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Home My WebLink About14-6972 Supreme C. a .-Pennsylvania ' Cour f Cao n Pleas For Prothonotary qse Only: "I'1M.E STAMP Q, Docket No: /./ h� ✓H �} . CUMB ► %County The informationcollected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of leadin s or other papers as required by law or rules of court. S Commencement of Action: E ® Complaint ❑ Writ of Summons ❑Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T, PORTFOLIO RECOVERY ASSOCIATES,LLC JEFFREY STRIKE,NANCY S STRINE 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 MDJ Appeal? ❑ Yes N No Name of Plaintiff/Appellant's Attorney: Robert N. Polas,Jr./Carrie Brown/Mark R. Garvey/Gregory J.Babcock ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance 0 Debt Collection: Other ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability(does not include E mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Zoning Board C ❑ Other: ❑ Employment Dispute: Other ❑ Other: T I {' ❑ Other: U I MASS TORT N [:] Asbestos ❑ Tobacco E] Toxic Tort-DES REAL PROPERTY MISCELLANEOUS B ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Other: ❑ Ground Rent E] 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: 17-25710 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 i''i J"t i t;(3N(121r,,,t� Portfolio Recovery Associates,LLC 120 Corporate Blvd Norfolk, V A 23502 C t1 bI B E h L;; J r TELE: 1-866-428-8102 PEIJ ��',4 j N T Y 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 No 9T) aOv I NORFOLK,VA 23502 Plaintiff, V. JEFFREY STRINE 905 MOUNT ROCK RD CARLISLE PA 17015 NANCY S STRINE 905 MOUNT ROCK RD CARLISLE PA 17015 Defendants. 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 writing4ith 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 l . (717) 249-3166 17-25710 tv,0- -3) L This communication is from a debt collector and is an attempt to collect a debt. 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 CIVIL ACTION-LAW PORTFOLIO RECOVERY ASSOCIATES,LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. JEFFREY STRINE 905 MOUNT ROCK RD CARLISLE PA 17015 NANCY S STRIKE 905 MOUNT ROCK RD CARLISLE PA 17015 Defendants. COMPLAINT 1. Plaintiff,Portfolio Recovery Associates,LLC is a Delaware Limited Liability Company with offices located at 120 Corporate Blvd,Norfolk, VA 23502. 2. Defendants,JEFFREY STRINE and NANCY S STRINE, are adult individuals with last known address of 905 MOUNT ROCK RD, CARLISLE PA 17015 and 905 MOUNT ROCK RD, CARLISLE PA 17015. 3. It is averred that Defendants were indebted to GE CAPITAL RETAIL BANK/GE CAPITAL RETAIL BANK/LOWE'S on May 15, 2008 with account number ************5027 (hereafter referred to as "Account"). 4. By using the Account,Defendants 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,Defendants have 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. Anv information obtained will be used for that purpose. 6. Defendants were 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 Defendants. A copy of the charge off statement is attached hereto and collectively marked as Exhibit "A." 7. Defendants were 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 21, 2013. 8. Plaintiff is the purchaser, assignee and/or successor in interest GE CAPITAL RETAIL BANK/ GE CAPITAL RETAIL BANK/LOWE'S 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$1,610.02. 10. Despite reasonable and repeated demands for payment. Defendants have 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 Defendants,JEFFREY STRINE and NANCY S STRINE, in the amount of $1,610.02,plus costs of this action and any otheIrrie ourt deems jus sonable. . Brown,Esquire,#94055 Robert N. Polas,Jr.,Esquire,#201259 Mark R. Garvey,Esquire,#312686 Gregory J. Babcock,Esquire,#205061 Attorneys for Plaintiff 17-25710 This communication is frorn a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Ricky L.Vaughan 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 0 3 2014 By: Ricky L.Vaughan Custodian of Records 17-25710 This communication is from a debt collector and is an attempt to collect a debt. Anv informntinn nhtninp.d will hp ncarl fnr that i XHIBIT A UN� This communication is from a debt collector and is an attempt to collect a debt. Anv information obtained will be used for that purpose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . GE +Caprtal SILL of SALE PIRAPLCO Fresh Febi gzrY,20I4 . .. . ... .. . ..... :::For:value ire ved-and in further consideration d-the mutual coveriants'and conditions.set.foith imthe . . Forward.Flow Receivables:Purchase Agreement(tYie Agreement ),dated.as:of this 16nn. day of January;2014 , by:and between General:Eleetric Capital Corporation,GE Capital Retail:Bank, GEMB Lend'*' '.Inc..,' . Monograrn'Credit Services,LL.L.C'.,RFS-Holdi' . L,L.C.,'and GEM Holding;L.L..C.(collectively"Seller")and :.: : . :. Portfolio.Recovory,Associates,LLC("Buyer"}, Seller hereby transfers;sells;.conveys,grants,,and delivers to Buyer,:its successors and assigns,without recourse.except as:set forth in the Agreern to the extent of its .: ownership''the Receivables.as set Earth:in the Notification:Files.(as defined in the Agreement),.delivered by.. . .: Sellet.to Buyer.on February 19-,201.4,:and.as further described:in the Agreement:: . . . .. . GE:Capital Retail Bank. Manogratri Credit.5ervices;:L.L:C:. :: . ICen'Wojcik Attorney in ct.Ken Wojcik : .. Title: EVP'Collections&Recovery Date: : pa:::.a�:-: . .: Date: -' (v:-. (�{. .. . .. . R xolaing, L:L.0 . .. (3eneral:Electii6Capital Corporation. By: .. . A tti�rn By: : ey:in F Ken o�:ci . Attorney in Fa Ifen Woj cik:;. : : Date;.... Date. GEM kTolding,L.L .0 . . GEMB Lending;In'' By: r. it. Attorney in Fa Ken.Wojcik By:' us Fa Iden Wojcik Date: Attorne y. :. ba. . . . . Date: .. . .... . .. .. . Portfolio Recovery. . . ci sties;LLC .. . . .. : .:. .. : .. ..... .. .. Title: Lowe's®Credit JEFFREY M STRINE Card Account NANCY S STRINE Visit us at www.lowes.com/credit Account Number 5027 Customer Service: 1-800.568-0156 Summary of Account Activity Payment Information Previous Balance $1,610.02 New Balance $0.00 Payments $0.00 Amount Past Due $0.00 Other Credits $1,610.02 Total Minimum Payment Due $528.00 +Purchases/Debits $0.00 Payment Due Date 01/24/2014 +Fees Charged $0.00 Late Payment Warning:lf we do not receive your +Interest Charged $0.00 minimum payment by the date listed above,you may have New Balance $0.00 to pay a late fee up to$35.00. Credit Limit $1,340.00 Available Credit $0.00 Statement Closing Date 01/2212014 Days in Billing Cycle 28 Transaction Summary Tran Date Post Date Reference Number/ Description of Transaction or Credit Amount Invoice Number 01/22 01/22 CHARGE OFF ACCOUNT-PRINCIPALS ($1,205.83) 01/22 01/22 CHARGE OFF ACCOUNT'FINANCE CHARGES' ($404.19) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 01/22 01/22 INTEREST CHARGE ON PURCHASES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2014 Totals Year-to-Date Total Fees Charged in 2014 $0.00 Total Interest Charged in 2014 $0.00 Total Interest Paid in 2014 $0.00 Interest Charge Calculation Your Annual Percentage Rate(APR)is the annual interest rate on your account. Expiration Annual Balance Subject Interest Balance Type of Balance Date Percentage Rate To Interest Rate Charge Method Regular Purchases NA 26.99% $0.00 $0.00 2D Important Account Information Statement not provided to customer. If your account has a deferred Interest promotion and you would like us to apply a payment on your account in a different way,please call Customer Service to discuss other options that may be available. PAYMENT DUE BY 5 P.M.(ET1 ON THE DUE DATE. NOTICE:We may convert your payment into an electronic debit.See reverse for details,Billing Rights Information and other important information. 7009 X5G 1 3 22 140122 Z X PAGE 1 of 1 9294 0010 0002 OIC<7009 <7009 Detach and mail this portion with your check.Do not include any correspondence with your check. —I Account Number 502 7 Total Mintmum Amount Payment P.,men Due Pas New Balance mt Due Due Date $528.00 $0.00 01/24/2014 $0.00 Payment Enclosed: ❑[1[1 F10 . F1 F1I1I1IINI'lI11111I I I VIII 11111111111Please use blue or black ink. New address or email?Print changes on back. JEFFREY M STRINE NANCY S STRINE 905 MOUNT ROCK RD Make Payment to:LOWE'S/GECRB CARLISLE PA 17015-9457 P.O.BOX 530914 ATLANTA,GA 30353-0914 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY f; 4`s'RIOTHO 20 DEC I S P[ 3: 23 CUMBERLAND CeialITY PENNSYLVANIA OFFICE OF FF#E SHERIFF Portfolio Recovery Associates, LLC vs. Jeffrey M Strine (et al.) Case Number 2014-6972 SHERIFF'S RETURN OF SERVICE 12/04/2014 07:45 PM - Deputy William Cline, 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: Jeffrey M Strine at 905 Mount Rock Road, Penn Township, Carlisle, P 17015 4 AM CLI E, DEPUTY 12/04/2014 07:45 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Jeffrey Stine, Husband, who accepted as "Adult Person in Charge" for Nancy S Strine at 905 Mount Rock Road, Penn Township, Carlisle, PA 17015. ICLIAM CLINE, DEPUTY SHERIFF COST: $50.78 SO ANSWERS, December 05, 2014 RONNY R ANDERSON, SHERIFF (c) CcuntySuite Sheriff, Teleosoi, inc.