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Home My WebLink About14-3760 Sumeme Q. ,Pennsylvania 6U.4. f Go m n Pleas f' For Prothonotary U e Only: '11M E STAMP Cl; VB� Ct Docket No: CUMB '- ;.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 bylaw or rules o court. S Commencement of Action: E ®Complaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction []Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: ,r PORTFOLIO RECOVERY ASSOCIATES,LLC ERIN E DICKNSON 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./Came Brown/Mark R Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRAIARY 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) C v'IL.,APPFAI S ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle a Debt Collection:Credit Card ❑ Board.of Elections ❑ Nuisance 0 Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S ❑ Product Liability(doer 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 r-1 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑Ernnnent Domain/Condemnation ❑ Declaratory Judgment ❑ 'Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABUJI'Y ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: s 16-02422 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 ,r Norfolk, VA 23502 a f TELE: 1-866-428-8102 ,` FAX:(757) 518-0860. PC G(1 UN Attorneys for Plaintiff yti "( T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVILACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC n 120 CORPORATE BLVD NORFOLK, VA 23502 : No. Plaintiff, V. ERIN E DICKINSON 1091 OYSTER MILL RD CAMP HILL PA 17011 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 n 32 South Bedford Street J Carlisle, PA 17013 16-02422 (717)249-3166 1 b 3 361(os& 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 CUMBIERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. : ERIN E DICKINSON 1091 OYSTER MILL RD CAMP HILL PA 17011 Demandado. NOTICIA LISTED 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 falls 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 1NFORMACION 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 16-02422 Esta connm.icacion es d.e un cobrador de deudas y es un intent do cobrar mia 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 TIS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 ; Plaintiff, No. V. ERIN E DICKINSON 1091 OYSTER MILL RD CAMP HILL PA 17011 Defendant. COMPLAINT I. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, ERIN E DICKINSON, is an adult individual with last known address of 1091 OYSTER MILL RD, CAMP HILL PA 17011. 3. It is averred that Defendant was indebted to MBNA/FIA CARD SERVICES, N.A. / ************4914 on August 8, 2005 with account number ************1219 (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 corxmnuzication is fi-orn 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 wasno 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 January 7, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest MBNA/FIA CARD SERVICES, N.A. / ************4914 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$11,592.28. 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, ERIN E DICKINSON, in theo t of$11,592.28, plus os of this action and any other relief as the Court deems just and reas nab . Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-02422 This corm11unication is frorn a debt collector and is an.attempt to collect a debt. Any information obtained wil be used for that rxurvose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Mann F. Cuffee 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: JUN 0 6 2014 By: Joann F. Cuffee Custodian of Records 16-02422 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that numose. 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. BankofAmerica EXHIBIT C BILL OF SALE AND ASSIGNMENT OF LOANS THIS BILL OF SALE AND ASSIGNMENT OF LOANS is made and entered into between PORTFOLIO RECOVERY ASSOCIATES,LLC("Purchaser")and FIA CARD SERVICES,N.A.("Seller'), pursuant to the Loan Sale Agreement dated September 13, 2013 (the "A eement") entered into between Purchaser and Seller. Capitalized terms not defined herein,shall have the same meaning as defined in the Agreement. (a) In consideration of the payments made pursuant to the Agreement and such other good and valuable consideration,the receipt and legal sufficiency of which are hereby acknowledged,.Seller does hereby sell, transfer,convey,assign and deliver to Purchaser all of Seller's right,title and interest in and to each and all of the Loans,as included on the electronic file referenced in Schedule 1 of the Loan Agreement as BAC Fresh PRA Sale Fite 0913 Final.xlsx,without recourse and without representation or warranty of any type,kind,character or nature,express or implied,except as specifically provided in the Agreement, and subject to Buyer's and Seller's repurchase rights as set forth in the Agreement. (b) Purchaser hereby accepts such sale,transfer,conveyance,assignment,and delivery of the Loans, including without limitation the right to all principal, interest or other proceeds of any kind with respect to the Loans remaining due and owing as of the Cut-Off Date applicable to such Loans. (c) Nothing in this Bill of Sale and Assignment of Loans shall be deemed to modify, limit or amend any of the rights or obligations of Purchaser or Seller under the Agreement. This Bill of Sale and Assignment of Loans shall inure to the benefit of,and be binding upon,the respective, permitted successors and assigns of Seller and Purchaser and shall be governed by and construed and interpreted in accordance with the Agreement and the laws of the State of Delaware,without regard to such state's principles of conflicts of law. (d) This Bill of Sale and Assignment-of Loans may be executed by facsimile or electronic transmission in multiple counterparts,each of which shall be an original, but together shall constitute one and the same instrument. IN WITNESS WHEREOF,each party,through its duly authorized officer,has caused this Bill of Sale and Assignment of Loans to be executed in their name this 26th day of September,2013. SELLER/ASSIGNOR: BUYER/ASSIGNEE: FIA CARD RVICES, PORTFOLIO OVERY ASSOCIATES,LLC By: By: Name: Debra L ellicciaro Name: �+SIT. /,!� Title: Vice President Title: Ay{rwogq,102 Fax:302.458.04:38 Fresh 9/13/13 Hank of America,Asset Sales Deerfield III,M Paper Mill Road,Newark,DE 19712 ERIN E DICKINSON Account Number: 1219 August 10-September Account Information: www.bankofamerica.com Payment Information Account Summary Mail billing Inquiries to: New Balance Total............................................................................$0.00 Previous Balance......................$11,592.28 Bank of America Current Payment Due........................................................................$0.00 Payments and Other Credits.........-11,592.28 P.O.Box 982235 Purchases and Adjustments....................0.00 El Paso,TX 79998-2235 Total Minimum Payment Due..............................................................$0.00 Fees Charged..................... ...............................0.00 Mail payments to: Payment Due Date......................................................................10/24/13 Interest Charged...............................................0.00 Bank of America P.O.Box 15019 Late Payment Warning:If we do not receive your Total Minimum Payment by New Balance Total ...............................$0.00 Wilmington,DE 19886-5019 the date listed above,your APRs may be increased up to the Penalty APR of Customer Service: 29.99%. Total Credit Line...................................$0.00 1.888.793.6262 Cash Credit Line...........................$2,970.00 (1.800.346.3178 TTY) Statement Closing Date....................9/26/13 Days in Billing Cycle..................................48 Transactions Transaction Posting Reference Account Date Date Description Number Number Amount rota/ Payments and Other Credits 09/23 09/23 ZERO CURBL ON SOLD ACCT —11,592.28 —$11,592.28 Purchases and Adjustments 09/26 09/26 +TRANS FROM 4313038295394914 11,592- 0.00 $0.00 Interest Charged 09/26 09/26 Interest Charged on Purchases 0.00 09/26 09/26 Interest Charged on Balance Transfers 0:00 09/26 09/26 Interest Charged on Dir Dep&Chk CashAdv 0.00 09/26 09/26 Interest Charged on Bank Cash Advances 0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2013 TotalsYear-to-Date Total fees charged in 2013 $235.00 Total interest charged in 2013 $1,773.64 1219 BANK OF AMERICA Account Number: 1219 P.O.BOX 15019 WILMINGTON,DE 19886-5019 .......$0.00 New Balance Total .......................................................... Total Minimum Payment Due.....................................................0.00 Payment Due Date.......................................................10/24/13 ERIN E DICKINSON Enter payment amount $ 1060 N CHARLOTTE STREET 220 LANCASTER PA 17603-0000 ❑ Check here fora change of mailing address orphone numbers. Please provide all corrections on the reverse side. Mail this coupon along with your check payable to:Bank of America L � Lqu■ IMPORTANT INFORMATION ABOUT THIS ACCOUNT USE811 Rev.08/13 CUSTOMER TIPS FOR DISPUTED ITEMS Many times disputed charges are legitimate charges that customers may not recognize ONLINE or remember.Before disputing a charge,we recommend that you verify a few things and make Online Banking is available 24 hours a day,7 days a week and every effort to resolve the dispute with the merchant Often the merchant can answer your allows you to view the most recent activity on your account questions and easily resolve your dispute.The merchants phone number may be located on your receipt or billing statement PHONE •Has a credit posted to your account? (� 1.866.266.0212 Please allow up to 30 days from the date on your credit voucher or acknowledgement letter �j, For prompt service,please have the merchant reference number(s)available for the merchant credit to post for the charge(s)in question. •Is the charge or amount unfamiliar? Check with other persons authorized to use the account to make sure they did not make the charge.It is possible that the merchants'billing names and store names are different or MAIL amounts can easily be confused with similar charges or include tips. Attn:Billing Inquiries PO Box 982235,EI Paso,TX 79998 One way to check for the credits or to view transaction details is to look at your account When writing,please include Your Name,Account Number,the Disputed statements online.If you are not enrolled in Online Banking,it is easy to enroll using the web Amount,Merchant Name,Transaction Date,and reference number of address on the front of your statement or give us a call. the disputed item and specific details regarding your dispute,including dates Please remember:If you find an error on your bill,you must notify us no later than of contact with the merchant and the merchant's response in each instance. 60 days after we sent your first statement on which the error or problem appeared Please include all supporting documentation,including sales and credit to preserve your billing rights. vouchers,contract and postage return receipts as proof of any returns. PAYING INTEREST TOTAL INTEREST CHARGE COMPUTATION We will not charge interest on Purchases on the next statement if you pay the New Balance Interest Charges accrue and are compounded on a daily basis.To determine the Interest Total in full by the Payment Due Date,and you had paid in full by the previous Payment Due Date. Charges we multiply each Balance Subject to Interest Rate by its applicable Daily Periodic Rate We will begin charging interest on Balance Transfers and Cash Advances on the transaction date. and that result is multiplied by the number of days in the billing cycle.To determine the total CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Interest Charge for the billing cycle,we add the Periodic Rate Interest Charges together.A Daily Average Daily Balance Method(including new Purchases): Periodic Rate is calculated by dividing an Annual Percentage Rate by 365. We calculate separate Balances Subject to an Interest Rate for Purchases and for each HOW WE ALLOCATE YOUR PAYMENTS Introductory or Promotional Offer balance consisting of Purchases.We do this by:(1)calculating Payments are allocated to posted balances.If your account has balances with different APRs, a daily balance for each day in the billing cycle;(2)adding all the daily balances together;and(3) we will allocate the amount of your payment equal to the Total Minimum Payment Due to the dividing the sum of the daily balances by the number of days in the billing cycle. lowest APR balances first(including transactions made after this statement).Payment amounts To calculate the daily balance for each day in this statement's billing cycle,we:(1)take the in excess of your Total Minimum Payment Due will be applied to balances with higher APRs beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate multiplied by before balances with lower APRs. the previous day's daily balance;(3)add new Purchases,new Account Fees,and new Transaction IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE Fees;and(4)subtract applicable payments and credits.If any daily balance is less than zero we When using the optional Pay-by-Phone service,you authorize us to initiate an electronic treat it as zero. payment from your account at the financial institution you designate.You must authorize the Average Balance Method(including new Balance Transfers and new Cash Advances): amount and timing of each payment.For your protection,we will ask for security information.A We calculate separate Balances Subject to an Interest Rate for Balance Transfers,Cash fee may apply for expedited service.To cancel,call us before the scheduled payment date. Same- Advances,and for each Introductory or Promotional Offer balance consisting of Balance Transfers day payments cannot be edited or canceled. or Cash Advances.We do this by:(1)calculating a daily balance for each day in this statement's YOUR CREDIT LINES billing cycle;(2)calculating a daily balance for each day prior to this statement's billing cycle The Total Credit Line is the amount of credit available for the account;however,only a that had a"Pre-Cycle balance'—a Pre-Cycle balance is a Balance Transfer or a Cash Advance portion of that is available for Bank Cash Advances. The Cash Credit Line is that amount you have with a transaction date prior to this statement's billing cycle but with a posting date within this available for Bank Cash Advances.Generally,Bank Cash Advances consist of ATM Cash Advances, statement's billing cycle;(3)adding all the daily balances together;and(4)dividing the sum of Over the Counter(OTC)Cash Advances,Same-Day Online Cash Advances,Overdraft Protection the daily balances by the number of days in this statement's billing cycle. Cash Advances,Cash Equivalents,Returned Payments,and applicable transaction fees. To calculate the daily balance for each day in this statement's billing cycle,we:(1)take the MISCELLANEOUS beginning balance;(2)add an amount equal to the applicable Daily Periodic Rate multiplied by the -Promotional Rate End Date:This date is based on a future statement closing date. previous day's daily balance;(3)add new Balance Transfers,new Cash Advances and Transaction If you change your payment due date,this date could change.Transactions must meet offer Fees;and(4)subtract applicable payments and credits.If any daily balance is less than zero we conditions in order to qualify for the promotional rate. treat it as zero. For the complete terms and conditions of your account,consult your Credit Card Agreement To calculate a daily balance for each day prior to this statement's billing cycle that had a FIA Card Services is a tradename of FIA Card Services,N.A.This account Pre-Cycle balance;(1)we take the beginning balance attributable solely to Pre-Cycle balance is issued and administered by FIA Card Services,N.A. (which will be zero on the transaction date of the first Pre-Cycle balance);(2)add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day's daily balance;(3)and add only the applicable Pre-Cycle balances and their related Transaction Fees.We exclude from this calculation all transactions posted in previous billing cycles. PAYMENTS We credit mailed payments as of the date received,if the payment is:(1)received by 5 p.m. If your billing address or contact information has changed,or if your address is local time at the address shown on the remittance slip on the front of your monthly statement; incorrect as it appears on this bill,please provide all corrections here. (2)paid with a check drawn in U.S.dollars on a U.S.financial institution or a U.S.dollar money order;and(3)sent in the return envelope with only the remittance portion of your statement accompanying it Payments received by mail after 5 p.m.local time at the remittance address Address 1 on any day including the Payment Due Date,but that otherwise meet the above requirements, will be credited as of the next day. Payments made online or by phone will be credited as of the date of receipt if made by 5 p.m.Central. Credit for any other payments may be delayed up to Address 2 five days. No payment shall operate as an accord and satisfaction without the prior written approval of one of our Senior Officers, City We process most payment checks electronically by using the information found on your check Each check authorizes us to create a one-time electronic funds transfer(or process it as a check or paper draft).Funds may be withdrawn from your account as soon as the same day State Zip we receive your payment Checks are not returned to you.For more information or to stop the electronic funds transfers,call us at the number listed on the front Area Code& If you have authorized us to pay your credit card bill automatically from your savings or Home Phone checking account with us,you can stop the payment on any amount you think is wrong.To stop payment,your letter must reach us at least three business days before the automatic payment is Area Code& scheduled to occur. Work Phone 1219 ugust - eptember 26, 2013 Page 3 of 4 Interest Charge Calculation Your Annual Percentage Rate(APR)is the annual interest rate on your account. Annual Promotional Promotional Promotional Balance Interest Percentage Transaction Offer ID Rate Until Subject to Charges by Rate Type Interest Transaction Rate Type Purchases 0.00% $0.00 $0.00 Balance Transfers 0.00% $0.00 $0.00 Direct Deposit and Check Cash 0.00 $0.00 $0.00 Advances Bank Cash Advances 0.00% $0.00 $0.00 1 i ■ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ��tv of'COW) , Jody S Smith Chief Deputy JUL_ 17 i' x; Richard W Stewart a 'i �r,i Solicitor )Ft ., sr l DUAL Portfolio Recorvery Associates, LLC Case Number vs. Erin E Dickinson 2014-3760 SHERIFF'S RETURN OF SERVICE 06/30/2014 03:30 PM- Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Charles Guthier, Husband, who accepted as"Adult Person in Charge"for Erin E Dickinson at 1091 Oyster Mill Road, East Pennsboro, Camp Hill, PA 17011. DAWN KELL, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, July 01, 2014 RONR ANDERSON, SHERIFF ict Cv.. ui;e Sh?,!ff,Tielrosoft I?c. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff FILED-OFFICi THE PROTHONOARY 20111 OCT I 0 PM 2: 28 CUMBERLAND COUNTY 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. ERIN E DICKINSON 1091 OYSTER MILL RD CAMP HILL PA 17011 No. 2014-3760 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above -entitled case as discontinued without prejudice. ul 16-02422 obert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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 Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 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. ERIN E DICKINSON 1091 OYSTER MILL RD CAMP HILL PA 17011 Defendant : No. 2014-3760 CERTIFICA1E OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon ERIN E DICKINSON, by First Class Mail, Postage Pre -Paid, a copy thereof on this 16-02422 , 2014, to: ERIN E DICKINSON, 1091 OYST ILL R, CA PA 17011 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 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.