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Home My WebLink About14-5078 Supreme Court of Pennsylvania Court Of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S E Lead Plaintiff's Name: Lead Defendant's Name: CRAIG R CYPHERS C PORTFOLIO RECOVERY ASSOCIATES LLC Are money damages requested? ® Yes ❑No Dollar Amount Requested: ® within arbitration limits (Check one) ❑ outside arbitration limits O (1j Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: Syretta Martin, Frank Janello, Beth Arnold Howell/Greg Dye ❑ 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 .Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability tdoes not include ❑Employment Dispute: mass tort) C ❑ Slander/Libel/Defamation Discrimination T ❑ Other: ❑Employment Dispute: Other ❑ Zoning Board 1 ❑ Other: O N ElOther: MASS TORT ❑ Asbestos ❑ Tobacco B ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partion ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111120 2931517 PPTXCPRI(05/06/2014) 111111111 VIII 111111111111111111 VIII 1111111111 VIII VIII VIII 111111111 IIII Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, 1835 Market Street, Suite 501 PORTFOLIO RECOVERY ASSOCIATES LLC Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION ` CRAIG R CYPHERS _ J 0-3 �m 31 GREENMONT DR ENOLA PA 17025co CD Defendant. - �� C �f _NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 Ct1 C 2931517 PPTNPRAI (04/24/2014) I IIIIIIII VIII III)IIIIII II IIIIII VIII VIII VIII VIII VIII VIII IIIIIII II IIII IJ AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notification. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 800-990-9108 Syretta Martin, Esq. PA Bar #309370 Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 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. CRAIG R CYPHERS 31 GREENMONT DR ENOLA PA 1.7025 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(s), CRAIG R CYPHERS, is/are an adult individual with last known address of 31 GREENMONT DR ENOLA PA 17025. 3. It is averred that Defendant(s) opened an account on 09-12-02 with account number XXXXXXXXXXXX0086 (hereafter referred to as "Account"). A copy of the charge-off statement is attached hereto and collectively marked as Exhibit "A". 4. By using the Account, Defendant(s) agreed to repay any incurred balances, charges and/or cash advances made to the Account. Failure to pay Defendant(s) incurred charges on the Account is considered a default. 2931517 PPTCPRAI (05/27/2014) (IIIIIIII VIII IIII IIIIII II IIIIII VIII VIII VIII VIII VIII VIII IIIIIII II IN 5. At all relevant times material hereto, Defendant(s) has used said Account for the purchase of products, goods, and/or for obtaining services. 6. Defendant(s) was provided with copies of Account statements showing debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant(s). 7. Defendant(s) was in default with respect to that debt for failure to make the required payments on the Account. The last payment date on this Account was on or about 08-10-2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest of CITIBANK, N.A. and Plaintiff is now the holder of the Account. A true and correct copy of Plaintiff's Verification is attached hereto. 9. As of the date within the Complaint, the remaining balance due, owing and unpaid of Defendant(s) Account, as a result of Defendant(s) and/or any authorized user's of said Account is in the sum of $2520.19. 10. Despite reasonable and repeated demands for payment, Defendant(s) has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all of the damage and detriment of the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant(s) CRAIG R CYPHERS, in the amount of $2520.19, plus costs of this action and any other relief as the Court deems just and reasonable. Respectfully Submitted, Dated: Syretta Martin, Es Bar #309370 Frank Janello, Es> - PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 800-850-1079 FAX: (215) 564-3818 Attorneys For Plaintiff BHLM REF #: 2931517 VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Donna Dangerfield 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: JUN 2 6 2014 By: v Donna Dangerfield Custodian of Records BHLM REF #: 2931517 PPTXPVRI (05/27/2014) Exhibit " A " 2931517 PPTXEXAI ( 04/17/2014 ) Account Statement Send Notice of Billing Errors and Customer Service Inquiries to: 6 Customer service: CITI MASTERCARD mastercard.citicards.com PC Box 6403,Sioux Falls SD,57117-6403 aff Account Inquiries: 1-888-316-8480 Account NtiYtber 0086 Summary of Account Activity Payment Information Previous Balance $2,437.65 New Balance $2,520.19 Payments -$0.00 Minimum Payment Due $833.00 Other Credits -$0.00 Payment Due Date March 21, 2013 Purchases +$0.00 Cash Advances +$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 +$47.54 Minimum Payment Warning: If you make only the minimum payment each New Balance $2,520.19 period,you will pay more in interest and it will take you longer to pay off your balance.For example: Past Due Amount $725.00 tf you make no'addttisinaI Yoi' 9 p ff the And w111: chatges using this rArr;' batai ce shown an trGs endue pOW4,arY Credit Limit $0.00 and eaoh rtlorith;you pay 'statement t7i'?about sstirrw6d totaFat Available Credit 0.00 _ ... . Cash Advance Limit $0.00 Only the minimum payment 11 years $5,063 Available Cash Limit $0.00 $100 3 years $3,615 Amount Over Credit Limit $0.00 (Savings=$1,448) Statement Closing Date 02/22/2013 if you would like information about credit counseling services,call 1-877-337-8188. Next Statement Closing Date 03/25/2013 Das in Billing Cycle 28 Please see the enclosed privacy notice for important information. TRANSACTIONS Trans Date Description Reference# Amount FEES 02/21 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD $ 35.00 8 GP 16 NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Page 1 of 6 This Account is Issued by Citibank,N.A. ----------------------------------------------------------------------------------------------------------------------------- 9 Please detach this portion and return with your payment to insure proper credit. Retain upper portion for your records.T' CI I tPast Due Amount is included in the Minimum Payment Due. tl Your.Account Number' Payment Due Date New Balance Past Due Amountt Minimum Payment Due Amount Enclosed 0086 MARCH 21,2013 $2,520.19 $725.00 $833.00 $ 0086 Make Checks Payable to: CITI MASTERCARD PO BOX 183016 CRAIG R CYPHERS COLUMBUS,OH 43218-3016 31 GREENMONT DR ENOLA,PA 17025-2644 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. You can avoid interest charges on 1. Within 30 days of receiving your letter,we must tell you that we received purchases,but not on balance transfers and cash advances.This is called a grace your letter.We will also tell you if we have already corrected the error. period on purchases.To get the grace period on purchases,pay the Net New 2. Within 90 days of receiving your letter,we must either correct the error or Balance in full by the payment due date every billing cycle.The Net New Balance is: explain to you why we believe the bill is correct. • The New Balance plus While we investigate whether or not there has been an error: • Any additional amount required by a promotional offer as part of the Minimum We cannot try to collect the amount in question,or report you as delinquent on Payment Due,minus that amount. Any 0%promotional balances that expire after the Next Statement Closing The charge in question may remain on your statement,and we may Date. (0%promotional balances do not include balance transfers and cash continue to charge you interest on that amount. advances.) While you do not have to pay the amount in question,you are responsible If you do not,you will not get a grace period until you pay the Net New Balance in for the remainder of your balance. full for two billing cycles in a row.Other promotional offers may also allow you to We can apply any unpaid amount against your credit limit. have a grace period on purchases without having to pay all or a portion of the After we finish our investigation,one of two things will happen: promotional balance by the payment due date. In addition,certain promotional offers may take away the grace period on purchases. If either is the case,the If we made a mistake:You will not have to pay the amount in question or any promotional offer will describe what happens. interest or other fees related to that amount. If we do not believe there was a mistake:You will have to pay the amount How We Calculate Your Balance Subject to Interest Rate.We use a daily in question,along with applicable interest and fees.We will send you a balance method(including current transactions)to calculate interest charges.To statement of the amount you owe and the date payment is due.We may then find out more information about the balance computation method and how the report you as delinquent if you do not pay the amount we think you owe. resulting interest charges were determined,contact us at the Account Inquiries If you receive our explanation but still believe our bill is wrong,number on the front. p y g,you must write to Balance Transfers.Balance transfer amounts are included in the"Purchases"line us within 10 days telling us that you still refuse to pay.If you do so,we cannot in the Summary of Account Activity(if balance transfers are available on your report you as delinquent without also reporting that you are questioning your bill. account). We must tell you the name of anyone to whom we reported you as delinquent,and we must let those organizations know when the matter has been settled between Rates.Variable APRs will vary with the market based on the Prime Rate. us. Credit Reporting Disputes.If you think we reported inaccurate information to a If we do not follow all of the rules above,you do not have to pay the first$50 of credit bureau write us at the Customer Service address shown on the front. the amount you question even if your bill is correct. Report a Lost or Stolen Card Immediately.Call the Account Inquiries number Your Rights If You Are Dissatisfied With Your Credit Card Purchases shown on the front. If you are dissatisfied with the goods or services that you have purchased with What To Do if You Find A Mistake On Your Statement your credit card,and you have tried in good faith to correct the problem with the If you think there is an error on your statement,write to us at the address for merchant,you may have the right not to pay the remaining amount due on the billing inquiries and correspondence shown on the front of your statement. purchase. In your letter,give us the following information: To use this right,all of the following must be true: • Account information:Your name and account number. 1. The purchase must have been made in your home state or within 100 Dollar amount:The dollar amount of the suspected error. miles of your current mailing address,and the purchase price must have • Description of problem:if you think there is an error on your bill, been more than$50.(Note:Neither of these are necessary if your describe what you believe is wrong and why you believe it is a mistake. purchase was based on an advertisement we mailed to you,or if we own the company that sold you the goods or services.) You must contact us: 2.You must have used your credit card for the purchase.Purchases made with • Within 60 days after the error appeared on your statement. cash advances from an ATM or with a check that accesses your credit card • At least 3 business days before an automated payment is scheduled,if you want account do not qualify. to stop payment on the amount you think is wrong. 3. You must not yet have fully paid for the purchase. You must notify us of any potential errors in writing.You may call us,but if you do If all of the criteria above are met and you are still dissatisfied with the purchase, we are not required to investigate any potential errors and you may have to pay contact us in writing at the address for billing inquiries and correspondence shown the amount in question. on the front of your statement. 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, if we think you owe an amount and you do not pay, we may report you as delinquent. Prism 07112 T02380-1215-0020-0200-E-9-D--09/01/02-72-000-P-E-0--7-0-0-MCSPECT2-T7-01/26/13-P6UB-January 25,2013-" N-- Important Payment Instructions. Copy Fee.We charge$5 for each copy of a billing statement that dates back 3 Right to Prepay Your Account.You may pay all or part of your account balance months or more.We add the fee to the regular purchase balance.We waive the fee at any time.However,you must pay,by the payment due date,at least the if your request for the copy relates to a billing error or disputed purchase. minimum payment due. Payment Options Other Than Regular Mall. Crediting Payments.If we receive your payment in proper form at our processing AutoPay Service.If you are enrolled in this service,your payment amount will facility by 5 p.m,local time there,it will be credited as of that day.A payment be deducted automatically each month on your due date from the bank account received there in proper form after that time will be credited as of the next day. you select. Allow 5 to 7 days for payments by regular mail to reach us.There may be a delay Pay by Phone Service.You may use this service any time to make a of up to 5 days in crediting a payment we receive that is not in proper form or is payment by phone.You will be charged$14.95 if a representative of ours not sent to the correct address. The correct address for regular mail is the helps expedite your payment.Call by 5 p.m.Eastern time to have your address on the front of the payment coupon.The correct address for courier or payment credited as of that day.If you call after that time,your payment express mail is the Express Payments Address shown below. will be credited as of the next day.We may process your payment Proper Form.For a payment sent by mail or courier to be in proper form,you must: electronically after we verify your identity. • Enclose a valid check or money order.No cash,gift cards,or foreign Express Payments.You can send payment by courier or express mail to currency please. the Express Payments Address.This address is:Payments Department, Include your name and account number on the front of your check or money 1500 Boltonfield Street,Columbus,OH 43228.Payment must be received order. in proper form at the proper address by 5 p.m.Eastern time to be credited If you send an eligible check with this payment coupon,you authorize us to as of that day.All payments received in proper form at the proper address complete your payment by electronic debit.If we do,the checking account will after that time will be credited as of the next day. be debited In the amount on the check.We may do this as soon as the day we receive the check.Also,the check will be destroyed. Page 2 of 6 Account: **** **** '*** 0086 TRANSACTIONS(cont.) Trans Date Description Reference# Amount INTEREST CHARGED 02/22 INTEREST CHARGE ON PURCHASES $ 43.42 02/22 INTEREST CHARGE ON CASH ADVANCES $ 4.12 TOTAL INTEREST FOR THIS PERIOD $ 47.64 201�;�`otals Year—to��ate Total Fees Charged in 2013 $70.00 Total Interest Charged in 2013 $98.44 INTEREST CHARGE CALCULATION Your Annual Percentage Rate(APR)is the annual interest rate on your account. Type ot_BalanCe _ AilnualPe'centagg Rate_(APS) Balance;.SubJect to interest Rata lnter $t Charge. PURCHASES REGULAR 24.99% M $2,265.03 $43.42 CASH ADVANCES REGULAR 27.15% M $197.94 $4.12 Page 3 of 6 Account: **** **** **** 0086 Page 4 of 6 01/13 075 =�-�WHAT DOES CITIBANK DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. ' Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share,and protect your personal information. Please read this notice carefully to understand _. what we do. ......... .. . .. . _ � ) The types of personal information we collect and share depend on the s product or service you have with us. This information can include: •Social Security number and income F •account balances and employment information 4 •credit history and transaction history All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information;the reasons Citibank chooses to share;and whether you can limit this sharing. For our everyday business purposes — such as to process your transactions, I maintain your account(s), respond to court Yes No i orders and legal investigations,or report to credit bureaus For our marketing purposes — to offer our products and services to you Yes No For joint marketing with other financial companies Yes No _ ..... . ... ... _.... ... .. . . . ..... For our affiliates' everyday business purposes — information about your Yes No transactions and experiences For our affiliates' everyday business purposes — information about your Yes Yes creditworthiness ......_.... .. . _ _. l For our affiliates to market to you Yes Yes _....._. . _........_ _..._.. ..... ........ ........ ........ ................. .. .._....__ For our nonaffiliates to market to you Yes Yes ........................ ........ ............................. ......................................_................._ .. . Call 1-877-491-0608 — our menu will prompt you through your choice(s). Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer,we continue to share your information as described in this notice. However, you can contact us any time to limit our sharing. Call 1-877-491-0608 or call the Customer Service number on the back of t` your credit card or on your billing statement. Page 5 of 6 01/13 a 076 .Who is providing You are receiving this notice from the retail partner cards group of this notice? Citibank, N A., the bank that issues your credit card. ... _.......... ! How does Citibank To protect your personal information from unauthorized access and use,we protect my personal =use security measures to comply with federal law.These measures include information? computer safeguards and secured files and buildings. How does Citibank We collect your personal information,for example,when you collect my personal •provide account information or give us your contact information Information? •provide employment information or apply for a loan • use your credit or debit card We also collect your personal information from others, such as credit i bureaus, affiliates, or other companies. ...._.... _ . _... _ ....__._....i Why can't I limit t Federal law gives you the right to limit only ;all sharing? •sharing for affiliates'everyday business purposes — information about your creditworthiness •affiliates from using your information to market to you •sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit i sharing. See below for more on your rights under state law. Affiliates f Companies related by common ownership or control.They can be financial and nonfinancial companies. k '•Our affiliates include companies with a Citi name,financial companies such as Citigroup Global Markets Inc. and Banamex USA. ... .. .. . . .... . . ........... . . .. ..........; te Nonaffiliates -Companies not related by common ownership or control.They can be financial and nonfinancial companies. •Nonaffiliates we share with can include companies engaged in direct marketing and the selling of consumer products and services. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products and services to you. ...... ... ......... ..._...... ... . , For Vermont Residents: We will not share information we collect about you with nonaffiliated third', parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account.In addition,we will not share information about your creditworthiness with our affiliates except with your authorization. I For California Residents: We will not share information we collect about you with nonaffiliated third; parties,except as permitted by California law,such as to process your transactions or to maintain your; account. We may share your personal information, as permitted by law,with the retailer whose name is on your card and with the companies related to the retailer.You cannot limit this sharing. Important Information about Credit Reporting We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. .. Page 6 of 6 Syretta Martin, Esq. PA Bar #309370 . Frank Janello, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 r � �../,.L-r Greg Dye, Esq. PA Bar #205316 Rij oT OPCO' Blatt, Hasenmiller, Leibsker & Moore, LLCi -r 1835 Market Street, Suite 501AUGf2� Philadelphia, PA 19103 Pfl 2: 2 f TELE: 215-564-1567 FAX: 215-564-3818 C}1f119 rR5,,jjVNT rLVA jj6 �' PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. (� L✓l qi CRAIG R CYPHERS No. 5o�� O 31 GREENMONT DR ENOLA PA 17025 Defendant(s). PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 BLATT, HASENMILLER, LEI E & MOORE, LLC Dated: L By: Syretta Mar ' , Esq. PA Bar #309370 �• Frank Jap6llo, Esq. PA Bar #315643 Beth Arnold Howell, Esq. PA Bar #203606 Greg Dye, Esq. PA Bar #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 TELE: 215-564-1567 FAX: 215-564-3818 Attorneys For Plaintiff 2931517 PPTXPEAI (05/12/2014) 11111111111111 IN 11111111111111111111111111111111111111111111111111111 IN Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �t Citktber OFFiCE 11-4E t=tiEFtiFr ?E14 SEP .23 411 16: 00 UNRERLAt/ PENN S YI.VANIa) COUNfl Portfolio Recovery Associates, LLC vs. Craig Cyphers Case Number 2014-5078 SHERIFF'S RETURN OF SERVICE 09/11/2014 07:03 PM - Deputy Jamie DiMartle, 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: Craig Cyphers at 31 Greenmont Drive, East Pennsboro, Enola, PA 17025. IE DIMARTLE, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, September 16, 2014 RON1V R ANDERSON, SHERIFF CouritySuite Sheriff, Teleoseft, Inc.