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HomeMy WebLinkAbout14-2709 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 fifinq and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction C3Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: LISA A HALL C PORTFOLIO RECOVERY ASSOCIATES LLC I Are money damages requested? ® Yes❑ N Dollar Amount Requested: ® within arbitration limits (Check one) ❑ outside arbitration limits 0 N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney '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 X Debt 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 mass ton ❑Employment Dispute: C ❑ Slander/Libel/Defamation Discrimination T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board 1 ❑ 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 2925445 PPTXSCPI (1/15/2014) Blatt, Hasen_miller, Leibs_ker& Moore, LLC Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney-LID #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 - No. � � , a cup LISA A HALL 7 BIRCH ST n _t MECHANICSBURG PA 17050 `"= 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 800-990-9108 2925445 PPTCPADI (03/04/2014) 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O 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 Syretta Martin Attorney I.D. #309370 Frank Janello Attorney I.D. #315643 Beth Arnold Howell Attorney I.D. #203606 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. LISA A HALL 7 BIRCH ST MECHANICSBURG PA 17050 Defendant(s). COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), LISA A HALL, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) opened an extension of credit agreeing to make monthly payments for the purchases charged to the account and/or cash advanced. 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$891.90. 4. Plaintiff is the successor in interest of said account from CITIBANK, N.A STAPLES 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. 2925445 PPTCDBCI (04/02/2014) 11111111111111 IIII 11111111111111 VIII VIII VIII VIII VIII VIII 111111111 IIII WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), LISA A HALL in the amount of $891.90, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC OnA.of its Atfornevs Syretta Martin Attorney I.D. #309370 Frank Janello Attorney I.D. #315643 Beth Arnold Howell Attorney I.D. #203606 Blatt, Hasenmiller, Leibsker& Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: � `� Verification I, Dwayne E.Danns , 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. Date: A P R 2 2 2014 Si nature 2925445 PPTXVRI I (011/14/2014) I VIII IIIIIII III 111111 VIII VIII VIII VIII VIII VIII IIIIIII II IIII Exhibit "A" PPTXEXAI Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: 6 Customer Service: STAPLES CREDIT PLAN � . staplespersonafaocouruoNiiecom PO Box 6403,Sioux Falls SD,67117-6403 Account Inquiries: •� 1-888-316-8480 i4GCnWtl:Nli1 ?15:`� 34 .: Summary of Account Activit Payment Information Previous Balance $861.06 New Balance $916.90 Payments -$0.00 Minimum Payment Due $405.99 Other Credits _$0.00 Payment Due Date January 4, 2012 Purchases 0.00 Cash Advances 0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Char ed +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$20,84 Minimum Payment Warning: If you make only the minimum payment each New Balance $916.90 period,you will pay more in interest and it will take you longer to pay off your balance For example Past Due Amount $340.99 ?, If y>1u n�lk>�itd diiYdii1dr19ai You will pax bfl ihs Atte you will charges usltlg tails oers balance shbwrl lyn tffls etrc4up p TO an and pacl rrlonth:you pay. statem4ht Pn abr�ut esttma#ad total of Credit Limit 0.00 Only the minimum payment 3 years $1,148 Available Credit $0.00 If you would like Information about credit counseling services,call 1-877-337-8188. Statement Closing Date 12/08/2011 Next Statement Closing Date 01/08/2012 Das in Billing Cycle 31 TRANSACTIONS Trans Date Description Reference# Amount FEES 12/04 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 12/08 INTEREST CHARGE ON PURCHASES $ 20.84 TOTAL INTEREST FOR THIS PERIOD $ 20.84 MANAGE YOUR ACCOUNT ONLINE . . ANYTI M _ ' -Access current and past statements -Set up email alerts -Pay your bill online 24/7 with same day posting" View recent activity . Register now at staplespersonal.accountonline.com •If payment is received by 5pm ET. 8SL3 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- '*Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.+ Make Checks Payable to: am STAPLES CREDIT PLAN t Past Due Amount is included in the Minimum Payment Due. Your Acoount Number Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 2;;4t:'.: JANUARY 4,2012 $916.90 $340.99 $405.99 $ SAVE STAMPS TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, � Paperless Statements and More. 344 STAPLES CREDIT PLAN PROCESSING CENTER LISA A HALL DES MOINES IA 50364-0001 105 EASTERLY DR MECHANICSBURG,PA 17050-7936 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(if available on your account)on the transaction date. While we investigate whether or not there has been an error: If you have a balance subject to a deferred interest or 0%APR promotion and that We cannot try to collect the amount in question,or report you as delinquent on promotion does not expire before the payment due date,that balance(the that amount. "excluded promotional balance")is excluded from the amount you must pay in full The charge in question may remain on your statement,and we may to get a grace period.However,you must still pay any separately required payment continue to charge you Interest on that amount. on the excluded promotional balance.In billing cycles in which payments are While you do not have to pay the amount in question,you are responsible allocated to deferred interest balances first,the deferred interest balance will be for the remainder of your balance. reduced before any other balance on the account.However,you will continue to We can apply any unpaid amount against your credit limit. get a grace period on purchases so long as you pay the New Balance less any After we finish our investigation,one of two things will happen: excluded promotional balances in full by the payment due date each billing cycle. If we made a mistake.You will not have to pay the amount in question or an We may refer to deferred interest promotions as No Interest or No Monthly interest or other fees related to that amount. y Interest promotions If we do not believe there was a mistake:You will have to pay the amount In addition,certain promotional offers may take away the grace period on in question,along with applicable interest and fees.We will send you a purchases.Other promotional offers not described above may also allow you to statement of the amount you owe and the date payment is due.We may then have a grace period on purchases without having to pay all or a portion of the report you as delinquent if you do not pay the amount we think you owe. promotional balance by the payment due date.If either is the case,the promotional offer will describe what happens. If you receive our explanation but still believe your bill is wrong,you must write to u ect to Interest Rate.For each balance,the us within 10 days telling us that you still refuse to pay.If you do so,we cannot How We Calculate Your Balance S letter following the Annual Percentage Rate in the Interest Charge Calculation report you as delinquent without also reporting that you are questioning your bill. section on the front of the statement indicates the method we use to calculate We must tell you the name of anyone to whom we reported you as delinquent,and we must let those organizations know when the matter has been settled between interest charges.For Methods B and E,we use an average daily balance method (including current transactions)to calculate interest charges.For Methods C,D and us. M,we use a daily balance method(including current transactions)to calculate If we do not follow all of the rules above,you do not have to pay the first$50 of interest charges.To find out more information about the balance computation the amount you question even if your bill Is correct. method that applies to your account and how the resulting interest charges were your Rights If You Are Dissatisfied With Your Credit Cab Purchases determined,contact us at the Account Inquiries number on the front. 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 not 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: What To Do if You Find A Mistake On Your Statement 1. The purchase must have been made in your home state or within 100 If you think there is an error on your statement,write to us at the address for miles of your current mailing address,and the purchase price must have billing inquiries and correspondence shown on the front of your statement. been more than$50.(Note:Neither of these are necessary if your rchase was based on an advertisement we ma In your letter,give us the following information: the company that sod you the goods or services.) d to you,or if we own • Account information:Your name and account number. 2.You must have used your credit card for the purchase.Purchases made with Dollar amount:The dollar amount of the suspected error. cash advances from an ATM or with a check that accesses your credit card • Description of problem:If you think there is an error on your bill, account do not qualify. describe what you believe is wrong and why you believe it is a mistake. 3. You must not yet have fully paid for the purchase. You must contact us: If all of the criteria above are met and you are still dissatisfied with the purchase, • Within 60 days after the error appeared on your statement. contact us in writing at the address for billing inquiries and correspondence shown • At least 3 business days before an automated payment is scheduled,if you want on the front of your statement. to stop payment on the amount you think is wrong. 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, 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 we are not required to investigate any potential errors and you may have to pay delinquent. the amount in question. RPLG 12)11 T01675-9194.2600.0003-E-40-X--12/01/10-27-000-P-B-0--7-8-0-STAPLES--04/30/11-STEB-November 7,2011-0 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 Payments.If we receive your payment in proper form at our processing payments.Contact your local store to see if in-store 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 front of your check or money payment credited as of that day.If you call after that time,your payment order. 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$5 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 that day.All payments received in proper form at the proper address months or more.We add the fee to the regular purchase balance.We waive the fee as if your request for the copy relates to a billing error or disputed purchase. afteerr that time will be credited as of the next day. Page 2 of 4 Account: **** **** **** 2344 �Q 1 `ntals 1�ear-to�Lfate Total Fees Charged in 2011 $284,96 Total Interest Charged in 2011 $176.66 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)Is the annual Interest rate on your account. oFBelartCtb, •: �: , ;Annua�P�roentaae RaC�:(AR�i , b)er:ttolnteirtft�ta (t►le�eSt Char e. ;� PURCHASES REGULAR 27.99%(M)(V) 876.68 $20.84 V =Variable Rate Page 3 of 4 Account: **** **** **** 2344 Page 4 of 4 Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, 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 LISA A HALL vs. No. ILI 7 BIRCH ST `` = — g x-- MECHANICSBURG PA 17050 Defendant(s). '. y=yrNI c' PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: `` _ r 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: April 15, 2014 By: yretta Martin Attorney 2925445 PPTXPEAI (11/18/2013) 11111111111111 IN 11111111111111111111111111111111111111111111111111111 IN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i±/1 U ;; = . Sheriff i'.' I H''. PROTI'iOHO ir`tiR Y Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF 20111 MAY 14 PM 3: 13 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Lisa A Hall Case Number 2014-2709 SHERIFF'S RETURN OF SERVICE 05/09/2014 08:11 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: Lisa A Hall at 7 Birch Street, Silver Spring Township, Mechanicsburg, PA 17050. Kai_ DAWN KELL, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, May 12, 2014 (C) CountySuite Sherif(, T©leosoff, Inc. RONZ ANDERSON, SHERIFF