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HomeMy WebLinkAbout14-4442 Supreme Cour4 V�Uto Pennsylvania '1x Cou�(�� "' ' Pleas o! Common Far Prothonotary Use Only: T[M E STA M P Cl Wf- iCg v e h,�' 'ke t DocketiNo: py yqq,,;L- CUNM&Ink- 1�?County The infortnation collected on this form is used solely for court administration purposes. This form does not supplement or replace the lin and service of pleadings or other papers as required by law or rules ofcourt. Commencement of Action: S IS Complaint C3 Writ of Summons E]Petition E 0 Transfer from Another Jurisdiction E]Declaration of Taking C Lead Plaintiffs Name. Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC JANIE L ROGERS T I Are money damages requested? 0 Yes 0 No Dollar Amount Requested: X within arbitration limits 0 (Check one) outside arbitration limits IN Is this an MDJAppeal? 0 Yes N No Is this a(7m Action Suit? 11 Yes ® No A Name of Plaintiff/Appeflant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R.Garvey D Check here if you have no attorney(are a 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 you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS f-1 Intentional 0 Buyer Plaintiff Administrative Agencies E] Malicious Prosecution r-1 Board of Assessment M Motor Vehicle 0 Debt Collection:Credit Card D Board of Elections F-1 Nuisance 0 Debt Collection:Other 171 Dept.of Transportation F-1 Premises Liability E3 Statutory Appeal:Other 0 Product Liability(does not include S Inass toil) 0 Employment Dispute: E M Slander/Libel/Defamation Discrimination M Zoning Board C E] Other: [I Employment Dispute:Other 0 Other: T I MASS TORT C] Other: 0 0 Asbestos N 0 Tobacco REAL PROPERTY MISCELLANEOUS F-1 Toxic Tort-DES El Ejectment F1 Common Law/Statutory Arbitration F-1 To)dc Tort-Implant E]Eminent Domain/Condemnation M Declaratory Judgment B r-1 Toxic Waste ED Ground Rent M Mandamus [-1 Other: 0 Landlord/Tenant Dispute F-1 Non-Domestic Relations E3 Mortgage Foreclosure:Residential Restraining Order El Mortgage Foreclosure:Commercial El Quo Wan-anto C] Partition D Replevin PROFESSIONAL LIABILITY m Quiet Title 171 Other: F-1 Dental D Other: E] Legal M Medical E] Other Professional: 16-03654 a Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 F;L E J,.01'F i C,:` Portfolio Recovery Associates, LLC 0 ['10 1'610 N 0 TA R y 120 Corporate Blvd r Norfolk, VA 23502 2014 JUL 30 PM 12: 09 TELE: 1-866-428-8102 CUMBERLAND CCI�!}�TY FAX:(7s7) s18-os6o Attorneys for Plaintiff PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. &AJ Plaintiff, 7 V. JANIE L ROGERS 28 ROBIN CT MECHANICSBURG PA 17055 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 1/3F (717)249-3166 G 7 ® 16-03654 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. 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. JANIE L ROGERS 28 ROBIN CT MECHANICSBURG PA 17055 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 ]a 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 16-03654 Esta conlunicacion es de un cobrador de deudas y es un itltent do cobras Lina deuda. Cualquier infroniacion sera utilirAda para cse 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 COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. JANIE L ROGERS 28 ROBIN CT MECHANICSBURG PA 17055 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, JANIE L ROGERS, is an adult individual with last known address of 28 ROBIN CT, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to U.S. BANK NATIONAL ASSOCIATION on July 1, 2011 with account number ************8284(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 cozTi-n i-ication is from a debt collector anti .is an.attempt to collect,a debt. Any information obtained Evill 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 August 24, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest U.S. BANKNATIONAL ASSOCIATION 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$2,401.87. 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, JANIE L ROGERS , in the amo 0 2,401.87, plus costs this act' n and any other relief as the Court deems just and reason e. Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-03654 'Ibis cotnril nication is from 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, Shirley Garcia hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief based upon information provided by the Plaintiff The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: JUN 17 2014 y� -A U Shirley Garcia Custodian of Records 16-03654 This conn"ication 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. EXHIBIT B BILL OF SALE AND ASSIGNMENT OF ASSETS The undersigned Assignor ("Assignor') hereby absolutely sells, transfers, assigns, sets-over, quitclaims and conveys to Portfolio Recovery Associates, LLC, a limited liability company organized under the laws of Delaware ("Assi nee") on an "AS IS" and "WITH ALL FAULTS" basis, without recourse and without representations or warranties of any type, kind, character or nature,express or implied, all of Assignor's right, title and interest in and to each of the assets identified in the Asset Schedule ("Asset Schedule") attached hereto as Exhibit A (the "Assets"),together with the right to collect all principal, interest or other proceeds of any kind with respect to the Assets remaining due and owing as of the date hereof(including but not limited to proceeds derived from the conversion, voluntary or involuntary, of any of the Assets into cash or other liquidated property, including, without limitation, insurance proceeds and condemnation awards), from and after the date of this Bill of Sale and Assignment of Assets. DATED: October 25, 2013 ASSIGNOR: U.S. Bapk National Association By: QVOA-, Name(p n oel G. Rebmann Title: Sr. i e President By: �G Nar6e (print)1. Title: M10 USB PRIME APPROVED 10/10/2013 bank. FlexPerks, March 2013 Statement Page 1 of 3 .� Open Date: 02/23/2013 Closing Date: 03/22/2013 Account 8284 U.S. Bank FlexPerks®Select Rewards Visa®Card Cardmember Service `' 1-800-692-8472 JANIE L ROGERS BNK 14 ' New Baanc $1,� g gg Activity Summary i0:lmufl7 ,avine Que $©'0 Previous Balance + $1,928.56 F� 'yrl 4h+t Du0e Date ; ?�11 M013 Payments $0.00 Other Credits - $1,928.56cR tate Payment warr>ing it ave do not re Ov your Purchases $0.00 mtr irnum payment kiy: date hsted atiaye you may.have Balance Transfers $0.00 to pay up to a$35 00 Late Fee Advances $0.00 Other Debits $0.00 Fees Charged - $199.00cR Interest Charged - $274.31 CR New Balance = $1,928.56 Past Due $0.00 Minimum Payment Due $0.00 Credit Line None Available Credit None Days in Billing Period 28 Payment Mail payment coupon Pay online at /� Pay by phone q Pay at your local Options: with a check www.flexperks.com C 1-800-692-8472 l U.S.Bank branch Please detach and send coupon with check payable to:U.S.Bank bank. _8284 .- Account Number 8284 Payment Due Date 4/19/2013 24-HourCardmember Service: 1-800-692-8472 New Balance $1,928.56 C .topay a bYphone Minimum Payment Due $0.00 .to change your address Amount Enclosed $ 000000633 1 SP 000638010211992 S U.S. Bank JANIE L ROGERS P.O. BOX 790408 4615 REDFIELD CT APT 2A St.LOUIS, MO 63179-0408 SAINT LOUIS MO 63121-2224 dllllllllll���lllllllllllllhllllllllllllll"11'1111"IIIIII�II, .III'll'1111"IIIIIIIIIII"IIIII'llll'llll'I'llllllll'IIIII�JIII What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement,please call us at the telephone number on the front of this statement,or write to us at: Cardmember Service,P.O.Box 6335,Fargo,ND 58125-6335. In your letter or call,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 believe it is a mistake. You must contact us within 60 days after the error appeared on your statement.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 on 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. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card,and you have tried in good faith to correct the problem with the merchant,you may have the right not to pay the remaining amount due on the purchase. To use this right,all of the following must be true: 1.The purchase must have been made in your home state or within 100 miles of your current mailing address,and the purchase price must have been more than$50.(Note:Neither of these are necessary if your purchase was based on an advertisement we mailed to you,or if we own the company that sold you the goods or services.) 2.You must have used your credit card for the purchase.Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3.You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase,contact us in writing at:Cardmember Service,P.O.Box 6335, Fargo,ND 58125-6335 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. Important Information Regarding Your Account 1.INTEREST CHARGE:Method of Computing Balance Subject to Interest Rate:We calculate the periodic rate or interest portion of the INTEREST CHARGE by multiplying the applicable Daily Periodic Rate("DPR")by the Average Daily Balance("ADB")(including new transactions)of the Purchase,Advance and Balance Transfer categories subject to interest,and then adding together the resulting interest from each category.We determine the ADB separately for the Purchases,Advances and Balance Transfer categories.To get the ADB in each category,we add together the daily balances in those categories for the billing cycle and divide the result by the number of days in the billing cycle.We determine the daily balances each day by taking the beginning balance of those Account categories(including any billed but unpaid interest,fees,credit insurance and other charges),adding any new interest,fees,and charges,and subtracting any payments or credits applied against your Account balances that day.We add a Purchase,Advance or Balance Transfer to the appropriate balances for those categories on the later of the transaction date or the first day of the statement period.Billed but unpaid interest on Purchases,Advances and Balance Transfers is added to the appropriate balances for those categories each month on the statement date.Billed but unpaid Advance Transaction Fees are added to the Advance balance of your Account on the date they are charged to your Account.Any billed but unpaid fees on Purchases,credit insurance charges,and other charges are added to the Purchase balance of the Account on the date they are charged to the Account.Billed but unpaid fees on Balance Transfers are added to the Balance Transfer balance of the Account on the date they are charged to the Account.In other words,billed and unpaid interest,fees,and charges will be included in the ADB of your Account that accrues interest and will reduce the amount of credit available to you.Credit insurance charges are not included in the ADB calculation for Purchases until the first day of the billing cycle following the date the credit insurance premium is charged to the Account.Prior statement balances subject to an interest-free period that have been paid on or before the payment due date in the current billing cycle are not included in the ADB calculation. 2. Payment Information:You must pay us in U.S.Dollars with checks or similar payment instruments drawn on a financial institution located in the United States. We will also accept payment in U.S.Dollars via the Internet or phone or previously established automatic payment transaction. We may,at our option,choose to accept a payment drawn on a foreign financial institution. However,you will be charged and agree to pay any collection fees required in connection with such a transaction. The date you mail a payment is different than the date we receive that payment. The payment date is the day we receive your check or money order at U.S.Bank National Association ND,P.O.Box 790408,St.Louis,MO 63179-0408 or the day we receive your electronic or phone payment.All payments by check or money order accompanied by a payment coupon and received at this payment address will be credited to your Account on the day of receipt if received by 5:00 p.m.CT on any banking day.Mailed payments that do not include the payment coupon and/or are mailed to a different address will be processed within 5 banking days of receipt and credited to your Account on the day of receipt.In addition,if you mail your payment without a payment coupon or to an incorrect address,it may result in a delayed credit to your Account,additional INTEREST CHARGES,fees,and possible suspension of your Account.Internet and telephone payment options are available,and crediting times vary(but generally must be made before 5:00 p.m.CT to 8 p.m.CT depending on what day and how the payment is made). If you are making an internet or telephone payment,please contact Cardmember Service for times specific to your Account and your payment option. Banking days are all calendar days except Saturday,Sunday and federal holidays.Payments due on a Saturday,Sunday or federal holiday and received on those days will be credited on the day of receipt. 3.Credit Reporting:We may report information on your Account to Credit Bureaus.Late payments,missed payments or other defaults on your Account may be reflected in your credit report. bank. Flex,,Perks March 2013 Statement 02/23/2013-03/22/2013 Page 2 of 3 OWJANIE L ROGERS Cardmember Service 1-800-692-8472 mportan#Messages.:. IMPORTANT INFORMATION ABOUT YOUR ACCOUNT: Effective May 13,2013, U.S. Bank National Association ND will merge with U.S. Bank National Association. Please note the following changes that will apply to your Cardmember Agreement. All references in your Cardmember Agreement to"U.S. Bank National Association ND"are replaced with"U.S. Bank National Association". The"Ownership of this Account; Governing Law"and"Arbitration Provision"sections of your Agreement are revised to replace references to"North Dakota"with"Ohio". The"Changes to Your Account'section is replaced with the following:Account and Agreement terms are not guaranteed for any period of time;we may change the terms of your Agreement, including APRs and fees, in accordance with applicable law and the terms of your Agreement.Your transactional experience with us may also cause a change, including an increase in the margin that is added to the Index,an increase in fees,or a decrease in the Credit Limit. Factors considered in determining the increased rate or Credit Limit decrease may include your general credit profile; existence, seriousness and timing of the defaults under any agreement that you have with us; and other indications of the Account usage and performance. We will give you notice of any such change in the manner required by Ohio and federal law. Revised Account terms apply as of the effective date communicated in our notice to you unless the notice provides you with the right to opt out, and you do opt out, before the effective date. Each time you or a third party on your,behalf, pays your bill by personal check, you authorize us to convert that payment into an electronic debit. If the check is processed electronically,the checking account will be debited for the amount on the check and the debit will appear on your account statement. If you have any questions, please contact us at the Inquiries phone number located on this statement. Transactions.:.::: Payments and Other Credits Post Trans Date Date Ref# Transaction Description Amount 02/28 CHARGE OFF $1,928.56CR TOTAL THIS PERIOD $1,928.56cR Fees Post Trans Date Date Ref# Transaction Description Amount 02/28 REVERSAL OF LATE PAYMENT FEE $175.000R 02/28 REVERSAL OF OTHER FEES AT CHARGE OFF $24.00cR TOTAL FEES THIS PERIOD $199.00cR Interest Charged Post Date Transaction Description Amount 02/28 INTEREST REVERSAL $274.31 CR TOTAL INTEREST THIS PERIOD $274.31cR ....._......_.._......_..............................._.........................................................................._........._......................_............._.............................................. ..... 20.1,3.Tota.... ao Date ..:....._ ..........._............................................................_................................._.................._............_........__............................................ Total Fees Charged in 2013 $164.00cR Total Interest Charged in 2013 $185.55cR Continued on Next Page bank. FlexPerks® March 2013 Statement 02/23/2013-03/22/2013 1 Page 3 of 3 JANIE L ROGERS Cardmember Service t: 1-800-692-8472 In#rest Charge Calcination: Your Annual Percentage Rate(APR)is the annual interest rate on your account. **APR for current and future transactions. Balance Annual Expires Balance Subject to Interest Percentage with Interest Balance Type By Type Interest Rate Variable Charge Rate Statement Free Period —BALANCE TRANSFER $0.00 $0.00 $0.00 0.00% NO —PURCHASES $1,678.09 $0.00 $0.00 0.00% YES "ADVANCES $723.78 $0.00 $0.00 0.00% NO ontact....Us CPhone O QuestionsMail payment coupon Online with a check Voice: 1-800-692-8472 Cardmember Service U.S.Bank www.flexperks.com TDD: 1-888-352-6455 P.O.Box 6352 P.O.Box 790408 Fax: 1-866-568-7729 Fargo,ND 58125-6352 St.Louis,MO 63179-0408 End of Statement Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE £14ERIFF ,.1 HE P O HONG :Hi'S 2011i SPP -2 PM 3: 57 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Janie L Rogers Case Number 2014-4442 SHERIFF'S RETURN OF SERVICE 08/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Janie L Rogers, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 28 Robin Court, Lower Allen, Mechanicsburg, PA 17055. Residence is vacant. SHERIFF COST: $39.79 SO ANSWERS, August 26, 2014 RONIN R ANDERSON, SHERIFF (c) CountySu to Shoritt, Te;leosoft. Inc. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061. Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff CF THE PRD THONO NpTA! 201 OCT -3 A //: 04 CUMBENSYND C LVANIANTy 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. 14-4442 JANIE L ROGERS 28 ROBIN CT MECHANICSBURG PA 17055 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above -entitled case as discontinued without prejudice (Ik7e ctfull ubmit 16-03654 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire 1 4 art R. Garvey, Esquire Gregory J. Babcock, Esquire Attorney ID # 94055/201259/312686/205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff V. JANIE L ROGERS 28 ROBIN CT MECHANICSBURG PA 17055 Defendant : No. 14-4442 CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon JAN L ROGERS, by First Class Mail, Postage Pre -Paid, a copy thereof on thfs day of , 2014, to: JANIE L ROGERS, 28 ROBIN CT HANICSBU' 17055 16-03654 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Gregory J. Babcock, Esquire PA Bar # 205061 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose.