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HomeMy WebLinkAbout14-4447 Sypreme Cou rt;of?Pennsylvania f: Court' f Common Pleas � J (��. �► �� For Prothonotary Use,Only: '1'1 Ni E S"t':1;�T[' Civil¢&vA,,Aket Docket No: CUMBEREAN. .County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. Commencement of Action: S N Complaint ❑ Writ of Summons ❑Petition E ❑ Transfer fromAnotherJurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: PORTFOLIO RECOVERY ASSOCIATES,LLC RHONDA K ROLLINS T I I0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes ®No Is this an MDJAppeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro 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 APPFAIS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle o Debt Collection:Credit Card ❑ Board of Elections ❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S E] Product Inability(does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defanration Discrimination ❑ Zoning Board ❑ Other: ❑ Employment Dispute:Other ❑ Other: C T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-DES ElE) Toxic Tort-Implant Ejectment E] Common Law/Statutory Arbitration B ❑ Toxic Waste E] Eminent Domain/Condemnation El Declaratory Judgment ❑ Other: E] Found Rent E] 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: 1 � 16-08278 i Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 _ r Mark R Garvey, Esquire PA Bar#312686 ' `r Portfolio Recovery Associates., LLC `"� C `� C f R y 120 Corporate Blvd h JUL 30 PM 12: TI Norfolk, VA 23502 TELE: 1-866-428-8102 CUMBERLAND COUNTY FAX: (757) 518-0860 PENNSYLVANIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVILACHON-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. 1,V- q7 C'C! Plaintiff, V. RHONDA K ROLLINS 967 W TRINDLE RD LOT 2 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 l Carlisle, PA 17013 3' 16-08278 (717)249-3166 S/lam G1,g:7 -V5/1,4 , �p9/tel 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 v. RHONDA K ROLLINS 967 W TRINDLE RD LOT 2 MECHANICSBURG PA 17055 Plaintiff, No. 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, RHONDA K ROLLINS, is an adult individual with last known address of 967 W TRINDLE RD LOT 2, MECHANICSBURG PA 17055. 3. It is averred that Defendant was indebted to CITIBANK, N.A / SEARS on November 13, 2011 with account number ************9586 (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 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 L Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#.312686 .` Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk,VA 23502 TELE: 17866-428-8102 FAX:(757) 518-0860 Attorneys for Plaintiff IN TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD : NORFOLK, VA 23502 Demandante, No. V. RHONDA K ROLLINS 967 W TRINDLE RD LOT 2 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 alas 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 16-08278 Esta corYninicacion es de un cobrador de deudas y es un intent do cobrar una deuda. C:iaalquier infrornacion sera utilimda para eye proposito. , r 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 17, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. / SEARS and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiff s 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$2,128.06. 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, RHONDA K ROLLINS , in t am nt of$2,128.06, plu is of this . action and any other relief as the Court deems just and easonab . Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-08278 Thl'S coirnnLn-iication 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 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: JUN 17 2W _ Shirley Garcia Custodian ofRecords 16-08278 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 coirnnunication is from a debt collector and is an attempt to collect a debt. Any information obtained wifl be used for that purpose. Contract ID. , Document ID: Document ID: BILL OF SALE AND ASSIGNMENT TEES BILL OF SALE AND ASSIGNMENT dated April 25, 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 headquartersi'principai 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 February 25, 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. Cltlbanlc,N.A. (Signature) Name: Title: �jy,�.r►C� �c (Ylo�jr; PRA 022513 10,F7SRSS157 . ... ... . �13oGument ID: . . .. . . . .. . .. . . ocument IIS: • . . ••.�' . E : . ..ASSETS H DULE. '. . :. : .• 'The m4 dividual Accounts trazisferre are described in'the:final:electronic.file acid r elivered by the; Bankto-,Buer,fhe'sani6-deemed attic'hed hei�eto:b this refeiince'. Y. Y: COOK:. ;Lot : .'Si e:A) -.A.ccourits :,nates' . .''.' -Safe.B Ia'nce Sears.Early: ..' 0¢:/10/ 3' -Out . . . :Sea-r.s•Early: : . - -- •EabeI :.: :.= .. •PRA.022S�3:. � .. . . _ Account Statement • Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: SEARS CREDIT CARDS searssearscard.com Po Box 6282 Sioux Falls SD 57117-6282 Sears MasterCard Account Inquiries: 1-800-669-8488 Account Number:- 9586.' Summary of Account Activity Payment Information Previous Balance $2,048.18 New Balance $2,128.06 Payments -$0.00 Minimum Payment Due $1,272.38 Other Credits -$0.00 Payment Due Date April 24,2013 Purchases +$0.00 Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Char ed +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$44,88 Minimum Payment Warning: If you make only the minimum payment each New Balance $2,128.06 period,you will pay more in interest and it will take you longer to pay off your balance.For example Past Due Amount $592.44 if you make no additional Youwrll pay,off the:. Andyzra wltl .' charges using this card. balance shown on-this endup paying an Credit Limit $0.00 and eaeh rhgnth:yqu pay;: statement in about estimated.totaI of Available Credit $0.00 Only the minimum payment 9 years $4,074 Cash Advance Limit $0.00 Available Cash Limit $0.00 $s5 3 years $3,065 Amount Over Credit Limit $578.06 (Savings=$1,009) Statement ClosingDate 03/28/2013 If you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 04/26/2013 Das in Billing Cycle 31 Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. TRANSACTIONS Trans Date Description Reference# Amount FEES 03/24 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 8 ME 18 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 This Account is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- T Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.T Sears MasterCard" tPast Due Amount is included in the Minimum Payment Due. F'A' count Number• Payment Due Date New Balance past Due Amountt Minimum Payment Due Amount Enclosed 958ti APRIL 24,2013 $2,128.06 $592.44 $1,272.38 $ SAVE STAMPS, TIME... AND TREES! Visit Account Online and register now for Online Bill Pay, Paperless Statements and More. 9586 Make Checks Payable to: SEARS CREDIT CARDS PO BOX 183082 RHONDA K ROLLINS COLUMBUS,OH 43218-3082 967 W TRINDLE RD LOT 2 MECHANICSBURG,PA 17055-4056 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your tetter How to Avoid Paying interest on Purchases.Your payment due date is at least When we receive your letter,we must do two things: 25 days after the close of each billing cycle. We will not charge you any interest on 1. Within 30 days of receiving your letter,we must tell you that we received purchases if you pay your New Balance by the payment due date each month. your letter.We will also tell you if we have already corrected the error. This is called a grace period on purchases. If you do not pay the New Balance in 2. Within 90 days of receiving your letter,we must either correct the error or full by the payment due date,you will not get a grace period on purchases until explain to you why we believe the bill is correct. you pay the New Balance in full for two billing cycles in a row. We will begin charging interest on cash advances and balance transfers(if available on your While we investigate whether or not there has been an error: account)on the transaction date. • We cannot try to collect the amount in question,or report you as delinquent on If you have a balance subject to a deferred interest promotion and that promotion that amount. does not expire before the payment due date,that balance(the"excluded The charge in question may remain on your statement,and we may promotional balance")is excluded from the amount you must pay in full to get a continue to charge you interest on that amount. grace period. However,you must still pay any separately required payment on the While you do not have to pay the amount in question,you are responsible excluded promotion.in billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first,the deferred interest balance will be reduced before any We can apply any unpaid amount against your credit limit. other balance on the account.However,you will continue to get a grace period on After we finish our investigation,one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional !f we made a mistake:You will not have to pa th balances in full by the payment due date each billing cycle. y e amount in question or any In addition,certain promotional afters may take away the grace period on interest or other fees related to that amount. purchases. Other promotional offers not described above may also allow you to !f we st not believe there was l mistake.,s You will have will pay the amount p Y Y 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. How We Calculate Your Balance Subject to Interest Rate.We use a daily u you receive our explanation but still believe your bill is wrong,you must write to balance method(including current transactions)to calculate interest charges.To e within 10 days telling us that you still refuse to pay.If you do cannot est on r find out more information about the balance computation method and how the report you as delinquent without also reporting that you are questioning your bill. We must tell you the name of anyone to whom we reported you as delinquent,and resulting interest charges were determined,contact us at the Account Inquiries number on the front. we must let those organizations know when the matter has been settled between US. Balance Transfers.Balance transfer amounts are included in the"Purchases"line If we do not follow all of the rules above,you do not have to pay the first$50 of in the Summary of Account Activity(if balance transfers are available on your the amount you question even e our bill is correct. account), Y Transaction,Date.The Transaction Date shown on the statement is also the Sale Your Rights If You Are Dissatisfied With Your Credit Card Purchases Date. if you are dissatisfied with the goods or services that you have purchased with Credit Reporting Disputes.If you think we reported inaccurate information to a Your credit card,and you have tried in good faith to correct the problem with the credit bureau write us at the Customer Service address shown on the front. merchant,you may have the right not to pay the remaining amount due on the Report a Lost or Stolen Card Immediatety.Call the Account Inquiries number purchase. shown on the front. 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 What To Do If You Find A Mistake On Your Statement miles of your current mailing address,and the purchase price must have If you think there is an error on your statement,write to us at the address for been more than$50.(Note:Neither of these are necessary if your billing inquiries and correspondence shown on the front of your statement. purchase was based on an advertisement we mailed to you,or if we own In your letter,give us the following information: the company that sold you the goods or services.) 2.You must have used your credit card for the purchase.Purchases made with • Account information:Your name and account number, cash advances from an ATM or with a check that accesses your credit card Dollar amount:The dollar amount of the suspected error. account do not qualify. • Description of problem:If you think there is an error on your bill, 3. You must not yet have fully paid for the purchase. describe what you believe is wrong and why you believe it is a mistake. If all of the criteria above are met and you are still dissatisfied with the purchase, You must contact us: contact us in writing at the address for billing inquiries and correspondence shown • Within 60 days after the error appeared on your statement. on the front of your statement. • At least 3 business days before an automated payment is scheduled,if you want While we investigate,the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. above.After we finish our investigation,we will tell you our decision.At that point, You must notify us of any potential errors in writing.You may call us,but if you do if we think you owe an amount and you do not pay, we may report you as delinquent. we are not required to investigate any potential errors and you may have to pay the amount in question. EM SK-MI-SCC-SU-1-111's 07/12 T02388-1238-5300-0035-9-E-9-X--11/01/11-33--P--0--7-402-0-0-SRSCHFEE---02/26/13-GDAB-February 25,2013-0-0-V 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 accepted at any time.However,you must pay,by the payment due date,at least the in-store will be credited as of that day.However,credit availability may be minimum payment due. subject to verification of funds.Not all stores accept payments.Contact your Crediting Payments.If we receive your payment in proper form at our processing local store to see if in-store payments are accepted at that location. facility by 5 p.m.local time there,it will be credited as of that day. A payment Online Payments.Visit the web address on the front and sign up for online received there in proper form after that time will be credited as of the next day. payments. Enrollment may take a few days. If we receive your request to make Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay an online payment by 5 p.m.Eastern time,we will credit your payment as of of up to 5 days in crediting a payment we receive that is not in proper form or is that day.If we receive your request to make an online payment after that time, not sent to the correct address. The correct address for regular mail is the we will credit your payment as of the next day.For security reasons,you may be address on the front of the payment coupon.The correct address for courier or unable to pay your entire New Balance with your first online payment. express mail is the Express Payments Address shown below. AutoPay Service,if you are enrolled in this service,your payment amount will be deducted automatically each month on your due date from the bank account Proper Form.For a payment sent by mail or courier to be in proper form,you must: you select. Enclose a valid check or money order.No cash,gift cards,or foreign Pay by Phone Service.You may use this service any time to make a payment currency please, by phone.You will be charged$14.95 if a representative of ours helps expedite Include your name and account number on the front of your check or money your payment.Call by 5 p.m.Eastern time to have your payment credited as of order. that day.If you call after that time,your payment will be credited as of the next If you send an eligible check with this payment coupon,you authorize us to day.We may process your payment 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 the be debited in the amount on the check.We may do this as soon as the day we Express Payments Address.This address is: Payments Department,1500 receive the check.Also,the check will be destroyed. Boltonfield Street,Columbus,OH 43228. Payment must be received in proper Copy Fee.We charge$3 for each copy of a billing statement that dates back 3 form at the proper address by 5 p.m.Eastern time to be credited as of that day. months or more.We add the fee to the regular purchase balance.We waive the fee All payments received in proper form at the proper address after that time will if your request for the copy relates to a billing error or disputed purchase. be credited as of the next day. Page 2 of 4 Account: **'* **** **** 9586 TRANSACTIONS(cont.) Trans Date Description Reference# Amount INTEREST CHARGED 03/28 INTEREST CHARGE ON PURCHASES $ 39.21 03/28 INTEREST CHARGE ON CASH ADVANCES $ 5.67 TOTAL INTEREST FOR THIS PERIOD $ 44,88 ..... 2Of-3:::: otals Year—tq=tlate <...... Total Fees Charged in 2013 $105.00 Total Interest Charged in 2013 $125.46 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type of,Balance Annual f?e*centage Rate(AP t) pBalance;Sub)ect to lnte�est-Ra ;', Interest Charge PURCHASES REGULAR 25.24%MV) $1.829.33 $39.21 CASH ADVANCES REGULAR 27.15%(DO) $246.06 $5.67 =Variable Rate D =Daily REWARDS SUMMARY Previous Points Balance 0 Points Earned 0 Points Adjusted 0 Points Redeemed 0 Ending Points Balance 0 Page 3 of 4 Account: **** **** **** 9586 Page 4 of 4 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F ;LEO-OFF/CL OF THE PRO THONOjAW1 ©FF.ICE OF THE SHERIFF Z014 AUG -8 AM 11: 01 CUMBERLAND COUNTY PENNSYLVANIA Portfolio Recorvery Associates, LLC vs. Rhonda K. Rollins Case Number 2014-4447 SHERIFF'S RETURN OF SERVICE 08/04/2014 07:05 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Rhonda K. Rollins at 967 W. Trindle Road, Lot 2, Monroe Townshi Mechanicsburg, PA 17055. o-Lun . DAWN KELL, DEPUTY SHERIFF COST: $39.79 SO ANSWERS, August 05, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RON R ANDERSON, SHERIFF