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Home My WebLink About14-3488 Supreme Couto -Pennsylvania Cour-tV Com on Pleas I For Prothonotary U e Onl : TIMESTAMP 64 dove ,949 et Docket No: vo MB CUA�VIN 1:1, YAt, un 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 ❑Petition C ❑Transfer fromAnotherJurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES,LLC JEREMY NESBIT,JENNIFER SOUDERS I O 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 haw 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) CIVIL 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/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-DES El EjectmentE]B Fl Toxic Tort-Implant Common Law/Statutory Arbitration ❑ Toxic Waste E3Erninent Domain/Condemnation El Declaratory Judgment ❑ Other: [3 Ground Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Watranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 15-59670 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 I f I ' Norfolk, VA 23502 TELE: 1-866-428-8102 `� t� FAX: (757) 518-0860 � t' �'.'Ci COIN, , Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVU,ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 00 120 CORPORATE BLVD No mSqoc v NORFOLK, VA 23502 Plaintiff, V. JEREMY NESBIT 521 QUAIL CT MECHANICSBURG PA 17050 JENNIFER SOUDERS 521 QUAIL CT MECHANICSBURG PA 17050 Defendants. 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 Q 32 South Bedford Street Carlisle, PA 17013 15-59670 (717)249-3166+ )03�SxI a 367/�o 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. JEREMY NESBIT 521 QUAIL CT MECHANICSBURG PA 17050 JENNIFER SOUDERS 521 QUAIL CT MECHANICSBURG PA 17050 Demandados. 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 per la Corte sin mas aviso per 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 15-59670 Esta COMM-iicacion es de un cobrador de deudas y es un intent do cobrar Lula deuda. Cualquier infromacion sera utilizada 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. JEREMY NESBIT 521 QUAIL CT MECHANICSBURG PA 17050 JENNIFER SOUDERS 521 QUAIL CT MECHANICSBURG PA 17050 Defendants. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendants, JEREMY NESBIT and JENNIFER SOUDERS, are adult individuals with last known address of 521 QUAIL CT, MECHANICSBURG PA 17050 and 521 QUAIL CT, MECHANICSBURG PA 17050. 3. It is averred that Defendants were indebted to GE CAPITAL RETAIL BANK/HH GREGG on November 30, 2012 with account number ************3620(hereafter referred to as "Account"). 4. By using the Account, Defendants 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. 'T'l.1is connzltmicatiou is from a debt collector and is an.attempt to collect a debt. Any inforination obtained will be used for that purpose. 5. At all relevant times material hereto, Defendants have used said Account for the purchase of products, goods and/or for obtaining services. 6. Defendants were 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 Defendants. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A" 7. Defendants were 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 December 30, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ HH GREGG 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$2,080.99. 10. Despite reasonable and repeated demands for payment. Defendants have refused and continues to refuse to pay allsums 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 Defendants, JEREMY NESBIT and JENNIFER SOUDERS, in the amount of $2,080.99, 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 15-59670 This com-mmication is f-or.n 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, Mina Spellman 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: Arm 4 t W# By: Itina Spellma, Custodian of Records 15-59670 This comrnanication 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 connn 6cation is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ... .... . F Capita BILL of SALE .. -- PRA PSCC Fresh-Seigtemk►er.20I3 For value received and in further consideration of the mutual covenants and conditions set Forth in the Forward Flow Receivables Purchase Agreement(the"Agreement');date :as of this 9` day of July,2013. by.and between General Electric Capital Corporation;GE Capital Retail Bank,GEMB Lending,Inc.;Nanogram Credit :. Services LIZ.:,RFS Holding., and.GEM Holdiag,:LL.C.(collective)y"Seller") 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 .' . September 19;2013,and as further described imthe Agreement: GE C ital Retail Bank Mono aP� graimCredit Services.L.L.C.. t r i By. _� By � _ . ... Keri Wojcik Attorney inF t Ken Wo cik �. Title. EVP.Collections&Recovery Date: 13 . - Lz Date: ..................... RFS Holding, L.L..0 r General Electric Capital.Corporation By: �- .. . ..Attorney in A&Ken Wojcik By; � . Attorney in Fac en Wojcik Date; ! -Z-- f Date: GENT Holding;L.L.G 'EMB Lending;Inc: By: AL r Wojcik Atto rney in F Ken: B Y: Attorney in PALA Ken WojcikDate: =10 - �3 Date: tb -Z- 13 ' Portfolio Recovery Associ 8te5. LLC. . 3 J Title:' ......./h4r, . � .: .. H H GREGCIGECRB Cardholder Name: JEREMY NESBIT Secondary Name: ERS Account Number: 3620 GE Capital Retail Bank Statement Closing s w»iq++++►+++++++++++++ it�4fr�vt�++t+++++t+t+t+++t+t+t+• Previous Balance $2,045.99 New Balance $0.00 + New Purchases $0.00 Taal Minimum Pay vent Due $577.00 Payments $0.00 Payment Due Date 08/09/2013 +!- Credits,Fees&Adjustments(net) $2,045.99- PAYMENT DUE BY 5 P.M.EASTERN ON THE DUE DATE. +/- Interest Charge(net) $0.00 We may convert your payment into an electronic debit. See New Balance $0.00 reverse sire. Credit Limit $3,000.00 Available Credit $0:00 Late Payment Warning If w do not receive your Total Minimum Payment Due by the Payment Due Date fisted above, Days in Billing Period .28 you may have to pay a late fee up to$35.00. Pay online for free at:gogecapital.com For GE Capital Retail Bank customer service orto report your card lost or stolen,call 1-8663968254. Best times to call are Wednesday-Friday. YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULLBY ITS EXPIRATION DATE TO AVOID PAYINGDEFERRED INTEREST CHARGES PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT FORFURTHER DETAILS YOU HAVE A PROMOTION(S)EXPIRINGON 12/10/13. tttttttttttttttttttttttttttttttttttttttttttttttttttt .Promotional Promotional Deferred Tran Date Description Initial Expiration Balance Interest Charge Purchase Date Amount 12/10/2013 $72646 $0.00 11/30/2012 Deferred Interest/No Interest If Paid In $75346 Full A summary of your promotional purchase is provided above. Any promotion may be terminated if youraccoum goes 60 days past due. Ifyou have a DEFERRED INT ERESr/NO INTEREST IF PAID IN FULL promotion:To avoid paying Deferred Interest Charges on these promotion(s),you must pay the entire applicable Promo ional Balance by the Promotional Expimt ion Date. To make more than one payment see Make Payment To address or pay online at gogecapital.com. miam"n.-n Tran Date Post Date Reference Number Description Amount 08/07/2013 08/07/2013 F9071006VO0999990 CHARGE OFF ACCOUNT-PRINCIPALS $1,701.60 CR 08/07/2013 08/07/2013 F9071006VO0999990 CHARGE OFF ACCOUNT*FINANCE $379.39 CR - CHARGES* FEES 08/02/2013 08/02/2013 LATE FEE $35.00 TOTAL FEES FOR THISPERIOD $35.00 INTEREST CHARGED 04/07/2013 08/07/2013 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FORTHISPERIOD $0.00 ttttttttttf916tR�sfl+lam+bl3blbttttttttttt Total Fees Charged in 2013 $235.W _ Total Interest Charged in 2013 $144.39 Total Interest Paid in 2013 $0.00 *NOTICE:See reverse side andadditional pages(if any)for important information concemingyour account. 5302 CZH 1 3 7 130807 ZD PAGE 1 of 3 9071 0200 RRJ2 OIEJ5302 Pay online at gogecapital.com or enclose this coupon with your check.Please use blue or black ink. ** 41+ + + +** +*+ +* + Payment Enclosed: $ .New address ore-mail? payment due includes$0.00 past clue.Please pay the past due amount PROMPTLY. Check the box at left and print changes on back If you only pay the Total Minimum Due it may not pay off the Promotional Purchase by the Expiration Date. JEREMY NESB[T AAA TATDFFTAA DDTAA TTFATFDADAATFTFATTTTD DF IDFFTTFDD DDTTFAFTTFAFA DFT JENNIFERSOUDERS 521 QUAIL Cr Make Payment to: GE CAPITAL RETAIL BANK MECHANICS13URGPA 17050-2083 PO BOX 960061 ORLANDO,FL 32896-0061 FTATFTTFTTDFTTFADTDFAFFFTTFDADFADAAAATDATFFADTFFAADD DDFFDDDTTFD AF 620 Customer Service/Questions:For account information,please ca I I the toll free number on the front of this statement.Unless your name is listed on this statement,your access to information on the account maybe limited.You may also mail questions (but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account number on any correspondence you send to us. Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www. gogecapitol.com. Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekiva Springs Road,Longwood,FL 32779. Notice:See belowforyour Billing Rights and other important information.Telephoning about billing errors will not preserve your rights under federal law.To preserveyour rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando, FL 32896-5035. Purchases,returns and payments madejust prior to billing date may not appear until next month's statement.When you provide a check as payment,you authorize us either to use information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction.When we use information from your check to make on 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 Iwith the remittance coupon),in your own envelope-not the enclosed remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address. What To Do If You Think You Find A Mistake On Your Statement: If you think there is an error on your statement,write to us at GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035. In your letter 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 be- lieve it is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in wrWng,You may call us,but ifyou do we are not required to investigate any potential errors and you may have to pay the amount in question. 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 nothave 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. Information About Payments:You may at anytime 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 five days if payment lel 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.,(cl is not accompaniedbythe remittance coupon attached to your statement,(d)contains more than one payment or remittance coupon,(e)is not received in the rem itto nce envelope provided or Ifl includes staples,paper clips,tope,a folded check or correspondence of any type.Conditional Payments All written communications concerning disputed amounts,including any check or other payment instrument that(i)indicates that the Payment constitutes"payment in full"or is tendered as full satisfaction of a disputed amount,or(ii)is tendered with other conditions or limitations('Disputed Payments").must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896-5035. Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits will be applied to your previous balance immediately upon receipt,but will not satisfy a ny required payment that may be due. Credit Reports and Account Information:If you believe that we may have reported inaccurate information about you to a- consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the inaccurate information and tell us why you believe itis incorrect.If you have a copy of the credit report that includes the inac- curate information,please include a copy of that report.We may report information about your accountto credit bureaus. Late payments,missed payments,or other defaults on your account may be reflected in your credit report. How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily bal- ance"of your account for each day in the billing cycle.We then add the interest to the daily balance. To get the"daily bal- ance"we take the beginning balance of your account each day(which includes unpaid interest),add any new charges,and applicable fees,and subtract any payments or credits.This gives us the daily balance.Any daily balance of less than zero will be treated as zero.A separate daily balance will be calculated for each balance type on your account.The balances)shown in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by the number of days in the billing cycle. Bankruptcy Notice:Ifou 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 103106,Roswell,GA 30076. Your account is owned and serviced by GE Capital Retail Bank. Hearing Impaired:TDD users call 1-877-448-8512 Use of Information About You and Your Account Our Privacy Policy describes our collection and disclosure of information about you and your Account.Ifyou would like another copy ofthe Privacy Policy,please call us at the customer service tele- phone number indicated on the front of this statement. This is an attempt to collect a debt and any information obtained will be used for that purpose. OlEJ5302-12-03/05/12 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 aboutyour account.including using any contact information orcell phone numbersyou provide, and you consent to the use of a ny automatic telephone dialing system and/or an artificial or rerecorded voice when contact- ing you,even ifyou are charged for the call under your phone plan. For changes ofaddress or phone number,please check the box and print the changes below. Retail EN-OlEJ5302 Name ❑ Street Address city State Zip Code Home Phone# Business Phone# Cell#or other phone#we can use to contactyou Email Address Remember,you can update the above information aswell as youre-mail address online at www.gogecapital.com Cardholder Name: JEREMY NESBIT Account Nwnbe'M33620 Secondary Name: JENNIFERSDUDERS Statement Closi [K11�' 'P.atft'61'h1bAtFttt4t4tftfttt?tf t4tttttft4t4tttttf t4tf ttt4t4tttttit4 Expiration Date Annual Balance Subject to Interest Charge Type of Balance Percentage Interest Rate Rate(APR) Purchases NA 29.99% $0.00 $0.00 Deferred Interest/No Interest If Paid In Full 12/1"13 29.99% $0.00 $0.00 5302 CZH 1 3 7 130807 ZD PAGE 2 of 3 9071 0200 HHJ2 OIEJ5302 5302 CZH 1 3 7 130807 ZD PAGE 3 of 3 9071 0200 HHJ2 OIEJ5302 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,~, ,^~,,,, , ~, �~~�,°,~°=~,�~~��°�== RpnnyR Anderson Sheriff ot Jody S8m�h Ch�fDepub/ �,�� |U| | � Pa 2: Richard WStewart UMB��| » �� Solicitorw` or CFm=�ew"s� ^ p ^ �' � � P-NQSYiV/\N)�\ Portfolio Recorvery Associates, LLC vs. Case Number Jeremy Nesbit (et al.) 3014-3480 SHERIFF'S RETURN OF SERVICE 06/12/2014 05:52 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jeremy Nesbit, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 521 Quail Court, Hampden Township, K8eohanicsburg, PA 17050. Deputies were advised by a neighbor that they have not seen the defendants at this address in ai ately three months and the Mechanicsburg Postmaster states that mail is still delivered to the address provided. 06/12/2014 05:52 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jennifer Souders, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 521 Quail Court, Hampden Township, Mechanicsburg, PA 17050. Deputies were advised by a neighbor that they have not seen the defendants at this address in approximately three months and the Mechanicsburg Postmaster states that mail is still delivered to the address provided. SHERIFF COST: $65.30 SO ANSWERS, �». July 14, 2014 R- NO R ANDERSON, SHERIFF Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, 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. JEREMY NESBIT 521 QUAIL CT MECHANICSBURG PA 17050 and JENNIFER SOUDERS 521 QUAIL CT MECHANICSBURG PA 17050 Defendants To the Prothonotary: No. 14-3488 CIVIL PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinued without prejudi 15-59670 e � - ct ully/� Submi e• r. t 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. Curie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, 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 : No. 14-3488 CIVIL v. JEREMY NESBIT 521 QUAIL CT MECHANICSBURG PA 17050 and JENNIFER SOUDERS 521. QUAIL CT MECHANICSBURG PA 17050 Defendants CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon JEREMY N IT and J , IFER SOUDERS, by First Class Mail, Postage Pre - Paid, a copy thereof on this day of�� , 2014, to: JEREMY N SBIT, 52 CU } S CT, MECHANICSBURG PA ;10 JENNIFER SOUDERS, 521 QUAIL ECHANICSBUR C ' A 050 15-59670 ert 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.