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Home My WebLink About13-6709 Supreme C Pennsylvania Cour l h f Cnm n Pleas' For _rbt/ev to ,acne Cl Oy1f'r yet > ?ucto� oo 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: � f i ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC ZACHARY KRAMER 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 Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey \a, ❑ 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 X Debt Collection: Credit Card ❑Board of Elections ❑ Nuisance Debt Collection: Other ❑ Dept. of Transportation ``? ❑ Premises Liability __ —_ -- ❑ Statutory Appeal: Other � ❑ Product Liability (does not include mass tort) El Employment Dispute: _— _-- _— _— _ —_ —_— ❑ Slander /Libel /Defamation Discrimination C] Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: ❑ Other: MASS TORT E] Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration F1 Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑Mandamus ❑Other: ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations - - -- .. � [3 Mortgage Foreclosure: Residential Restraining Order \\ \\ ❑Mortgage Foreclosure: Commercial C1 Quo Warranto ❑ Partition ❑Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: �� ❑ Legal --- - - - - -- — ----------------- ❑ Medical — — —_— — ❑ Other Professional: ------------ 14 -08368 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 " j ? : = "C' � €-(0 O TA" ' ' 120 Corporate Blvd Norfolk, VA 23502 2 f) 13 Hri V '1 2 PH 3: 0 5 TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 CUB °IBERLAND COUNTY Attorneys for Plaintiff P E NN SY LVAN I A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD V l No NORFOLK, VA 23502 �C Plaintiff, V. ZACHARY KRAMER 211 MARKET ST APT C NEW CUMBERLAND PA 17070 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 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 14 -08368 n lJ�'v zoui a Cl g l 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. ZACHARY KRAMER 211 MARKET ST APT C NEW CUMBERLAND PA 17070 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 AGENCI .S. 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 14 -08368 11sta comunicacion es de vii cobrador de d.eudas y es un intent do cobrar una deud.a. Cualquier infromacion sera utilizada para ese proposito. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. ZACHARY KRAMER 211 MARKET ST APT C NEW CUMBERLAND PA 17070 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, ZACHARY KRAMER, is an adult individual with last known address of 211 MARKET ST APT C, NEW CUMBERLAND PA 17070. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK / AEO, INC. on November 18, 2011 with account number * * * * * * * * * ** *5073 (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 comizitmication 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 July 16, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / AEO, INC. 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 $4,313.10. 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, ZACHARY KRAMER , in the amount of $4,313.10, 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 14 -08368 This communication is from a debt collector and is an atte ipt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, ItiUa Sp eft aiereby 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: OCT ! 5 2013 B Itina Spellman Custodian of Records 14 -08368 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 9 l Norfolk, VA 23502 Telephone: 1- 866 -428 -8102 Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *5073 ZACHARY KRAMER Account Holder: ZACHARY KRAMER 211 MARKET ST APT C NEW CUMBERLAND PA 17070 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / AEO, INC. Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *5073 Date Account Opened: November 18, 2011 Date of Last Payment: July 16, 2012 Date of Charge Off: February 20, 2013 Balance at Purchase: $4,313.10 Purchase Date: March 26, 2013 Balance at Charge -Off: $4,313.10 Less Payments: $.00 Balance Due: $4,313.10 14 -08368 GECR90 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. GE Capital PRA PLCC Fresh — March 2013 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 this 1P day of December, 2012 by and between General Electric Capital Corporation, GE Capital Retail 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 March 26, 2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. Glenn Marino Glenn Marino Title: EVP Title: President L'25 -13 Date: � ' 2 Date: General Electric Capital Corporation RFS Holding, L.L.0 . By: ��' r By: Glenn Marino Joseph Ressa Title: Vice P esident Title: CFO Date: - Date: '1;.. GEMB Lending, Inc. GEM Holding, L.L,C By: By: Stephen Motta Joseph Ressa Title: Director Title: CFO Date: Date- J GE Capra! PRA PLCC Fresh — March 2013 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 this 13` day of December, 2012 by and between General Electric Capital Corporation, GE Capital Retail 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 March 26, 2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Glenn Marino Glenn Marino Title: EVP Title: President Date: Date: General Electric Capital Corporation RF'S Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Title: Vice President Title: CFO Date: Date: GEMB Lendin , Inc. GEM Holding, L.L.0 r By: By- StephenW6da Joseph Ressa Title: Director Title: CFO Date: 4 1` Date: o � zoc 3 GE Capita! PRA PLCC Fresh — March 2013 For value received and in further consideration of the tnutual:covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated, . as of this 13' day of December, 2012 by and between'. General Electric, Capital, Corporation, GE Capital Retail 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 March 26, 2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: Glenn Marino Glenn Marino Title: EVP Title: President Date: Date: General Electric Capital Corporation RF ]ding* L.L.0 ' . By: By: Glenn Marino Joseph R s Title: Vice President Title: CFO Date: Date: 7. L• l ''� GEMB Lending, Inc. GEM olding L.L.0 . By By: Stephen Motta Joseph R s , ; Title: Director Title: CFO Date: Date: ' q SHERIFF'S OFFICE OF CUMBERLAND CODY�NTY Ronny R Anderson 0F THE- PROTHMOTARY Sheriff Jody S Smith 21,113 NOV 25 Pty 4: 04 Chief Deputy �"y CUMBERLALID COUINTY Richard W Stewart a Solicitor OFFICE OF r ERIT P N N S Y L�If� l Ail Portfolio Recovery Associates, LLC Case Number vs. Zachary Kramer 2013-6709 SHERIFF'S RETURN OF SERVICE 11/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Zachary Kramer, but was unable to locate the Defendant,j.n his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as"Not Found"at 211 Market Street, Apt. C, New Cumberland Borough, New Cumberland, PA 17070.Deputies were advised by a neighbor that the defendant moved out one month ago. Per the New Cumberland Postmaster mail is still delivered to the address provided. SHERIFF COST: $52.21 SO ANSWERS, x 11;:;�122 November 21, 2013 RON14Y R ANDERSON, SHERIFF (c)Counlysuite Sheriff,Teleosott.Inc. ail Carrie A. Brown, Esquire ,Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID #94055/201259/312686 t: Portfolio Recovery Associates, LLC i t z HE FRO THBNO TA I 2014 J�� _� AHD � •, 120 Corporate Blvd Norfolk, VA 23502 E Attorneys for Plaintiff CUMBERLAND COUNTY PENNSYLVANIA 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. 13-6709 CIVIL v. ZACHARY KRAMER 211 MARKET ST APT C NEW CUMBERLAND PA 17070 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. es. -ctfully Submitte•, 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 14-08368 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. 13-6709 CIVIL v. • ZACHARY KRAMER • 211 MARKET ST APT C • NEW CUMBERLAND PA 17070 • Defendant • CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon ZACHARY KRAMER, by First Class Mail, Postage Pre-Paid, a copy thereof on this day of , /03, to: ZACHARY KRAMER, 211 MARKET ST APT C, NEW CUM t •, AND PA 17070 ////ra74, 14-08368 Rob- • '. 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.