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Home My WebLink About14-3473 Svprerme Cort-;of Pennsylvania Court:' Common Pleas f � e*'. �i} r�, For Prothonotary Use Onl . T l M I STtkm P C* �CoverjSlf&t Do )tll cket No: CUMBR 'County Y 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 of court. SCommencement of Action: E [N Coirplaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T ! PORTFOLIO RECOVERY ASSOCIATES,LLC JANIS ROBBINS O +' Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits I A Is this a Class Action Suit? 11Yes ®No Is this anMDJAppeal? 11Yes ®No Name of PlaintiBfAppellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R.Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) I Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CML APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S ❑ Product Liability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Ltbel/Defarration Discrimination ❑ Zoning Board C ❑ Other: ❑ Enployment Dispute:Other ❑ Other: T I ❑ Other: 0 i MASS TORT N ❑ Asbestos i ❑ Tobacco F-1 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort-Inplant E] Ejectment E] Common Law/Statutory Arbitration F1 Toxic Waste E] Eminent Domain/Condetrmation ElDeclaratory Judgment ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: t 15-55940 i I kobert 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 Z": Norfolk, VA 235021 �f TELE: 1-866-428-8102 FAX:(757) 518-0860 PF 'l VD CoI f Attorneys for Plaintiff L VA N/A '� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 2 120 CORPORATE BLVD 1q, NORFOLK, VA 23502 No. Plaintiff,. V. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty (20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service -CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 15-55940 (717) 249-3166 a�l V- Y0-73 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 Carne 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. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 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 15-55940 Esta coniunicacion es de un cobrador de deudas y es un intent do cobrar una deuda. CL►al.quier infromacion sera util.i.zada 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 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. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 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, JANIS ROBBINS, is an adult individual with last known address of 20 WHITE OAK DR, CARLISLE PA 17015. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/TJX on August 12, 2011 with account number ************0425 (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 communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used tier 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 August 3, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ TJX and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiff s Bill of Sale is attached hereto and collectively marked as Exhibit "A." 9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of$2,273.92. 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, JANIS ROBBINS , in the amount of$2,273.92, plus costs of this action and any other relief as the Court deems just and reasonable. - Carrie A. Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15-55940 This communication is from 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, TiffanYOffM 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 8 2014 By: Tiffany C wffm i cords 15-55940 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. I XHIBIT A . II This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. KID D GE Capital PRA PLCC Fresh--March 2013 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"), dated as of this 13'h day of December, 2012 by and between General Electric Capital Corporation, GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, LL.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 March 26,2013, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. Glenn Marino Glenn Marino Title:EVP Title:President Date: 2J — / 3 Date: General Electric Capital Corporation RFS Holding,L.L.0 By- r' By: Glenn Marino Joseph Ressa Title: Vice P esident Title: CFO Date: Date: GEMB Lending,Inc. GEM Holding,L.L,C By: By: Stephen Motta Joseph Ressa Title: Director Title:CFO Date: Date: Flo 1 GE Capita! PRA PLCC Fresh—March 2013 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated as of this 13`h. day of December, 2012 by and between General Electric Capital Corporation, GE Capital Retail 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 ("Bayer"), 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 A-otification Files(as defined in the Agreement), delivered by Seller to Buyer on March 26, 2013,and as further 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: Date: General Electric Capital Corporation RFS Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Title: Vice President Title: CFO Date: Date: GEMB Lendin ,Inc. GEM Holding, L.L.C. By: 4�;j By: Stephen t a Joseph Ressa Title: Director Title: CFO Date: 2 Date: iiscR90 zor3 • • :.� X90 / l . GE Capita! PRA PLCC Fresh—March 2013 For value received and in further consideration of the mutual:covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated:. as of this 13cn day of December, 2012 by and between*.General Electric'. Capital. Corporation, GE Capital Retail 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, onveys;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 March 26, 2013, and as further 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: Date: General Electric Capital Corporation RF Wing;L.L.0 By: By Glenn Marino Joseph R s Title: Vice President Title: CFO Date: Date: t,1 �,L• GEMB Lending, Inc. GEM olding L:L.0 . By: By: Stephen Motta: Joseph R s. , Title: Director Title:CFO Date: Date: X90 � 3 TJ)REWARDS* Rewarding News! Your Rewards Certificates will be included in your monthly statement.So be sure to check your statement every month to see how many Rewards you've earned. ik.. The TJX Rewards' JANIS ROBBINS Visit mat www.tjxrewards.com Platinum MasterCard* Amount Number —0425 Customer Service: 1-877-822-2015 MIMM111ii+i+i+i+i+i+i+i+i RIM11.1 i+i+i+++i+i+i+i+i+i++ Previous Balance aia�a�a�a...aa$z273.92 New Balance '1 a�a.�a...aya�a�a�a..a a$07 -Other Credits $2,273.92 Amount Past Due $O.QO New Balance $0.00 Total Minimum Payment Due 5634.00 Payment Due Date 03/11/2013 Credit Limit $1.870.00 Late Payment Warning: If we do not receive your minimum Available Credit $0.00 payment by the date listed above,you may have to pay a late Cash Limit $380.00 fee up to$35.00. Available Cash $0.00 Statement Closing Date 03/10/2013 Days in Billing Cycle 30 - ifi►�FWWY1WirWW7Y�Y14Pit.+Miii+i+i+i yNy(*��#+#+#+#+#+#+#+#+#+### iiiiiiiiiiii•iiiiiiii Beginning TJX Rewards Points Balance 0 Turn every shopping trip into a rew clstrip with Points Earned-Our Stores 0 the TJX Rewards card Earn rewards on purchases Points Earned-Other Purchases 0 at T.J.Maxx,Marshalls,and HomeGoods. Points Redeemed-Certificate Issuance 0 Hurry in now. Current TJX Rewards Points Balance 0 Lifetime TJX Rewards Points Earned 3,179 Points Eamed Toward Next Certificate $10 250 pts 500 pts 750 pts IOOOpts ..a�a�a�aaa......�aaa�aaa...aaaaa.aa�a Tran Date Post Date Reference Number Description of Transaction or Credit Amount Other Transactions 03/10 03/10 F1410002500999990 CHARGE OFF ACCOUNT-PRINCIPALS ($1,81217) 03/10 03/10 F1410002500999990 CHARGE OFF ACCOUNT"FINANCE CHARGES* ($461.75) Continued on next a PAYMFNT IN IF BY 5 P M.(FT)ON THE DI 1F.DATF. NOTICE:We may convert your payment into an electronic debit.See reverse for details.Billing Rightsand other important information. 8640 GGH a 3 8 130310 Z%PAGE 1 of 3 1410 1000 T201 Ot CBS640 Detach and mail this portion with your check.Do not include any correspondence with your check. — Account Number: 0425 Ye!'.RIV11h1MttF tt�rAnbT�#t hrpMF# ++7Fel12nh # i+ TJZREWARDS'_ $634.00 1 $0.00 1 03/11/2013 1 $0.00 $0.00 Payment Enclosed .... . .. Please use blue or black ink. $ New address or email?Print changes on back. JANIS ROBBINS AAFDDTFFTADAATFAAFAFDADAFDAAAADTDADTATTFTDFAFAFDDFFrTFFDFFDTTATTD 20 WHITE OAK DR CARLISLE PA 17015-9169 Make Payment to: TJX REWARDS/(ECRB PO BOX 530949 FADDDFTFFFFAFATDAFAFTFFDTDADFFFPTFFDFATFAAAFTFATTFFAAFFDFAFDbAAPK - 0949 0 425 Customer Service/Questions:For account information,please ca II the loll 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 328963013.Please include yburaccounl number on any correspondence you send to us. Payments:Send payments to the address listed on the remit portion of this statement or pay online, Noffoe:See below for your Billing Rights and other important information.Telephoning about billing errors will not preserve your rights under federal law Tbpreserveyour rights,please writetoour Billing Inquiries Address,P.O.Box 965016,Orlando,FL32896-5016. Purchases,returns.and payments made Just prior to billing dale 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 your account or to 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,addressed to:P.O.Box 960097,Orlando,FL 32896.0097 and notthe Payment Address. Mat To Do It You Think You Find A Mistake On Your Statement full satisfaction of a disputed amount;or(it)is tendered with other If you think there is an error on your statement,write to us at the conditions or limitations('Disputed Payments"),must be mailed or Billing Inquiries Addressof: delivered to us at P.O.Box 965016,Orlando.FL 32896-5016. GE Capital Retail Bank Credits To Your Account.,An amount shown in parenthesis or P.O.Box 965016,Orlando,FL 32896-5016 preceded by a minus(-)sign is a credit or credit balance unless In your letter,give us the following information: otherwise indicated.Credits will be applied to your previous balance •Account information:Your name and account number immediately upon receipt.but will not salisly any required payment that •Do!laramount The dollar amount of the suspected error may bedue. •Description of Problem:If you thinkthere is an error on your bill. CredltReportsAndAccoantInformation:Ifyou believe thatwehave describewhatyou believe iswrong and why you believe It is a mistake. reported inaccurate information about you to a consumer-reporting You must contact us within 60 days after the error appeared on your agency,please contact us at PO.Box 965015,Orlando,FL32896- statement 5015.In doing so,please identify the inaccurate information and tell us You must notify us of any potential errors in wnting.You may call us. why you believed is incorrect.If you have a copy of the credit report that but if you do we are not required to investigate any potential evorsand includes[he inaccurate Information,please includeacopy ofthat report. you may havelopay theamount in question We may report information about your account to credit bureaus,Late While we investigate whether or not there has been an error,the payments,missed payments,or other defaults on your account may be following are true: re0ected in yourcredit report. •We cannot try to collect the amount In question,or report you as Balance Subject To Interest Charge Calculation delinquent on that amount. Daily Balance Method:We figure the interest charge on your amount •The charge in question may remain on your statement,and we by applying the periodic rate to the"dairy balance"of youraccount for mayconlinueto charge you interested thatamount.But,if we determine each day in the billing cycle.We then add the interest to the daily thatwemadeamistake,youwillnot have topay the amount inquestion balance.Togetthe"daily balance"we take the beginning balance of or any interest brother fees related lbthalamount. your account each day(which includes unpaid interest),add any new •While you do not have to pay the amount in question,you are charges,and applicable fees,and subtract any payments or credits, responsible for the remainder of your balance. This gives us the daily balance.Any daily balance of less than zero will •We can apply any unpaid mount against your creditlimit. be treated as zero.A separate daily balance will be calculated for each Your Rights If You Are Dissatisfied With Your Credit Card balance type on your account.The balance(s)shown in the Interest _ Purchases Charges section of this statement is the sum of the daily balances for If you are dissatisfied with the goods or services that you have each day in the billing cycle divided by the number of days in the billing purchased with your credit card,and you have tried in good faith to cycle. correct the problem with the merchant,you may have the right not to Bankruptcy Notice:If you file bankruptcy you must send us notice, pay the remaining amount due on the purchase. including account num bar and all information related to the proceeding To use this right,all of the following must be true: to the following address:GE Capital Retail Bank,Attn:Bankruptcy 1.The purchase must have been made in your home state or within Dept„P.O.Box 103104,Roswell,GA 30076, 100 miles of your current mailing address,and the purchase price must Your account Is owned and serviced by GE Capital RetallBank have been more than 550.(Note:Neither of these are necessary if your Nearing Impaired:TDD users call 1-800-444-1732. 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 mus(have used your credit card for the purchase.Purchases made with cash advances from an ATM or with a check that accesses yourcredit card account do not qualify 3.You must not yet have fully paid for the purchase. If all of the criteria above are mel and you are still dissatisfied with the purchase,contact us in wnling at: GE Capital Retail Bank P,O.Box 965016,Orlando,FL 32896-5016 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. Information About Payments:You may at any time pay,In whole or in part,the total unpaid balance without any 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 fivedays if payment(a)is not received at the 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 statemerri contains more than one paymenlorremittance 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:Ail 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 O1CB86W-1-07/12/1011 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 orcell 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 and/or email,please check the box and prim the changes below Street Address City,State, F-1Zip Phone# E-mail Home Phone It 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. TPREWARDS' � ti rsorbe" T"asteis,sr.bt>«;,s�nr�g-Ike;�:oiors,whate•;a?r yrxt.azant i:v nail the,r,they're IN and in a bic quay`:Add a I'rttla designer co!rr to ya r wardmFv> at htlrae,avat:Y l•�hell.<rt l".,1.'s, IA araha!Is and rlarneGwas and their pretty little pries. x 'i N/".�� h'�� h I f. _�•e^.P�rxst�^.0 or•tom l�t.5•r; m'.•.^•;1s.[nno'C.LI '.I.Y-., J^ .'Yy, ercjj��'. � @r N 3^' ,t 8 r,�7<i�r�^oS N:,^:hafa at I R:,ii e) 4 /1�mc(:.:,.;s.:%1•iiia(.4-n:F:^. �`�� - "----- %10PTHEM ALL Tran Date Post Date- Reference Number Description of Transaction or Credit Amount FEES TOTAL FEES FOR THIS PERIOD $0,00 INTEREST CHARC ED 03/10 03/10 INTEREST CHARGE ON PURCHASES $0.00 03/10 03/10 INTEREST CHARC;E ON CASH ADVANCES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 +ttt+ttt+i2Di1�f('btflt'4!r#c!•liak#ttttt+tttt Taal Fees Charged in 2013 $0.00 Taal Interest Charged in 2013 $97.04 HedMF�i1+'#tttttt+t ttt+t#tt+•F+#+#t+ttt+tt+tt#tf++tttt+'+t t t#++t+ Your Annual Percentage Rate(APR) is the annual interest rate on your account. Expiration Annual Percentage Balance Subject to Type of Balance Date Rate Interest Rate Interest Charge Purchases N/A 26.99%(v) $0.00 $0.00 Cash Advances N/A 29.99%(v) $0.00 $0.00 (v)=Variable Rate Ile+McF7eEdilN+teNilrt+ttttt#t+t#t#ttttt#t+t#t+ttttt+t+t#t#t+ttttt#t+tt - Please Note:Enclosed is the Privacy Policy for this account.Please take a moment to readit,then keep it with other financial documents.If you have previously opted-out,you do not need to do so again. 8640 GGH 1 3 8 130310 ZXPAGE 2 of 3 1410 1000 T201 OICB8640 1 r i I i I l a i i 8640. GGH 1 3 3 130310 ZXPAGE 3 of 3 1410 1000 T201 OICB8640 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 01 4 Jody S Smith itiki 20 /: - Chief Deputy Richard W Stewart Solicitor CE IJI1PBEEALSIY AL;Mjitif Portfolio Recorvery Associates, LLC Case Number vs. Janis Robbins 2014-3473 SHERIFF'S RETURN OF SERVICE 06/11/2014 04:16 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 William Robbins, husband, who accepted as"Adult Person in Charge"for Janis Robbins at 20 White Oak Drive, Dickinson Township, Carlisle, PA 17015. fl'lxi' 1 $ I, 4 AMANDA EBERSOLE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, June 12, 2014 RON— R ANDERSON, SHERIFF ir r13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORIFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff V. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Date: No. 14-3473 PRAECIPE FOR DEFAULT Defendant JUDGMENT 15-55940 Filed on Coun alf o of Rec laintiff for this P Robert N. Polas, Jr., Esq e, # 201259 Carrie A Brown, Esquire, # 94055 Mark R. Garvey, Esquire, # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff cowA szllh ?( &if clocioV )Z41 SOV)6 Ncrk)ce This communication is from a debt collector is an attempt to collect a debt. Any inlbrmation obtained will be used fbr that purpose. 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. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Defendant No. 14-3473 PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, JANIS ROBBINS, for failure to answer the Complaint. (X) Amount Due $2,273.92 Less Credits $.00 TOTAL $2,273.92 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PAR.C.P.237 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her attorney of record. (X) Pursuant to PA.R.C.P.231.1, I certify that a w men otice of inter 'en to file this praecipe was mailed or delivered to the par aga' t who . ' dgment . to be entered and to his/her attorney of record, if any, . "er th defa o carred . at least ten days prior to the date of the filing of this praa co ttached. 15-55940 Robert N. Polas, ., Esquire, # 201259 Carrie A Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff communication is from a debt collector is an attempt to collect a debt. Any ini:ormation obtained will be used :fib that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. JAMS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Plaintiff : No. 14-3473 Defendant NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above -captioned matter has been entered against you in the amount of $2,273.92. (X) A copy of all documents filed with the Prothonotary in support or attached. If you have any questions regarding this Notic 15-55940 i Ro. ert N. Polas, Jr., Es uire, # 201259 Carrie A. Brown, Esquire, # 94055 Mark R Garvey, Esquire, # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) 1-866-428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used :for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC Litigation Department 120 Corporate Blvd Norfolk, VA 23502 Telephone: 1-866-428-8102 Fax: (757) 518-0860 Hours of Operation: Monday through Thursday 8 AM to 11 PM, Friday 8 AM to 9 PM, Saturday 8 AM to 5 PM, Sunday 12 PM to 11 PM (EST) July 3, 2014 JANIS ROBBINS 20 WHILE OAK DR CARLISLE PA 17015 RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. JANIS ROBBINS 14-3473 Dear JANIS ROBBINS: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. 15-55940 Sincerely, Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Mark R. Garvey, Esquire Attorney ID #201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION — LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 v. JAMS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Plaintiff No. 14-3473 Defendant TO: JAMS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 DATE OF NOTICE: July 3, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 HERE 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. 15-55940 Lawyer Referral Service - CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Robert N. Polas, Jr., Esquire Carrie A Brown, Esquire Mark R Garvey, Esquire Attorney ID #201259/94055/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 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. 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. JANIS ROBBINS 20 WHITE OAK DR CARLISLE PA 17015 Defendant No. 14-3473 AFFIRMATION OF NONMILITARY SERVICE The undersigned counsel, as attorney for Plaintiff, herein affirms under the penalties of perjury that I am the attorney for the Plaintiff in the above -captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 20 WHITE OAK DR CARLISLE PA 17015 and is not in the military service of the United States or its Allies, or . e within the Service Members Civil Relief Act and its Amendments. 15-55940 Robert N. Polas, Jr. Esquire, #201259 Carrie A Brown, Esquire, #94055 Mark R Garvey, Esquire, #312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 (T) (866) 428-8102 (F) (757) 518-0860 Attorneys for Plaintiff This communication is a debt collector and is an attempt to collect a debt. Any inibnuation. obtained will be used for that purpose. Department of Defense Manpower Data Center Results as of : Jul -18-2014 04:38:21 PM SCRA 3.0 Status Report Pliant to Servicemernbers Civil. Relief Act Last Name: ROBBINS First Name: JANIS Middle Name: Active Duty Status As Of: Jul -18-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No `Ir. NA This response reflects the individuals' active duty status based on the AotiveDutyStatus Date Left Active Duty Within 367 Dar s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ._.:. NA - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received earty:notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 8BG0T7CAHO8FE80