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Home My WebLink About14-4964 Supreme Court:;of Pennsylvania Co urtl fmf ion Pleas ,�► For Prothonotary Use Only: T[MESTAMP GOcbvelr�Sl><''�et Docket No: CUMB �,. ty The information collected on this form is used solely for court administration putposes. This forret does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. S Commencement of Action: Complaint ❑ Writ of Summons ❑Petition E ❑ TransferfromAnotherJurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES,LLC DAWN KEPLER I O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits Nt I (Check one) outside arbitration limits A Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑ Yes ® No Name of Plaintiff/Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you haw 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 ❑ 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 liability ❑ Statutory Appeal:Other ❑ Product Liability(does not include S niass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T j E] Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ To)dc Tort-DES REAL PROPERTY MISCELLANEOUS E] To)dc Tort-Implant ❑ Ejectment El Common Law/Statutory Arbitration Bi ❑ To:ac Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: '� 16-34484 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R Garvey, Esquire PA Bar#312686 . FILED-uF FIC'; . Portfolio Recovery Associates, LLC THE PRO TNO "" ; `r 120 Corporate Blvd NO l A fi ,_ Norfolk, VA 23502 291 � G 22 l re. TELE: 1-866-428-8102 518-0860 CU1�fBEr�L p Attorne59 ys for Plaintiff PENNS YND c O LINTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD It t U NORFOLK, VA 23502 No. Plaintiff, V. DAWN KEPLER 153 OLD FORD DR CAMP HILL PA 17011-8399 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 (71.7) 249-3166 16-34484 This communication is from a debt collector and is an attempt to collect a debt. 5566.) Any information obtained wX be used for that purpose. J,j 6*1 1 A 1 .0' 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 Norfok 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. DAWN KEPLER 153 OLD FORD DR CAMP HILL PA 17011-8399 Demandado. NOTICIA LISTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta ]a 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. LISTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA SI USTED NO TIENE UN ABOGADO, VAYA O LAMNIE 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 16-34484 Esta com nicacion es do un cobrado.r de deudas y es un intent do cobras ma.deuda. Cualquier nifromac.ion sera utilizada para esc 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 TBE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 ; Plaintiff, No. V. DAWN KEPLER 153 OLD FORD DR CAMP HILL PA 17011-8399 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, DAWN KEPLER, is an adult individual with last known address of 153 OLD FORD DR, CAMP HILL PA 17011-8399. 3. It is averred that Defendant was indebted.to CITIBANK, N.A. /THE HOME DEPOT on January 9, 2007 with account number ************5558 (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. 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 This corrnnunication is frown a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Defendant. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A" 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on March 15, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. /THE HOME DEPOT 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$3,040.43. 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, DAWN KEPLER, in the am $3,040.43, plus costs is ction and any other relief as the Court deems just and reas able. Carrie A Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R Garvey, Esquire, #312686 Attorneys for Plaintiff 16-34484 T'liis coirnnunication is froi.n a debt collector and .is an.attempt to collect a debt.. Any infoi-imtion obtained twill be used for that purpose. 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. Date: JUL 0 2,2014 By: Elonda Sherman Custodian of Records 16-34484 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. 'ru I& ' fontract ID:PRITHIMM082213 Document ID:011014PR1 TH 1 MMB l BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT, dated January 17, 2014, 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 P12A 082213.doex Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: HOME DEPOT CREDIT SERVICES SHOP �m� myhomedepotaccount.com PO Box 790328,St.Louis,MO 63179 ANY TIME, Account Inquiries: s+iii+1� w wY i�fii•::33 i REI Q A`ccotiii."Nur 4 t �� ANYWHE ONLINE MOBIIE IN STORE 1-866-458-7683 11>IbeTy - r;r.4;'�::.r 45558.: :,;iii+"r�':4''^ _"t.:C!`'`;H,.,,f:�.:A;:;.�f.+,:•a.4?`:cC,y-we>w-r� ..:k.:tf��,-� Summary of Account ActivitPayment Information Previous Balance $2,929.75 New Balance $3,040.43 Payments -$0.00 Minimum Payment Due $998.00 Other Credits -$0.00 Payment Due Date August 14,2013 Purchases +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Fees Charged +$35.00 date listed above,you may have to pay a late fee up to$35. Interest Charged +$75.68 Minimum Payment Warning: If you make only the minimum payment each New Balance $3,040.43 period,you will pay more in interest and it will take you longer to pay off your Past Due Amount $856.00 j balance. For example: {,}u��;jl��r�� *;�rGhf�Tt?.firl-gt21.7 C2-r ' I t'' �'s1DSNn�`t'ht _k. �.F i�� J.1•"J5 Credit Limit $0.00d�+ac -1 ,tt�rou'pa � ►s �nfitrtf"fZtillattEal0, . Available Credit $0.00 Only the minimum payment 19 years $7,511 Statement Closing Date 07/18/2013 $129 3years $4,646 Next Statement Closing Date 08/18/2013 1 1 (Savings=$2,865) Days in Billing Cycle 31 it you would like information about credit counseling services,call 1-877-337-8188. Your minimum payment due is$998.00.To avoid interest charges on your non-promotional(revolving)balance and any expiring promotions,pay $3,040.43 by August 14, 2013.if you pay your non-promotional balance in full every month,no additional billed Interest charges will apply. Interest accrues daily from your statement closing date until we receive your payment,so please check your next statement for any additional interest you may have incurred. TRANSACTIONS Trans Date Description Reference# Amount FEES 07/14 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED 07/18 INTEREST CHARGE ON PURCHASES $ 75.68 TOTAL INTEREST FOR THIS PERIOD $ 75.68 8HD11 PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4. Page 1 of 4 This Account is Issued by Citibank,N.A. ----- Please detach and return lower portion with your payment to insure proper credit. Retain upper portion for your records. y ----------------------------------------------------------------------------------------------- Your Account Number t�5558 l"7,21- Payment Due bate August 14,2013 P.O.Dox 790393 New Balance St.I oils,MO 63179 $3,040.43 Past Due Amountt $856.00 Minimum Payment Due $998.00 Statement Enclosed is%;";if'i''rsc;'•dn�.';i:' _t%'i '''%::," Ls"{`{:.' :�4:, .� :rxr�a;:i,y�1a:.: -,+,:.�. �1Q�ftlU`�)f1�'•;�IScbS@'C3.>?> .�r r ',• ti: tPast Due Amount is included in the Minimum Payment Due. Please print address changes on the reverse side. Make Checks Payable to-w HOME DEPOT CREDIT SERVICES DAWN KEPLER PO BOX 182676 153 OLD FORD DR COLUMBUS,OH 43218-2676 CAMP HILL,PA 17011-8399 CCCA- information About Your Account. Proper Form.For a payment sent by mail or courier to be in proper form, How to Avoid Paying Interest on Purchases.Your payment due date is you must: at least 25 days after the close of each billing cycle.We will not charge you - Enclose a valid check or money order made payable to Horne Depot any interest on purchases if you pay your New Balance by the payment due date each month.This is called a grace period on purchases.If you do Credit Services.No cash,gift cards,or foreign currency please. riot pay the New Balance in full by the payment due date,you will not get Include your name and the last four digits of your account number. a grace period on purchases until you pay the New Balance in full for two Payment Other Than By Mail. billing cycles in a row. • online.Go to the URL on Page 1 of your statement to make a payment. If you have a balance subject to a deferred interest or 0%APR pron'iotion For security reasons,you may not be able to pay your entire New and that promotion does not expire before the payment due date,that Balance the first time you make a payment online.The payment balance(the-excluded balance")is excluded frorn the amount you must cutoff time for Online Bill Payments is midnight Fastern time.This Pay in full to get a grace period,However,you must Still pay any separately means that we will credit your account as of the calendar day,based required payment on the excluded balance.In billing cycles in which on Eastern time,that we receive your payment request. payments are allocated to deferred interest balances first,the deferred AutoPay.Sign up at Account Online to have your payment amount interest balance will be reduced before any other balance on the account. automatically deducted each month from tare account you choose. However,you will continue to get a grace period on purchases so long as Your card account will be credited on the due date with that amount. You pay the New Balance less any excluded balances in full by the payment Phone.Call the phone number on Page I of your statement to make due date each billing cycle.We may refer to deferred interest promotions a payment_We may process your payment electronically atter we verify as No Interest promotions. your identity.The payment cutoff time for Phone Payments is midnight In addition,certain promotional offers may take away the brace period on Eastern time.This means that we will credit your account as of the purchases.Other promotional offers not described above may also allow calendar clay,based on Eastern time,that we receive your payment You to have a grace period on purchases without having to pay request. all or a portion of the promotional balance by the payment due date. Express Mail.Send payment by courier or express mail to:Payments If either is the case,the promotional offer will describe what happens. Department,1500 Boltonfield Street,Columbus,CH 43228.Payment How We Calculate Your Balance Subject to Interest Rate,For each must be received in proper form at the proper address by 5 p_m,Eastern balance,the letter following the Annual Percentage Rate in the interest time to be credited as of that day.All payments received in proper form Charge Calculation section on the front of the statement indicates the at the proper address after that time will be credited as of the next day. method we use to calculate interest charges.For Methods C,H and M, In-Store Payments.For your added convenience,payments can be we use a daily balance method(including current transactions)to calculate made at The Home Depot stores,with no service fee.Any payment in interest charges.For Methods I and L,we use an average daily balance proper form accepted in-stare will be credited as of that day.However, method(including current transactions)to calculate interest charges.For credit availability may be subject to verification of funds. Method K,we use an average daily balance method(excluding current if you send a method eligible check with this payment coupon,you authorize transactions)to calculate interest charges, find out more information cus to complete about the balance computation ethad thatt applies to your account pyour payment by electronic debit.If we do,the checking and how the resulting interest charges were determined,contact us at account will be debited in the amount on the check.We may do this as Customer Service number on the front. soon as the day we receive the check.Also,the check will be destroyed, Other Account and Payment information. Payment Amount.You may pay all or part of your account balance at any time.However,you must pay,by the payment due date,at least the minimum payment due. When Your Payment Will Be Credited.If vie receive your mailed payment in proper form at our processing facility by 5 p.m.local time there,it will he credited as of that day.A payment received there in proper form after that time will be credited as of the next day.Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form or is not sent to the correct address,The correct address for regular mail is the address on the front of the payment coupon.The correct address for courier or express mail is the Express Mail Address shown in the Express Mail section. Toasoo PLEASE SEE IMPORTANT INFORMATION ON PAGE 4 HD-2 APRt3 Page 2 of 4 Change of Address Please print address changes in blue or black ink. V'LTMPS x M AND �` i � Register now for Paperless Statements and more at MYho edepotaccou nt.00m Account: **** **** **** 5558 'A. fWl. � Total Fees Charged in 2013 $245.00 Total Interest Charged in 2013 $485.28 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR is the annual interest rate on your account w . e t=ttf3'" TMAWI.P.,k # t `. +, fits taact e;,r PURCHASES Revolvin Balance 29.99% M $2,971.79 $75.68 Page 3 of 4 Credit Reporting Disputes.If you think we reported inaccurate address After we finish our investigation,one of two things will happen: information to a credit bureau write us at the Customer Service shown on Page i. if we made a mistake:You will not have to pay the amount in question Report a Lost or Stolen Card Immediately,Call the Account Inquiries or arry interest or other fees related to that amount. number shown on Page 1. If we do not believe there was a mistake:You will have to pay the ion,What To Do If You Find A Mistake On Your Statement send you agUeS statementlonof theramolulnit you l oweeand the datest andspaWe will yment 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 errors and customer service inquiries shown on amount we think you owe. Page 1 of your statement. if you receive our explanation but still believe your bill is wron In your letter,give us the following information: must write to us within ID days telling us that you still refuse to pay. Account information:Your name and account number. If You do so,we cannot report you as delinquent without also re Dollar amount:The dollar amount of the suspected error. porting that you are questioning your bill.We must tell you the'name of Description of problem:if you think there is an error on your bill, organianyonzations know whOlto whom we lrthe matter hated you asts inqubeen settledJbetmust ween us hose deswhat you believe You mustust contact us: 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 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 Dissafisfied With Your Credit Card Purchases At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goods or services that you have purchased if you want to stop payment on the amount you think is wron You must notif us of art g. with your credit card,and you have tried in good faith to correct the Y y 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. What Will Happen After We RecTo use this right,all of the following must be true; eive Your Letter i. The purchase must have been made in your home state or within 100 When we receive your letter,we must do two things: miles of your current mailing address,and the purchase price must I. Within 30 days of receivina your letter,we must tell you that have been more than$50.(Note:Neither of these are necessary it we received your letter.We-will also tell you if we have already your purchase was based on an advertisement we mailed to you,or corrected the error. if we own the company that sold you the goods or services.) 2. Within 90 days of receiving your letter,we must either correct 2.You rnust 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 While we investigate whether or not there has been an error: your credit card account do not quality. We cannot try to collect the amount in question, 3.You must not yet have fully paid for the purchase. or report you as delinquent on that amount. if all of the criteria above are met and you are still dissatisfied with the The charge in question may remain on your statement, purchase,contact us in writing at the address for billing errors and and we may continue to charge you interest on that amount, customer service inquiries shown on Page 1 Of your statement. While you do not have to pay the arhount in question, While we investigate,the same rules apply to the disputed amount as you are responsible for the remainder of your balance. discussed above.After we finish our investigation,we will tell you our We can apply any unpaid amount against your credit limit. decision,At that point,if we think you owe an amount and you do not 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 C.ard,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. T03501-HD-9196-0400-0002-E-9-X--01/01/07-55-116-P-E-0--7-8-0-NOPLAY--06/22/12-H18P-June 17,2013-0-0 N-- PLEASE SE[IMPORTANT INFORMATION ON PAGE 2 IAD-4 APR13 Page 4 of 4 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 - iTiFr 0 -TNQT14r'i- 20111 OCT 21 f,1-1 10: 51 J3 Ii 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. DAWN KEPLER 153 OLD FORD DR CAMP HILL PA 17011-8399 Defendant To the Prothonotary: No. 14-4964 CIVIL PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinued without prejudice. 16-34484 y Submitted 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 Mark R. 6arvey, 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. DAWN KEPLER 153 OLD FORD DR CAMP HILL PA 17011-8399 Defendant : No. 14-4964 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praeci e to Discontinue upon , AWN KEPLER, by First Class Mail, Postage Pre -Paid, a copy thereof on thLV day of , 2014, to: DAWN KEPLER, 153 OLD FORD D ' , "AMP HILL PA 170 16-34484 obert 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.