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Home My WebLink About14-3356 x, Sd ireifie Cao ,.o, ,Pennsylvania 1 Cou f Com�'_on Pleas For Prothonotary Use Only: -"rlMESTA MP Ci; 4.Verhet Docket No: r' r} �� Com' �` ..�Coun ✓ rr,,,,ll CUMB - The information collected on this form is used solely for court administration purposes. This form 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 r-1 Petition ❑Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES, LLC LISA ANDERSON I 0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (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./Carrie Brown/Mark R Garvey ❑ Check here if you hale 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. 1f you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CON'T'RACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Credit Card n Board of Elections ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other •h-5�� ❑ Product Liability(does not include E mass tort) [3Employment Dispute: ❑ Slander/Ubel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T ❑ Other. 0 MASS TORT N ❑ Asbestos ❑ Tobacco REAL,PROPERTY MISCELLANEOLS ❑ Toxic Tort-DFS j ❑ Toxic Tort-Implant ; E] Ejectment F1 Common L awJStatutory Arbitration ❑ Toxic Waste C] Eminent Domain/Condemnation F-1Declaratory Judgment F1 Other E] Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition : ❑ Replevin PROFESSIONAL LIABILYIY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: j 15-93302 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. LISA ANDERSON 165 J AVE NEW CUMBERLND PA 17070 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 15-93302 Esta coi-nunicacio.n es de un cobrador de deudas y es un intent do cobras urea deuda. Cualquier infron-cion 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:(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 Plaintiff, No. V. LISA ANDERSON 165 J AVE NEW CUMBERLND PA 17070 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, LISA ANDERSON, is an adult individual with last known address of 165 J AVE, NEW CUMBERLND PA 17070. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/JC PENNEY on April 10, 2011 with account number ************3248 (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 conrn»LnD.ication is from a debt collector and is an attempt to collect a debt. Any infornnation 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 April 14, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ JC PENNEY 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$2,777.40. 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, LISA ANDERSON, in the o t of$2,777.40, s c sts 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 15-93302 Ibis coznnn i.ication is fi-orn a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cdstina Patterer 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 unsworn falsification to authorities. MAY 01 2014 _ Date: By: Cds ina Patters°" Custodian of Records 15-93302 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. ... "..:: GF apitpl BILL of SALE PRA PLCO Fresh--November:2013 For value received and in further consideration of the mutual covenants and:conditions set.farth in the Forward Flow Reeeivables Purchase Agreement(the"Agreement"),dated as of this 9th day:ofJuly,:2013 by and between General.Electric Ca ital.Co oration .GE Ca ital Retail P� rP. � p Bank,GEMB Lending,inc.;Mono Credit . Services;L.L.C.,.RFS Holding;L.L.C,;.and GEM Holding L:L.C.(collectively''Sellee')and Portfolio Recovery Associates;LLC(`BuyO�l,Sellerhereby 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 20,2013,and.as further described in the Agreement. GE Capital Retail.Bank : .. Monogram Credit Services,L L:C. " . . . L By: t Ken Wojcik 3 " Attorney in Fa . Ken Wojcik ... . Title: $V.P Collections&Recoverry Date: Date [ : RFS Holding, I,.L:C: .. , [ General Electric Capital Corporation . . . By Attorney in Fact en Wojcik Attorney in:Facts en Wojcik Date: (. , •. f - t.�j:' Date': .�'p�:•. [ GEM Holding,L.L.C. GEM B:Lending; Inc. By: Attorney in Fac en Wojcik . By: ;. . . ... Attorney in Fact Met Wojcik Date: �d (;Z 13 Date. ('71 Portfolio Recovery Associates,LLC. . .. . ... Title..'' ic— YOURCHANGE MAKESREAL The CHANGE Breast Cancer When people dare,great things happen.Each month, Icp cares supports a new cause,inviting customers to round up their purchases to the nearest dollar. Research This month's nonprofit partner is The Breast Cancer Foundation. Research Foundation g,which provides critical funding for innovative clinical and translational research worldwide. JCPenney thanks you for making a difference. For more information,visit jep.cortt/jcpeares. cares 211111111 LISA RANDERSON Visit usat jcp.com/credit Accotnt Ending ******32481 Customer Service: 1-800-527-3369 PO Box 965009 Orlando FL 3289(x5009 Previous Balance $2,777.40 New Balance $0.00 -Other Credits $2,777.40 Amount Past Due $0.00 New Balance $0.00 Total Minimum Payment Due $744.00 Payment Due Date 10'22/2013 Credit Limit $2,300.00 Late Payment Warning: If we do not receive your minimum Available Credit None payment by the date listed above,you may have to pay a late Statement(losing Date 10/20/2013 fee up to$35.00. Days in Billing Cycle 30 Tran Balance Date Reference Number Type Description of Transaction or Credit Amount 10/20 F9119009500999990 R CHARGE OFF ACCOUNT-PRINCIPALS ($2,243.35) 10/20 F9119009500999990 R CHARGE OFF ACCOUNT*FINANCE CHARGES* ($534.05) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 10/20 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FORT HIS PERIOD $0.00 Total Fees Charged in 2013 $175.00 Taal Interest Charged in 2013 $495.26 Total Interest Paid in 2013 $153.97 PLEASE NOTE YOUR MAILED PAYMENT MUST BE RECEIVED BY 5 P.M.(ET)OR YOUR IN-STORE PAYMENT MUST BE RECEIVED DURING STORE HOURS ON THE DUE DATE. NOTICE:Your payment may be converted into an electronic debit.See reverse for details,Billing Rights Information and other important information _{ PLEASE DETACH AND RETURN THIS ST UB WITH YOUR CHECK PAYABLE TO GECRB. Account Endin: **3248 744.00 $0.001a22n013 $0.00 FILL IN TOTAL PAID$ . ... . .. III'II IIII I I III it I IIOII�I I VIII III New address or email?Print changes on the back. LISA R ANDERSON 165 JAVE TADAFATATAFDDDDTDATDADDFTDDFAFDATAATTTDFTTTATDFDFTDDFFTFTADAFATFT NEW CUMBERLAND PA 17070-5021 GECRB/jcp P.O.Box 960090 TDFDATTFFTFDDFTTA TFTFATAFFTDTD DDATA DFTDTTDATFDAFTFT4ARUg*[ANQFdffi0 - 248 5433 H9R 1 3 19 131020 ZX PAGE 1 of 3 9119 3900 M183 OIFG5433 the jcpenney gold/platinum credit card program The jcpenney gold/platinum credit card program offers special benefits exclusively for jcpemey gold I platinum credit cardmembers, including a passbook with special offers and discounts,savings events,and tree shipping events. As of October 15,2013,jcpenney gold/platinum status is earned as follows:You must spend 5500 or more on merchandise or services with your - jcpenney credit card over 2 or more unique shopping days in a calendar year to earn or maintain jcpenney gold status, Spend$1,000 or more on merchandise or services with yourjcpenney credit card over 2 or more unique shopping days in a calendar year to earn or maintainjcpenny platinum statusjcpenney gold/platinum status is determined at the time of your monthly billing statement after meeting purchase threshold.We reserve the right to change or cancel the jcpenney gold/platinum program or any or all of its benefits at any time without notice. If your account is not in good standing andlor you no longer meet our criteria,you may be ineligible for the jcpenney gold/platinum program and/or unable to take advantage of jcpenney gold I platinum promotions. Thejcpenney gold/platinum benefits are available only while you are a resident of the 48 contiguous United Stales,Puerto Rico and Alaska. Credits To YOurA"ount-An amount shown in parenthesis or preceded by a minus(-)sign 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 requirements that may be due. Bankruptcy Notice:If you 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 103104,Roswell,GA 30076, Your Account is owned and serviced by GECapilal Retail Bank. Nearingimpaked TOD users call 1.800-444-1732. Customer Sen7ce/Questions:For account information,please call the loll free number on the front of this statement.Unless yyour name is listed on this statement,Vour access to information on the account may be limited.You may also mail questions(but not payments)to:P.O.Box 965009, Orlando,Fl. 96-5009.Please include Your account number on any correspondence you send to us. - Payments:Send payments to P 0.960090,Orlando,FL 32896 0090 or payy online. Notice.See below for your Billing Rights and other important information.Telephonin about billing errors will not preserve your rights under federal law.To preserve urn his, lease write to our BillingInquiries Address,P.O.Box 965008,Orlando,FL,32896-5008, 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 Iromyour check to make a one-time electronic fund transfer from your account or to process the payment as a check Uansaction. When we use mformauon from your check to make an electronic fund transfer,funds maybe withdrawn from your account as soon as[he same day we receive your payment,and you will not receive your check back From your financial institution. You may clroose nil[o have your paynnent collected eleclronrcally by sendingg your pa ent/wrtln the paynnent stub) in your own envelope—not Ince enclosed window envelo addressed lo:P.O.Box 530945 AUannla GA 30353-0945 and not Une Pa ent/Lddress. a o 0 ou m ou m rs a e ora a emen or remh ante coupon, a Is no recent in the remittance envelope If you think there is an error on your statement,write to us at the provided or(f)includes staples.paper clips,tape,a folded check,or - Billin0Inquiries Address of: correspondence of any type. Under ordina y circumstances, any GE Capital Relatl Bank,P.O.Box 965008,Orlando.FL 32896-5008 pa mems made al a jcpenney store will be credited as of the day you Or,complete and mail or fax the Dispute Form found ac ma"ke such a payment.Alternawely,you ma V make your payment www jcp.com/credit online at the websfte address shown on our billing statement,pprovided - - In your letter give us the following information: you make bur payment in U.S.dollars�rom a batik located in the U.S. • ccc intinlomnation Your name and account number. Condili�ona Parent-.All written commumcalans concerning disputed •Dotal amount.The dollar amount of the suspected error. amounts,including any check or other payment ins0ument that:(i) •Description of Problem:If you think there is an error on your bill, indicates that the ayment constitutes'paymenl in full"or is tendered as describe what you believe is wrong and why you believe it is a mistake. full satisfaction o�a disputed amount;or pi)Is tendered with other You must contact us within 60 days after he error appeared on your conditions or limnalions ("Disputed Payments"j, muss be mailed or statement. delivered to us at P.O.Box 965008,Orlando.FL x32896-5008 You must notify us of any potential errors in rvnting.You may call us Credit Reports acrd Account Information:If you believe that we have but if you do we are not requiredto Investigate any potential errors and repined inaccurate information about you to a consumer rporting you may have to pay the amount n question. agency9,please contact us at P.O.Box 965007,Orlando,FL.'32896 i While we investigate whether or not there has been an error,the 5007.In domy so.please idenfity the inaccurate Information and tell us following are true: wh yt}u believe it is inctrrted.If you have a,co�y of the credit report that We cannot try to collect the amount in question,or report you as incudes the inaccurate in(onna6on'please include a cap of That rep n. delinquent on that amount. We may report informati m about please account to cretliYbureaus,Late •The charge In question may remain on your statement,and we may paVmems,missed pa encs,or alien defaults on your account may be continue to charge you interest on that amount.But.If we determine that reflecled in your credlf report - we made a mistake,you will not have to pay the amount in question or Balance Subject-To Interest Charge Calculation any interest or other fees related to that amount. A.(Average Darty.Balance intruding current lrar liorus:We •While you do not have to pay the amount in question,you are figure the interest chary:on your,account by applying the per' he rate resppoonsible for the remainder of your balance, to the"average dailV balance'of your account. Io gel the average •We can apply anV unpaid amount against your credit limit daily balance we take the beginning balance of your account each day, Your Rights 7T You Are Dissatisrred With Your Credit Card which includes any un id inleres charges from the previous billing Purchases cycle,add any new charges,and applicable fees and subtract any If you are dissatisfied with the goods or services that you have payments or credits. This gives us the daily balance. Then,vie add up purchased with your credit card,and you have tried in qood faith to all the dally balances for She billing cycle and divide the total by the correct the prob em with the merchant.you may have the right not to number of da yys in the billing cepde. This gives us the"average dolly pap the remainingg amount due on the purchase, balance.'whic7h is the balance s7rown in the Interest Charges section of To use this right,all of the following must be true: this statement. Any average daily balance of less than zero will be IB The pu chase must have been made in your home state or within treated as zero. A separate average daily balance will be calculated for 100 miles of your current mailing address.and the purchase price must each balance type on rur account, have been more than 550.(Note:Neither of these are necessary if.Your B.The same as Method A,except unpaid Interest Charges are not purchase was based on an advertisement we mailed to you,or if we included in the beginning balance. own the company that sold you the goods or services.) C.The same as N eft A,except new Purchases are not included in 2.You must have used your c I card for the purchase.Purchases the daily balance. made with cash advances from an ATM or with a check that accesses D.The same as Method C,except unpaid Interest Charges are not your credit cad account do not quality, included in the beginnin balance. 3.You must not yet have fully paid for the purchase., E.(Dairy.Balance Me�or):We figure the interest charge on your If all of the criteria above are met and you are still dissatisfied with the account by applying the periodic rale to the"daily balance of your purchase,contact us in wn6nq(or electronically)at: account for each day to the billing cycle.We then add the interest to the GE Capilal Retail Bank,P.O.Box 965008,Orlando,FL.32896.5008 daily balance.To get the daily balance'we take the b�innin balance (www.jcp.coMcredil) of your account each day(which includes unpaid interesrj,ad gamy new White we investigate,the same rules apply to the disputed amount as charges,and applicable fees,and subtract any payymments or credits. discussed above.After we finish our investigation,we will tell you our This gives us the daily balance.A%daily balance ofless than zero wilt decision.At that point,if we think you owe an amount and you do not be treated as zero.a separate daily balance will be calculated for each pa wemayreporlyouasdeingLie nt. balance type on your account.The balancels)shown,in the Interest lnlonnation About Payments:You may atony time p.ay,in whole or Charges section of this statement is he sum of the dotty balances for in part rhe rota!unpaid balance without any additional charge for each day in he billing cycle divided by the number of days in the billing prepayment Mailed payments received atter 5:00 PM(ET)on any day c de. well be credited as of the next day. Credit to your Account may be Balance Type on the face of this statement refers to the following delayed up to.five days if paymenf(a)is not received at the Payment payment method: R=Regular Charge: M=Major Purchase Charge; Address,lib)is not made m U.S.dollars drawn on a U.S.financial C=Commercial. institution�cWed In the U.S..(c)is not accompanied by the remittance You can request to receive statements in Spanish byy calhnq Customer coupon attached to your statement(d)contains more than one payment Service number at 1-800542-0800. 01 FG3433-3-09/11/13 This is an attempt to collect a debt and any information obtained will he 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 for the call under your phone plan. . For changes of address,phone number andlor email,please check the box and print the changes below. Street Address City.St. Zip Phone# E-mail Home Phone# Business Phone# Cell#or other phone#we can use Email Address 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 tojcpenney so you can receive special offers and updates. Yom Annual Percentage Rate(APR) is the annual interest rate on your account. Annual Balance Expimtien Percentage Subject To Interest Balance Type of Balance Date Rate Interest Rate Charged Method RegLdw NA 26.99% $0.00 $0.00 E Statement not provided to customer. Good news-Gold and Platinum upgrade status levels are tack!As of October 15,2013,cardnembers who have spent 5500 on their JCPenney Credt Card thiscalendar year over 2 or more shoppingdays will be automatically upgraded to JCPenney Gold Card Status,and cardholders who have spent 51,000 on their JCPenney Credit Card this calendar year over 2 or more shopping days will be automatically upgraded to JCPenney Platinum Card Status.Certain conditions and limitations apply.See back of statement for additional information. Until further notification,reward certificates earned in the jep rewords program will only be delivered by email if you have registered your email address on jepnewwris.com.All other rewards certificates will be delivered via U.S mail. Good news!Now you can cam up to 5100 in jcp rewards each month when you use your JCPenney Credit Card to make qualifying purchases.See a JCPenney Associate member or visit jcprewardccauderedt for details. . { ME LJ F STYLE F £ g Jcpenrley gift CaYCd5 fitany iME £3CCc5iCJf1>Sty'Ca$ budget. in stores•jcpCom•1.800.322.1189 5433 H9H 1 3 19 131020 2XPAGE 2 of 3 9119 3900 M183 OlFG5433 5433 H9H 1 3 19 131020 Z XPAGE 3 of 3 9119 3900 M183 OIFG5433 Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mirk R. sCarvey, Esquire Attorney ID # 94055/201259/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff OF U& -( -11'104,41 CtitIBEi�Z0f44 PE. Cr!�} dire ... 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. LISA ANDERSON . 165JAVE NEW CUMBERLND PA 17070 Defendant To the Prothonotary: No. 14-3356 CIVIL PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinued without prejudice. R ully Submitte 15-93302 . 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. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mt&rk R.aGarvey, 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 PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff v. LISA ANDERSON 165 J AVE NEW CUMBERLND PA 17070 Defendant : No. 14-3356 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue day of upon LISA ANDERSON, by First Class Mail, Postage Pre -Paid, a copy thereof on this 15-93302 , 2014, to: LISA ANDERSON, 165 J AVE, N BERLND PA rt 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.