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Home My WebLink About14-2841 y�apreme Court;:o Pennsylvania Court�of Com on Pleas ?,/ r_,. R:• 1 For Prothonotary Use Only: TiMESTA MP Milk Ve�,S �et Docket No: CUMBCounty The information collected on this form is used solely for court administration purposes. This fonn does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o 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: j PORTFOLIO RECOVERY ASSOCIATES,LLC KRYSTI OTT f I Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N I (Check one) outside arbitration limits 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./Came Brown/Mark R Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]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(doer not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T 1 ❑ Other: Q MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toadc Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toadc Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Tozac 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: 15-60771 r• j 'Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 - r [`- _ Portfolio Recovery Associates, LLCrr PR0 H t `- 120 Corporate Blvd �,� r NO T .x•f Norfolk, VA 23502 t - �� TELE: 1-866-428-8102 �(/jyC /4 FAX:(757) 518-0860 PES YL C Attorneys for Plaintiff A r 0 U'A' T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LA W PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD q1 VI NORFOLK, VA 23502 No. )�• Plaintiff, V. KRYSTI OTT 1.8 WINCHESTER GDNS CARLISLE PA 17013 Defendant. 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 1701.3 15-60771 (717)249-3166 �t7Sa i� 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 TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. KRYSTI OTT 18 WINCHESTER GDNS CARLISLE PA 17013 Demandado. 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 SI USTED NO TIENE UN ABOGADO, VAYA O LANM E POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE rA 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 15-60771 Esta cornunicacion es de un.cobrador de deudas y es un intent do cobrar was de;uda. Cualquier infrorrucion sera utilizada para ese proposito. 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 TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 : Plaintiff, No. V. KRYSTI OTT 18 WINCHESTER GDNS 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, KRYSTI OTT, is an adult individual with last known address of 18 WINCHESTER GDNS, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to.GE CAPITAL RETAIL BANK/GENERAL ELECTRIC CAPITAL CORP/CARE CREDIT on March 27, 2011 with account number ************9430(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 coirnlnunication is fi-orn 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 June 29, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ GENERAL ELECTRIC CAPITAL CORP/CARE CREDIT and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiff s 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 $1,210.85. 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, KRYSTI OTT , in the amo $1,210.85, plus co s f this action and any other relief as the Court deems just and reasonabl rrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 15-60771 This confl-IlU ication is :6-orn.a debt collector and is an.attempt to collect a debt.. Any inforination obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, DOCY N.Parker 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: APR n 9 201 By: Custodian o Records 15-60771 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 Ts�a This comnunication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. EXHIBIT A BILL of SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated as of this 13th day of December,2012 by and between General Electric Capital COrparation,GE Capital Retail Bank, GEMS Lending,Inc.,Monogram Credit Services,L.L.C.,RFS Holding, L.L.C.,and GEM Holding,L.L.C.(collectively"Seller")and Portfolio Recovery Associates,LLC(`Buyer"), Seller hereby transfers,sells,conveys,grants,and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement,to the extent of its Ownership,the Receivables as set forth in the Notification Files(as defined in the Agreement), delivered by Seller to Buyer on each Transfer Date,and as ftuther described in the Agreement. GE Capital Retail Bank By: Glenn Marino Title: EVP General Electric Capital Corporation By. , .. .. Glenn Marino Title:_Vice President GEMB Lending,Inc. By: Stephen Motta Title:Director Monogram Credit Services,L.L.G., Glenn Marino Title:President ` 31 EXHIBIT A BILL of SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement'),dated as of this 13th day of December,2012 by and between General Electric Capital Corporation,GE Capital Retail Bank,GEMS Lending,Inc.,Monogram Credit Services,L.L.C.,RFS Holding,L.L.C.,and GEM Holding,L.L.C.(collectively"Seller")and Portfolio Recovery Associates, LLC("Buyer"), Seller hereby transfers,sells,conveys,grants,and delivers to Buyer,its successors and assigns, without recourse except as set forth in the Agreement,to the extent of its ownership,the Receivables as set forth in the Notification Files(as defined in the Agreement),delivered by Seller to Buyer on each Transfer Date,and as further described in the Agreement. GE Capital Retail Bank By: Glenn Marino Title: EVP General Electric Capital Corporation By: Glenn Marino Title: Vice President GEMB Lending,Inc. By: kk �' step en offs Title:Director Monogram Credit Services,L.L.C., By: Glenn Marino Title:President 31 RFS olding,L.L.C. 8y: Josep essa Title: F GEM Holding,L.L.C. By: 4—C a Titl 32 CARECREDIT/(ECRB Cardholder Name: Account Number: 9430 GE Capital Retail Bank Statement Closing Date: 02/0W2013 i •+i+i+i+i+•+i+•+i+ }}i�# *4�•+i+i+i+i+•+i+•+i+•+i+i i►`'14.It13l�+J61��ti4lIi0L+ +r,r� �r�„r�a.i.�y Previous Balance $1,175.85 New Balance $000 + New Purchases - $0,00 Taal Minimum Payment Due $313.00 - Payments $0.00 Payment Due Date 02110'2013 +/- Credits,Fees&Adjustments(net) $1,175$5- PAYMENT DUE BY 5 P,M.EASTERN ON THE DUE DATE. +/- Interest Char net $0.00 We may convert your payment into an electronic Mbit. See NewBalonce $0,00 reverse side. Credit Limit $4,OOa00 Available Credit $0,00 Late Payment Warning: If we do not receive your Total Days in Billing Period 27 Minimum Payment Due by the Payment Due Date listed above, you may have to pay a late fee up to$35.00. Pay online for free at:gDWeapital.com For GE Capital Retail Bank customer service or to report yourcard lost or stolen,call 1-866.8937864. Best times to call are Wednesday-Friday, 70:2108-/2013 +#+i+Post Date Reference Number pesaiption Amount 2/08/2013 F9072001700999990 CHARGE OFF ACCOUNT.PRINCIPALS $38200CR 2/082013 F9072001700999990 CHARGE OFFACCOUNT-FINANCE $828.85CR CHARGES' FEES 071052013 07/052013 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INTEREST CHARCED 02/082013 WJ082013 - INTEREST CHARGE ON PURCHASES $0,00 TOTAL INTEREST FOR THIS PERIOD $0.00 ttttttttt+lyt*}��}} t¢*tt+t+t+ttt+ •+i+#+i+t+#Mvi1#W# ��i W�f+#+i+i+i+t+ Total Fees Charged in 2013 $70.00 Total Interest Charged in 2013 $26.07 Total Interest Paid in 2013 $0,00 +• + + +•+#+•+i+i+i+i+i+•+•+i+i+•+i+#+i+•+i+#+i+•+•+#+#+#+i+t Expiration Date Annual Balance Subject to Interest Charge Type of Balance Percentage Interest Rate Ratc(APR) Purchases NA 26.99% $0.00 $0.00 +ttt+t+t+t+t+t+t+t+t+t+ttttt+t+ttt+t+t+t+ttt+t+t+ttt In order to protect youraccount privacy,we are unable to provide account information to anyone other than the cardholder(s)or an authorized party.If you wish to permit us to speak to an authorized party such as a spouse about your amount,please send written authorization to the General inquiries address •NOTICE:See reverse side andadditional pages(if any)for important information concemingyour account. 5302 DEE 1 3 10 130208 2D PAGE 1 of 1 9072 3000 C6L0 OlEJ5302 Pay online at gogecapital.com or enclose this coupon with your check.Please use blue or Mack ink. Payment Enclosed: $ .... .. .. ' .New address ore-mail? Payment due includes$0.00 fast due.Please pay the past due amount PROMPTLY. Check the box at left and print changes on back KRYSTI M OTT FFAFDFFFTFDFFFDFFDFDDADFFMfTTFTFDAFATAADAADAATDTATADTAADDTTFDDTF - 18 WINCHESTER GDNS CARLISLE PA 17013-1071 Make Paymentto: CE CAPITAL RETAIL BANK PO BOX 960061 ORLANDO,FL 32896.0061 FAFFrDTDTTFTAADFTTATTAAAFDADFAFAFDTDATFDDAFDTD77FrMDAADTDAFAAADA Customer Service/Questions:For account information,please call the toll free number on the front of this statement.Unless your name is listed on this statement,your access to information on the account maybe limited.You may also mail questions (but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033..Please include your account number on any correspondence you send to us. Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www. gogecapital.com. Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekivo Springs Road,Longwood,FL 32779. Notice:See belowforyour Billing Rights and other important information.Telephoning about billing errors will not preserve your rights under federal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando, FL 32896-5035. Purchases,returns and payments made Just prior to billing date may not appear until next month's statement.When Cdprovide a check as payment,you authorize us either to use information from your check to make a one-time electronic fundtransferfrom your account ortoprocessthe payment asacheck transaction.When we use information from your check to make an electronic fund transfer,funds maybe withdrawn from your account as soon as the someday we receive your payment and you will not receive your check back from your financial institution.You may choose not to have your payment collected electronically by sending your payment lwlth the remittance coupon),In your own envelope-not the enclosed remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address. What To Do If You Think You Find A Mistake On Your Statement: Ifyou think there is an error on your statement,write to us at GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035. In your letter give us the following information: •Account information:Your name and account number •Dollar amount:The dollar amount of the suspected error •Description of problem:Ifyou think there is an error on your bill,describe what you believe is wrong and why you be- lieve it is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing.You may call us,but ifyou do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not there has been an error,the following are true: •We cannot try to collect the amount in question or report you as delinquent on that amount. •The charge in question may remain on your statement and we may continue to charge you interest on that amount. But,if we determine that we made a mistake,you will not have to pay the amount in question or any interest or other fees related to that amount. •While you do not have to pay the amount in question,you are responsible for the remainder of your balance. •We can apply any unpaid amount against your credit limit. Information About Payments:You may at anytime pay,in whole or in part,the total unpaid balance without any additional charge for prepayment. Payments received after 5:00 PM(ETI on any day will be credited as of the next day.Credit to your account may be delayed up to five days if payment to)is not received at the payment address,IN is not made in U.S.dollars drawn on a U.S.financial institution located in the U.S.,Ic)is not accompanied by the remittance coupon attached to your statement.(d)contains more than one payment or remittance coupon.(e)is not received in the remittance envelope provided or(f)includes staples,paper clips,tape,a folded check or correspondence of any type.QI1d&Qn9L9aym&otw All written communications concerning disputed amounts,including any check or other payment instrument that(i)indicates that the payment constitutes"pa ment in full"or is tendered as full satisfaction of a disputed amount,or(iii is tendered with other conditions or limitations 1"Disputed Payments'),must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896-5035. Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits will be applied to your previous balance immediately upon receipt,but will not satisfy any required paymentthat may be due. Credit Reports and Account information:Ifyou believe that we may have reported inaccurate information about you to a consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the inaccurate information and tell us why you believe it is incorrect.Ifyou have a copy of the credit report that includes the inac- curate information,please include a copy of that report.We may report information about your account to credit bureaus. - Late payments,missed payments,or other defaults on your account may be reflected in your credit report. How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily but- once"of your account for each day in the billing cycle. We then add the interest to the daily balance. To get the"daily bal- . once"we take the beginning balance of your account each day(which includes unpaid interest),add any new charges,and applicable fees,and subtract any payments or credits.This gives us the daily balance.Any daily balance of less than zero will be treated as zero.A separate daily balance will be calculated for each balance type on your account.The balance(s)shown in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by the number of days in the billing cycle. Bankruptcy Notice:Ifyou file bankruptcy you must send us notice,including account number and all information related to the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell.GA 30076. Your account is owned and serviced by GE Capital Retail Bank. Hearing Impaired:TDD users call 1-877448-8512 Use of Information About You and Your Account:Our Privacy Policy describes our collection and disclosure of information aboutyou and your Account.Ifyou would like another copy of the Privacy Policy,please call us at the customer service tele- phone number indicated on the front of this statement. This is an attempt to collect a debtand any information obtained will be used forthat purpose. OlEJ5302-12-03/05/12 By providing a telephone number on your account,you consentto GE Capital Retail Bank and any other owner or servicer of your account contacting you about your account,including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system and/or an artificial or rerecorded voice when contact- ing you,even ifyou are charged for the call under your phone plan. For changes of address or phone number,please check the box and print the changes below. Retail EN-OlEJ5302 Name ❑ Street Address City State Zip Code Home Phone# Business Phone# Cell#or other phone#we can use to contactyou Email Address Remember,you can update the above information as well as youre-mail address online at www.gogecapital.com SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c` L F U Sheriff i. THE P RO I HO 0 `z F Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE S'! RIFF is JUN- p: 3: (5 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Krysti M Ott Case Number 2014-2841 SHERIFF'S RETURN OF SERVICE 05/16/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Krysti M Ott, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 18 Winchester Gardens, North Middleton, Carlisle, PA 17013. Deputies were advised that the current resident has lived at this address for two years nad the defendant does not live at this address. Per the Carlisle Postmaster mail is still delivered to this address. SHERIFF COST: $46.56 SO ANSWERS, May 23, 2014 (c) CountySuito Sheriff, Teleosoft, Ir . RONI4S1 R ANDERSON, SHERIFF Carrie A. Brown, Esquire -EPcP. Tul-ifOri Robert N. Polas Jr, Esquire 2014 Mark R. Garvey, Esquire 1 % 4 Attorney #94055/201259/312686 OF THE Portfolio Recovery Associates, LLC kCOLTAfi VA NIANTY 120 Corporate Blvd JUL 29 PH (2: I Norfolk, VA 23502 CUMBERLAND COU Attorneys for Plaintiff PEYL NNs 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. 14-2841 CIVIL V. KRYSTI OTT 18 WINCHESTER GDNS CARLISLE PA 17013 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. espect ly Subm. ted -s sert 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 15-60771 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 Roberl- N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID#94055/201259/312686 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 PORTI-OLIO RECOVERY ASSOCIATES, LLC • 120 CORPORATE BLVD : NORFOLK, VA 23502 : Plaintiff : No. 14-2841 CIVIL v. . • KRYSTI OTT • 18 WINCHESTER GDNS • CARLISLE PA 17013 • Defendant • CERTINCATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon KRYSTI OTT, by First Class Mail, Postage Pre-Paid, a copy thereof on tiliday of Aif / ir , 2014, to: KRYSTI OTT, 18 WINCHESTER GD S, CA LISLE PA 013 ert 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 l'ELE: 1-866-428-8102 FAX: (757) 518-0860 15-60771 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.