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Home My WebLink About13-4841 Supreme C,o >t Q, .,Pennsylvania Cour` f Coms n Pleas " or, allrrt Mary a llr:ly �� 1 N1 3 S.1 A M.1 Ci v et t �, m � CLIMB - County The information collected on this form is used solely 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: Complaint p ❑ Writ of Summons ❑Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking i Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC JENNIFER WILLIAMS Are money damages requested? ®Yes ❑ No Dollar Amount Requested: X within arbitration limits (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? Yes ® No Name of Plaintiff/Appellant's ellant's Attorne Y' Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey PP ❑ 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 r , check the one that NO you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution E] Board of Assessment �s. ❑ Motor Vehicle ❑ Debt Collection: Credit Card E] Board of Elections ❑ Nuisance ® Debt Collection: Other [I Dept. of Transportation H „ ` ❑ Premises Liability — ❑ Statutory Appeal: Other ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: —_— ❑ Slander /Libel /Defamation Discrimination E] Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: y ❑ Other: E MASS TORT — — — s ❑ Asbestos ❑ Tobacco ❑Toxic Tort -DES REAL PROPERTY MISCELLANEOUS El Toxic Tort - Implant F) Ejectment ❑ Common Law /Statutory Arbitration 4 120❑ Toxic Waste E] Eminent Domain /Condemnation ❑ Declaratory Judgment NIM ` Other: ❑ Ground Rent E] Mandamus — - - -- ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ( ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ' ❑ Dental ❑ Other: ❑ Legal — — — - -- -- ❑ Medical �_ w — — ❑ Other Professional: 13 -61624 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 I 1 e- a Portfolio Recovery Associates, LLC M r `� 120 Corporate Blvd A p. Norfolk VA 23502 TELE: 1- 866- 428 -8102 + "f� CO FAX: (757) 518- 0860 Y( VA f A �� Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. Plaintiff, V. JENNIFER WILLIAMS 324 2ND ST ENOLA PA 17025 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 13 -61624 (�� ,B18 3,75 Q c #/ LL This communication is from a debt collector and is an attempt to collect a debt. 1u L A S 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. JENNIFER WILLIAMS 324 2ND ST ENOLA PA 17025 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 13 -61624 Esta core- ua. .).icacion es de un cobrador de deudas y es un. intent do cobrar uiia deuda. Cualquier .i frornaci.on sera utilizada Para ese p.roposito. 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. JENNIFER WILLIAMS 324 2ND ST ENOLA PA 17025 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, JENNIFER WILLIAMS, is an adult individual with last known address of 324 2ND ST, ENOLA PA 17025. 3. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / LOWES on September 7, 2008 with account number * * * * * * * * * ** *5825 (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 conimun:icat.ion is from. a debt collector. and is an attempt to collect a debt. Any information obtained will be used for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on November 6, 2009. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK, F.S.B. / LOWES 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 $867.72. 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, JENNIFER WILLIAMS , in the amount of $867.72, plus costs of this action and any other relief as the Court deems just and reaso Carr e A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -61624 `.fbis con.im.un:i.cat.ion is from. a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry J. AndreW Siereby states that he /she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his /her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: JUL 16 2013 By. Larry J. A ndrews Custodian of Records 13 -61624 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 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 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * * * *5825 JENNIFER WILLIAMS Account Holder: JENNIFER WILLIAMS 324 2ND ST ENOLA PA 17025 Consumer Account Product Code: PVT Issuer: GE MONEY BANK, F.S.B. / LOWES Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *5825 Date Account Opened: September 7, 2008 Date of Last Payment: November 6, 2009 Date of Charge Off: June 11, 2010 Balance at Purchase: $867.72 Purchase Date: June 30, 2011 Balance at Charge -Off: $867.72 Less Payments: $.00 Balance Due: $867.72 13 -61624 GECL52 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. Larry J. Andrews I, the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ( "Account Assignee ") which is doing business at Riverside Commerce Center, 120 Corporate Blvd, Norfolk, VA 23502. 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 MONEY BANK, F.S.B. / LOWES ( "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 30, 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 JENNIFER WILLIAMS ( "Debtor ") to the Account Seller the sum of $867.72 with the respect to account number ending in * * * * * * * * * ** *5825, as of June 11, 2010 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 $867.72 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. Pow Recovery Aso 'a C B y . Larry J. Andrew tustodian of Records 4Notary sw m to before me on of , 2013 --- JUL -" 2013 lic [KIMBE RLY ROCHELLE COLES -MOORE 13 -61624 NOTARY PUBLIC REGISTRATION # 73695 MMO W EAL I H OF VIPR ESA M0 - --- Tbl'S Communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ' GE Money Bank BILL of SALE PRA 180 -day Mid Prime — June 2011 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 the 20 day of December, 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (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, 2011, and as further described in the Agreement. GE Money Bank t By: Title: CFO Retailer Cre(' Services Inc By: ZC Title: President General Electric Capital Corporation By: Title: Vice President ' GE Money Bank BILL of SALE PRA 180 -day Mid Prime — June 2011 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 the 20`" day of December, 2010 by and between General Electric Capital Corporation, a Delaware corporation, GE Money Bank, a federal savings bank, and Retailer Credit Services Inc, a Delaware corporation (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, 2011, and as further described in the Agreement. GE Money Bank By: Title: CFO Retailer Credit Services Inc By: Title: President General Electric Capit Corporation 1 By: A Title: Vi bPre den t EC daft 9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F,LED-0FF1i; Sheriff :F T HL Phi 3 H0N0Ttk.R"Y Jody S Smith Chief Deputy 2013.AUG 243 PH 2: 26-Richard W Stewart CUMBERLAND COUNTY Solicitor 0��,C_ .FTF="tiFRIrr PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. 2013-4841 Jennifer Williams SHERIFF'S RETURN OF SERVICE 08/19/2013 04:40 PM - Deputy Shawn Harrison, being duly sworn according to law, served the eq ested Complaint & Notice by handing a true copy to a person representing themselves to Pa.,Yvon e J nes, friend, who accepted as"Adult Person in Charge"for Jennifer Williams at 1324 2nd tr st P nnsboro/W. Fairview, Enola, PA 17025. SH HA SON, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, August 20, 2013 RbNNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Toleosott,Inc. Carrie A. Brown, Esquire ,Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff f Ft ?oil/ SEP o rHoNo �UI� 23 4M 11: PENNS yNo CplIN L VANI, rY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. JENNIFER WILLIAMS 423 4TH ST NEW CUMBERLAND PA 17070 Defendant No. 13-4841 CIVIL PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. 13-61624 Res ly submitted -47 Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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. icarric4A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 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. 13-4841 CIVIL V. JENNIFER WILLIAMS 423 4TH ST NEW CUMBERLAND PA 17070 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End upon JENNIFER WILLIAMS by First Class Mail, Postage Pre -Paid, a copy thereof on this 13-61624 day of , 2014, to: JENNIFER WIT LIAMS 423 4TH CU BERLAN 7070 o ert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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.