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Home My WebLink About14-0298 Supreme C of Pennsylvania «tip Cour Com n Pleas C1 oVe et For Prz ion6tattt Use 6 Docket Nok t F: d x CUMBi�' = County I �H 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 papers as required by law or rules of court. Commencement of Action: E IN Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC VICKI GRAMLEY Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits (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. Garve ❑ 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 S ❑ Product Liability (does not include ------------------ E mass tort) - - -- - - - -- - - - -- - - - - - -- ❑ Employment Dispute: -- - -------- ------------- Boar ❑ Slander /Libel /Defamation Discrimination E] Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T, --------------------------- �_ ------------------ --------- ❑ Other: O MASS TORT --------------------------- N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS B ❑ 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 ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ------------------------- -------------------------- ------------------------- ❑ Medical -------------------------- ❑ Other Professional: �' 14 -04182 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 ;,- r. Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 m TELE: 1- 866 - 428 -8102 tttZr; COUNTY FAX: (757) 518 -0860 PE JNS YL VA Nl j� 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. / / ( 1 11/ - , Plaintiff, V. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 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 C�S') 14 -04182 (717) 249 -3166 r a�� a 7U This communication is from a debt collector and is an attempt to collect a ebt. 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. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 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 14 -04182 Esta COMLIIIicacitm es de un cobrador de deudas y es urn intent do cobras' Una deuda. CualgUier inf'roniaclon scra utilizada Mara 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. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 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, VICKI GRAMLEY, is an adult individual with last known address of 458 STONE CHURCH RD, CARLISLE PA 17015. 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 31, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK / LOWE'S 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 $5,990.15. 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, VICKI GRAMLEY , in the unt of $5,990.15, costs of this action and any other relief as the Court deems just and r a ie A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 14 -04182 This communication is from a debt collector and is an attempt to collect a debt. And int brrnation obtained will be used ti3r that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry J . Andrews 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. DEC 1 3 2013 Date: By: Larry J. Andrews Custodian of Records 14 -04182 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: * * * * * * * * * ** *2422 VICKI GRAMLEY Account Holder: VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK / LOWE'S Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *2422 Date Account Opened: May 29, 2003 Date of Last Payment: May 31, 2013 Date of Charge Off: January 28, 2013 Balance at Purchase: $6,256.15 Purchase Date: February 19, 2013 Balance at Charge -Off: $6,256.15 Less Payments: $266.00 Balance Due: $5,990.15 14 -04182 GECR57 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. E Captal BML of SALE PRA PLCC Fresh — February 2013 For value received and in fiuther consideration of the mutual covenants and conditions set forth in the Forward now Receivables. Purchase Agreement (the "Agreement ), dated Las of the. 13 day of December, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lend cling, Inc., Monogram Credit Services, L.L.C., RFS Molding, 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 assigas, 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 can February 19, 2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. Glenn Marino Glenn Marino Title: -,VP Title: _President Date; —/ "� Date: General Electric Capital Corporation RFS Holding, L.L.0 Glenn. Marino Joseph Ressa Title: Vice President Title: -CFO Date: / Date: GENIB Lending, Inc. GEM Holding, L.L.0 By: By: Stephen Motta Joseph Ressa Title: _Director. Title: —CFO Dater Date: GE Capital BILL. of SALE PRA PLCC Fresh -- Febrdary 2013 For value received and in further consideration of the mutual covenants and conditions forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 1P day of December, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding. 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 February 19, 2113, and as fin - ther 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 RFS Holding, L.L.0 BY' -- - --- -- BY` Glenn Marino Joseph Ressa Title: Vice President Title CFO Date: Date: . GEMB Lending, Inc. GEM Holding, L.L.0 By: By Stephen Joseph Ressa Title: Director Title: CFU Date Date: GE Ca pifttl . . . BILL of SALE PRA PLCC Fresh - February► 201:3. 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 I P day of December, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMS 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 February 19, 2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. $y: By: Glenn Marino Glenn Marina Title: EVP Title President Date. Date: General Electric Capital Corporation RFS ing, L.L.0 By: By: Glenn Marino Joseph R s a Title: _Vice President Title: -CFC3 Date: Date: GEMB Lending, Inc. GEM ding, L.L. By: By: Stephen Motta Joseph Res Title: _Director Title: _CFO Date: Date; L(- 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson !;- FiLtC�-0F F ILA. �,, Sheriff � !HE PROTHf31'OTA.F , Jody S Smith 2014 JAN 24 AN 51 Chief Deputy Richard W Stewart CUMiNNSYLVANIA RLAND COUNTY Solicitor =_ ,W r. .. - Portfolio Recovery Associates, LLC vs. Case Number Vicki Gramley 2014-298 SHERIFF'S RETURN OF SERVICE 01/15/2014 01:45 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Mark Gramley, husband, who accepted as"Adult Person in Charge"for Vicki Gramley at 458 Stone Church Road, Lower Frankford, Carlisle, PA 17015. DENKS FRY, DEPU SHERIFF COST: $34.78 SO ANSWERS, r January 16, 2014 RbNW R ANDERSON, SHERIFF u roF. _ .....,. Portfolio Recovery Associates, LLC : IN THE COURT OF COMMON PLEAS OF 120 Corporate BLVD : CUMBERLAND COUNTY, PENNSYLVANIA Norfolk, VA 23502 Plaintiff, : CIVIL ACTION—LAW v. : NO. 2014-298 CIVIL TERM Vicki Gramley r_ 458 Stone Church RD c Carlisle, PA 17015 -D cJ -31 CD ANSWER TO PLAINTIFF'S COMPLAINT o -ri The Defendant, Vicki Gramley, by and through her attorneys, Turo Robinson ttorf'eys' at Law, hereby responds to Plaintiffs Complaint and states the following: 1. Admitted. 2. Admitted. 3. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 4. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 5. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 6. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 7. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 8. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 9. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 10. Defendant is without sufficient knowledge or information to form a belief about the truth of the allegation. 11. This averment is a conclusion of law to which no response is required. WHEREFORE, Defendant respectfully requests that this Court find in favor of Defendant and against Plaintiff and deny the relief requested. Respectfully submitted, TURO ROBINSON Attorneys at Law f 2 tt o Date Daniel L. Puskar, Esquire Supreme Ct. No. 311444 129 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. . r / y Date Vi'ki Gramley Portfolio Recovery Associates, LLC : IN THE COURT OF COMMON PLEAS OF 120 Corporate BLVD : CUMBERLAND COUNTY, PENNSYLVANIA Norfolk, VA 23502 Plaintiff, • : CIVIL ACTION—LAW v. : NO. 2014-298 CIVIL TERM Vicki Gramley 458 Stone Church RD Carlisle, PA 17015 • • CERTIFICATE OF SERVICE I hereby certify that on this day I served a true and correct copy of the foregoing Answer on Plaintiffs Counsel, Carrie A. Brown, Esquire, by depositing same in the United States Mail, first class, postage pre-paid, from Carlisle, Pennsylvania, addressed as follows: Carrie A. Brown, Esquire Portfolio Recovery Associates, LLC 120 Coporate BLVD Norfolk, VA 23502 TURO ROBINSON Attorneys at Law /r-Z- 2 tt-i/29,1 Date Daniel L. Puskar, Esquire Supreme Ct. No. 311444 129 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant Robert N. Polas, Jr., Esquire PA Bar#201259 �1 Carrie Brown,Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates LLC Jr- i {^ ` ' L` 120 Corporate Blvd � �' / "ifgi1,41 ,, - Norfolk, VA 23502 ' ' , 4 TELE: 1-866-428-8102 Cut h , 'frf/0: c FAX: (757) 518-0860 PENN;�l/. F 1+S Attorneys for Plaintiff L A y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES,LLC ( ( , ./ 120 CORPORATE BLVD No. j `( ' D9 ? Cot NORFOLK,VA 23502 Plaintiff, • v. • • VICKI GRAMLEY 458 STONE CHURCH RD •• CARLISLE PA 17015 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 14-04182 �; a {tu 11 d y of 3LLh .Z`D , 114' 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. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 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 0 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 0 GRATIS. Lawyer Referral Service-CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (717)249-3166 14-04182 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier infroinacion 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. VICKI GRAMLEY • 458 STONE CHURCH RD CARLISLE PA 17015 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,VICKI GRAMLEY,is an adult individual with last known address of 458 STONE CHURCH RD, CARLISLE PA 17015. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/LOWE'S on May 29, 2003 with account number************2422 (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 he used for that purpose. z r a • 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 31, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ LOWE'S 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 $5,990.15. 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, VICKI GRAMLEY, in th; am. nt of$5,990.15, . • . costs of this action and any other relief as the Court deems just an. rea„:4 .. - i/ // 'arrie A. Brown,Esquire,#94055 Robert N. Polas, Jr., Esquire,#201259 Mark R. Garvey,Esquire,#312686 Attorneys for Plaintiff 14-04182 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, Larry J. Andrews 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. DEC 3 201 , Date: By: at j. JhW.1i Lry J. Andrews Custodian of Records ar 14-04182 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT 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 : ************2422 VICKI GRAMLEY Account Holder: VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 Consumer Account Product Code: PVT Issuer: GE CAPITAL RETAIL BANK/LOWE'S Assignee: Portfolio Recovery Associates,LLC Account Number: ************2422 Date Account Opened: May 29, 2003 Date of Last Payment: May 31, 2013 Date of Charge Off: January 28,2013 Balance at Purchase: $6,256.15 Purchase Date: February 19,2013 Balance at Charge-Off: $6,256.15 Less Payments: $266.00 Balance Due: $5,990.15 14-04182 GECR57 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 61-6 Capital a BILL of SALE PRA PLCC Fresh-February 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 the 13th day. of December, .2012 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 y defined in the Agreement), delivered by Seller:to:Buyer on February 19, 2013. y y and as further described in the Agreement. GE Capital Retail Bank. Monogram Credit Services,L.L.C. Fty: By: Glenn Marino Glenn.Marino Title: EVF Title:i _ Presideiit, ,. f '`.7 -1.. .: . D a t e --j 3 Late: `�:J General Electric Capital Corporation RFS Holding,L.L.0 By:8 - By: . . Glenn Marino Joseph Ressa Title: Vice President . Title:._CFt3 Date._Vice ` /: Date: GEMB Lending,Inc. GEM Holding,L.L.0 B By Stephen Motto Joseph Ressa .. Title: Director: Title: y CFO: Date: Date:.. 61#6 • GE Capital BILL of SALE PRA PLCC Fresh—February 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.the:.13 day of December, 2012 by and between: General: Electric Capital Corporation,GE Money Bank, GEMB Lending, Inc., Monogram Credit Services,L.L,C.,. : x RFS.Holding, L.L.C. and GEM.Holding, L.L.C. collectivel r Seller") and Portfolio : . . Recovery Associates, LLC (w Buyer xx), Seller hereby trans ers, se s,: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 February 19,.2013, and as further described in the Agreemen#.. GE G ital Retail Bank.. Mono am Credit:Services, L.L.C. By:. B Glenn:Marino. Glenn Marino Title:_EVP Tit e: : President:.: Date: Date: . General Electric Capital Corporation: RFS Holding,:L:L.e By:. By. Glenn Marino Joseph.Ressa Title: ^Vice President Title: CFO _ ': Date: Date~ GEMB Lending, Inc: GEM Holding,L:L.0 Y f BY:. Stephen Joseph Ressa Title: .:Director Title: : CFO Dater. 1,1, Date: 1‘....-2 I GE Capital BILL of SALE PRA PLCC Fresh�February*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 berg 2012: by :and between General Electric Capital of the .13 :day:of .Decem 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 orth in the. :. :.: Agreement,:to the:extent of its ownership,the Receivables as set forth in hi the Notification . : • Files:(as defined in the Agreement), delivered by Seller to Buyer on:February 19, 2013, : : : and aS further.described in .the Agreernent. S. . : . 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 RFS • •ing,L.L.0 By By _ .ti Lam:. Glenn Marino Joseph iiii;a Title: _Vice President . Title: CFO .. Date: Date: GEMB Lending, Inc. GEM .:• ding,L.L.0 By By: j .. Stephen lvlotta Joseph Res. .. Title:_Director :::.. . Title: CFO Date: Date; r:2-.2.--1 Carrie A. Brown, Esquire PA Bar #:94055 Robert N. Po las, Jr, Esquire PA Bar #: 201259 Mark R. Garvey, Esquire PA Bar #: 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-4102 FAX: 757-518-0860 Attorneys for Plaintiff F; L ED-C7FIC.T C.1-7 THE PRO MONO TAR Y 2e/iirAR 24 MO: 10 CUMBERLAND COUNTY PENNS YLVA NIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD NORFOLK, VA 23502 V. VICKIE GRAMLEY Plaintiff Defendant : No. 2014-298 PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Plaintiff demands that Defendant answer and respond to the following Request for Production of Documents under oath pursuant to the Pennsylvania Rules of Civil Procedure within 30 days from the date of service hereof. Plaintiff also demands that Defendant answer and respond to the following Request for Admissions pursuant to Pa. Rule of Civil Procedure 4014. You are requested to admit the truth of each of the statements of fact hereinafter stated. You are instructed that: 1. These requests are made under Pennsylvania Rules of Civil Procedure 4001, et seq., and each of these matters of which an admission is requested shall be deemed admitted unless your sworn statement in compliance with such Rules is timely made. 2. If you do not admit each of such statements, you must specifically deny each one not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each such matter. 3. Your answer, signed and properly verified, must be delivered to the undersigned attorney of record for the Plaintiff within thirty (30) days after delivery hereof. 4. If you fail or refuse to admit the truth of any such statement of fact and the Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses incurred in making such proof, including attorneys' fees, witness expenses, etc. 5. If, in response to any of the following statements of fact, it is your position that the statement is true in part or as to some items, but not true in full or as to all items, then answer separately as to each part or item. 6. If you have been sued in more than one capacity or if your answers would be different if answered in any different capacity, such as partner, agent, corporate officer or director or the like, then you are requested to answer separately in each such capacity. Failure to do so constitutes an admission in any such capacity. 7. In these Requests for Admissions: A. The word "person(s)" means all entities, and, without limiting the generality of the foregoing, includes natural persons, joint owners, associations, companies, partnerships, joint ventures, trusts, and estates; B. The word "documents(s)" means all written, printed, recorded, graphic, or photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any manner to the subject matter indicated; C. The words "identity ", "identify ", "identification ", when used with respect to a persons) means to state the full name and present or last known address and business address of such person(s) and, if an actual person, his present or last known job title, and the name and address of his present or last known employers; D. The words "identity ", "identify ", "identification ", when used with respect to a dated, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name(s) of the addressee or addressees if any and the name(s) and address(es) of each person who have possession, custody, and control of said document(s). If any such document was, but is no longer in possession, custody, or control, or in existence, state the date and manner of its disposition; and E. The word "identify ", when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act "), means to (1) described the substance of the event or events constituting such an act, and to state the date when such an act occurred; (2) identify each and every person(s) participating in such an act; (3) identify all other person(s) (if any) present when such an act occurred; (4) state whether any minutes, notes, memoranda, or other record of such act was made; (5) state whether such record now exists; and (6) identify the person(s) presently having possession, custody or control of such record. 8. Unless otherwise indicated, all Requests herein relate to those certain events, persons, and period of time more fully described in the pleading in this case. 9. These requests are of a continuous nature. These Requests for Production of Documents shall be deemed continuing so as to require supplemental answers and documents if any information of documents are acquired subsequent to the filing of responses hereto, which information or documents would have been included in the answers and documents produced had it been known or available at the time the answers and the documents provided pursuant hereto produced. Defendants shall supply such information and documents by supplemental answers and production of documents as soon as such information becomes known or available and in all events, prior to trial of this action. If objection is made to any requests for production of documents, it is demanded that the requests for which there is no objection be answered and furnished within the aforesaid period. All documents identified in response hereto shall be organized and labeled to correspond with the request to which it pertains. For all documents produced, list the individual and his or her job title and department from whose file it was produced and all current custodian of said document. If a document called for it is believed to exist or is known to exist, but is in the possession, custody or control of another person or party, the existence of the document, the identity of the possessor, custodian and one in control of such documents shall be provided along with any applicable common description or citation utilized by the publisher, possessor, custodian, or disseminator of such document. If any document called for by this request is withheld on the basis of any claims of privilege or any similar claim, identify that document as follows: author, addressee; indicated or blind copies, dated, subject matter; number of pages; attachments or appendices; all persons to whom distributed, shown or explained; present custodian; and nature of the privilege or similar claim asserted. REQUEST FOR PRODUCTION OF DOCUMENTS 1: Produce any and all documents evidencing proof of all payments on the subject credit card referenced in the Complaint, including, but not limited to, cancelled checks, receipts, coupons, statements, accountings, memoranda, invoices, financial statements, accounting entries, diaries, charts, lists, phone records, data compilations etc. REQUEST FOR PRODUCTION OF DOCUMENTS 2: Produce any and all documents you intend and/or provide testimony on as evidence at the time of the trial. REQUEST FOR ADMISSION NO. 1: Defendant applied for the Credit Card referenced in the Complaint. Admitted Denied If the answer to Request for Admissions No. 1 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 2: Defendant has failed to make all required payments on the credit card. Admitted Denied If the answer to Request for Admissions No. 2 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 3: The attached monthly statement correctly identifies the payments, charges, and balance on the account. Admitted Denied If the answer to Request for Admissions No. 3 is "denied", then supply copies of canceled checks, both front and back, and/or if not available, specific written documentation supporting the denial.. REQUEST FOR ADMISSION NO. 4: Defendant has not submitted any written dispute as to the billing inaccuracy concerning the credit card in question during the time the account was opened on May 29, 2003 until the last payment date of May 31, 2013. Admitted Denied If the answer to the Request for Admissions No. 4 is "denied", then supply copies of specific written disputes as to any billing inaccuracies REQUEST FOR ADMISSION NO. 5: $5,990.15 is the correct and accurate balance of the credit card account in question at the time the account was charged off. Admitted Denied If the answer to Request for Admissions No. 5 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. REQUEST FOR ADMISSION NO. 6: 6. Please admit that you agreed to pay Plaintiff's predecessor all amounts due resulting from the use of your credit card account, including any finance charges and other charges due under the terms of the agreement. Admitted Denied If the answer to Request for Admissions No. 6 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. REQUEST FOR ADMISSION NO. 7: 7. Please admit that for each month you had a balance on your credit card account, you were sent, by mail or otherwise, a bill, statement of account, invoice or other request for payment showing all transactions billed to your account during the billing period. Admitted Denied If the answer to Request for Admissions No. 7 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. INTERROGATORIES Please identify the person(s) answering these Interrogatories. ANSWER: 2. Please identify each and every person that has assisted you in responding to these Interrogatories. ANSWER: 3. Separately, for each of your answers to Requests for Admissions 1 through 9 above where your answer is anything other than an unqualified admit, please: a. State each fact known to you upon which you rely to support your denial or qualified answer; b. If your response is that you do not have sufficient information or knowledge to admit or deny, then describe each effort you have made to acquire the information you feel would be necessary to admit or deny the request; c. Identify each document known to you which you believe contains information relevant to your answer; and d. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your denial or qualified answer and as to each witness, state the information you believe is known to them with respect to your answer. ANSWER: 4. If you filed affirmative defenses to Plaintiff's Complaint, separately for each defense, please: a. State the factual basis that supports your defense; b. Identify each document known to you which you believe contains information relevant to your defense; and c. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your defense and as to each witness, please state the information you believe is known to them with respect to your defense. ANSWER: 5. Have you ever requested Plaintiff's predecessor to open a credit card account in your name? If so, please state the credit card account number(s). ANSWER: 6. Are you aware of any credit card accounts with Plaintiff's predecessor opened in your name? If so, please state the credit card account number(s). ANSWER: 7.. Have you ever made a purchase or obtained a cash advance by using a card, account number and/or account access check issued by Plaintiff's predecessor? If so, please state the credit card account number(s) and the date(s) of the purchase or cash advance. ANSWER: 8. Has Plaintiff's predecessor ever sent to you, by mail or otherwise, any bills, statements of account, invoices or other requests for payment? If so, identify each document and state whether you objected to it. If you have objected, identify each objection, including whether it was written or oral. ANSWER: 9. Have you ever objected, in writing or otherwise, to any bills, statements of accounts or invoices you were sent? ANSWER: 10. If you keep records of purchases or payments with respect to your credit card account with Plaintiff's predecessor, do these records show a balance owing on the account? If so, what is that balance? ANSWER: 11. Is there any portion of Plaintiff's claim that you admit you owe? If so, state the amount that you admit you owe to Plaintiff and any facts that support your claim that you do not owe the rest of Plaintiff's claim. ANSWER: 12. If you claim that the account on which Plaintiff is suing is inaccurate, specify each inaccuracy and any facts that support your conclusion that the account is inaccurate. ANSWER: Respectful ubmitted, B Came A. Brown, Esquire #94055 Robert N. Polas Jr., Esquire #201259 Mark R. Garvey, Esquire #312686 Carrie A. Brown, Esquire PA Bar #:94055 Robert N. Po las, Jr, Esquire PA Bar #: 201259 Mark R. Garvey, Esquire PA Bar #: 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-4102 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 V. VICKIE GRAMLEY, Plaintiff : No. 2014-298 Defendant CERT1HCA 1E OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Complaint upon Defendant by First C ass Mail, Postage Pre-Paid, a copy thereof on this day of , 2014, to: Daniel L. Puskar, ESQ. 129 South Pitt Street Carlisle, PA 17013 B C A. Brown, Esquire #94055 Robert N. Polas Jr., Esquire #201259 Mark R. Garvey, Esquire #312686 GE Capita BILL of SALE PRA PLCC Fresh - February .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 the 13th day. of December, 2012 by . and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc:, Monogram Credit Services, 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 February 19, 2013, and as further described in the Agreement, GE Capital Retail Bank : :. Monogram Credit Services, _ L.I::C. By: Glenn Marino :: Glenn. Marino ate: Title:: _resident ::.... . Date :: General Electric Capital Corporation :: : RFS Holding, L.LC maY: Glenn Marino : Joseph Ressa Tine: Vice President . ,, Title:. _CFO Date: GEMB Lending, Holding; L.L: Stephen Motto ::: Joseph Ressa .. Title: _Director : : Title: _CFO Dater :::Date: : :.. pill - ofSALE: PRA PLCC.Fresh - FebruarV 2013 ,: ................ CapltclI For value reeeived.and in further consideration of:the mutual covenants: and conditions Set t forth in the Forward Flow- Receivables Purchase Agreenient (the "Agreement "), dated: as :Of the 13:day: of December;: 201:2 by and between General . Electric Capital: Corporation, GGE: Money Bank, GEMS Lending, Inc;, Monograrn Credit Services, 1FS : Holding ;: LL.C. and GEM Holding, L;L:C: (collectively "Seller ") and Portfolio Recovery: Associates, LLC ( "Buyer "), :Seller hereby transfers; seils,: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 February 19, 2013; and as further described in:the Agreement- ...... .. .. GE CapitalRetail Bank Monogram:Credi erg By :.... :. lenn :Marino Glenn. Marino itle.. EVP Title :: President .:... Date :. neraI Electric. Capital Corporation : : RFS :Holding;: I.;] oseph Ressa title: _Vice President = : : Title: CFO Date :: Date: GEMB Lending, Tic : GEM Holding, L:L.0 By. .. Stephen Title: Director Date:. ?�1 o 1 Joseph Ressa Title: CFO .: .ate•:. Capital: For value received and in further consideration of the mutual covenants and conditions set forth in the. Forward Flow Receivables Purchase Agreement (the "Agreement' as of the :.13th : day of December, 2012 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, and ates, LLC ("Buyer), Sealer. hereby transfers, sells, conveys, grants, a 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 February 19, 2013, and as further described in the Agreemen ding, L.L ( 4, Rao es() AFFIDAVIT OF SALE OF ACCOUNT BY ORIGINAL CREDITOR State of Minnesota County of Ramsey Diane Stone being duly sworn, deposes and says: I am over 18 and not a party of this action. I am a Collections Operations Representative of GE Capital Retail Bank. In that position I have access to creditor's books and records, and am aware of the process of the sale and assignment of electronically stored business records. On or about 2/19/2013 GE Capital Retail Bank (formally known as GE Money Bank) sold a pool of charge-off accounts (the Accounts) by a Purchase and Sale Agreement and a Bill of Sale to Portfolio Recovery Associates, LLC. As part of the sale of the Accounts, electronic records and other records were transferred on individual Accounts to the debt buyer. These records were kept in the ordinary course of business of GE Capital Retail Bank. The Creditor has a process to detect and correct errors on these accounts. The above statements are true to the best of my knowledge. Signed this 19th day of March, 2013 Signed and sworn to before me this 19th day of March, 2013 by Evelyn Ocana. (Notary Stamp) NY AOS1.1. 028/12 Sr. Paul EVELYN OCANA Notary Public-Mtnnesota Commtegdan Explres Jan 31, BLANKET CERTIFICATE OF CONFORMITY FOR NOTARY EVELYN OCANA 1, Brett Rouleau, an attorney-at-law admitted to practice in the State of Minnesota and fully acquainted with dielaws of the State Of Mitmesota do hereby certify that 1 am duly qualified to `make this certificate of conformity and that the acknowledgement or proof ttpon the affidavits of merit Were taken by Notary Evelyn Ocana,'aioCary public in the State of Minnesota, in'the-manner prescribed by the laws of the State of Minnesota and confirms to the laws thereof in all respects. • IN WITNESS WHEREOF, I have hereuntoset my signature, on March 19,2013. Brett Rouleau-, Attorney at Law, Slate.of Minnesota -e56 F-51 Lowe's' Credit Card Account VICKI L GRAMLEY Account Number Summary of Account Activity Previous Balance - Payments - Other Credits + Purchases/Debits + Fees Charged + Interest Charged 56,256.15 50.00 56,256.15 50.00 $0.00 $0.00 New Balance Credit Limit Available Credit Statement Closing Date Days In Billing Cycle 50.00 $6,400.00 50.00 01/28/2013 29 242 2 Visit us at www.lowes.comfcredit Customer Service: 1- 800 - 568 -0156 Payment Information New Balance 50.00 Amount Past Due 50.00 Total Minimum Payment Due 51,373.00 Payment Due Date 01/30/2013 Late Payment Waming:If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to 535.00. Transaction Summary Tran Date Post Date Reference Number/ invoice Number 01/28 01/28 CHARGE OFF ACCOUNT - PRINCIPALS 01/28 01 /28 CHARGE OFF ACCOUNT "FINANCE CHARGES' FEES TOTAL FEES FOR THIS PERIOD INTEREST CHARGED 01/28 01/28 INTEREST CHARGE ON PURCHASES TOTAL INTEREST FOR THIS PERIOD Description of Transaction or Credit 2013 Totals Year -to -Date Total Fees Charged in 2013 Total Interest Charged in 2013 Total Interest Paid in 2013 50.00 50.00 50.00 Amount ($3,519.71) ($2,736.44) 50.00 50.00 50.00 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Type of Balance Current Transactions Regular Purchases Transactions on or before 05131/2012 Regular Purchases Expiration Annual Balance Subject Interest Balance Date Percentage Rate To Interest Rate Charge Method NA 24.99% 50.00 50.00 20 NA 21.99% 50.00 50.00 20 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. 7009 X5G 1 3 27 130128 2 0 PAGE 1 of 3 9294 0010 2CS1 01CX7009 II GIB BIGI GI IGI VICKI L GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 -9524 Detach and mail this portion with your check. Do not include any correspondence with your check. Total Minimum Payment Due 51,373.00 Amount Past Due Account Number 2 New Balance Payment Due Date $0.00 01/30/2013 $0.00 Payment Enclosed: Please use blue or black ink. ■ New address o email? Print changes on back. Make Payment to LOWE'S /GECRB P.O. BOX 530914 ATLANTA, GA 30353 -0914 '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. 7009 X5G 3 27 130128 Z D PAGE 2 of 3 9294 0010 2C01 01CX7009 1 PORTFOLIO RECOVERY ASSOCIATES, LLC 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1 -866- 428 -8102 Fax: (757) 518 -0860 Statement of Account Account : * * * * * * * * * ** *2422 VICKI GRAMLEY Account Holder: VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 Consumer Account Product Code: PVT Issuer: Assignee: Account Number: GE CAPITAL RETAIL BANK / LOWE'S Portfolio Recovery Associates, LLC * ** * * * * ** *2422 Date Account Opened: May 29, 2003 Date of Last Payment: May 31, 2013 Date of Charge Off: January 28, 2013 Balance at Purchase: $6,256.15 Purchase Date: February 19, 2013 Balance at Charge -Off: $6,256.15 Less Payments: $266.00 Balance Due: $5,990.15 14 -04182 GECR57 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. [ACCTNU M 4 :::n.:.:.n 2422 :MKR FN ;VICKI 1MKR_LN 1GRAMLEY tCMPNY NAME MKR_TAXID 1MKR_AD1 iMKR AD2 iMKR AD3 385 1458 STONE CHURCH RD MKR_CITY =CARLISLE MKR_ST IPA MKR_ZIP 317015 -9524 MKR HP .......:.. »:..£441 :MKR WP 10 ;MKR BARDATE 10 €MKR BKCHAP ;MKR CASENUM i €MKR DISCHDTE 0 MKR DISMSDTE 90 :MKR_BKMEETDTEI0 MKR_BK0OU RT iMKR BKFILEDT 10 1ECOA 11 OPENDATE 120030529 1CHGOFF_DATE 120130128 1RMSLASTPMT 120120608 €LASTPMTAMT $972 .......................... ... DOFD 120120730 1CHGOFFCODE !SKIP LOSSAMT `6256.15 t 1 •»: nvv» n» �».::. ». »»,»»nwmv::»»:.w.v. »v»!Tn » ».: iCURBAL =6256.15 RMSFILENUM nw »Y�69148076 ACCTSTS SF5 FSTSDESC .......... 1JDGDATE Sales - Final - Primary Random Sale 0 ;OFF CODE 1LOW027 !OFF DESC 1BCLE , .BCLE DESC nY BUYERCODE (I NT_RAT E NET COSTSwtl iNET INTEREST 1NET PRINCIPA 1PRINC LOSS 1ASSOC COSTS ILowe's Consumer .181 {Retail Bank PR1S 124.99 . w 12729.14 n L 13527.01 ,. » » »4.- n.wn:.v....w. n,...»w,w »v.. ».n..... 13527.01 fACCRDINT 12729.14 1LASTPURCHDT 120101222 FCMKR_LN CMKR TAXID iCMKR_ADDR1 'CMKR_ADDR2 CMKR_CITYr: CMKRSTATE CMKR ZIP ICMKR_LIABLE MKR_DOB m;1959 Data printed by Portfolio Recovery Associates, LLC from electronic records provided by GE CAPITAL RETAIL BANK pursuant to the sale of accounts from GE CAPITAL RETAIL BANK to Portfolio Recovery Associates, LLC Lowe's® Credit Card Account VICKI L GRAMLEY Account Number Summary of Account Activity Previous Balance - Payments - Other Credits + Purchases/Debits + Fees Charged + Interest Charged $5,054.18 $972.00 $0.00 $0.00 $0.00 $1,382.26 New Balance $5,464.44 Credit Limit $6.400.00 Available Credit $0.00 Statement Closing Date 06/29/2012 Days in Billing Cycle 30 422 Visil us at www.lowes.com /credit Customer Service: 1-800-444-1408 Payment Information New Balance $5,464.44 Total Minimum Payment Due $158,00 Payment Due Data . 07/25/2012 Late Payment Warning:If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to $35.00. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no additional charges using this card and each month you pay .... You will pay off the balance shown on this statement in about ... And you will end up paying an estimated total of ... Only the minimum payment 19 years $14,096.00 $209.00 3 years $7,512.00 (Savings = $6,584.00) I you would like information about credit counseling services, call 1-877- 302 -8775. Promotional Purchase Summary The terms that apply to your promotional purchase(s) areas follows: DEFERRED INTEREST: To avoid paying Accrued Interest Charges on a DEFERRED INTEREST promotion, you must pay at least your minimum payment due, if any, each month and the entire applicable Payoff Amount by the promotion Expiration Date. For each promotion, after a promotion ends or is terminated, non - promotional account terms will apply. To make more than one payment, you can pay online at the online address stated above or you can mail in your payment to the address on the remit stub. This address is also available from our automated customer service system. Purchase Purchase Date Amount Promotion Type 11/22/2010 $3,877.68 Reg Deferred Interest/With Pay Accrued Billed INTEREST INTEREST Payoff Expiration CHARGES CHARGES Amount Date Billed $1,346.90 $3,606.76 Expired Transaction Summary Tran Data Post Date 06/08 06 /08 (Continued on next page) Reference Number/ Invoice Number Description of Transaction or Credit ONLINE PYMT THANK YOU ALPHARETTA GA FEES TOTAL FEES FOR THIS PERIOD Amount ($972.00) $0.00 PAYMENT DUE BY 5 P.M. fETI ON THE DUE DATE. NOTICE: We may convert your payment into an electronic debit. See Statement Disclosures link below for details, Billing Rights Information and other important information, 7009 x5G ��II�II�I 11 DGli 1 VICKI L GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015.9524 7 27 120629 E PAGE 1 of 3 9294 0010 2C51 01C27009 Account Numbe '422 Total Minimum Payment Due Payment Due Date New Balance $158.00 07/25/2012 $5,464.44 Save a stamp. Make Payment to: LOWE'S/GECRB P.O. BOX 530914 ATLANTA, GA 30353-0914 Transaction Summary(Continued) Tran Date Post Date Reference Number) Description of Transaction or Credit Amount Invoice Number INTEREST CHARGED 06/29 06/29 INTEREST CHARGE ON PURCHASES TOTAL INTEREST FOR THIS PERIOD 2012 Totals Year -to -Date Total Fees Charged in 2012 $105.00 Total Interest Charged in 2012 $1,602.17 Total Interest Paid in 2012 $49.59 $1,382.26 $1,382.26 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual Interest rate on your account. Type of Balance Current Transactions Regular Purchases Transactions on or before 05/3112012 Regular Purchases Reg Deferred Interest/With Pay Expiration Annual Balance Subject Date Percentage Rate To Interest Rate NA 24.99% NA Expired 21.99% 21.99% Interest Balance Charge Method $0.00 $0.00 2D $1,955.83 $35.36 2D $3,716.39 $1,346.90 2D 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. 7009 X5G 1 7 27 120629 E PAGE 2 of 3 9294 0010 2CS1 O1CX7009 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 ,�(O 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. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 Defendant No. 2014-298 PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED WITH PREJU espec 14-04182 sub i itte 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. 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. 2014-298 v. VICKI GRAMLEY 458 STONE CHURCH RD CARLISLE PA 17015 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End upon VICKI GRAMLEY by First Class Mail, Postage Pre -Paid, a copy thereof on this 14-04182 dayo/'4' , 2014, to: DAN ,L L PUSKAR ESQ., 129 5 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 Noi-folk, 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. Anv information obtainer] will he mei' for this niimnce