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HomeMy WebLinkAbout13-7338 Supreme C Pennsylvania Cou>r� m n Pleas l ` 1. S. A N 1: Ci t AP 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 ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC HEATHER L GREEN 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 MDJ Appeal? ❑ 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 Se] 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 ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: ❑ Slander /Libel /Defamation Discrimination El Other: ❑ Zoning Board [I Employment Dispute: Other ❑ Other: ---- --- - ----- ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order -- - - - - -- - - -- --- ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition E] Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ------ - - - - -- ❑ Medical ---------------------- ❑ Other Professional: 13 -98295 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 PROTHONOTAIRly 120 Corporate Blvd DEC 13 AN it: 2 Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 C UMBERLAND C0UNTY FAX: (757) 518 -0860 PENNSYLVANIA 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. HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 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 Robtrt 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. HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 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 -98295 Esta cornunicacion es cue un cobrador de deudas y es un intent do cobrar una deuda. Cualquier inf'romacion 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. HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 Defendant. COMPLAINT I . Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, HEATHER L GREEN, is an adult individual with last known address of 638 HOLLY PIKE, MOUNT HOLLY SPRINGS PA 17065. 3. It is averred that Defendant was indebted to MBNA / FIA CARD SERVICES, N.A. / 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and /or for obtaining services. 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 February 15, 2013. 8. Plaintiff is the purchaser, assignee and /or successor in interest MBNA / FIA CARD SERVICES, N.A. / * * * * * * * ** *8462 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 $10,979.41. l O.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, HEATHER L GREEN , in the amount of $10,979.41, 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 -98295 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, Leonar Wolfe 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: OCT 0 9 201 B y : Laawd Wolfe Custodian of Records 13 -98295 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: * * * * * * * ** *3495 HEATHER L GREEN Account Holder: HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 Consumer Account Product Code: CC Issuer: MBNA / FIA CARD SERVICES, N.A. / * * * * * * * ** *8462 Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * ** *3495 Date Account Opened: May 3, 2005 Date of Last Payment: February 15, 2013 Date of Charge Off. September 29, 2012 Balance at Purchase: $11,363.01 Purchase Date: October 29, 2012 Balance at Charge -Off: $11,363.01 Less Payments: $383.60 Balance Due: $10,979.41 13 -98295 BOAQ51 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. BankofAmefica EXHIBIT C BILL OF SALE AND ASSIGNMENT OF LOANS THIS BILL OF SALE AND ASSIGNMENT OF LOANS is made and entered into between PORTFOLIO RECOVERY ASSOCIATES, LLC ( " Purchaser ") and FIA CARD SERVICES, N.A. (" % pursuant to the Loan Sale Agreement dated October 12, 2012 (the " Agyeement ") entered into between Purchaser and Seller. Capitalized terms not defined herein, shall have the same meaning as defined in the Agreement. (a) In consideration of the payments made pursuant to the Agreement and such other good and valuable consideration, the receipt and legal sufficiency of which are hereby acknowledged, Seller does hereby sell, transfer, convey, assign and deliver to Purchaser all of Seller's right, title and interest in and to each and all of the Loans, as included on the electronic file referenced in Schedule 1 of the Loan Agreement, without recourse and without representation or warranty of any type, kind, character or nature, express or implied, except as specifically provided in the Agreement, and subject to Buyer's and Seller's repurchase rights as set forth in the Agreement. (b) Purchaser hereby accepts such sale, transfer, conveyance, assignment, and delivery of the Loans, including without limitation the right to all principal, interest or other proceeds of any kind with respect to the Loans remaining due and owing as of the Cut -Off Date applicable to such Loans. (c) Nothing in this Bill of Sale and Assignment of Loans shall be deemed to modify, limit or amend any of the rights or obligations of Purchaser or Seller under the Agreement. This Bill of Sale and Assignment of Loans shall inure to the benefit of, and be binding upon, the respective, permitted successors and assigns of Seller and Purchaser and shall be governed by and construed and interpreted in accordance with the Agreement and the laws of the State of Delaware, without regard to such state's principles of conflicts of law. (d) This Bill of Sale and Assignment of Loans may be executed by facsimile or electronic transmission in multiple counterparts, each of which shall be an original, but together shall constitute one and the same instrument. IN WITNESS WHEREOF, each party, through its duly authorized officer, has caused this Bill of Sale and Assignment of Loans to be executed in their name this 29`" day of October, 2012. SELLER/ASSIGNOR: BUYER/ASSIGNEE: FIA CARD SERVICES, N.A. PORTFOLIO RECOVERY AS CIATES, LLC 3 jf d By: BY Name: Debra L Pelli Name. Title: Vice President Title: r 2 -pa ap, t,.,. Fam 302,4580938 Fresh Forward Flow 14 / 12 / 12 Bank of America, Asset Saks Deerfield III, 865 Paper MITI Road, Newark, DE 18711 RewdedN +per SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff uzistk� prxd Jody S Smith € ,� ` -2 Ati (` r {r Chief Deputy m Richard W Stewart '3 L` E`� j L a Solicitor OFF C4,r = r FE NNSYLVAN1 +o. Portfolio Recovery Associates, LLC Case Number vs. Heather L Green 2013-7338 SHERIFF'S RETURN OF SERVICE 12/26/2013 01:40 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Heather L Green at 638 Holly Pike, South Middleton, Mt. Holly Springs= '7065. 4/' AOr AO:0!' GUTS L, DEPUTY SHERIFF COST: $35.91 SO ANSWERS, December 27, 2013 RONIV ANDERSON, SHERIFF Michael J. Pykosh, Esquire ID#58851 =`. u ,' , Dethlefs-Pykosh Law Group, LLC J / ,; f! • 2132 Market Street Camp Hill, Pennsylvania 17011 � Ek�',"t'C �p` '�9 "` Telephone—(717)975-9446 u � + P<! Fax—(717)975-2309 mpykosh dplglaw,com Attorney for Defendant PORTFOLIO RECOVERY : COURT OF COMMON PLEAS ASSOCIATES, LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. No: 13-7338 – Civil Term • HEATHER L. GREEN, Defendant • NOTICE TO PLEAD To: Portfolio Recovery Associates, LLC do Mark R. Garvey, Esquire 120 Corporate Blvd. Norfolk, VA 23502 You are hereby notified to plead to the enclosed Preliminary Objections within twenty (20) days from the date of service hereof or a default judgment may be entered against you. Respectfully S •mitted, Date: 1 -- b — l ( Michael J/"'kosh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Attorney for Defendant Michael J. Pykosh, Esquire ID#58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 mpykosh(c dplglaw,com Attorney for Defendant PORTFOLIO RECOVERY : COURT OF COMMON PLEAS ASSOCIATES, LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. No: 13-7338 — Civil Term • HEATHER L. GREEN, Defendant DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Heather L. Green, by and through her Attorneys Dethlefs-Pykosh Law Group, LLC, by Michael J. Pykosh, Esquire, who files his Preliminary Objections to the Plaintiff's Complaint, and avers as follows: 1. Plaintiff filed suit against Defendant alleging that Defendant owes money to Plaintiff arising out of an account issued by MBNA/ FIA CARD SERVICES, N.A. Comp. ¶ 3. 2. The Complaint was filed on December 13, 2013. First Preliminary Objection - Pa. R.C.P. 1028(a)(2) Failure to Conform to Law or Rule of Court 3. Pursuant to Pa. R.C.P. 1028(a)(2), a party may file a Preliminary Objection based upon the failure of a pleading to conform to law or rule of court or inclusion of scandalous or impertinent matter. 4. Plaintiff's Complaint is based upon a contract. 5. Plaintiff asserts a cause of action based upon an Account Stated theory of recovery. 6. An account stated theory of recovery is not applicable in credit card cases. Capital One Bank (USA) NA v Cleverstine, 7 Pa. D&C 5th (Ct. Corn. PI. Centre County 2009). JMMM PC Company v Patricia Stillwagon 2011 Pa. D&C Dec. Lexis 24 (Luzerne County). 7. Plaintiff in pleading account stated cause of action is not permitted to escape pleading requirements otherwise applicable. CitiBank (South Dakota, N.A.) vXenofon Skaboulos, No. 09-8676 (Cumberland County). Second Preliminary Objection - Pa. R.C.P. No. 1028(a)(2) Failure to Conform to Law or Rule of Court 8. Plaintiff is not the original creditor, but rather assignee of the original creditor. Comp. If 3 and 8. Since the Plaintiff's right to maintain an action as an assignee is predicted upon written assignment or agency agreement, that writing must be attached to the Complaint, pursuant to Pa. R.C.P. 1019(i). 9. By failing to attach a complete copy of the assignment and bill of sale of the debt to the Plaintiff, the Complaint does not comply with an express rule of court, in violation of Pa. R.C.P. 1028(a)(2). Remit Corporation v Miller 5 Pa. D&C 5th 43 and Capital One Bank v. Clevenstine, 7 Pa. D&C 5th 153. Third Preliminary Objection- Pa. R.C.P. 1028(a)(2) Failure to Conform to Law or Rule of Court 10.The Complaint avers the existence of some type of contract pertaining to a credit card between the parties. 11.Pursuant to Pa. R.C.P. 1019(h), where a claim asserted is based upon an agreement, the pleading must state whether the agreement is oral or written. 12.Pursuant to Pa. R.C.P. 1019(i), if the agreement is written, it must be attached to the pleading or, if not, the pleader must explain its absence and set forth the substance of the agreement. More specifically, Plaintiff has failed to attach the original Loan/Credit Agreement, including both original and amended terms and conditions applicable to the credit card agreement. Asset Acceptance, LLC v Margaret Madden dated March 18, 2009, No. 2912 of 2008 GD (Fayette County 2009) citing Atlantic Credit & Finance, Inc. v Guiliana, 829 A.2d 340 (Pa. Super. 2003). Plaintiff has also failed to attach "other periodic mailings detailing changes to the terms of the contract Remit Corporation v Miller, 5 Pa. D&C 5th 43, 45 (Centre Cty., 2008). Plaintiff has failed to explain the absence of the written agreement and has failed to set forth the substance of the agreement. Fourth Preliminary Objection - Pa. R.C.P. No. 1028(a)(3) Insufficient Specificity in a Pleading 13.The Complaint contains only a general assertion of the amount the Plaintiff claims is owed by the Defendant. It provided no detail as to the date(s) on which the debts were incurred, the amounts incurred on each date, the dates or amounts of payments, nor dates of accrual and amounts of interest charges and other fees. 14.Pa. R.C.P. No. 1019 and Pa. R.C.P. 1028(a)(3) require that the above detail be included in a Complaint of this type. 15.By not including the requisite detail of the account, the Complaint fails to conform to an express rule of Court. Fifth Preliminary Objection - Pa. R.C.P. 1028(a)(5) Lack of Capacity to Sue 16.Pa. R.C.P. 2002(a) required that an action be brought by the real party in interest. 17.By failing to attach a copy of the necessary writing by which the Plaintiff would become the assignee of the account and thus the real party in interest or an agency agreement, the Plaintiff has failed to conform with the requirements of the aforesaid rule. 18.Plaintiff has not shown standing or capacity to sue Defendant. 19.Since this matter was not brought by the real party in interest it must be dismissed. WHEREFORE, the Defendant respectfully requests that her Preliminary Objections be sustained, and that Plaintiff's Complaint be dismissed with prejudice. Respectf I Su. itted, Date: I ^ M' hael J. Pykosh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 (717)975-9446 Attorney for Defendant Michael J. Pykosh, Esquire ID#58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 mpykosh(a�dplglaw,com Attorney for Defendant PORTFOLIO RECOVERY : COURT OF COMMON PLEAS ASSOCIATES, LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. No: 13-7338 — Civil Term HEATHER L. GREEN, Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant's Preliminary Objections to Plaintiff's Complaint, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Portfolio Recovery Associates, LLC do Mark R. Garvey, Esquire 120 Corporate Blvd. Norfolk, VA 23502 Res•ectfully Submitted, Date: 1 — K, Michael -ykosh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Attorney for Defendant 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 HE r. TH iN.0 3A} 2014 APR 10 AM 10:53 CUMBERLAND COUNTY f7LNN5YLVANIA 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. No. 13 -7338 CIVIL HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above - entitled case as discontinued without prejudice. 13 -98295 Res lly Submitted, ' • •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 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. Po las 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 v. HEATHER L GREEN 638 HOLLY PIKE MOUNT HOLLY SPRINGS PA 17065 Defendant : No. 13-7338 CIVIL CERTIHCATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon MICHAEL J PYKOSH, by First Class Mail, Postage Pre-Paid, a copy thereof on this7& day of 13-98295 , 2014, to: MICHAEL J PYKOSH, 2132 MARKET S , • MP L, PA 170 /,7// Ro - 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.