HomeMy WebLinkAbout14-3548 S>ipreme Court.-of Pennsylvania
Court,4 f CpIll; 0n Pleas For Prothonotary Use Only TIMFS'1AMP
Civil/;Cover Sheet Docket No:
CUMBER ?County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the lin and set-vice 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:
,r
PORTFOLIO RECOVERY ASSOCIATES,LLC PEDRO ARCAS
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 have no attorney(are a Self-Represented[Pro Sel Litigant)
r
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:
Q MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ To)dc Tort-DES REAL PROPERTY MISCELLANEOUS
B ❑ To)dc Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration
❑ To)dc Waste ❑Eminent Domnain/Conderrmation ❑ Declaratory Judgment
❑ Other: ❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations
❑ Mortgage Foreclosure:Residential Restraining Order
❑ Mortgage Foreclosure:Commercial ❑ Quo Wamanto
❑ Partition ❑ Replevin
PROFESSIONALLIABILTTY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
15-94688
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 t
120 Corporate Blvd
Norfolk, VA 23502 �
TELE: 1-866-428-8102 �(��,.��- j
FAX: ) 518-0860 �
Attorne7 s for Plaintiff E 101S Y I� C,1�^�' f,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CML ACTION-LA W
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502 No.
Plaintiff,
V
PEDRO ARCAS
434 B ST
CARLISLE PA 17013
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
(717)249-3166 /aJ /
15-94688 7S
(�- a
)9
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 TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION- LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Demandante, No.
V.
PEDRO ARCAS
434 B ST
CARLISLE PA 17013
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 dine ro 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
casted.
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
i Carlisle, PA 17013
(717) 249-3166
15-94688
Esta comuiiicacion es de un cobrad.or de deudas y es uta intent do cobras tnaa deuda.
Cualquier irlfromacion sera utilirada 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.
PEDRO ARCAS
434 B ST
CARLISLE PA 17013
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, PEDRO ARCAS, is an adult individual with last known address of 434 B ST,
CARLISLE PA 17013.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/WAL-MART on
December 5, 2007 with account number ************7416 (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.
IIAS COMULMication is from a debt collector and .is an attempt to collect a debt.
Any information 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 "All
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 July 7, 2012.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/
WAL-MART 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$931.48.
10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to
refuse to pay all sums due and owing on the aforementioned Account, all to the damage and
detriment of the Plaintiff.
11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration.
WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of
Plaintiff and against Defendant, PEDRO ARCAS , inEarric
o f$ 31.48, plus costs of this acti d
any other relief as the Court deems just and reasona
A Brown, Esquire, #94055
Robert N. Polas, Jr., Esquire, #201259
Mark K Garvey, Esquire, #312686
Attorneys for Plaintiff
15-94688
t
This coirnmLuaication is fi-orn a debt collector and .is an.atternpt to collect a debt.
Any information obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates,LLC,
Samaria Braswell
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.
MAY 012014
Date:
By:
Samaria Braswell
Custodian of Records
15-94688
I
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
i
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
t
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 1P 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; 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 '9— Date:
General Electric Capital Corporation RFS Holding,L.L.0
By: By:
Glenn Marino Joseph Ressa
Title: Vice P esident Title:CFO
Date: Date:
GEMB Lending,Inc. GEM Holding,L.L.0
By: By:
Stephen Motta Joseph Ressa
Title: Director Title:CFO
Date: Date:
Flo
l GE Capra!
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 ("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.
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 zlnc. GEM Holding, L.L.0
4�4By: By:
StephenW&fa Joseph Ressa
Title: Director Title: CFO
Date: 4141113 Date:
G&cp, 9o.
Z �' 3
. X90
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 13th 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, 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 lding;L.L.0
By: By:
Glenn Marino Joseph R s
Title:Vice President Title: CFO
Date: Date: y �,L•
GEMB Lending,Inc. GEM oldirig L:L.0 .
By By:
Stephen Motta Joseph R s- ,
Title: Director Title:CFO
Date: Date: -•t 3
GL 3 ��
90 3
Q
Wa1mart
Save money.Live better. t'
Walmart" PEDRO D ARCAS Visit mat walmart.com/credit
Credit Card Account Number: 416 Customer Service:1-8006414526
mer*aur t#+±+±ttt±+#+±t± le>ttr►t±>Fa»afa,#t±+±+#+±t±t±..tutu+±+
Previous Balance $931.48 NeWBalaaes $0.00
-Other Credits - $931.48 Amount Past Due $0.00
NewBalance $0.00 Total Minimum Payment Due $336.00
Payment Due Date 02/12/2013
Credit Limit $800 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 Advance/Quick Cash Limit $160 fee up to$35.00.
Available Cash $0.00
Statement Closing Date 02/10/2013
Days in Billing Cycle 26
#t#ttt###tf##ttttttt#t##tttt#t#ttttt####tttt#t#t#tttt#tt
Tran Date Post Date Reference Number Description of Transaction or Credit Plan Type Amount
02/10 02/10 F9112001900999990 CHARCEOFF ($681.88)
ACCOUNT-PRINCIPALS -
02/10 02/10 F9112001900999990 CHARGE OFF ACCOUNT-FINANCE ($249.60)
CHARGES-
FEES
HARGESFEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARCED
02/10 02/10 INTEREST CHARGE ON PURCHASES $0.00
02/10 02/10 INTEREST CHARGE ON CASH $0.00
ADVANCES .
TOTAL INTEREST FOR T HIS PERIOD $0.00
.... .'d- ---
•�tlt#+iti+tti+i+
Total Fees charged in 2013 • - --- - ---$0.00
Total Interest charged in 2013 $18.51
Total Interest Paid in 2013 $0.001
9r lFiiitirtirtihitititirtirtiiititi+iFihitititirti*iiitiiirti*
Your Annual Percentage Rate(APR) is the annual interest rate on your account.
Annual Percentage Balance Subject to
Type of Balance Expiration Date Plan Type Rate Interest Rate Interest Charge
Current Transact ions
Regular Purchases&Cash NA REG 22.90%(v) $0.00 $0.00
Advances
Transactions on or before 12/31/2010
Regular Purchases N/A REG 22.90% $0.00 $0.00
(v)=Variable rate
lnllitfallln�uNiti+i*iMi*iti+i*i*i+i4iti*i*#*i+it i*+*iiiiiM�iFi*i*
Ifyour account has a deferred interest promotion and you would like is to apply a payment on your account to a specific
balance,please call Customer Service to discuss options that may be available.
PAYMENT DI JE By 5 P M(ET)ON THE DI TF DATF
NOTICE:We may convert your payment into an electronic debit.See reverse for details,Billing Rights and otter important
information
5404 HFH 1 3 12 130210 ZX PAGE 1 of 1 9112 1400 0204 OlDD5404
+� r Detach and mail this portion with your check.Do not include any correspondence with your check.
Account
um
16
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Save money.Uve better. v
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$336.00 $0.00 02/12/2013 1 $0.00 $0.00
Payment Enclosed . ... . ..
Please use blue or black ink. $
*6032201415547416* New address or email?Print changes on back.
ST D ARCAS
434 B SDAFTI'I'FATATTATADDFDAFFTADFDADTFDFDAADDTFCITATDFATFTTAFFFFT)TDAFDD
434 B r
CARLISLE PA 17013-1827 Make PaymentTo: WALMART/CECRB
P.O.BOX 530927
FAAFTTDAAFADTDATFTTAAATADDDDADDATADADFFADDDFFATFF ribfkABTAER+-Mlj&,R927
7 416
Customer ServlceiQuestions:For account information,please call 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 may be limited.You may also mail questions(but not payments)to:P.O.Box 965023,Orlando,FL
32896.5023.Please include youraccount number on any correspondenceyou send to us.
Payments:Send payments to the address listed on the remit portion of this statement or pay online.
Notice:See below foryour Silting Rights and other important information.Telephoning about billing errors will not preserve your rights under federal law.
To preserveyourrights,please wrileto our Billing Inquiries Address,PO.Box 965023,Orlando,FL 32896-5023.
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 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 yourcheck to make an electronic fund transfer,funds maybe withdrawn from youraccount 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 960098,Orlando,FL 32896-0098 and notthe Payment Address.
What To Do It You Think You Find A Mistake On Your Statement including any checker other payment instrumenithat:(I)indicates that the
If you think there is an error on your statement,write to us at the Billing payment constitutes"payment in full"or is tendered as full satisfaction of a
Inquiries Address of: disputed amount;or(it)is tendered with other conditions or limitations
GE Capital Retail Bank ("Disputed PaymenW),must be mailed or delivered to us at P.O.Box
P0.Box 965023,Orlando,FL 32896-5023 965023,Orlando,FL 32896.5023.
In your letter,give us the following information: Credits To YourAccoutn:An amount shown in parenthesis or preceded
•Account information.,Your name and account number by a minus(-)sign is a credit or credit balance unless otherwise indicated.
•Dollar amount:The dollar amount of the suspected error. Credits will be applied to your previous balance immediately upon receipt,
•Description of Problem If you think there is an error on your bill, butwiilnotsatlsfyany required payment that maybe due.
describewhatyoubelieve iswrong and whyyoubelieve itisamistake. Credit Reports And Account Information.,If you believe that we have
You must contact us within 60 days after the error appeared on your reported inaccurate Information about you to a consumer-reporting
statement. agency,please contact us at P.O.Box 965024,Orlando,FL 328965024.In
You must notily us of any potential errors in writing.You may call us,but doing so,please identify the inaccurate information and tell us why you
if you do we are not required to investigate any potential errors and you believe It Is incorrect.If you have a copy of the credit report that Includes
mayhavelo pay the amount in question. the Inaccurate information,please include a copy of that report.We may
While we investigate whether or not there has been an error,the report information about your account to credit bureaus.Late payments,
following are We: missed payments,or other defaults on your account may be reflected in
•We cannot try to collect the amount in question,or report you as your credit report.
delinquent on that amount. Balance Subject Todntevest Charge Calculation
• The charge in question may remain on your statement,and we may Method 2D(Dally Balance method):We figure the Interest charge on your
continue to charge you interest on that amount.But,if we determine that account byapplyirig the periodic rate tothe'daily bale noaofyour account for
we made a mistake,you will not haw to pay the amount in question or any each day in the billing cycle.Wethen add the interest tothe daiybalance.To
interest or other fees related to that a mount. get the"daily belarxe"we take the beginning balance of your account each
• While you do not have to pay the amount in question,you are day(which includes unpaid interest),add any new charges,and applicable
responsible forthe remainder of yourbalance. fees,and subtract any payments or credits.This gives us the daily balance.
• We can apply any unpaid amount against your credit limit. Any daily balance of less than zero will be treated as zero.A separate daily
Your Rights If You Are Dissatisfied With Your Credit Card balance will be calculated for each balance type on your account.The
Purchases balances)shown in the Interest Charges section of this statement Is the sum
If you are dissatisfied with the goods or services that you have of the daily balances for each day in the billing cycle divided by the number of
purchased with your credit card,and you have tried in good faith to days in the billing cycle,
correct the problem with the merchant,you may have the rig htnot topay Method 2M(Avemp Daily Sal ance Including cu mant transactions):
the remaining amount due on the purr base. We figure the interest charge on your account by applying the periodic rate to
To use this night,all of the following must be true: the"average daily balance'of your account.To get the"average daily
1.The purchase must have been made in your home state orwilhin 100 balance"we take the beginning balance of your account each day,which
miles of your current mailing address,and the purchase price must have includes any unpaid interest charges from the previous billing cycle,add any
been more than 550.(Note:Neither of these are necessary if your new charges,and applicable fees and subtract any payments or credits.This
purchase was based on an advertisement we mailed to you,or if we own gives us the daily balance.Then,we add up all the daily balances for the
thecompanythatsold you the goods orservices.) billing cycleabedividethetotalbythenumberofdaysinthe billingcycle.This
2.You must have used your credit card for the purchase.Purchases gives us the'average daily balance,"which is the balance shown in the
madewithcash advances from an ATM orwith a check that accesses your Interest Charges section ofthtsstatement.Anyaveragedailybalanceofless
credilcard aocountdonolqualify. than zero will be treated as zero A separate average dairy balance will be
3.You must not yet have fullypaidforthepurchase. calculated foreachbalancetypeonyouraccount.
If all of the criteria above are met and you are still dissatisfied with the BankruptcyNodce:If you Is bankruptryyou must send us notice,including
purchase,contact us in writingat account number and an Information related to the proceeding to the following
GE Capital Retail Bank address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,PO Box 103104,
P0.Box 965023,Orlando,FL 32896-5023 Roswell,GA30076.
While we investigate,the same rules apply to the disputed amount as Youraccountis owned andservicedbyGECapitalRetail Bank
discussed above.After we firesh our investigation,we will tell you our Hearing lmpakediusers call 14800444-1732.
decision.At that point,if we think you awe an amount and you do not pay
we may report you as delinquent.
Information About Payments:You may at any time pay,in whole orin - -
part the total unpaid balance without any additional charge for
prepayment Payments received after 5:10 PM(ET)on any day will be
credited as of the next day.Credit toyourAmount maybe delayed upto five
days if payment(a)scot received atthe 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 yourstatement,(d)
contains more than one payment or remittance 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:All written communications concerning disputed amounts,
OID05404-2-071132011
This is an attempt to collect a debt and any information obtained will be used for that purpose.
*By providing a telephone numberon your account,you consent to GE Capital Retail Bankand any otherowneror servicerof youraccounl 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 andfor email,please check the box and print the changes below.
Street
Address
City,State,
Zip
Phone#
E-mail
Home Polon# Business Phone# 'Cell If 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 Walmarl.
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
THE r RO I HOMO Tt,
i 1l4 JUL --9 AM 9: 1
CUMBERLAND PENNSYLVANIA 7Y
OFFICE OF `rHE SHERIFF
Portfolio Recovery Associates, LLC
vs.
Pedro Arcas
Case Number
2014-3548
SHERIFF'S RETURN OF SERVICE
06/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Pedro Arcas, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 434 B
Street, Carlisle Borough, Carlisle, PA 17013. Residence is vacant and to this date the Carlisle Postmaster
has not been able to provide a good forwarding address for the defendant.
SHERIFF COST: $39.78 SO ANSWERS,
June 30, 2014
(c) CountySuite Sheriff, Teleosoft. Inc.
RRR 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
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PENNSYLVANIA
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.
PEDRO ARCAS
434 B ST
CARLISLE PA 17013
No. 14-3548 CIVIL
Defendant
PRAECIPE TO DISCONTINUE
To the Prothonotary:
Please mark the above -entitled case as discontinu
15-94688
out prejudice.
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
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.
PEDRO ARCAS
434 B ST
CARLISLE PA 17013
Defendant
: No. 14-3548 CIVIL
CERTIFICATE OF SERVICE
The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue
upon P) RO ARCAS, by First Class Mail, Postage Pre -Paid, a copy thereof on this 6/(f day of
2014, to:
15-94688
PEDRO ARCAS, 434 B ST R SLE PA 17013
/7//
Robert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.