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HomeMy WebLinkAbout14-3302 Supreme Cou#Af Pennsylvania i Cou 'of CO M n Pleas._ Cl -� ve> S et 3 CUMB ounty The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required bylaw or rules o court. 4 Commencement of Action: ® Complaint ❑ Writ of Summons ❑Petition ❑ Trans fer from Another Juris diction ❑Declaration of Taking =. Lead Plaintiffs Name: Lead DeEndant's Name: a PORTFOLIO RECOVERY ASSOCIATES, LLC KATHY G GOODRICH 3';. 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) 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 E] Board of Elections ❑ Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ' ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: ❑ Slander /Libel/Defamation Discrimination E] Zoning Board ❑ Other: ❑ Employment Dispute: Other ❑ Other: ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑Toxic Tort - Implant ❑ Ejectment E] Common Law /Statutory Arbitration ❑Toxic Waste El Faninent Domain /Condemnation El Declaratory Judgment E] Ground ❑Other: ound Rent E] Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ,k ❑ Partition ❑ Replevin = PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 15 -93144 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 `� 4y PH 1: ` '- TELE: 1- 866 - 428 -8102 aU M B E R L A i D i. () L N 3 ,'( FAX: (757) 518 -0860 P E N N SJ Y LVA N 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. /q G,�-N Olut-L / •' Q to Plaintiff, V. KATHY G GOODRICH 1105 DRY POWDER CIR MECHANICSBURG PA 17050 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 S, Cumberland County Bar Association 32 South Bedford Street g /03 '?' CL Carlisle, PA 17013 15 -93144 � (717) 249 -3166 A182 � fz* (54"7 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. KATHY G GOODRICH 1105 DRY POWDER CIR MECHANICSBURG PA 17050 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 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 -93144 Es a cOMUnicaclon es de un cobrador de deudas y es un intent do cobrar rum deuda. Cualpier i ifroynacion sera utilkida 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: (151) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUNIB" COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC ; 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, : No. V. KATHY G GOODRICH 1105 DRY POWDER CIR MECHANICSBURG PA 11050 Defendant. 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 February 15, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest U.S. BANK NATIONAL ASSOCIATION 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 $1,057.27. 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, KATHY GOODRICH, in the amount of $1,057.27, plus costs of this action and any other relief as the Court deems just and reas abl . Carrie A Brown, Esquire, # 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R Garvey, Esquire, # 312686 Attorneys for Plaintiff 15 -93144 HIS coinra11.u1ic=ation is 6-oan a debt collector and is an attempt to collect a debt. Any infonnition obtained will be dised for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Leonard Wolfe 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 Plaintiff 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 21114 By: A A- 4 --c— Leonard Wolfe Custodian of Records 15 -93144 This coirnmnication 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. • EXHIBIT B BILL OF SALE AND ASSIGNMENT OF ASSETS The undersigned Assignor ( " Assignor ") hereby absolutely sells, transfers, assigns, sets -over, quitclaims and conveys to Portfolio Recovery Associates, LLC, a limited liability company organized under the laws of Delaware ( " Assignee ") on an "AS IS" and "WITH ALL FAULTS" basis, without recourse and without representations or warranties of any type, kind, character or nature, express or implied, all of Assignor's right, title and interest in and to each of the assets identified in the Asset Schedule ( "Asset Schedule ") attached hereto as Exhibit A (the " Assets "), together with the right to collect all principal, interest or other proceeds of any kind with respect to the Assets remaining due and owing as of the date hereof (including but not limited to proceeds derived from the conversion, voluntary or involuntary, of any of the Assets into cash or other liquidated property, including, without limitation, insurance proceeds and condemnation awards), from and after the date of this Bill of Sale and Assignment of Assets. DATED: October 25, 2013 ASSIGNOR: U.S. BaANational Association By: ✓ Name (p n ' G. Rebmann Title: S4 V e President By: N e (print): 54 : W haLn ie bvJ fv Title: 6�6LY14- USB FRESH APPROVED 10/10/2013 R1 ltm Bai k..A. LISTENING IS JUST THE BEGINNING. — September 2013 Statement Pa e 1 of 3 0 1 k 1 Open Date: 08/21/2013 Closing Date: 09/17/2013 Account: 7644 Select Rewards Visa® Platinum Card Cardmember Service C 1- 866 - 794 -2137 KATHY G GOODRICH ELN 8 11 New Balance $1,057:27 Activity Summary Minimum Payment Due $524.00 Previous Balance + $1 ,046.40 Payment Due Date 10115/2013 Payments $0.00 Other Credits $0.00 Late Payment Warning: If we do not receive your Purchases $0.00 minimum payment by the date listed above, you may have Balance Transfers $0.00 to pay up to a $35.00 Late Fee. Advances $0.00 Minimum Payment Warning: If you make only the Other Debits $0.00 minimum payment each period, you will pay more in Fees Charged $0.00 interest and it will take you longer to pay off your balance. Interest Charged + $10.87 For example: New Balance = $1,057.27 If you make no You will pay off And you will Past Due $483.00 additional charges the balance shown end up paying Minimum Payment Due $524 .00 using this card and on this statement an estimated Credit Line $1,000.00 each month you in about... total of... Available Credit None Only the minimum 19 months $1 Days in Billing Period 28 payment Reward Points If you would like information about credit counseling Earned This Statement 0 services, call 866 - 951 -1391. For details, see your rewards summary. Mail payment coupon Pay online at f Pay by phone Payment Options with a check www.fultonbank.com 1 -866- 794 -2137 Please detach and send coupon with check payable to: Cardmember Service M B 7 6 4 4 LISTENING IS JUST THE BEGINNING.— Account Number 7644 Payment Due Date 10/15/2013 24 -Hour Cardmember Service: 1- 866 -794 -2137 New Balance $1,057.27 . to p ay a b Yphone Minimum Payment Due $524.00 . to change your address Amount Enclosed $ 000011006 1 AT 0.384 000638075675470 P Cardmember Service KATHY G GOODRICH P.O. Box 790408 1105 DRY POWDER CIR St. Lours, MO 63179 -0408 MECHANICSBURG PA 17050 -1976 II11�11�1�1��1���I1111'I' 1111' II���II�II�III�III�II�I�I� 'lllll�ll I�II��III' III' �1��' II' I�"' ��I' �I�II 'll�l���'lll�llll��l������1�' What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement, please call us at the telephone number on the front of this statement, or write to us at: Cardmember Service, P.O. Box 6335, Fargo, ND 58125 -6335. In your letter or call, give us the following information: ► Account information: Your name and account number. ► Dollar amount: The dollar amount of the suspected error. ► Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement. 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. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: 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 $50. (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 or services.) 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 your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at: Cardmember Service, P.O. Box 6335, Fargo, ND 58125 -6335. While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Important Information Regarding Your Account 1. INTEREST CHARGE: Method of Computing Balance Subject to Interest Rate: We calculate the periodic rate or interest portion of the INTEREST CHARGE by multiplying the applicable Daily Periodic Rate ( "DPR") by the Average Daily Balance ( "ADB ") (including new transactions) of the Purchase, Advance and Balance Transfer categories subject to interest, and then adding together the resulting interest from each category. We determine the ADB separately for the Purchases, Advances and Balance Transfer categories. To get the ADB in each category, we add together the daily balances in those categories for the billing cycle and divide the result by the number of days in the billing cycle. We determine the daily balances each day by taking the beginning balance of those Account categories (including any billed but unpaid interest, fees, credit insurance and other charges), adding any new interest, fees, and charges, and subtracting any payments or credits applied against your Account balances that day. We add a Purchase, Advance or Balance Transfer to the appropriate balances for those categories on the later of the transaction date or the first day of the statement period. Billed but unpaid interest on Purchases, Advances and Balance Transfers is added to the appropriate balances for those categories each month on the statement date. Billed but unpaid Advance Transaction Fees are added to the Advance balance of your Account on the date they are charged to your Account. Any billed but unpaid fees on Purchases, credit insurance charges, and other charges are added to the Purchase balance of the Account on the date they are charged to the Account. Billed but unpaid fees on Balance Transfers are added to the Balance Transfer balance of the Account on the date they are charged to the Account. In other words, billed and unpaid interest, fees, and charges will be included in the ADB of your Account that accrues interest and will reduce the amount of credit available to you. Credit insurance charges are not included in the ADB calculation for Purchases until the first day of the billing cycle following the date the credit insurance premium is charged to the Account. Prior statement balances subject to an interest -free period that have been paid on or before the payment due date in the current billing cycle are not included in the ADB calculation. 2. Payment Information: You must pay us in U.S. Dollars with checks or similar payment instruments drawn on a financial institution located in the United States. We will also accept payment in U.S. Dollars via the Internet or phone or previously established automatic payment transaction. We may, at our option, choose to accept a payment drawn on a foreign financial institution. However, you will be charged and agree to pay any collection fees required in connection with such a transaction. The date you mail a payment is different than the date we receive that payment. The payment date is the day we receive your check or money order at Cardmember Service, P.O. Box 790408, St. Louis, MO 63179 -0408 or the day we receive your electronic or phone payment. All payments by check or money order accompanied by a payment coupon and received at this payment address will be credited to your Account on the day of receipt if received by 5:00 p.m. CT on any banking day. Mailed payments that do not include the payment coupon and /or are mailed to a different address will be processed within 5 banking days of receipt and credited to your Account on the day of receipt. In addition, if you mail your payment without a payment coupon or to an incorrect address, it may result in a delayed credit to your Account, additional INTEREST CHARGES, fees, and possible suspension of your Account. Internet and telephone payment options are available, and crediting times vary (but generally must be made before 5:00 p.m. CT to 8 p.m. CT depending on what day and how the payment is made). If you are making an internet or telephone payment, please contact Cardmember Service for times specific to your Account and your payment option. Banking days are all calendar days except Saturday, Sunday and federal holidays. Payments due on a Saturday, Sunday or federal holiday and received on those days will be credited on the day of receipt. There is no prepayment penalty if you pay your balance at any time prior to your payment due date. 3. Credit Reporting: We may report information on your Account to Credit Bureaus. Late payments, missed payments or other defaults on your Account may be reflected in your credit report. Riltm Bank.... LISTENING IS JUST THE BEGINNING. - September 2013 Statement 08/21/2013 - 09/17/2013 Page 2 of 3 KATHY G GOODRICH Cardmember Service 1- 866 - 794 -2137 Visa Select Rewards This Year Rewards Earned Statement to Date Points Earned on Net Purchases 0 0 Total Earned 0 0 For rewards program inquiries and redemption information call 800 - 657 -8308 24 hours a day, 7 days a week or visit us at www.fultonbank.com to access your account. Important Messages ** THERE IS A BETTER WAY TO FIX THIS PROBLEM *'* Your account is scheduled to be charged -off as a bad debt and we will be forced to report it to the national credit bureaus, which can stay on your credit report for as long as 7 years. We really don't want that to happen. PLEASE CALL US IMMEDIATELY to discuss your options at 1- 866 - 951 -3862 or VISIT US ONLINE at WWW.MYACCOUNTACCESS.COM. Each time you or a third party on your behalf, pays your bill by personal check, you authorize us to convert that payment Into an electronic debit. If the check is processed electronically, the checking account will be debited for the amount on the check and the debit will appear on your account statement. If you have any questions, please contact us at the Inquiries phone number located on this statement. Transactions Interest Charged Post Date Transaction Description Amount 09/17 INTEREST CHARGE ON PURCHASES $10.87 TOTAL INTEREST THIS PERIOD $10.87 2013 Totals Year-46 ate Total Fees Charged in 2013 $200.00 Total Interest Charged in 2013 $89.12 lnt+arest Charge; Calculation:!. Your Annual Percentage Rate (APR) is the annual interest rate on your account. * * APR for current and future transactions. Balance Annual Expires Balance Subject to Interest Percentage with Interest Balance Type By Type Interest Rate Variable Charge Rate Statement Free Period PURCHASES $763.51 $756.41 YES $7.10 12.24% YES — BALANCE TRANSFER $0.00 $0.00 YES $0.00 16.99% NO "PURCHASES $293.76 $289.99 YES $3.77 16.99% YES — ADVANCES $0.00 $0.00 $0.00 20.99% NO Continued on Next Page Riltm B ank - LISTENING IS JUST THE BEGINNING. — September 2013 Statement 08/21/2013 - 09/17/2013 Page 3 of 3 KATHY G GOODRICH Cardmember Service t� 1- 866 - 794 -2137 interns# eharg$ Calcula #ion Your Annual Percentage Rate (APR) is the annual interest rate on your account. * * APR for current and future transactions. Balance Annual Expires Balance Subject to Interest Percentage with Interest Balance Type By Type Interest Rate Variable Charge Rate Statement Free Period Contact Us (I Phone ��/ Questions ✓ Mail payment coupon Online with a check Voice: 1- 866 - 794 -2137 Cardmember Service Cardmember Service www.fultonbank.com TDD: 1- 888 - 352 -6455 P.O. Box 6354 P.O. Box 790408 Fax: 1- 866 - 616 -1750 Fargo, ND 58125 -6354 St. Louis, MO 63179 -0408 End of Statement Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ©FF C€ QF TVE $ {ERIFF CUKBERLAN[1 CCLE,: Y PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Kathy G Goodrich Case Number 2014-3302 SHERIFF'S RETURN OF SERVICE 07/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kathy G Goodrich, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 1105 Dry Powder Circle, Hampden Township, Mechanicsburg, PA 17050. Address appears to be vacant and to this date the Mechanicsburg Postmaster has not been able to provide a good forwarding address and the Complaint and Notice has expired at this time. SHERIFF COST: $44.30 SO ANSWERS, July 02, 2014 (c) CountySuite Sheriff, Teleosoff. Inc. RONI4c1 R ANDERSON, SHERIFF .Carie,A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney 1D # 94055/201259/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff Pr` sTNOIVOri r.> 2°ly �Ph 2: CtV 20 ilk 5 CLll BERL4AID PEMsrLVA Uri; 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. KATHY G GOODRICH 1105 DRY POWDER CW MECHANICSBURG PA 17050 Defendant To the Prothonotary: No. 14-3302 PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinue. 'tthout prejudice. PI 15-93144 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Carie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID # 94055/201259/31.2686 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 v. KATHY G GOODRICH 1105 DRY POWDER OR MECHANICSBURG PA 17050 Defendant : No. 14-3302 CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon THY G GOODRICH, by First Class Mail, Postage Pre -Paid, a copy thereof on thisday of �� 2014 to: THY G GOODRICH, 1105 DRY POWD • C P , MECHANICG PA 17050 15-93144 obert 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 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.