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Home My WebLink About14-2531 Supreme Co- ur,t;of Pennsylvania 'Coux of Ctom; on Pleas . �' ,- "1 A For Prothonotary Use Only :' TIME STAMP Ci 4 ove D et Docket No: CUMB County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the Cling and service of pleadings or other papers as required by law or rules of court. S Commencement of Action: E ® Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking T Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES, LLC SHERI C MELNICK, WAYNE S MELNICK Y O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits I 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. Garvey ❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) I 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: - -- – – ❑ Slander /Libel /Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T - - - -- - -- - -- I ❑ Other: U 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: 15 -55691 Robert N. Polas, Jr., Esquire PA Bar # 201259 .Carrie Brown, Esquire PA Bar # 94055 1Mark R. Garvey, Esquire PA Bar # 312686 i L , • ;-4."� j ;; Portfolio Recovery Associates, LLC T P it OTi z,'iN0 T ;' t4 1 120 Corporate Blvd Norfolk, VA 23502 20 1 4 APR 2 Al E I : 1 1 5 TELE: 1- 866 - 428 -8102 CUIMBERLANO COUNTY FAX: (757) 518 -0860 PENNSYLVANIA 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. Plaintiff, V. SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 Defendants. 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 15 -55691 ] (717) 249 -3166 CJ� 3 7 M+ 6 6 5p ai ak, 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. SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 Demandados. 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. Sl USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON 1NFORMACION 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 15 -55691 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar vLna deuda. Cualquier infromacion sera utilizada Para ese proposito. Robert N. Polas, Jr., Esquire PA Bar # 201.259 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. SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 Defendants. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendants, SHERI C MELNICK and WAYNE S MELNICK, are adult individuals with last known address of 1016 HEMLOCK LN UNIT 29, ENOLA PA 17025 and 1016 HEMLOCK LN # 29, ENOLA PA 17025. 3. It is averred that Defendants were indebted to MBNA / FIA CARD SERVICES, N.A. / * * * * * * * ** *7057 on September 14, 2005 with account number * * * * * * * ** *2283 (hereafter referred to as "Account "). 4. By using the Account, Defendants 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. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 5. At all relevant times material hereto, Defendants have used said Account for the purchase of products, goods and/or for obtaining services. 6. Defendants were 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 Defendants. 7. Defendants were 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 15, 2012. 8. Plaintiff is the purchaser, assignee and /or successor in interest MBNA / FIA CARD SERVICES, N.A. / * * * * * * * ** *7057 and Plaintiff is now the holder of the Account. 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 $13,190.24. 10. Despite reasonable and repeated demands for payment. Defendants have 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 Defendants, SHERI C MELNICK and WAYNE S MELNICK, in the amount of $13,190.24, plus costs of this action and any other relief t Court deems j reasonable. arrte A. Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15 -55691 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, Cynthia Clarke 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. MAR 2 8 9014 By . Cynthia Clarke Custodian of Records 15 -55691 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. 1 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. BankofAmeric a� I EXHIBIT C BILL OF SALE AND ASSIGNMENT OF LOANS THIS BILL OF SALE AND ASSIGNMENT OF LOANS is made and entered into between PORTFOLIO RECOVERY ASSOCIATES, LLC ( " Purchaser ") and FIA CARD SERVICES, N.A. ( " Seller "), pursuant to the Loan Sale Agreement dated September 13, 2013 (the " Agreement ") entered into between Purchaser and Seller. Capitalized terms not defined herein, shall have the same meaning as defined in the Agreement. (a) In consideration of the payments made pursuant to the Agreement and such other good and valuable consideration, the receipt and legal sufficiency of which are hereby acknowledged, Seller does hereby sell, transfer, convey, assign and deliver to Purchaser all of Seller's right, title and interest in and to each and all of the Loans, as included on the electronic file referenced in Schedule I of the Loan Agreement as BAC Multicard PRA Sale File 0913 Final.xlsx, without recourse and without representation or warranty of any type, kind, character or nature, express or implied, except as specifically provided in the Agreement, and subject to Buyer's and. Seller's repurchase rights as set forth in the Agreement. (b) Purchaser hereby accepts such sale, transfer, conveyance, assignment, and delivery of the Loans, including without limitation the right to all principal, interest or other proceeds of any kind with respect to the Loans remaining due and owing as of the Cut -Off Date applicable to such Loans. (c) Nothing in this Bill of Sale and Assignment of Loans shall be deemed to modify, limit or amend any of the rights or obligations of Purchaser or Seller under the Agreement. This Bill of Sale and Assignment of Loans shall inure to the benefit of, and be binding upon, the respective, permitted successors and assigns of Seller and Purchaser and shall be governed by and construed and interpreted in accordance with the Agreement and the laws of the State of Delaware, without regard to such state's principles of conflicts of law. (d) This Bill of Sale and Assignment of Loans may be executed by facsimile or electronic transmission in multiple counterparts, each of which shall be an original, but together shall constitute one and the same instrument. IN WITNESS WHEREOF, each parry, through its duly authorized officer, has caused this Bill of Sale and Assignment of Loans to be executed in their name this 26` day of September, 2013. SELLER/ASSIGNOR: BUYER/ASSIGNEE: FIA CARD RVICES, N.A. PORTFOLIO COVERY ASSOCIATES, LLC By: By: Name: Debra L Pel icclaro Na me: 4R+,S Title: Vice President Title: Aurrtp�i Fix: 302.458.0438 Multicard .9/13/13 Bank of America, Asset Sales Deerfield Ill, 855 Paper Mill Foad, Newark, DE 0M i�ke r� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;L Sheriff x, :star:ti _ j HE PR0TH0N0T;' Jody S Smith Ott , j Chief Deputy _ 2 14 APR 30 PM 3: 01 Richard W Stewart CUMBERLAND COUNT Solicitor "`` PENNSYLVANIA Portfolio Recorvery Associates, LLC Case Number vs. 2014-2531 Wayne Melnick(et al.) SHERIFF'S RETURN OF SERVICE 04/25/2014 08:41 PM - Deputy Dawn Kell, 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: Wayne Melnick at 1016 Hemlock Lane Unit 29, East Pennsboro Township, Enola, PA 17025. Z " 4 DAWN KELL, DEPUTY 04/25/2014 08:41 PM -Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Wayne Melnick,who accepted as"Adult Person in Charge"for Sheri C Melnick at 1016 Hemlock Lane Unit 29, East Pennsboro Township, Enola, PA 17025. Z S DAWN KELL, DEPUTY SHERIFF COST: $60.95 SO ANSWERS, April 28, 2014 RONW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleo=oft.Inc. V THE 1 r, !1 E PRAT HONQ TAR i 201, NAY 14 PH 1.:02 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORFOLIO RECOVERY ASSOCIATES, LLC, Plaintiff, v. 'SHERI C MELNICK WAYNE S MELNICK Defendants No. 14-2531 Civil Term PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, this 14th day of March 2014, come the Defendants, Sheri C. Melnick and Wayne S. Melnick, and file these Preliminary Objections to the Complaint of Portfolio Recovery Associates, LLC, and aver as follows: 1. Plaintiff files suit against the Defendants alleging that Defendants owe Plaintiff money arising out of an account issued by MBNA/FIA Card Services, N.A. FIRST PRELIMINARY OBJECTION — Pa. R.C.P. 1028 (a)(2) FAILURE TO CONFORM TO LAW OR RULE OF COURT 2. Pa. R.C.P. 1019(h) requires that a claim state specifically whether it is based upon an oral or written agreement. 3. Plaintiff has not averred whether its claim is based upon an oral or written agreement. 4. Pa. R.C.P. 1019(i) requires that when an action is based on writing, the writing shall be attached to the Complaint, or if not, the pleader must explain its absence and set forth the substance of the agreement. 5. Plaintiff has failed to attach such writing to the Complaint. 6. Plaintiff has failed to explain the absence of such writing or set forth the substance of the agreement. SECOND PRELIMINARY OBJECTION — Pa. R.C.P. 1028 (a)(3) INSUFFICIENT SPECIFICITY IN A PLEADING 7. The Complaint contains only a general assertion of the amount Plaintiff claims is owed by the Defendant. It provides no detail as to the date(s) the debt were incurred, the amounts incurred on each date, the dates or amounts of payments, nor the dates of accrual and amounts of interest charges and other fees. 8. Pa. R.C.P. 1019 and Pa. R.C.P. 1028(a)(3) require that such detail be included in a complaint of this type. 9. To support its claim, Plaintiff must allege facts and attach documents that contain: a. the charges that are part of the claim; b. the dates of those charges; c. credits for any payments; d. dates and amounts of any interest charges; and 2 e. dates and amounts of other charges. 10. Plaintiff has failed to attach any account agreement. 11. Plaintiff has failed to attach any monthly or other statements, records, or receipts upon which it bases its claim for the account alleged by Plaintiff to have been agreed to by Defendant. 12. Plaintiff has failed to describe the goods, merchandise, or services provided to Defendant. 13. Plaintiff's failure to include the required detail does not conform to an express rule of court. THIRD PRELIMINARY OBJECTION — Pa. R.C.P. 1028 (a)(2) FAILURE TO CONFORM TO LAW OR RULE OF COURT 14. Plaintiff's Complaint is based upon a contract. 15. Plaintiff appears to assert a cause of action based upon an Account Stated theory of recovery. 16. An Account Stated theory of recovery is not available in consumer credit card cases. 17. Even when alleging an Account Stated theory of recovery, the Complaint must at the very least include allegations which would support a finding that the cardholders have agreed to or acquiesced to the correctness of the account. 18. Plaintiff's failure to include the required detail does not conform to an express rule of court. 3 WHEREFORE, Defendants request that their Preliminary Objections be sustained, and that Plaintiff's Complaint be dismissed with prejudice. Date: May 14, 2014 Respectfully Submitted, Wayne SMelnick Sheri C. Melnick 1016 Hemlock Lane Enola, PA 17025 (717) 856-5494 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORFOLIO RECOVERY ASSOCIATES, LLC, Plaintiff, v. SHERI C MELNICK WAYNE S MELNICK Defendants No. 14-2531 Civil Term Certificate of Service I, Wayne S. Melnick, hereby certify that a copy of the foregoing Preliminary Objections was served upon the following via United States Mail, First Class, Postage Prepaid: Date: May 14, 2014 Carrie A. Brown Robert N. Polas, Jr. Mark R. Garvey Portfolio Recovery Associates, LLC 120 Corporate Boulevard Norfolk, VA 23502 Wayne . Melnick IN THE COURT OF THE COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 and WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 Defendants No. 14-2531 CIVIL PRAECIPE FOR JUDGMENT BY CONSENT Kindly enter Judgment against the Defendants, SHERI C MELNICK and WAYNE S MELNICK, in the amount of $13,190.24. CONSENTED TO: SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 15-55691 Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff QAKA &\\11. -?.A ect* L9 YACt Q�3►oo�'1 This communication is from a debt collector and is an attempt to collect a debt. , Any information obtained will be used for that purpose. 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. SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 and WAYNE S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 Defendants No. 14-2531 CIVIL CONSENT JUDGMENT AGREEMENT PORTFOLIO RECOVERY ASSOCIATES, LLC ("Plaintiff') and SHERI C MELNICK and WAYNE S MELNICK ("Defendant(s)") hereby consent to the resolution of the above -captioned action as follows: 1. Defendants agree, admit, and consent to Judgment in favor of Plaintiff in the sum of $13,190.24. 2. In an effort to resolve this matter, the parties have agreed that said sum shall be paid as follows: The Plaintiff has agreed to accept and Defendants have agreed to pay the total sum of $13,190.24, to be paid as follows: down payment of $125.00 due on May 15, 2014, followed by 104 payments of $125.00, and a final payment of $65.24. Monthly payments will begin on June 15, 2014 and will continue on the 15th day of each month thereafter until agreed upon balance is paid in full. Payments by Defendants shall be made payable to the order of PORTFOLIO RECOVERY ASSOCIATES, LLC, and sent to P.O. BOX 12903, NORFOLK, VA 23541. 3. Plaintiff agrees to stay execution on the Judgment entered for so long as the Defendants makes timely payment as set forth herein, except that nothing herein shall prevent Plaintiff from recording the Judgment as a lien against any real property owned by Defendants. Upon completion of the payment terms as stated above, Plaintiff shall deliver to the Court of Common Pleas of CUMBERLAND County and undersigned, as applicable, a Praecipe to Settle and Satisfy. 4. In the event that Defendants shall fail to make payments as due, or should said payments be returned unpaid by the payer bank or financial institution for any reason, Defendants shall be deemed to be in default. Should such default not be cured within ten (10) days of This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. any payment, the Plaintiff may begin execution on the Judgment. 5. The Defendants waive all defects of service of process and consents to the jurisdiction of this Court. 6. The parties agree that Plaintiff may enter Judgment pursuant to this agreement without issuance of a Rule to Show Cause, and without further proceedings or notice. 7. This Stipulation may be executed in two counte signature of all partiesA r their respective cou elj eco d shall be effective o SHERI C MELNICK 1016 HEMLOCK LN UNIT 29 ENOLA PA 17025 WAYN S MELNICK 1016 HEMLOCK LN # 29 ENOLA PA 17025 15-55691 Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, # 94055 Mark R. Garvey, Esquire # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (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.