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Home My WebLink About14-1870 >Si dpriri a Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only. Civil Cover Sheet Docket No: Cumberland County H 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 pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: ELAINE G RAMSEY C PORTFOLIO RECOVERY ASSOCIATES LLC i Are money damages requested? ® Yes❑ N Dollar Amount Requested: ® within arbitration limits (Check one) ❑ outside arbitration limits U [1l Is this a Class Action Sult? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No 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 ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ j2ebt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability (does not include ❑ Employment Dispute: mass tort) C ❑ Slander /Libel /Defamation Discrimination T ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board i ❑ Other: N MASS TORT ❑ Other: ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory 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 1/1/20 2843426 PPTXSCPI (1/15/2014) 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. ELAINE G RAMSEY 85 OLD SAW MILL DR CP NEWBURG PA 17240 t om - cj --o 1, Defendant. r- NOTICE TO DEFEN 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 800 - 990 -9108 S a_ 2843426 00-�lD()o PPTCPADI (03/04/2014) So 3tP3 AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR 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 800 - 990 -9108 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. ELAINE G RAMSEY 85 OLD SAW MILL DR NEWBURG PA 17240 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), ELAINE G RAMSEY , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with CITIBANK, N.A., (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 $2799.93. 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. 2843426 PPTCDBCI (01/14/2014) 11111111111111 IN 11111111111111111111111111111111111111111111111111111 IN WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), ELAINE G RAMSEY in the amount of $2799.93, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC 0 -- D One of its Attorneys Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800). 850 -1079 Dated: Verification I LAGONtd Wolfe , 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 penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. M AR 1 20% Date: Signature 2843426 PPTXVRII (01/14/2014) 1111111111111111111111111111111111111111111111111111111111111 Exhibit "A" PPTXEXAI Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: C Customer Service: CITI MASTERCARD �` ► com PO Box 6403, Sioux Falls $D, cRicards mastercard.. 57117.6403 Citi A Account Inquiries: , ",,;�•::,.,,.,,;,:,,,, ,:.;•:::,:. >..;. 1- 888 - 316 -8480 i;:.ibeF X72`: Summary of Account Activity Payment Information Previous Balance $3,188.96 New Balance $3 Payments -$0.00 Minimum Payment Due $670.00 Other Credits -$0.00 Payment Due Date February 13, 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 +$25,97 Minimum Payment Warning: If you make only the minimum payment each New Balance $3,249.93 period, you will pay more in interest and it will take you longer to pay off your balance. For example: Past Due Amount $577.00 .7 1( yo tx{a(ke�bb additignat .::... '1 bu will pap the Attd yot+ wdt . chargOS ysltsg this bal'�1 ., kialaricQ sho�rrrnn ih +s spdvp payirfg �h Credit Limit $0.00 antleacti,month,yu,. ;.;taEerrint : esttma#ezl.totf.e; %:.,:,_ Available Credit 0.00 :.....:... .. ......:: . Cash Advance Limit 0.00 Only the minimum payment 13 years $4,779 Available Cash Limit 0.00 $104 3 years $3,734 Amount Over Credit Limit 0.00 (savings = $9,045) Statement Closing Date 01/17/2012 if you would like Information about credit counseling services, call 1 -877- 337 -8188. Next Statement Closing Date 02/15/2012 Days in Billing Cycle 32 TRANSACTIONS Trans Date Description Reference 9 Amount FEES 01113 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 01117 INTEREST CHARGE ON PURCHASES $ 25.97 TOTAL INTEREST FOR THIS PERIOD $ 25.97 8 GP 10 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account Is Issued by Citibank, N.A. ----------------------------------------------------------------------------------------------------------------------------- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records. T /1 Make Checks Payable to: C ' �' � CITI MASTERCARD t Past Due Amount is included in the Minimum Payment Due. `F;etar:IAcvtititNumbr: Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed FEBRUARY 13, 2012 $3,249.93 $577.00 $670.00 $ Thank you for making at least your Minimum Payment Due each month. I i - 4372 CITI MASTERCARD PO BOX 183016 ELAINE G RAMSEY COLUMBUS, OH 43218 -3016 85 OLD SAW MILL OR NEWBURG, PA 17240 -9399 Point 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. You can avoid interest charges on 1. Within 30 days of receiving your letter, we must tell you that we received purchases, but not on balance transfers and cash advances. This is called a grace your letter. We will also tell you if vie have already corrected the error. period on purchases. To get the grace period on purchases, pay the Net New 2. Within 90 days of receiving your letter, we must either correct the error or Balance in full by the payment due date every billing cycle. The Net New Balance is: explain to you why we believe the bill is correct. The New Balance plus While we investigate whether or not there has been an error: Any additional amount required by a promotional offer as part of the Minimum Payment Due, minus We cannot try to collect the amount in question, or report you as delinquent on Any 0% promotional balances that expire after the Next Statement Closing that amount. Date. (0% promotional balances do not include balance transfers and cash The charge in question may remain on your statement, and we may advances.) continue to charge you interest on that amount. Ii you do net, you will not get a grace period until you pay the Net New Balance in While you do not have to pay the amount in question, you are responsible full for two billing cycles in a row. Other promotional offers may also allow you to for the remainder your balance. have a grace period on purchases without having to pay all or a portion of the We can apply any unpaid amount against your credit limit. prorotional balance by the payment due date. In addition, certain promotional After we finish our investigation, one of two things will happen: offers may take away the grace period on purchases. If either is the case, the If we made a mistake: You will not have to pay the amount in question or any promotional offer will describe what happens. interest or other fees related to that amount. How We Calculate Your Balance Subject to Interest Rate. We use a daily If we do not believe there was a mistake: You will have to pay the amount balance method (including current transactions) to calculate interest charges. To in question. along with applicable interest and fees. We will send you a find out more information about the balance computation method and how the statement of the amount you owe and the date payment is due. We may then resulting interest charges were determined, contact us at the Account Inquiries report you as delinquent if you do riot pay the amount we think you owe. number on the hunt. If you receive our explanation but still believe your bill is wrong, you must write Balance Tlransters. Balance transfer amounts are included in the 'Purchases" line to us within tU days telling us that you still refuse to pay. If you do so, we cannot in the Summary of Account Activity (if balance transfers are available on your report you as delinquent without also reporting that you are questioning your bill. account). We must tell you the name of anyone to whom we reported you as delinquent, Rates. Variable AFRS will vary with the market based on the Prime Rate. and we must let those organizations know when the matter has been settled between us. Credit Reporting Disputes. If you think we reported inaccurate information to a If we do not follow all of the rules above, you do not have to a credit bureau write us at the CUStgrTter Service address shown on the front. pay the first $50 of Report a Lost or Stolen Card Immediately. Call the Account Inquiries number the amount you question even if your bill is correct. shown on the front. Your Rights If You Are Dissatisfied With Your Credit Card Purchases What Tb Do !f You Find A Mistake On Your Statement if you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the If you think there is an error on your statement, write to us at the address for merchant, you may have the right not to Tray the remaining amount due: on the billing inquiries and correspondence shown on the front of your statement. purchase. In your letter give us the following information: To use this right, all of the following must be true: Account Information: Your name and account number. 1. The purchase must have been made in your home state or within 100 Doliararnounk The dollar amount of the suspected error, miles of your current mailing address, and the purchase price must have Description of problem: If you think there is an error or your bill, been more than S50. (Note: Neither of these are necessary if your describe what you believe is wrong and why you believe it is a mistake. purchase was based on an advertisement we mailed to you, or if we own You must contact us: the company that sold you the goods or services.) Within 60 days after the error appeared on your statement. 2. You must have used your credit card for the purchase. Purchases made with At least 3 business days before an automated payment is scheduled, if you want cash advances from an ATM or with a check that accesses your credit card to stop payment on the amount you think is wrong. account t not qualify. 3. You must not yet have fully paid for the purchase. You must notify us of, any potential errors in writing. You may call us, but if you do If all of the criteria above are met and you are still dissatisfied with the purchase, we are not required to investigate any potential errors and you may have to pay contact us in writing at the address for billing inquiries and correspondence shown the arnount in question. on the front of your statement While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Prism 12111 T01673 -1215- 0030 - 3700- E -10-D- -07101!08 -06- 000- P-- 0- 7 -0-0 -- -04130111 -PZ58- December 16, 2011 -0 N - -- Important Payment Instructions. Copy Fee. We charge $5 for each copy of a billing statement that dates back 3 Right to Prepay Your Account. You may pay all or part of your account balance months or more. We add the fee to the standard purchase balance. We waive the at any time. However, you must pay, by the payment due date, at least the fee if your request for the copy relates to a billing error or disputed purchase. minimum payment due. Payment Options Other Than Regular Mail. Crediting Payments. If we receive your payment in proper form at our processing Pay by Phone Service. You may use this service any time to make a payment facility by 5 p.m. local time there, it will be credited as of that day. A payment by phone. You will be charged $14.95 it a representative of ours helps expedite received there in proper form after that time will be credited as of the next day. your payment. Call by 5 p.m. Eastern time to have your payment credited as of Allow 5 to 7 days for payments by regular mail to reach us. There may be a delay that day. If you call after that time, your payment will be credited as of the next of up to 5 days in crediting a payment we receive that is not in proper form or is day. We may process your payment electronically after we verify your identity. not sent to the correct address. The correct address for regular mail is the Express Payments. You can send payment by courier or express mail to address on the front of the payment coupon. The correct address for courier or the Express Payments Address. This address is: Payments Department, express mail is the Express Payments Address shown below. 1500 Boltonfield Street, Columbus, OH 43228. Payment must be received in proper form at the proper address by 5 p.m. Eastern time to be credited Proper Form. Fora payment sent by mail or courier to be in proper form, you must: as of that day. All payments received in proper form at the proper address • Enclose a valid check or money order. No cash, gift cards, or foreign after that. time will be credited as of the next day. currency please. include your name and account number on the front of your check or money order. If you send an eligible check with this payment coupon, you authorize us to complete your payment by electronic debit. If we do, the checking account will be debited in the amount on the check. We may do this as soon as the day we receive the check. Also, the check will be destroyed. Page 2 of 4 Account: 4372 :2012 �'ota� Year�to Date Total Fees Charged in 2012 $35.00 Total Interest Charged in 2012 $25.97 INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual Interest rate on your account. 'r'Y -.... .Bali a,. ;.. .: ,:- _. - °;• �Aitir► a >�tP.�rcent��v�k�lt�a(Ai?R } : Balee$ub�e�f�oInt�ri��r�R�te �, f++'f�Yesi<+Gh�rge PURCHASES REGULAR 9.24% (D )M $3206.97 $25.97 CASH ADVANCES REGULAR 19.99% D .00 $0.00 = Variable Rate Page 3of4 Account: * * ** * * ** # * *# 4372 Page 4of4 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 COL ELAINE G RAMSEY -:: 85 OLD SAW MILL DR NEWBURG PA 17240 C CO Defendant(s). PRAECIPE TO ENTER APPEARANCE �� _37 n, 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: March 7, 2014 By: Morris Scott Attorney Syretta Martin Attorney 2843426 PPTXPEAI (11/18/2013) 111111111 IIII 111111 IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �r r ii Sheriff i "ti- t h Y1-10 Oµ TARY Jody S Smith Chief Deputy Richard W Stewart Solicitor ., • 1i APR 2t Ili flf2 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Elaine G. Ramsey Case Number 2014 -1870 SHERIFF'S RETURN OF SERVICE 04/04/2014 04:36 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Elaine G. Ramsey, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 85 Old Sawmill Drive, Hopewell Township, Newburg, PA 17240. The Shippensburg Postmaster provided a new address os 1192 Gum Run Lane, Shippensburg, PA 17257 which is located in Franklin County. SHERIFF COST: $50.60 SO ANSWERS, April 16, 2014 RONR ANDERSON, SHERIFF Gi Co r..ty u ., h2. . Teleosoft....,.