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Home My WebLink About14-5070 Supreme Courttof�-=' Pennsylvania f* Courl oon Pleas l�t' r*v_ 8 � For Prothonotary Use Only: TIME STAMP Civil�G VeV)' eet Docket No: CUMBE14ounty RLA The it formation collected on this form is used solely for court administration purposes. This form does not supplement or•replace theflLna and seryice ofpleadings or other papers as required by law or rules of court. S Commencement of Action: E ® Complaint ❑ Writ of Summons E]Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking T jLead Plaintiffs Name: Lead Defendant's Nacre: PORTFOLIO RECOVERY ASSOCIATES,LLC JAMES RQUARLES I I O Are money damages requested? ® Yes ❑ No Dollar Amount Requested: X within arbitration limits N (Check one) outside arbitration limits A Is this a Class Action Suit? ❑Yes ® No Is this an MDJAppeal? ❑Yes ®No Name of Plaintiff7Appellant's Attorney:Robert N.Polas,Jr./Carrie Brown/Mark R Garvey ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) I 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) ❑ En-ployment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute:Other ❑ Other: Ti I ❑ other: O MASS TORT N ❑ Asbestos ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Tonic Tort-DES E]B F1 Toxic Tort-Implant Ejectment ❑ Common Law/Statutory Arbitration F-1 Toxic Waste E] Eminent Domain/Condemnation El Declaratory Judgment ❑ Other: E] Ground Rent E3 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- 16-16444 i Robert N. Polas, Jr., Esquire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar# 312686 M` `71L ED-OFFI L -_ Portfolio Recovery Associates, LLC `'` € �� 7ft`0ljfl,) t�,� 120 Corporate Blvd ZJI4 AUG 28 Norfolk, VA 23502 't TELE: 1-866-428-8102 CUMBERLAND f FAX:(757) 518-0860 PENN ��,f� a A 4 I ,� Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD No NORFOLK, VA 23502 Plaintiff, V. JAMES R QUARLES 925 BRANDYWINE WAY MECHANICSBURG PA 17050 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 s (717) 249-3166 � I g 16-16444 ag �jLi- This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. D IL 's 1 �•�� r 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. JAMES R QUARLES 925 BRANDYWINE WAY MECHANICSBURG PA 17050 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 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 16-16444 Esta coniunicacion es de un cobrador de deudas v es un.intent do cobrar una deuda. Cualquier infronlacion sera utilizada 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. JAMES R QUARLES 925 BRANDYWINE WAY MECHANICSBURG PA 17050 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, JAMES R QUARLES, is an adult individual with last known address of 925 BRANDYWINE WAY, MECHANICSBURG PA 17050. 3. It is averred that Defendant was indebted to CITIBANK, N.A. /THE HOME DEPOT on July 15, 2006 with account number ************6807 (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 i.n1br.ination obtained will be used for that purpose. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A." 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on June 23, 2012. 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$1,61.1.03. 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. "l l. 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, JAMES R QUARLES , in t ount of$1,611.03, pl osts this action and any other relief as the Court deems just d rea le Carrie A. Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 16-16444 This con-ununication is frorn a debt collector and is an attempt to collect a debt. Any information obtained w.111 be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates,LLC, Elaine Freeman-Lark 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 10 2094 By: Elaine Freeman-Lark Custodian of Records 16-16444 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. This communication is from a debt collector and is an attempt to collect a debt. Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: Customer Service: HOME 6 DEPOT CREDIT SERVICES myhomedepotaccount.com PO Box 790328,St.Louis,MO 63179 Account Inquiries: \ 1-866-458-7683 IL AcC1t9Uftt6>07F i..'r '� r Summary of Account Activity Payment Information Previous Balance $1,541.52 New Balance $1,611.03 Payments -$0.00 Minimum Payment Due $630.00 Other Credits -$0.00 Payment Due Date February 21, 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 +$34.51 Minimum Payment Warning: If you make only the minimum payment each New Balance $1,611.03 period,you will pay more in interest and it will take you longer to pay off your Past Due Amount $544balance For example .00 additoftii 111",sl YO3r QyH 1:R,@ �',t,{char�e��bstng��t1{5�alntl�Y� �1��se �s�n tri t0,211 Credit Limit € aetrrptkthp�ria ,` .satea4eiltl�rltL $0.00 Available Credit $0.00 Only the minimum payment 6 years $2,624 Statement Closing Date 01/25/2013 $65 3 years $2,336 Next Statement Closing Date 02/22/2013 (Savings=$288) Das in Billing Cycle 31 1 you would like information about credit counseling services,call 1-877-337-8188. Your minimum payment due is$630.00.To avoid interest charges on your non-promotional(revolving)balance and any expiring promotions,pay $1,611.03 by February 21, 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 01/21 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 Everything you need to know about your account is here—in one What-8.0h your easy-to-read statement:account number,payments,fees, Interest, billing`sta#ement? credit limit,contact information and more. Please see page 4 for additional information. 8HD16 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION -- -- ---Page 1 of 4 This Account is Issued by Citibank,N.A. ♦Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.T tPast Due Amount is included in the Minimum Payment Due. Y�4t pcourft Nt#ntbet , Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed d .I FEBRUARY 21,2013 $1,611.03 $544.00 $630.00 $ .. 6807 Make Checks Payable to: HOME DEPOT CREDIT SERVICES PO BOX 182676 JAMES R QUARLES COLUMBUS,OH 43218-2676 925 BRANDYWINE WAY MECHANICSBURG,PA 17050-1905 Print address changes above in blue or black ink. Information About Your Account. Now to Avoid Paying interest on Purchases.Your payment due date is at least 25 days after the What Will hfappen After We Receive Your Loner close of each billing cycle.We will not chargeYou any interest on purchases if you pay your New When we receive your letter,we must do two things: Balance by the payment due date each month.This is called a grace period on purchases,If you do 1 Within 30 d not pay the New Balance in full by the payment due date,you will not get a grace period on purchases nays of receiving your letter.we must telt you that we received your letter.We will also until you pay the New Balance in full for two billing cycles in a row. tell you if we have already corrected the error. 2.Within 90 days of receiving your letter,we must either correct the error or explain to you wily we If you have a balance subject to a deterred interest or 0%APRpromotion and that promotion does not believe the bill is correct. expire before the payment due date,that balance(the°excluded balance") is excluded from the amountyou must pay in full to get a graceper€ed.However,you must still pay any separately ret red While we investigate whether or not there has been an error: Payment on the excluded balance. In billing cycles in which payments are allocated to deterred •We cannot try to collect the amount in question,or report you as delinquent on that amount. interest bounces first,the deferred interest balance will be reduced before any other balance on the •The charge in question may remain on your statement,and we may continue to charge you lnterest account.However,you will continue toget a grace period on purchases so long as you pay the New on that amount. Balance less any excluded balances in hill by the payment due date each billing cycle.We may refer .While you do not have to pay the amount in question,you are responsible for the remainder of to deferred interest promotions as No Interest promotions, your balance. in addition, certain promotional offers may take away the grace period onpurchases. Other •We can apply any unpaid amount against your credit limit. promotional others not described above may also allow you to have a grace period on purchases After we finish our investigation,one of two without having to pay all or a portion of the promotional balance by the payment due date.If either is 9 things will happen: the case,the promotional offer will describe what happens. •It we made a mistake.-You will not have to pay the amount in question or any interest or other fees related to that amount. Now We Calculate Your Balance Subject to Interest Rate. For each balance,the letter «If we do not believe there wds a mistake:You will have to pay the amount in question,along with following the Annual Percentage Rate in the Interest Charge Calculation section on the front of theapplicable interest and fees.We will send you a statement of the amount you owe and the date statement indicates the method we use to calculate interest charges.For Methods C,H and M,we use payment is due.We may then report you as delinquent if you do not pay the amount we think you owe. a daily balance method(including current transactions)to calculate interest charges.For Methods I and L,we use an average daily balance method(including current transactions)to calculate interest Ifyou receive our explanation but still believe your bill is wrong,you must write to us within 10 days charges.For Method K,we use an average daily balance method(excluding current transactions)to telling us that you still refuse to pay.If you do so,we cannot report you as delinquent without also calculate Interest charges.To find out more Information about the balance computation method that reporting thatyou are questioning your bill.We must tell you the name of anyone to whom we reported applies to your account and how the resulting interest charges were determined, contact us at you as delinquent,and we must let those organizations knew when the matter has been settled Customer Service number on the front. between us. Credit Reporting Disputes.If you think we reported inaccurate information to a credit bureau write If we do not follow all of the rules above,you do not have to pay the first$50 of the amount you us at the Customer Service address shown on the front. question even if your bill is correct. Report a Lost or Stolen Card Immediately. Call the Account inquiries number shown on Your Rights If You Are llissatieled With Your Credit Card Purchases the front. If you are dissatisfied with the goods or services that you have purchased with your credit card,and What To go If You find A Mistake Qn Your Statement you have tried in good faith to correct the problem with the merchant,you may have the right not to If you think there is an error on your statement,write to us at the address for billing inquiries and Ray the remaining amount 62 on the purchase. correspondence shown on the front of your statement. To use this right,all of the following must be true: In your letter,give us the following information: 1.The purchase must have been made in your home state or within 100 miles of our current •Account inforrnafion,Your name and account number. mailing address,and the purchase price must have been more than W.(Note:Neither of these •Dollar amount.The dollar amount of the suspected error. are necessary if your purchase was based on an advertisement we mailed to you,or if we own the •Description ofprahlem:if you think there is an error on your bill,describe what you believe is wrong company that sold you the goods or services.) and why you believe it is a mistake. 2.You must have used your credit card for the purchase.Purchases made with cash advances from You must contact us: an ATM or with a check that accesses your credit card account do not qualify. •Within 60 days after the error appeared on your statement. 3.You must net yet have fully paid for the purchase. •At least 3 business days before an automated payment is scheduled,It you want to stop payment on the amount you think is wrong. if all of the criteria above are met and you are still dissatisfied with the purchase,contact us in writing You must nodly us of any potential errors in wrifing.You may call us,but ff you do we are not required at the address for billing Inquiries and correspondence shown on the front of your statement, to investigate any potential errors and you may have to pay the amount in question. While we investigate,the same rules apply to the disputed amount as discussed above,After we finish our investigation,we will tell you our decision.At that point,ft 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 S 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. FdWetallq'i'ncluding ith edit approval for qualifying purchases made an The Home Depot or EXPO Design Center Consumer Credit Card,17.99%-26.99%APR.Minimum interest charge:$2.See card agreement for APR applicable to you.Offer is only valid for consumer accounts and is subject to change without notice. Important Payment instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance at any time. •Online Payments. Visit myhornedepotascourt.com and sign up for free online payments. However,you must pay,by the payment due date,at least the minimum payment due. Enrollment may take a few days,it we receive your request to make an online payment by 5 p.m. Crediting Payments.If we receive our mailed payment in proper form at our processing facility by Eastern time,we will credit your payment as of that day and it will post within three business days, 5 p.m.local time there,it will be creel ted as of that day.A payment received there In proper form after If we receive your request to make an online payment after that time,we will credit your payment as that time will be credited as of the next day,Allow 5 to 7 days for payments by regular mail to reach of the next day and It will post within three business days.For security reasons,you may be unable us.There may be a delay of up to 5 days in crediting a payment we receive that is not in proper form to pay your entire New Balance with your first online payment. or is not sent to the correct address.The correct addiess for regular mail is the address on the front of .Aaatr►Pay Service, If you are entailed in this service,your payment amount will be deducted shown below,the payment coupon.The correct address for courier or express mail is the Express Payments Address automatically each month on your due date from the bank account you select. Proper Form.For a payment sent by mail or courier to be in proper farm,you must: •Pay by Phone Service.You may use this service an time to make a payment by phone,if your • Enclose a valid check or move order made c account is eligible.You will be charged$14.95 to use t Is service If a representative of ours helps y payable to Home Depot Credit Services.No cash, expedite your payment.Call by 5 p.m,Eastern Time to have your payment credited as of that day and gift cards,or foreign currency please. posted within three business days.If you call after that time,your payment will be credited as of the • Include your name and account number on the front of your check or money order. next da and posted within three business days.We may process your payment electronically after If you send an eligible check with this payment cocappen,you authorize us to complete we vert>Yy your identity. your payment by electronic debit.If we do,the checking account will he debited in the *Express Paymeni s.You can send paymant by courier or express mail to the Express Payments amount on the check.We may do this as soon as the day we receive the check.Also, Address. This address is: Customer Service Center, Attention: Payment Mail Opening, 1500 the check will be destroyed. Boltonfield St.,Columbus,OH 43228. Payment must be received in proper form at the proper Capt'Fee.We charge$5 for each copy of a billing statement that dates back 3 months or more.We address by 5 p.m.Eastern time to be credited as of that day.All payments received in proper form at add the fee to a balance of our choosing.We reserve the right to add this fee to balances subject to a the proper address after that time will be credited as of the next day. higher annual percentage rate.We waive the fee if your request for the copy relates to a billing error or •In-Store Payments.For your added convenience,payments can be made at The Home D eta disputed purchase. stares,with no service fee.Any payment in proper farm accepted fn-store will be credited as of that day.However,credit availability may be subject to verification of funds. T02354-9196-0400-0002-E-o-X--07/01/06-77-113-P-B-0--7-8-0-NOPLAY-TC-02/24/12-H53B-December 25,2012-0-0 N--- HD/EX JUL12 Page 2 of 4 Account: **** **** **** 6807 •TRANSACTIONS cont. Trans Date Description INTEREST CHARGED Reference# Amount 01/25 INTEREST CHARGE ON PURCHASES TOTAL INTEREST FOR THIS PERIOD $ 34.51 $ 34.51 Total Fees Charged in 2013 � r"`- $35.00 Total Interest Charged in 2013 $34.51 INTEREST CHARGE CALCULATION Y P Of$ag Y`, sri►ttp1 p, Your Annual Percentage Rate(APR)is the annual interest rate on your account. PURCHASES .��Gettta `"v�� !�f', .�;�.� .� >.;� Revolvin Balance 25.99% M $1,563.7,4 $34.51 Page 3 of 4 S _ Account: **** **** **** 6807 t Clear. Conti Vie. �s to read. Clear: Statements are::wntten iri everyday language that you q be able to read and understand They show you exactly how'much you via: spent how much you owe wh2n,you awe,it and how long:it w11E take you to'pay;lt off The information is bucketed"into sections that make It easy to find what you're looking for and is wntten An normal everyday. language Eas to read.y ' Not only,are the words themselves easier to understand they re In a larger and easter to read type face. MW Alm OW Summary of Account Activlty Monthly account activity-payments, credits, fees, and interest charged Transactions ..� Account Number/Contact Information See clearly the activity that occurred to create your monthly Payment Information balance: purchases, payments Your balance, minimum payment and due date and credits, fees and interest Payment Calculator . for the billing period An estimated time it will take to pay off your balance when making the minimum payment Promotions Section and how much you should pay each month to pay off your balance in 36 months Customer-friendly summary so you know how your balance Account State m t was calculated and how your , .OVIca .�.�� a e.eoeo..eereew ..} �i IltO111RY sDOWNU HONE UEP,nALL"TX 75 payments are applied. �`°°°' Po fatraaoaa.o�uA9nc ysaasom a�.c � nquhlea: A000urR FDIm6ei9fiD9 ti°�1Y Promotions are also listed in the order of expiration ' sedrynaAccryanrd�ttV' µt?reuloue'Betarice !�mcrnt�*tzil'rr-sru;pn�--» = " s99,e9a.wNew Balance otAey Gedas 699,999.98 bwlYthart Sea,aea.9a Paymem ow ..... .. . :> Purchases 1� ':'b99,999.99... +s9a,999.e9 PaYmem Due Uate nt�lm 0,YM ,,. Feaa,�a'9 r tad. ..;M Ittwnat C0 N-r •� d ayrrrea:M we m not receive yourmamum paymerrt ..,. �1e the date HtW atrwa,YOU may have to wry a late tae up 0 a& .?'- 199,999 99 GarlHnttm Payment Wunlrr�a you mel.Dory the ndnlnaart peymat <a: Past Due Amoutd :.° �{ 588,989.98 r period,you wyl pay more F hlereet end n etln tela!ypa forger m PWaRYmebalar"Fa mangle; you rhexe.rro addhlon YOU wtil pay aq.tha 'AiM Suu wn Crena uma 59tl,899.&9 :m+mgea ueu,a.mle nerd oalaroo aa>frn'an mra ena tip,ppaayky,�s Uylt "ir'w.• ¢ Avalabb Crack 4if�,Aah irlo wu DeY-•,'ete0yhiard In a0out.. ded�natea btaT E YAS ._ - StawRNM ciftny Date "e �8.98B:99 abYh�minenum pay„�em peU, OeaeAP9!!v _ 'ly NmR9talamenf C4loWnB_Dare .< MMIDr�/YYyy afzare . >'a�TM M7D�KiHTnm�aLR�s AHO e6e+�In areal S In Bill z 9S aYev eevN UM'-'-- .ee,e ommor or" .To ewM eeenat ..: NONE MPOFr CNO1KA QACAEIXr �nm9 Atm WN-tPAVF�1$Eh�vwetanro .. 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HD/EX AUG 11 Page 4 of 4 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED OFFICE JF- THE PROTHONOTARY 2014 SEP 12 PM 3: 48 CUMBERLAND COUNTY PENNSYLVANIA czzom ni`�tin OFFICE OF THE SHERIFF Portfolio Recovery Associates, LLC vs. James R Quarles Case Number 2014-5070 SHERIFF'S RETURN OF SERVICE 09/05/2014 07:49 PM - Deputy Shawn Gutshall, 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: James R Quarles at 925 Brandywine Way, Hampden Township, Mechabur•, PA 17050. S AIS W HA -7; - - SHERIFF A— ;-- SHERIFF COST: $39.79 SO ANSWERS, September 08, 2014 (c) CountySuito Sheriff, Teleosofi, Inc. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire .-Mark k. Garvey, Esquire + t� Gregory J. Babcock, Esquire ; ; j 0 .,} Attorney ID # 94055/201259/312686/205061 t''',:..'.1 -11'' i U. Portfolio Recovery Associates, LLC �' l 10: la % 120 Corporate Blvd iu; !i:°�;;_ ,• 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. JAMES R QUARLES 925 BRANDYWINE WAY MECHANICSBURG PA 17050 Defendant No. 14-5070 PRAECIPE TO SETTLE DISCONTINUE AND END PLEASE MARK THE ABOVE -CAPTIONED ACTION AS SETTLED, DISCONTINUED AND ENDED. 16-16444 e ctfully 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 4roberr 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 : No. 14-5070 JAMES R QUARLES 925 BRANDYWINE WAY MECHANICSBURG PA 17050 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Settle Discontinue and End upon MATTHEW S. KUDRICK, ESQ. by First Class Mail, Postage Pre -Paid, a copy thereof on thi day of , 2014, to: MATTHEW S. KUDRICK, ESQ. 1 CO 16-16444 SE SQUARE, CA ,_,s'r PA 17013 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. Anv infnrmatinn nhtained will hp used fnr this nnrnnse