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Home My WebLink About14-3550 Supreme Cour-VoU.ennsylvania fou, ` of Comm Pleas ira t i ForProthoKot U Only: T.[MLS'fAMP "i Covee 'Set Docket No: t C County 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 papers as required by law or rules o court. S Commencement of Action: E ®Complaint 1❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking ,I, Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC ROBERT GENET I O Are money damages 'requested? ® Yes 11 No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A Is this a Class Action Suit? 11Yes ®No Is this an MDJAppeal? 11Yes ®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. ' I s TORT(do not include Mars Tort) CONTRACT.(do not.include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board,of Assessment ❑ Motor Vehicle i ❑ Debt Collection:Credit Card ❑ Board of Elections. ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation i ❑ Premises Liability p Statutory Appeal:Other S ❑ Product Liability(does not include ` E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defarnation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T j 1 � • ❑ Other: Q MASS TORT N ❑ Asbestos. j ❑ Tobacco E] To?ac Tort-DES I REAL PROPERTY MISCELLANEOUS B El TOxiC Tort-Implant ❑ Ejectment, E] Common Law/Statutory Arbitration E] Toxic Waste ❑Eminent Domain /Condemnation ElDeclaratory Judgment ❑ Other: I E] Ground Rent E] Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations i ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILT ,y ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal f ❑ Medical ❑ Other Professional: ; i I 14-10239 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 COUN'T'Y, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. ROBERT GENET 305 W ELMWOOD AVE MECHANICSBURG PA 17055 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, ROBERT GENET, is an adult individual with last known address of 305 W ELMWOOD AVE, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to U.S. BANK NATIONAL ASSOCIATION ND/US. BANK NATIONAL ASSOCIATION ND on December 1, 2011 with account number ************3379(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. J1.1is COITI nunication is from a debt collector and is an.attempt to collect a debt. Any information obtained will be rased for that ptupose. 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. ROBERT GENET 305 W ELMWOOD AVE MECHANICSBURG PA 17055 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 14-10239 Esta connanicacion es de un cobrador de deudas y es un intent do cobrar-una deuda. Cualquier uifromacion sera utihmda 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. ROBERT GENET 305 W ELMWOOD AVE MECHANICSBURG PA 17055 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, ROBERT GENET, is an adult individual with last known address of 305 W ELMWOOD AVE, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to U.S. BANK NATIONAL ASSOCIATION ND/U.S. BANK NATIONAL ASSOCIATION ND on December 1, 2011 with account number ************3379 (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 comn1LInication is frorn 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 "A" 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on April 6, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest U.S. BANK NATIONAL ASSOCIATION ND/US. BANK NATIONAL ASSOCIATION ND 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$7,189.64. 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, ROBERT GENET , EE? ost oft ' action and any other relief as the Court deems just and reas55 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 14-10239 Jbis corm-n:niication is li-om a debt collector and is an attempt to collect a debt. Any inforn-ution obtained twill be used for that purpose. i VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, -10a„„F.Cuffae, hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belied based upon information provided by the Plaintiff The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: APR S 2014 By: Joann F. Cuffee Custodian of Records 14-10239 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. XHIBIT A This communication is from a debt collector and is an attempt to collect a debt. ° Any information obtained will be used for that purpose. EXMRIT B BILL OF SALE AND ASSIGNMF.NI-'OF ASSETS The undersigned Assignor("Assignor")hereby absolutely sells, transfers, assigns, sets-aver, quitclaims and conveys to Portfolio Recovery Associates, LLC, a Ih-nited liability company organized under the laws of Delaware ("Ass> c") on an "AS IS" and "WITH I Al_J:, FAULTS" basis, without recourse and without representations or warranties of any type, kind, character or nature, express or implied,,all of Assignor's right, title and interest in and to each of the assets identified in the Asset Schedule ("_Asset Schedule") attached hereto as Exhibit AA (the "Assets"), together with the right. to collect all principal, interest or other proceeds of any kind with respect to the Assets remaining due and owing as of the date hereof (including but not limited tot proceeds derived from the conversion, voluntary or involuntary, of any of the Assets into cash or other liquidated property, including, without limitation, insurance proceeds and condemnation awards), from and after the date of this Bill of Sale and Assignment of Assets. DATED: April 1,2013 ASSIGNOR: U.S.Bank National Association ND ° �r BY: Name p•int): j bef G.Rebmann Title: M Vie President_ Name (prifit): Steven Stamper Title: VP of Recovery III 1 3 I Nationul Loan Exchange Inc./NLEX USBWASAWC (13/26/21]13 i J PEOPI.EsBa November 2012 Statement Page 1 of 3 OF- Open Date: 10/24/2012 Closing Date: 11/30/2012 Account: 3379 Visa®Business Card Cardmember Service t� 1-866-552-8855 VILLA MEDUSA aus 35 ROBERT A GENET(CPN 001040284) Activity Summary New.Balance $5,86+0 62 Previous Balance + $6,083.61 Mmlmum Payment Due $0 00 Payments $0.00 Payment Due Da#e 12/2512Q12 other Credits - $5,866.62cR Purchases $0.00 Late Payment Warning If.. do not receive your Balance Transfers $0.00 min�mum payment by the date hsted above,you may have Advances $0.00 to pay up to a$39 Oq Late Fee and your APRs may bit Other Debits $0.00 ....... up to the Penalty APR of 28 9990 Fees Charged - $351.00cR ._ . Interest Charged - $972.02cR New Balance = $5,866.62 Past Due $0.00 Minimum Payment Due $0.00 Credit Line None Available Credit None i Days in Billing Period 38 Mail payment coupon Pay online at /� Pay by phone Payment Options: With a check myaccountaccess.com 1 1-866-552-8855 Please detach and send coupon with check payable to:Cardmember Service CPN 001040284 3379 PEP Oank Account Number 3379 O lEsB �� Payment Due Date 12/25/2012 24-Hour Cardmember Service: 1-866-552-8855 New Balance $5,866.62 r .'toY a bYP hone Minimum Payment Due $0.00 P .to change your address Amount Enclosed 000002242 1 SP 106481893383343 S VILLA MEDUSA Cardmember Service ROBERT A GENET P.O. Box 790408 3320 E MARKET ST• St. Louis,MO 63179-0408 YORK PA 17402-2619 IIIIIIIII,II,II,I,II,II„Ihll,1111,lllll,lll,llllllll,llllllllll ,1,1111,1,1111111'II'Illlllllllllldl'lllll'I'I'lllllllly„II,II r What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement,please call us at the telephone number on the front of this statement,or write to us at: Cardmember Service,P.O.Box 6335,Fargo,ND 58125-6335. In your letter or call,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 believe it is a mistake. You must contact us within 60 days after the error appeared on your statement.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 not have 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. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card,and you have tried in good faith to correct the problem with the merchant,you may have the right not to pay the remaining amount due on the purchase. To use this right,all of the following must be true: 1.The purchase must have been made in your home state or within 100 miles of your current mailing address,and the purchase price must have been more than$50.(Note:Neither of these are necessary if your 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 must have used your credit card for the purchase.Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3.You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase,contact us in writing at:Cardmember Service,P.O.Box 6335, Fargo,ND 58125-6335.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. Important Information Regarding Your Account 1.INTEREST CHARGE:Method of Computing Amount Subject to Interest:We calculate the periodic rate or interest portion of the INTEREST CHARGE by multiplying the applicable Daily Periodic Rate("DPR")by the Average Daily Balance("ADB")(including new transactions)of the Purchase,Advance and Balance Transfer categories subject to interest,and then adding together the resulting interest from each category.We determine the ADB separately for the Purchases,Advances and Balance Transfer categories.To get the ADB in each category,we add together the daily balances in those categories for the billing cycle and divide the result by the number of days in the billing cycle.We determine the daily balances each day by taking the beginning balance of those Account categories(including any billed but unpaid interest,fees,credit insurance and other charges),adding any new interest,fees,and charges,and subtracting any payments or credits applied against your Account balances that day.We add a Purchase,Advance or Balance Transfer to the appropriate balances for those categories on the later of the transaction date or the first day of the statement period.Billed but unpaid interest on Purchases,Advances and Balance Transfers is added to the appropriate balances for those categories each month on the statement date.Billed but unpaid Advance Transaction Fees are added to the Advance balance of your Account on the date they are charged to your Account.Any billed but unpaid fees on Purchases,credit insurance charges,and other charges are added to the Purchase balance of the Account on the date they are charged to the Account.Billed but unpaid fees on Balance Transfers are added to the Balance Transfer balance of the Account on the date they are charged to the Account.In other words,billed and unpaid interest,fees,and charges will be included in the ADB of your Account that accrues interest and will reduce the amount of credit available to you.Credit insurance charges are not included in the ADB calculation for Purchases until the first day of the billing cycle following the date the credit insurance premium is charged to the Account.Prior statement balances subject to an interest-free period that have been paid on or before the payment due date in the current billing cycle are not included in the ADB calculation. 2. Payment Information: You must pay us in U.S.Dollars with checks or similar payment instruments drawn on a financial institution located in the United States. We will also accept payment in U.S.Dollars via the Internet or phone or previously established automatic payment transaction. We may,at our option,choose to accept a payment drawn on a foreign financial institution. However,you will be charged and agree to pay any collection fees required in connection with such a transaction. The date you mail a payment is different than the date we receive that payment. The payment date is the day we receive your check or money order at Cardmember Service,P.O.Box 790408,St.Louis, MO 63179-0408 or the day we receive your electronic or phone payment.All payments by check or money order accompanied by a payment coupon and received at this payment address will be credited to your Account on the day of receipt if received by 5:00 p.m.CT on any banking day. Mailed payments that do not include the payment coupon and/or are mailed to a different address will be processed within 5 banking days of receipt and credited to your Account on the day of receipt.In addition,if you mail your payment without a payment coupon or to an incorrect address,it may result in a delayed credit to your Account,additional INTEREST CHARGES,fees,and possible suspension of your Account. Internet and telephone payment options are available,and crediting times vary(but generally must be made before 5:00 p.m.CT to 8 p.m.CT depending on what day and how the payment is made). If you are making an intemet or telephone payment,please contact Cardmember Service for times specific to your Account and your payment option. Banking days are all calendar days except Saturday,Sunday and federal holidays.Payments due on a Saturday,Sunday or federal holiday and received on those days will be credited on the day of receipt. 3.Credit Reporting:We may report information on your Account to Credit Bureaus.Late payments,missed payments or other defaults on your Account may be reflected in your credit report. PEOP9EsBank vs wtley Con¢vry November 2012 Statement 10/24/2012- 11/30/2012 Page 2 of 3 ti VILLA MEDUSA Cardmember Service 1-866-552-8855 ROBERT A GENET(CPN 001040284) important Messages We understand that our cardmembers impacted by Hurricane Sandy have special needs during this difficult time. If you are one of those affected, please call Cardmember Service for questions or assistance. We appreciate your business and are here to support you. You asked; we listened.Your New Statement Design is Here! Simply Stated,we want to keep you informed about your account with clear and useful information. The new design is easier to read with important information available at a glance. Please see the enclosed insert for more details.Thank you for your business and your feedback. rt ransaawns Payments and Other Credits Post Trans Date Date Ref# Transaction Description Amount Notation 11/30 CHARGE OFF $5,866.62CR TOTAL THIS PERIOD $5,866.62CR Fees Post Trans Date Date Ref# Transaction Description Amount Notation 11/30 REVERSAL OF LATE PAYMENT FEE $234.00CR 11/30 REVERSAL OF OTHER FEES AT CHARGE OFF $117.0008 TOTAL FEES THIS PERIOD $351.00CR Interest Charged Post Date Transaction Description Amount Notation 11/30 INTEREST REVERSAL $972.02CR TOTAL INTEREST THIS PERIOD $972.02CR ... ...... 2012 Totals Year to-flats Total Fees Charged in 2012 $39.00 Total Interest Charged in 2012 $84.95 Compan A royal (This area ftr use by your aompat�y) Y pp . . ...... . ... ... .. Signature/Approval: Accounting Code: Continued on Next Page 4 'I }t F Ir PEOPI:EsBank AC.-I.,C- ' November20.12 Statement 10/24/2012- 11/30/2012 Page 3 of 3 VILLA MEDUSA Cardmember Service 1-866-552-8855 ROBERT A GENET(CPN 001040284) interest Charge Calculatid Your Annual Percentage Rate(APR)is the annual interest rate on your account. **APR for current and future transactions. i Balance Annual Expires Balance Subject to Interest Percentage with Interest Balance Type By Type Interest Rate Variable Charge Rate Statement Free Period —BALANCE TRANSFER $0.00 $0.00 YES $0.00 28.99% NO "PURCHASES $7,189.64 $7,189.64 YES $216.99 28.99% YES —ADVANCES $0.00 $0.00 YES $0.00 28.99% NO To reduce or avoid paying additional fees and interest charges on your purchase balance,pay the total new balance of $5,866.62 by 12/25/12.Any cash balance or balance transfer balance will continue to accrue daily interest until the date your payment is received. Contact Us. t� PhoneO Questions Mail payment coupon Online with a check Voice: 1-866-552-8855 Cardmember Service Cardmember Service myaccountaccess.com TDD: 1-888-352-6455 P.O.Box 6353 P.O.Box 790408 Fax: 1-866-807-9053 Fargo,ND 58125-6353 St.Louis,MO 63179-0408 P 1 i t f f h P End of Statement Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF;CE OF TH. $F4.RIFF L. E ('i o t`r 2 j i. r� JUL 1 �11 fpi n t�f i trl CUMBERLAND COU N''t iPENNSYLVANlA Portfolio Recovery Associates, LLC vs. Case Number Robert Genet 2014-3550 SHERIFF'S RETURN OF SERVICE 06/20/2014 07:10 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: Robert Genet, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 305 W. Elmwood Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055. Deputies were advised by Deborah Genet, defendant's wife, that the defendant moved to Montecito Sequoia Lodge, P.O. Box 848, Kings Canyon National Park, California 93633. SHERIFF COST: $39.30 SO ANSWERS, June 25, 2014 (c) CountySui!e Sheriff, Teleosoft. Inc. RONWR ANDERSON, SHERIFF OP 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 Tti 1'(i 0 THON5 2014AUG 19 RP!I1:I+1 CUti8ERLgND COlIN -�: pEtYt�S r'LVANJ� 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. ROBERT GENET 305 W ELMWOOD AVE MECHANICSBURG PA 17055 Defendant No. 14-3550 CIVIL PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above -entitled case as discontinued without prejudice. y Submitt 14-10239 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. ROBERT GENET 305 W ELMWOOD AVE MECHANICSBURG PA 17055 Defendant : No. 14-3550 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon OBERT GENET, by First Class Mail, Postage Pre -Paid, a copy thereof on this day of , 2014, to: ROBERT GENET, 305 W ELMWOOD A'VE, s: HANICSBU s 7055 14-10239 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.