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HomeMy WebLinkAbout13-7393 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: / Cumberland County 13' 13 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the flling and service of leadin s 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 S E Lead Plaintiff's Name: Lead Defendant's Name: CHRISTOPHER TROSTLE C PORTFOLIO RECOVERY ASSOCIATES LLC Dollar Amount Requested: ® within arbitration limits Are money damages requested? X fj� N❑ (Check one) ❑ outside arbitration limits 0 N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? Y,&] X N[ A Name of Plaintiff /Appellant's Attorney: Morris Scott /Syretta Martin ❑ 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 ❑ B er Plaintiff Administrative Agencies 1:1 Malicious Prosecution R Debt Collection: Credit Card Bad of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other B6alyd of Elections ❑ Nuisance Dpt. of Transportation S ❑ Premises Liability Story Appeal: Other E ❑ Product Liability (does not include ❑ Employment Dispute: mass tort) C ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other Zing Board I OF&r: 0 N El Other: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation D®laratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1 11120 2698263 PPTXSCPI Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800 - 850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. CHRISTOPHER TROSTLE AKA CHRIS TROSE 122 E PORTLAND ST MECHANICSBURG PA 17055 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 2 ,:X) C l.? �.. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDQ> Cn YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO =' ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. C. LAWYER REFERRAL SERVICE w y. 32 SOUTH BEDFORD STREET 4 ... CARLISLE, PA 17013 l ©3. q 5 PD w �I �►�038 2698263 PPTCPADI AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267 -2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800 - 850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. CHRISTOPHER TROSTLE AKA CHRIS TROSE 122 E PORTLAND ST MECHANICSBURG PA 17055 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1 . The Defendant(s), CHRISTOPHER TROSTLE , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE MONEY BANK / LOWES IN STORE, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2608.40. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2698263 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), CHRISTOPHER TROSTLE in the amount of $2608.40, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC One o s Attorneys Morris S Attorney I.D. #83587 Syretta Martin At o : -. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: November 25, 2013 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800 - 850 -1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. CHRISTOPHER TROSTLE AKA CHRIS TROSE 122 E PORTLAND ST MECHANICSBURG PA 17055 Defendant(s). AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Cumberland: I, Morris Scott /Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendants) is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. See Defendant(s) Military Status Report pursuant to 50 U.S.C. App. Section 521, 525 which was obtained from the Department of Defense Manpower Data Center ( https: / /www.dmdc.osd.mil /appj /scra /). I also herby certify that the statements made in the foregoing Affidavit of Non - Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, ILLER, LEIBSKER & RE, LLC Dated: November 25, 2013 By: Morris Scott Syretta Martin 2698263 PPTJCAMI (06/28/2013) 1111111111111111111 1111 III 111111 VIII VIII VIII VIII VIII VIII VIII IIII IIII Verification Tiffany Gri am an authorized agent and /or employee of Plaintiff. I am authorized to make this verification on behalf of Plaintiff. The statements of facts set forth in the complaint are true and correct based upon my information and belief and are made subject to the penalities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. i 2698263 PPTXVR 1 I 1111111111111111111 IN Exhibit "A" PPTXEXAI t Find a lower price and EVERYDAY we'll match it PLUS take LOW an additional 10% off PRICE Everyday Low Prices Guare ised at Lowe's 'We lrmmmee our everyday competltive pEms. h you find a lamxr everyday or adaerdsetl price on an iEenA4y1 stock item rt an'f loal rohq mmpetoor teal has dw nem M cock, wa'e Oeat thdrpriee 6y 10 %when you huy Irpn us. Just hdrp us the compmdors current a0. or we'll pll to veriy IDe pemS prlm That you Iwve IouM. CasrvetaNe card and nrry puMases oidr. CompetdmS tlosmut, 5perial order, doconfinued, clearmm, liquidation and damapeE Eems ue excluded hom thB otter. On pemem oN sales, vre wig math die we p ts0 me on otter. Lhnnetl to reasanmla qumdles be hommwnes andanMouse order Cuartnlesta casn and tarty mmnaore. Cunam Mr.umE pdm, Ivwm,ovenides L.oweS eErartlSed prim. Price quanmee nomrn:d a all Lowx's reWl bgtions. IaCOr darpes col product PoetaEafion are exGUdetl from out Driee puaramee Oder m our acmes with an inshlkd Sa4s Propem, YaE store for complete detnl6. Lowe's Credit CHRISTOPHER A TROSTLE Visit us at www.lowes.comlcredit Card Account Account Number 9772 Customer Service: 1-800 -566 -0156 Summary of Account Activity Payment Information Previous Balance $2,608.40 New Balance $0.00 - Payments $0.00 Minimum Payment This Period $651.00 Other Credits $2,608.40 Amount Past Due $0.00 + Purchases/Debits $0.00 Total Minimum Payment Due $651.00 +Fees Charged $0.00 Payment Due Dale 02/22/2011 • Interest Charged $0.00 Late Payment Warning:lf we do not receive your New Balance $0.00 minimum payment by the date listed above, you may have to pay a late fee up to $35.00. Credit Limit $2,050.00 Available Credit $0.00 Statement Closing Date 02/2012011 Days in Billing Cycle 26 Transaction Summary Tran Date Post Date Reference Number/ Description of Transaction or Credit Amount Invoice Number 02120 02120 CHARGE OFF ACCOUNT- PRINCIPALS ($2,021.56) 02120 02/20 CHARGE OFF ACCOUNT `FINANCE CHARGES' ($586.84) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 02/20 02/20 INTEREST CHARGE ON PURCHASES $ TOTAL INTEREST FOR THIS PERIOD $0.00 2011 Totals Year -to -Date Total Fees Charged in 2011 $0.00 Total Interest Charged in 2011 $60.98 _PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other Important information. Detach and mail this portion with your check. Do not include any correspondence with your check. ! I Account Number: 9772 Total Minimum Amount Payment New Balance t Payment Due Past Due Due Date $651.00 $0.00 02/22/2011 1 $0.00 Payment Enclosed: 11 ❑ ❑ ❑ ❑ . ❑ ❑ II�II ��I�IIIII��II��IIIII� Q�I�) ltl� ��I'll�� Please use blue or black ink. New address or email? Print changes on back. CHRISTOPHER A TROSTLE 722 E PORTLAND ST MECHANICSBURG PA 17055 -3351 Make Payment to: LOWE'S/GEMB P.O. BOX 530914 ATLANTA, GA 30353 -0914 ustomerServicelQuestions: oraccoun in ormabon,peasecal t e o reenum anon a non o issta emert. nessyournames is e on this statement, your access to information on the account maybe limited. You may also mail questions (but not payments) lo: P.O. Box 981064 El Paso, TX 79998. 1064. Please include youraccount numberonarrycorrespondenceyou send to us. Payments: Send paymenfsto I headdress listed on the remit portion of this statement or pay online. Notice. See below for your Billing Rights and other important information. Telephoning about billing errors will not preserve your rights under federal l aw. To preserve your rights, please writeto curBilling InquinesAddress. P0. Box 981401, El Paso, TX 79998 -1401. Purchases, returns, and payments made just prior to billing date may not appear until next month's statement. When you provide a check as payment, you authorize useiiherto use information from your check to make a one -time electronic fund transfer from youraccount orIo process the payment as a check transaction. When we use information from yourcheck to make an electronic fund transfer, funds maybe withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. You may choose not to have your payment collected electronically by sending your payment (with the payment stub), in your ow n envelope— not the enclosed window envelope, addressedto:P.O,Box 960097, Orlando, FL32896 .0097 and notthe Payment Address, What ToDolf You Think YouTindA Mistake On YourStatement incorrect. It you have a copy of the credit report that includes the inaccurate If you lhinklhereisanerroronyourstalemenl ,wrilelousaL information, please Include a copy of that report. We may report information GE Money Bank about your account to credit bureaus. Late payments, missed payments, or P.O. Box 981401, El Paso, TX 79998 -1401 otherdefaultsonyouracmurt mayberelecledinyourcredt report. In your letter, give us the following information: Balance Subject To Interest Charge Calculation Account information: Your name and account number. Method 2D (Daily Balance method): We figure the interest charge on Do0aramount The dollar amount of the suspected error your account by applying the periodic rate to the 'daily balance °of your DesrnpfionofProblem: lf you thinkthere isanerroron your bill, describe account for each day in the billing cycle. We then add the interest to the what you believe iswmng and why you believe itisamistake. dailybalance. To get the "daily balance"we take the beginning balance of You must contact us within 60 days after the error appeared on your your account each day (which includes unpaid interest), add any new statement. charges, and applicable fees, and subtract any payments or credits. This You must notify us of any potential errors in writing. You may call us, but if gives us the daily balance. Any daily balance of less than zero will be you do we are not required to investigate any potential errors and you may treated as zero. A separate daily balance will be calculated for each havelopaylheamount inquestion. balance type on yyour account. The balance(s) shown in the Interest While we Investigate whether or not there has been an error, the following Chargesseclionofthis statement is the sum of the daily balances foreach aretrue: day in the billing cycle divided bythe number of days inthe billing cycle. • We cannot try to coped the amount in question, or report you as Method 2M (Average Daily Balance including current transactions): delinquent on thal amount. We figure the interest charge on your account by ?plying the periodic rate • The charge in question may remain on your statement, and we may to the "average daily balance' of your account. To get the 'average daily continue to charge you intereston that amount. But, if we determine that we balance' we take the beginning balance o f your account each day .. which made a mistake, you will not have to pay the amount in question or any includes any unpaid interest charges from the previous billing cycle, add interest crother fees related lothalamount. any new charges, and applicable fees and subtract arry payments or • Whiley oudonot haveto pay the amount in question, you areresporsible credits. This gives us the dally balance Then, we add up all the daily forthe remainderofyour balance. balances forthe billing cycle and divide the total by the number of days in • Wecan apply any unpaid amount against yourcredltlimit. the billing cycle This gives us the 'average dally balance," which Is the YourRightsi fYouArisMsatisfled With YourCrediiCardPurchases balance shown in the Interest Charges section of this statement. Any If you are dissatisfied with the goods or services that you have purchased average daily balance of lessthan zerowill be treated as zero. Aseparate with your credit card, and you have tried in good faith to correct the problem average daily balance will be calculated for each balance type on your with the merchant, you may have the right not to pay the remaining amount account. due on the purchase. Method 3D (Daily Balance excluding current transactions): We figure To usethis right, all of the following must betrue: the interest charge on your account by applying the periodic rate to the 1. The purchase must have been made in your hone state or within 100 'dally balance" of your account for each day in the billing cycle. To gel the miles of your current mailing address, and the purchase price must have 'daily balance' we take the beginning balance of your account each day, beenmorethan$50( Note: Neither of these are necessary ifyourpumhase add any interest and applicable fees and subtract any payments or credits. was based on an advertisement we mailed to you, or if we own thecompary We do not add in any new charges. This gives us the daily balance. Any that soclyou the goods orservices.) daily balance of less than zero will be treated as zero. The balance(s) 2. You must have usedyourcredit card forthe purchase. Purchases made shown in the Interest Charges section of this statement is the sum of the with cash advances from an ATM or with a check that accesses your ored t daily balances for each day in the billing cycle divided by the number of card account do not quality. days in the billing cycle. A separate daily balance will be calculated for 3. You In ustnol haveful each balance type on your account. yet r e m If all of the criteria above are met and you are still dissatisfied wilh the Method 5 (Average Daily Balance excluding current transactions and purchase, contact us in writing at: unpaid interest charges): We figure the interest charge on youraccount GE Money Bank by applying the periodic rate to the 'average daily balance' of your PO Box 981401, El Paso, TX 79998-1401 account. To get the'average daily balance'we takethe beginning balance While we investigate, the same rules apply to the disputed amount as of youraccount each day, add applicable fees and subtract any payments, discussed above. After we finish our investigation, we will tell you our credits and unpaid interest charges from the previous billing cycle. We do decision. At that point, f wethink you owe an amount and you do not pay we up a ll t hed y ybalan rges .T h sglvasus ycle a nddiidet total by mayreport youasdelinquent. up all the daily balances for the billing cycle and divide the total by the Information About Payments: You may number of days in the biting Cycle. This gives us the "average daily y y pay more than the Tofa! balance,' which is the balance shown in the Interest Charges section of Minimum Payment at any time. Payments received after 500PM(ET)on lhisstatemenl. Any average daily balance of less than zero will be treated arty day will be credited as of the next day. Credit to your Account may be as zero. A separate average daily balance will be calculated for each delayed uplofivedaysif payment ( a) is not received at the PaymentAddress, balance type onyouraccount. (b) is not made in U.S. dollars drawn on a U.S. financial institution located in Method 6(Average Daily Balance including currenitransaclions and the U.S., (c) is not accompanied by the remittance coupon attached to your excluding unpaid Interest charges): We figure the interest charge on statement, ( d) contains more than one payment or remittance coupon, (e)is your account by applying the periodic ratetothe'avera dal balance'of not received in the remittance envelope provided or (I) includes slapies, your account. To get the "average daily balance' wetake the beginning paper dips, tape, a folded check, or correspondence of any type. balance of your account each day, add any new charges and applicable Conditional PavmeM.x Al written communications concerning disputed tees and subtract any payments, credits and unpaid interest charges from amounts, including any check or other payment instrument that (i) indicates the previous billing cycle. This gives us the daily balance. Then,weadd that the payment constitutes "payment in full" or is tendered as full up all the daily balances for the billing cycle and divide the total by the satisfaction ofa disputed amount; or(ii )is tendered with other conditions or number of days in the billing cycle. This gives us the *average daily limitations ("Disputed Payments "), must be mailed or delivered to us at P.O. balance,' which is the balance shown in the Interest Charges section of Box 981401. El Paso, TX 79998 -1401. this statement. Any average daily balance of less than zero will be treated Credits To YourAccount. An amount s hewn in parenthesis orprecededby as zero. A separate average daily balance will be calculated for each a minus ( -) sign is a credit or credit balance unless otherwise indicated. balance typeon your account. Credits will be applied to your previous balance immediately upon receipt, Bankruptcy Notice: If you file bankruptcy you must send us notice, butwtl not safslyany required payment that may bedue. including account numberand all information related tothe proceeding tothe Credit Reports And Account Information: If you believe that we have felowing address GE Money Bank, Attn: Bankruptcy Dept., P0. Box reported inaccurate information about you to a consumer reporting agency, 103104, Roswell, GA 30076. Pease contact us at P.O. Box 981400, El Paso, TX 791140D. In doing so, youraccount is ownedand servked byGEMoneyBank please identify the Inaccurate information and tell us wiry you believe t is Nearinglmpalred:TDDuserseali 1- 800 -444 1732. O1CN7009 - 3 - 06/28/2010 This is an attempt to coiled a debt and any information obtained will be used for that purpose. 'By providing a telephone number on my account, I consent to GE Money Bank and any otherowner or servicerof my account contacting me about my account, including using any contact information orcell phone numbers I provide, and I consent to the use of myautomatic telephone dialing system and/or an artificial or prerecorded voicewhen contacting me, even if lam charged forthe call under my phone plan. For changes of address, phone numberandlor email, please check the box and print the changes below. Name Street F1 Address CRY, St, Zip Phone # E -mail Home Phone # Business Phone # `Cell # or other phone # we Email Address can use to contact you By providing your email address, you agree to receive email communications about your account and also give permission for us to share your email address to Lowes. Find a lower price and EVERYDAY we'll match it PLUS take LOW an additional 10% off PRICE Everyday Low Prices Guaranteed at Lowe's 'We guemmee our everyday eompeflM prices. d you flnd a lower everyday or aderdse0 prke on an ldnnia! slack item at wry root recall cgnpeft that has the hem In stock we 'h beat thdr OR by 10°4 when you buy cram us. Just btlr�p us the campdhars radram aq or we'll call to verity the hems peke that you have found. CasNcharp card and airy purciuses any. lbmpethort closeout spedal order, discrondnued,'1 -, liquidation and damaged Hems are euluded from this oher. On percent off nles, vre wig el the compedtoA percent oh Other. Lblhd to reewnabla quantlflee tm homeavmerand --how order quail formsh and can contractors. Current Instore pda, h bwm, ovenldes ILM's advertised price. Price guarantee honored at ell Locus's raah Wool. liner chirps for protect Installation are eeduded from our price guarantee other In our scores with an Installed Sales Program. Vish store for complete details. Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Expiration Annual Balance Subject Interest Balance Type of Balance Date Percentage Rate To Interest Rate Charge Method Regular Purchases NA 26.99% $0.00 $0.00 20 Important Account Information If your account has a deferred interest promotion and you would like us to apply a payment on your account in a different way, please call Customer Service to discuss other options that may be available. Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215- 564 -1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. {3 - 7393 N,,l IPA CHRISTOPHER TROSTLE AKA CHRIS TROSE 122 E PORTLAND ST MECHANICSBURG PA 17055 Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above - captioned matter on behalf of PLAINT �,� t, f PORTFOLIO RECOVERY ASSOCIATES LLC. ;~ wC ?' 61, Papers may be served at the address set forth below:`,: c°, ' ^r Blatt, Hasenmiller, Leibsker & Moore, LLC r `° 1835 Market Street, Suite 501_ Philadelphia, PA 19103 ' c� Telephone Number: 1- 215- 564 -1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: November 25, 2013 By: Z� Morris Scott Attorney Syretta Martin Attorney 2698263 PPTXPEAI (111/18/2013) 1 11111111 11111 IIII 111111 11 111111 VIII VIII VIII VIII VIII VIII 1111 VIII IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1 .11 Sheriff ariitber, Jody S Smith �' Chief Deputy '" 7EIRL A i' ) 1, J+, Richard W Stewart `, S \ N A Solicitor Portfolio Recorvery Associates, LLC vs. Case Number Christopher Trostle 2013-7393 SHERIFF'S RETURN OF SERVICE 12/30/2013 06:07 PM - Deputy Shawn Harrison, being duly sworn according to law -d e r-•uested Complaint & Notice by"personally" handing a true copy to a person representint; t 1'. -e es t• be the Defendant, to wit: Christopher Trostle at 122 E. Portland Street, Mechanicsburg :or"- .h, ec :nicsburg, PA 17055. I r S,irWN • , DEPUTY SHERIFF COST: $39.30 SO ANSWERS, December 31, 2013 RONNN R ANDERSON, SHERIFF e