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HomeMy WebLinkAbout14-4022 Supreme Com-of Pennsylvania X' CourtA f Common Pleas j,� �- �1 For Prothonotary Use Only: '1'1NILSTAMI' Ci 4&Ve s' et Docket No: (4 N r", CUMBE .County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the lin and set-vice ofpleadings oi-other o 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 Def'endant's Name: ,r PORTFOLIO RECOVERY ASSOCIATES,LLC CARRISA A DELOSSANTOS O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Checkone) outside arbitration limits A Is this a Class Action Suit? ❑Yes ® No Is this an MDJAppeal? ❑Yes ®No Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you 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 indude 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 Inability ❑ 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: 0 MASS TORT N ❑ Asbestos ❑ Tobacco E] ToTort-DES REAL PROPERTY MISCELLANEOUS B El Tordc Tort-Implant C] Ejectment ❑ Common Law/Statutory Arbitration F-1 Toxic Waste E] Eminent Domain/Condemnation El Declaratory Judgment ❑ Other: E] Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warr-anto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: a` 16-16178 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#3.12686 �; ;r,' vt Portfolio Recovery Associates, LLC t' i/J Otr C 120 Corporate Blvd €t � � r ' n Norfolk, VA 23502 �t TELE: 1-866-428-8102 CU�lt3ERL A h,,o FAX: (757) 518-0860 PENt4 S YL VA i�Co T( Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD /\ n-11 v� NORFOLK, VA 23502 :. No. Plaintiff, V. CARRISA A DELOSSANTOS 316 BLACKLATCH IN 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 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 16-16178 OJtJ This communication is from a debt collector and is an attempt to collect a debt 3d g r S 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 CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. CARRISA A DELOSSANTOS 316 BLACKLATCH IN CAMP HILL PA 17011 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 16-16178 Esta coMunicacion es de un cobrador de deudas y es un intent do cobrar Lu-1a deuda. Cualquier>Aroniacion 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 THE COURT OF COMMON PLEAS OF CUMBERLAND CO Y, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. CARRISA A DELOSSANTOS 316 BLACKLATCH LN CAMP HILL PA 17011 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, CARRISA A DELOSSANTOS, is an adult individual with last known address of 316 BLACKLATCH LN, CAMP HILL PA 17011. 3. It is averred that Defendant wasindebted to CITIBANK, N.A. /THE HOME DEPOT - EXPO on July 20, 1992 with account number ************5142 (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. `1"leis coirn-iltunication is from a debt collector and is an.attempt to collect a debt. Any inforirkation obtained will be i sed 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 August 3, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBAN& N.A. /THE HOME DEPOT - EXPO 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$3,438.03. 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, CARRISA A DELOSSANT , in the amount of$3,438.0 , s costs of this action and any other relief as the Court deems ' st an reasonable. Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-16178 'T'llis c0nII-1I ulication is from a debt collector and is an attempt to collect a debt. Any infol7nation obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Larry E. Whitaker 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: a` —�Q� By: Larry E. Whitaker Custodian of Records 16-16178 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. • WractID:PRITHIMM082213 Document ID: 121013PRITH 1 MMB I 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 SHOP s myhomedepotaccount.com PO Box 790328 St Louis MO 63179 ANY TIME, �� Account Inquiries: 4 u �. ; ANYWHERE! ONLINE MOBILE IN STORE 1-866-458-7883 "�lCct�ltlnt�NtSIa@' & Summary of Account Activity Payment Information Previous Balance $3,438.03 New Balance $3,438.03 Payments -$0.00 Minimum Payment Due $908.00 Other Credits -$0.00 Payment Due Date April 5,2013 Purchases +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$0.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$0.00 Minimum Payment Warning: If you make only the minimum payment each New Balance $3,438.03 period,you will pay more in interest and it will take you longer to pay off your Past Due Amount $873.00 balance For example k ^It■py�}�., �,r��S *T ...........'Rt13 Credit Limit $3,700.00ca Available Credit $0.00 Only the minimum payment 16 years $3,438 Statement Closing Date 03/08/2013 $96 3 years $3,438 Next Statement Closing Date 04/08/2013 (Savings=$o) Das in Billing Cycle 30 If you would like information about credit counseling services,call 1-877-337-8188. Your minimum payment due is$908.00.To avoidS YE STAMPS, Register now for Paperless interest charges,pay$3,438.03 by April 5,2013. % TIME.- Statements and more at Af4O TREES! rrtyhorne+depotaccount,com TRANSACTIONS Trans Date Description Reference# Amount FEES TOTAL FEES FOR THIS PERIOD $ 0.00 INTEREST CHARGED TOTAL INTEREST FOR THIS PERIOD $ 0.00 Awna PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4 Page 1 of 4 This Account is Issued by Citibank,N.A. y Please detach and return lower portion with your payment to insure proper credit. Retain upper portion for your-records- y Your Account Number is -5142 P.O. Box 790393 ®;r` St. Louis, MO 63179 Payment Due Date April 05,2013 New Balance $3,438.03 Past Due Amountt $873.00 Minimum Payment Due $908.00 Statement Enclosed '�►rrwurrf�rti:losed ,�, x tPast Due Amount is included in the Minimum Payment Due Print address changes on the reverse side Make Checks Payable to HOME DEPOT CREDIT SERVICES CARRISA A DELOSSANTOS PO BOX 182676 316 BLACKLATCH LN COLUMBUS,OH 43218-2676 CAMP HILL,PA 17011-8412 5142 Information About Your Account. Proper Form.For a payment sent by mail or courier to be in proper form, Haw to Avoid Paying Interest on Purchases.Your payment due date you must: is at least 25 days after the close of each billing cycle.We will not charge Enclose a valid check or money order made payable to Home Depot you any interest on purchases if you pay your New Balance by the Credit Services.No cash,gift cards,or foreign currency please. payment due date each month.This is called a grace period on purchases. Include your name and account number on the front of your check If you do not pay the New Balance in full by the payment due date,you or money order. will not get a grace period on purchases until you pay the New Balance in If you send an eligible check with this payment coupon,you authorize full for two billing cycles in a row. us to complete your payment by electronic debit.if we do,the If you have a balance subject to a deferred interest or 0%APR promotion checking account will be debited In the amount on the check.We and that promotion does not expire before the payment due date,that may do this as soon as the day we receive the check.Also,the check balance(the"excluded balance")is excluded from the amount you will be destroyed. must pay in full to get a grace period.However,you must still pay any separately required payment on the excluded balance.In billing cycles Copy Fee.We charge .We add the fee for each copy of a billing statement that dates back 3 months We in which payments are allocated to deferred interest balances first,the a balance of our choosing. deferred interest balance will be reduced before any other balance on the reserve the rigghtt more.to add this fee to balances subject to a higher annual account.However,you will continue to get a grace period on purchases so percentage rate. waive the fee if your request for the copy relates long as you pay the New Balance less any excluded balances in full by the to a billing error orr disputed purchase. payment due date each billing cycle.We may refer to deferred interest Payment Options Other Than Regular Mail. prornotions as No interest promotions. Online Payments.Visit myhornedepotaccount.cam and sign up for In addition,certain promotional offers may take away the grace period on free online payments.Enrollment may take a few days.If we.receive purchases.Other promotional offers not described above may also allow your request to make an online payment by 5 p.m.Eastern time,we you to have a grace period on purchases without having to pay will credit your payment as of that day and it will post within three all or a portion of the promotional balance by the payment due date. business days.if we receive your request to make an online payrnent If either is the case,the promotional offer will describe what happens. after that time,we will credit your payment as of the next day and it How We Calculate Your Balance Subject to Interest Rate.For each will post within three business days.For security reasons,you may be balance,the letter following the Annual Percentage Rate in the Interest unable to pay your entire New Balance with your first online payrnent. Charge Calculation section on the front of the statement indicates the AutoPay Service.If you are enrolled in this service,your payment method we use to calculate interest charges.For Methods C,H and M, amount will be deducted automatically each month on your due date we use a daily balance method(including current transactions)to from the bank account you select. calculate interest charges.For Methods I and L,we use an average Pay by Phone Service.You may use this service any time to make daily balance method(including current transactions)to calculate a payment by phone,if your account is eligible.You will be charged interest charges.For Method K,we use an average daily balance method $14.95 to use this service if a representative of ours helps expedite (excluding current transactions)to calculate interest charges.To find your payment.Call by 5 p.m.Eastern time to have your payment out more information about the balance computation method that credited as of that day and posted within three business days.If you applies to your account and how the resulting interest charges were call after that time,your payment will be credited as of the next day determined,contact us at Customer Service number on the front, and posted within three business days.We may process your payment Important Payment Instructions. electronically after we verity your identity. Right to Prepay Your Account.You may pay all or part of your account Express Payments.You can send payment by courier or express balance at any time.However,you must pay,by the payment due date,at mail to the Express Payments Address.This address is:Customer least the minimum payrnent due. Service Center,Attention:Payment Mail Opening,1500 Boltonfield St., Crediting Payments.If we receive your mailed payment in proper form Columbus,OH 43228.Payment must be received in proper form at theproper address by 5 p.m.Eastern time to be credited as of that day. at our processing facility by 5 p.m.local time there,it will be credited as All payments received in proper form at the proper address after that of that day.A payment received there in proper form after that time will time will be credited as of the next day. be credited as of the next day.Allow 5 to 7 days for payments by regular In-Store Payments.For your added convenience,payments can be mail to reach us.There may be a delay of up to 5 days in crediting a made at The Home Depot"stores,with no service fee.Any payment payment we receive that is not in proper form or is not sent to the correct irr proper form accepted in-store will be credited as of that day. address.The correct address for regular mail is the address on the front However,credit availability may be subject to verification of funds. of the payment coupon.The correct address for courier or express mail is the Express Payments Address in the Express Payments section. PLEASE SEE.IMPORTANT INFORMATION ON PAGE 4 HD-2 JAN13 Page 2 of 4 Change of Address Print address changes in blue or black ink. I %=:E Register now for Paperless Statements and more at fnyhomedepotaccount.co Account: **** ''`** **** 5142 �4.�''aYr„r,�`+:i k'.'.'�,,. Yh.�x=.w acv,. a.„- .w ry n, .x.7hi",� � ...�^•a' t �:.: Total Fees Charged in 2013 $70.00 Total Interest Charged in 2013 $131.56 INTEREST CHARGE CALCULATIONYour Annual Percentage Rate(APR is the annual}interest trate on your account. PURCHASES Revolving Balance 25.99% M $0.00 $0.00 MAJOR PURCHASE PLAN 17.99% M $0.00 $0.00 Page 3 of 4 Credit Reporting Disputes.If you think we reported inaccurate After we finish our investigation,one of two things will happen: information to a credit bureau write us at the Customer Service address If we made a mistake:You will not have to pay the amount in question shown on Page 1. or arty interest or other fees related to that amount. Report a Lost or Stolen Card Immediately.Call the Account Inquiries If we do not believe there was a mistake,You will have to pay the number shown on Page 1- amount in question,along with applicable interest and fees.We will What To Do If You Find A Mistake On Your Statement send you a statement of the amount you owe and the date payrnent If you think there is an error on your statement,write to us at the is due.We may then report you as delinquent if you do not pay the address for billing inquiries and correspondence shown on Page 1 amount we think you owe. of your statement. if you receive our explanation but still believe your bill is wrong,you In your letter,give us the following information: must write to us within 10 days telling us that you still refuse to pay. If you do so,we cannot report you as delinquent without also reporting • Account information:Your name and account number. that you are questioning your bill.We must tell you the name of Dollar amount:The dollar amount of the suspected error. anyone to whom we reported you as delinquent,and we must let those • Description of problem:If you think there is an error on your bill, organizations know when the matter has been settled between us. describe what you believe is wrong and why you believe it is a mistake. If we do not follow all of the rules above,,you do not have to pay the You must contact us: first$50 of the amount you question even if your bill is correct, . • Within 60 days after the error appeared on your statement, Your Rights if You Are Dissatisfied With Your Credit Card Purchases At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goads or services that you have purchased if you want to stop payment on the amount you think is wrong. with your credit card,and you have tried in good faith to correct the You must notify us of any potential errors in writing.You may call us, problem with the merchant,you may have the right not to pay the but if you do we are not required to investigate any potential errors and remaining amount due on the purchase. you may have to pay the amount in question. To use this right,all of the following must be true: What WIII_Hapien_After We Receive Your Letter 1. The purchase must have been made in your home state or within 100 When we receive your letter,we must da two things: miles of your current mailing address,anis the purchase price must have been more than sed (Note:Neither of these are necessary if 1. Within 30 days of receiving your letter,we must tell you that your purchase was based t an advertisement or mailed to you,or we received your letter-We will also tell you if we have already if we own the company that Sold you the goods or services.) corrected the error. 2.Within 90 days of receiving your letter,we must either correct 2.You must have used your credit card for the purchase.Purchases the error or explain to you why we believe the bill is correct. made with cash advances from an ATM or with a check That accesses your credit card account do not qualify. While we investigate whether or not there has been an error: 3.You must not yet have fully paid for the purchase. We cannot try to collect the amount in question, If all of the criteria above are met and you are still dissatisfied with the or report you as delinquent on that arnount. The charge in question may remain on our statement, purchase,contact o in writing at the of your ressstat for billing inquiries and 9 Y Y correspondence shown on Page 1 of your statement, and we may continue to charge you interest on that amount. While we investigate,the same rules apply to the disputed amount as While you do not have to pay the amount in question, discussed above.After we finish our investigation,we will tell you our you are responsible for the remainder of your balance. decision.At that point,if we think you owe an amount and you do not We can apply any unpaid amount against your credit limit. 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 optional 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. T02918-9196.0401.0001-1-15-D--07/01/92-65-216-F--0--7-8-0-NOPLAY--02/08/12-E14B-February 6,2013-0-0 N--- PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 HD-4.1AN13 Page 4 of 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED -OFFICE SheriffOF THE PROTHONOTARY � a�t�,t!, at .atiorrl����� Jody S Smith 21114 JUL 31 MI 3: 37 Chief Deputy` Richard W Stewart -»" CUMBERLAND COUNTY Solicitor OFFICE OF THE S1fERIFF PENNSYLVANIA Portfolio Recovery Associates, LLC vs. Carrisa A Delossantos Case Number 2014-4022 SHERIFF'S RETURN OF SERVICE 07/11/2014 05:39 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: Carrisa A Delossantos, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 316 Blacklatch Lane, Lower Allen, Camp Hill, PA 17011. Residence appears to be vacant and per the Camp Hill Postmaster the defendant now resides at 8503 E. Woodcove Drive, Apt. 225, Anaheim, CA 92808-1267. SHERIFF COST: $44.95 SO ANSWERS, July 28, 2014 RONM' R ANDERSON, SHERIFF (c) CounlySuile Sheriff, Teleosoft. Inc. CaNiie 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. No. 14-4022 CARRISA A DELOSSANTOS 316 BLACKLATCH LN CAMP HILL PA 17011 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above -entitled case as discontinued without prejudice. 16-16178 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. CARRISA A DELOSSANTOS 316 BLACKLATCH LN CAMP HILL PA 17011 Defendant : No. 14-4022 CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue up ARRIS . DEL SSANTOS, by First Class Mail, Postage Pre -Paid, a copy thereof on this day • f L , 2014,.to: 16-16178 CARRISA A DELOSSANTOS, 316 BLAC . TC . LN, CAMP HILL 11 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.