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Home My WebLink About00-01956 .. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. DRIVE 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 1873 HOLLY PIKE CARLISLE, PA 17013-9118 4168100005703077 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS KRISTI J CLARK Defendant NO.00-1956 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS $5,885.80 $1,177.16 $399.11 ($0.00) ($0.00) TOTAL $7,462.07 PLUS ADDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. .-"'<'-"'0 -'"'"'"". . -;. ,r -F-<" ,~ 1'-".' . ,; -'" . . . - . . . , I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". v1 --------- VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW, m ~ :Jl.{ ,..rvV'\ , Judgment is entered in favor the Plaintiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certificat~ion. If (1~-i;,..>R~ / ROTHONOTARY PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,;-~::-,,~, _ ,.- O:_~_:~'~',,_'f_~_""'_'~' _ " .,,~,~o,!.,,; '~\-'_^:~'f"'<":~.l_i,____",,~_;_~,e , '.. "'-_0""" '",.,? "'" " -~, " ~,,', =-' . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES,P.C. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 1873 HOLLY PIKE CARLISLE, PA 17013-9118 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS KRISTI J CLARK Defendant NO. 00-1956 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: KRISTI J CLARK 1873 HOLLY PIKE CARLISLE, PA 17013-9118 DATE OF NOTICE: 5/3/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACf WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE, P A 17013 (717) 240-6200 PARK LAW ASSOCIATES,P.C. BY: VALE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "..,-.,~~-~~ !'~~' . r~,!,l.,~tft~," ~ml!H".~,_, _ (~ - r ..0 ~~ r (:) ~ ~ ~ ..co. ...0 8 -v p:: 1- (") c <" "J2u-:-J f:II'P ?;f!.: ~~~ ~:~.:C) r~t3 ~ a o ~ -~ -~.:.: o " :-d ,:1:,j:O r- ---,rn J,y ~:j9 c'~-H ',2<:'5 o ill -i S -< TV ~~- ~"tJ -i1r- :...J '-0 .-,....,j _~ "~-r."'!' "._~~,~~~~i;;~II~~~l~<l'lI'~l!I!!ilt!~i"ffl~~';<!<!'t'\llji;~II!!!l\!I1I1'l'_~l~lfl~ VALERIE ROSENBLUTH PARK ATTORNEY 1.0. # 72094 PARK LAW ASSOCIATES, P.C. DRIVE 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 1873 HOLLY PIKE CARLISLE, PA 17013-9118 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION plaintiff VS KRISTI J CLARK NO. 00-1956 Defendant VERIFICATION OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS VALERIE ROSENBLUTH PARK, Esquire, being duly sworn according to law, deposes and says that she will make this affidavit on behalf of the within Plaintiff, being authorized to do so, and that she believes and therefore avers, that KRISTI J CLARK, Defendant is over 21 years of age; that his/her place of residence/business is located at 1873 HOLLY PIKE CARLISLE, PA 17013-9118 and that he/she is employed and that he/she is not in the Military or Naval Service of the United States or its Allies or otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its amendments. ::~K LA~ Valerie Rosenbluth Park Attorney for Plaintiff E10 <"':. .-^,,\-,"_.,'\'-~,';, _. :!"'": ",'0" - ." 'j '""","v" '_", . , --""-__""';~ ,_.' - _,:0,,_,;:;, '<-'~"'_' '_~_~"'--'C_' "_~, ~ ,_,_ ~.H .' . _ C,' ,. ,., I o fi ~~J1 &i~;:~~ ~i:=': ~!3 ~ (,':) (::;) :z ::-~ -< o " ~;i ;;;l~ -om .,,:10 :'_._j l .:.:::,C; :::::fj ;~~(') Om s;! ~ ," ~):"& <"D ~>? {..,) "...I - "11m! '...... _ ,tlf!~~M!!IIli!llIE"~!B'1Jl _<'.~_" ,. _ ~. ~~~1Il _l~~ VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. DRIVE 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 1873 HOLLY PIKE CARLISLE, PA 17013-9118 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS KRISTI J CLARK NO. 00-1956 Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: [X] Judgment by Default [ ] Money Judgment [ ] Judgment in Replevin [ ] Judgment in Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on Judgment Note [ ] Judgment on Writ of Revival [ ] Praecipe to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. 5/"'1/00 NT?r~'JK.~ PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. s:~ , -" -?_',_.,.,r :<.:-:_ ~>~"__"_t,;_ .- ~"', ---~";- ',- ~.~, --,.-,." -~"-~-''"-~,-~,-, " .. _ ',-_~r' ' u'_~ c_ ""~," "__ __ ~_, C", VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST SELECT CORPORATION Plaintiff VS. KRISTI J CLARK Defendant NO.Cb- j'lt,;1e. C'u~(T~ 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 within 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 for any money claimed in the Complaint or for other claims 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 OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. c,_.. _ '-" ',' - ".,_.."1--;,'_p_,c',' , '_ - '"," -'-.'.-"h',-.,, ~-- ~ -.., "" VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT#:4168100005703077 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION 4460 ROSEWOOD PLEASANTON, CA 94588 PLAINTIFF VS KRISTI J CLARK 1873 HOLLY PIKE CARLISLE, PA 17013-9118 DEFENDANT NO. 0--0- JqS~ Ci.vu- I~ CIVIL ACTION 1. The Plaintiff, FIRST SELECT CORPORATION, a California corporation, organized and existing under the laws of the State of California and with its principal place of business at 4460 Rosewood, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, KRISTI J CLARK, is an individual who resides at 1873 HOLLY PIKE, CARLISLE, PA 17013-9118. 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or authorized by the Defendant on a credit card or line of credit, bearing account number 4168100005703077. ~ , """""f-'~-"",'T,:'-.-_' '1!,;~\,?,~c"':~_ 0"__'",--;" ,-,~ -,,"- --",- -','''' --',.., ,. , "L'~__ e_._ ,__ 4. The terms of said account are stated in the documentation attached hereto as Exhibit "An. 5. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the outstanding debt as agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $5,885.80 as of 01/11/2000, plus pre-judgment contractual interest at the rate of 19.80% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,177.16. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT CORPORATION, and against the Defendant in the amount of $5,885.80, plus pre-judgment interest at the contractual rate of 19.80% per annum from 01/11/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,177.16, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT II 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as though set forth in full. 9. The Defendant received a monetary benefit, which was in fact appreciated by the Defendant. 10. The Defendant accepted the benefits. 11. By virtue of the circumstances surrounding the request for funds made, the Defendant knowingly requested the funds at issue and/or knowingly and voluntarily accepted the benefits bestowed. " ~'''''- " '0' .<P . ':' '-. ",',1, ie__,_, "0.' ---,~" . ,-- _d_ . -,' , or 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands that Judgment be rendered in favor of the Plaintiff, FIRST SELECT CORPORATION, and against the Defendant in the amount of $5,885.80, plus pre-judgment interest at the contractual rate of 19.80% per annum from 01/11/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,177.16, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALER E ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -" .~ ~ -~,~:_,- ,,_~r_"9':; ", . ^,___'R,' ~''''_:!>_)' ~~_'''", -"',' ,,~ ",_ C_'_"""_,._,"";'_' < f '''-' ,,~"~", -,-/", . , I, VERIFICATION , SUSAN M. WRIGHT , declare that as of January 18, 2000: I am a designated agent of FIRST SELECT CORPORATION, the plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in the State of California. ~L , '~,"- ,- - '-'.' c " ,",""'_'"1" ---. -" -~ ,-' ~ 1-~ F1RST SELECT . c o < ? o R A r o .." ACCOUNT AGREEMEl'iT J:. 1 " Your St.'0i TRUST account has b<<n tn.l't1f~ eo first S~lectCorporation. Your SL'N TRliST account '....:l.,S; ::~c:!c:d olt the ~imt: of chis ~rmsf~r, and wilt thertiore continue to b~ closed. ~i~ Account A~~mem contains the t=tnS that govern your f'irst S~leCt ac~ount (tho: ~ ..:...;:~unt:'), .l.n :his A?I'eement, "you" and "your" me.:l(l each ~on who IS ltable for payment on the .:.1,ceount. ~We,~ "our," "ours," and "us" me:m rlf!l. Sel~ Cor;:ontlon or Its assl~~<::S. 8ec.:lu:se your .~Ccount" has been trJ.l1Sferred to us, you are now obligated ~a repay !.he Account co u:s instead ofStiN T'KL:ST. ([tho: Ac-:::unt 'Has opened as <ljoint account. we ma.y a.ct on the instrUctions of any joint :J.ccountholder. Parmenb { Finance Ch::lr:f:3. As tong as you h:J.ve a. balancl: oUlStanding on your ...l"ccount, fmanc: char'gd .l("': ::t!culated 3.$ foUo.....-s: To figure the fin:mc: charges for ~h biHmg C'jrc{e, we multiply the J.v~ge daily balance on your A.;::aunt try :!, 6.ily ~riodic r~te. The d.1,ily periodic rate we apply ts your ACl:ount's .A.nnu:J.1 Perc-.:ntl1ge ROlte divided by 365. Tn,= A.nnual ?:C'l:etttage Rate will becUculatcd ~ disclosed in your"most ri:ccnt St;"N TRUST aceoum ~~ (the "Origina.l Termsl, lfyaur Original Tmns provided fordiiferent .:l..Muat P~:nuge RJ.td to.Oe applid to diff'erentcomponents of your outsta..nding balance, we will apply tile lo~ sUc:h AnnU:J.! P:fl:::ttug= Ra.te to your entire outstanding balance:. We may accept \atc or partial paymr.::nC3, or paynu:nu marked "paid in fuU" or.mark;:d with athcr rr.::::st.riC"..ions. wtc..1.out losing oW' right to coU.:a all iltnounU owing under chis Agre-:ment. Fee3. We. will charge your .~ccount a fe.e forea.c:h billing: cycle wichin wNch your Account is delinquent (tat~ ch~~=). The amount of the tat;: charge ~ilI ~:1.S di:se;l~d lnyour Original Tem'I3.or the ma.:<imum (ate charge poermicted by the: law of your state of~icenc=. v,,'hichever is lo.....er. . _ We will charge your Account 3. fee for e~h returned payment cheel<. (returned. check charge). The amount 0 f <"1.e .-=cum~ check charge will be as disclosed in your Original T~. or the ma:<imum n:tumcti ch<<:lc. charge permitted by the law oryour state of re:sidenc.:, ....hic::ever is tower. To the extent pro~ded in your Original Tmns., and to the eXIent ~tted by applic::I.ble law, in adc!.itiol't to ~'OU: Obligation to pay the outStanding balance on your A.ccount, ptus intr:rest and fc= as.disc:tQ:!!j~ herein. we may also charge you for any collection costs we incur. t.nch.:dlng but not limited to reasonable attOrneys' fees and court costs. If your Original T crms provided for an award of aItorneys' fees 3nd court caSU, succr. provision as incof'lXlnt.ed herein shall apply reciproclly to the p(,l!:vailing party in any .1a.W3Uit wing out of~. Agreement. Non-Waiver ofCert:U.n Ri.ghb. We may delay O( waive enforcement of any provi.sion ofthu.:.1,gre:::ne:1t wit."':out to:sing our right to enforcl!: itor any other provision later. A.ppUcable La~ Sevenbility; A.:s.signment. No matter wh~ you live, this Agreemoent and your Account are. governed by feder:lllaw and by the law of the state de:signat!:d as the applicable Ia.w in your Original Tcrt'l'1S. tfyourOriginal tmns did not contain an appltc3.blo: {~w provisio~ then this .~I:~entand your A.ccount are go~ect by fed~l ta.w 3.tld the- taw of your suteofrr.::sidence. This .~ement is a final ~x;:r=ssioC!. of the ag:r~ement between you and US and may not be conU'i1dic:ted by evidence of any alleged. omI i1.greement. tf any provision of this .~gr~~ent is ho:ld ':0 be ;"",,'alid or unenforeeable, you and we will col'ISider that provision modiiiedto conlorm to appllable law, and the r=st afthe provisions in the .l:\greemeru will nill =-: .::Uarceabli:. We may tnn,sfer oras.slgn our right to all or some of your payments. U'nate law requires that you r:c:ive notice ocsuch an, event ~o 9rot~.:he pu~~~or as.signr.::e, we may give you such notice by filing a financing statement with the State's Secretary ofSca.te. Credit Reporting. If you fail ~o fulfin the t~ ofyouT' credit obligation. a negative credit repo~ .dl<:eeir.g on :'our Ct'I:dit r:cord may be submitted to a credit reporting agency. lIt order to dispute any information we ate reporting about your Account, you must write ::0 L:S 3.t the faHawing address: First Sol:lect Corponlion, P.O. 80:c 9l04, PI~ton. Califomi~ 94566. .~:. ~: YOUR BILLIl'iC RIGHTS - KEEP THIS NOTICE FOR FC.-rt'RE USE I' ,\ 1b.is noticl: contains impo1'Urtt uuom1:!,uon about your righu and our l'C:SpOruibititie:s under the Fair Crectit SiItmg Act.. Not:iIy U:s in C:J.1ol: of Errors or Qu~o(U ."bout Your Bill Ifyau think your bill is Vott'ong.. oe' if you need mory. information about an ~rry on yourbitl. urrite u.s. an as~aru~ sh~t.:u. the foHowing address: First Select' Corpol'l1tion., P.O. 80x 9l04, Plea.sanlan. CA, 94j66. Write to us as soon as possible. We must hear from :,ou l'tO later than 60 days a.ftcr we sent you the fLrSt bill on which the error Ot problol:m app<:ared. Yo",," CUi r.dl:phone us, but doing:!o will not pr.:serve: your rights, lIt your h::tter, give US th~ foHowing: Your name and Account numb<l:r. The dollar amount oCthe swpec:t~ o=rror. O~crib,= the ~ITOt and ~xplai_n. if you can, why you believe there is an ~lTOr. lfyou need mar.:: i.tJformatiol"'_ c.csc:i.be r.he iter." you are not su~ about. Your Righu 'J.r\d Our Re~port3ibilitie:s After We Receive Your Written ':-1ot1<:e w~ must acknowledge your letter within 30 da.ys, t1.nless we hOlve col't'f:Ccedthe ~ol"by then. Within 90 6:'1. we must eitherco~ the error or e:cpiain \Nhy w.e; believe !h..: bill was correct. After we receiv~ your [.e:ctcr, we e::t.(ll'lot r.ry Co coHect o( report you iI.$ delinquent ::.s to any amount you question. inCluding finOLnc,:: chatge:s. We C::Ln apply any unp;ud ;unount iJ,ga.inst YOUt ctedit line. You do not have. to pa.y any qu~toned :trnount while we are investigating, but you U'e scill obligi1.t.e:d. to p:ty the p:uu of the bin r.h::tt are l'tot in qU.e:Stion. ' {fwe find th.u we mad.: a. mist:l.k.e on yourbiU, you will not have to pay any fin:u\cl!I eh:z.rge rel...tol:d to any questtoned amount. [(we did not male.: a. mist:J..k:. you may h:J.ve to p...y fmanc.::: clu.rges. and you. will have l.O malc.1i: up the missed pavmcnl:S on the:: questioned unou:;t. (n -:l:ither C:U~. we will :!.end you a st;1lorntol:nt of the :unount you owe an~ thl:: dat.e: that'it is chle. tfyou rail to pay the amount ~e think you ow.e:, we m::l.'f r~~ ~;ou J.S delinquent. However.lfo~re;'(pla.na.tion dOd Clot satisfy you 'lnd you wrile to us within 10 dAys telling us th.a.t you still ret\L:Se to pOly, we must lell an~'one we report you to that you qucstlon your bill. And we must tell you the name of1.lttyone Wl: repol'ted you ~o. We must teU 3J1yonc \Ne teport you lo th;1t ll."'!O: :::actc:t' ha.:s been sectled betwt:l:n us when it finaUy i.s. tfwe do not foHow thC$c rulc:s, wee::t.Mot collect the first S50 of the questioned :unounlcv.e:~ if'foul'bilt ~~ :ot":'eet. Sp~ci:1J Rule for Credit C:1rd Pureh:l:S~ tf~.ou hav.: a problem with eho: quality of,!oods J.nd servlc::s that you purcha.s.ed with your St.:.: T~l'ST ,---:,,::ciit :ud and you have tried i!1 g?Od faick to CQlTeet the problo:m wilh (h~ mo:rt'h.unl, you m~y no( h~...~ 10 pay 'he:: rem~ininJ <UnOUCl'( duo: on the goods or 3er,:i';~3. 7:,.:::,,: u.: two limit,],tions to thts rIght: (J.) y~u must h:t.ve mad..: the purc:h:ue in your hom.e: st.:1te ~r. if not within vour home SUto:. within lOa mil.e:s o~ :our ..:urr.:~t ma.iling ;lddres:S~ <:Lnd (b) lhc.pureh::l.;SC: pnc:: must have ~en more than Sin. These limit,l.tto~ do not :1pply ir'eithc:r we Ot St;;.i TRUST own or \Jp'c:"~le ;,.1-:= ~~:,,:h::Lnt. at if we ur SL~ TRUST m,ulcd you!.h.e: :1dvertis.ement for th~ ptoperty or S.e:('ViCd. '~~,~ ~~ , -'- ~"/__,,_~ or~__.._,~ ~: ,~~.~ - ~-~~~~!.... ,--- --", .tg. .t- lI{C , . g B 1 ~~~ 'C ~ () IN i--! 6"'- ~ L ~~ J o C '2" -rJfD Olrn Z:.1) ZC r:P" ~~ ""d )'c z =< o o ::11: :r-ill< ';:4) = o ~ ::..:l ;hF~ ----,rn -:'.';1::;1 (')(1. :;~j .:;;~ ;.--~ --, :,~(,5 ,.--,rn u """ "!,:;>. :"0 -< {0 ~;\lmil~<W'!!mIi!'W~~1m"l"i,!;wmjl"i'filj"~"lnl'1"l'~'_1'1\f{ffi'll~"'!!l~~fw.-t_~,~11't"W!i)J'31_rll'ltlffl1!il!IliI/!iiW!;1Il.!>MUI~q -0 :x ~? "-> (J] SHERIFF'S RETURN - REGULAR CASE NO: 2000-01956 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS CLARK KRISTI J KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within NOTICE & CIVIL ACTION was served upon CLARK KRISTI J the DEFENDANT , at 0019:30 HOURS, on the 12th day of April 2000 at 1873 HOLLY PIKE CARLISLE, PA 17013 by handing to KRISTI J. CLARK a true and attested copy of NOTICE & CIVIL ACTION together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: ~~ ~t:4f!~ R. Thomas Kline 04/13/2000 PARK LAW ASSOCIATES Sworn and Subscribed to before By: ~~S~ J @~ d f ~ ay 0 me this o,-",J ,:LIH>-O ~.D.. Qr-LB ~ ~ P 0 honotary , .'_"'l"'. ,",'