Loading...
HomeMy WebLinkAbout14-3375s E C T I 0 N A S E C T I 0 N B Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet Cumberland County For Prothonotary Use Only: Docket No:F)(-1 ✓ e Sn S The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint 0 Writ of Summons O Transfer from Another Jurisdiction ❑ Declaration of Taking 0 Petition Lead Plaintiff's Name: PORTFOLIO RECOVERY ASSOCIATES LLC Lead Defendant's Name: DIANNA SHUTT Are money damages requested? ® Yes ❑ No Dollar Amount Requested: (Check one) ® within arbitration limits O outside arbitration limits Is this a Class Action Suit? ❑ Yes Name of Plaintiff/Appellant's Attorney: ❑ Check here if you hav Nature of the Case: Place an "X" to the left of t PRIMARY CASE. If , _____ __ you consider most important. ® No Is this an MDJ Appeal? Syretta J. Martin, Esq. 309370 Beth A. Howell, Esq. 203606 Frank lanello, Esq. 315643 Gregory Dye, Esq. 205316 TORT(do not include Mass Tort) ❑ Intentional O Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance O Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/Defamation ❑ Other: MASS TORT O Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABILITY O Dental ❑ Legal O Medical ❑ Other Professional: 2860869 CONTRACT/do not include Judgments) O Buyer Plaintiff ,E- Debt Collection: Credit Card O Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other O Other: REAL PROPERTY ❑ Ejectment O Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute O Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial ❑ Partion ❑ Quiet Title ❑ Other: PP1TXP1R014/12141/20I11141) 11111111111111111111111111111111111111111111 ❑ Yes ® No I Howell tigant) s your ,k the one that CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: Updated 111120 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 VS. DIANNA SHUTT 1 ALTOONA AVE ENOLA PA 17025 Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION 1'1. 33'7 S C No. .d; NOTICE TO DEFEND Fri (T You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 1 701 3 800-990-9108 2860869 PPTNPRAI (04/24/2014) 11111111111111111111111111DIN 11111111]11111111111111111111MIME 1111 OifiA4 6 1OS, emkoc,N9P6-11j AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de Ia fecha de la demanda y Ia notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar Ia demanda en contra suva sin previo aviso o notificacion. Ademas, Ia corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 .11....1 ........ a..... I. U............1. 1.1111..... 'tons mem mire tem ... Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 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 v. DIANNA SHUTT 1 ALTOONA AVE ENOLA PA 17025 Plaintiff, No. 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(s), DIANNA SHUTT AND/OR , is/are an adult individual with last known address of 1 ALTOONA AVE ENOLA PA 17025 AND/OR . 3. It is averred that Defendant(s) opened an account on 12-17-10 with account number XXXXXXXXXXXX1827 (hereafter referred to as "Account"). A copy of the charge-off statement is attached hereto and collectively marked as Exhibit "A". 4. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 2860869 PPTCPRAI (04/24/2014) 111111111111111111 I O N 11 111 11 11111 1 1111 11111 1111 11 11 5. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 6. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 7. Defendant(s) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 09-10-2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest of GE CAPITAL RETAIL BANK AMAZON and Plaintiff is now the holder of the Account. A true and correct copy of Plaintiff's Verification is attached hereto. 9. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $1400.97. 10. Despite reasonable and repeated demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) DIANNA SHUTT AND/OR , in the amount of $ 1400.97, plus costs of this action and any other relief as the Court deems just and reasonable. Dated: BHLM REF #: 2860869 Respectfully Sub ' ted, Syre ,-' artin,• PA Bar #309370 Frank Janello, E • PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 Attorneys For Plaintiff VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Meryl Dreano 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: MAY 0 9 2014 BHLM REF #: 2860869 Meryl Dreano Custodian of Records Exhibit m 2860869 PPTXEXAI (04/17j2014) amazon.com Your Amazon.com Store Card offers these exclusive cardmember benefits; i• Special financing offers (visit ww.w.amazon.com/finan.ing for more information): • No;annual fee:: •:24-hour toll-free customer service ....... .... .... .... •:Online account management: at WWw.gernoney.corn/amazon D' ('d You can take advantage of special financing offers �*' .7 . : throughout the year 'With your Store Card." Know?: You can use: the Store: Card for your everyday Amazon.com purchases..: : . DIANNA L SHUTT Account Numberlf Summary of Account Activity Previous Balance - Other Credits $1,400.97 $1,400.97 New Balance Credit Limit Available Credit Statement Closing Date Days in Billing Cycle 50.00 $900.00 $0.00 11/11/2012 30 Subject to::your available:credit. Visit us at www.amazon.com/storecard 1827 Customer Service: 1-866-771-1104 Payment Information New Balance Amount Past Due Total Minimum Payment Due Payment Due Date 50.00 50.00 $394.00 11/12/2012 Late Payment Warning:If we do not receive your minimum payment by the date listed above, you may have to pay a late fee up to $35.00. Transaction Summary Tran Date Post Date Reference Number Description of Transaction or Credit Amount OTHER CHARGES 11/11 11/11 F934200NC00999990 CHARGE OFF ACCOUNT -PRINCIPALS ($756.23) 11/11 11/11 F934200NC00999990 CHARGE OFF ACCOUNT 'FINANCE CHARGES' ($644.74) TOTAL OTHER CHARGES ($1,400.97) FEES TOTAL FEES FOR THIS PERIOD 50.00 INTEREST CHARGED 11/11 11/11 INTEREST CHARGE ON PURCHASES 60.00 TOTAL INTEREST FOR THIS PERIOD 50.00 2012 Totals Year -to -Date Total Fees Charged in 2012 $339.07 Total Interest Charged in 2012 5254.22 Total Interest Paid in 2012 $14.54 PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE. NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information. 5484 X2G 1 3 10 121111 1 X PAGE 1 of 3 9342 1000 AP54 011.05484 Detach and mail this portion with your check. Do not include any correspondence with your check. —I amazon.com• DIANNA L SHUTT 1 ALTOONA AVE ENOLA PA 17025-2504 Account Number1827 Total Minimum Payment Due Amount Past Due Payment Due Date Overlimit New Balance Amount $394.00 $0.00 11/12/2012 50.00 50.00 Payment Enclosed: Please use blue or black ink. Save a stamp, pay on-line at www.amazon.com/storecard $1-1711 71. New address or email? Print Changes on back. Make Payment to: GECRB/AMAZON PO BOX 960013 ORLANDO, FL 32896-0013 n amazon.com Sign up today for a safe and easy, way to view your Amazon Credit Card statement. Online statements provide all the same information— without paper. Enjoy the convenience: • View your statement from wherever you are, any time of day • No more paper bills to organize or shred • Make your payment electronically to save time and money Go to gemoney.com/amazon for more information. Interest Charge Calculation Your Annual Percentage Rate (APRis the annual interest rate on your account. Type of Balance Regular Purchase (v) = Variable Rate Expiration Date NA Annual Balance Subject Percentage Rate to Interest Rate 25.99% (v) $0.00 Interest Charge $0.00 Cardholder News and Information We understand the impact of natural disasters can be difficult and we hope you and your loved ones are safe. If you need special assistance with your account, our representatives are available to assist you by calling the number on this statement. 5484 X2G 1 3 10 121111 Z X PAGE 2 of 3 9342 1000 APS4 011.15404 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 VS. DIANNA SHUTT 1 ALTOONA AVE ENOLA PA 17025 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. (1/13?'? a:" PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above -captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 Dated: a>/ 2860869 PPTXPPRI (04/16/2014) 111111111111111111111111111111111111111111111111111111111111111111111111111 BLATT, HASEN jl LER, LEIBSKER & MOORE, JCC One of Ittt rneys Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF CH"„ $t?EF<IFF THE tR THO 20 Ei 'UN 13 Fri 2: 0 I CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Dianna L Shutt Case Number 2014-3375 SHERIFF'S RETURN OF SERVICE 06/09/2014 03:56 PM - Deputy Amanda Ebersole, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Gary Shutt, Husband, who accepted as "Adult Person in Charge" for Dianna L Shutt at 1 Altoona Avenue, East Pennsboro, Enola, PA 17025. SHERIFF COST: $44.95 June 10, 2014 (c) C,ountySuite Sheriff, Teleosoft, Inc. in AMANDA EBERSOLE, DEPUTY SO ANSWERS, RONR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff Vs Dianna L Shutt 1 Altoona Avenue Enola, PA 17025 Defendant, Case No. (14-3375 Civil) NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set forth in New Matter, you must take action within twenty (20) days after this Answer and New Matter are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the Court without further notice for any money claims in the Defendant's Answer and New Matter or relief requested by the Defendant. You may lose money or property or other rights import 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 LEGAL HELP: Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 Dianna L Shutt 1 Altoona Ave Enola, PA 17025 TELE: (717) 732 2604 CeII Phone (717) 329-5512 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff Vs Dianna L Shutt 1 Altoona Avenue Enola, PA 17025 Defendant, Case No. (14-3375 Civil) ANSWER AND NEW MATTER And now, comes the Defendant, Dianna L Shutt, pro se, who answers Plaintiff's Complaint as follows: 1. Paragraph 1 is admitted. 2. Paragraph 2 is admitted 3. Paragraph 3 is admitted 4. Paragraph 4 is admitted 5. Paragraph 5 is admitted 6. Paragraph 6 is admitted 7. Paragraph 7 is admitted in part and denied in part. After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of paragraph 7, which is therefore denied. 8. Paragraph 8 is admitted in part and denied in part. After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of paragraph 8, which is therefore denied. 9. Paragraph 9 is admitted in part and denied in part. After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of paragraph 9, which is therefore denied. 10. Paragraph 10 is admitted in part and denied in part. After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of paragraph 8, which is therefore denied. NEW MATTER 11. Defendant repeated attempted to contact GE Capital Retail Bank Amazon to discuss the inability to pay due to Medical Conditions, including going on Medical Leave of Absence with a 70% reduction in salary the end of December 2012, as well as other medical conditions and financial hardships that began December 2011, that caused a hardship to the Plaintiff's financial inability to keep up with the payments. 12. Despite repeated attempts to contact the Plaintiff using the contact number on the statements of the PORTFOLIO RECOVERY ASSOCIATES, LLC, Defendant was unable to get through to the Plaintiff's office to talk to a representative in order to set up payments as the short term. WHEREFORE, the defendant requests that judgement be entered against the plaintiff. Respectfully submitted, Defendant Dianna L Shutt 1 Altoona Ave Enola, PA 17025 TELE: (717) 732 2604 Cell Phone (717) 329-5512 I verify that the statements made in this Answer and New Matter are true and correct. I understand that fats statements herein are made subject to the penalties of 18 Pa.C.S 54904, relating to unsworn falsification to authorities. Date: 6r)11 i/YukoOd(:t,-)51 c pi n lac, LS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff VS Dianna L Shutt 1 Altoona Avenue Enola, PA 17025 Defendant, Case No. (14-3375 Civil) CERTIFICATE OF SERVICE I, Dianna L Shutt, hereby certify that I have mailed by U.S.mail, first class, postage prepaid on this day June 28, 2014, a true and correct copy of the Answer and New Matter with Notice to Plead to the person(s) at the address indicated and package was delivered on June 30, 2014 : Date: 7/7/2014 PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Dianna L Shutt 1 Altoona Ave Enola, PA 17025 TELE: (717) 732 2604 Cell Phone (717) 329-5512 U.S. Postal Service -70132250000043493050 Lost package? File a Lost or Damaged Package Claim Package Tracking Number: 70132250000043493050 Package Status: Your item was delivered at 2:20 pm on June 30, 2014 in PHILADELPHIA, PA 19103. Activity Out for Delivery, June 30, 2014, 10:03 am, PHILADELPHIA, PA 19104 Sorting Complete, June 30, 2014, 9:53 am, PHILADELPHIA, PA 19104 Depart USPS Sort Facility, June 30, 2014, 4:45 am, PHILADELPHIA, PA 19176 Arrival at Unit, June 30, 2014, 4:26 am, PHILADELPHIA, PA 19104 Processed through USPS Sort Facility, June 29, 2014, 9:15 pm, PHILADELPHIA, PA 19176 Depart USPS Sort Facility, June 29, 2014, 1:15 am, HARRISBURG, PA 17107 Processed through USPS Sort Facility, June 28, 2014, 5:48 pm, HARRISBURG, PA 17107 Depart Post Office, June 28, 2014, 3:50 pm, HARRISBURG, PA 17107 Acceptance, June 28, 2014, 10:31 am, HARRISBURG, PA 17107 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC do Blatt, Hasenmiller, Leibsker & Moore, LLC vs. DIANA SHUTT Plaintiff, Defendant(s). Attorneys fnr Plain '� ��� U JUL PENNS YL ANl,tt IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION CASE NO. 14-3375 Civil PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER Plaintiff, Portfolio Recovery Associates LLC, through its attorneys, Blatt, Hasenmiller, Leibsker and Moore, LLC, does hereby answer the New Matter brought forth by the Defendant and states as follows: 1. Denied. Plaintiff has no record of Defendant attempting to set up arrangements. However, Defendant can call 215-564-1567 to ask to speak with someone to establish payment arrangements. 2. Denied. Plaintiff has no record of Defendant attempting to set up arrangements. However, Defendant can call 215-564-1567 to ask to speak with someone to establish payment arrangements. WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, requests that this Honorable Court deny and dismiss Defendant's New Matter with prejudice. • Respectfully submitt Syretta artin, Attorney No. 309370 VERIFICATION I, Syretta J. Martin, am the attorney in the enclosed matter, and I have prepared the Plaintiff's Reply to Defendant's New Matter after reviewing the file, speaking with my client, and my personal information and belief. I affirm that the facts asserted are true and correct to the best of my knowledge and belief. DATE: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19135 800-850-1079 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC do Blatt, Hasenmiller, Leibsker & Moore, LLC vs. DIANA SHUTT Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION CASE NO. 14-3375 Civil CERTIFICATE OF SERVICE I, Syretta J. Martin, as attorney filing the attached pleading, hereby certify that I mailed an exact copy of the attached to the party(ies) below at the address indicated by U.S. Mail first class postage prepaid, unless otherwise stated below. Diana Shutt, Pro Se 1 Altoona Avenue Enola, PA 17025 Syretta J. Marti Date