HomeMy WebLinkAbout14-6965 Supreme Co sof.Pennsylvania
COUI�8 C-o fi .:on Pleas
���J/,., �rd�v", For Prothonotary Use Only. TIME STAMP
P
ClV°ll OVei�"ll a Docket No:
CUM� Count
Y
The information collected on this form is used solely for court administration purposes. This fonn does not
supplement or replace the Cling and service o leadin s or other a ers as required by law or rules of court.
Commencement of Action:
S ® Corrplaint ❑ Writ of Summons ❑Petition
E ❑ Transfer from Another Jurisdiction []Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
PORTFOLIO RECOVERY ASSOCIATES,LLC MCOLECARNEY
T
I Dollar Amount Requested: X within arbitration limits
O Are money damages requested. ® Yes ❑ No q —
(Check one) outside arbitration limits
N
Is this a Class Action Suit? ❑Yes ®No Is this anAMJAppeal? ❑Yes ®No
A Name of PlaintifVAppellanfs Attorney:Robert N.Polar Jr./Carrie Brown/Mark R Garvey/Gregory J.Babcock
❑ 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.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
r-1Malicious Prosecution E] Board ofAssesstrent
❑ Motor Vehicle ❑ Debt Collection:Credit Card ❑ Board of Elections
❑ Nuisance ® Debt Collection:Other ❑ Dept.of Transportation
❑ Premises Liability ❑ Statutory Appeal:Other
❑ Product Liability(does not include
S mass tort) ❑ Employment Dispute:
E ❑ Slander/Libel/Defamation Discrimination ElZoning Board
❑ Other: ❑ Employment Dispute:Other ❑ Other:
C
T ❑ Other:
I MASS TORT
Q ! ❑ Asbestos
b
❑ Tobacco N REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort-DES
❑ Toxic Tort-Implant ❑ Ejectment E] Common Law/Statutory Arbitration
r-1 Toxic Waste E] Eminent Domain/Condemnation ElDeclaratory Judgment
C] Other: ❑ Found Rent ❑ 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:
17-10279
Robert N. Polas, Jr., Esquire PA Bar.#201259
Carrie Brown, Esquire PA Bar#94055
Mark R. Garvey, Esquire PA Bar#312686 + r
Gregory J. Babcock Esquire PA Bar#205061
q
Portfolio Recovery Associates, LLC AN 10; 36
120 Corporate Blvd 'J"'' t=i?L
Norfolk, VA 23502 t,r.'f) r-�I'',f_
p't1d ' YC. • I rc 1 Z
TELE: 1-866-428-8102
FAX: (757) 518-0860
Attorne s for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CML ACTION-LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD No
NORFOLK, VA:23502 lY
NORF ,
P laintiff,
v.
NICOLE CARNEY
9 GRINNEL DR
CAMP HILL PA 17011
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
against you by the Court without further notice.of
proceed without you and a judgment may be entered
any money claimed or any other claim or relief requested by the Plaintiff. You may.lose money or
property rights important to you.
UR LAWYER AT:ONCE. IF YOU DO NOT HAVE A
YOU SHOULD TAKE THIS PAPER TO YO
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
'i 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 S
Carlisle,PA 17013
(717)249-3166
17-10279
0 L 95-
This communication is from a debt collector and is an attempt to collect a debt.R-4
��
31a ;
j 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
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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CML ACTION - LAW
PORTFOLIO RECOVERY ASSOCIATES, LLC
120 CORPORATE BLVD
NORFOLK, VA 23502
Demandante, No.
V.
NICOLE CARNEY
9 GRINNEL DR
CAMP HILL PA 17011
Demandado.
NOTICIA
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas
en la's 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
17-10279
Esta comunicacion es de un cobrador de deudas y es tui intent do cobrar una deuda.
Cualquier.infromacion sera utilizada para ese proposito.
r
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 r
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.
NICOLE CARNEY
9 GRINNEL DR
CAMP HILL PA 17011
Defendant.
COMPLAINT
t
1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with
offices located at 120 Corporate Blvd, Norfolk, VA 23502.
2. Defendant, NICOLE CARNEY, is an adult individual with last known address of 9 GRINNEL
DR, CAMP HILL PA 17011.
3. It is averred that Defendant was indebted to CITIBANK, N.A. /CITIBANK, N.A. /THE HOME
DEPOT on April 24, 2007 with account number ************5372 (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 coirnnunication is fro-in a debt collector and is an attempt to collect a debt.
Arm infnrimtinn nhfninnrl %,,;I] k� 4l„•f1,.,+,..,.-.. —
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 September 27, 2012.
8. Plaintiff is the purchaser, assignee and/or successor in interest CITIBANK,N.A. /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$1,132.81.
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.
it. 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,NICOLE CARNEiA-
mount of$1,132.81, plus of this
action and any other relief as the Court deems just e
Brown, Esquire, #94055
Robert N. Polas, Jr., Esquire, #201259 .
Mark R. Garvey, Esquire, # 312686
Gregory J. Babcock, Esquire, #205061
Attorneys for Plaintiff
17-10279
This communication is from a.debt collector and is an attempt to collect a debt.
n,,,, ;,,f�,-,,,at;nn obtnined will be used for that purpose.
VERIFICATION
The undersigned Custodian of Records for Portfolio Recovery Associates,LLC,
�`lffany(iriffiffi 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:
NOV 19 20% By: Ofiffin
1
*Oof records
17-10279
This communication is from a debt collector and is an attempt to collect a debt.
._..;� ,,,,,,;�„nt,tai„Pcl will be used for that purpose.
i
This communication is from a debt collector and is an attempt to collect a.debt.
A�_.;� ,.,,.,,+;An nhtninnd will be used for that purpose.
�ITui6
ontract ID:
Document lD:
BILL OF SALE AND ASSIGNMENT
THIS BILL OF SALE AND ASSIGNMENT, dated January 17, 2014, .is'b 1 iitibbank,at �N.., a
national banking association organized under the laws of the United States,
01 East
60th Street North, Sioux Falls, SD 57117 (the "Bank") to Portfolio Recovery Associates, LLC
("Buyer"), organized under the laws of Delaware,
with
its headquarters/principal place of
business at 130 Corporate Boulevard,Norfolk,
For value received and subject to the terms and conditions of the Purchase
t
and Sale Agreement
dated August 22, 2013, between Buyer and the Bank (the "Agreement"), Bank does hereby
transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's
successors and assigns,the Accounts described in Exhibit 1 and the final electronic file.
Citibank,N.A.
By: '
(Signature
Name: . Patricia Hall
Title: Financial Account Manal er
PRA 082213.doex
Account Statement
Send Notice of Billing Errors and Customer Service Inquiries to:
Customer S@fVICe: HOME DEPOT CREDIT SERVICES
PO Box 790328,St.Louis,MO 63179
SHOP as V myhomedepotaccount.com y � s
r iPR� Account Inquiries: ) yrt�t',N
ANY TIME A oun Rmbee�
ANYWHERE! ONLINE MOBLE IN5roRE 1-866-458-7683
Summa of Account Activit Pa ent Information
$1,076.49 New Balance $1,132.81
Previous Balance $456.00
Payments -$0.00 Minimum Pa ment Due June 20, 2013
Other Credits -$0.00 Payment Due Date
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 +$21.32 Minimum Payment Warning: If you make only the minimum payment each
New Balance $1,132.81 period,you will pay more in interest and it will take you longer to pay off your
balance For example
Past Due Amount
a
388.00 si 4C f5i I st
$ � u mkKihc c tftlfta nei
cinricat�d b *sron ;tf�1a*dux yet
d'����t'Hart'� o:u�ay���`�'F•,`-L`s _ t�an.�Irr��''�t >~r"�}, , 13taQ' t ._
Credit Limit. $0.00
Available Credit $0.00
Only the minimum payment 3 years $1,460
Statement Closing Date 05/24/2013 B you would like information about credit counseling services,cal11-877-337-8188.
Next Statement Closing Date 06/23/2013
Da s ion
Cycle 31
Your minimum payment due is$456.00.To avoid interest charges on your non-promotional(revolving)balance and any expiring promotions,pay $1,132.81 by June 20,2013.
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 Reference# Amount
Trans Date Description
FEES $ 35.00
05/20 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD
INTEREST CHARGED $ 21.32
05/24 INTEREST CHARGE ON PURCHASES $ 21.32
TOTAL INTEREST FOR THIS PERIOD
78 HD 15
Page 1 of 4 This Account is issued by Citibank,N.A.
PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4. 9 +
Please detach and return lower portion with yourpayment to insure proper credit Retain upper portion for your records__ _____
--------------
_______________________.
-----
------------
------------
Your Account Number is372
.........................:.
Payment Due Date June 20,2013
17 \�. Understanding how New Balance $1,132.81
P.O.Dox 790393
SL l ntris,MO 06179 flies �� � a.x Past Due Amoun$ $388.00
1 6 Ee
a Minimum Payment Due $456.00
You now have until midnight
(Eastern)on the due date to pay il`i``°. ` ` "`
Statement Enclosed "Aftoit%I(i; iSclr)se 'lT r e r
your bill online or by phone.
-:::: ---` tPast Due Amount is included in the Minimum Payment Due.
Please print address changes on the reverse side.
Make Checks Payable tow
HOME DEPOT CREDIT SERVICES
PO BOX 182676
NICOLE CARNEY COLUMBUS,OH 43218-2676
9 GRINNEL DR
CAMP HILL,PA 17011-7716
5372 -
Information About Your Account. Proper Form.For a payment sent by mail or courier to be in proper form,
How to Avoid Paying Interest on Purchases.Your payment due date is you must:
at least 25 days after the close of each billing cycle.We will not charge you Enclose a valid check or money order made payable to Home Depot
any interest on purchases if you pay your New Balance by the payment Credit Services.No cash,gift cards,or foreign currency please.
due date each month.This is called a grace period on purchases.If you do Include your name and the last four digits of your account number.
not pay the New Balance in full by the payment due date,you will not get Payment Other Than By Mail.
a grace period on purchases until you pay the New Balance in full for two Online.Go to the URL on Page 1 of your statement to make a payment.
billing cycles in a row. For security reasons,you may not be able to pay your entire New
if you have a balance subject to a deterred interest or O�io APR promotion Balance the first time you make a payment online.The payment
and that promotion does not expire before the payment due date,that c:Utoff time for Online Bill Payments is midnight Eastern time.This
balance(the"excluded balance")is excluded from the amount you must means that we will credit your account as of the calendar day,based
pay in full to get a grace period.However,YOU must still pay any separately on Eastern time,that we receive your payment request.
required payment on the excluded balance.In billing cycles in which AutoPay.Sign up at Account Online to have your payment amount
payments are allocated to deferred interest balances first,the deferred automatically deducted each month from the account you choose.
interest balance will be reduced before any other balance on the account. your card account will be credited on the due date with that amount.
However,you will continue to get a grace period on purchases so long as
you pay the New Balance less any exclude o deferred interlances in est promotionsy the - a payment.lWe may process your payment the phone number on gelectron ca ly after we verify
due date each billing cycle.We may referyour identity.The payment cutoff time for Phone Payments is midnight
as No Interest promotions. Eastern time.This means that we will credit your account as of the
In addition,certain promotional offers may take away the grace period on calendar clay,based on Eastern time,that we receive your payment
purchases.Other promotional offers not described above may also allow request.
You to have a grace period on purchases without having to pay Express Mail.Send payment by courier or express mail to:Payments
all or a portion of the promotional balance by the payment due date. Department,1500 Boltonfieid Street,Columbus,OH 43228,Payment
If either is the case,the promotional offer will describe what happens. must be received in proper form at the proper address by 5 p.m.Eastern
How We Calculate Your Balance Subject to Interest Rate.For each time to be credited as of that day.All payments received in proper form
balance,the letter following the Annual Percentage Rate in the Interest at the proper address after that time will be credited as of the next day.
Charge Calculation section on the front of the statement indicates the In-Store Payments.For your added convenience,payments can be
method we use to calculate interest charges.For Methods C,H and M, made at The Home Depot stores,with no service tee.Any payment in
we use a daily balance method(including current transactions)to calculate proper form accepted in-store will be credited as of that day.However,
interest charges.For Methods I and L,we use an average daily balance credit availability may be subject to verification of funds.
method(including current transactions)to calculate interest charges.For
Method K,we use an average daily balance method(excluding current If you send an eligible check with this payment coupon,you authorize
transactions)to calculate interest charges.To find out more information us to complete your payment by electronic debit.if we do,the checking
about the balance computation method that applies to your account account will be debited In the amount on the check.We may do this as
and how the resulting interest charges were determined,contact us at soon as the day we receive the check.Also,the check will be destroyed.
Customer Service number on the front.
Other Account and Payment information.
Payment Amount.You may pay all or part of your account balance at
any time.However,you must pay,by the payment due date,at least the
minimum payment due.
When Your Payment Will Be Credited.if we receive your mailed payment
in proper form at our processing facility by 5 p.m.local time there,it will be
credited as of that day.A payment received there in proper form after that
time will be credited as of the next day.Allow 5 to 7 days for payments by
regular mail to reach us.There may be a delay of up to 5 days in crediting a
payment we receive that is not in proper form or is not sent to the correct
address.The correct address for regular mail is the address on the front of T03500
the payment coupon.The correct address for courier or express mail is the
Express Mail Address shown in the Express Mail section. HD-2 APR13
PLEASE SEE IMPORTANT INFORMATION ON PACE 4
Page 2 of 4
Change of Address
Please print address changes in blue or black ink.
:AVE STA
TIME...
AND 'FREES!
Register now for Paperless Statements and more at
myhomedepota000unt.CoM
Account: '`*** **** **** 5372
� Aoc' ass
Total Fees Charged in 2013 $175.00
Total Interest Charged in 2013 $93.55
INTEREST CHARGE CALCULATION sYour"Annual Percentage Rate(APR is the annual interest rate on your account.
.... ,. ...,. ..., e.•.,-�.a-�.::�ix+• y;em::": .�.;.;+s�S:-tu4::}+xr-'ar��;.�a+...•:.;v^:;i"(r^"n �s •r;_tar5�.:exr;:e�;.e�"�sr-.tirP,:..,..
'"�' z"i�_� � '��:�F�� .��' 4 c'�inta "e;l�ate, F� �4�''�<8�1 itce:Silb e�t�'o,inbe��st�,a`lE� �1t►er:�s'�'G:h
._,...� .. w.... . is .:" -jj•,, '•.�r�� `,y J1tin'u�l:t��_...
PURCHASES
Revolvin Balance 22.99% M $1,092.37 $21.32
Page 3 of 4
Credit Reporting Disputes.If you think we reported inaccurate After we finish our investigation,one of two things will happen:
information to a credit bureau write us at the Customer Service address If we made a mistake:You will not have to pay the amount in question
shown on Page 1. or any interest or other fees related to that amount.
Report a Lost or Stolen Card Immediately.Call the Account Inquiries If we do not believe there was a mistake:You will have to pay the
number shown on Page 1. amount in question,along with applicable interest and fees.We will
What To Do If You Find A Mistake On Your Statement send you a statement of the amount you owe and the date payment
If you think there is an error on your statement,write to us at the is due.We may then report you as delinquent if you do not pay the
address for billing errors and customer service inquiries shown on amount we think you owe.
Page 1 of your statement. If you receive our explanation but still believe your bill is wrong,you
In your letter,give us the following information: must write to us within 10 days telling us that you still refuse to pay.
If you do so,we cannot report you as delinquent without also reporting
Account information_Your name and account number. that you are questioning your bill.We must tell you the name of
Dollar amount:The dollar amount of the suspected error. anyone to whom we reported you as delinquent,and vie must let those
Description of problem:If you think there is an error on your bill, organizations know when the matter has been settled between us,
describe what you believe is wrong and why you believe it is a mistake. If we do not follow all of the rules above,you do not have to pay the
You must contact us: first$50 of the amount you question even if your bill is correct.
• Within 60 days after the error appeared on your statement. Your Rights If You Are Dissatisfied With Your Credit Card Purchases
At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goods or services that you have purchased
if you want to stop payment on the amount you think is wrong. with your credit card,and you have tried in good faith to correct the
You must notify us of any potential errors in writing.You may call us, problem with the merchant,you may have the right not to pay the
but if you do we are not required to investigate any potential errors and remaining amount due on the purchase.
you may have to pay the amount in question. To use this right,all of the following must be true:
What Will Happen After We Receive Your Letter 1. The purchase must have been made in your home state or within 100
When we receive your letter,we must do two things: miles of your current mailing address,and the purchase price must
1. Within 30 days of receiving your letter,we must tell you that have been more than$50.(Note:Neither of these are necessary if
we received your fetter.We will also tell you if have already your purchase was based on an advertisement we mailed to you,or
if we own the company that sold you the goods or services.)
corrected the error.
2.Within 90 days of receiving your letter,we must either correct 2.You must have used your credit card for the purchase.Purchases
made with cash advances from an ATM or with a check that accesses
the error or explain to you why we believe the bill is correct. your credit card account do not qualify.
While we investigate whether or not there has been an error: 3.You must not yet have fully paid for the purchase.
We cannot try to collect the amount in question, If all of the criteria above are met and you are still dissatisfied with the
or report you as delinquent on that amount.
• The charge in question may remain on our statement, Purchase,contact us in writing at the address for billing errors and
9- q Y Y customer service inquiries shown on Page 1 of your statement.
and we may continue to charge you interest on that amount. While we investigate,the same rules apply to the disputed amount as
While you do not have to pay theamount in question, discussed above.After we finish our investigation,we will tell you our
you are responsible for the remainder of your balance. decision.At that point,if we think you owe an amount and you do not
We can apply any unpaid amount against your credit limit. pay,we may report you as delinquent.
KEY CREDIT TERMS-NO INTEREST IF PAID IN FULL WITHIN 6 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.
*With credit approval for qualifying purchases made on The Home Depot or EXPO Design Center Consumer Credit Card,17.99% 26.99%APR.
Minimum interest charge$2.See card agreement for details including APR applicable to you.Offer is only valid for consumer accounts and is
subject to change without notice.
T03501-HD-9196-0400-0002-E-0-X--04101/07-30-192-P-E-0-7-8-0-NOPLAY-TC-07/13/12-H50B-April 23,2013.0-0 N---
PLEASE SCC IMPORTANT INFORMATION ON PAGE 2 HD-4 APR13
Pace 4 of 4
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND CO NTY
rA lir, 19 t
^jJ p 1414SYL\INSI
Portfolio Recovery Associates, LLC
vs.
Nicole Carney
Case Number
2014-6965
SHERIFF'S RETURN OF SERVICE
12/11/2014 06:34 PM - Deputy Jamie DiMartile, 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: Nicole Carney at 9 Grinnel Drive, Lower Allen Township, Camp Hill, PA 17011.
DIMARTILE, DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
December 12, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuito Sheriff, Te':eosoft, Inc.