HomeMy WebLinkAbout14-4019 Supreme Court;o f ennsylvania
Court-of Common Pleas
t V f- � � For Prothonotary U.se Only: TrMLSTAMP
1VII
C �COVertj et Docket No•
CvN i '
,County �
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing 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 from Another Jurisdiction ❑Declaration of Taking
Lead Plaintiffs Name: Lead Defendant's Name:
,I
PORTFOLIO RECOVERY ASSOCIATES,LLC ANDREW LINN
I
O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits
N (Check one) outside arbitration limits
A Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ® No
Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carne Brown/Mark R Garvey
❑ Check here if you haw 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
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 Flections
❑ 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 REAL PROPERTY MISCELLANEOUS
❑ To)dc Tort-DES
B ❑ To)dc Tort-Implant El Ejectment ❑ Common Law/Statutory Arbitration
❑ To)dc 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:
16-13033
Robert N. Polas, Jr., Esquire PA Bar#201259
! Carrie Brown, Esquire PA Bar#94055
Mark R Garvey, Esquire PA Bar#312686 OF Tta l f - �c— ^c
Portfolio Recovery Associates, LLC `c 0
1 d
.20 Corporate Blvd JU `
Norfolk, VA 23502 8 rNorvfl rA,�;.
P11 1
TELE: 1-866-428-8102 CtJN'3E8C A NO ��
Attorneys for Plaintiff 860 PEAS Y��A N/A
A�{
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA
CBAL ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC _
120 CORPORATE BLVD
NORFOLK, VA 23502 NO
Plaintiff,
V.
ANDREW LINN
107 IRONSTONE RD
NEW CUMBERLAND PA 17070
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
AWYERIF 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
16-13033
auk 5
This communication is from a debt collector and is an attempt to collect a debt. �� O
Any information obtained will be used for that purpose.
Robert N. Polas, Jr., Esquire PA Bar#201259
y 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.
ANDREW LINN
107 IRONSTONE RD
NEW CUMBERLAND PA 17070
Demandado.
NOTICIA
LISTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demandapuestas
en ]as 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
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
16-13033
Esta corn micacion es de un cobrador de deudas y es un intent do cobrar cora deuda.
Cualquier infrornacion 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 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.
ANDREW LINN
107 IRONSTONE RD
NEW CUMBERLAND PA 17070
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, ANDREW LINN, is an adult individual with last known address of 107
IRONSTONE RD, NEW CUMBERLAND PA 17070.
3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/CARE CREDIT on
January 21, 2008 with account number ************8625 (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 corm -w1cation is fi-orn a debt collector and .is an.attempt to collect a debt.
Any infoi7nation 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 March 8, 2013.
8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/
CARE CREDIT 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$1,806.48.
10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to
refuse to pay all sums due and owing on the aforementioned Account, all to the damage and
detriment of the Plaintiff.
11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration.
WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of
Plaintiff and against Defendant, ANDREW LINN,Earrie
of ,8;Esquire,
lus costs is action
and any other relief as the Court deems just and re
A Brown, #94055
Robert N. Polas, Jr., Esquire, #201259
Mark R Garvey, Esquire, #312686
Attorneys for Plaintiff
16-13033
This coirnntmication is fi-oin a debt collector and is an attempt to collect a debt:.
Any inforination obtained will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates, LLC,
Crl$Una Pabmn 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 fals' tion to authorities.
MAY 292014 '
Date: By:
Z^
Patterson
Custodian of Records
16-13033
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
r
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.
C rt
Gf rap !as
BILL of SALE
PRA PSCC Fresh--November 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 9°i:day of July,201:3 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"},S:eller.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 Huger on
November 19 2013,:and_as further described in the Agreement.: .
GE Ca ital.RetailBank Monogram Credit Services; h.L.C:.
By By:
Ken Wojcik . Attorne in Fae
J y' Wojcik:
'I'itie: EVP Collections&Recovery. Date: -
Date•
RFS:Holding,L.L.0
General Electric Ca pi al Corporation By:
Attorn
eyinFact n'UVojcik
Attorney_in Fact._ Wojcik Date: t ( • ( �
Date:
GEM Holding,L.L:C . :
GEMB Lending,Inc. .
ac
Attorney F t Wojcik.
By:
Attorney in Fact n:Wojcik . 'Date:
-r
UO
Date:
Portfolio Recovery.Associates LLC:
CARECREDIT/GECRB Cardholder Name: G 1
Aceount Number: 625
GE Capital Retail Bank Statement Closing
+a►a,r,r�lr
Previous Balance $1,771.48 New Balance $0.00 /
+ New Purchases SO.00 Taal Minimum Payment Due $657.00
Payments $0,00 Payment Due Date 10/11/2013
+/- Credits,Fees&Adjustments(net) $7,771.48- PAYMENT DUEBY 5 P.M.EASTERN ON THE DUE DATE.
+/- Interest Char net 50.00 Wemayconvert your payment into an electronic debit. See
NewBalance S0.00 reverse side.
Credit Limit $1,500.00
AvnilableCredit 30.00 Late Payment Warning: If we do not receive your Total
Days in Billing Period 29 Minimum Payment Due by the Payment Due Date listed above,
you may have to pay a late fee up to$35.00.
Pay online for free at:gogecapital.com
Fo(GE Capital Retail Bank customer service or to report
your card lost or stolen,=11 1-8658937864.
Best times to call aro Wednesday-Friday.
tbiA ++++�+4+i+�+i+++++�+i+�+�+ft++++4+•+i+++++++�+�+++++lit++•
Tran Date Post Date Reference Number Description Amount
10/09/2013 10/09/2013 F907200S000999990 CHARGE OFF ACCOUNT-PRINCIPALS $949.82 CR
10/09/2013 10/09/2013 CHARGE OFF ACCOUNT-FINANCE $85666CR
CHARGES-
FEES
IOM312013 10/03/2013 LATE FEE $35.00
TOTAL FEES FOR THISPERIOD $35.00
INTEREST CHARGED
10/09/2013 10/09/2013 INTEREST CHARGE ON PURCHASES $0.00
TOTAL INTEREST FORTHISPERIOD $0.00
tttt4tst4tiuF54'F.l4.,ltfkltltk +iti+it�+t+
Total Fees Charged in 2013 $350.00
Total Interest Charged in 2013 $;03.30
Total Interest Paid in 2013 $170.01
Expiration Date Annual . Balance Subject to Interest Charge
Type of Balance Percentage Interest Rate
Rate(APR)
Purchases NA 26.99 v $0.00 $0.00
(v)=Variable rate
o tttttftttfttttttttttttttttt4t4t4tttttttttttttttttttt
In order to protect youraccount privacy,we are unable to provide account information to anyone other than the cardholder(s)or
an authorized party.If you wish to permit us to speak to an authorized party such as a spouse about your amount,please send
' written authorization to the Qneml In 'ries address
*NOTICE: &e reverse side andadditional pages(if any)for important information concemingyour account.
5302 DFH 1 3 8 131009 2x PAGE I of 1 9072 1800 xA08 OIEJ5302
Pay online at gogecapital.com orenclose this coupon with your check.Please use Woe or black ink.
4.
Payment Enclosed: $ .... . ..
. New address ore-mail? Payment due includes$0.00 past due.Please pay the past due amount PROMPTLY.
Check the box at left and
print changes on back
ANDREW G LINK TTFDTFDTFFFFFTFDATA TTDDFDDAFDTAFAFAFD FTAA FADDDTADTAATA DTTAFDTFFDF
183 FISHER RD k 2
ETTERSPA 17319-9318 Make Paymemto: GE CAPITAL RETAIL BANK
PO BOK 960061
ORLANDO,FL 32896-0061
ADDAFTFAAADDTATAFAAAAFTTDADFTDFTDTDFDDTTADAADDA-DFAF•TAADTDAAADDTA
8 625■
Customer Service/Questions: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 maybe limited.You may also mail questions
(but not payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account number on any correspondence
you send to us.
Payments:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www.
gogecapital.com.
Overnight Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekivo Springs
Road,Longwood,FL 32779.
Notice:See below foryour Billing Rights and other important information.Telephoning about billing errors will not preserve
your rights underfederal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Orlando,
FL 32896-5035.
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
fundtronsferfromyouraccountorto processthe paymentasacheck transaction.When we use information from your check
to make an electronic fund transfer,funds may be withdrawn from your account as soon as the some day we receive your
payment and you will not receive your check back from your financial institution.You may choose nat to have your payment
collected electronically by sending your payment(with the remittance coupon),in your own envelope-not the enclosed
remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the payment address.
What To Do If You Think You Find A Mistake On Your Statement:
If you think there is an error on your statement,write to us at _
GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035.
In your letter give us the following information:
•Account information:Your name and account number
•Dollar amount:The dollar amount of the suspected error
•Description of problem:If you think there is an error on your bill,describe what you believe is wrong and why you be-
lieve it is a mistake.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing.You may call us,but if you do we are not required to investigate any
Potential errors and you may have to pay the amount in question.
While we investigate whether or not there has been an error,the following are true:
•We cannot try to collect the amount in question or report you as delinquent an 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.
Information About Payments:You may at anytime pay,in whole or in part,the total unpaid balance without any additional
charge for prepayment. Payments received after 5:00 PM(ET)on any day will be credited as of thenext day.Credit to your
account maybe delayed up to five days if payment(a)is not received at the payment address,ib)is not made in U.S.dollars
drawn on a U.S.financial institution located in the U.S.,(cl is not accompanied by the remittance coupon attached to your
statement,(d)contains more than one payment or remittance coupon,(e)is not received in the remittance envelope provided
or If)includes staples,paper clips,tape,a folded check or correspondence of any type.Conditional Pavmonts:All written -
communications concerning disputed amounts,including any check or other payment instrument that(1)indicates that the
payment constitutes"pa ment in full"oris tendered as full satisfaction of a disputed amount,or(til is tendered with other
conditions or limitations 1"Disputed Payments'),must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896-5035.
Credits to Your Account:An amount shown in parenthesis is a credit or credit balance unless otherwise indicated.Credits
will be applied to your previous balance immediately upon receipt,butwili not satisfy any required payment that may be due.
Credit.Reports and Account Information:Ifyou believe that we may have reported inaccurate information about you to a
consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL 32896-5036.In doing so,please identify the
inaccurate information and tell us why you believe it is incorrect.If you have o copy of the credit report that includes the inac-
curate information,please include a copy of that report.We may report information aboutyour account to credit bureaus.
Late payments,missed payments,or other defaults on your account may be reflected in your credit report.
How We Calculate Interest:We figure the interest charge on your account by applying the periodic rate to the"daily bal-
ance"of your account for each day in the billing cycle.We then add the interest to the daily balance. To get the"daily bal-
ance"we take the beginning balance of your account each day(which includes unpaid interest),add any new charges,and
applicable fees,and subtract any payments or credits.This gives us the daily balance.Any daily balance of less than zero will
be treated as zero.A separate daily balance will be calculated for each balance type on your account.The balance(s)shown
in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by
the number of days in the billing cycle.
Bankruptcy Notice:If you file bankruptcy you must send us notice,including account number and all information related to
the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell,GA 30076.
Your account Is owned and serviced by GE Capital Retail Bank.
Hearing Impaired:TDD users call 1-877-448-8512
Use of Information About You and Your Account:Our Privacy Policy describes our collection and disclosure of information
aboutyou and your Account.If you would like another copy of the Privacy Policy,please call us at the customer service tele-
phone number indicated on the frontof this statement. -
Thisis an attemptto collect a debtand any information obtained will be used forthat purpose.
OIEJ5302-12-03/05/12
By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of
your account contacting you about your account,including using any contact information orcell phone numbersyou provide,
and you consent to the use of any automatic telephone dialing system and/or an artificial or rerecorded voice when contact-
ing you,even if you are charged for the call under your phone plan.
For changes of address or phone number,please check the box and print the changes below. Retail EN-OlEJ5302
Name
❑ Street Address
City State Zip Code
Home Phone# Business Phone# Cell#or other phone#we can use to contact you Email Address
Remember,you can update the above information as well as your e-mail address online at www.gogecapital.com
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
r-1
THE 1-31:1'0 If/ONO-TA
2014 Alt 19 AN l f 1¢
,�
`' UNSER/.,r. ND
PFllf1SYLAit 1 il •T
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.
ANDREW LINN
107 IRONSTONE RD
NEW CUMBERLAND PA 17070-2708
Defendant
To the Prothonotary:
No. 14-4019 CIVIL
PRAECIPE TO DISCONTINUE
Please mark the above -entitled case as discontinued without prejudice.
16-13033
lly Submitted,
0,/
o ert N. Polas, Jr., Esquire PA Bar # 201259
Carrie Brown, Esquire PA Bar # 94055
Mark R. Garvey, Esquire PA Bar # 312686
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
Carrie A. Brown, Esquire
Robtrt 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.
ANDREW LINN
107 IRONSTONE RD
NEW CUMBERLAND PA 17070-2708
Defendant
: No. 14-4019 CIVIL
CERTIFICATE OF SERVICE
The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue
upon NDREW LINN, by First Class Mail, Postage Pre -Paid, a copy thereof on this
16-13033
, 2014, to:
day of
ANDREW LINN, 107 IRONSTONE RD, " UMBERL P 'A 17070-2708
obert 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.