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Home My WebLink About14-5075 Supreme Court-of.Pennsylvania Cou WV8�1 Com�on Pleas Civil lk��W vel' e t For Prothonotary Use Only: IIMF STA-MP Docket No:: C U M )1-�D� County The information collected on this form is used solely for court administration purposes. This form does not supplenient or re lace the rlin and service of pleadincs or other a rs as required by law or rules of court. S Commencement of Action: E [N Complaint n Writ of Surarrions ❑Petition C ❑ Transfer from Another Jurisdiction C1 Declaration ofTaking T Lead Plaintiffs Name: Lead Defendant's Name:PORTFOLIO RECOVERY ASSOCIATES,LLC DEBRA D STINE 0 N Are money damages requested?0 Yes CI No Dollar Amount Requested: X within arbitration limits (Check one) i outside arbitration limits Is this a Class Action Suit? 0 yes 0 No Is this an AMJAppeal? 0Yes A ®No Narric ofPlainfifflAppellants Attorney.Robert N.Polas,Jr./Carrie Brownt Mark R.Garvey 0 Check here if you have no attorney(are a Self-Represented[Pro Sel Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. i TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS I E] Intentional ❑ Buyer Plaintiff Administrative Agencies lic E] Malicious Prosecution n Board of Assessment Malicious E❑ C] Mot Vehicle I Motor Vehicle 11 Debt Collection:Credit Card F1 Board of Elections 0 Nuisance ® Debt Collection:Other n Dept.of Transportation 0 Prernises Liability f-1 Statutory Appeal:Other S 0 Product Liability(does not include E "loss torr) [3 Eirployment Dispute: E] Slander/Libel/Delarnation Discrimination C E] Other: f-I Zoning Board T 0 Employment Dispute:Other n Other: E3 Other: 0 MASS TORT N 0 Asbestos [] Tobacco 0 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS 0 Toxic Tort-Implant o Ejectment F1 Common Law/Statutory Arbitration Ej Toxic Waste Ei Eminent Dornain/Condenrination f-1 Declaratory Judgment i El Other: 0 Ground Rent n Mandamus E] Landlord/Tenant Dispute n Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order El Mortgage Foreclosure:Commercial M Quo Wan-anto P [I Partition n Replevin PROFESSIONAL LIABILITY Ej Quiet Title n Other: 0 Dental 0 Other: 71 Legal El Medical El Other Professional: 16-05265 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 N _it,P ICE 120 Corporate Blvd r �'� SIO ,, . Norfolk, VA 23502 2014 Auc, TELE: 1-866-428-8102 ` ;a FAX:(757) 518-0860 C""BER j x ND 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 No. V(J S v� Plaintiff, V. DEBRA D STINE 600 FRANKLIN HTS APT 4 SHIPPENSBURG PA 17257 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 16 Carlisle, PA 17013 i6-05265 (717) 249-3166 60� c� fC.f�f- S 31�oL�S This communication is from a debt collector and is an attempt to collect a deb !_/ Any information obtained will be used for that purpose. � 4(�'Q 3 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. DEBRA D STINE 600 FRANKLIN HTS APT 4 SHIPPENSBURG PA 17257 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 16-05265 (717) 249-3166 Esta connmicacion es de un cobrador de deudas y es un intent do cobrar una deuda. Cualquier.inkonlacion.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. DEBRA D STINE 600 FRANKLIN HTS APT 4 SHIPPENSBURG PA 17257 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, DEBRA D STINE, is an adult individual with last known address of 600 FRANKLIN HTS APT 4, SHIPPENSBURG PA 17257. 3. It is averred that Defendant was indebted to CITIBANK, N.A. / SEARS on December 23, 2006 with account number ************7891 (hereafter referred to as "Account"). 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. This communication is from a debt collector and is an attempt to collect a debt. Any in.1brznation 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 May 18, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK, N.A. / SEARS and Plaintiff is now the holder of the Account. A true and correct copy of the 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$4,224.65. 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, DEBRA D STINE , in the ou of$4,224.65, plus c s this action and any other relief as the Court deems just and reas abl arrie A. Brown, Esquire, #94055 Robert N. Polas, Jr., Esquire, #201259 Mark R. Garvey, Esquire, #312686 Attorneys for Plaintiff 16-05265 This corm-nun.ication is from a debt collector and is an attempt to collect a debt. Any inibrrnation obtained will be used f:or that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Elaine Freeman-Lark hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: JUL. 10 2014 By: C Elaine Freeman-Lark Custodian of Records 16-05265 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. V t XHIBI A WOJVVVVVV This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. t %DQ�FiSIICIIt•'�� • �QGt1C12CAt•�: ` NM I+I`";:Wired it Clr N. 2 I N.A. :n�tiQ��l..b��g as�o�iat�gn..o.�g �I.'�uat��:.t��-:��vVs:;ci�'�he• ni � '� a go. fixC, ak`' to•Pztai T3= 4Ycry°: isscals ` ; ' 3 organs4�r the lands :0. •r i o,aware; t 1mseatiquarEepra place - L { C.. L(d1S1blS;Q . 1L; !t18$:G `=tdBCtlx1 Feuary5,_ OI ;�btWeet�' y,ter and`fhe' 8I2�C rrA, ST1SC1' SG'II•:: ( ' . . IP�'B !lOf:Si1cE: , r. , assi canv .;baa, sl •queer rad :dtrt' u r. . xe . a Ye ; P.,� to BOY.`at�d:t ;f t8t�eTcfi�oru1e ClAitfik, ��e ;__ :�at3ica�•�•all - . P. :nlSt3SRS R 8 6 z :: . . . ': ': •• .. .. .. .. .. .. .. . . . ... EX8ffiIZ'1 . .: � •:•:: . :•.: .. ::� ASSET�SCHEDUi,, : .The individual accounts transferred-are described:in;the final'elecbroriic file:acid delivered.by fire ; t'a Buyer,the samedeemed aitachei :hereto by thi 'referenc . ' # of Sale cut-off Lot Sale ID Accounts Rates Sale Balance Date Sears Early 03/11/13 Out - -__ :: .. MasterCard Sears Early 03/11/13 Out Private ..'.•.�. Label : : :•. . . .:. FRA'02251 Account Statement SEARS CR DTNotice of ICARDS ling Errors arid Customer Customer Service: Sears K Sears Card' searscard.com PO Box 6283,Sioux Falls,SD 57117-6283 kwmrt Account Inquiries: - - 1-800-917-7700 Accou»t Numkier 7891. Summa of Account Activit Previous Balance Payment Information Pa ments $4,103.57 New Balance Other Credits -$0.00 Minimum Payment Due $4 2A Purchases -$0.00 Payment Due Date $1 1 [New ash Advances +$0.00 January 25, ees Char ed +$0.00 Late Payment Warning: If we do not receive your minimum payment by the +$35.00 date listed above,you may have to pay a late fee up to$35. terest Char ed +$86.08 Minimum Payment Warning: If you make only the minimum payment each Balance $4,224.65 period,you will pay more in interest and it will take you longer to pay off our st Due Amount balance.For example: y $1,017.05 ff you make no additional -You wdl a off:the P y `.:And you,will charges.using this card balance shown on tills end up paying an anti r3aoh month you pay staterrtieht 177 about: estimated:Total Credit Limit Al2/28/2012 Only the minimum payment 15 years Available Credit $9,469 Amount Over Credit Limit $169 $6,066 3 years Statement ClosingDate (Savings=$3,403) If you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closin Date Das in Billin C cle Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately. TRANSACTIONS Trans Date Description FEES Reference# Amount 12/25 LATE FEE TOTAL FEES FOR THIS PERIOD $ 35.00 INTEREST CHARGED $ 35.00 12/28 INTEREST CHARGE ON PURCHASES TOTAL INTEREST FOR THIS PERIOD $ 86.08 $ 86.08 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 4 8 SE 19 ----------------------------- This Account- Issued - Citibank,N.A. ------------------------------------------------------------------------ '�'Please detach this portion and return with your payment to insure Sears Card® pro per credit. Retain upper gonion for your records.T tPast Due Amount is included In the Minimum Payment Due. -Your,Account Number•.• Payment Due Date New Balance Past Due Amountt Minimum:Pay:nmen:tD]ueAmount Enclosed JANUARY25,2013 $4,224.65 $1,017.05 $1 $ 7891 Make Checks Payable to: SEARS CREDIT CARDS DEBRA D STINE PO BOX 183081 600 FRANKLIN HTS APT 4 COLUMBUS,OH 43218-3081 SHIPPENSBURG,PA 17257-1656 Print address changes above in blue or black ink. Information About Your Account. What Will Happen After We Receive Your tetter How to Avoid Paying Interest on Purchases.Your payment due date is at least When we receive your letter,we must do two things: 25 days after the close of each billing cycle. We will not charge you any interest on I. Within 30 days of receiving pdrehases if you pay your New Balance by the payment due date each month, y 9 your letter,we must tell you that we received This is called a grace period on purchases. If you do not pay the New Balance in your letter.We will also tell you if we have already corrected the error. full by the payment due date,you will not get a grace period on purchases until 2. Within 90 days of receiving your letter,we must either correct the error or you pay the New Balance in full for two billing cycles in a row. We will begin explain to you why we believe the bill is correct. charging interest on cash advances and balance transfers(if available on your While we investigate whether or not there has been an error: account)on the transaction date. . We cannot If you have a balance subject to a deferred interest promotion and that promotion that amou try to collect the amount in question,or report you as delinquent on does not expire before the payment due date,that balance(the"excluded The charge in question may remain on your statement,and we may promotional balance")is excluded from the amount you must pay in full to get a continue to charge you interest on that amount, grace period. However,you must still pay any separately required payment on the While you do not have to pay the amount in question,you are responsible excluded promotion.In billing cycles in which payments are allocated to deferred for the remainder of your balance. interest balances first,the deferred interest balance will be reduced before any ' We can apply any unpaid amount against your credit limit. other balance on the account.However,you will continue to get a grace period on After we finish our investigation,one of two things will happen: purchases so long as you pay the New Balance less any excluded promotional balances in full by the payment due date each billing cycle. If we made a mistake:You will not have to pay the amount in question or any In addition,certain promotional offers may take away the grace period on interest or other fees related to that amount. purchases. Other promotional offers not described above may also allow you to if we st not believe there was l mistake.,You will have w pay the amount have a grace period on purchases without having to pay all or a portion of the t question,along with applicable interest and fees.We will send you a promotional balance by the payment due date. If either is the case,the statement of the amount you owe and the date payment is due.We may then promotional offer will describe what happens. report you as delinquent if you do not pay the amount we think you owe. How We Calculate Your Balance Subject to Interest Rate.We use a daily If You receive our explanation but still believe your bill is wrong,you must write to balance method(including current transactions)to calculate interest charges-To us within 10 days telling us that you still refuse to pay.if you do so,we cannot find out more information about the balance computation method and how the report you ll delinquent without also reporting that you are questioning your bill, resulting interest charges were determined,contact us at the Account Inquiries We must tell you the name of anyone to whom we reported you as delinquent,and number on the front, we must let those organizations know when the matter has been settled between Balance Transfers.Balance transfer amounts are included in the"Purchases"line us. in the Summary of Account Activity(if balance transfers are available on your If we do not follow all of the rules above,you do not have to pay the first$50 of account), the amount you question even if your bill is correct. Transaction Date.The Transaction Date shown on the statement is also the Sale Your Rights H You Are Dissatisfied With Your Credit Card Purchases Rate. If you are dissatisfied with the goods or services that you have purchased with Credit Reporting Disputes.If you think we reported inaccurate informationto a your credit card,and you have tried in good faith to correct the problem with the credit bureau write us at the Customer Service address shown on the front. merchant,you may have the right not to pay the remaining amount due on the Report a Lost or Stolen Card Immediately.Call the Account Inquiries number purchase. shown on the front. To use this right,all of the following must be true: What To Do if You Find A Mistake On Your Statement 1. The purchase must have been made in your home state or within 100 If you think there is an error on your statement,write to us at the address for miles of your current mailing address,and the purchase price must have billing inquiries and correspondence shown on the front of your statement. been more than$50.(Note:Neither of these are necessary f your purchase was based an advertisement ry mailed to you,or if we own In your letter,give us the following information: the company that soldld you the goods or services.) • Account information:Your name and account number. 2. You must have used your credit card for the purchase.Purchases made with Dollar amount:The dollar amount of the suspected error. cash advances from an ATM or with a check that accesses your credit card Description of problem:If you think there is an error on your bill, account do not qualify. describe what you believe is wrong and why you believe it is a mistake. 3. You must not yet have fully paid for the purchase. You must contact us: If all of the criteria above are met and you are still dissatisfied with the purchase, • Within 60 days after the error appeared on your statement. contact us in on the front owritif yo usttthe a dress for billing inquiries and correspondence shown • At least 3 business days before an automated payment is scheduled,if you want While we investigate,the same rules apply to the disputed amount as discussed to stop payment on the amount you think is wrong. You must notifyus of an ifwe think you owe an amount ater we finish our nyou investigation,we will tell you our decision.At that point, y potential errors in writing.You may call us,but if you do you do not pay, we may report you as we are not required to investigate any potential errors and you may have to pay delinquent. the amount in question. EM SMC-TGI-SCC-SCP-HIPs 07112 T02388-9351-5000-4001-P-E-9-X--12/01/06-95--P-E-0--7-402-0-0----12/04/12-PKKB-November 28,2012-0-0-V N--- Important Payment Instructions. Payment Options Other Than Regular Mail. Right to Prepay Your Account.You may pay all or part of your account balance In-Store Payments(Where Available).Any payment in proper form accepted at any time.However,you must pay,by the payment due date,at least the minimum payment due. in-store will be credited as of that day.However,credit availability may be subject r verification of funpd y Not all stores accept payments.Contact your Crediting Payments.If we receive your payment in proper form at our processing local stare to see if in-store a ments are accepted at that location. facility by 5 p.m.local time there,it will be credited as of that day. A payment Online Payments.Visit the web address on the front and sign up for online received there in proper form after that time will be credited as of the next day. payments. Enrollment may take a few days. If we receive your request to make Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay an online payment by 5 p.m.Eastern time,we will credit your payment as of of up to 5 days in crediting a payment we receive that is not in proper form or is that day.If we receive your request to make an online payment after that time, not sent to the correct address. The correct address for regular mail is the we will credit your payment as of the next day.For security reasons,you may be address on the front of the payment coupon.The correct address for courier or unable to pay your entire New Balance with your first online payment. express mail is the Express Payments Address shown below. AutoPay Service.If you are enrolled in this service,your payment amount will Proper Form,For a payment sent by mail or courier to be in proper form,you must: be deducted automatically each month on your due date from the bank account • Enclose a valid check or money order.No cash,gift cards,or foreign Vou select. currency please. Pay by Phone Service.You may use this service any time to make a payment Include your name and account number on the front of your check or money by phone.You will be charged$14.95 if a representative of ours helps expedite order. V your payment.Call by 5 p.m.Eastern time to have your payment credited as of If you send an eligible check with this that day.If you call after that time,your payment will be credited as of the next complete our Payment coupon,you authorize us to day.We may process your payment electronically after we verify your identity. P Y payment by electronic debit.If we do,the checking account will Express Payments.You can send payment by courier or express mail to the be debited in the amount on the check.We may do this as soon as the day we Express Payments Address.This address is: Payments Department,1500 receive the check.Also,the check will be destroyed. Boltonfield Street,Columbus,OH 4322$, Payment must be received in proper Copy Fee.We charge$3 for each copy of a billing statement that dates back 3 form at the proper address by 5 p.m.Eastern time to be credited as of that day. months or more.We add the fee to the regular purchase balance.We waive the fee All payments received in proper form at the proper address after that time will if your request for the copy relates to a billing error or disputed purchase. be credited as of the next day. Page 2 of 4 Account: **** **** **** 7891 ETotaToMl, -Yeat=to Date l Fees Charged in 2012 $235.00 Interest Charged in 2012 $931.74 EPURCHASES REST CHARGE CALCULATION rtoe SubJect to interestRate Interest Char o`f;Bal�rt.6 ` Yo uaPercentage A'nnuatPercenta a Rate.APIA 9.. ,. YourAnnual Rate APR is the annual interest rate on our account. GULAR 25.24% D V ariable RaterD =Dai $4J49.65 $86.08 Page 3 of 4 Account: **** **** **** 7891 Page 4 of 4 Carrie AOroW'F, 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 7 1-71_ CD- OFFICE 115- PRO rfloNoTARY i,t0L/ JO CO7 P.:BERL Y P Os 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. DEBRA D STINE 600 FRANKLIN HTS APT 4 SHIPPENSBURG PA 17257 Defendant To the Prothonotary: No. 14-5075 CIVIL PRAECIPE TO DISCONTINUE Please mark the above -entitled case as discontinued without prejudice. 16-05265 ully Submitted, Aor/f/Ase/ ert 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. Carne A. Ip►rown, 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. DEBRA D STINE 600 FRANKLIN HTS APT 4 SHIPPENSBURG PA 17257 Defendant : No. 14-5075 CIVIL CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praecipe to Discontinue upon DEBRA D STINE, by First Class Mail, Postage Pre -Paid, a copy thereof on this / day of 16-05265 , 2014, to: DEBRA D STINE, 600 FRANKLIN HTS SHIPPENSBURG ' • 257 rr/// ort 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.