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Home My WebLink About13-5021 Supreme Cou t o:f.,Pennsylvania Cour Hof Cnm an Pleas For Prothonotary Use Only: TIME STAMP CI; 4 F y overwh et Docket No: •/^1,' 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 pleadings or other a ers as required by law or rules of court. Commencement of Action: E ® Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: I , PORTFOLIO RECOVERY ASSOCIATES, LLC PAMALA RENNINTGER I 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) i Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) El Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco F1 Toxic Tort -DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration E] Toxic Waste E] Eminent Domain /Condemnation ❑ Declaratory Judgment F Other: E] Ground Rent E] Mandamus p Landlord /Tenant Dispute ❑ Non - Domestic Relations • Mortgage Foreclosure: Residential Restraining Order • Mortgage Foreclosure: Commercial ❑ Quo Warranto • Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal _ ❑ Medical ❑ Other Professional: 13 -58439 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 ,,:� { � 3 O Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC" tFb, R 120 Corporate Blvd' i Norfolk, VA 23502 '` ►i � �d CCUNT Y TELE: 1- 866 - 428 -8102 r- NN S Y LVA N I 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 NO. Plaintiff, V. PAMALA RENNINGER 204 MARION AVE CARLISLE PA 17013 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 -58439 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. p� 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. PAMALA RENNINGER 204 MARION AVE CARLISLE PA 17013 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 -58439 Esta conaunicacion es de un cobrad.or de deudas y es un intent do cobrar una deuda. Cualquier infromacion sera utilizada para ese propos.ito. 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. PAMALA RENNINGER 204 MARION AVE CARLISLE PA 17013 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, PAMALA RENNINGER, is an adult individual with last known address of 204 MARION AVE, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / WAL -MART on July 15, 2010 with account number ************0230 (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 from a debt collector acid is an attempt to collect a debt. Any inl:orniation obtained will be used for that purl .)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 May 27, 2011. 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 $656.28. 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, PAMALA RENNINGER , in the amount of $656.28, plus costs of this action and any other relief as the Court deems just and reaso Carrie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -58439 This communication 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, Mary L. Moore 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 authori Date: JUL. 17 2013 B Mary L. Moore Custodian of Records 13 -58439 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: * * * * * * * * * ** *0230 PAMALA RENNINGER Account Holder: PAMALA RENNINGER 204 MARION AVE CARLISLE PA 17013 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / WAL -MART Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *0230 Date Account Opened: July 15, 2010 Date of Last Payment: May 27, 2011 Date of Charge Off: January 23, 2012 Balance at Purchase: $656.28 Purchase Date: February 29, 2012 Balance at Charge -Off: $656.28 Less Payments: $.00 Balance Due: $656.28 13 -58439 GECN78 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 Mary L. Moore , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ( "Account Assignee ") which is doing business at Riverside Commerce Center, 120 Corporate Blvd, Norfolk, VA 23502. 1 am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from 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 February 29, 2012. Further, the Account Assignee has been assigned all of the Account Seller's power acid 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 PAMALA RENNINGER ( "Debtor ") to the Account Seller the sum of $656.28 with the respect to account number ending in * * * * * * * * * ** *0230, as of January 23, 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 $656.28 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. P fo 'o Recovery Associates, LLC By: Mary L Moore Custodian of Records JUL 17 2 013 Subscribed and sworn to before me on of , 2013 w, SANDRA A. WHITE NOTARY PUBLIC n G /� REGISTRATION # 9 CJ(� ( � m COMMONWEALTH OF F VIRGI Notary Public MY COMMISSION EXPIRES SEPTEMBER 30, 2013 13 -58439 This communication is from. a debt collector and is an attempt to collect a debt. An.y haformation obtained will be used for that purpose. ... ...... . GECN78 GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20` day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lencling. Inc. By: Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Ser\ ices, L.L.C. By: Title: Glenn Marino -EVP Title: Glenn Marino- President RFS Holding. L.L.C. GEM Holding, L.L.C. By: By: Title: Vishay Gulati -CFO Title: Vishay Gulati -CF-o GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 20` day of December, 2011 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date, and as further described in the Agreement. General Electric Capital Corporation GEMB Lending, Inc. By. By: <= Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: B Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: Title: Vishal Galati -CFO Title: Vishal Galati -CFO i GE Money Bank BILL of SALE PRA Fresh — February 2012 For value received and in fiu 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. General Electric Capital Corporation GEMB Lending, Inc. By: By: Title: Glenn Marino -Vice President Title: Stephen Motta- Director GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Title: Glenn Marino -EVP Title: Glenn Marino - President RFS Holding, L.L.C. GEM Holding, L.L.C. By: By: . Title: yaW ;t� - 7C��+� I _ Title: )�ItLi Z _ �7 Walmart .' Save money. Live better. Walmart PAMALA C RENNINGER Visit us at e: 1-BO -641- credit Credit Card Account Number. —0230 Customer Service: 1- 800.641 -4526 Summary of Account Activity Payment Information Previous Balance $656.28 New Balance - Other Credits $0.00 $656.28 Amount Past Due $0.0 New Balance $0.00 Total Minimum Payment Due $199.00 0 Credit Limit Payment D ue Date 02/15/2012 $500 Late Payment Warning:lf we do not receive your minimum Available Credit $0.00 Cash Advance /Quick Cash Limit $100 payment $3 the date listed above, you may have to pay a late Available Cash fee up to $35.00. $0.00 Statement Closing Date 01/23/2012 Days in Billing Cycle 32 [Tran ansaction Summary Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount 23 01/23 F91120OD700999990 CHARGE OFF ($456.68) ACCOUNT - PRINCIPALS 23 01/23 F91120OD700999990 CHARGE OFF ACCOUNT "FINANCE ($199.60) CHARGES` FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 01/23 01123 INTEREST CHARGE ON PURCHASES 01/23 01/23 INTEREST CHARGE ON CASH $0.00 $0.00 ADVANCES TOTAL INTEREST FOR THIS PERIOD $0.00 2012 Totals Year -To -Date Total Fees charged in 2012 $0.00 Total Interest charged in 2012 $0.00 Total Interest Paid in 2012 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APR)s the annual interest rate on your account. Type of Balance Expiration Plan Annual Percentage Balance Subject to Interest Charge Regular Purchases &Cash Date Type Rate Interest Rate NA REG 22.90% Advances $0.00 $0.00 Cardholder News and Information If your account has a deferred interest promotion and you would like us to apply a payment on your account to a specific balance, please call Customer Service to discuss options that may be available. PAYMENT DUE BY 5 P M (ET) ON THE ni iF nor NOTICE: We may convert your payment into an electronic debit. See reverse for details. Billing Rights and other important information. 5404 BFII 1 5 AGE i of 1 20 120123 Z X P 9112 3100 0201 OlUD5409 Detach and mail this portion with your check. Do not include any correspondence with your check. — I Walmar Account Number: -0230 �$ a , Total Minimum Amount Payment Due Overlimit New Balance Save money. Live better. Payment Due Past Due Date Amount $199.00 $0.00 02/15/2012 $0.00 $0.00 Payment Enclosed: $ ❑ F] El El ❑ FIE] Please IIIIIIIIIUIIIIII�II�IIIIIIIII�IIIIII �IIIIIIIIIIIIIIIII �IIII�IIIIIII� IIII�I u se blue or black ink. New address or email? Print changes on back. PAMALA C RENNINGER 204 MARION AVE CARLISLE PA 17013 -1138 Make Payment To: WALMART/GECRB P.O. BOX 530927 ATLANTA, GA 30353-0927 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F11 ETO-0 F lt; Sheriff ! THE PRQTHONOTAPy ��srskp �� Jody S Smith T 1013 SEP _6 AN J I,; O b Chief Deputy Richard W Stewart . CUMBERLAND>- Solicitor wP�i�E Or T"E'�°R'Fr PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Pamala Renninger 2013-5021 SHERIFF'S RETURN OF SERVICE 08/26/2013 05:26 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Nick Renninger, husband, who accepted as"Adult Person in Charge"for Pamala Renninger at 204 Marion Avenue, North Middleton, Carlisle, PA 17013. RYAN BURGETT, SHERIFF COST: $34.78 SO ANSWERS, August 27, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosof;,Inc. 0F; 2013 SEP 16 PM 3R 20 CUMBERLAND T Y James Proctor Law Office,LLC 17 East High Street,Suite 102 Carlisle,PA 17013 717.559.0123/Fox 717-831-1579 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff CIVIL ACTION—LAW V. NO.2013-5021 PAMALA RENNINGER 204 MARION AVE CARLISLE, PA 17013 Defendant PRAECIPE FOR ENTRY OF APPEARANCE 1. To the Prothonotary: Enter my appearance on behalf of Pamala Renninger (Defendant). 2. Papers may be served at the address set forth below. James L. Proctor, Jr. PA I.D. #312202 James Proctor Law Office, LLC 17 East High Street, Suite 102 Carlisle, PA 17013 (717) 559-0123, Fax(717) 831-1579 Date: September 16, 2013 ignature ii-0 F t F! f" I L.i�LJ C fi. 7813 SEP 16 PM 3 23 CUMBERLAND COUNTY PENNSYLVANIA James Proctor Law Office,LLC 17 East High Street,Suite 102 Carlisle,PA 17013 717.559.01231Fax 717-831-1579 ' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff CIVIL ACTION—LAW V. NO. 2013-5021 PAMALA RENNINGER 204 MARION AVE . CARLISLE,PA 17013 . Defendant ANSWER And now comes the Defendant, Pamala Renninger, by and through her attorney, James L. Proctor, Jr., and files the following Answer to the above captioned Complaint in Civil Action, averring as follows: 1. Paragraph 1 is admitted. 2. Paragraph 2 is admitted. 3. Paragraph 3 is admitted. 4. Paragraph 4 is admitted. 5. Paragraph 5 is admitted. 6. Paragraph 6 is admitted, with the exception noted in Paragraph 9 of the Answer. 7. Paragraph 7 is admitted. ti r i 8. Paragraph 8 is admitted. 9. Paragraph 9 is admitted in part and denied in part. Defendant admits to owing $456.68 for purchases she made using the card. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining amounts Plaintiff claims in Paragraph 9 it is owed; therefore,that averment is specifically denied. 10. Paragraph 10 is specifically denied. Defendant has repeatedly requested to arrange a repayment schedule with Plaintiff, but Plaintiff has refused to negotiate such a plan in good faith with Defendant. 11. Defendant admits that the amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Defendant Pamala Renninger prays this Honorable Court dismiss the lawsuit filed by Plaintiff against her. Respectfully submitted, Date: September 16, 2013 J M�%OPR6cfOR, JR. A omey r Defendant Pamal 'nger s r TH0t 2013 SEP 16 PM 3: 20 CUI-IBERLAND COUNTY PENNSYLVANIA VERIFICATION I, James Lewis Proctor, Jr., hereby verify that the statements made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Date: September 16, 2013 J MES LEWIS OCTOR,J . 2913 SE:P 16 PM T 20 CUMBERLAND COUNTY PENNSYLVANIA James Proctor Law Office,LLC 17 East High Street,Suite 102 Carlisle,PA 17013 717.559.01231Fox 717-831-1579 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff CIVIL ACTION—LAW V. NO. 2013-5021 PAMALA RENNINGER 204 MARION AVE CARLISLE,PA 17013 Defendant CERTIFICATE OF SERVICE 1 hereby certify that a true and correct copy of the Answer was served on Plaintiff s Counsel of Record this 16'h day of September 2013 by First Class mail,U.S. Postage Prepaid at the following address: Carrie A. Brown, Esquire Robert N. Polas,Jr.,Esquire Mark R. Garvey, Esquire Portfolio Recovery Associates, LLC 120 Corporate Blvd. Norfolk,VA 23502 . PROCT OR, JR.)MrES for Defendant Pamala nger