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HomeMy WebLinkAbout13-4893 Supreme Co Pennsylvania �t Cour cif tom' ' n Pleas + 7 1 y For Prothonotary Use Only: �t 1? S T:� P Cl E NO ,, et Docket No: CLIMB 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 leadin s or other papers as required by law or rules of court. S Commencement of Action: E ® Complaint [3 Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC DENISE M SPARROW I O Are money damages requested? ® 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 — i mass tort) C3 Employment Dispute: E ❑ Slander /Libel/Defamation Discrimination ❑ Zoning Board i C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T I ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco [] Toxic Tort -DES REAL PROPERTY MISCELLANEOUS � ❑Toxic Tort - Implant [I Ejectment [I Common Law/Statutory Arbitration B El Eminent Domain /Condemnation ❑ Declaratory Judgment F Toxic Waste ❑ Ground Rent ❑ Mandamus El Other: ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations I ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin E PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: — ❑ Legal ❑ Medical ❑ Other Professional: 13 -50491 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 E Portfolio Recovery Associates, LLC ;_';° � ; � ', ; ; N 0 T r; ; 120 Corporate Blvd Norfolk, VA 23502 �:i�'r:'a 19 A IL TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 (''`It�l3 E R� -A��fl CdU ��� � Attorneys for Plaintiff' L�!�3, A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD 11A NORFOLK, VA 23502 NO ' Plaintiff, V. DENISE M SPARROW 591 GENEVA DR 18 MECHANICSBURG PA 17055 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 MAYBE 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 os (717) 249 -3166 ��� � �3 ��•�_ _1 13 -50491 J ��agys� 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. DENISE M SPARROW 591 GENEVA DR 18 MECHANICSBURG PA 17055 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 -50491 Esta co:tuiuiicacion es de un cobrador de deudas y es tui intent do cobrar una deuda. Cuafquier inli 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. DENISE M SPARROW 591 GENEVA DR 18 MECHANICSBURG PA 17055 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, DENISE M SPARROW, is an adult individual with last known address. of 591 GENEVA DR 18, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on May 3, 2009 with account number * * * * * * * * * ** *7508 (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 cominumcatio:n is from a debt collector and is an attempt to collect a debt. Any informat:.ion 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 January 31, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. / SEARS 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 $787.02. 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, DENISE M SPARROW, in the amou $787.02, 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 -50491 This cominu ii.cation 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, Anita Bray 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. Date: JUL 2 9 2013 B Custodian of ecords 13 -50491 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: * * * * * * * * * ** * 7508 DENISE M SPARROW Account Holder: DENISE M SPARROW 591 GENEVA DR 18 MECHANICSBURG PA 17055 Consumer Account Product Code: PVT Issuer: CITIBANK, N.A. / SEARS Assignee: Portfolio Recovery Associates, LLC Account Number: ************7508 Date Account Opened: May 3, 2009 Date of Last Payment: January 31, 2012 Date of Charge Off: September 6, 2012 Balance at Purchase: $787.02 Purchase Date: December 20, 2012 Balance at Purchase: $787.02 Less Payments: $.00 Balance Due: $787.02 13 -50491 SRSQ93 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, Anita Bray , 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 CITIBANK, N.A. / SEARS ( "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 20, 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 DENISE M SPARROW ( "Debtor ") to the Account Seller the sum of $787.02 with the respect to account number ending in * * * * * * * * * ** *7508, as of December 20, 2012 with there being no known un- credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and /or setoffs occurring subsequent to the date of sale, Account Assignee claims the sum of $787.02 as due and owing as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. Portfolio Recovery Associat s, LLC By: Anita Bray , Custodian of Reco s Subscribed and sworn to before me on JU of 3 201 , 2013 Lucretia Ann Etheridge Commonwealth of Virginia Notary Public Notary Public Commission No. 7042513 My Commission Expires 9/30/2014 13 -50491 This conimunicati.on is frorn a debt collector and is an atte.nipt to collect a debt. Any information obtained will. be used for that puil)ose. Contract ID: PRiSP1EMI10712 Document ID: 121312PRISPIE:MBI BILL OF SALE AND ASSIGNMENT THIS BILL Or SALE AND ASSIGNMENT, dated December 20, 2012, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701. East 60th Street North, Sioux Falls, SD 57117 (the "Bank ") to Portfolio Recovery Associates, LLC, organized under the laws of the United States, with its headquarters /principal place of business at 130 Corporate Boulevard, Norfolk, VA 23502 (" Buyer" ). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated November 7, 2012, between Buyer and the Bank (the "Agreement "), the Bank does hereby transfer, sell, assign., convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 and the final electronic file. Citibank, N.A. By: L__ (Signature J Name: Patricia Hall Title: Financial Account Mana>;er PILE 110712 Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Cu arsc rd. Service: SEARS Box SD 57117.6283 /.� //�� SEARS CREDIT CA sea �� SearSCard.COm 6283 Sioux Falls G Sears Card Account Inquiries: 1 - 800 - 917 - 7700 Accouttt.Numtsera 75D8.. Summary of Account Activity Payment Information Previous Balance $753.63 New Balance $799.17 Payments - Minimum Payment Due $371.03 Other Credits -$0.00 Payment Due Date October 2, 2012 Purchases +$0.00 Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charg +$35.00 date listed above, you may have to pay a late fee up to $35. Interest Charg +$10.54 Minimum Payment Warning: If you make only the minimum payment each New Balance $799 period, you will pay more in interest and it will take you longer to pay off your balance. For example: Past Due Amount $ 317 . 13 IfyoGmakenq Youwillpayoffthe AndynttW81, ctlarges using this t alit balance strown tintFifs end up paying an ;'.arid eacri n'iontii you pay statem ®_nt iri abbot y estimated:total of Credit Limit 0.00 Only the minimum payment 2 years $930 Available Credit $ 0.00 It you would like information about credit counseling services, call 1 -877- 337 -8188. Amount Over Credit Limit $299.17 Statement Closing Date 09/05/2012 Next Statement Closing Date 10/05/2012 Days in Billing Cycle 30 1 You must pay your promotional balance of $110.17 in full by 01/02/13 to avoid paying deferred interest charges. You must pay your promotional balance of $24.12 in full by 01/02/13 to avoid paying deferred interest charges. Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. TRANSACTIONS Trans Date Description Reference # Amount FEES 09/02 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 8SE2 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank, N.A. ----------------------------------------------------------------------------------------------------------------------------- + Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. + Sears Card ® tPast Due Amount is included in the Minimum Payment Due. Your. Account Number• . Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 7508 OCTOBER 2, 2012 $799.17 $317.13 $371.03 $ Make Checks Payable to: SEARS CREDIT CARDS PO BOX 183081 DENISE M SPARROW COLUMBUS, OH 43218 -3081 1015 GREEN ST APT 1 HARRISBURG, PA 17102 -2931 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your Letter How to Avoid Paying Interest on Purchases. Your payment due date is at least When we receive your letter, we must do two things: 25 days after the close of each billing cycle. We will not charge you any interest on 1. Within 30 days of receiving your letter, we must tell you that we received purchases if you pay your New Balance by the payment due date each month. your letter. We will also tell you if we have already corrected the error. This is called a grace period on purchases. If you do not pay the New Balance in 2. Within 90 days of receiving your letter, we must either correct the error or full by the payment due date, you will not get a grace period on purchases until explain to you why we believe the bill is correct. you pay the New Balance in full for two billing cycles in a row. We will begin While we investigate whether or not there has been an error: charging interest on cash advances and balance transfers (if available on your g account) on the transaction date. • We cannot try to collect the amount in question, or report you as delinquent on If you have a balance subject to a deferred interest promotion and that promotion that amount. does not expire before the payment due date, that balance (the "excluded The charge in question may remain on your statement, and we may promotional balance ") is excluded from the amount you must pay in full to get a continue to charge you interest on that amount. grace period. However, you must still pay any separately required payment on the While you do not have to pay the amount in question, you are responsible excluded promotion. In billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first, the deferred interest balance will be reduced before any We can apply any unpaid amount against your credit limit. other balance on the account. However, you will continue to get a grace period on After we finish our investigation, one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional If we made a mistake: You will not have to pay the amount in question or any balances in full by the payment due date each billing cycle. interest or other fees related to that amount. In addition, certain promotional offers may take away the grace period on If we do not believe there was a mistake. You will have to pay the amount purchases. Other promotional offers not described above may also allow you to in question, along with applicable interest and fees. We will send you a have a grace period on purchases without having to pay all or a portion of the statement of the amount you owe and the date payment is due. We may then promotional balance by the payment due date. If either is the case, the report you as delinquent if you do not pay the amount we think you owe. promotional offer will describe what happens. if you receive our explanation but still believe your bill is wrong, you must write to How We Calculate Your Balance Subject to Interest Rate. We use a daily us within 10 days telling us that you still refuse to pay. If you do so, we cannot balance method (including current transactions) to calculate interest charges. To report you as delinquent without also reporting that you are questioning your bill. find out more information about the balance computation method and how the We must tell you the name of anyone to whom we reported you as delinquent, and resulting interest charges were determined, contact us at the Account Inquiries we must let those organizations know when the matter has been settled between number on the front. us. Balance Transfers. Balance transfer amounts are included in the "Purchases" line If we do not follow all of the rules above, you do not have to pay the first $50 of in the Summary of Account Activity (if balance transfers are available on your the amount you question even if your bill is correct. account), Transaction Date. The Transaction Date shown on the statement is also the Sale Your Rights if You Are Dissatisfied With Your Credit Card Purchases Date. If you are dissatisfied with the goods or services that you have purchased with Disputes. If you think we reported inaccurate information to a Your credit card, and you have tried in good faith to correct the problem with the Credit Reporting credit bureau wrte us at the Customer Service address shown on the front. merchant, you may have the right not to pay the remaining amount due on the purchase. Report a Lost or Stolen Card Immediately. Call the Account Inquiries number To use this right, all of the following must be true: shown on the front. 1. The purchase must have been made in your home state or within 100 What To Do if You Find A Mistake On Your Statement miles of your current mailing address, and the purchase price must have If you think there is an error on your statement, write to us at the address for been more than $50. (Note: Neither of these are necessary if your billing inquiries and correspondence shown on the front of your statement. purchase e company that sold you the gods or advertisement we mailed to you, or if we own In your letter, give us the following information: 2. You must have used your credit card for the purchase. Purchases made with • Account information: Your name and account number. cash advances from an ATM or with a check that accesses your credit card Dollar amount: The dollar amount of the suspected error. account do not qualify. • Descri of problem: If you think there is an error on your bill, 3. You must not yet have fully paid for the purchase. describe what you believe is wrong and why you believe it is a mistake. If all of the criteria above are met and you are still dissatisfied with the purchase, You must contact us: contact us in writing at the address for billing inquiries and correspondence shows • Within 60 days after the error appeared on your statement. on the front of your statement. • At least 3 business days before an automated payment is scheduled, if you want While we investigate, the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. 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 You must notify us of any potential errors in writin . You may call us, but if you do delinquent. we are not required to investigate any potential errors and you may have to pay the amount in question. EM SMC-TGI- SCC- SCP -HIPs 07/12 T02388 -9351- 5000 - 0021- 9- E- 39 -X - -05 /01/09 97 P E -0 - -7- 402- 0 -0 ---- 09/01/11 -PDGB- August 6, 2012 -0 -0 -V N -- Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account. You may pay all or part of your account balance In-Store Payments (Where Available). Any payment in proper form accepted at any time. However, you must pay, by the payment due date, at least the in-store will be credited as of that day. However, credit availability may be minimum payment due. subject to verification of funds. Not all stores accept payments. Contact your Crediting Payments. If we receive your payment in proper form at our processing local store to see if in -store payments are accepted at that location. Online Payments. Visit the web address on the front and sign up for online facility by 5 re i local time there, it will be credited as a dited as that day. A payment payments. Enrollment may take a few days. If we receive your request to mak received there y proper form after that time will be credited a the next day, a delay an online payment by 5 p.m. Eastern time, we will credit your payment as of Allow 5 to 7 days for payments by regular mail to reach us. There may or m or is that day. If we receive your request to make an online payment after that time of up 5 days in crediting a payment n t to the correct address. The correct receive that is not address for regular ar mail proper f the or we will credit your payment as of the next day. For security reasons, you may L not se nrrl c ourier or unable to pay your entire New Balance with your first online payment. address on the front of the payment coupon. The correct address for c AutoPay Service. If you are enrolled in this service, your payment amount will express mail is the Express Payments Address shown below. be deducted automatically each month on your due date from the bank accou; Proper Form. For a payment sent by mail or courier to be in proper form, you must: you select. • Enclose a valid check or money order. No cash, gift cards, or foreign Pay by Phone Service. You may use this service any time to make a payment currency please. by phone. You will be charged $14.95 if a representative of ours helps expedite • Include your name and account number on the front of your check or money your payment. Call by 5 P.M. Eastern time to have your payment credited as o order. that day. If you call after that time, your payment will be credited as of the nex If you send an eligible check with this payment coupon, you authorize us to day. We may process your payment electronically after we verify your identity. complete your payment by electronic debit. If we do, the checking account will Express Payments. You can send payment by courier or express mail to the be debited in the amount on the check. We may do this as soon as the day we Express Payments Address. This address is: Payments Department, 1500 receive the check. Also, the check will be destroyed. Boltonfield Street, Columbus, OH 43228. Payment must be received in proper form at the proper address by 5 p.m. Eastern time to be credited as of that da Copy Fee. We charge $3 for each copy of a billing statement that dates back 3 All payments received in proper form at the proper address after that time wil months or more. We add the fee to the regular purchase balance. We waive the fee be credited as of the next day. if your request for the copy relates to a billing error or disputed purchase. Page 2 of 4 Account: '' ** * * ** * * *' 7508 TRANSACTIONS cont. Trans Date Description Reference # Amount INTEREST CHARGED 09/05 INTEREST CHARGE ON PURCHASES $ 10'54 TOTAL INTEREST FOR THIS PERIOD $ 10.54 �01 �'jrotals Year�to Date Total Fees Charged in 2012 $267.27 Total Interest Charged in 2012 $64.11 Original Previous Payments Billed New Promo Deferred Trans Trans Promotion and Interest Promotion Monthly Interest Expiration PROMOTIO Amount Date Balance Credits Charges B alance Payment Charges_ Date DEFERRED INT W /PMTS $111.29 12/20/11 $110.17 $110.17 $8.88 $17.34 01/02/ DEFERRED INT W/PMTS $24.37 12/20/11 $24.12 $24.12 $2.00 $3.74 01102/13 INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual interest rate on your account. .. ; ;,; Balance SuB ect to rtteestR�le ;:interest > Gharge Tyke of;Balatice.; pnnualPercentage Rate (APR 1. PURCHASES REGULAR 20.40% D V $629.05 $10.54 DEFERRED INT W /PMTS 20.40% ID "'I DEFERRED INT W /PMTS 20.40% (D"' Variable Rate (D) Dai Page 3 of 4 Account: * * ** * * ** * * ** 7508 Page 4 of 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F_ Sheriff 1' 1 Qt ‘mr4herr. 1 Jody S Smith Chief Deputy Richard W Stewart f Solicitor - � L r _ � ��� 5�J v O G T Y EH";,,'r L VA CIA Portfolio Recovery Associates, LLC Case Number vs. Denise M Sparrow 2013-4893 SHERIFF'S RETURN OF SERVICE 09/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Denise M Sparrow, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 591 Geneva Drive,#18, Upper Allen, Mechanicsburg, PA 17055. Per neighbor, defendant moved out 9 months ago. Put in for a post office check; did not receive any information back from USPS before paper expired. SHERIFF COST: $44.30 SO ANSWERS, September 20,2013 RONIN R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosoft,Inc. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC , ;°,` P R O i N O N,C?T, f 120 Corporate Blvd , ACT Norfolk,VA 23502 8 ji ( j: U ( Attorneys for Plaintiff •Ut D�RLAN COUNTY IN THE COURT OF COMMON PLEAS OFCUM 'WJ AND COUNTY,PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff No. 13-4893 CIVIL v. DENISE M SPARROW 591 GENEVA DR 18 MECHANICSBURG PA 17055 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. R- e• fully Submitte. o.ert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar# 94055 Mark R. Garvey, Esquire PA Bar# 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff 13-50491 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. 13-4893 CIVIL v. DENISE M SPARROW • 591 GENEVA DR 18 •• MECHANICSBURG PA 17055 • Defendant •• CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon DENISE M SPARROW, by First Class Mail, Postage Pre-Paid, a copy thereof on this day of • '(7L- , 200: DENISE M SPARROW, 591 GENEVA DR 18, MEC A f SBURG PA 171 13-50491 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.