HomeMy WebLinkAbout14-3299 Supreme C Pennsylvania
Courif Com� n Pleas
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CUNIB& o bounty _, T
The information collected on this form is used solely for court administration purposes. This form does not
supplement or rep lace the filing and service ofpleadings or other a ers as required by law or rules o court.
Commencement of Action:
® Complaint ❑ Writ ofSumrnons ❑Petition
❑ Transfer fromAnother Jurisdiction ❑Declaration of Taking
�m Lead Plaintiffs Name: Lead Defendant's Name:
I PORTFOLIO RECOVERY ASSOCIATES, LLC REGINA BROUGHTON
Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
"
(Check one) outside arbitration limits
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 haw no attorney (are a Self- Represented [Pro Se] Litigant)
€EE
3 32, Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRO MY 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) CIVQ. APPEALS
=' ❑ Intentional
<<, E] 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 El Statutory Appeal: Other
S ❑ Product Liability (does not include
mass tort) ❑ Employment Dispute:
❑ Slander /Libel/Defamation Discrimination ❑ Zoning Board
❑ Other:
El Employment Dispute: Other E] Other:
A
❑ Other:
MAS S TORT
❑ Asbestos
❑ Tobacco
E ❑Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Toxic Waste ❑ Eminent Domain /Condemnation El Declaratory Judgment
F Other: E] Ground Rent E] Mandamus
., ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
IN 11
❑ Mortgage Foreclosure: Residential Restraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Wananto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILPTY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
15 -84213
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 y 2 F 14 1
Norfolk, VA 23502
TELE: 1-866-428-8102 r �'D
FAX: (757) 518-0860 FE N' Y LVA N, I A
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. N-3,Z9� �/ ��'�'`
Plaintiff,
V.
REGINA BROUGHTON
105 WALNUT ST
BOILING SPRINGS PA 17007
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 QD
Cumberland County Bar Association
32 South Bedford Street ?CL &11y(
Carlisle, PA 17013
(717) 249-3166
15-84213
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.
REGINA BROUGHTON
105 WALNUT ST
BOILING SPRINGS PA 17007
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 aiso 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 LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION 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 -84213
Esta C011IL1r1icacion es de un eobrador de deLicl as y es un fluent do cobrar Lnla dCUda.
CLAILlier irifromacion sera utilizada party 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 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.
REGINA BROUGHTON
105 WALNUT ST
BOILING SPRINGS PA 17007
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, REGINA BROUGHTON, is an adult individual with last known address of 105
WALNUT ST, BOILING SPRINGS PA 17007.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/ AMAZON on
December 13, 2009 with account number * * * * * * * * * ** *2099 (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.
"Ihs C 11 MILInication is fiom a cleft collector and is an attempt to collect a debt.
Any int6ii nration 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. A copy of the charge off statement is attached hereto and collectively marked as
Exhibit "A"
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 March 20, 2012.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK /
AMAZON and Plaintiff is now the holder of the Account. A true and correct copy of the
Plaintiffs Bill of Sale is attached hereto and collectively marked as Exhibit "A"
9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's
Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum
of $1,123.98.
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 Jud ent in favor of
Plaintiff and against Defendant, REGINA BROUGHTON , e amount of $1, 3.9 , plus costs of this
action and any other relief as the Court deems just and re o ble.
ie Brown, Esquire, # 94055
Robert N. Polas, Jr., Esquire, # 201259
Mark R Garvey, Esquire, # 312686
Attorneys for Plaintiff
15 -84213
This CoMMUnication is fi °ont a debt collector and L's an atten -4)t to collect a debt.
Any infonTiation obtained will be ci.5ed for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Anita Bray 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 belied based
upon information provided by the Plaintig
The undersigned understands that false statements herein are made subject to the
penalties of 18 Pa. C. S. Section 4904, relating to unworn falsification to authorities.
Date: APR 3 0 2114 By:
Anita Bray
Custodian of Records
15 -84213
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
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
/ l
GE Capital
BILL of SALE
PRA PLCC Fresh – November 2012
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 the 25 day of June, 2012 by and between General Electric Capital Corporation, GE
Money Bank, GEMB 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 November 20, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: B y: 1 �c -,,.,� v—
Glenn. Marino Glenn Marino
Title: _EVP Title: President I
Date: 1 Z.� t 3 IZ Date: 1Z'I 43! 1 Z.
General Electric Capital Corporation RFS Holding, L.L.0
B `-`' -�/ By:
Glenn Marino Joseph Ressa
Title: _Vice President Title: –CFO
Date: 12 !3W Date:
GEMB Lending, Inc. GEM Holding, L.L.0
By: By:
Stephen Motta Joseph Ressa
Title: _Director Title: CFO
Date: Date:
AddoLdNEIN
' GE Capita!
BILL of SALE
PRA PLCC Fresh — November 2012
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 the 25` day of June, 2012 by and between General EIectric Capital Corporation, GE
Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RF S 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 November 20, 2012, and as
fin described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
By: By:
Glenn Marino Glenn Marino
Title: _EVP _ Title: President
Date: i Date:
General Electric Capital Corporation RFS Holding, L.L.0
By: B
Glenn Marino Joseph Ressa
Title: _Vice President Title: CFO
Date: Date:
GENM Lending, Inc. GEM Holding, L.L.0
By- r By:
Stephen otta Joseph Ressa
Title: Director Title: CFO
Date: At1T1 Date:
r '
' GE Capital
BILL of SALE.
PRA PLCC Fresh - November 2012
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 the 25` day of June, 2012 by and between General Electric Capital Corporation, GE
Money Bank, GEMS Lending, Inc., Monogram Credit Services, L,.I..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 November 20, 2012, and as
further described in the Agreement.
GE Capital Retail Bank Monogram Credit Services, L.L.C.
B y' — - — - -- _ B y .
Glenn Marino Glenn Marino
Title: _EVP Title: President
Date: Date:
General Electric Capital Corporation RFS ding, L.L. .
By: By: _.___ U_ f
Glenn Marino Joseph R s a
Title: _Vice President_ "Title: CFO
Date: _ Date.
GEMS Lending, Inc. GE olding, L.L.
By: By: �-
Stephen Motta Joseph es a
Title: _Director Title: CFO
Date: __....._. -._ Date: t-
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REGINA L BROUGHTON Visit mat www,amazon.com/storecard
Account Number 2099 Customer Service: 1- 866 - 771 -1105
IPAIaIo�t ! # «Mi�' +ttt +t +t +t +ttttt# P11 * +&dt - .............. .. ......
Previous Balance $1,123.98 NewBalance $0.00
- Other Credits _ $1,123.98 Amount Past Due $0.00
New Balance $0.00 Total Minimum Payment Due $333.00
Payment Due Date 10/28/2012
Credit Limit $900.00 Late Payment Warning If we rb not receive your minimum
Available Credit $0.00 payment by the date listed above, you may haveto pay a late
Statement Closing Date 10/26/2012 fee up to $35.00.
Days in Billing Cycle 30
Tmn Date Post Date Reference Number Description of Transaction or Credit Amount
OTHER CHARGES
10/26 10/26 F93420OMW00999990 CHARGE OFF ACCOUNT- PRINCIPALS ($796.13)
10126 10/26 F934200MW00999990 CHARGE OFF ACCOUNT -FINANCE CHARGES* ($327.85)
TOTAL OTHER CHARGES ($1,123,98)
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
10/26 10/26 INTEREST CHARGE ON PURCHASES $0.00
TOTAL INTEREST FOR THIS PERIOD $0.00
Total Fees Charged in 2012 $210.00
Taal Interest Charged in 2012 $189.47
Taal Interest Paid in 2012 $85.00
PAYMENT DUE BY 5 P M (ET) ()N THE !]] IE OATP
NOTICE: We may convert your payment into an electronicdebit. See reverse for details, Billing Rights Information and other
important information
5484 X2G 1 3 25 121026 Z PAGE I of 3 9342 1000 APS1 OILA5484
Detach and mail this portion with your check. Do not include any correspondence with your check.
amazon.com Account Number: 2099
. A4 0 el&D * *41* dt t
$333.00 $0.00 1 10/28/2012 $0.00 1 $0.00
Payment Enclosed: Olson o n
Please me blue or black ink. $
Save a stamp, pay on-line at
www.amazou.com /storecard New address or email? Print Changes on back.
REGINA L BROUGHTON FTADAFDFADFDFFFDAAADDDAATDDADDFFADDDDFTATFDFFAFFTDAATATTAFFATFDDA
425A W KING ST
SHIPPENSBURGPA 17257 -1613 Make Payment to: (ECR &AMAZON
PO BOX 960013
ORLANDO, FL 32896 -0013
DAFDTAAATFTAAAFDDFADTFTFFTDATFADFDDAADAFDTFFAFATTTA &
2 0990
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 may be limited. You may also mail questions (but not payments) to. P.O. Box 965013,
Orlando, FL 3 2896 -501 3. Please include youraccount c umber on any correspondence you send to us.
Payments: Send payments to the address listed on the remit portion of this statement or pay online.
Notice: See below for your Billing Rights and other important information. Telephoning about billing errors will not preserve your nghis under federal
law. To preserve your rights, please write to our Billing Inquiries Address, PO. Box 965016, Orlando, FL 32896 -5016.
Purchases. returns and payments made just prior to billing date may not appear until next month's statement. When you provide a check as
payment, you authorize us either to use information from your check to make a one -lime electronic fund transfer from youraccountorto process the
payment as a check transaction. When we use information from your check to make an electronic fund transfer, funds maybe withdrawn from your
account as soon as the same day 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 (with the payment stub), In your own envelope — not
the enclosed window envelope, addressedto: P. O.Box530993,Atlanta,GA30353.0993 and not the P mentAddress.
Wh aiiDoIf You Think YoulildAMistakeOnYourStatement Credits To Your Account: An amount shown in parenthesis or
II you think there is an error on your statement. write to us at the preceded by a minus ( -) sign is a credit or credit balance unless
Billing Inquiries Addressof. otherwise indicated. Credits will be applied to your previous balance
GF Capital Retail Bank Immediately upon receipt, but will not satisfy any required payment that
P0. Box 965016, Orlando, FL 32896-5016 maybedue.
In your letter, give us the following information: Credit Reports And Account Information: If you believe that we have
• Accountinformation : Your name and account number reported inaccurate information about you to a consumer - reporting
• Dottaramount The dollar amount of the suspected error agency, please contact us at P0. Box 965015, Orlando, FL 32896-
• Description of Problem: If you think there is an error on your bill, 5015. In doing so, please identifythe inaccurate information and tell us
describe what you believe is wrong and why you believe it is a mistake. why you believe it is incorrect. If you have a copy of the credit report that
You must contact us within 60 days after the error appeared on your includes the inaccurate in formation, please include acopy ofthat report.
statement. We may report information about your account to credit bureaus. Late
You must notify us of any potential errors in writing. You may call us, payments, missed payments, or other defaults on your account may be
but if you do we are not required to investigate any potential errors and reflected in yourcredit report .
you may haveto paytheamounl in question. Balance Subject To Interest Charge Calculation
While we investigate whether or not there has been an error, the Method 2D (Daily Balance method): We figure the interest charge on
following are We: your account by applying the periodic rate to the daily balance' of your
• We cannot try to collect the amount in question, or report you as account for each day in the billing cycle. We then add the interest to the
delinquenton thatamounl. daily balance. To get the 'daily balance we take the beginning balance
• The charge in question may remain on your statement, and we may of your account each day (which includes unpaid interest), add any new
continue to charge you interest on that amount. But, if we determine that charges, and applicable fees, and subtract any payments or credits.
we made a mistake, you will not have to pay the amount in question or This gives us the daily balance. Any daily balance of less than zero will
any interest or other fees related to [hat amount. be treated as zero. A separate daily balance will be calculated for each
• While you do not have to pay the amount in question, you are balance type on your account. The balance(s) shown in the Interest
responsible for the remainder of your balance. Charges section of this statement is the sum of the daily balances for
• We can apply any unpaid amount against your credit limit. each day in the billing cycle divided by the number of days in the billing
Your Rights it You Are Dissatisfied With Your Credit Card cycle.
Purchases Bankruptcy Notice: If you file bankruptcy you must send us notice,
If you are dissatisfied with the goods or services that you have including account number and all information related to the proceeding
purchased with your credit card, and you have tried in good faith to to the following address: GE Capital Retail Bank, Attn: Bankruptcy Dept.,
correct the problem with the merchant . you may have the right not to P0. Box 103104. Roswell GA30076.
pay the remaining amount due on the purchase. Your account is owned and serviced by GE Capital Retail Bank.
To use this right . all of the following must be true: Hearing Impaired: TOD users call 1 -800- 444 -1732.
1. The purchase must have been made in your home state or within
100 miles of your current mailing address, and the purchase price must
have been more than S50. (Note: Neither of these are necessary if your
purchase was based on an advertisement we mailed to you,. or if we
own the company that sold you the goods orservices.)
2. You must have used your credit card for the purchase. Purchases
made with cash advances from an ATM or with a check that accesses
yourcredii card account do not qualify
3. You must not yet have fully paid forthe purchase.
If all of the critena above are met and you are still dissatisfied with the
purchase, contact us in writing at:
GE Capital Retail Bank
P0. Box 965016, Orlando. FL 32896 -5016
While we investigate, thesame rules apply tothe disputed amount as
discussed above. Ader 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.
Information About Payments: You may at any time pay, in whole or
in part, the total unpaid balance withoutany additional charge for
prepayment. Payments received after 5.00 PM (ET) on any day will be
credited as of the next day. Credit to your Account may be delayed up to
five days if payment (a) is not received atlhe Payment Address, (b) is not
made in U.S. dollars drawn on a U.S. financial institution located in the
U.S., (c) 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.
Conditional Payments All written communications concerning disputed
amounts, including any check or other payment instrument that: (i)
indicates that the payment constitutes'payment in full" or is tendered as
full satisfac0on of a disputed amount, or (it) is tendered with other
conditions or limitations ( "Disputed Payments'), must be mailed or
delivered to us at P0. Box 965016, Orlando, FL 32896 -5016.
01 LA5484 - 1 - 06/3012011
This is an attempt to collect a debt and any information obtained will be used for that purpose.
'By providing a telephone number on your account, you consent to 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 prerecorded voice when contacting you. even if you are charged forthe call under your phone plan.
For changes of address, phone number andfor email. please check the box and print the changes below
Street
Address
City. Slate,
❑ Zip
Phone #
E -mail
Home Phone # Business Phone # "Cell # or other phone # we Email Address
can use to contact you
By providing your email address, you agree to receive email communications about your account and
also give permission for us to share your email address to the named retailer on this account.
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'i'i Si "iLlii "i'i li i. l ii i Y i i iii i i i i i iiiiiiiii i iii i ii ii i iiii i ii i ii iii ii
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Expiration Annual Balance Subject Interest
Type of Balance Date Percentage Rate to Interest Rate Charge
Regular Purchase NA 25.99% $0.00 $0.00
5484 %2G 1 3 25 121026 Z %PAGE 3 of 3 9342 1000 APS1 OILA5484
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _�
L r
Sheriff _1; THE PRCTt'It)��L.1 !tat
r wee/
Jody S Smith 7.{11Li JUN 17 AM 9: V.3
Chief Deputy`
Richard W Stewart M CUMBERLAND COUNTY
Solicitor OFFICE OFTHE $HF-F•IFF PENNSYLVANIA
Portfolio Recorvery Associates, LLC
vs.
Regina Broughton
Case Number
2014-3299
SHERIFF'S RETURN OF SERVICE
06/05/2014 10:20 AM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint &
Notice by "personally' handing a true copy to a person representing themselves to be the Defendant, to
wit: Regina Broughton at 105 Walnut Street, South Middleton Township, Boiling Springs, PA 17007.
SHERIFF COST: $34.78
June 09, 2014
(c) CauntySuite Sheriff, Teleosoff, Irc.
at
RYAN BURGETT, DE
RYAN DEP Y
SO ANSWERS,
RONIV R ANDERSON, SHERIFF
Carrie A. isquire
Robert N. i-U.Ab Jr, Esquire
Mark R. Garvey, Esquire
Gregory J. Babcock, Esquire
Attorney ID # 94055/201259/312686/205061
Portfolio Recovey Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff
v.
REGINA BROUGHTON
105 WALNUT ST
BOILING SPRINGS PA 17007
Defendant
No. 2014-3299
PRAECIPE TO SETTLE DISCONTINUE AND END
PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED,
DISCONTINUED AND ENDED.
15-84213
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Gregory J. Babcock, Esquire PA Bar # 205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
Carrie A. 1, n, Esquire
Robert N. Polas Jr, Esquire
Mark R. Garvey, Esquire
Gregory J. Babcock, Esquire
Attorney ID # 94055/201259/312686/205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC :
120 CORPORATE BLVD
NORFOLK, VA 23502
Plaintiff : No. 2014-3299
v.
REGINA BROUGHTON
105 WALNUT ST
BOILING SPRINGS PA 17007
Defendant
CERTIFICATE OF SERVICE
The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle
Discontinue and End upon REGINA BROUGHTON by First Class Mail, Postage Pre -Paid, a copy thereof
on th. day of
15-84213
2014, to:
REGINA BROUGHTON 105
AL
OILING SPRI;7007
*71'
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Gregory J. Babcock, Esquire PA Bar # 205061
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Anv information obtained will he need for this nitronce