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HomeMy WebLinkAbout14-4965 Supreme Court-of Pennsylvania A4 �. Court}of Com Pleas w 2 �) t For.Prothonotary Use Only: I7it1E STAlt9I' CPVII�C�overSleet Docket No: Liq cumB L-A 1 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 papers as required by law or rules of court. s Commencement of Action: ' E ® Complaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T PORTFOLIO RECOVERY ASSOCIATES,LLC DIANA ZEIGLER I 0 Are money damages requested? ® Yes 0 No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration linuts A Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ®No Name of PlaintiIDAppellant's Attorney:Robert N.Polas,Jr./Can ie Brown/Mark R Garvey ❑ 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 ❑ 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 S ❑ Product Liability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: T I ❑ Other: Q MASS TORT N ` ❑ Asbestos ❑ Tobacco REAL,PROPERTY MISCELLANEOUS ❑ Toxic Tort-DES B ❑ Toxic Tort-Implant E] Ejectment E] Common Law/Statutory Arbitration F1 Toxic Waste E] Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Other: El Found Rent ❑ Mandan-us ❑ 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: 15-60894 Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar# 312686 1, ta, Portfolio Recovery Associates, LLC !I-pp,0Tflojv- 120 Corporate Blvd 01 T r Norfolk, VA 23502 CUbJ G�Z //: 01; TELE: 1-866-428-8102 -REPT hl� COUP FAX:(757) 518-0860 S Attorneys for Plaintiff YL VA 41A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC C�✓`. 120 CORPORATE BLVD NORFOLK, VA 23502 No. 1 Plaintiff, V. DIANA ZEIGLER 300 RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 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 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 O (717) 249-3166 15-60894 '�'A 1 , —* S%o2lD 1 93lo�l0la This communication is from a debt collector and is an attempt to collect a debt 210 M 3 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. DIANA ZEIGLER 300 RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 Demandado. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en ]a 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 1NFORMACION 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 15-60894 Esta comunicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Citalquie.r .infromacion sera util.izada para ese proposito. Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar# 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION- LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. DIANA ZEIGLER 300 RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 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, DIANA ZEIGLER, is an adult individual with last known address of 300 RAMSAY PL APT 419, NEW CUMBERLND PA 17070-3409. 3. It is averred that Defendant was indebted to GE CAPITAL RETAIL BANK/GENERAL ELECTRIC CAPITAL CORP /CARE CREDIT on October 30, 2009 with account number ************2207 (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 frorn a debt collector and .is an attempt to collect a debt. Any inibrnnation.obtained will be used for that pit-pose. 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 June 24, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ GENERAL ELECTRIC CAPITAL CORP /CARE CREDIT 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$2,968.01. 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, DIANA ZEIGLER, in t a unt of$2,968.01, plus - s of this action and any other relief as the Court deems just and re on Carrie A. Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 15-60894 This convnunication is from a debt collector and is an attempt to collect a debt. Any infor.ination obtained will. be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cdstina Patterson 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 autho ' ies. Date: JUL 0 9 2014 By: Usfina Patterson Custodian of Records 15-60894 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. EXHIBIT A BILL of SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated as of this l3th day of December,2012 by and between General Electric Capital Corporation,GE Capital Retail Bank,GEMB Lending,Inc.,Monogram Credit Services, L.L.C.,RFS Holding,L.L.C.,and GEM Holding,L.L.C.(collectively"Seller")and Portfolio'Recovery Associates,LLC("Buyer"), Seller hereby transfers,sells,conveys,grants,and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement,to the extent of its ownership,the Receivables as set forth in the Notification Files(as defined in the Agreement),delivered by Seller to Buyer on each Transfer Date,and as fiutlier described in the Agreement. GE Capital Retail Bank By: Glenn Marino Title: EVP General Electric Capital Corporation By: _R5X_C.1 _ Glenn Marino Title:_Vice President GEMB Lending,Inc. By: Stephen Motta Title:Director Monogram Credit Services,L.L.C., By: -.4-�„ Gtenn Marino Title:President 31 EXHIBIT A BILL of SALE For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement(the"Agreement"),dated as of this 13th day of December,2012 by and between General Electric Capital Corporation,GE Capital Retail Bank,GEMB Lending,Inc.,Monogram Credit Services,L.L.C.,RFS.Holding,L.L.C.,and GEM Holding,L.L.C.(collectively"Seller")and Portfolio Recovery Associates, LLC("Buyer"), Seller hereby transfers,sells,conveys,grants,and delivers to Buyer,its successors and assigns, without recourse except as set forth in the Agreement,to the extent of its ownership,the Receivables as set forth in the Notification Files(as defined in the Agreement),delivered by Seller to Buyer on each Transfer Date,and as further described in the Agreement. GE Capital Retail Bank By: Glenn Marino Title: EVP General Electric Capital Corporation By: Glenn Marino Title: Vice President GEMB Lending,Inc. By: Step en otta Title:Director Monogram Credit Services,L.L.C., By: Glenn Marino Title:President 31 'RFS aiding,L.L.C. By: Josep e5sa Title: F GEM Holding,L.L.C. By: Joseph sa. Tide: C o 32 CARECREDIT/CECRB Cardholder Name: DIANA M ZBIGLER Account NumberClosin 2207 GE Capital Retail Bank Statement Closin7NewPwchases � abnce , 6271 New Balancechases $2,933.01$O.Op Minimum payment This Period $100s .00 $0.00 Amount Past Due ees @ Adjustments(net) $544,00$3500Taal Minimum Payment Due $644 00 har net $ Payment Due Dateance 01/25`2013 $2,933.01 PATM�.DUEBYIP.M.EASTERNONTHE DUEDATE. Credit Limit $3,00000 We may convert your payment into an electronic debit. See Available Credit $000 reverse side. Days in Billing Period 31 Pay online for free at:gogecapital.com Late Payment Warning: If%e do not receive yore Total �� P Minimumu Payment Due by the Payment Due Date listed above, For Capital Retail Bank customer service or to report Your card lost or stolen,call 1-866-89X786y, _ you may have to pay a late fee up to$35.00. Minimum Payment Warning: Making only the Total Minimum Best times to call are Wednesday-Friday. Payment Duk will increase the amount of interest you pay and the time it takes to repay your balance.For example: {7pyeut?utuldttyt t tYOYtrt Iftt !M ft*4+t Only the minimum 15 years $8,653.00 payment If you%ould like information about credit counseling services, call 1-877-302-8797. +tut t.ttt4t, f{ttfttttt4tttttt+ftutu+ttttttttttttttttttttftftftttt i+'' YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULL BY ITS EXPIRATION DATE TO AVOID PAYINGDEFERRED INTEREST CHARCFS, PLEASE SEETHE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT FORFURTHER DETAILS YOU HAVE A PROMOTION(S)EXPI CHASE 07/MAR tu01/13. Iii III IF 1110 111 tu+ttttfttt[ttttttttttttttttttttttt[tt{ttf t tttt t+t 111 111 IF 1111 1 Promotional Promotional Deferred Tran Date Description Expiration Balance interest Charge Initial Date Purchase Amount 07/01/2013 $1,350.00 5444.40 12/15`2011 Deferred Interest/No Interest If Paid In Full $1,350.00 A summary of your promotional purchase is provided above. Any promotion may M terminated if your aceoumt goes 60 days past doe. If you have a DEFERRED INTEREST/NO INTEREST IFPAID IN FULL Promotion:To avoid paying Deferred Interest Charges on these promotion(s),you must pay the entire applicable Promotional Balance by the Promotional Expiration Date. Ona Fixed Payment(Extended Payment Plan)promotional purchase,the Interest Charge is billedmonthly and included as pan of the Minimum Payment due. To make more than one payment see Make Payment To address or pay online at gogecapital.com. on"Jhhatr�ttttttt+ttttftttttttttitttttttftttttttttft.tttttttttttttf Tran Date Pott Date Reference Number Description Amount FEES 12/25/2012 12/25/2012 LATE FEE $35.00 TOTAL FEES FOR THISPERIOD $35.00 minuted on next a •NOTICE:See reverse side andadditional pages(if any)for important information conoemingyour account. 5302 DFH 1 7 2 130102 ED PAGE 1 of 3 9072 3000 xAOB OlEJ5302 Pay online at gogecapital.com orenclose this coupon with you check.Please use blue or black ink. 4• Payment Enclosed: $ ..... .. . New address ore-moil? Payment due includes$544.00 past doe.Please pay the past due amount PROMPTLY. Check the box at left and print changes on back If you only pay the Taal Minimum Due it may not pay off the Promotional Purchase by the Expiration Date, DIANA M ZEIGLER FDDADTAFTDTTDADTDFDDFFDTAAFAAADDDTFAAAADDAFADTDAAFDDDTADFTDDDTAAF 300RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 Make Payment to: M CAPITAL RETAIL BANK PO BOX 960061 DDDFDAAAFFTADDAADDAFADDFTTFATDDATAFDTFAADDAADDFATDTTTTp FDDDDDDDLANDO,FL FAI 2 207■ F er Service/Questions:For account information,please call the toll free number on the front of this statement.unless me is listed on this statement,your access to information on the account maybe limited.You may also mail questions payments)to:P.O.Box 965033,Orlando,FL 32896-5033.Please include your account numberon any correspondence d taus.ts:Send payments to the address listed on the remittance coupon portion of this statement or pay online at www. itol.com. ght Payments:Payments cannot be made in person,mail payments to GE Capital Retail Bank,140 Wekivo Springs Road,Longwood,FL 32779. Notice:See below foryour Billing Rights and other Important information.Telephoning about billing errors will not preserve your rights under federal law.To preserve your rights,please write to our Billing Inquiries Address,P.O.Box 965035,Oriando, FL 32896-5035. q Purchases,returns and payments made/ust prior to billing date may not appear until next month's statement.When you provide a check as payment,you authorize us either to use information from your check to make a one-time electronic fund transfer fmmyour account ortoprocessthe payment asacheck transaction.When we use information from your check to make an electronic fund transfer,funds may be withdrawn from your account as soon as the some day we receive your payment and you will not receive your check back from your financial institution.You may choose not to have your payment collected electronically by sending your payment Iwith the remittance coupon),In your own envelope-not the enclosed remittance envelope,addressed to:PO Box 530960,Atlanta,GA 30353-0960 and not the Payment address. What To Do If You Think You Find A Mistake On Your Statement: If you think there is an error on your statement,write to us at GE Capital Retail Bank,P.O.Box 965035,Orlando,FL 32896-5035. In your letter give us the following information: •Account information:Your name and account number •Dollar amount The dollar amount of the suspected error if •Description of problem:If you think there is an error on your bill,describe what you believe is wrong and why you be- eve it Is a mistake. You must contact us within 60 days after the error appeared onyour statement. You must not' us of any potential errors in writing,You may callus,but Ifyou do we are not required to investigate any potential errors and you may have to pay the amount in question. 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 hove 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, are responsible for the remainder of your balance. •We can apply any unpaid amount against your credit limiyou t. Information About Payments:You may atany time pay,inwhole orIn art,the total unpaid balance without any additional charge for prepayment. Payments received after 5:00 PM(ET)on any Say will be credited as of thenext day.Credit to your account may be delayed up to five days if payment(al is not received at the payment address,IN is not made in U.S.dollars drawn on a U.S.financial institution located in the U.S..(c)is not accompanied by the remittance coupon attached to your statement,(d)contains more than one payment orremittance coupon.le)isnot received inthe remittance envelope�rovided or If)includes staples,paper clips,tape.a folded check or correspondence of any type.Londttional Payments;All written communications concerning disputed amounts,including any check or other payment instrument that Ii)indicates that the payment constitutes"Payment in full"or is tendered as full satisfaction of a disputed amount,or(ii)is tendered with other conditions or limitations"Disputed Payments"),must be mailed or delivered to us at P.O.Box 965035,Orlando,FL 32896.5035. Credits to Your Account:An amount shown In parenthesis is a credit or credit balance unless otherwise indicated.Credits will be applied to your previous balance immediately upon receipt,but will not satisfy any required payment that may be due. Credit Reports and Account Information:If you believe that we may have reported inaccurate informati consumer-reporting agency,please contact us at P.O.Box 965036,Orlando,FL on about you to a 32896-5036.In doing so,please identify the Inaccurate information and tell us why you believe it is incorrect.Ifyou have a copy of the credit report that includes the inac- curate Information,please include a copy of that report.We may report information about your account to credit bureaus. Late payments,missed payments,or other defaults on your account maybe reflected in your credit report. How We Calculate Interest:we figure the interest charge on your account by applying the periodic rate to the"daily bal- ance"of your account for each day in the billing cycle.We then add the interest to the daily balance. To get the"daily bal- ance"we take the beginning balance of your account each day(which includes unpaid Interest),add any new charges,and applicable fees,and subtract any Payments or credits.This gives us the daily balance.Any daily balance of less than zero will be treated as zero.A separate daily balance will be calculated for each balance type on your account.The bolance(s)shown in the Interest Charges section of this statement is the sum of the daily balances for each day in the billing cycle divided by the number of days in the billing cycle. Bankruptcy Notice:If u file bankruptcy you must send us notice,including account number and all information related to the proceeding to the following address:GE Capital Retail Bank,Attn:Bankruptcy Dept.,P.O.Box 103106,Roswell,GA 30076. Your account Is owned and serviced by GE Capital Retail Bank. Hearing Impaired:TDD users call 1-877-448-8512 Use of Information About You and Your Account Our Privacy Policy describes our collection and disclosure of information aboutyou and your Account.Ifyou would like another copy ofthe Privacy Policy,please call us at the customer service tele- phone number Indicated on the front of this statement. This is an attempt to collect a debt and any information obtained will be used for that purpose. OIEJ5302-12-03/05/12 By providing a telephone number on your account,you consent to GE Capital Retail Bank and any other owner or servicer of your account contacting you aboutyour account,including using anycontact information orcell phone numbersyou provide, and you consent to the use of ony automatic telephone dialing system and/or an artificial or rerecorded voice when contact- ing you,even ifyou are charged for the call under your phone plan. For changes of address or phone number,please check the box and print the changes below. Retail EN-OIEJ5302 Name ❑ Street Address - Oh' State Zip Code Home Phone# Business Phone# Cell#or other phone#we can use to contactyou Email Address Remember,you can update the above information as well as your a-mail address online at www.gogecapital.com Cardholder Name: DIANAMZEICLER Account Number: 2207 Statement Closing Date:01/02/2013 t1Dk lilkt ttttft}tttftttftft}ttttt}tfttttttttttt}ttttttt}tttt Tran Date Post Date Reference Number Description Amount INTEREST CHARGED 01/02/2013 01/02/2013 INTEREST CHARCE ON PURCHASES $35.30 **..;;** TOTAL INTEREST FOR TMS PERIOD $35.30 i*iM+*;tf+ MW�F�} tftttttftft �'F"NP�rtirttht►trti* Total Fees Charged in 2013 $35.00 Total Interest Charged in 2013 $35.30 Total Interest Paid in 2013 $000 #V 'P4tttttttttttttttttttttttttttttttttft}tttitttfttt}tttftt Type of Balance Expiration Date Annual Balance Sub/e'ct to Interest Charge Percentage Interest Rate Rate(APR) Purchases NA 26.99 Deferred Interest/No Interest lfPaid In Full °) $1,539.79 $35.30 v)=Variable rate 07/OU2013 $1,773.34 $0,00 ( on ttttttt}ttttttttt}tftttttFtftftftttttftftttttftttttt We understand the impact of natural disasters can be difficult and we hope you andyour loved ones are safe. If you need special assistance with your account,our representatives are available to assist you by calling the number on this statement. In order to protect youraccount privacy,we are unable to provide account information to anyone other than the cardholder(s)or an authorized party.If you wish to permit tato speak to an authorizedpady such as a spouse about your account,please send written authorization to the Qneral Inquiries address IMMEDIATE PAYMENT ARRANt;EMENTS MUST BE MADE TODAY ON YOUR ACCOUNT. CALL 1-500-399-5166 5302 DFH 1 7 2 130102 ED PAGE 2 of 3 9072 3000 XA08 OlEJ5302 5302 DFH 1 7 2 130102 ED PAGE 3 of 3 9072 3000 XAOH OlEJ5302 Carrie A. Brown, Esquire Rotert N. Polas Jr, Esquire lark 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 '•- al ; pai rt4 4 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. DIANA ZEIGLER 300 RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 Defendant To the Prothonotary: No. 14-4965 CIVIL PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinued 15-60894 ithout prejudice. S -d, 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. 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. DIANA ZEIGLER 300 RAMSAY PL APT 419 NEW CUMBERLND PA 17070-3409 Defendant : No. 14-4965 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon DIANA ZEIGLER, by First Class Mail, Postage Pre -Paid, a copy thereof on this day of , 2014, to: DIANA ZEIGLER, 300 RAMSAY PL APT 4 CUMBERLND 15-60894 7070-3409 Rosen 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 inforniation obtained will be used for that purpose.