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HomeMy WebLinkAbout13-4469 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. 13-4469 CIVIL V. WANDA SINKLER • • 65 QUARRY HILL RD . or) rn rri C-1 r- --4 NEWVILLE PA 17241 : PRAECIPE FOR DEFAULT Cfr I cj- Defendant : JUDGMENT — rd- -0 cD-1-1 • P.C3 .7st • Filed on Behalf of Plaintiff Counsel of record for this Party Date: ,2 7 / /1/4 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 13-58010 omA SAU ajA f -LQ 12§- qUal6 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. ,va -di maw 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. 13-4469 CIVIL v. WANDA SINKLER 65 QUARRY HILL RD • NEWVILLE PA 17241 Defendant • • PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant,WANDA SINKLER ,for failure to answer the Complaint. (X) Amount Due $946.26 Less Credits $.00 TOTAL $946.26 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237(Notice for Final Judgment or Decree),I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.231.1,I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. 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 13-58010 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. 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. 13-4469 CIVIL v. WANDA SINKLER 65 QUARRY HILL RD • NEWVILLE PA 17241 . Defendant . NOTICE OF JUDGMENT (X)Notice is hereby given that a judg ent in the above-captioned matter has been entered against you in the amount of$946.26, on )011 i 1 3 • , •, i (X)A copy of all documents filed with the Prothonotary in support of th 'hin ju gme t iskao re attached. By: a , If you have any questions regarding this Notice,please contact the filing party. M ,/ Z Robert N.Polas, Jr.,Esquire, #201259 y 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 13-58010 This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used fix-that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax: (757)518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, August 31,2013 WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. WANDA SINK.LER 13-4469 CIVIL Dear WANDA SINKLER: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, R;c9: tip' fit-: Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 Attorneys for Plaintiff 13-58010 k • This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION—LAW • PORTFOLIO RECOVERY ASSOCIATES,LLC 12 • 0 CORPORATE BLVD • • Plaintiff No. 13-4469 CIVIL v. • WANDA SINKLER • • 65 QUARRY HILL RD • NEWVILLE PA 17241 Defendant TO: WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 DATE OF NOTICE: August 31,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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-CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 'a.. i., a ' is Robert N.Polas,Jr.,Esquire Carrie A.Brown,Esquire Mark R. Garvey,Esquire Attorney ID#201259/94055/312686 Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk,VA 23502 13-58010 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. 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. 13-4469 CIVIL v. • WANDA SINKLER • 65 QUARRY HILL RD NEWVILLE PA 17241 Defendant AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for plaintiff,herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter,and that to the best of my knowledge,information and belief,the above named Defendant,is over 21 years of age;is last known to reside at 65 QUARRY HILL RD NEWVILLE PA 17241 and is not in the military service of the United States or its Allies,or otherwise within the provisions of the Service Members Civil Relief Act and its Amendments. M /(- 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)(866)428-8102 (F) (757)518-0860 13-58010 Attorneys for Plaintiff This communication is a debt collector and is an attempt to collect a debt. Any,information obtained will be used for that purpose. Results as of:Sep-16-2013 04:01:53 SCRA 3.0 �y�,��,�y Report t7f `X#ll �'F rt, Status Repolt ,..r 1 Pursuant to Servicemembers Civil Relief Act .'x Last Name: SINKLER First Name: WANDA Middle Name: Active Duty Status As Of: Sep-16-2013 • On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .?No,- NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA • This response reflects whether the uuti iduator.his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 1/141114,4,4"-`10 Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 13-58010 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have riot been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 04Z3I4B9207AH10 Supreme Co f Pennsylvania Cou f Com on Pleas * b N For Prothonotary Use Only: 1 1 \1 T� '�I A %I P Cl Cove eet Docket No: Vq q CUMBE" hA Count The information collected on this form is used solely for court administration purposes. This forrn does not supplement or replace the filing and service ofpleadings or other papers as required b); law or rules of court. r S Commencement of Action: E ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking I C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC WANDA SINKLER I Are money damages requested? N Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A Is this a Class Action 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 Sel 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 ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) ❑ Employment Dispute: _ ❑ Slander/Libel /Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T - I ❑ Other: 0 MASS TORT N ❑ Asbestos ❑ Tobacco Fl Tort -DES REAL PROPERTY MISCELLANEOUS i B E] Toxic Tort - Implant El 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: 13 -58010 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 (� 7 120 Corporate Blvd � i-; , , Norfolk, VA 23502 � 3 JL 30 :.� . TELE: 1- 866 - 428 -8102 U' FAX: (757) 518 -0860 PE ERL ND rw Attorneys for Plaintiff LVA j�; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC / 120 CORPORATE BLVD NORFOLK, VA 23502 No. J �/ Plaintiff, V. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 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 0JU .9 jn3, 75/4 13 -58010 C" 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. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 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 -58010 Esta com unicacion es de u1i cobrador de deudas y es un. intent do cobrar una deuda. Cualquier inftornacion sera ut:ilixada 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. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 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, WANDA SINKLER, is an adult individual with last known address of 65 QUARRY HILL RD, NEWVILLE PA 17241. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on January 21, 2010 with account number * * * * * * * * * ** *1544 (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 cominuiiication is 1'rorn a debt collector and is an atte - n pt 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 October 26, 2012. 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 $946.26. 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, WANDA SINKLER , in the amount of $94 6, lus costs of this action and any other relief as the Court deems just and reasonable. Carrie A. Brown, Esq ire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -58010 This communication is fa a cleft collector and is an. attempt to collect a debt. ,Nny information. obtained will be used for lh.at puipose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Meryl D reano 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 unswom falsification to authorities. Date: JUN 2 8 2013 By: Meryl Dreano Custodian of Records 13 -58010 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 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1- 866 - 428 -8102 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *1544 WANDA SINKLER Account Holder: WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: ************1544 Date Account Opened: January 21, 2010 Date of Last Payment: October 26, 2012 Date of Charge Off: July 29, 2011 Balance at Purchase: $976.26 Purchase Date: June 28, 2012 Balance at Charge -Off: $976.26 Less Payments: $30.00 Balance Due: $946.26 13 -58010 GECP03 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, Meryl Dreano , 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. I 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 June 28, 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 WANDA SINKLER ( "Debtor ") to the Account Seller the sum of $976.26 with the respect to account number ending in * * * * * * * * * * ** 1544, as of July 29., 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 $946.26 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. 6 P rtfolio Rec ry soci B : Me Dr nO Custodian of Records bscribed and sworn a re me on 04 2 S 2013 2013 Nicole J. Moore tary Public Commonwealth of Virginia Notary Public Commission N 7373912 13 -58010 `'w ' ^' °� My Commission Expires 813112014 This communication Is fron:r a debt collector and is an. atlernpt to collect a debt. Any information obtained will be used for that pur3)ose. GECP03 i GE Capital BILL of SALE PRA 120 -day Mid Prime —,JUNE 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, -rants, 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 June 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB GEMB Lending, Inc. Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: P By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding, L.L.C. GEM Holding, U —C. By: By: Title: Vishal Galati -CFO Title: Vishal Gulati -CFO r r GE Capital BILL of SALE PRA 120 -day Mid Prime — JUNE 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 June 19, 2012, 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: B 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 1 � GE Capital BILL of SALE PRA 120 -day Mid Prime —JUNE 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 June 19, 2012, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, 'Inc. By: B Title: Glenn Marino -Vice President Title: Stephen Motta - Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: B Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Hol L.C. GEM Hold' L.L.C. By: B Title: YX4; / 7t"l L — U 1 Title: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff -7 Jody S Smith Chief Deputy . -y Richard W Stewart tn� Solicitor OFF CE OF THE$ FtFP ,Ct 7�p -n CD,t� Portfolio Recovery Associates, LLC vs. Case Number Wanda Sinkler 2013-4469 SHERIFF'S RETURN OF SERVICE 07/31/2013 10:45 AM- Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Marlon Sinkler, Husband,who accepted as"Adult Person in Charge"for Wanda Sinkler at 65 Quarry Hill Road, Penn Township, Newville, PA 17241. s. JE,rdL46zi, DEPUTY SHERIFF COST: $41.56 SO ANSWERS, August 01, 2013 RbNK9 R ANDERSON, SHERIFF {c)CountySuito Sheriff,Teleosoft.Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 PLAINTIFF vs. NO. 13-4469 CIVIL WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION -MONEY JUDGMENTS TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. s-a " (1) Direct to the Sheriff of CUMBERLAND County,PA; -- rrt G7 "T1 (2) against WANDA SINKLER Defendant(s); (3) and against MEMBERS 1ST FCU Garnishee(s); (11 G3 —0 c; (4) And index this writ r. (A) against WANDA SINKLER Defendant(s) --t t (B) and against MEMBERS 1ST FCU Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the garnishee(s). Specifically describe the property per attached property description. All accounts including but not limited to all savings,checking and other accounts,c• i rcates of deposi s es receivables, collateral, pledges,documents of title, securities, coupons and safe deposit boxes. / (5) Amount Due: $946.26 ignature/ID Number Interest From October 1,2013: $8.56 Robert N. Polas,Jr.,Esq.#201259 (At an interest rate of 6% per year) Print Name Total: $954.82 Plus costs& interest Carrie A. Brown, Esq. #94055 (Total includes post judgment credits) Print Name Mark R. Garvey,Esq. #31286 1 Print Name to D9r l`y 120 Corporate Blvd � } ( , ( „3, cAg- Address V •1 S Li t � Q Norfolk,VA 23502 13-58010 14 -�� t` 1.1 a5 6 \ gW___a)(D/1 I(4- tif EA This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-4469 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC Plaintiff(s) From WANDA SINKLER,65 QUARRY HILL ROAD,NEWVILLE,PA 17241 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: MEMBERS 1sT FCU, 1711 SPRING ROAD,CARLISLE,PA 17013-ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS,CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT,NOTES RECEIVABLES,COLLATERAL,PLEDGES, DOCUMENTS OF TITLE,SECURITIES,COUPONS AND SAFE DEPOSIT BOXES. and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$946.26 Plaintiff Paid$ Interest FROM OCTOBER 1,2013-$8.56(AT AN INTEREST RATE OF 6% PER YEAR) Attorney's Comm. % Law Library$.50 Attorney Paid$190.81 Due Prothonotary$2.25 Other Costs$ Date: FEBRUARY 5,2014 David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : CARRIE A. BROWN, ESQUIRE Address: 120 CORPORATE BLVD. NORFOLK,VA 23502 Attorney for: PLAINTIFF Telephone: 1-866-428-8102 Supreme Court ID No. 94055 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1, ft Sheriff r o O?. 0 I irs •h I i�L��i.J Jody S Smith Chief Deputy 2014 FEB 19 M Richard W Stewart Solicitor -; W w CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Number Wanda Sinkler 2013-4469 SHERIFF'S RETURN OF SERVICE 02/12/2014 10:00 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle, Members Service Rep., 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 him/her. The writ of execution and notice to defendant was mailed on February 14, 20 to nda Winkler at 65 Quarry Hill Road, Newville, PA 17241. I IAM CLINE, DEPU SO ANSWERS, February 14, 2014 RONNR ANDERSON, SHERIFF THE CQURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES, LLC NO. 13-4469 CIVIL ;. C) CORPORATE BLVD NORFOLK, VA 23502 PLAINTIFF , vs. ,- .s' WANDA SINKLER .- "" 65 QUARRY HILL RD cy P ),_. NEWVILLE PA 17241 (s�,y .:-'' DEFENDANT(S) O,Ii ly liS c' '° `. F3 -- ..- INTERROGATORIES TO GARNISHEE -7,r- ? TO: MEMBERS 1ST FCU 1711 SPRING RD CARLISLE, PA 17013 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty(20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information is possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. 13-58010 This communication is from a debt collector and is an attempt to collect a debt. ti's_, Any information obtained will be used for that purpose.. 711111 INTERROGATORIES TO GARNISHEE DEFENDANT(S) -WANDA SINKLER 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s)has in each account. If the Defendant(s)maintains any of these jointly with any other person, or persons, give their name and address. cc-As-qs/64 44,@.s a. 0)( CI r \\ , 3. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. 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 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, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 0 CD 3. 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 funds on deposit,not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. q■J 0 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? 1\j.t 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, including the identification number or other designation of the box or boxes. Include a full description of the content and also the amount of cash among those contents. If the Defendant(s)maintains any of these jointly with any other person or persons give their full name and address. N' 13-58010 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. ?AL OR,PERSONAL PROPERTY: At the time you were served or at any subsequent time, state wh . not the Defendant(s) own any personal property that was in your possession and/or control. If so, inclu le a full description of all personal property giving full value and present location. State also whether or ildt there are any encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s)which are not disclosed in the preceding Interrogatories. If so,please set forth all details concerning those asset(s) and state the reason for the exemption, the amount being withheld under each exemption, the amount of funds in each account, and the entity electronically deposition those funds on a recurring basis. \ 'c 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s)had an interest? If so,please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s)• N o _. 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charge by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. 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) 518-0860 Attorneys for Plaintiff 13-58010 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : No. 13 -4469 CIVIL Plaintiff vs. WANDA SINKLER Defendant vs. MEMBERS 1ST FCU Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the writ of attachment filed a _ ' st the Garnishee only in the above - entitled matter, without prejudice. 13 -58010 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) 518 -0860 Attorneys for Plaintiff avt.4 gq,soPti aft C n This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. bLig 86 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff vs. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 Defendant No. 13-4469 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Dissolve Attachment upon WANDA SINKLER and MEMBERS 1ST FCU, by/it Clq,ss Mail, Postage Pre-Paid, a copy thereof on this 7 day of C 11 , 2014, to: WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 Date: 13-58010 MEMBERS 1ST FCU 1711 Sp d. Car s , P 17013 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FRLTtfONO L'.:, 2J1ii JUN 13 PM 12: 13 CUMBERLAND COUNTY PENNSYLVANIA OFFICE OF THE SHERIFF Portfolio Recovery Associates, LLC vs. Wanda Sinkler Case Number 2013-4469 SHERIFF'S RETURN OF SERVICE 02/12/2014 10:00 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle, Members Service Rep., 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 him/her. The writ of execution and notice to defendant was mailed on February 14, 2014 to Wanda Winkler at 65 Quarry Hill Road, Newville, PA 17241. 06/12/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED. Plaintiffs attorney was able to collect the full amount of the judgment directly from the defendant. SHERIFF COST: $106.84 SO ANSWERS, June 12, 2014 RONNR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teieosofi, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD NORFOLK, VA 23502 v. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 Plaintiff : No. 13-4469 CIVIL Defendant. PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE -ENTITLED CAUSE AS SETTLED AND SATISFIED. Res lly Submitted, 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 13-58010 4s.so?(.L0' cK� AMMO R=11 36.72.9y This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD NORFOLK, VA 23502 v. WANDA SINKLER 65 QUARRY HILL RD NEWVILLE PA 17241 Plaintiff : No. 13-4469 CIVIL Defendant. CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle and Satisfy upon WANDA SINKLER by First Class Mail, Postage Pre -Paid, a copy thereof on this day oi��/ 4 , 2014, to: Date: 13-58010 WANDA SINKLER 65 QUARRY HILL RD NEWVILLE 17241 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) 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.