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HomeMy WebLinkAbout14-4274 Supreme Court of Pennsylvania Court of Common Fleas For Prothonotary Use Only: Civil Cover Sheet Docket Na: � l Cumberland County tr The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S r., E Lead Plaintiff's Name: Lead Defendant's Name: PAMELA YORK C PORTFOLIO RECOVERY ASSOCIATES LLC t" I Are money damages requested? ® Yes ❑No I Dollar Amount Requested: M within arbitration limits (CheclCone) ❑ outside arbitration limits (1) Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: S.yretta Martin,'Frank Janello, Beth Arnold Howell/Greg Dye ❑ Check here if you have no attorney(area Self-Represented [Pro Se] 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 A you consider most important., TORTido not include Mass Ton) CONTRACT(do not include Judgments)' i,CIVIL APPEALS ❑ Intentional Buyer Plaintiff ` Administrative Agencies ❑ Malicious Prosecution Debt Collection: Credit Card �'❑ -Boaid of Assessment ❑ Motor Vehicle ❑ DW'Collecti6n: Othei '° ❑ Board of Elections ❑ Nuisance ❑-,Dept.of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability tdoes not include mass tort) ❑Employment Dispute: C ❑ Slander/Libel/Defamation Discrimination ` T ❑ Other: ❑Employment;Dispute: Other ❑ •Zoning Board ❑ Other: O N MASS TORT ❑:Ot�h'er: ; ❑ Asbestos ❑ Tobacco - B ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REALPROPERTY, • MISCELLANEOUS ❑ Toxic Waste El Ejectment I-] CommonLaw/Statutory Arbitration 13 Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment n'6round`Rent ❑ Mandamus ❑,Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin S ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: i ❑ Other Professional: I Updated 111120 2933815 PPTXCPRI(05/06/2014) 1111111111111 IN 111111111111111111111111111111111111111111111111111111111 j Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, 1835 Market Street, Suite 501 PORTFOLIO RECOVERY ASSOCIATES LLC Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC _ c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAtS'— 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, (J') r CIVIL ACTIONo C–rs VS. - Vic', No. ` PAMELA YORK / f 4 OCKER LN SHIPPENSBURG PA 17257 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 of 2933815 J l PPTNPRAI (04/24/2014) t 11111111111111 IN 111111111111111111111111111111111111111111111111111111111 AVISO Le han demandado a usted en la Corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 Attorneys For Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. PAMELA YORK 4 OCKER LN SHIPPENSBURG PA 17257 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(s), PAMELA YORK, is/are an adult individual with last known address of 4 OCKER LN SHIPPENSBURG PA 17257. 3. It is averred that Defendant(s) opened an account on 05-03-08 with account number XXXXXXXXXXXX9441 (hereafter referred to as "Account"). A copy of the charge-off statement is attached hereto and collectively marked as Exhibit "A". 4. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 2933815 PPTCPRAI (05/27/2014) 1111111111111 IIII 111111111111111111111111111111111111111111111111111111111 5. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 6. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 7. Defendants) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 02-21-2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest of CITIBANK N.A./TRACTOR SUPPLY and Plaintiff is now the holder of the Account. A true and correct copy of Plaintiff's Verification is attached hereto. 9. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $5273.26. 10. Despite reasonable and repeated demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) PAMELA YORK, in the amount of $5273.26, plus costs of this action and any other relief as the Court deems just and reasonable. Respectfully Submitt d, Dated: yretta Ma �n, Esq PA r #309370 Frank Janello, Esq. P)Vgar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 Attorneys For Plaintiff BHLM REF #: 2933815 VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Elonda Sherman 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. .SUN 2 7 2014 plonda Sherman Date: By: /& AnI UIJ Custodian of Records BHLM REF #: 2933815 PPTXPVRI (05/27/2014) Exhibit " A " 2933815 PPTXEXAI ( 04/17/2014 ) Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: T Customer Service: TRACTOR SUPPLY CREDIT PLAN tractorsupplypersorlal accountoninecorn PO Box 6403 Sioux Falls SD,57117-6403 Account Inquiries: rouPPLYCO. 1-888-316-8480 Accblitlt Ntri lbet' 944'x` Summa of Account Activit -Payrnent Information Previous Balance $5,235.20 New Balance $5,273.26 Payments -$0.00 Minimum Payment Due $747.00 Other Credits -$0.00 Payment Due Date May 21,2012 Purchases +$0.00 Cash Advances +$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 +$38.06 Minimum Payment Warning: If you make only the minimum payment each New Balance $5,273.26 period,you will pay more in interest and it will take you longer to pay off your balance For example Past Due Amount $622.00 If YOU make no a("§6nal,; Youw111 pay +ff the And:you wiN charges using this card balance shoWri:nn ttNs dnd iap'paytng an :and each:nlonth.yottpay .' �taf9rt1eht1n.abtsut .,. 9sttmatedfotaLot. Credit Limit $0.00 Only the minimum payment 4 years $6,207 Available Credit $0.00 $170 3 years $6,117 Statement Closing Date 04/24/2012 (Savings=$90) Next Statement Closing Date 05/25/2012 B you would like Information about credit counseling services,call 1-877-337-8188. Das in Billing Cycle 30 TRANSACTIONS Trans Date Description Reference# Amount FEES TOTAL FEES FOR THIS PERIOD $ 0.00 INTEREST CHARGED 04/24 INTEREST CHARGE ON PURCHASES $ 38.06 TOTAL INTEREST FOR THIS PERIOD $ 38.06 If you missed our call, we may still be able to help you bring your account current. When we call you about your account, we're calling with suggestions to help bring your account up to date.We may have payment programs you did not know about that can help you avoid future late fees. Please call us today at 1-866-676-5204. We'll be happy to help you find a solution that works for you. 8 TY 16 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account Is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- i +Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.+ WSUMNOX Make Checks Payable to: TRACTOR SUPPLY CREDIT PLAN f Past Due Amount is included in the Minimum Payment Due. your Account Nymber Payment Due Date New Balance Past Due Amountl Minimum Payment Due Amount Enclosed 9441 MAY 21,2012 $5,273.26 $622.00 $747.00 $ SAVE STAMPS TIME... AND TREES! Visit Account©mine and register now for Online Bill Pay, � Paperless Statements and More. 9441 TRACTOR SUPPLY CREDIT PLAN PO BOX 183015 PAMELA YORK COLUMBUS,OH 43218-3015 4 OCKER LN SHIPPENSBURG,PA 17257-9473 Print address changes above in blue or black ink. Information About Your Account. You must notify us of any potential errors in writing.You may call us,but if you do How to Avoid Paying Interest on Purchases.Your payment due date is at least we are not required to investigate any potential errors and you may have to pay 25 days after the close of each billing cycle. We will not charge you any interest on the amount in question. purchases if you pay your New Balance by the payment due date each month. What Will Happen After We Receive Your Letter This is called a grace period on purchases. If you do not pay the New Balance in When we receive your letter,we must do two things. full by the payment due date,you will not get a grace period on purchases until you pay the New Balance in full for two billing cycles in a row.We will begin 1. Within 30 days of receiving your letter,we must tell you that we received charging interest on cash advances(if available on your account)on the your letter.We will also tell you if we have already corrected the error. transaction date. 2.Within 90 days of receiving your letter,we must either correct the error or If you have a balance subject to a deferred interest or 0%APR promotion and that explain to you why we believe the bill is correct. promotion does not expire before the payment due date,that balance(the While we investigate whether or not there has been an error: excluded balance")is excluded from the amount you must pay in full to get a We cannot try to collect the amount in question,or report you as delinquent on grace period. In addition,if you have a major purchase plan,equal payment plan that amount, or budget purchase plan balance,that balance(the"excluded balance")is excluded The charge in question may remain on your statement,and we may from the amount you must pay in full to get a grace period.However,you must still continue to charge you interest on that amount. pay any separately required payment on the excluded balance. In billing cycles in While you do not have to pay the amount in question,you are responsible which payments are allocated to deferred interest balances first,the deferred for the remainder of your balance. interest balance will be reduced before any other balance on the account. We can apply any unpaid amount against your credit limit. However, you will continue to get a grace period on purchases so long as you pay the New Balance less any excluded balances in full by the payment due date each After we finish our investigation,one of two things will happen: billing cycle.We may refer to deferred interest promotions as No Interest or No If we made a mistake.You will not have to pay the amount in question or any Monthly Interest promotions. interest or other fees related to that amount. In addition,certain promotional offers may take away the grace period on If we do not believe there was a mistake.You will have to pay the amount purchases. Other promotional offers not described above may also allow you to in question,along with applicable interest and fees.We will send you a have a grace period on purchases without having to pay all or a portion of the statement of the amount you owe and the date payment is due.We may then promotional balance by the payment due date.If either is the case,the report you as delinquent if you do not pay the amount we think you owe. promotional offer will describe what happens. If you receive our explanation but still believe your bill is wrong,you must write to How We Calculate Your Balance Subject to Interest Rate.For each balance,the us within 10 days telling us that you still refuse to pay.If you do so,we cannot letter following the Annual Percentage Rate in the Interest Charge Calculation report you as delinquent without also reporting that you are questioning your bill. section on the front of the statement indicates the method we use to calculate We must tell you the name of anyone to whom we reported you as delinquent,and interest charges.For Methods B and E,we use an average daily balance method we must let those organizations know when the matter has been settled between (including current transactions)to calculate interest charges.For Methods C,D and us. M,we use a daily balance method(including current transactions)to calculate If we do not follow all of the rules above,you do not have to pay the first$50 of interest charges.To find out more information about the balance computation the amount you question even if your bill is correct. method that applies to your account and how the resulting interest charges were determined,contact us at the Account Inquiries number on the front. Your Rights If You Are Dissatisfied With Your Credit Card Purchases Credit Reporting Disputes.If you think we reported inaccurate information to a If you are dissatisfied with the goods or services that you have purchased with credit bureau write us at the Customer Service address shown on the front. your credit card,and you have tried in good faith to correct the problem with the Report a Lost or Stolen Card Immediately.Call the Account Inquiries number merchant,you may have the right not to pay the remaining amount due on the shown on the front. purchase. What To Do If You Find A Mistake On Your Statement To use this right,all of the following must be true: If you think there is an error on your statement,write to us at the address for 1. The purchase must have been made in your home state or within 100 billing inquiries and correspondence shown on the front of your statement. miles of your current mailing address,and the purchase price must have been more than$50.(Note:Neither of these are necessary if your In your letter,give us the following information: purchase was based on an advertisement we mailed to you,or if we own Account information:Your name and account number. the company that sold you the goods or services.) Dollar amount:The dollar amount of the suspected error. 2. You must have used your credit card for the purchase.Purchases made with Description of problem:If you think there is an error on your bill, cash advances from an ATM or with a check that accesses your credit card describe what you believe is wrong and why you believe it is a mistake. account do not qualify. You must contact us: 3. You must not yet have fully paid for the purchase. • Within 60 days after the error appeared on your statement. If all of the criteria above are met and you are still dissatisfied with the purchase, At least 3 business days before an automated payment is scheduled,if you contact us in writing at the address for billing inquiries and correspondence shown y y on the front of your statement. want to stop payment on the amount you think is wrong. While we investigate,the same rules apply to the disputed amount as discussed above.After we finish our investigation,we will tell you our decision.At that point, if we think you owe an amount and you do not pay, we may report you as delinquent. FMJ-Zales-TS-CH 12/I1 T01671-9194-0575-0001-E-37-D--05/01/08-70-000-P-B-0--5-8-0--02-02/24/12-TSCS-March 25,2012-0 N--- Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance In-store Payments(Where Available).Any payment in proper form at any time.However,you must pay,by the payment due date,at least the accepted in-store will be credited as of that day.However,credit minimum payment due. availability may be subject to verification of funds.Not all stores accept Crediting Payments. If we receive your payment in proper form at our processing Payments.Contact your local store to see if in-store payments are facility by 5 p.m.local time there,it will be credited as of that day.A payment accepted at that location. received there in proper form after that time will be credited as of the next day. Online Payments.Visit the web address on the front and sign up for Allow 5 to 7 days for payments by regular mail to reach us-There may be a delay online payments.Enrollment may take a few days. If we receive your of up to 5 days in crediting a payment we receive that is not in proper form or is request to make an online payment by 5 p.m.Eastern time,we will credit not sent to the correct address. The correct address for regular mail is the your payment as of that day.If we receive your request to make an online address on the front of the payment coupon. The correct address for courier or payment after that time,we will credit your payment as of the next day. express mail is the Express Payments Address shown below. For security reasons,you may be unable to pay your entire New Balance with your first online payment. 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 Enclose a valid check or money order.No cash,gift cards,or foreign payment by phone. You will be charged$14.95 if a representative of ours currency please. helps expedite your payment.Call by 5 p.m.Eastern time to have your Include your name and account number on the front of your check or payment credited as of that day.If you call after that time,your payment money order. will be credited as of the next day.We may process your payment If you send an eligible check with this payment coupon,you authorize us to electronically after we verify your identity. complete your payment by electronic debit.If we do,the checking account will Express Payments.You can send payment by courier or express mail to be debited in the amount on the check. We may do this as soon as the day we the Express Payments Address.This address is:Payments Department, receive the check. Also,the check will be destroyed 1500 Boltonfield Street,Columbus,OH 43228.Payment must be Copy Fee We charge$5 for each copy of a billing statement that dates back 3 received in proper form at the proper address by 5 p.m.Eastern time to be credited as of that day.All payments received in proper form at the proper months or more. We add the fee to the regular purchase balance.We waive the fee if your request for the copy relates to a billing error or disputed purchase. address after that time will be credited as of the next day. Page 2 of 4 Account: **** **** **** 9441 2b'12�`otal$Yearto-bate;.: , , Total Fees Charged in 2012 $0.00 Total Interest Charged in 2012 $153.51 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type of.Balanc+� ;: AnnuatPercentai 13 (APPY; bect ft Mterest.fl ile PURCHASES REGULAR 9.90% M $4,678.08 $38.06 Page 3 of 4 Account: **** '*** **** 9441 Page 4 of 4 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC Jt1j 1835 Market Street, Suite 501 Philadelphia, PA 19103 �"Q� s b 54 TELE: 215-564-1567 FAX: 215-564-3818 PE�bs yt Cajj�jTy NJ PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION A Z_ No. 1q / foxl 1;1 , 7 47' PAMELA YORK 4 OCKER LN SHIPPENSBURG PA 17257 Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLE LEIBSKER && M`OORE, L C Dated: By Syretta Ma tin, Esq. PA Bar # 70 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 Attorneys For Plaintiff 2933815 PPTXPEAI (05/12/2014) IIIIIIII VIII IIII 111111 I1 IIIIII VIII IIII'VIII VIII VIII VIII 111111111 IIII Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND RILED -OFFICE f`i� THE �'COUNTYRt��HO�4Q 7r`;r ' ..rtYbt cm,4`to+„r. 2014 AUG -5 PI 9: SI CUMBERLAND COUNTY PENNSYLVANIA OFFICE. OF Ilia $4E IF Portfolio Recorvery Associates, LLC vs. Case Number Pamela York 2014-4274 SHERIFF'S RETURN OF SERVICE 07/29/2014 04:52 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Shannon Adkins, husband, who accepted as "Adult Person in Charge” for Pamela York at 4 Ocker Lane, Southampton Township, Shippensburg, PA 17257. CHRISTOP R SHARPE, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, July 30, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF IN THE COURT OF Common Pleas 'Cumberland County, Pa rri co Civil Action u)1"-- -0> No.14-4274 civil c cp PLAINTIFF Portfolio Recovery Associates LLc 1835 Market Street Suite 501 Philadelphia, Pa 19103 vs Defendant Pamela Adkins 4 'Ocker°lane Shippensburg PA 17257 Case # 14-4274 civil NOTICE OF INTEND TO DEFEND I, Pamela Adkins HEREBY GIVE NOTICE OF INTEND TO DEFEND THE ABOVE TITLE ACTION, AND DEMAND STRICK PROOF OF THE PLAINTIFF ALLEGED CLAIM. zxiN yo4 iga \'_-Iq,,_?Oki