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
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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.
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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
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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
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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
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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
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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.