The URL can be used to link to this page

Home My WebLink About14-1770 Supreme C,o , Pennsylvania Court f,Qm lon Pleas , For Prothonotary Use Only: TIME 5T_\MI' Ci�:� ov er et Docket No: CLIMB ; County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the fi ling and service ofpleadings or other a ers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ]1t ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC SADAT TEMORE Q Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? Yes 0 N A; Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey ❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle o Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include S mass tort) ❑ Employment Dispute: E ❑ Slander /Libel/Defamation Discrimination ❑ Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: C T - ❑ Other: I MASS TORT U ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant E] Ejectment E] Common Law /Statutory Arbitration E] Eminent Domain /Condemnation E] Declaratory Judgment B C] Toxic Waste ❑ Other: ❑ Ground Rent E] 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: p Legal ❑ Medical ❑ Other Professional: 15 -24714 a Robert N. Polas, Jr., Esquire PA Bar.# 201259 Carrie Brown, Esquire PA Bar #194055 L. Of FI- - Mark R. Garvey, Esquire PA Bar # 312686' t ttti °J i`l0_NJ �DA R Y Portfolio Recovery Associates, LLC�� 120 Corporate Blvd AM l I I ; � 6 Norfolk 86 6 -428- - 8102 1: - TELE: 1 - MBERL,� ND CQUN Y 86- 428 - FAX: (757) 518 -0860 f 't� SYLVANIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS, OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW. PORTFOLIO RECOVERY ASSOCIATES, LLC p 120.CORPORATE,BLVD NORFOLK, VA 23502 No; • r Plaintiff, V., SADAT TEMORE 208 FAITH CIR CARLISLE PA 17013 t Defendant. i 9 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 b 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 by the Court without further notice of any money claimed or any other claim or relief requested bj! the'I'laintiff. 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 TOO 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 lNFORMATION'ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE'OR NO FEE. Lawyer Referral Service- CUMBERLAND County Bar' Association ' Cumberlan&County Bar Association 32 South Bedfor&Street Carlisle,'PA `17013 (717) 249 -3166 15 -24714 -y �L � 1�3. /�p a l "� ck4 2b3u(4 s i from a debt collector and is an attempt to collect a de t. This communications f . p _� co le 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 Plaintiff, No. V. SADAT TEMORE 208 FAITH CIR CARLISLE PA 17013 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, SADAT TEMORE, is an adult individual with last known address of 208 FAITH CIR, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to HSBC BANK NEVADA, N.A. / CAPITAL ONE BANK (USA), N.A / METRIS on November 30, 2006 with account number * * * * * * * * * ** *0974 (hereafter referred to as "Account "). 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. be used. for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on February 24, 2012. 8. Plaintiff is the purchaser, assignee and /or successor in interest HSBC BANK NEVADA, N.A. / CAPITAL ONE BANK (USA), N.A / METRIS and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs Bill of Sale 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 $6,357.66. 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, SADAT TEMORE , in the am f $6,357.66, plus c is f this action and any other relief as the Court deems just and reasonabl . Ca Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15 -24714 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, Itim Spel lMan hereby states that he /she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his /her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: By: gfim Spellman Custodian of Records 15 -24714 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. A. . � s'a k .: E X i This communication is from a debt collector and is an attempt to colfecVa debt. Any information obtained,,will be u that purpose., "0 Exhibit 1: :.:. .. .. .. ...... .... .. .. Vorward Flow Receivable Sale Afire emerit dated-11 /09 2012 :..BILL: OF -SALE.. :.. . . osing:bate: 03115/2013 C apital: - One } - National: Association: (" Seller ')jn considerafioa of; a : Purcliase :Price ' of :. : and , ther 'valuable coiisi o .. : deration; :the ieceipt: of :which is :hereby . acknowledged: . hereby,siN', assigns and,iransfas , alf .. d interes .. ght; title ant in the Accounts identified in the Sale - :......... File :end led: -' -- -- ' -- ...... — — _ :(which ma b6 in eworiic _ . tp - Portfolio Recov Associates, LLC: - and: its: - affilYates� � ,and . *its: subsidiary B � entities ': - - ( uyer }, : vv�thout: recourse: , or representation : ex :: t : as : ex ressl. 'died herein :or' on' the P Y 1?r'Qn : s and:subjeet conditions, set fcir ;in.the Agreement (as.defined below): :. :. :This Bill- of: -Sale :is= delivered:- pursuat�f t tliat. Certain ::Foravard :Flow:Receivable :Sale. . '::' Agreement, dated as of 11%09/2012; by and :between: Seller .and . Buyer . (tfie "Agreement" ):. All capitalized: terrris:used;. but not defined ;; in this Bill -of Sale •shall have'the meanings assigned: to such .terms in the Agreement: Th .... :. :� .. � ••.•..:� � �.' ,- .� The Cutoff lJ&e:for.the.Sale:File was 03%12/ 200: The'aggregate Unpaid.$alance of the: Accounts as of the �utioffDate was . ONE; NATIONAL: ASSOCIATION. ::. . �Ad�: I4ame: -John H. Maurer Title:• Vice President . .. ... ... .... 0 ...... .. .. Exhibit 2 .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . - Forward - Flow Receivable Sale: Agreement dated 11 /09/201.2. ."BILL-OF SALE :.. C losing Date: 03/I5/2013�::��.� - � -- Capital Dne Bank (USA ) , National Association .("Seller.'), : in consideration: of a -Purchase. ' ' Prise: : of: : ::and : .other: valuable consideration,' the rec4t;: is ...'... '.:' acknowledged, hereby sells; assigns 'and .transfers all right title:and interest in the ceounts identified in the: Sale File. entitled.HCS.1 - PRA 2:0211. PRN; HCS2 ^PRA - 2 PRN (which: may be , in. eleetronic ' fpriri) : to :Portfolio - :Recovery Associates; ; :LLC .:and l ts -affiliates and' - its: , su ..id... entities " Bu ei'' . ary :. ( y ), Without ; recourse ; or ,representation, except : as expressly :provided herein .or:.on the terms;. and: subject .to : the. cottditions set fvztti in the below }: JUs Bill. of Sale: is delivered: pursuant :to - that - certain: Forward Fiow ' Receivable `Sale Agreement,: defied -as ;of : t 1/09/ 201.2;. by: and between- Seller- and :Buyer :(the "Agr eement I.: ;AI1:.. :: cap ta ter ........ms. u but not defined;' in this. Bill :of Sale. shall: have -the meanings :assigned'to :.. such terms.in the Agreement: ::. ' .::::.::. ::.:: ...... .. . . . e Cutoff Date,fo'rthe. - /i2/ 2013. - The aggregate Unpaid:Balance of the . ..: Account's as cif the: CutoffDate was ' :: .... :: .:.. SA);. ....cAprrA�, olvE:BANx:(�r . . .ASSOCIATION- :. B. ............... ... :.. .. .... ..... ..... .. - ..: - . ' - Nanie:lohn �H.:Maurer.: .. .. 'Title: 'Vice 'President Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i i t = ',r a T OFFICE C:F THE $t±ERIFF 7.511i APR —2 PM L: l 4 CUMBERLAND COU. NT Y PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Case Number Sadat Temore 2014-1770 SHERIFF'S RETURN OF SERVICE 03/27/2014 07:59 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint & Notice by "personally' handing a true copy to a person representing themselves to be the Defendant, to wit: Sadat Temore at 208 Faith Circle, North Middleton, Carlisle, PA 17013. RYAN BURGETT, DEP SHERIFF COST: $34.78 SO ANSWERS, March 28, 2014 RR ANDERSON, SHERIFF (C) CountySuite Sherit(, Teieosoft. Inc. �{,arrieA. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire. Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff OF THE Pii0T110NO TA Pi 20.1 11 DEC 14M I ! : 10 CllMr`3t.i1LAL'U COUNTY PEN;'g ¥LV/ -S I A 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. SADAT TEMORE 208 FAITH CIR CARLISLE PA 17013 Defendant No. 14-1770 PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. 15-24714 ctfully submitted, obert N. Polas, Jr:, Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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 Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 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. 14-1770 v. SADAT TEMORE 208 FAITH CIR CARLISLE PA 17013 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End upon SADAT TEMORE by First Class Mail, Postage Pre -Paid, a copy thereof on this / day of, 15-24714 , 2014, to: SADAT TEMORE 208 FA 0' , CARLISLE PA 1 e4, Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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 he nseri for this nnrnnse