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Home My WebLink About13-5115 Supreme C,oraf.,Pennsylvania Cour` of Com n Pleas -t% For Prothonotary Use Only: T f M E S TA %•t P CL 11✓OVer et Docket No: CUMB x , r 7 `'County s1 /s The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of leadin s or other papers as required by law or rules of court. S j Commencement of Action: E ® Complaint E] Writ of Summons C1 Petition C ❑ Transfer from Another Jurisdiction E] Declaration of Taking T Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC BRANDY PLACIDO I Are money damages requested? R Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ®No Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey ❑ Check here if you have no attorney (are a Self- Represented (Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T I ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Ejectment B E] Toxic Tort - Implant ❑Common Law /Statutory Arbitration E] Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Other: El Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: a 13 -57397 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 No. Plaintiff, V. C= BRANDY PLACIDO M rEl 125 MARKET ST FL 1 ST`S ENOLA PA 17025 <)> C Defendant. r- a rn —4 CO 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 $o, 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 n (717) 249 -3166 ��3• r SQ 13 -57397 A 4- a 3 9 Y" pW 7 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. BRANDY PLACIDO 125 MARKET ST FL I 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 -57397 Esta comunicacion es de un cobrador de deudas y es un. intent do cobrar una deuda. Cualquier infirornacion 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. BRANDY PLACIDO 125 MARKET ST FL 1ST 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, BRANDY PLACIDO, is an adult individual with last known address of 125 MARKET ST FL 1 ST, ENOLA PA 17025. 3. It is averred that Defendant was indebted to GE MONEY BANK, F.S.B. / CARE CREDIT on March 9, 2010 with account number * * * * * * * * * ** *6606 (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 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 April 29, 2010. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE MONEY BANK, F.S.B. / CARE CREDIT 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 $656.61. 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, BRANDY PLACIDO , in the amoun $656.61, plus sts f this action and any other relief as the Court deems just and reasonable Carrie A. Brown, Esquire, # 94b55 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -57397 This con. munication 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, Angela Petroccia 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 unworn falsification to authorities. Y Date: JUL 16 2013 B Angela Petrocci�, Custodian of Records 13 -57397 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBI 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 1 ! � 7 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** * 6606 BRANDY PLACIDO Account Holder: BRANDY PLACIDO 125 MARKET ST FL 1ST ENOLA PA 17025 Consumer Account Product Code: PVT Issuer: GE MONEY BANK, F.S.B. / CARE CREDIT Assignee: Portfolio Recovery Associates, LLC Account Number: ************6606 Date Account Opened: March 9, 2010 Date of Last Payment: April 29, 2010 Date of Charge Off: December 2, 2010 Balance at Purchase: $656.61 Purchase Date: December 22, 2010 Balance at Charge -Off: $656.61 Less Payments: $.00 Balance Due: $656.61 13 -57397 GESJ95 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, Angeia PeuOc6a 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. / CARE CREDIT ( "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 22, 2010. 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 BRANDY PLACIDO ( "Debtor ") to the Account Seller the sum of $656.61 with the respect to account number ending in * * * * * * * * * ** *6606, as of December 2, 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 $656.61 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. 4 PI'T' l io Recovery Associates, LLC Angola iroxia B , Custodian of Records Subscr ed and sworn to before me on dp 2 3 2013 2013 No u is - - - 13 -57397 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 8664201312 • 10:42:03 01 -10 -2011 212 EXHIBIT A BILL OF SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Purchase Agreement"), dated as of October 19, 2010 by and between GE Capital Corp. (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 Purchase Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Purchase Agreement), delivered by Seiler to Buyer on each Transfer Date, and as further described in the Purchase Agreement. GE Capital Corp. By: Title: (/P Date: t Cut -off Date Face Value # of Accounts Purchase Purchase Price Price Factor GESJ 95 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 0 f7 F 1 C V Sheriff 'M P:F*�, 1,110 f 4 to Jody S Smith 2013 SEP 16 PM 2: 9 Chief Deputy Richard W Stewart CUMBERLAND COU N*f Y Solicitor QFjFiCG OF TK SKRIP: PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Brandy Placido 2013-5115 I SHERIFF'S RETURN OF SERVICE 09/06/2013 12:18 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Brandy Placido, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 125 Market Street, 1 st Floor, East Pennsboro/W. Fairview, Enola, PA 17025. Deputies were advised that the defendant now resides at 47 S. Baltimore Street, Apt. 8, Dillsburg, PA 17019 which is located in York County. SHERIFF COST: $44.95 SO ANSWERS, September 10, 2013 RbNI`rY R ANDERSON, SHERIFF (ct CountySuite Sheriff,Teleosoft,fnc. 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 F1LED— O r 10E Cr THE f ;OT; 10a?OTAP Zi?i=; 10 3a t 11: 04 CUNDERLAND COU ,TY PEi;;'S YLVAi ElA 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. BRANDY PLACIDO 125 MARKET ST FL 1ST ENOLA PA 17025 No. 13-5115 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. 13-57397 tfully submitted 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. Any information obtained will be used for that purpose. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney lD # 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. 13-5115 v. BRANDY PLACIDO 125 MARKET ST FL 1ST ENOLA PA 17025 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End upon BRANDY PLACID() by First Class Mail, Postage Pre -Paid, a copy thereof on this 13-57397 day , 2014, to: BRANDY PLACIDO 125 MARKE obert 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.