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Home My WebLink About14-0321 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: � Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filin,- 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 El Declaration of Taking S intiff's E Le ad Pla Name:. Lead Defendant's Name: KEVIN T OBRIEN C PORTFOLIO RECOVERY ASSOCIATES LLC 'es N�] Dollar Amount Requested: ® within arbitration limits Are money damages requested? X 0 (Check one) El outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? Yes] 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 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 uyer Plaintiff Administrative Agencies El Malicious Prosecution 0 Debt Collection`. Credit Card BUrd of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other B®rd of Elections ❑ Nuisance Dpt. of Transportation S ❑ Premises Liability S Appeal: Other E ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: C ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other Zing Board I O1&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 DBaratory 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 11 120 2805078 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, c� CIVIL ACTION M UD VS. y' No. :(V( uo.T KEVIN T OBRIEN --� < c � 204 W SPRINGVILLE RD - P- t- - �;r- — �: BOILING SPRINGS PA 17007 -9530' 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. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 a� 2805078 d D 1 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 provisioner 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 TAL 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. KEVIN T OBRIEN 204 W SPRINGVILLE RD BOILING SPRINGS PA 17007 -9530 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1 . The Defendant(s), KEVIN T OBRIEN , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with CITIBANK,N.A. SEARS, (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 $2195.67. 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. 2805078 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), KEVIN T OBRIEN in the amount of $2195.67, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC 0 e of its rneys Morri cott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Has,enmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850 -1079 Dated: December 6, 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. KEVIN T OBRIEN 204 W SPRINGVILLE RD BOILING SPRINGS PA 17007 -9530 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 Defendant(s) 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, HA MI LER, LEIBSKER & MOORE LL Dated: December 6, 2013 By: Morris Scott Syretta Martin 2805078 PPTJCAMI (06/28/2013) 11111111 VIII 111111 III 111111 VIII VIII VIII VIII VIII VIII VIII IIII IIII Verification Mina Spellman 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. JAN Q 3 Z'O14' Signature til]a Spellman 2805078 PPTXVR11 1111111111 ME 111111111 IN Exhibit "A" PPTXEXAI Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: /�. Customer Service: SEARS CREDIT CARDS sea rscard.com s {� PO Box 6283, Sioux Falls SD 67117.6283 SearsCharge PLUS` Account Inquiries: 1- 800 - 917-7700 AGCC31ti1t7ilrtl`bei f�993 Summary of Account Activity Payment Information Previous Balance $2,114.74 New Balance $2,195.67 Payments -$0.00 Minimum Payment Due $721.80 Other Credits -$0.00 Payment Due Date February 25, 2012 Purchases +$0.00 Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above, you may have to pay a late fee up to $35. Interest Charged +$45.93 Minimum Payment Warning: If you make only the minimum payment each New Balance $2 , 1 95.67 period, you will pay more in interest and it will take you longer to pay off your balance. For example: Past Due Amount $618.87 .y ?...�1ak�i'.atltltt .canal;,:- ;:: <;,;:::.. P..y:; :::�,.....: Ypri�vlll =r `. 1'ou well a c5ffthe And .., . c#iar "ges usltg hits card' balance sho>nrn rsrt this pying,ari arid.each fnontta;you pay :: ; - ::tafement in about ,esiirYtated total of Credit Limit 0 0 0 Only the minimum payment 10 years ! $4,175 Available Credit $0.00 $88 3 years $3,153 Amount Over Credit Limit $0,00 __ __ - __. i (Savings = $1,022) Statement Closing Date 01/29/2012 It you would like information about credit counseling services, call 1 -877 -337 -8188. Next Statement Closing Date 02/27/2012 Days in Billing Cycle 31 Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. TRANSACTIONS Trans Date Description Reference # Amount FEES 01/25 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 01/29 INTEREST CHARGE ON PURCHASES $ 45.93 TOTAL INTEREST FOR THIS PERIOD $ 45.93 8 TE 19 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account Is Issued by Citibank, NA. ----------------------------------------------------------------------------------------------------------------------------- + Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. + Make Checks Payable to: SearsCharge PLUS' M SEARS CREDIT CARDS t Past Due Amount is included in the Minimum Payment Due. 1Folir: ' Ac ci ui4t tiu# b r: Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed - FEBRUARY - -- $279567 — -- — $61 - 8.87 — - $72 - T.80 — $ -- SAVE STAMPS, TIME... AND TREES! visit Account Online and register nosh. for Online Bill Pay, Paperless Statements and More. 0993 SEARS CREDIT CARDS PO BOX 183081 KEVIN T OBRIEN COLUMBUS, OH 43218 -3081 1400 LINDEN ST READING, PA 19604 -1844 Print address changes above in blue or black ink. Information About Your Account, What Will Happen After We Receive Your Letter How to Avoid Paying Interest on Purchases. Your payment due date is at least When we receive your letter, we must do two things. 25 days after the close of each billing cycle. We will not charge you any interest on 1. Within 30 days of receiving your letter, we must: tell you that we received purchases if you pay your New Balance by the payment due date each month. This your letter. We will also tell you if we have already corrected the error. is called a grace period on purchases. If you do not pay the New Balance in full by 2. Within 90 days of receiving your letter, we must either correct the error or the payment due date, you will not get a grace period on purchases until you pay explain to you why we believe the bill is correct. the New Balance in full for two billing cycles in a row. We will begin charging interest on cash advances and balance transfers (if available on your account) on While we investigate whether or not there has been an error: the transaction date. • We cannot try to collect the amount in questiork or report you as delinquent on If you have a balance subject to a deferred interest promotion and that promotion that amount. does not expire before the payment due date, that balance (the "excluded The charge in question may remain on your staterent, and we may promotional balance ") is excluded from the amount you must pay in full to get a continue to charge you interest on that amount. grace period. However, you must still pay any separately required payment on the While you do not have to pay the amount in question, you are responsible excluded promotion. In billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first, the deferred interest balance will be reduced before any We can apply any unpaid amount agairst your credit lirnit- other balance on the account. However, you will continue to get a grace period on After we finish our investigation, one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional balances in full by the payment due date each billing cycle. in er made a mistake: You will not have amount- pay the amount in question or any In addition, certain promotional offers may take away the race interest or other fees related to that ke: Y p y y g period on !f we do not believe (here was a mistake: You will have to pay the amount purchases. Other promotional offers not described above may also allow you to in question, along with applicable interest and fees. We will send you a have a grace period on purchases without having to pay all or a portion of the statement of the amount you owe and the date payment is due. We may then promotional balance by the payment due date. If either is the case, the report you as delinquent if you do riot pay the amount we think you owe. promotional offer will describe what happens. and How We Calculate Your Balance Subject to Interest Rate We use a daft If you receive our explanation but still believe your bill is wrong, you must write to balance method (including current transactions) to calculate interest charges. To report within 10 days telling us that you still refuse to pay. If you de st i o n cannot find out more information about the balance computation method and how the We mus't t as delinquent without ell you the name of anyone reporting that you e a questoning your bill. resulting interest charges were determined, contact us at the Account Inquiries must tone to whom we reported you as delinquent, number on the front. we must let those organizations know when the matter has been settled between us. Balance Transfers. Balance transfer amounts are included in the "Purchases" line if we do not follow all of the rules above, you do not have to pay the first $50 o` in the Summary of Account Activity (if balance transfers are available on your account). the amount you question even if your bill is correct. Transaction Date. The Transaction Date shown on the statement is also the Sale Your Riqhts If You Are Dissatisfied With Your Credit Card Purchases Date. If you are dissatisfied with the goods or services that you have purchased with Credit Reporting Disputes. If you think we reported inaccurate information to a Your credit card, and you have tried in good faith to correct the problem with the credit bureau write us at the Customer Service address shown on the front. merchant, you may have the right riot to pay the remaining amount due on the Report a Lost or Stolen Card Immediately. Call the Account Inquiries number purchase. shown on the front. To use this right, all of the following must be true: 1. The purchase must have been made in your home state or within 100 What Tb Do If You Find A Mistake On Your Statement miles of your current mailing address, and the purchase price must have If you think there is an error on your statement, write to us at the address for been more than $50. (Note: Neither of these are necessary if your billing inquiries and correspondence shown on the front of your statement, purchase was based on an advertisement we mailed to you, or if we own In your letter, give us the following information: the company that sold you the goods or services.) • 2. You must have used your credit card for the purchase. Purchases made with Account information: Your name and account number. • Doliaramount: The dollar amount of the suspected error, cash advances from an ATM or with a check that accesses your credit card account do not qualify. Description of problem: If you think there is an error on your bill, 3. You must not yet have fully paid for the purchase. describe what you believe is wrong and why you believe it is a mistake. If all of the criteria above are met and you are still dissatisfied with the purchase, You must contact us: contact us in writing at the address for billing inquiries and correspondence shown • Within 60 days after the error appeared on your statement. on the front of your statement • At least 3 business days before an automated payment is scheduled, if you want While we investigate, the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. above. After we finish our investigation, we will tell you our decision. At that point, You must notify us of any potential errors in writing. You may call us, but if you do if we think you owe an amount and you do not pay, we may report you as required to investigate an delinquent we are not re q g y potential errors and you may have to pay the amount in question. EM SMC-TGI-SCC-SCP+'IPs iZr11 T0 9351 -5010- 0004- 9- E- 39- D- 10 /otfo8- 40— P- B -0- -7- 402- 0-0- -- 04/30 %11 -PKOB- December 29. 2011 -0 -V N —. Important Payment Instructions, Payment Options Other Than Regular Mail. Right to Prepay Your Account. You may pay all or part of your account balance In -Store Payments (Where Available). Any payment in proper form at any time. However, you must pay, by the payment due date, at least the accepted in - store will be credited as of that day. However, credit minimum payment due. availability may be subject to verification of funds. Not all stores accept _ _.Crediting- P- ayments. If -we- receive -your- payment in proper form at our processing - payments. Contac -t your locaa store to see if in - state payments are - - - facility by 5 p.m. local time there, it will be credited as of that day. A payment accepted at that location. received there in proper form after that time will be credited as of the next day. Online Payments. Visit the web address on the front and sign up for Allow 5 to 7 days for payments by regular mail to reach us. There may be a delay online payments. Enrollment may take a few days. If we receive your of up to 5 days'in crediting a payment we receive that is not in proper form or Is request to make an online payment by 5 p.m. Eastern time, we will credit not sent to the correct address. The correct address for regular mail is the address your payment as of that day. If we receive your request to make an online on the front of the payment coupon. The correct address for courier or express payment after that time, we will credit your payment as of the next day. mail is the Express Payments Address shown below. For security reasons, you may be unable to pay your entire New Balance with your first online payment. Proper Form. For a payment sent by mail or courier to be in proper form, you must: Pay by Phone Service. You may use this service any time to make a • Enclose a valid check or money order. No cash, gift cards, or foreign payment by phone. You will be charged $14.95 if a representative of ours currency please. helps expedite your payment. Call by 5 p.m. Eastern time to have your Include your name and account number on the frost of your check or money a t order. payment credited as of that day. If you call after that time, your payment will be credited as of the next day. We may process your payment If you send an eligible check with this payment coupon, you authorize us to electronically after we verify your identity. complete your payment by electronic debit. If we do, the checking account will Express Payments. You can send payment by courier or express mail to be debited in the amount on the check. We may do this as soon as the day we the Express Payments Address. This address is: Payments Department, receive the check. Also, the check will be destroyed 1500 Boltonfield Street, Columbus, OH 43228. Payment must be received Copy Fee. We charge $3 for each copy of a billing statement that dates back 3 in proper form at the proper address by 5 p.m. Eastern time to be credited months or more. We add the fee to the regular purchase balance. We waive the fee as that day. All payments received in proper form at the proper address if your request for the copy relates to a billing error or disputed purchase. after itiat time will be credited as of the next day. Page 2 of 4 A ccount: * * ** * * ** * * ** 0993 ;. ZQ12' ita# D Y;:; ea ate Total Fees Charged in 2012 $35.00 Total Interest Charged in 2012 $45.93 INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) Is the annual interest rate on your account. _YAof $alahce, - ...,.:., Annuat:.Rereertta.i.� ( APR } Ba1ite Sttt3ject= fo7riteiretRae; [tt�resti✓harge PURCHASES REGULAR 25.24% (D )(V) $2142.47 $45.93 = Variable Rate D = Dail Pane 3 of 4 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. V No. "1 J KEVIN T OBRIENz? 204 W SPRINGVILLE RD C:i -�C� c-n �C:.) BOILING SPRINGS PA 17007 -9530 e� n Defendant(s). -„ -� Iy t� C-1 e" C:) r..... PRAECIPE TO ENTER APPEARANCE —e CD TO THE PROTHONOTARY: Kindly ENTER my appearance in the above - captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller,, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1- 215- 564 -1567 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: December 6, 2013 By: Morris Scott Attorney Syretta Martin Attorney 2805078 PPTXPEAI (11/18/2013) IIIIIIIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson a • r;JN1 T h5ti`i Sheriff iatp Lgi €bt(i Jody S Smith Mil ii FEB H PH 3: 1 14 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Kevin T O'Brien 2014-321 SHERIFF'S RETURN OF SERVICE 02/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kevin T O'Brien, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found" at 204 W. Springville Road, South Middleton, Boiling Springs, PA . Per current resident, they have lived here since August 2013. Per Post Office, defendant is not known at address given. SHERIFF COST: $39.78 SO ANSWERS, February 05, 2014 RONNY R ANDERSON, SHERIFF Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 vs. KEVIN T OBRIEN 1400 LINDEN ST READING PA 19604-1844 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. ok01 " 360 PRAECIPE TO WITHDRAW COMPLAINT WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly WITHDRAW the Complaint filed in the above -captioned matter, WITHOUT prejudice. Dated: I IL/ /N 2805078 PPTJPWCI (09/17/2014) 111111111111111111111111111111111111111111111111111111111111111111111111111 Respectfully submitted, By: Syretta Martin, Es'-. PA Bar #309370 Frank Janello, Es.. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Kami S. Miller, Esq. PA Bar #78590 Christopher A. Titus, Esq. PA Bar #315746 Blatt, Hasenmiller, Leibsker & Moore; LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818