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HomeMy WebLinkAbout14-3954 r - Supreme Court-,of�PenInsylvania Court,W Common Pleas 10, 1-/ �, ,s f h\ For Prothonotary Use Only: TIME STA MI' CIAO f-over,,Sheet Docket No: CUMBERIACoun I 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 JEAN A HAKE 1 O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A t a Class Action Suit? ❑Yes N 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 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 indude 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 ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ To)ac Waste ❑Eminent 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 LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: LN 16-16162 4 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 M PRO THO ` „ ,. 120 Corporate Blvd � �/`' Norfolk, VA 23502 t JUL 8 PN I.: + TELE: 1-866-428-8102 CU1't3r-n ( FAX:(757) 518-0860 PEN;�iSYL AtjlA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LA W PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD No. NORFOLK, VA 23502 Plaintiff, V. JEAN A HAKE 76 BEARD RD MECHANICSBURG PA 17050 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 � 16 3, 7 �/J 16-16162 n � lJ" C � a(d&q 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. : JEAN A HAKE 76 BEARD RD MECHANICSBURG PA 17050 Demandado. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta ]a 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 ]as demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service- CUMBERLAND County Bar Association Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)249-3166 16-16162 Esta conRmicacion es de un cobrador de deudas y es un intent do cobrar Luna deuda. Cualquier iniomacion 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 TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-.LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. JEAN A HAKE 76 BEARD RD MECHANICSBURG PA 17050 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, JEAN A HAKE, is an adult individual with last known address of 76 BEARD RD, MECHANICSBURG PA 17050. 3. It is averred that Defendant was indebted to CITIBANK, N.A. /THE HOME DEPOT on October 7, 2002 with account number ************1728 (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 cottnrnruication is frorn a debt collector and is an.attempt to collect a debt. Any information obtained will be used for that purpose. I �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 February 22, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. /THE HOME DEPOT 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$11,327.78. 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, JEAN A HAKE, in the ount o $11,327.78, plus costs of ' action and any other relief as the Court deems just and reas able. ie Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, #312686 Attorneys for Plaintiff 16-16162 This C01MIinaication is fi-orn 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, Cristina PaatDerson 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 fa ' c ion to authoritie . MAY 292014 Date: By: Cristna Patterson Custodian of Records 16-16162 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. . • *tract ID:PRITHIMM082213 Document ID: 121013PRITHIMMB 1 BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated December 27, 2013, is by Citibank,N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank") to Portfolio Recovery Associates, LLC ("Buyer"), organized under the laws of Delaware, with its headquarters/principal place of business at 130 Corporate Boulevard,Norfolk, VA 23502. For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated August 22, 2013, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns,the Accounts described in Exhibit 1 and the final electronic file. Citibank,N.A. By: (Signature) Name: Patricia Hall Title: Financial Account Manager PRA 082213.docx Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: HOME DEPOT CREDIT SERVICES myhomedepotaccount.com PO Box 790328,St.Louis,MO 63179 aAccount Inquiries: 1-866-458-7683CCi131t t��Jet�t 1728 Summary of Account Act"y Payrnent Information Previous Balance $11,259.16 New Balance $11.527.78 Payments -$0.00 Minimum Payment Due $2,670.00 Other Credits -$0.00 Payment Due Date December 18, 2012 Purchases +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$233.62 Minimum Payment Warning: If you make only the minimum payment each New Balance $11,527.78 period,you will pay more in interest and it will take you longer to pay off your Past Due Amount $2286.00 balance For example , �� s m ¢ x, I. SS�Ift1ri tttr� �4tf4 f f1F} 1orttlfpu� sl �, tlb;tm}`bouft etiiS►a r5 ! f�'j' Credit Limit $0.00 Available Credit $0.00 Only the minimum payment 31 years $29,559 Statement Closing Date 11/21/2012 $458 3 years $16,502 Next Statement Closing Date, 12/21/2012 (Savings=$13,057) Das in Billing Cycle 30 If you would like information about credit counseling services,call 1-877-337-8188. Your minimum payment due is$2,670.00.To avoid interest charges on your non-promotional(revolving)balance and any expiring promotions,pay $11,527.78 by December 18,2012.If you pay your non-promotional balance in full every month,no additional billed interest charges will apply. Interest accrues daily from your statement closing date until we receive your payment,so please check your next statement for any additional interest you may have incurred. We are here to support our customers affected by Hurricane Sandy. Above all, we hope you and your family are safe. If you have been impacted by the storm and need assistance, please call us at the customer service number listed on your statement. We will work to help with your individual needs during this challenging time. 8HD14 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page,1 of 4 This Account is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.T tPast Due Amount is included in the Minimum Payment Due. Xdu� oitrt hFgtiib%+t Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed DECEMBER 18,2012 $11,527.78 $2,286.00 $2,670.00 $ 9 k n4, 1728 Make Checks Payable to: HOME DEPOT CREDIT SERVICES PO BOX 182676 JEAN A HAKE COLUMBUS,OH 43218-2676 76 BEARD RD MECHANICSBURG,PA 17050-1644 Print address changes above in blue or black ink. Information About Your Account. How to Avoid Paying Interest on Purchases.Your payment due date Is at least 25 days after the What Wiil Happen After We Receive Your Lefler G16Se of each billing cycle.We will not charge}Fou any interest on purchases if you pay your New When we receive your letter,we must do two things: Balance by the payment due date each month.This is called a grace period on purchases.If you do 1.Within 30 days of receiving your letter.we must tell you that we received your letter.We will also not pay the New Balance in full by the payment due date,you will not get a grace period on purchases tali you if we have already corrected the error. until you pay the New Balance in full for two billing cycles in a row. If you have a balance subject fie a deferred interest or 0%APR promotion and that promotion does not 2.Within 90 days of receiving your letter.we must either correct the error or explain to you why we y. t l.7 believe the bill is correct. expire before the payment due date,that balance(the "excluded balanced) is excluded from the While we investigate whether or not there has been an error: amountyou must pay in full to get a grace period.However,you must still pay any separately requl red payment on the excluded balance. In billing cycles in which payments are allocated to deferred •We cannot try to collect the amount in question,or report you as delinquent on that amount. interest balances first,the deferred interest balance will be reduced before any other balance on the •The charge In question may remain on your staterneriL and we may continue to charge you interest account.However,you will continue toget a grace period on purchases so long as you pay the New on that amount. Balance less any excluded balances in full by the payment due date each billing cycle. 'e may refer •While you do not have to pay the amount In question,you are responsible for the remainder of to deferred interest promotions as No Interest promotions, your balance. In addition, certain promotional offers may take away the grace period on purchases. Other •We can apply any unpaid amount against your credit limit, promotlonai offers not described above may also allow you to have a grace period on purchases After we finish our investigation,one of two things viii happen: without having to pay all ora portion of the promotional balance by the pay,nr nt due date,if either is •it we made a mistake:You will not have to pay the amount in question of any interest or other fees the case,the promotional offer viii describe what happens. related to that amount Now We Calculate Your Balance Subject to Interest Rate. For each balance,the letter •fj we do not believe there was a mistake:You will have to pay the amount in question,along with following the Annual Percentage Rate in the Interest Charge Calculation section on the front of the applicable interest and fees.We will send you a statement of the amount you rave and the date statement indicates the method we use to calculate interest charges.For Methods C,H and M,we use payment is due.We may then report you as delinquent if you do not pay the amount we think you on, a daily balance method(including current transactions)to calculate interest charges.For Methods 1 and L,we use an average daily balance method(including current transactions)to calculate interest If You receive our explanation but still believe your bill is wrong,you must write to us within 10 days charges.For Method K,we use an average daily balance method(excluding current transactions)to telling us that you still refuse to pay.If you do so,we cannot report you as delinquent without also calculate interest charges.To find out more information about the balance computation method that reporting thatyou are questioning your bill.We must tell you the name of anyone to whom we reported applies to your account and how the resulting interest charges were determined, contact us atyyou as delinquent,and we must let those organizations know when the matter has been settled Customer Service number on the front, t€etween us. Credit Reporting Disputes.If you think we reported inaccurate information to a cmdit bureau write If we do riot follow all of the rules above,you do not have to pay the first$50 of the amount you us at the Customer Service address shown on the front. question even it your bili is correct. Report a Lost or Stolen Card Immediately. Call.the Account Inquiries number shown on Your Rights YYou Are B14mfisfled With Your Cmd1tCar#Purchases the front. If you are dissatisfied with the goods or services that you have purchased with your credit card,and What To Do ff You FindA Mistake On Your Statement you have tried in good faith to correct the problem with the merchant,you may have the right not to If you think there is an error on your statement,write to us at the address for billing inquiries and pay the remaining amount due on the purchase. correspondence shown on the front of your statement. To use this right,all of the following must be true: In your letter,give us the following Information: 1.The purchase must have been made in your home state or within 100 miles ofour current +Account information:Your name and account number. mailing address,and the purchase price must have been more than$50.(Note:Neither of these •Doilaramount.The dollar amount of the suspected error. are necessary If your purchase was based on an advertisement we mailed to you,or if we own the •(Description ofprobiem:If you think there is an error on your bill,describe what you believe fs wrong company that sold you the goods or services.) and why you believe it is a mistake. 2.You must have used your credit card for the purchase.Purchases made with cash advances from You must contact us: an ATM or with a check that accesses your credit card account do not quality. Within 60 days after the error appeared on your statement. 3.You must not yet have fatly paid for the purchase. •At least 3 business days before an automated payment is scheduled,it you want to stop payment on the amount you think is wrong. If all of the criteria above are met and you are still dissatisfied with the purchase,contact us in writing You must notify us of any potential errors in wrifing.You may call us,bit if you do we are not required at the address for billing Inquiries and correspondence shown on the front of your statement.- to tatement:to investigate any potential errors and you may have to pay the amount in question. While we investigate,the same rules apply to the disputed amount as discussed above,After we finish our investigation,we will fell you our decision.At that point,if we think you owe an amount and you do not pay,we may report you as delinquent. KEY CREDIT TERMS—NO INTEREST IF PAID IN FULL WITHIN 6 MONTHS".$299 minimum purchase required.Minimum payments required.Interest will be charged to your account from the purchase date If the purchase balance(including premiums for options[credit insurance)is not paid in full within 6 months or if you make a late payment. With credit approval for qualifying purchases made on The Home Depot or EXPO Design Center Consumer Credit Card,17.99%-26.99%APR.Minimum interest charge:$2.See card agreement for details including APR applicable to you.Offer is only valid for consumer accounts and is subject to change without notice. Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance at any time. •Online Payments. Visit mytromedepotaccount.com and sign up for free online payments. However,you must pay,by the payment due date,at least the minimum payment due. Enrollment may take a few days,if we receive your request to make an online payment by 5p.m. Crediting Payments.ft we recelve your mailed payment in proper form at our processing facility by Eastern time,we will credit your payment as of that day and!twill post within three business days. 5 p.m.local time there,it will be credited as of that day.A payment received there in proper form after 'If we receive your request to make an online payment after that time,we will credit your payment as that time will be credited as of the next day.Allow 5 to 7 days for payments by regular[nail to reach of the next day and li will post within three business days.For security reasons,you may be unable us.There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form to pay your entire New Balance with your first online payment. or is not sent to the correct address.The correct address for regular mail is the address on the front of •AutaPay Service. If you are enrolled in this service,your payment amount will be deducted the payment coupon.The correct address for courier or express mail is the Express Payments Address automatically each month on your due date from the bank account you select. shown below. Proper Form.For a payment sent by mail or courier to be in proper form,you must: •Pay by Phone Service.You may use this service any time to make a payment by phone,If your account is eligible.You will be charged$14.95 to use this service It a representative of ours helps • Enclose a valid check or money order made payable to Home Repot Credit Services.No cash, expedite your payment.Call by 5 p.m.Eastern time to have your payment credited as of that day and gift cards,or foreign currency please. posted within three business days.If you call after that time,your payment will be credited as of the • Include your name and account number on the front of your check or money order. next day and posted within three business days.We may process your payment electronically after If you send an eligible check with this payment can on,you authorize us to complete we verily your identity, your payment by electronic debit.If we do,the checking account will be debited in the •Express Payments.You can send payment by courier or express mail to the Express Payments amount on the check.We may do this as soon as the day we receive the check.Also, Address. This address is: Customer Service Center, Attention: Payment Mail Opening, 1500 the check will be destroyed. Boitonfield St„Columbus,OH 43228.Payment must be received In proper form at theproper Copy Fee.We charge$5 for each copy of a billing statement that dates back 3 months or mare.We address by 5 p.m.Eastern time to be credited as of that day.All payments received in proper format add the fee to a balance of our choosing.We reserve the right to add this fee to balances subject to a the proper address after that time will be credited as of the next day. higher annual percentage rate.We waive the tee if your request for the copy relates to a billing error or •In-Stere Payments.For your added convenience,payments can be made at The Home Doto disputed purchase. stares,with no service fee.Any payment in proper form accepted In-store will be credited as That ray.However,credit availability may be subject to verification of funds. T02354-9196-0400-0001-E-0-X--10/01/02-28-113-P--0--7-8-0-NOPLAY--06/22/12-H178-October 22,2012-0-0 N--- HO/EXJUL12 Page 2 of 4 Account: **** **** *** 1728 TRANSACTIONS Trans Date Description Reference# Amount FEES 11/18 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 36.00 INTEREST CHARGED 11/21 INTEREST CHARGE ON PURCHASES $ 233.62 TOTAL INTEREST FOR THIS PERIOD $ 233.62 - Total Fees Charged in 2012 $350,00 Total Interest Charged in 2012 $2,773.76 INTEREST CHARGE CALCULATION � � uY� Your Annual Percentage Rate(APR is the annual interest rate on your account� r ...�' b _ .Fx _ fir ��,�iG 1# LF�t�F,�#'itai _5�_� iY `� `� �1` 1�' >`�� . ft►.. . .Oita, +2 PURCHASES Revolving Balance 25.99% M $8,527.20 $182.14 MAJOR PURCHASE PLAN 21.99% M $2,849.09 $51.48 Page 3 of 4 Account: **** **** **** 1728 Page 4 of 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ FILED -C ` lG Sheriff . ! HE PROTtIONO Ti".h; Jody S Smith Chief Deputy Richard W Stewart Solicitor ' of Coin 2014 JUL 31 AM IO 38 OFFICE OFTHE SI";RIFF CU PENNSYLVAN AT Y Portfolio Recorvery Associates, LLC vs. Jean A Hake Case Number 2014-3954 SHERIFF'S RETURN OF SERVICE 07/21/2014 07:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Jean A Hake at 76 Beard Road, Silver Spring, Mechanicsburg, PA 17050. DAWN KELL, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, July 22, 2014 (c) CountySuite Sheriff, Teleosoft, RONIVR ANDERSON, SHERIFF