiulher consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated as of the 25 day of June, 2012 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 October 23, 2012, and as further described in the Agreement. GE Capital Retail Bank ; Monogram Credit Services, L.L.C. By: By: Glenn Marino Glenn Marino Title: EVP Title: President Date: Date: General Electric Capital Corporation RFS Holding, L.L.0 By: By: Glenn Marino Joseph sa Title: Vice President Title: CFO Date: Date: u • Lam: 1 GEMB Lending, Inc. GEM Holding, L.L.0 By; By Stephen Motta Joseph ss Title: _Director Title: CFO Date: Date: t. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F11 L E D-OFF 1�C E THE PROTHONOTP,;111 Sheriff Jody S Smith 2013 JUL —9 AM 10: 13 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PT-CE C',F TYE SHCRIF' PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Suzanne Lindermann 2013-3604 I SHERIFF'S RETURN OF SERVICE 06/27/2013 08:19 PM-Deputy Jason Kinsler, 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: Suzanne Lindermann at 45 Vine Drive, Lower Frankford, Carlisle, PA 17015. JAtON KINSLER, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, June 28,2013 RbNI`4Y R ANDERSON, SHERIFF (C)CountySuite Sheriff.Teleosoft,Inc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES, LLC C:, 120 CORPORATE BLVD c _ NORFOLK, VA 23502 No. 13-3604 CIVIL rnp cy) M M f= Plaintiff =:o -0 --<> v. CIVIL ACTION - LAW © �',CD SUZANNE LINDERMANN D 45 VINE DR CARLISLE PA 17015 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 1304020. 2. Relief was ordered on August 2, 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. Respec WJr., squire By. Robe N. , 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 13-14397 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 t day of August, 2013 by depositing same in the Post Office, first class mail,postage prepaid, addressed as follows: SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 Ro ert 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 13-14397 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 l I 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 J. Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID#94055/201259/312686 • = (3r Portfolio Recovery Associates, LLC ` '� °R( fNO O TA 120 Corporate Blvd _� � '�. � Norfolk,VA 23502 Attorneys for Plaintiff UMSERL A NU COUNT Y PINNS YLVA NIA 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. 13-3604 CIVIL v. SUZANNE LINDERMANN 45 VINE DR CARLISLE PA 17015 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued ithout prejudice. : -s 11 Submitt- 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 13-14397 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. 13-3604 CIVIL v. SUZANNE LINDERMANN 45 VINE DR • CARLISLE PA 17015 • Defendant • CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon SUZ NNE LINDERMANN, by First Class Mail, Postage Pre-Paid, a copy thereof on this° day of ( .---- , 2Q4o: SUZANNE LINDERMANN, 45 VINE DR, CARLISLE ' 1 115 /le 13-14397 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.