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HomeMy WebLinkAbout13-4798 Supreme C_ ; f.Pennsylvania Cour "f Com n Pleas l Aori'roiho"tary e C)nifi� 1 1 S 1'A�1 P CI ve 'et Vbcket No o .... 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 required by law or rules of court. Commencement of Action: Com laint Writ of Summons ® p ❑ El Petition F R Transfer from Another Jurisdiction ❑ 1 s Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC ANTHONY HARGROVE log Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits c Is this a Class Action Suit? []Yes ®No Is this an MDJ Appeal? ❑ 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 ❑ Product Liability (does not include S; mass tort) [I Employment Dispute: c ❑ Slander /Libel /Defamation Discrimination ❑Zoning Board =' ❑ Other: ❑ Employment Dispute: Other ❑ Other: --------------------- 3 .�.... ..:. .t � ❑Other: to .: MASS TORT -----------___--- ❑ Asbestos Tobacco \ ❑ ❑Toxic Tort -DES REAL PROPERTY MISCELLANEOUS F Toxic Tort - Implant El Ejectment E:] Common Law /Statutory Arbitration 0 -By F Toxic Waste ❑ Eminent Domain /Condemnation El Declaratory Judgment l E] Other: E] Ground Rent ❑ Mandamus 1 , ❑ 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 3 ❑ Legal ------------------ --------------------- `'` ❑ Medical 1 ❑ Other Professional: 13 -58377 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 ° ;.' - ' �° �� r F � F I:. - 120 Corporate Blvd Norfolk, VA 23502 TELE: 1- 866 -428 -8102 FAX: (757) 518 -0860 (�1.j �;E� .�iL� � ` C) COUNt T Y Attorneys for Plaintiff ' g s', L VA N 6 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD 2 al NORFOLK, VA 23502 No. �J Plaintiff, V. ANTHONY HARGROVE 401 MEADOW DR CAMP HILL PA 17011 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, 17013 (717) 249 49 -3166 Pennsylvania Lawyer Referral Service 13 -58377 (800) 692 -7375 oo� c V L g6 q 1 y3S°! 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 -0.860 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. ANTHONY HARGROVE 401 MEADOW DR CAMP HILL PA 17011 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 AQUTABAJO. 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 -58377 Esta. comunicacion. es de un cobrador de deudas v es u» intent do cobrar una deuda. Cualquier infromacion sera utilizada 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. ANTHONY HARGROVE 401 MEADOW DR CAMP HILL PA 17011 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, ANTHONY HARGROVE, is an adult individual with last known address of 401 MEADOW DR, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on June 12, 2007 with account number * * * * * * * * * ** *3156 (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 fToXxt a debt collector and is an attempt to collect a debt. Any information obtained will be used for that puil)ose. 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 August 21, 2010. 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 $658.73. I O.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, ANTHONY HARGROVE , in the amount of $658.73, plus costs of this action and any other relief as the Court deems just and reasonable.. Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -58377 Th.i.s corn.111 rtication is From a debt collector and is an attempt to collect a debt. Any i.ni:ormation obtained will. be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Joann F. Cuffee 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. JUL 0 5 2013 Date: c Joann F. Cuffee Custodian of Records 13 -58377 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. .X IBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1- 866 - 428 -8102 f' Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *3156 ANTHONY HARGROVE Account Holder: ANTHONY HARGROVE 401 MEADOW DR CAMP HILL PA 17011 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *3156 Date Account Opened: June 12, 2007 Date of Last Payment: August 21, 2010 Date of Charge Off: February 22, 2011 Balance at Purchase: $658.73 Purchase Date: December 29, 2011 Balance at Charge -Off: $658.73 Less Payments: $.00 Balance Due: $658.73 13 -58377 GECN31 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, —_ Joann E, Cuffe_e_ 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 December 29, 2011. 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 ANTHONY HARGROVE ( "Debtor ") to the Account Seller the sum of $658.73 with the respect to account number ending in * * * * * * * * * ** *3156, as of February 22, 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 $658.73 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. Po olio Recover ssoc' OF B . Cuffee Custodian of Records JUL 05 2013 Subscribed and sworn to before me on _ - -_ of , 2013 Notary Public SANDRA A. WHITE NOTARY PUBLIC REGISTRATION # 7242619 13 -58377 COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES SEPTEMBER 30, 2013 'I "his cola i nunication is - rTom a debt collector and is an attempt. to collect a debt. Any information obtained will. be used for that purpose. 1lllalmart ,*.; Save money. Live better. ANTHONY D HARGROVE Walmart Visit us at walmart.com /credit Credit Card Account Number. —3156 Customer Service: 1- 800 - 641 -4526 Summary of Account Activity Payment Information Previous Balance $658.73 New Balance $0.00 - Other Credits $658.73 Minimum Payment This Period $150.00 New Balance $0.00 Amount Past Due $0.00 Total Minimum Payment Due $150.00 Credit Limit $450 Payment Due Date 02/2512011 Available Credit $0.00 Late Payment Warning: if we do not receive your minimum Cash Advance /Quick Cash Limit $80 payment by the date listed above, you may have to pay a late Available Cash $0.00 fee up to $35.00. Statement Closing Date 02/22/2011 Days in Billing Cycle 25 Transaction Summary Tran Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount 02/22 02/22 F9112001M00999990 CHARGE OFF ($447.70) ACCOUNT - PRINCIPALS 02/22 02/22 F9112001 M00999990 CHARGE OFF ACCOUNT "FINANCE ($211.03) CHARGES` FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 02/22 02/22 INTEREST CHARGE ON PURCHASES $0.00 02/22 02122 INTEREST CHARGE ON CASH $0.00 ADVANCES TOTAL INTEREST FOR THIS PERIOD $0.00 2011 Totals Year -To -Date Total Fees charged in 2011 $0.00 Total Interest charged in 2011 $12.95 Interest Charge Calculation Your Annual Percentage Rate (APR)s the annual interest rate on your account. Annual Percentage Balance Subject to Type of Balance Expiration Date Plan Type Rate Interest Rate Interest Charge Current Transactions Regular Purchases & Cash NA REG 29.90% $0.00 $0.00 Advances Transactions on or before 0 411 112 01 0 Regular Purchases N/A REG 22.90% $0.00 $0.00 Cash Advances N/A REG 22.90% $0.00 $0.00 PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE. NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights and other important information. 5404 ➢FH 1 5 26 110222 Z PAGE 1 of 1 9112 3100 .201 OICS5404 Detach and mail this portion with your check. Do not include any correspondence with your check. — I Walmart Account Number: Total Minimum Amount Payment Due Overlimi New Balance Save money. Live better. 0 Payment Due Past Due Date Amount $150.00 $0.00 02/25/2011 $0.00 $0.00 III Payment Enclosed: 11111111 ❑ . F1 F1 II I�III�I�I I I II III III II �I I� III II �Il P lea s e u se blue or black ink. New address or email? Print changes on back. ANTHONY D HARGROVE 401 MEADOW DR - CAMP HILL PA 17011 -1228 Make Payment To: WALMART /GEMB P.O. BOX 530927 ATLANTA, GA 30353.0927 CustomerService/ Questions: For account information, please call the toll free number on the front of this statement. Unless your name is listed on this statement, your access to information on the account maybe limited. You may also mail questions (but not payments) to: P.O. Box 981470, EI PasoTX 79998.1470. Please includeyour account number on any correspondence you send to us. Payments: Send payments to the address listed on the remittance portion of this statement or pay online. Notice: See below for your Billing Rights and other important information. Telephoning a bout billing errors will not preserve your rights under federal law. To preserve your rights, please write to ou r Billing Inquiries Address, P.O. Box 981470, E Paso, TX 79998 -1470. Purchases, returns, and payments made just prior to billing date may not appear until next month's statement. When you provide a check as payment, you authorize us either to use information from your check to make a one -lime electron is fund transfer from your account or to process the payment as a check transaction. When we use information from your check to make an electronic fund transfer, funds maybe withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. You may choose not to have your payment collected electronically by sending your payment (with the payment stub), in your own envelope — not the enclosed window envelope addressed to: P.O. Box 960098 Orlando FL 32896.0098 and not the Pa ment Address. What To Do If You Think You Find A Mistake On Your Statement Credit Reports And Account Information: If you believe that we have If you think there is an error on your statement, write to us at: reported inaccurate information about you to a consumer reporting GE Money Bank agency, please contact us at P.O. Box 981471, E Paso, TX 79998 -1471, P.O. Box 981470, El Paso, TX 79998 -1470 In doing so, please identiy the inaccurate information and tell us why you believe it is incorrect. If you have a copy of the credit report that includes In your letter, give us the following information: the inaccurate information, please include a copy of that report. We may •Account information: Your name and account number report information aboutycuraccountlo credit bureaus. Late payments, • Dollaramount.. The dollar amount of the suspected error missed payments, or other defaults on your account may be reflected in • Description of Problem. If you think there is an error on your bill, yourcredit report. describewhatyou believe iswrongandwhyyou believe itisa mistake, Balance Subject to Interest Charge Calculation You must contact us within 60 days after the error appeared on your Method 2D (Daily Balance method): statement. We figure the interest charge on your account by applying the periodic You muslnotiyusof any polentialerrorsinwriting .Youmaycall us, but ratetothe "daily balance "of your account foreach day in the billing cycle, if you do we are not required to investigate any potential errors and you We then add the interest to the daily balance. To get the "daily balance" may have to pay the amount in question. we take the beginning be lance of your account each day (which includes While we investigate whether or not there has been an error, the unpaid interest), add any new charges, and applicable fees, and subtract followingaretrue: any payments or credits. This gives us the daily balance. Any daily balance of less than zero will be treated as zero. A separate daily • We cannot try to collect the amount in question, or report you as balance will be calculated for each balance type on your account. The delinquent on that amount. balance(s) shown in the Interest Charges section of this statement is the • The charge in question may remain on your statement, and we may sum of the daily balances for each day in the billing cycle divided by the continue to charge you interest on that amount. But, if we determine that number of days in the billing cycle. we made a mistake, you will not haveto paythe amount in question or any Dail Method 2M interest or other fees related tothat amount. (Average y Balance including current • While you do not have to pay the amount in question, you are transactions): responsible forthe remainder of your balance. We figure the interest charge on your account by applying the periodic • We can apply any unpaid amount against your credit limit. rate to the "average daily balance' of your account, To get the "average daily balance" we take the beginning balance of your account each day, Your Rights If You Are Dissatisfied With Your Credit Card which includes any unpaid interest charges from the previous billing Purchases cycle, add any new charges, and applicable fees and subtract any If you are dissatisfied with the goods or services that you have payments or credits. This gives us the daily balance. Then, we add up purchased with your credit card, and you have tried in good faith to all the daily balances for the billing cycle and divide the total by the correct the problem with the merchant, you may have the right not to number of days in the billing cycle. This gives us the "average daily paythe remaining amount dueon the purchase. balance, "which is the balance shown in the Interest Charges section of To use this right, allot the following must be true: this statement. Any average daily balance of less than zero will be 1. The purchase must have been made in your home slate or within 100 treated as zero. A separate average daily balance will be calculated for miles of your current mailing address, and the purchase price must have each balance type on your account. been more than $50. (Note: Neither of these are necessary if your Bankruptcy Notice: If you file bankruptcy you must send us notice, purchasewasbasedonan advertisement wematedloyou ,orifweown including account numberand all information relaledto the proceeding the companythat sold you the goods or services.) to the following address: GE Money Bank, Attn: Bankruptcy Dept., P.O. 2. You must have used your credit card for the purchase. Purchases Box 103104, Roswell, GA30076. made with cash advances from an ATM or with a check that accesses Your account Is owned and serviced by GE Money Bank. your credit card account do not quality. 3. You must not yet have fully paid forthe purchase. Hearing Impaired: TDD users call 1- 800 - 444 -1732. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writingat: GE Money Bank P0. Box 981470, El Paso, TX 79998 -1470 While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Information About Payments: You may pay more Man the Total Minimum Payment at any time. Payments received after 5:00 PM (ET) on any day will be credited as of the next day. Credit to your Account may be delayed up to five days if payment (a) is not received at the Payment Address, (b) is not made in U.S. dollars drawn on a U.S. financial institution located in the U.S., (c) is not accompanied by the remittance coupon attached to your statement, (d) contains more than one payment or remittance coupon, (e) is not received in the remittance envelope provided or (I) includes staples, paperclips, tape, a folded check, or correspondence of any type. Conditional Payments All written communications concerning disputed amounts, including any check or other payment instrument that: (i) indicates that the payment constitutes "payment in full" or is tendered as full satisfaction of a disputed amount. or (ii) is tendered with other conditions or Imitations ('Disputed Payments "), must be mailed or delivered to us at P.O. Box 981470, El Paso, TX 79998 -1470, Credits To YourAccount: An amount shown in parenthesis or preceded by a minus ( -) sign is a credit or credit balance unless otherwise indicated. Credits will be applied to your previous balance immediately upon receipt, but will not satisfy any required payment that may be due. 01 CS5404 - 3 - 06/23/2010 This is an attempt to collect a debt and any information obtained will be used for that purpose. "By providing a telephone number on your account, you consent to GE Money Bank and any other owner or servicer of your account contacting you about your account, including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system and /or an artificial or prerecorded voice when contacting you, even if you are charged forthe call underyour phone plan. For changes of address, phone number and /or email, please check the box and print the changes below. Name Street Address City State, ❑ Zip Phone # E -mail Home Phone # Business Phone # 'Cell # or other phone If we Email Address can use to contact you By providing your email address, you agree to receive email communications about your account and also give permission for us to share your email address to Walmart. FR833282333_WALMART CREDIT CARD T &C PLCC PDF 5/12 GE CAPITAL RETAIL BANK SECTION 1: RATES AND FEES TABLE WALMART® CREDIT CARD ACCOUNT AGREEMENT PRICING INFORMATION Interest Rates and Interest Charges Annual Percentage Rate The APR for purchases is the prime rate plus 19.65 %. (APR) for Purchases This APR will vary with the market based on the Prime Rate. How to Avoid Paying Your due date is at least 23 days after the close of each billing cycle. We will not charge Interest you any interest on purchases if you pay your entire balance by the due date each month. Minimum Interest Charge If you are charged interest, the charge will be no less than $1.00. Penalty Fees • Late Payment Up to $35 How We Will Calculate Your Balance: We use a method called "daily balance ". See your credit card account agreement on the next page for more details. SECTION II: RATES, FEES AND PAYMENT INFORMATION WALMART® CREDIT CARD ACCOUNT AGREEMENT 1 How Interest is Calculated Your Interest Rate The APR for purchases is the prime rate plus 19.65 %. We use a daily rate to calculate the interest on the balance on your account each day. The daily rate for purchases is the APR times 1/365. As of September 1, 2011 the daily rate for purchases was .06274% (APR 22.90 %). Interest will be imposed in amounts or at rates not in excess of those permitted by applicable law. Daily Rates May Vary. The APR and the daily rate on your account vary with the market based on the prime rate. The Prime Rate for a billing cycle is the highest bank prime loan rate published in The Wall Street Journal in its Money Rates section on the 15th day (or the next business day if the 15th day is not a business day) of the calendar month preceding the first day of the billing cycle. If the prime rate increases, the daily rate and APR will increase. As a result, interest, your total minimum payment and the number of payments it would take you to pay off your account balance may increase. We apply any change in rates because of a prime rate change to your entire account balance. A change in the prime rate will take effect on the first day of the first billing cycle after the change. We may select a new interest rate index if the prime rate is not available. When We Charge Interest We charge interest on your purchases from the date you make the purchase until you pay the purchase in full. See exceptions below. • We will not charge you interest during a billing cycle on any purchases if: 1. You had no balance at the start of the billing cycle; OR 2. You had a balance at the start of the billing cycle and you paid that balance in full by the due date in that billing cycle. • We will credit, as of the start of the billing cycle, any payment you make by the due date that we allocate to purchases if: 1. You had no balance at the start of the previous billing cycle; OR 2. You had a balance at the start of the previous billing cycle and you paid that balance in full by the due date in the previous billing cycle. How We Calculate Interest We figure the interest charge on your account separately for each balance type. We do this by applying the daily rate to the daily balance for each day in the billing cycle. A separate daily balance is calculated for the following balance types, as applicable: purchases and balances subject to different interest rates, plans or special promotions. See below for how this works. 1. How to get the daily balance. We take the starting balance each day, add any new charges and fees, and subtract any payments or credits. This gives us the daily balance. Credit insurance premiums and debt cancellation fees, if any, are not included in the daily balance. Late payment fees are treated as new purchases. 2. How to get the daily interest amount. We multiply each daily balance by the daily rate that applies. 3. How to get the starting balance for the next day. We add the daily interest amount in step 2 to the daily balance from step 1. 4. How to get the interest charge for the billing cycle. We add all the daily interest amounts that were charged during the billing cycle. We charge a minimum of $1.00 of interest in any billing cycle in which you owe interest. This charge is added proportionately to each balance type. How Fees Work Late Payment Fee We will charge this fee if we do not receive the total minimum payment due on your account by 5 p.m. (ET) on the due date. This fee is equal to: 1. $25, if you have paid your total minimum payment due by the due date in each of the prior six billing cycles. OR 2. $35, if you have failed to pay your total minimum payment due by the due date in any one or more of the prior six billing cycles. The late payment fee will not be more than the total minimum payment that was due. Minimum Payment Calculation Your total minimum payment is calculated as follows. 1. The greater of: • $25, or $35 (which includes any past due amounts) if you have failed to pay the total minimum payment due by the due date in any one or more of the prior six billing cycles. OR • The sum of: a. Any past due amounts; PLUS b. 1/24th of your new balance shown on your billing statement; PLUS c. Any payment due in connection with a special promotional purchase with a unique payment calculation. OR 2. If you are charged a late payment fee during a billing cycle, for each of the next four months we will make the following calculation as long as you make at least the total minimum payment as shown in section 1 above. We will calculate if the total of your payments is at least equal to the sum of the following: (A) the interest billed on your statement each month, plus (B) 1 % of the new balance shown on your billing statement each month, plus (C) the late payment fee that was assessed in the billing cycle before the four month period. If for the four month period the sum of your payments is not at least equal to the sum of A, B and C, then your total minimum payment for future billing cycles will be the greater of: • The minimum payment calculation shown in section 1 above. OR • The sum of: a. 1 % of your new balance shown on your billing statement plus interest and late payment fees charged in the current billing cycle; PLUS b. Any past due amounts; PLUS c. Any payment due in connection with a special promotional purchase with a unique payment calculation. We round up to the next highest whole dollar in figuring your total minimum payment. Your total minimum payment will never be more than your new balance. Special Promotional Financing Offer Information At times, we may offer you special financing promotions for certain transactions ( "special promotions "). The terms of this Agreement apply to any special promotions. However, any special promotional terms that are different than the term in this Agreement will be explained on promotional advertising or other disclosures provided to you. Below is a description of certain special promotions that may be offered: • No Interest for 6 Months For each promotion, if the promotional balance is not paid in full within the promotional period, • No Interest for 12 Months interest will be imposed from the date of purchase at the APR that applies to your account when the promotional purchase is made. • No Interest for 18 Months At the time your account is opened, this is a variable APR of 22.90 %. This APR will vary with • No Interest for 24 Months the market based on the prime rate. When you make a qualifying purchase under one of these promotions, no interest will be assessed on the purchase if you pay the following (the "promotional balance ") in full within the applicable promotional period: (1) the promotional purchase amount, and (2) any related optional credit insurance /debt cancellation charges. If you do not, interest will be assessed on the promotional balance from the date of the purchase. Minimum monthly payments are required. Regular account terms apply to non - promotional purchases and, after promotion ends, to promotional purchases. Offers are subject to credit approval. These promotional offers may not be available at all times for all purchases. Please see any special promotion advertising or other disclosures provided to you for the full terms of any special promotion offered. SECTION III: STANDARD PROVISIONS WALMART® CREDIT CARD ACCOUNT AGREEMENT ABOUT THE CREDIT CARD ACCOUNT AGREEMENT This Agreement. This is an Agreement between you and GE Capital Retail Bank, 170 Election Road, Suite 125, Draper, UT 84020, for your credit card account shown above. By opening or using your account, you agree to the terms of the entire Agreement. The entire Agreement includes the four sections of this document and the application you submitted to us in connection with the account. These documents replace any other agreement relating to your account that you or we made earlier or at the same time. Parties To This Agreement. This Agreement applies to each accountholder approved on the account and each of you is responsible for paying the full amount due, no matter which one uses the account. We may treat each of you as one accountholder and may refer to each of you as "you" or "your". GE Capital Retail Bank may be referred to as "we", "us" or "our ". Changes To This Agreement. We may change, add or delete terms of this Agreement, including interest rates, fees and charges. Special Promotions. The terms of this Agreement apply to any special promotion. However, any special promotional terms that are different than the terms in this Agreement will be explained on promotional advertising or other disclosures provided to you. HOW TO USE YOUR ACCOUNT /CARD Use Of Your Account. You may use your account only for lawful personal, family or household purposes. You may use your account for purchases from Walmart locations. You may use your credit card to obtain cash loans ( "quick cash advances ") at participating Walmart owned registers (not at registers in leased departments) in Walmart stores. Each quick cash advance must be in increments of $20.00, up to any limit we may set, and may only be obtained if you are making an approved purchase with your credit card. No more than one quick cash advance may be obtained on your account each day. Except as otherwise expressly provided in the Agreement or any applicable offer, a quick cash advance will be treated as a purchase. You Promise To Pay. You promise to pay us for all amounts owed to us under this Agreement. Your Responsibility. Each accountholder will receive a card. You may not allow anyone else to use your account. If you do, or if you ask us to send a card to someone else, you will be responsible for paying for all charges resulting from their transactions. Purchase Limits. To prevent fraud, we may limit the number or dollar amount of purchases you can make in any particular amount of time. We also may decline any particular charge on your account for any reason. Credit Limit. You will be assigned a credit limit and cash advance limit on your account that we may increase or decrease from time to time. If we approve a transaction that makes you go over your credit limit or your cash advance limit, we do not give up any rights under this Agreement and we do not treat it as an increase in either limit. HOW AND WHEN TO MAKE PAYMENTS When Payments Are Due. You must pay at least the total minimum payment due on your account by 5 p.m. (ET) on the due date of each billing cycle. Payments received after 5 p.m. (Eli will be credited as of the next day. You may at any time pay, in whole or in part, the total unpaid balance without any additional charge for prepayment. If you have a balance subject to interest, earlier payment may reduce the amount of interest you will pay. We may delay making credit available on your account in the amount of your payment even though we will credit your payment when we receive it. Payment Options. You can pay by mail, online or at Walmart®. We may allow you to make payments over the phone but we will charge you a fee to make expedited phone payments. Your payment must be made in U.S. dollars by physical or electronic check, money order or a similar instrument from a bank located in the United States. How To Make A Payment. You can pay by mail, online or at a Walmart or Sam's Club store. If you do not, credit of your payment may be delayed up to five days. Your billing statement also explains how information on your check is used. Payment Allocation. We will apply the required total minimum payment to balances on your account using any method we choose. Any payment you make in excess of the required total minimum payment will be applied to higher APR balances before lower APR balances. Applicable law may require or permit us to apply excess payments in a different manner in certain situations, such as when your account has a certain type of special promotion. - -- -- - -- - - - -1- _ .. - T— . - -_ .. - _ —_ . _..... �__, INFORMATION ABOUT YOU Using And Sharing Your Information. When you applied for an account, you gave us and Wal -mart Stores, Inc. information about yourself that we could share with each other. Wal -mart Stores, Inc. will use the information in connection with the credit program and for things like creating and updating its records and offering you special benefits. More information about how we use and share information is set forth in the privacy policy for your account. Address /Phone Change. You agree to tell us right away if you change your address or phone number(s). We will contact you at the address or phone number in our records until we update our records with your new address or phone number. Consent To Communications. You consent to us contacting you using all channels of communication and for all purposes. We will use the contact information you provide to us. You also consent to us and any other owner or servicer of your account contacting you using any communication channel. This may include text messages, automatic telephone dialing systems and /or an artificial or prerecorded voice. This consent applies even if you are charged for the call under your phone plan. You are responsible for any charges that may be billed to you by your communications carriers when we contact you. Telephone Monitoring. For quality control, you allow us to listen to and /or record telephone calls between you and us. IMPORTANT INFORMATION ABOUT YOUR ACCOUNT Closing Your Account. You may close your account at any time by sending a letter to the address shown on your billing statement or calling customer service. We may close your account at any time, for any reason. If your account is closed, you must stop using ft. You must still pay the full amount you owe and this Agreement will remain in effect until you do. Collection Costs. If we ask an attorney who is not our salaried employee to collect your account, we may charge you our collection costs. These include court costs and reasonable attorneys' fees. Credit Bureau Reporting. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be shown in your credit report. Tell us if you think we reported wrong information about you to a credit bureau. Write to us at P.O. Box 965024, Orlando, FL 32896 -5024. Tell us what information is wrong and why you think it is wrong. If you have a copy of the credit report that includes the wrong information, send us a copy. Default. You are in default if you make a late payment, do not follow any other term of this Agreement or become bankrupt or insolvent. If you default or upon your death, we may (a) request payment of the full amount due right away, (b) take legal action to collect the amounts owed, and /or (c) take any other action allowed. Disputed Amounts. The billing rights summary in section IV of this Agreement describes what to do if you think there is a mistake on your bill. If you send us correspondence about a disputed amount or payment, you must send it to the address for billing inquiries. We do not give up any rights under this Agreement if we accept a payment marked "payment in full" or given with any other conditions or limitations. Unauthorized Use. If your card is lost, stolen or used without your consent, call us immediately at 1- 877 - 294 -7880. You will not be liable for unauthorized use on your account, but you will be responsible for all use by anyone you give your card to or allow to use your account. IMPORTANT INFORMATION ABOUT THIS AGREEMENT Assignment. We may sell, assign or transfer any or all of our rights or duties under this Agreement or your account, including our rights to payments. We do not have to give you prior notice of such action. You may not sell, assign or transfer any of your rights or duties under this Agreement or your account. Enforceability. If any part of this Agreement is found to be void or unenforceable, all other parts of this Agreement will still apply. Governing Law. Except as provided in the Resolving a Dispute with Arbitration section, this Agreement and your account are governed by federal law and, to the extent state law applies, the laws of Utah without regard to its conflicts of law principles. This Agreement has been accepted by us in Utah. Waiver. We may give up some of our rights under this Agreement. If we give up any of our rights in one situation, we do not give up the same right in another situation. RESOLVING A DISPUTE WITH ARBITRATION PLEASE READ THIS SECTION CAREFULLY. IF YOU DO NOT REJECT IT, THIS SECTION WILL APPLY TO YOUR ACCOUNT, AND MOST DISPUTES BETWEEN YOU AND US WILL BE SUBJECT TO INDIVIDUAL ARBITRATION. THIS MEANS THAT. (1) NEITHER A COURT NOR A JURY WILL RESOLVE ANY SUCH DISPUTE; (2) YOU WILL NOT BE ABLE TO PARTICIPATE IN A CLASS ACTION OR SIMILAR PROCEEDING; (3) LESS INFORMATION WILL BE AVAILABLE; AND (4) APPEAL RIGHTS WILL BE LIMITED. • What claims are subject to arbitration 1. If either you or we make a demand for arbitration, you and we must arbitrate any dispute or claim between you or any other user of your account, and us, our affiliates, agents and /or Wal -mart Stores, Inc. if it relates to your account, except as noted below. 2. We will not require you to arbitrate: (1) any individual case in small claims court or your state's equivalent court, so long as it remains an individual case in that court; or (2) a case we file to collect money you owe us. However, if you respond to the collection lawsuit by claiming any wrongdoing, we may require you to arbitrate. 3. Notwithstanding any other language in this section, only a court, not an arbitrator, will decide disputes about the validity, enforceability, coverage or scope of this section or any part thereof (including, without limitation, the next paragraph of this section and /or this sentence). However, any dispute or argument that concerns the validity or enforceability of the Agreement as a whole is for the arbitrator, not a court, to decide. • No Class Actions YOU AGREE NOT TO PARTICIPATE IN A CLASS, REPRESENTATIVE OR PRIVATE ATTORNEY GENERAL ACTION AGAINST US IN COURT OR ARBITRATION. ALSO, YOU MAY NOT BRING CLAIMS AGAINST US ON BEHALF OF ANY ACCOUNTHOLDER WHO IS NOT AN ACCOUNTHOLDER ON YOUR ACCOUNT, AND YOU AGREE THAT ONLY ACCOUNTHOLDERS ON YOUR ACCOUNT MAY BE JOINED IN A SINGLE ARBITRATION WITH ANY CLAIM YOU HAVE. If a court determines that this paragraph is not fully enforceable, only this sentence will remain in force and the remainder will be null and void, and the court's determination shall be subject to appeal. This paragraph does not apply to any lawsuit or administrative proceeding filed against us by a state or federal government agency even when such agency is seeking relief on behalf of a class of borrowers, including you. This means that we will not have the right to compel arbitration of any claim brought by such an agency. • How to start an arbitration, and the arbitration process 1. The party who wants to arbitrate must notify the other party in writing. This notice can be given after the beginning of a lawsuit or in papers filed in the lawsuit. Otherwise, your notice must be sent to GE Capital Retail Bank, Legal Operation, P.O. Box 29110, Shawnee Mission, KS 66201, ATTN: ARBITRATION DEMAND. The party seeking arbitration must select an arbitration administrator, which can be either the American Arbitration Association (AAA), 1633 Broadway, 10th Floor, New York, NY 10019, www.adr.org, (800) 778 -7879, or JAMS, 620 Eighth Avenue, 34th Floor, New York, NY 10018, www.jamsadr.com, (800) 352 -5267. If neither administrator is able or willing to handle the dispute, then the court will appoint an arbitrator. 2. If a party files a lawsuit in court asserting claim(s) that are subject to arbitration and the other party files a motion with the court to compel arbitration, which is granted, ft will be the responsibility of the party asserting the claim(s) to commence the arbitration proceeding. 3. The arbitration administrator will appoint the arbitrator and will tell the parties what to do next. The arbitrator must be a lawyer with at least ten years of legal experience. Once appointed, the arbitrator must apply the same law and legal principles, consistent with the FAA, that would apply in court, but may use different procedural rules. If the administrator's rules conflict with this Agreement, this Agreement will control. 4. The arbitration will take place by phone or at a reasonably convenient location. If you ask us to, we will pay all the fees the administrator or arbitrator charges, as long as we believe you are acting in good faith. We will always pay arbitration costs, as well as your legal fees and costs, to the extent you prevail on claims you assert against us in an arbitration proceeding which you have commenced. • Governing Law for Arbitration This Arbitration section of your Agreement is governed by the Federal Arbitration Act (FAA). Utah law shall apply to the extent state law is relevant under the FAA. The arbitrator's decision will be final and binding, except for any appeal right under the FAA. Any court with jurisdiction may enter judgment upon the arbitrator's award. • How to reject this section You may reject this Arbitration section of your Agreement. If you do that, only a court may be used to resolve any dispute or claim. To reject this section, you must send us a notice within 60 days after you open your account or we first provided you with your right to reject this section. The notice must include your name, address and account number, and must be mailed to GE Capital Retail Bank, PO Box 965012, Orlando, FL 32896 -5012. This is the only way you can reject this section. SECTION IV: OTHER IMPORTANT INFORMATION WALMART° CREDIT CARD ACCOUNT AGREEMENT This section of the agreement includes state notices, billing rights summary and rewards terms (if applicable) and is not required to be provided as part of the credit card agreement posted online or provided to the CFPB. FR833282333_WALMART CREDIT CARD T &C PLCC PDF 5/12 EXHIBIT A BILL of SALE =Fresh 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 Lendin Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. GE Capital Retail Bank By: Title: Glenn Marino -EVP General Electric Capital Corporation 7 By. Title: Glenn Marino -Vice President GEMB Lending, Inc. By: Title: Stephen Motta- Director Monogram Credit Services, L.L.C. By: Title: Glenn Marino- President 49C .....::.:.:..... :.:..:.:....... . ............. �` EXHIBIT A BILL of SALE =Fresh Far value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20 day of December, 2011 by and between General ]electric Capital Corporation, GE Money Bank, GEMB Lending. Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L,C,, and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. GE Capital Retail Bank By: Title: Glenn Marino -EVP General Electric Capital Corporation By: Title: Glenn Marino -Vice President GEMB Lending, Inc. By: -- Title: Stephen Motta - Director Monogram Credit Services, L.L.C. By: Title: Glenn Marino - President .............. : RFS Hol in L.L.0 t By: Title: GEM olding, L.L.0 By:� Title: 28 -73 ...:.. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ �' � Sheriff ] 1 NE PROT O t I2 q �At3tit, of�.4rant�r�� Jody S Smith 14 2013 AWG 28 AN to-. 31 Chief Deputy � ��� Richard W Stewart CUMBERLAND COUNTY Solicitor Or.r' E"rT"'E`" RIFF PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. 2013-4798 Anthony Hargrove SHERIFF'S RETURN OF SERVICE 08/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Anthony Hargrove, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Served"at 401 Meadow Drive, Wormleysburg Borough, Camp Hill, PA 17011. Deputies were advised by a neighbor that the defendant moved apprxoimately two month prior to this date. Per the Camp Hill Postmaster the defendant moved and left a forwarding address of 139 Royal Terrace, Harrisburg, PA 17103. SHERIFF COST: $44.95 SO ANSWERS, August 26, 2013 RONW R ANDERSON, SHERIFF (ci CountySuite Sheriff,Teloosoft.Im. 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 : ` ° 1 H O N D TA" Norfolk, VA 23502 zon OCT - I Ali 11; 31 Attorneys for Plaintiff CUMBERLAND COUNTY IN THE COURT OF COMMON PLEAS OF iLitgiM COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 13-4798-CIVIL v. ANTHONY HARGROVE 401 MEADOW DR CAMP HILL PA 17011 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respect . ,bmitted, / Robe N. Polas, Jr., Esquire PA Bar#2012,59 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 13-58377 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. 13-4798-CIVIL v. • ANTHONY HARGROVE • 401 MEADOW DR • CAMP HILL PA 17011 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon ANTH NY HARGROVE,by First Class Mail, Postage Pre-Paid, a copy thereof on this day of , 2Q-� to: ANTHONY HARGROVE, 401 MEADOW DR, CAMP HILL 'A 17 11 13-58377 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.