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Home My WebLink About00-01957 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 PROVIDIAN NATIONAL BANK plaintiff VS. GERALDINE C GORMAN Defendant NO. ()() - 19S7 Gbi.L~ 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. ^ !1-" ,., ' ~, {^, r, ". ,. ..... . - '0 C. ,"-, "c_""__, _ -", -., 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#:4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 DEFENDANT NO. (J-o. /951 {l;J. ~ CIVIL ~CTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, GERALDINE C GORMAN, is an individual who resides at 204 ALLENDALE RD, MECHANICEBURG, PA 17055-3401. 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 . -, -~,.. , _,' _ "" .~; ,--< _'''; " '.' ",? _.0_ - , ~- -', -c /' " ,,_ ~_,_"___,_. ","" -~-.,'- " -~ -- -~- owned by the Plaintiff bearing account number 4217390552605848. 4. The Defendant requested an account, account number 4217390552605848, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit UA" and made a part hereof. 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 $5,399.14 as of 12/31/1999, plus pre-judgment contractual interest at the rate of 17.90% 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 $1,079.83. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, 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. 1'?", -"/':__ -~~~-!_,_c "",,"''_'-, "_, -",-,-~",. "~V'''' -'-'~~~-"""''f_" -.,'"' -." ,_ ,'." "<.,, "-7,' 0 , "'_"_" - ~ _. _~.,__=,." ".<."-,-"-<.- . , ,'~ 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. 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VAL 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. ~--- on._ _"?-:,, '--'"--~0'"'' '_'i_,'>!'~''''_''"v",,,__-,- >,,'Po' ,""'_'_' '_'_"':_;""_~'""" _;'" ~" ." _C_'. ~'."r:.' . ,~ I, VERIFICATION SUSAN M. WAIGHl , declare that as of January 10, 2000: I am a designated agent of PROVIDIAN NATIONAL BANK, 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. Designated Agent ,,,." " "~-(! .- - ~,""-- ,1, ~ ,-~ _, . . \ \ ." Membership Request Certificate YES, 1'd like the VIS~ Gold card , with cash up to $10,000. l'J.easC'~nd me the VISA Gold c::u:d and immediate cash. if I have requested it br.llow. 1 a~ to bl: bound b,y the AOi:o~t Agree-ment,,(which will be ~ed to me wlWn mv o.OXOW'lt b opened) and to repay principaJ... mtel;'e$t, and lnreres\:." ~NOn, ex.:e.pt that [..,.Jill have no oblig.:ttion if L::l!turn the cardW ~:'I.d <:h~~ 0 (if appr'~le) unUl3ed. after rE:,':lewtng tbe~ount A.gr~;:aent. i '1.1 " ' Thisi.'l< itationexpires: February 20". 1995 II" ,I I : i." Geraldine C. Gorman 634t stephens, crossing Mebhanicsburg, PA 17055-2347ij75 II ' i.' 1526A6 CTM40 GX9'9 HEElI Q,JQR OBBB LBED AEAD 30-'.- 526":'09~1I-8-8591-7 , , , , i I . 'I' i ; . . I ~M~tj,~/7/(2fi so2Lgo/~ h (L ~ L LJ Q.:5 Ii. I ' , (71i~~906Z7aJ'3f-711u Home fh.one Work/Second Phone Ext. I' !"\"'n" : 1 I ! I I .i I . .. --'.-.'j~:~ ". . ----;:~~~ "~:'~~::,"::~~:::.;.:~~,'i.':'_r: ~..~.~z:-' ..~, -----'~-.....:..: '-:--;;~-.' .-.--. ....-----0'"\---.-.---- .,.1 I . ..... ...~"" I" 'It ".,:",; ....1.... .~.wqul"hhll':lIl!.jd"..'..II. lil"'l' .,.1'1"""~ .... ,.,. ~"~':f.h,,, .. ."., '.' .'. ,.... ..,. '~''''''~' .... '1" 'j' . .. ',. " .:.i,i..'...:.....".:~...l.,,;,.:........ ~,.~,,~i::.2.:;.;.l,,:!;R. '.' "'~i VIS' A" :G' "'I'd'N: .,' -..., " ':~"',' +,:i;::.' :~.'" }'::':'o..:;:,;,::,;!:~,i!;j,;f;'f,iii:;i;i ,"~" f/l,1!:.C:..." ,. ........,...." . ..,.. ,9 '... ._..._..g~ : " . = {eference Nurnber: 4217390552605848 ~ox {ear latch j8N \CCOUl}t;/;!_ : 1104 : 95 :8 : 162661563 --:4217390552605848 . '," '." "":. '_, , 'rlll~l~.':'" '. f:1~~... ,~I~:': J~::;~~l '~~'~~l~:~!s:;('~~~:< ,)~':7':'~-:"'~'~;~: .:.'~,: ..~~~~ :1~~';: ::~:; .~' VISA GOLD -5275 ... No Annual Fee $10,000 Credit Line Immediate Cash Our lowest Interest Rales i " ...., ! J I!.. / c-~ Q!;./,y ", 0-" - of,;l.""'-.. Eileen Stack Vice President , ---;I t I, . , . , \ > t. . . .. > , : ': IMMEDIAT'if IC#;;:'~ . Obtain Cash for Balance Transfers or for any other reason. Check one: o $10,000 0 $8,000 0 $6,000 0 $4,000 0 $2,000 526-0911-48-8591-7 PLAINTIFF'S I ex;tIT , - MLHARTS FGl84 j ?H-? ~ ~ -' ~'- .~~ ,I~PROVIDIAN Finunciul ;:',01/1 I:CHl Na c<al B,;~;, ',jIS '(B;'or I\Lr:ecCal-d@ Ace ,I;:'t A,- p:omer' ;\)~S3er"lldme :-' :"'--;ormOln ~ a r [J,' - , j " PLAiNTIFF' ~1 ~ 1 Please review this document and keep It with your c the! Import~nt papers This t.,CCOUiI; ,pgree,-nent UJ'Y3Ins I"',~ terms WlllC1I gO'iern lour PrOVldlan f'latlof1al Bank VISA 01 tvlasterCaid Ac;:'-:;u~t (the "Account")_ The Account allows you to make puchases by Jsmg your VIS; or tvla~terCar;:; card (Lie "Card") wherever It IS honored and to gel cash advances from us or any othe' part clpatlng financiallnshtution and from Automated Teller Machnes Convenle:1ce checks iraI' al~o oe provided t,) you as an addltlonai wav to use the Accoun- in this P,greement, "you" and "your" !TIean each person for whom we have openea a credit carel Account "We" "'our," "ou's" ane "us" mean Pro'vldlan ~jatlonal Bank or ITs aSSignees, as listed on your billing statemen; The Account may be used only for personal, family, household, and chari:able purposes and not for Jny buo- ness or commerCial purpose Any use of this Account shall CO,1stltute acceptance of the terms of this Agreement. You and we agree as follows Payments. You will receive a monthly statement st'owmg your outstanding balance, Paymenton this Account is required In U S dollars (checks must be payable at a U S, ofke of lhe bank the check IS drawn on) for at least the payment due as shO\>vn on ycur statement by the payment oue dale In accordance With payment InstructiOns on your monthly statement The back of your statements shows the rules we follow when we post payments Convenience cleeks and other c~ecks we IS3UE to you may n:,; be 'Jsed to make pavmeilts on your Accouni or te- make paV"lents on any other accounl you have with us or our affiliates The payment due Will be, 2% of the new balance shown on your statemem plus the amount of any past due payment, and may IOCluae the amount by which the new balance exceeds your credit line However, the payment due Will not be less than $15 (unless your new balance IS less than S15. In whICh case the payment due Will be the amount of the new balance), If your Account is past due or above the credit Ime, we may require a higher minimum payment bul we Will notify you before dOing so If your payment IS more than the payment due, It will be treated as a single payment and none of It Will be applied to future payments due, We may accept iate or partial payments or payments marked "paid IrI full" or ~21rked with other restrictions, without losing our right to collect all amounts oWing under thiS Agreement Finance Charges. Except as described in the Grace Period for Purchase Balance section of thiS Agreement. fmance charges begin to accrue on a debit when It IS included In one of your Gaily balances and continue until that balance is reduced by a payment or credit. Your Account has the follOWing balances The Purchase Balance, which consists of your eXisting Purchase Balance and new purchases you make with your Card and fees for certain optional services; one or more Custom Cash Advance Balances, which consists of balances that you transfer to your Account using balance transfer checks and balances that we transfer for you, and the Cash ,Advance Balance which consists of all other cash advances and cash advance transaction fees Any payment amount we receive th~l exceeds the finance charges and fees then due Will ordinarily be applied first to the Balance With the lowest Annual Percentage. Rate (APR), until thaI Bala~ce IS zero. and then to the Balance With the next lowest APR, until that Balance IS zero, and then to any remaining Balance. We reserve the right to apply payments differently Without further notice. The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date posted_ Purchases are included in your Purchase Balance as of the date made. Custom cash advances are included in your Custom Cash Advance Balance as follows: funds electronically transmitted to other lenders to transfer balances, as of the date transmitted; checks to transfer balances, as of the date presented to us Other cash advances are included in your Cash Advance Balance as follows' cash advances from other financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are idenlified as cashier's checks and mailed to you at your request, as of seven days after the date we print on the check; all other checks, as of the date presented to us Other debits are Included in your Purchase, Custom Cash Advance, or Cash Advance Balance as of the date posted, Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the lasl day of the billing cycle. There is no grace period for custom cash advances or other cash advances To figure the daily finance charge for each type of Balance, we start With your prevIOUs day's Balance, add all debits and subtract all credits for the currenl day and multiply the net amount by the applicable daily periodic rate (see fOllowing paragraphs) The finance charge for each type of Balance IS then added to and Included in that day's Balance We treat a credit balance for any day as Zero. We determine Ihe total finance charges on balances for the billing cycle by adding together the finance charges for each type of Balance for each day Within the billing cycle, In calculating finance charges, an adjustment will be made for any transaction mpayment that would have affected the finance charge calculation in a prior billing cycle had it been posted in that cycle. The applicable daily penodlc rate for such a transaction will be the rate In effect for the current billing cycle rather than the rate in effect on the date of the transactIon. Your statement includes an average daily balance for each type of Balance_ You can multiply each average daily balance_ that is not zero by the number of days in the billing cycle and the periodic rate to obtain subtotals, and then add the subtotals together to determine your total finance charges on balances for the billing cycle. If a cash advance transaction fee IS charged, that amount is also a finance charge. The term "Prime Rate" as used in the Agreement means the highest prime rate published In the Waif Street Journal on the first business day of the previous calendar monlh. Any increase or decrease in the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight increase or decrease in the amount of your minimum payment The ANNUAL PERCENTAGE RATE (APR) for purchases will vary and may be adjusted each billing cycle up to 9.65% above Prime Rate, but wtll in no event be less than 17.9%. Using this formula, the APR for purchases in the January 2000 billing cycle is 18.15%, corresponding to a dally periodic rate of 0.04973%. The ANNUAL PERCENTAGE RATE for custom cash advances will vary and may be adjusted each billing cycle up to 9.4% above Prime Rate, but will in no event be less than 17,9%. Using this formula, the APR for custom cash advances in the January 2000 billing cycle IS 17.9%, corresponding to a daily periodic rate of 0.04904%. The ANNUAL PERCENTAGE RATE for cash advances w~1 vary and may be adjusted each billing cycle up to 11,65% above the Prime Rate, but will in no event be less than 19_9%. Using this formula, the APR for cash advances In the January 2000 billing cycle is 20.15%, corresponding to a daily periodic rate of 0.05521%. If your payment _is received late twice in any 12-month period, or if you significantly increase your lotal unsecured debt (as explained in the CREDIT REVIEW paragraph below), the APR for purchases may Increase, but will not exceed 21.9%, corresponding to a daily periodic rate of 0.06000%; and the APR for cash advances and custom cash advances may increase, bul will not exceed 23.9%, corresponding to a daily periodic rate of 0.06548% Your Account may be eligible for lower APRs after you have met the terms of this Agreement for three months. If you contact us, we will review your Account to determine your eligibility for lower APR, CREDIT REVIEW: SPECIAL REQUIREMENT. You agree nolto significantly increase your total unsecured debt. Your APR can increase (as explained above) based on a significant increase in unsecured debt, if your total unsecured debt and your total unsecured debt with other lenders each increases by more than 55,000 and your annual household income is less than four limes your total unsecured debt G~ce Period for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, do not begin to Incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due date shown on your statement. New purchases posted in any other blUing cycle incur a finance charge, and there is no period in which such purchases may be repaid without incurring a finance charge. Fees. We will charge your Account $0 for: each Card you ask us to replace; each returned payment; each check you write on your Account that we return unpaid; each stop payment order or renewal of su~h an order; each billing cycle within which your Account is delinquent (late charge); and each billing cycle within which your balance exceeds your credit line (overlimit fee), even if your Account IS closed. If you request copies of billing statements that were first sent to you more than three months earlier, we may charge a handling fee of $2 for each such copy. A cash advance fee of 3% (minimum $5), which IS a FINANCE CHARGE, may be charged for each cash advance transaction made on your Account. ~efault. You will be in defaull: if any information yo~ provided us prov~s to.be incomplete o~ untrue; if y.ou do n~t co,:"ply with ~ny part of this Agreement; upon your death, bankruptcy, or Insolvency; If you do n?t pay other debts when due; If a bankruptcy pet~tlon IS filed by or agalrlst.Y.ou; or If we believe Irl good faIth that you may not payor perform your obligations under this Agreement If you are In default we may, Without further demand or notIce, cancel your credIt pnvlleges, declare your Account balance immediately due and payable, and use any remedy we may have. In the.event of your default, the outstanding balance on your Account shall continue to accrue interest al the APR(s) disclosed in the Finance Charges section of this Agreement, even if we have filed SUit to collect the amount you owe. Credit Line. Your .cr~it line is s~cified fr?m time to t.ime in a separate notice. Xour monthly statem~nts show ,y?ur credit line an~ the amount of your available credit. We may increase or ~ecrea.se your cre~lt line based on information we obtained from you or your credit records. Your available credit ts normally the difference between your credit line and your Account balance (including transa~lions ma~ or authonzed but not yet posted). If you send us a large payment check, we may limit your available credit while we confirm that the check will clear. For certain transactIons, available credit may be less. You will not use your Account for, and we may refuse 10 honor, any transaction which would cause you to exceed your available credit. Promis~ to Pay. You promise to pay us when due al! amounts bo~row~ whe~ you or so~€C!ne else use your Account (even if the amount charged exceeds your permission), all other transact!ons and charges to your Account, and collection costs we Incur including, but not limited to, reasonable attorney s fees and court costs. (If you win the suit, we will pay your reasonable attorneys fees and court costs,) C~anges. After we provide you any notice required ~y law, we may cha.nge any part of this Agreement an~ add or remove requirements. If a change is made to the Finance Charges section of thIS Agreement, the new finance charge calculallon Will apply to your entire Account balance from the effechve date of the change. Changes will apply to balances that include items oosted to llQ1!L Account before the date of the chanae, and will apply whether or not you continue to use the Account. Foreign Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U.S. dollars, the transactions will be converted to U.S. dollars, generally using either a (i) government-mandated rate or (ii) wholesale market rate in effect the day before the transaction is processed, increased by three percent (3%). If a credit is subsequently given for a lransacllon, it (Continued on reverse) (5846-0698) 4217390552605848 1554 013 2561 ""''''''~f!'IlIli1'''''''-''''".~!_~I'I!'lII," . . ~...",- ----"--- , will be decreased by the same percentage. The currency conversion rate used on the conversion date may differ from the rate in effect on the date you used your Card. You agree to accept the converted amounlln U.S dollars The Card; Cancellation. You may cancel You"r ~~~ privileges at any time by notifying us in writing and destroYing the Card(s)", Upon the Card ,expiration at the end of the month shown on It. we reserve the fight nol to renew the Card. We may cancel the Card and your credit pnvile9€s atany lIme after 30 days notice to you, or without notice i~ permitted by I~w. If your, Card IS cancelled or not renewed, finance charges and other fees will conllnue 10 be assessed, payments will contmue to be due, and all other applicable provIsions of this Agreement will remain In effect If you terminate your credit privileges. or If weceancel or do not renew the Card, you may ndlonger wn'e checks on your Account, and you should destroy any unused checks we have Issued to you Personal Information; Documents, You will provide us at least 10 days notice if you change your name, home or mail!ng address, telephone n~mbers, employment or income, Upo~ our request, you will provide us additional financial Information. .We r~serve the. right to obtain Information from others, Inclu~lng :red[t r~portlng agencies, and to provide your address and information about your Account to others. We mavalso share information with our affiliates. However. vou may write to us at any time Instructino us not to share credit information with our affiliates If you do not fulfill your obligations under this !'9reement, a negative credit report that may reflect on your credit m~y_ be submitted to the credit reporting agencies. Customer Service; Unauthorized Use, Loss, or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safeguarding the Card, your Personalldentlficalion Number ("PIN", which provides access tGAutomated Teller Machines) and any checks Issued to you from theft, and keeping your PIN separate from your Card. If you discover or suspect that your Card, PIN, or any unused checks are lost or stolen, or tha! there may be an unauthoriz.ed transaction on your Account, you will promplly notify us by calling 1-800-933.,7221.. So we can Immediately act to limit losses and liabilit}', you will phone us even though you may also notify us In writing, Your liability for unauthorized use occurnng before you notify us [S limited to 550. If you report or we suspect unauthorized use of your Account, we may suspend your credit privileges until we resolve the problem to our satisfaction or issue you a new Card. If your Card IS lost or stolen, you will promptly destroy all checks In your possession. To improve customer service and secunty, you agree that your calls may be monitored or recorded Merchant Relations. We will not be liable ifany person or Automated Teller Machine refuses to honor the Card or accept your checks, or fails to return the Card to you, We have no responsibility for goods and services purchased with the Card or checks except as required by law. (See SpeCial Rule below.) Certain benefits that are available with the Account are provided by third-party vendors We are not responsible for the quality, availability, or results of any of the services you choose to use Stop Payment Orders. If you wish 10 s~ payment on a check, you may send us a stop payment order by writing to us at our address for customer service listed on yourstatemenl . You can make a stop payment order orally by callmg the number listed on your statement. When you make a stop payment order, you must provide your Account number and specific information about the check: the exact amount, the date on the check. the name of the. party to whom it was payable, the name of the person who signed it, and the check number. You will be asked to confirm an oral stop payment order m wntmg. We ma\l dsreoard \lour oral order If w.e do not recei'll,e a, sinned wflUen con~Imat)on wl\hm two weeks after the alaI order, .or If we ha\le not received an adequate deSCription of the Item so that payment can be stopped. The order will not be effectNe If the check was paid by us before we had a reasonable opportunity to act on the order. We may, Without liability, disregard a written stop payment order SIX months after receipt unless it IS renewed in writing. . Standard of Care. Because this Accollnt involves both credit card and check transactions which are processed through separate national systems before the transactions are consolidated by us, and because not every check and Card slip will be sent to us, transactions in your Account will be processed mechanically without our necessarily reviewing eNery item. Our processing system will call our attention to certain items which we will examine. We will examine all transactions when you report that ypur Card or checks have been lost or stolen. We do not intend ordinarily to examine all items, and we will not be negligent if we. do not do so, This rule establishes the standard of ordinary care which we In good faith will exercise in adminrstering your Account.. Because of our limited review, and because neIther your cancelled checks nor Card Iransacti~n slips will be returned to you with the monthly statement, you should be careful to enter all checks In your check register or otherwise keep a record of them. You should also save your credit card cash advance and purchase slips. You aoree to check vour monthlv statements aaainst vour record and to notiN us immediatelv of anv unauthorized transactions or errors. Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreementwithoutloslng our right to enforce it or any other provision later. You waive: the right to presentment, demand, protest or notice of dishonor; any applicable statute of limitations; and any right you may have to require us to proceed agamst anyone before we file SUit against you Applicable Law; Severability; Assignment. No matter where you li\le, this Agreemen1 and your Accoun1 are governed by federal la:w and 'r:Jy New Hampshire law, lhis Agreement is a flnal expressIon of the agreement between you and us and m?lY not be contradicted by eVidence of any alleged oral agreement. If any proviSion of this Agreement is held to be invalid or unenforceable, you and we will consider that provision modified to conform to appiicable law, and the rest of the provisions in the Agreement will still be enforceable. At any time after we determine in good faith that any proposed or enacted legislation, regulatory action, or Judicial.decision has rendered or may render any matenal provisions of this Agreement invalid or unenforceable, or impose any increased tax, reporting requirement, or other burden in connection With any such proviSion or its enforcement, we may, after at least 30 days notice to you, or without notice if permitted by law, cancel the Card and your Credit privileges. We may transfer or assign our right to all or some of your payments, If state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such notice by'filing a financing statement with the state's Secretary of State. Notices. Other notices to you shall be effective when deposited in the mail addressed to you at the, address shown on our records, unless a longer notice period is specified in this Agreement or by law, which period shall star! upon mailing, Notice to us shall be mailed to our address for customer service on your statement (or other addresses we may specify) and shall be effective when we receive it YOUR BILLING RIGHTS .- KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill. If you think your bHl is wrong or if you need more information about any transaction on your bill, write us on a separate sheet, at the address listed in the Billing RIghts Summal'f on your bill. Write to us as soon ,as possible, We must hear worn YOIl no later than 60 days after we sent you the nrst b\\\ on which the error or problem appeared. You can telephone us, but doing so will not preseNe your rights. In your Jetter, give us the fOllowing information: - Your name and Account number. -- The dollar amount of the suspected error. -- Describe the error and explain, if you can why you believe there is an error. If you need more information, describe the item you are not sure about. Your Rights and Our Respolfsibilities After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the bill was correct. After we receive your leiter, we cannot try to collect any amount you question, or report you as delinquent We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit line, You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. If we find t.hat we made a mistake o.n your bill, you will not have to pay any finance ~harge related to, any questioned amount. If we didn't make a mistake, you may have to pay finance .charges, and you Will have to make up the missed payments on the questioned amount. In either case, we WIll send you a statement of the amount you owe and the date that it is dl:le. If you fall to pay the amount we think you owe, we may report you as delmquent. However, if our explanatIon does not satisfy you and you write to us within 10 days telling us that you stili refuse to pay, we must tell anyone we report you to that you question your bill. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct. Special R~/e for Credit Card Purchases. If you have a problem with the quality of the property or services that you purchased with our credit card and you haye tried in good faith to correct the problem With the merchant, YOlJ may not have to pay the remaining amount due on the goods or services. There are two limitations on this right (a) you must have made the purchase in your home state, or if not within your home state, withm 100 miles of your current mailing address; and (b) the purchase price must have been more than $50. These limitations do nol apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. '. ~ ~- \J ~~"",,"MMJ ~~~ . ."_ . 0 _, ,~_~ - , " . . .~ h .~ ",-- 0 0 0 ~ ~ ~ C Cl "T1 1 '? 8 -om :J!:: :':J (I). nlfTl J''5I -':'1" C5 Z:.JJ ;:0 f)1-..1 d ,- 8 . zc co ;-lrTl ~ W-e;<::-:: 0 " _le"] ~ ~ -<.,~~ :;-~) 1 r-c ~:: ( ) ~~ -0 . jl "1; I -."( ) :~:!R (j'- ~~C\ ~ "- ~ ;t:-c..-: c'"' c'jm ...c:: -...c::. ~ z ~_.-j '\) =< I"~ J'> -.j :J:J -< ~ Lf? f ~ r'""tJ ~ 10-- . ,f' ~ ~r CJ~ ~ ~ cf ,"~~'~,41'_l!/fli _. ..."..""""",.,,~,"~ ~~~~UJ,,'~!'lJ~J~~JUJJI'~!fS'E''F.'''<-'''''l1'ry,ilor\~'~t!~JJI . SHERIFF'S RETURN - NOT FOUND / CASE NO: 2000-01957 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CQMBERLAND PROVIDIAN NATIONAL BANK VS GORMAN GERALDINE C R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GORMAN GERALDINE C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GORMAN GERALDINE C DEFT. NO LONGER RESIDES AT ADDRESS STATED, ALTERN ADDRESS NEVER RECIEVED, PAPER EXPIRED 5/1/00. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 6.20 5.00 10.00 .00 39.20 S~/ R. Thomas Krine Sheriff of Cumberland County PARK LAW ASSOCIATES 05/11/2000 Sworn and subscribed to before me this /';~ day of ~ ~ A.D. ~~~oer~~ ~ , . I HEREByHA'ftHE Wl'fH11\l IS A TRUE AND C()HFtECT COpy OF HE Of- Gi;~AL ON FILE, 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 :5 V ERIE ROSENBLUTH PARK . .',' .'.... ,." '.I'iTlcF'rliV-'Unn'f" A\\H:,:..I ,:..-_.-'!rl :."'_.1"" ~':. '" 'I~,_~~, . ATT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROVIDIAN NATIONAL BANK Plaintiff VS. GERALDINE C GORMAN Defendant NO. OO."./9S7 C"l..lll~~ 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 .. 4 th Floor, Cumberland County Courthouse .. ' " , Carlisle, PA 17013 TRUE COpy FROM RECORD (717) 240-6200 In Testimony whereQ1.1 ;bare untl}set my hand and the saaI of said Court at Carlisle, Pi. ~~>>~~. ofl{~~1!J~ THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ';' ~- "~- . 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#:4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 DEFENDANT NO. CIVIL Jt,.CTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, GERALDINE C GORMAN, is an individual who resides at 204 ALLENDALE RD, MECHANICEBURG, PA 17055-3401. 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by then Defendant or authorized by the Defendant on a credit card or line of credit ,"" owned by the Plaintiff bearing account number 4217390552605848. 4. The Defendant requested an account, account number 4217390552605848, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit "A" and made a part hereof. 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 $5,399.14 as of 12/31/1999, plus pre-judgment contractual interest at the rate of 17.90% 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 $1,079.83. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, 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. ,q:'1 '" - --"", 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. 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, less payments made, plus C9sts and any other such relief as this Court deems reasonable and ust. 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. ~= , -,., ~- VERIFICATION I, SUSAN M, WR~G~.n declare that as of January 10, 2000: I am a designated agent of PROVIDIAN NATIONAL BANK, 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. Am,l1Jt / !J Designated Agent ~ .,,'" I , Membership Request Certificate YES, 1'd like the VISA:' Gold card , with cash up to $10,000. Please ~end me the V!SA Gold card. and immediate cash if I have requested it b..!low. I agree to bl: bound by the Acco~t Agreement. (which will be ~iled to me whi:1n mr <J;<<ount is OI;eT'IedJ and to repay prirlcipal. interest, and. Lnteres~ 0 th<:lreoll. e:..<::e-pt that I will nave no obligaeion if r return the C3rd(5) and checlotJ (if appr'~le) un~ed. after ,re"iewmg the 4<<ount Agr~e~cnt. II .1.. ' TItisinc it,tion"'pi,,'" February 20, 1995 I!. ! Geraldine C. Gorman 634t stephens crossing Methanicsburg, PA 17055-2347475 II . " .. 1526A6 CTM40 GX919 HEB:i: QJQR OEHE L:BiD AEAD 30-. , . 526-09448-8591-7 I , , i ," ,j " I ;#dM~~f}1(]A ~r'4> 2_~(L-1~ ~ 0 Social curity Number i'. ; I <: . /11'9:: U-9()!;Z 717 %3f-1/1 & Hom:~hpne Work/Second Phone Ext. I I..'.'.". 1 ! I .i I ... ,~.. ,'",'.-r----. .----.--...."., i , I , , : ..] : \ :', "1" ~~:,~. ~~;;;",.~::~ ,;':: 'I":~ :;;.;::~;li~;iiilill~i!~;.i.i';;,.;;~ 'iii';;lI' ')1 ;';H"11,"" "" ''';'::!I' ;""" I, . ..!.,..,..,:...".,......" C~,.;i::,:.~':~:;;:R.eq. ues t VISA "" .: :~,: ,::;;:;,::~:!!,:.:,t-:':::.,::l:~~;~;:::.~:!:~~;m!~!r.~;::!.~-::~~~:I;:~;~"MM.~. ,'",...~ .. M '''.H'."'.''., .. {eference Nurnber: 4217390552605848 lox fear latch ;SN :,ccount # i!< :1104 : 95 :8 162661563 :4217390552605848 -.",- -, '" !:'J.i~\;;;;'"'' " ':'~~:::;:~=~~;~~7 I -;i VISA GOLD . . . No Annual Fee $10,000 Credit Line Immediate Cash Our lowest Interest Rates i . '.. / ; ~ /;1 I c- :IM ;'Sffr,t;( .!..,~ "".."':' Eileen Stack . Vice President 'jl '..i~m ~~ ~'~~l~l~~U!\.;:;~.l:;'~ ,;:~~':~7~: ,:,:~~~1:'" :;!,: . ., , J ; ;, . . ..." . I .... -.,," ....,- ,," ." . ~', .; ;~, '. ... : ' fMME:DcU"rE :C:f~~ " . o $10,000 o $4,000 Obtain Cash for Balance 1Iansfers or for any other reason. Check one: o $2,000 o $8,000 o $6,000 526-09QQe-8591-7 ,,_...... ." .....--?l,.....-----. '\;"' ',". :,.., "";':"::'"'' :""1,' GdldNowf PLAINTIFF'S I EirlT , MLHARTS FGl84 ?A? :; 1VI<:!im Na: O~2: Bar" /IS..:,@::o( l\!I;os:erCer,,jf) .>,cc::.ur Ag. e~l]ef1: fei Geroildlne C Gorm2f1 J2nu3~i '3 =XC PLAINTIFF'S ) EXIf ~j) i1J ~-~ I~)PROVIDIAN ---- Finollc;u/ 'lJiJiJ~~it7 ~~iHi~~ I I I I Please review this document and keep It with your ether Import2nt ~apers ,-hiS Accoun; ,A,::;reernent con,talf1S tre terms whiCh gC'i'2fn jour Provldlan National Bank VISA or MaSlerCarc Ac::u.~1 (the "Account"), The Account allows you to make purchases by IJslng your \/ISA or MasterCard card (tr';€ "Card") wherever It IS honored and to get cash advances from us or any other :::ar.:::oatm'9 financiallnstltullon and from Automaled Teller Machines Convenience creeks may also be provided to \IOU as an additional way to use the Account, In thiS ,6,greemenl, "you" ane "your'" ,nean each person for whom we have ope(\ed a credit card Account. "We," "our," "ours," and "us" mean ::lrovldlan National Bank or rts assignees, as listed on your billing statement The ,J"ccount mav be used only for personal, family, household, and charitable purposes, and ;n,ot for any bUSiness or commercial purpose Any use 0; t~IS !\ccount shall constitute acceptance of the terms of this Agreement You and we agree as follows Payments. You will receive a monthly statement shOWing your outstanding balar.ce Payment 'In thiS Account IS reqUired In U S collars (checks must be payable at a U.S office of the barK :he check IS drawn on) for alleast the payment due as shown on your statement by the payment due date In accordance with payment Instructions on your monthly statement. The bac:{ of your statemenls shows the rules we follow when we post payments Convenience checks and other checks we Issue to you may ,.:< c-e 'Jsed to make payments on your Account or to make pal/mants on any other account you have with us or our affiliates The payment due Will be 2% of the new balance shown on your st81emeii, pius the amount of any past due payment, and may InCIIJae the amount by which the new balance exceeds yourcreditl1n8 However, the payment due will not be. less than 515 (unless your new balance IS less than S15, In which case the payment due will be the amount of the new balance), If your Account is past due or above the credit line, we may reqUire a higher minimum payment but we will notify you before dOing so, If your payment IS more than the payment due" it Will be treated as a single payment and none of it Will be applied to future payments due, We may accept lale 'Jr partial payments, or payments marked "paid In full" or marked with other restrictions, without lOSing our right to collect all amounts owing under thiS Agreement Finance Charges. Except as described In the Grace Period for Purch<lse Balance section of thiS Agreement, finance charges begll1to accrue on a debit when it IS included In one of your dally balances and continue until thai balance is reduced by a payment or credit Your Account has the follOWing balances: The Purchase Balance, which consists of your existlf1g Purchase Balance and new purchases you make With your Card and fees for certain optional services, one or more Custom Cash Advance Balances, which conSists of balances that you transfer to your Account using balance transfer checks and balances that we transfer for you; and the Cash Advance Balance which conSists of all other cash advances and cash advance transaction fees. Any payment amount we receIVe that exceeds the finance char~es and fees then due Will ordlnanly be applied first to the Balance With the lowest Annual Percentage Rate (APR), until that Balance IS zero and then to the Balance with the next lowest APR, unhl that Balance IS zero, and then to any remaining Balance. We reserve the fight to apply payments differently Without further notice The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the dale posted. Purchases are included In your Purchase Balance as of the date made. Custom cash advances are included In your Custom Cash Advance Balance as follows. funds electronically lransmitted to other lenders to transfer balances, as of the date transmitted; checks to lransfer balances, as of the date presented to us, Other cash advances are included tn your Cash Advance Balance as follows' cash advances from other financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are identified as cashier's checks and mailed 10 you at your request, as of seven days after the date we print on the check; all other checks, as of the date presented to us. Other debits are Included in your Purchase, Custom Cash Advance, or Cash Advance Balance as of tne date posted. Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last day of the billing cycle. There is no grace period for custom cash advances or other cash advances To figure the daily finance charge for each type of Balance, we start with your previous day's Balance, add aU debits and subtract all credits for the current day and multiply the net amount by the applicable daily periodic rate (see follOWing paragraphs). The finance charge for each type of Balance is then added to and included In that day's Balance. We treat a credit balance for any day as zero. We determine the total finance charges on balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle, In calculating finance charges, an adjustment will be made for any transaction orpayment that would have affected the finance charge calculation in a prior billing cycle had it been posted in that cycle. The applicable daily periodic rate for such a transaction will be the rate In e~ecl for the current billing cycle rather than the rate in effect on the date of the transaction. Your statement includes an average daily balance for each type of Balance, You can multiply each average daily balance. that is not zero by the number of days in the billing cycle and the periodic rate to obtalf1 subtotals, and then add the subtotals together to determine your total finance charges on balances for the billing cycle, If a cash advance transaction fee is charged, that amount IS also a finance charge. The term .Prime Rate" as used in the Agreement means the highest prime rate published in the Wall Street Journal on the first business day of the previous calendar month. Any increase or decrease in lhe Annual Percentage Rate will lake effecl on the first day of your billing cycle and may result in a slight increase or decrease in the amount of your minimum payment The ANNUAL PERCENTAGE RATE (APR) for purchases will vary and may be adjusted each billing cycle up to 9,65% above Prime Rate, but will in no event be less than 17.9%. Using this formula, the APR for purchases in the January 2000 billing cycle tS 18.15%, corresponding to a dally periodic rate of 0.04973% The ANNUAL PERCENTAGE RATE for custom cash advances will vary and may be adjusted each billing cycle up to 9.4% above Prime Rate, but will in no event be less than 17.9%. Using this formula, the APR for custom cash advances in the January 2000 billing cycle is 17,9%, corresponding to a daily periodic rate of 0.04904%. The ANNUAL PERCENTAGE RATE for cash advances will vary and may be adjusted each billing cycle up to 11.65% above the Prime Rate, but will in no event be less than 19.9%. Using this formula, the APR for cash advances in the January 2000 billing cycle is 20.15%, corresponding to a daily periodic rate of 0,05521%. If your payment is received late. twice in any 12.month period, or if you significantly increase your tolal unsecured debt (as explained in the CREDIT REVIEW paragraph below), the APR for purchases may increase, but Will not exceed 21.9%, corresponding to a daily periodic rate of 0.06000%; and the APR for cash advances and custom cash advances may increase, but will not exceed 23.9%, corresponding to a daily periodic rate of 0.06548%. Your Account may be eligible for lower APRs after you have met the terms of lhis Agreement for three months. If you contact us, we will review your Account to determine your eligibility for lower APR,. CREDIT REVIEW: SPECIAL REQUIREMENT. You agree not to significantly increase your total unsecured debt. Your APR can increase (as explained above) based on a significant increase in unsecured debt, if your total unsecured debt and your total unsecured debt with other lenders each increases by more than 55,000 and your annual household income is less than four times your total unsecured debt Grace Period for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, do not begin to incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due date shown on your statement. New purchases posted in any other billing cycle incur a finance charge, and there is no penod in which such purchases may be repaid without Incurring a finance charge. Fees. We will charge your Account $0 for: each Card you ask us to replace; each returned payment; each check you write on your Account that we return unpaid; each stop payment order or renewal of such an order; each billing cycle within which your Account is delinquent (late charge); and each billing cycle within which your balance exceeds your credit line (overlimit fee), even if your Account is c1os~. . If you request copies of blUing statements that were first sent 10 you more than three months earlier, we may charge a handling fee of $2 for each such copy. A cash advance fee of 3% (minimum $5), which IS a FINANCE CHARGE, may be charged for each cash advance transaction made on your Account Default. Y~u will be in default if any information yo~ provided us prov~~ lo.be incomplete o~ untrue; if y.ou do n<?t cO'!1ply with ~ny part of this Agreement; upon your death, ba.nkruptcy, or . Insolvency; If you do not pay other debts when due; If a bankruptcy petl!lon IS filed by or against you; or If we beheve In good faith that you may not pay Of perform your obligations under thiS Agreement. jf you are in default we may, without further demand or nolice, cancel your credit privileges, declare your Account balance immediately due and payable, and use any remedy we may have. In the.event of your default, the outstanding balance on your Account shall continue to accrue, interest at the APR(s) disclosed in the Finance Charges section of this Agreement, even if we have filed SUit to collect the amount you owe. Credit Line. Your .cr~it line is sp~ified frl?m time to tjme in a separate notice. Xour monthly statem~nts show your credit line an~ the amount of your available credit. We may increase or ~ecrea.se your cre~ltline based on Info:rmatJon we obtained from you or your credit records. Your available credit is normally the dIfference between your credit line and your Account balance (Including lransacllons made or authonzed but not yet posted). If you send us a large payment check, we may limit your available credit while we confirm that the check will clear. For certain transactions, available credit may be less. You will not use your Account for, and we may refuse to honor, any transaction which would cause you to exceed your available credit. Promise to- Pay. You promise to pay us when due al! amounts bo~row~ whe~ you or sO~8<:'ne else. use your Account (even ifJh~ arnountcharged_~xceeds yQur.permission)....cill.9tb~.L ___.. transactions and charges to your Account, and collection costs we Incur IncludIng, but not limited to, reasonable attorney's fees and court costs. (If you win the suit, We will pay your reasonable allorney's fees and court costs.) C~anges. After we provide you any no.lice requ!red ~y law, we may cha.nge any part of this Agreement and add or remove requirements. If a change is made to the Finance Charges section of thiS Agreement, the new finance charge calculation Will apply to your entire Account balance from the effective date of the change. Changes will apply to balances that include items oosted to YQYL Account before the date of the cnanae, and will apply whether or not you continue to use the Account. Foreign Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U.s. dollars, the transactions will be converted to U.S, dollars, generally using either a (i) government-mandated rate or (ii) wholesale market rate in effect the day before the transaction is processed, increased by three percent (3%). If a credit is subsequently given for a transaction, it (Continued on reverse) (5846-0698) 4217390552605848 1554 013 Z561 '"~l1!l ,,'~'''''"'1'~!~lIt;."~'''''':''i"''''",.lllll" ,-. " ~ "'~,,- ~^' WI!! be ~creasep by the same percentage. The currency converSJon rate used on the conversion date may differ from the rate in effect on the date you used your Card Yau agree 10 aceee! the converted amount In U,S dollars The Card; Cancellation. You may canc;;i YoiSr c~~dft priVIleges at any InT1s by notifying us In writing and destroYing the Card(:ol U()on the Card eXpiration at Ih!:?: end of the month shown on It we reserve the right not to renew the Card. We may cancel the Card and your credit prlvlle~s at any r~me after 30 days nollce to yOU. or without nollce if permitted by law. If your Card IS cancelled or not renewed, finance charges and other fees Will continue 10 be assessed, payments Will continue 10 be due. and all other applicable prOVIsions of this Agreement Will remain In effect If you terminate your credit {XlVlleges. or If we cancel or do not renew the Card. you may no longer write checks on your Account, and yOll should aesrroy any unused checks we have Issued 10 'Iou Personal Information; Documents. You will prOVide us at leastlp days_ notice if you change your name, home or mailing addr.ess, telephone numbers, employment or Income Upon our request, you wJJJ proVIde us addilJOnal finanCIal mformahbn. We reSElNe the nghlto obtain mformatlon from others, mcludlng credit reporting agencIes. and !o proVIde your address and Informa!!on about your Account to others_ We mavalso share information with our affiliates However vou mav wnle to us at anv time IRslructlno us not 10 share credit Informallon with our affiliates If you do not fulfill your obligations under Ihls Agreement, a-negative credit report that may reflecl on your credit may be submitted to the credit reporting agencies. Customer Service; Unauthorized U:e, loss, or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safeguarding the Card, your Personalldenllilcation Number ("PIN", which provlde:s access t!)Automated Teller Machines) and any checks Issued to you from theft, and keepmg your .PIN separate from your Card. If you discover or suspect that your Card, PIN, or any unused checks are lost or stolen, or that there may be an unauthonz_ed transactl~ on you~ A~~ounl, you WIll promplly notify us by calling 1.800.933~7221. So we can Immediately act to limit losses and liability, you will phone us even though you may also notify uS In wfltlng. Your liability for unauthOrized use occurring before you notify us IS limited 10 S50 If you report or we suspect unauthOrized use of 'jour Account, we may suspend your credit pnvlleges until we resolve the problem to our salisfacllon or Issue you a new Card, If your Card IS lost or stolen, you will promptly destroy all checks In your possession. To Improve customer s~rvlce and secUrity, you agree that your caUs may be moMored or recorded Merchant Relations. We will not be liable if any person or Automated Teller Machme refuses to honor the Card or accept your checks, or fatls to return the Card to you We have no responsibility for goods and services purchased WIth lfie Card or checks except as required by law (See Special Rule below,) Certain benefits that are available with the Account are prOVided by third-party vendors_ We are not respon:ilble for the quality, availability, or results of any of the services you choose 10 use. Stop Payment Orders. If you wish to skip payment on ~ check, you may .send us a stop payment order by writing to us at our address for customer seNice listed on yours/atement ,You can make a stop payment order orally by calling the number \lstOO on your statement. When you make a stop payment order, you must prOVide your Account number and specific Information about the check: the exact amount, the dale on the check, the name of the party to whom it was payable, the name of the person who Signed II, and the check number You Will be asked to confirm an oral stop payment order In wnting, We mav dsreaard vour oral.order if w~ do not receive a.sianed written con~rmation within two weeks after the oral order,.or If we have not received an adeguate description of the Item so that payment can be stopped. The order WIll not be effective If the check was paId by us before we had a reasonable opportunity to act on the order. We may, without liabJlHy, disregard a written slop payment order six months after receipt unless if is renewed in writing . Standard of Care. Because this Account involves both credit card and check transactions which are processed through separate national systems before the transactions are consolidated by us, and because not every check and Card slipwiU be sentta us, transactions in your Account will be processed mechanically without our necessarily reviewing every item. Our proce~sin.g system will call our attention to certain items which we WIll examine. We will examine all transactions when you report that Y9ur Card or checks have been lost or stolen. We do not intend ordinarily to examine all items, and we will not be negligent if we. do not do so. This rule establishes the standard of ordinary care which we in good faith will exercise in administering your Account._ Because of our limited review, and because neither your cancelled checks nor Card transaction slips will be returned to you with the monthJy statemen~, you should be careful /0 entSf all checks (n .yolJ.r check register or othelWise keep a record of them. You should also save your credit card cash advance and purchase slips. You aaree to check vour monthlv statements aaalnst vour record and to notify us immedlatelv of anv unauthorized transactions or errors. Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. You waive: the, right to presentment, demand, protest, or notice of dishonor; any applicable statute of limItations: and any right you may have to reqUire us to proceed against anyone before we file suit agamst YOll. Applicable Law; Severability; Assignmeht. No matter where you live, this Agreement and your Account are governed by federal law and by New Hampshire law. This Agreement is a final expression of the agreement between you and us and m;;1y not be 'contradicted by eVIdence of any alleged oral agreement. If any proviSion of thiS Agreement IS held to be invalid or unenforceable, you and we will consider that provision modified to conform to applicab1e law, and the rest of the provisions in the Agreement will still be anforceable. At any time after we determine in good Faith that any proposed or enacted legislation, regulatory action, or judicial-decision has rendered or may render any material proviSIons of this Agreement invalid or unenforceable, or imp_ose any Increased tax, reporting requirement, or other burden in connection with any such provision or its enforcement, we may, after at least 30 days notice to you, or without notice if permitted by law, cancel Ine Card and your Credit privileges. We may transfer or assign our right to arr or some of your payments, If state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give y~u such notice by'filing a finanCing statement with the state's Secretary of State. Notices. Other notices to you shall be effective when deposited in the mail addressed 10 you at the addre~ shown on our recor~, unless a longer notice period is specified in this Agreement or by law, which period shall start upon mailing_ Notice to us shall be mailed to our address for customer seNiee on your statement (or other addresses we may specifj) and shall be effective when we rsceNe it. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Fair Credit Billlng Act. Notify Us in Case of Errors or Questions About Your Bill. If you think your bill is wrong or if you need more infor~ation about any transaction on your bill, write us on a separale sheet, at the address Hsted in Ihe Billing Rights Summary on your biU. Write to us as soon as pOSSIble. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: - Your name and Account number. .- The dollar amount of the suspected error. - Describe the error and explain, if you can why you believe there is an error. If you need more Information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the bill was correct. After we receive your leiter, we cannot tlY to collect any amount you question, or report you as delinquent We can conhnue to bill you for the amount you question, Including finance charges, and we can apply any unpaid amount against your credit line, You do not have to pay any questioned amount while we are investlgatmg, but you are still obligated to pay the parts of your bill that are not in questIon. If we find that we made a mistake on your bill, you will not have to pay any finance charge related 10 any questioned amoun!. If we didn't make a mistake, you may have 10 pay finance charges, and you will have to make up the missed payment; on the questioned amount. In either case, we will send you a statement ,of the amount you owe and the date that it is due. !f you fail to pay the amount we think you owe, we may report you as delinquent. However, if our explanation does not satis~ you arid you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you question your bin. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to thai the matter has been settled between us when it finally is. If we don't follow these rules, we can't collectlhe first $SO of the questioned amount, even if your bill was correct. Special R,!le for Credit Card Purchases. If you have a problem with the quality of the property or services thai you purchased with our credit card and you haye tried in good faith to correct the problem With the merchant, you may not have to pay the remaining amount due on the goods or seNices. There are two limitations on Ihis right: (a) you must have made the purchase in your home state, or if not within your home state, within 100 miles of your current mailing address; and (b) the purchase price must have been more than $50. These limitations do noi apply if we own or operate the merchant, or if we mailed you tne advertisement for the property or services. ~ ,~ ~ ~ ~r~~, ",,_'oJ.) " ..~~" \-! , 001 I;~ OI Zl I , ,'-, , , jd IE u~H ~ ~..\ '\;?::. - 4!;' \~4' ;'kr .;,1";:;:;' .'r-I:~' ~!i-i_L ~:u 3:)i.:L:W IfMJII!IIII~".,.""",,:,,W."W "1l!M ~,~ 11 rUl\j~,,]U~~~;Wn'1lt;Wjlj\lJ!!~~!!IIj!1fi\q~~jj'f!!l\I1IMl~ ,~F:ft.! I I, I' I I. ~. " '"l\ I ~ I' "^ I ;":' I "'" I'(J I: ~ I: I ~ I" , " I " il , VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM ORDER AND NOW, this :l..3rd. day of fY\~ ,2000, upon consideration of the Plaintiff's petition and upon Motion of Valerie Rosenbluth Park, Esquire, it is ORDERED and DECREED that the Defendant may be served in accordance with Pennsylvania Rules of civil Procedure, by mailing a true and correct copy of the Complaint to the Defendant at the Defendant's last known address bI both certifi fed mail, return receipt requested, and by first c ass mail, postage paiQ) A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. J. ~~ ,,'J..3-00 1\K.3 "'- "",', , _ '0 .,c:>';.'~, ,'" '1,:0-" ,,~-,",~,' - . ,_, e., _rn_ 'J~',',. _ '-"'. . . '\i'\\\\\j/\."\).SNN::d 1 ~~ \n~'r, ,...,,"/.,' ,_,/_".,r) 1\.1..1\1 \!~y,,~ !,_::'.:. - ~~,H'dl/\l I', 8 ..1\ :...'..\.1 0"7 \\1'1 flO ~ CV r"lifl U J..,'dV1C,<:>:.L'jc,:: :10 3~;.\:HCr{J3'1b:l , , - ~ ,-""" -~~ j ,. m'll'!',....~m..!"""~_III!IftIl'l~ ~~~"_'""",M__.. ~!B,! ~.11I1, lll"'~!jI _~,_,,~_ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of the Plaintiff by its attorneys, PARK LAW ASSOCIATES, P.C., respectfully represents that: 1. The Complaint was filed on 03-30-00. 2 . return of the hereof The Sheriff of CUMBERLAND of service of the Complaint on sheriff's return of service is and marked Exhibit "P-1". County made a "Not Found" 05-01-00. A true and correct attached hereto, made a part 3. The last known address of the Defendant is 204 ALLENDALE RD., MECHANICEBURG, PA 17055-3401. 4. Subsequent to the Plaintiff's attorneys' receipt of the Sheriff's "Not Found" return, Plaintiff's attorney made the described efforts to locate the whereabouts of the Defendant as indicated in the attached Affidavit of Investigation. 5. Despite Plaintiff's attorneys' inquiries, the Plaintiff has been unable to locate the Defendant. '-,'"0-- ,-j' ,,",-,'-'-' n.".'. ~_"",_,_" "'< - , ~"c_, . , 6. The Plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff's attorney shall file an affidavit of service showing service of the Complaint as set forth herein. PARK LAW ASSOCIATES, P. C / BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF > """'_--<J,..",,;-~,\t-"._-' _'u~""_ C ". -',-<',- _._-"~-;",,,~:~,_'t">"~.J?, .,C '-'C'._,_ ~~ u " :.: -e--~~~~'~.;--: -- - -- - - - - --- -- -- MAY 11 2101010 12:35 FR ~l~..~IFF717 2410 6397 TO 9121534841015 CASE NO, 2000-0~957 P , COMMONWEALTH OF l'ENNSYL~ COUNrY OF CUMBERLAND P.02/02 l'~OVIDIAN NATIONAL ~ -"_......, VS GORMAN GERALDINE C coo~ ',. R. Thomas Kline ~ . "Sheriff or Deputy Sheriff, who being .; - ... . duly s...orn according to ltll1, i;f8.ys, that he made a diligent search and ..Iii. inquiry for the within rtamed '!'efendant, nEFENDANT GORMAN GERALDINE C but was unable to locate ~ in his bailiwick. He therefore returns the COMl'LAINT & NOTICE f ~ , NOT FOUND , as to the within named DEFENDANT , GORMAN GERALDINE: C ....., . DEFT. NO LONGER RESIDES AT ADD~ESS STJ\.TED, ALTERN ADDRESS NEVER RECIEVED, PAPER EXPIRED 5/1/00. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 1ll.00 ~.20 5.00 10.00 .00 39.20 S:~;~ R. Thomas Iaine Sheriff of cumberland county PARK LAW ASSOCIATES .05/11/2000 Sworn and subscribed to.:b~for@ ltle EXHIBIT j-P-I this day ,of - , A.D. Prothonotary - ~,.: ,~- ** TOTAL PAGE.la2 ** -,,,,~~~.;.,..- COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she is the attorney for the Plaintiff in the foregoing matter; that she is authorized to take this affidavit on its behalf; and that the facts contained in the foregoing petition are true and correct to the best of her knowledge, information and belief. Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. VALERIE ~'_, _ ~~~_, _~."",,_.,. _~__ ~ ~_ _;_, _ ',~ __ _," " _" d,-.._~". '. ^" -- - - -,~'-':1'_ ." ,- ~ ~.; - VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a) A check of the local telephone directory shows that GERALDINE C. GORMAN does not have telephone number listing at the address of 204 ALLENDALE RD., MECHANICEBURG, PA 17055-3401. b) A letter addressed to the Defendant with the notation typed thereon, "Address Correction Requested, Do Not Forward" was not returned by the Post Office. c) A letter addressed to shows GERALDINE C. GORMAN is address of 204 ALLENDALE RD., Office's response is attached marked as Exhibit "A". the Office of Voter's Registration not a registered voter with an MECHANICEBURG, PA 17055-3401. The hereto, made a part hereof and d) A letter addressed to the Office Assesment shows GERALDINE C. GORMAN is not property at 204 ALLENDALE RD., MECHANICEBURG, Office's response is attached hereto, made marked as Exhibit "B". of the Board the owner of PA 17055-3401. a part hereof of the The and ", ^ - '. '~T" .> ._'_< "_",,-,' ~,-,_~'- -' " -, ,~. " .' -_ ,_n~ -,= e) A letter addressed addressed to GERALDINE C. MECHANICEBURG, PA 17055-3401 response is attached hereto, Exhibit "C". to the Postmaster shows that mail GORMAN at 204 ALLENDALE RD., is delivered. The Postmaster's made a part hereof and marked as Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. PARK LAW ASSOCIATES, P.C. ~/\-----/ BY: VALERI ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF . , , ~- .~-i" , ,., -.-' . -~,,~-- . . ,. , .. .. .. n' PARK LAW ASSOCIATES A PROFESSiONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O, BOX 1779 OOYLESTOWN. PENNSYLVANIA 18901 VALERIRROSENBLUTH PARK* ROBERT E, ANGST' TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 . ALSO MEMBER NJ BAR "'ALSO MEMBER FL BAR April 19, 2000 Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 ~EXH'B'T il ~~ ~ T" RE: GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBtJRG, PA 17055-3401 OUR FILE NO: 8703-1 Dear Sir/Madam: I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the add~ess for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Very truly yours, PARK LAW ASSOCIATES, P.C. MEL1~/U- BY: Legal Assistant . .- . Enclosure . ,...",.... . ~ ~ ! . ." ~ Name~-of Person: GERALDINE C GORMAN Current Address: Date of Registration: Date of Birth: Previous Registration Address: ~ o.DO\fe. - r-&.r.ercc6.. ~6()(1 (:::::, f'6T- 0... \'..e:J... \ &s~ \lekS \(\ L~~~ ,0\\. K~Qi'STlQ..\ :~" [.U:::;p/7.-bL __ _ _ rl'll"!l!!ll!'o, DOOZ I. ':I '" v ~d\f _"00 G~'n"tA:'a''A''O \\\t :\, ~. nt.'Q~~>_1 ~- , ,'lI"'!1 -~,~ ~"~ -.- ,!".-.'I~~~~.~ v'flll",,_ " ~..",,~!'I , ~I P AR...T( LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 OOYLESTOWN, PENNSYLVANIA 18901 VALERlEROSENBLUTH PARK' ROBERT E, ANGST' TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 . ALSO MEMaER NJ BAR +ALSO MEMBER. FL BAR April 19, 2000 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013-3387 EXHIBIT 12> ~ D " RE: GERALDINE C GORMAN Dear Sir!Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address; 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 Please note the name and address of the owner below and return this letter to me in the enclosed self- addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES,P.C. BY; ~L~ -tv ME I SA FLAK ~ Enclosure Property Address; 204 ALLENDALE RD,MECHANICEBURG, PA 17055-3401, Name of Owner: ~f~ ~ ~~"';f-k- ~W"_"\~> 0' Address of Owner: ~ L.'>. ~_ ~ I0.c LI?"~\~(bj Deed Book and Page No.: U 'f 315 P ARK LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET. SUITE 101 P,O. BOX 1779 DOYLESTOWN. PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK>/< ROBERT E, ANGST' TELEPHONE (215)348-5200 FACSIMILE (215) 348-4015 -ALSO MEMBER HJ BAR +AlSO MEMBER FL BAR Post Master United States Post Office MECHANICEBURG,PA 17055-3401 April 19,2000 EXHIBIT i1 !l--~- REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please flll1lish the new address or the name and street address~(ifa boxholder) for the following: Our file #: 8703 NAME: ADDRESS: GERALDINE C GORMAN 204 ALLENDALE RD MECHANlCEBURG, PA 17055-3401 NOTE: The name and last Imovrn address are required for change of address information. The name, if Imovrn, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information, The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney 2. I,Statute or regulation that empowers me to serve process (not required when requester is_an attorney): 3. The names of alllmown parties to the litigation: PROVIDIAN NATIONAL BANK VS. GERALDINE C GORMAN 4. The Court in which the case bas been OJ will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifYing number if one has been issued: CCP 6. The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRlMINAL PENALTIES INCLUDING A FINE OF UP TO $10:060 OR IMPRJSONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORETHAN 5 YEARS, (TITLE 18 U,S,C. SECTION 1001). I certify that the above information is true and that the address infonnation is needed ~G. "TIll be used solely for service flegal process in connection with actual or prospective litigation. cL "6 25 East State Street Doylestown, PA 18901 FOR POST OFFICE USE ONLY _No change of address order on file. NEW ADDRESS OR BOXHOLDER'S REGISTERED ADDRESS _Not Imovrn at address given ~ Moved, left no forwarding address. _No such address"_ POSTMARK: WHAT COUNTY IS TIDS ADDRESS IN? C63 THIS IS AN ATTEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED C,ll 'ill OOOZ 9 6 ~dV .~ - "'" . -~, ~ -~"~ 1Jn,.",~l1,Il><_='1"~_-r_ , ~lIII':Ilf;j~ ~l"!1!\IIi'~~1~_~~ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ..~ -," ___~~~fI~M!~ 0 (::J (j C 0 -.( ~ , ,J CG ;= n1 f '-, Z .- " " 2.': :J:; ~~~~ "~l yl cr. :; . (;~) yCf -r_l } ~~,~ j; .-- "' , 2~\.' :~~ ~.~~ ,,'C w >C~ ",-.' z :..:> ~:; =< :.1:.1 ,.0 -< ~, ",~lfl'l!lJI(_L ~,,- ~:~ "'J'-- , 06-/9S7 G~.nt PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. , . Sherry Clifford, Classified Ad Manager of THE SENTINEL , , of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Not;ce of Publication IN THE COURT OF COMMON PLEAS'OF~ CUMB_ERLAND COUNTY, PENNSYLVANIA, . #d9~9.51 DO,.,\\lIn;l\N NATIO~AL BANK vs. _~);' (f;ERACI:5' fiJE C. GOR~ NotiC:E!tb~ above named Def~nda;:';t(s): - man-aYe been named as a Defendant in a Civil Action n-siltiJtedl3Y the Plaintiff, Provi~ian Nat~o~al 8a~k, - - min-st you In this Court. Plaintiff, Provldlan National ariK a11~es in the Com plaint ,that you a~e in;:Jebted to the Plaintiff as result of your usmg a.ce:rtaln Visa ~old reclit- caTIrand failing to pay the Plaintiff the monlas due 'haElainYtrttncludlng interest and atto~ney's lees now , P-dueJne_PTaintiff alleged in the Complamt. ., IE::::'rdo-are'--l1ereby notified to plead to the Comp!al~t In IEtfits case of which above is a brief summary, wlthm ~nl:r(~dayS from the date of publicatio~, ~ ~- you wish to defend, you must enter a written appear- '::'-ance personally or by attorney and file your defenses, or oJ2.iection:~dn writing wit~ the C~urt, _ - YOu are warned that If you fall to do so, the case may """pro-c-e-e-d without you and a Ju~gment may ~e entered Wf'Jinst x.o_u without further notice forthe rehef requested I.....y 'h. e p.l..a.lhtiff. You ma.Y lose money or property. or,othe., ' i hts im-p"Cftfant to you, .:.. YOU Sf:!OULD TAKE THIS NOTICE TO YOUR LAW- Efi-ATONCE, IF YOU DO NOT HAVE A LAW'(ER Of{ -J\"NNDTAFFORD ONE, GO TO OR TELEPHONE . ~OE'FICE SET FORTH BELOW TO FIND OUT ",,-,-'i" flEREl'OU CAN GET LEGAL HELP, Ii!i;:- _:J Court Administrator ~4frl":::Floor, Cumberland County Courthouse ~ ~.':._'.- Carlisle, PA 17013 ~ --;-:..' 717-240-6200 .Ef.-.i .. J ~~~:. ~........ . ~--~-----~ July 4, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. ~ od /*~ ~ ~, 2:00 Sworn to and subscribed before me this 5 day of July , 2000 ~xk~ otary Public My commission expires: Notarial Seal , Wendy L. Metzger. Notary PubliC Carlisle Bora, Cum.berland County My Commission ExpIres June 2, 2001 Member, Pennsylvama Association of Notaries . . RETAIN THIS PORTION FOR YOUR RECORDS REMITTANCE ADDRESS I Bill TO THE SENTINEL - LEGAL & ASSOC. MELVYN S. MANTZ P.O. BOX 130, CARLISLE, PA 11013 AD NUMBER I CLASS SALESPERSON BILLING DATE LINES 180661 10 PUBLIC NOTICES c30 07/05/00 68 * 2 AD DESCR1PTION START DATE STOP DATE IN THE COURT OF COMMON PLEAS OF CUM 07/04/00 07/04/00 PUBLICATION INSERTIONS RATE NET AMOUNT GROSS AMOUNT ,3 THE SENTINEL - LEGAL 1 LGL 71.40 'rOTAL AD CHARGE 71. 40 3 PROOF OF PUBLICATION PROOF 6.25 DAYS RUN 7/11/00 PURCHASE ORDER . PAY THIS AMOUNT 77.65 93.18* Cs# 00-1957 . AFTER OB/04/00 MESSAGE: Thank you for advertising with The Sentinel. Deadlines for in-column legal advertisements: Monday is Friday at 11 a.m. ; Tuesday is Friday at 4 p.m.; Wednesday is Monday at 12 Noon; Thursday is Tuesday at 12 Noon; Friday is Wednesday at 12 Noon; Sunday is Thursday at 12 Noon. If you have any questions regarding your Legal bill please call Sherry Clifford, Classified Manager, at 243-2611, extension 204. Fax your legals to 243-3754, attention Sherry Clifford DETACH AND RETURN THIS PORTION WITH YOUR PAYMENT THE SENTINEL - LEGAL POBOX 130 CARLISLE PA 17013 Cs# 00-1957 . . AD NUMBER ClASSO START DATE STOP DATE 180661 PUBLIC NOTI.CES 07/04/00 07/04/00 AD DESCRIPTION BilLING DATE TELEPHONE NUMBER IN THE COURT OF COMMON PLEAS OF CUM 07/05/00 215-348-5200 GROSS AMOUNT OF 93.18 DUE AFTER 08/04/00 TOTAL AMOUNT DUE 77.65 & ASSOC. MELVYN S. MANTZ 25 E. STATE STREET P.O. BOX 2284 DOYLESTOWN, PA 18901 1",11/"1,1,1"11",,,,11,,,111 ENTER AMOUNT ENCLOSED 20200000001806610000000000000000931800000077655 ,-~-~ f;', . """ .".. '.'. ,JIJL ". 1 0 <000 '" .~ .\.l11J C' ~~= -06: fllC;1 z:::::. zc 0~{ ~:::Cj :..-.:;:(~ Z' >2 ~ o o ,- ,- i::'::: . . o ,! -' ;-j-l;:!J :31:3 2(1) -,-- -'I ~--n ~~~ ""t> '::;:J -< -ry ~ ~y .:.,) (J1 :!lIl!,~.","""_"""",~~,,MrJ~~!Nll>!,w.,C<'ll~BI~~~'~~I!!':II!i!l1l1J!~~-!<l;'Il'_1WlI ,.~_"""...... "l' VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. GERALDINE C GORMAN Defendant NO. 00-1957 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did attempt to serve the Defendant, GERALDINE C GORMAN, on 07-21-00, at his/her last known address located at 204 ALLENDALE RD. MECHANICSBURG, PA 17055-3401 by United states certified mail, Article No. 7099-320-0008-4396- 4848, Return Receipt Requested, Postage Paid, with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter with the appropriate notice to plead as set forth in Pennsylvania Rules of Civil Procedure. The United States Post Office attempted to serve the Defendant several times; however, the Certified Mail was returned to your deponent marked unclaimed, the original which is attached hereto, made a part hereof and marked Exhibit "A". That in accordance with the Order of Court, Valerie Rosenbluth Park, Esquire did serve the Defendant with a true and correct copy of the Complaint by United States Mail, Postage Paid, First Class on JULY 5, 2000 the original which is attached hereto, made a part hereof and marked Exhibit "B". TJ"::, ry- ,,' '-" " ...,~ ,-,', ~- ~,-^ -." -", " - . ~. ~ :~ 77TS8' : VALERIE ROSENBLUTH PARK, Attorney for Plaintiff Pursuant to the Fair Debt Collections Act, it is required state the following to you: This is an attempt to collect Any information obtained will be used for said purpose. ~";' ,-, ." ~--,;~ " ~ ' . , - ,-~ -, . -- ESQUIRE that we a debt. -'.' <0 3" <0 3" lJ S ="OOSt"H -:: rv If CERTIFIED MAIL AE-( Elf< I (DOlnes/le /Vlall Omy N I , 0 nsurance COll'erage P rOV1ded) ArtIcle Sent ro. ~ ...lJ IT" IT1 3" Postage $ Certified Fee Return ReceiPt Fee (Endoroement Required) Restricted Dellvel')f Fee (Endorsement Required) Tl)tal Postage & "ees <0 o o o IT1 IT" IT" o I'- . Complete "ems 1, 2, and 3, Also complel" item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. C. Signature o Agent o Addressee D. Is delivery address dffferentfrom ~m 1? Dyes ~ , x '.Mi~{!>>~ XJ'I~ ~ 11f~/l4 . /7DS:>= Yf/tJl If YES, enter delivery address below: 3. Service Type ~Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail, 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. A~e Number (Copy from service label) f.../.:/ d / __ /tJ9f- Y';;>-ZO -Cl?ri!If?- 7:> /Cor 'IR9'tY PS Fonn 3811 , July 1999 Domestic Return Receipt 102595-99-M-1789 y"'>l ~ .-" ,~, . ~ ~ <2- ~ ~. ~ ~ RJ~ &-~~ ~~~. ):::l ==-> "30>0> - :s a<::L{) es- ~ . c -- ~ ~ ~ ~~~ ~. ~ -l ..::s 0' Ul (j\ ~ ~ ~ .J \ '0 ~ , _ .--:i - i ~ =-n as -. :eCiJ .... :0 ca- _I>> 0: ... fl: .- II LL.= ,~"tl Om)> o JJ rs~" m~> -1m::E 0(0)> ::E-IOO z' cn - -c 0 ,,00 )>m); ....0'-1 IIlxm l!l....cn ...~~ ~ ~~~. CI 1::'" o ""ii: . :5-., !J ~[:! '" CJ. g~' e S!'~ Q) :t>r- r' (/) ...b.l.AJ 3: '-ITl,h N. Ot:lOOCll;r. ~...b ~;n~clcJ~ ~ I"'\..J -1(;>--~ ~ _ C~ ~ :D " '" :P m . . "- ~ .x Qftj 0 " . 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E o u '" .c fj~~:J~~~~~~~ :. ,'.':. ~ ~ ,~"." g~~~:f~~~'! ... '" '" ~ ~~~~,' ",~~:. " ' ..~.~.... ~~'~ ~ g ~~~l.~i~Jt~,,, C? :-, ,..:': .h"~ ':'''1;;..~i" ~ . . . E .. ~"....,_. .':.'" .~""'!... o u. (f.I h',' D- ~r, '"~",,~,~,.:-,,.: :'I""f.".!',. t, ~. ~ '_0 ~~ ~,,",r~ "! ~'- ".- .,.... ~ " ^- - _,V" "I'~ '" ,', ,,-. ~, .~ ~~." . , () <::) 0 c c " ;;: ~ :-;j :::JG:J 1f.j ;;.;,::0 CJfll . ..- ...--:.__l.J :fi~ ~~ (~'j ,".::u -ry ~:-J~=K "- ,~;:o 3 g(; ,'-0 Om 5c z U1 ~ =< 0 '< ,~$~~';''lI~m\HH''.~~IIll'Ml~'''~~~~"I.1 VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GERALDINE C GORMAN Defendant NO.00-19579633 322S see8 139~ 1818 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 $5,399.14 $1,079.83 $638.12 ($0.00) ($0.00) $7,117.09 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. 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 cor~ect copy of the notice pursuant to Pennsylvania Rule of Civil rocedure No. 237.1 is attached hereto and marked Exhibit II TOTAL VALERIE SENBLUTH PARK,ESQUIRE Attorn for the Plaintiff _ H_ "" , _, ,.._,'" ~_ _~ _", ' AND NOW, .QE'.~;P ,.;;)CXJn , Judgment is entered in favor of the P{aintiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. 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. 1._ "-!' . ,. _0 -, ""~,.,.~_; ~';. .'-j,~.'''7"T-,,,_ ,";_ .' ."<,,,-..~ - ., ,-., ~ ~- '- , VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 r ARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTOR..1\ffiY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, N1I 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTV.COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GERALDINE C GORMAN Defendant NO. 00-1957 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 EXHIBIT I#- DATE OF NOTICE: 8/14/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN_THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAJNST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER Th1PORTANT 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. COVRTADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4" FLOOR CARLISLE, P A 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 00-1957 7099-3220-0008-4396-4848 GERALDINE C GORMAN Defendant VERIFICATION OF NON-~ILITARY 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 GERALDINE c GO~, Defendant is over 21 years of age; that his/her place of residence/business is located at 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 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 19 0 and its amendmen PARK LA ASSOCIATES, P. . BY: Valle senbluth Park Attorney for Plaintiff .,0 "",- . _,-<0 .~ '-''-''-, ~I- - - T~ ~ __ '__'C' '~',~_' - VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 00-1957 7099-3220-0008-4396-4848 GERALDINE C GORMAN 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. PURSUANT TO THE FAIR DEBT COLLECTION PRAC 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. - ,',_,~", c'.,' -v--~~-v _'"-C'_" [ f! ~ ""9- --0 . 0 0 c) r-. - () ~; C) :;-,:) f ........ L0 B ....... -[1 r-~,: ..... U fTl{: . CT1 ~ L_:T~ u 3 ~ F- t15'~: (X) -.0 ~~ ~:: lU' "'~J 1- -'>'.-j -,', , ~ ~=-:: r-'; ~ ~'C',": (.0 (5 z ,'0,) ::;::i --j ::i] -< <:;) ~, ,,. -, -,-", " .-.-.","" ..,,", ."...' , " .' . ~ "",,~-~., ".- 1IIl1ill~~m _<'~~',_ _ ~"I, .,_. ,_~___ - ~ -, .)" Cumberland County Prothonotary's Office Civil Case Print 2000-01957 PROVIDIAN NATIONAL BANK (vs) GORMAN GERALDINE C PYS511 Page 1 Reference No. . : Case Type.....: COMPLAINT Judgment......: 7117.09 Judge Assigned: Disposed Desc. : ------------ Case Comments ------------- Filed. . . . . . . . : Time......... : Execution Date Jury Trial.... Disposed Date. Higher Crt 1.: Higher Crt 2.: 3/30/2000 3:27 0/00/0000 0/00/0000 ******************************************************************************** General Index Attorney Info PROVIDIAN NATIONAL BANK PLAINTIFF ANGST VALERIE ROSENBLUTH 295 MAIN STREET TILTON NH 03276 GORMAN GERALDINE C 204 ALLENDALE ROAD MECHANICSBURG PA 17055 3401 DEFENDANT ******************************************************************************** Judgment Index Amount Date Desc GORMAN GERALDINE C 7,117.09 9/08/2000 FAILURE TO PLEAD ******************************************************************************** * Date Entries * ******************************************************************************** 3/30/2000 5/11/2000 5/18/2000 5/23/2000 7/17/2000 8/11/2000 9/08/2000 9/08/2000 9/08/2000 FIRST ENTRY - - - - - - - - - - - - - - COMPLAINT - CIVIL ACTION ------------------------------------------------------------------- SHERIFF'S RETURN FILED Litigant.: GORMAN GERALDINE C SERVED : NOT FOUND PAPER EXPIRED 5/01/00 Costs....: $39.20 Pd By: PARK LAW ASSOCIATES 05/11/2000 ------------------------------------------------------------------- PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE ------------------------------------------------------------------- ORDER - DATED 5/23/00 - IN RE PETITION FOR SERVIE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE - BY EDWARD E GUIDO J COPIES MAILED 5/23/00 ------------------------------------------------------------------- PROOF OF PUBLICATION ------------------------------------------------------------------- VERIFICATION OF SERVICE ------------------------------------------------------------------- PRAECIPE FOR DEFAULT JUDGMENT AND DEFAULT JUDGMENT ENTERED ------------------------------------------------------------------- NOTICE MAILED TO DEFENDANT ------------------------------------------------------------------- VERIFICATION OF NON-MILITARY SERVICE - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - ******************************************************************************** * Escrow Information * * Fees & Debits Beq Bal Pvmts/Adi End Bal * ******************************************************************************** COMPLAINT TAX ON CMPLT SETTLEMENT JCP FEE JDMT/DEFAULT 35.00 .50 5.00 5.00 9.00 35.00 .50 5.00 5.00 9.00 .00 .00 .00 .00 .00 ------------ .00 54.50 54.50 ******************************************************************************** * End of Case Information * ******************************************************************************** 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 PROVIDIAN NATIONAL BANK Plaintiff VS. GERALDINE C GORMAN Defendant NO. CC - 195'7 Obi.L ~ 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. 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#:4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 DEFENDANT NO. HJ - /951 {l;d ~ CIVIL ~CTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, GERALDINE C GORMAN, is an individual who resides at 204 ALLENDALE RD, MECHANICEBURG, PA 17055-3401. 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 owned by the Plaintiff bearing account number 4217390552605848. 4. The Defendant requested an account, account number 4217390552605848, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit "A" and made a part hereof. 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 $5,399.14 as of 12/31/1999, plus pre-judgment contractual interest at the rate of 17.90% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit !lA, !I Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,079.83. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, 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 ln 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. 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VAL ...--.. 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. ,." . I, VERIFICATION SUSAN M. WRIGHl , declare that as of January 10, 2000: I am a designated agent of PROVIDIAN NATIONAL BANK, 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. Designated Agent ! 1 MembershIp Request Certificate YES, I'd like the VIS~ Gold card I with cash up to $10,000. Please ~nd me the VlSA Co!cl aud. and immediate cash if I have requested it bulow. .1 a~ to b.. bound by the ACCO!-Ult ~gP!'!D\en~ (which will be ~ed to me w""n my account is opened) alnd to repay principal, interest, and Interest:- th~reo~. e:xcept that [ will have no ubUgation if I ",turn the c:ard(s) and chl!C~ 0 (if aplj~le) unWled after re\1ewing the ~unt A~-!1l<:nt. l 'I . I '. . This' I Yio~exPires: Februar? 20, 1995 Ger~ldine c. Goim~~ 63~t stephens crossing Mebhanicsburg, FA 17055-2347475 II ! . .. i . '.,!', 1526A6 CTM40 GX919 HEBI QJQR oasa L~ED AEAD 30-" 1 ' 526-09ij48-8591-7 1 1 i .1 . I .' I ;A,'MMA.tt~~-n:t2A . JI-F.&~(L~L~ ~0 ~'{Z~-9fJ62~;ZlJt:e '1/~~ I I" I' ",,' , I ,. I , ,I I , ,,,,:.-:::.~~~:~:;~.:;;~::::~~;!.;~~~J~;~4:j,::: jlj';;'~'i";'~";':~~~=-'~":;!I' ;..." ..:. -:~~'i'" .:~,~..~.. . - :.:~~~ ,-O:\~-~---~- . -- -----.... -.- , ,. . 1 , : '..1 I " ',. ..!.:..: ".....!."......i...'....~... :':..':",~.:;,~..;,;,j.....:li'.];) . t' VIS'A' 'G "ld"N -. .., .. .... ; 'j,' ,"'" ....I': ;.",'" .,...........I".-:i1i.......riill't.1ml:fl"eaues Q ow, . . .' ,. ',.; ,,:..;,,:: ~:':.:: It, ".. .~~..,.;.!.:.':~~..;:;~....~.~~..:!:it~:.."' ;..~~ ;'::.~:::l....... ............ .. - "...."..,. "..... , .... " . ,~;..... .-............. , '" ".. , ,.. . ..' eference Number: 4217390552605848 : 1104 : 95 :8 : 162661563 :4217390552605848 .,,"~;:~~lU7.-.r."~~~'~Yc:' I '4 =1 " .0"1 . t ""mof t "~~.'.~~ ....A '1 f .,J ":'] '21 .~ I ~n~ :b ''';':i~~il.Cii ill! ~I .itl1fllf'. - '~'f.-.flI " ;1,' (' '''' " " ... "". '. ':::~~...":<., , "," VISA GOLD 52'75 I ----1i ... No Annual Fee $10,000 Credit Line Immediate Cash Our lowest Interest Rates " . .. , .'.i..~ _ .~ .~l' ( .. --- ;'~ It, !ptRHt~CZ Eileen Stack Vice President ;. .. t ~ ,~~ "l~!I,.il':';:.'I:i'.. ,i~:,' ':~7~i ':'1: ::.~ .';~)'_' :."..:' )~; :.!ot~:l;. :::.: ' I I' IMMEDIATE CAS~ Obtain Cash for Balance lIansfers or for any other reason. Check one: o $10,000 0 $8,000 0 $6,000 0 $4,000 0 $2,000 526-09448-8591-7 FCl84 ?A? MLHARTS .~f-~ . ,--- , J~PROVIDIAN Finul/ciu! Provldian Nat,onal Bank VISA@ or MasterCard@ Account Agreement for Geraldine C Gorman . Januar~ 13, 2'JOO PLAINTIFF'S I EX/( Please review this document and keep It with your other Importantpapers This Accoun: Agreement contains the terms which :Jovern your Drovldlan ~Iatlonal Bank VISA or MasterCard Account (the "Account"). The Account allows you to make purchases by uSing your VISA or MasterCard card (the "Card") wherever Ills honored and to get cash advances from us or any other partlclpatrng financial Institution and from Automated Teller Machines Convenience checks may also be provided to you as an additional way to use the Account In thiS Agreement, "you" and "your" mean each person for whom we have openeu a credit card Account "We," "our," "ours," and "us" mean Provldlan National Bank or Its assignees, as listed on your billing statement The Account may be used only for personal, family, household, and charitable purposes, and not for any bUSiness or commerCial purpose. Any use of thiS Account shall constitute acceptance of the terms of thiS Agreement. You and we agrl:!e as follows Payments. You Will receive a monthly statemenl shOWing your outstanding balance. Payment on thiS Account IS required In U S dollars (checks must be payable at a US office of the bank the check IS drawn on) for at least the payment due as shown on your statement by the payment due date in accordance With payment Instructions on your monthly statement The back of your statements shows the rules we follow when we post payments Convenience checks and other checks we Issue to you may n0: be 'Jsed to make payments on your Account or to make payments on any other account you have With us or our affiliates The payment due will be 2% of the new balance shown on your statement piuS the amount of any past due payment, and may Include the amount by which the new balance exceeds your credit line. However, the payment due Will not be less than $15 (unless your new balance IS less than 515, In which case the payment due will be the amount of the new balance) If your Account IS past due or above the credit line, we may require a higher minimum payment bul we Will notify you before dOing so If your payment IS more than the payment due, It Will be treated as a Single payment and none of It Will be apptled to future payments due. We may accept late or partial payments or payments marked "paid In full" or marked with other restrictions, without lOSing our nght to collect all amounts oWing under thiS Agreement Finance Charges. Except as descnbed In the Grace Period for Purchase Balance seclion of thiS Agreement finance charges begin to accrue on a debit when It IS Included In one of your daily balances and continue until that balance IS reduced by a payment or credit. Your Account has the follOWing balances The Purchase Balance, which consists of your eXisting Purchase Balance and new purchases you make with your Card and fees for certain optional services; one or more Custom Cash Advance Balances, which consists of balances that you transfer to your Account using balance transfer checks and balances that we transfer for you; and the Cash Advance Balance which consists of all other cash advances and cash advance transaction fees Any paymenl amount we receive that exceeds the finance charges and fees then due will ordinarily be applied firsl to the Balance With the lowest Annual Percentage Rate (APR), until that Balance IS zero, and then to the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balance. We reserve the right to apply payments differently Without further notice. The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date posted Purchases are included In your Purchase Balance as of the date made. Custom cash advances are included In your Custom Cash Advance Balance as follows funds electronically transmitted to other lenders to transfer balances, as of the date transmitted; checks to transfer balances, as of the date presented to us. Other cash advances are included In your Cash Advance Balance as follows cash advances from other finanCial Instttutlons and through Automated Tellers, as of the date made; cash advance checks made payable to you that are identified as cashier's checks and mailed to you at your request, as of seven days after the date we prrnt on the check, all other checks, as of the date presented to us. Other debits are Included In your Purchase, Custom Cash Advance, or Cash Advance Balance as of the date posted. Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last day of the billing cycle. There is no grace period for custom cash advances or other cash advances To figure the daily finance charge for each type of Balance, we start with your prevIous day's Balance, add all debits and subtract all credits for the current day and mulltply the net amount by the applicable daily periodic rate (see following paragraphs). The finance charge for each type of Balance is then added to and Included in that day's Balance We treat a credit balance for any day as zero We determine the total finance charges on balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle. In calculating finance charges, an adjustment will be made for any transaction or payment that would have affected the finance charge calculatton in a prior billing cycle had it been posted in that cycle. The applicable daily penodlc rate for such a transaction will be the rate in effect for the current billing cycle rather than the rate in effect on the date of the transaction. Your statement includes an average daily balance for each type of Balance You can multiply each average daily balance that is not zero by the number of days in the billing cycle and the penodic rate to obtain subtotals, and then add the subtotals together to determine your total finance charges on balances for the billing cycle. If a cash advance transactton fee IS charged, that amount IS also a finance charge. The term 'Prime Rate" as used in the Agreement means the highest prrme rate published in the Wall Street Journal on the first bUSiness day of the previous calendar month. Any increase or decrease In the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight increase or decrease In the amount of your minimum payment. The ANNUAL PERCENTAGE RATE (APR) for purchases will vary and may be adjusted each billing cycle up to 965% above Prime Rate, but will in no event be less than 17.9%. USing thiS formula, the APR for purchases In the January 2000 billing cycle is 18.15%, corresponding to a daily periodic rate of 0.04973%. The ANNUAL PERCENTAGE RATE for custom cash advances will vary and may be adjusted each billing cycle up to 9.4% above Prime Rate, but will in no event be less than 17.9%. Using this formula, the APR for custom cash advances In the January 2000 billing cycle is 17.9%, corresponding to a daily penodic rate of 0.04904%. The ANNUAL PERCENTAGE RATE for cash advances will vary and may be adjusted each billing cycle up to 11.65% above the Prime Rate, but will in no event be less than 19.9%. Using this formula, the APR for cash advances in the January 2COO billing cycle is 20.15%, corresponding to a daily periodic rate of 0.05521%. If your payment is received late twice In any 12-month period, or if you significantly increase your total unsecured debt (as explained in the CREDIT REVIEW paragraph below), the APR for purchases may Increase, but will not exceed 21.9%, corresponding to a daily periodic rate of 0.06000%; and the APR for cash advances and custom cash advances may increase, but will not exceed 239%, corresponding to a daily perrodlc rate of 0.06548% Your Account may be eligible for lower APRs after you have met the terms of this Agreement for three months. If you contact us, we will review your Account to determine your eligibility for lower APRs. CREDIT REVIEW: SPECIAL REQUIREMENT You agree not to significantly increase your total unsecured debt. Your APR can increase (as explained above) based on a significant increase in unsecured debt, if your total unsecured debt and your total unsecured debt with other lenders each increases by more than 55,000 and your annual household income is less than four ttmes your total unsecured debt. Grace Period for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, do not begin to incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due date shown on your statement. New purchases posted in any other billing cycle incur a finance charge, and there is no period in which such purchases may be repaid without incurring a finance charge. Fees. We will charge your Account $0 for: each Card you ask us to replace; each returned payment; each check you write on your Account that we return unpaid; each stop payment order or renewal of such an order; each billing cycle Within which your Account is delinquent (late charge); and each billing cycle within which your balance exceeds your credit line (overlimit fee), even if your Account is closed. If you request copies of billing statements that were first sent to you more than three months earlier, we may charge a handling fee of $2 for each such copy. A cash advance fee of 3% (minimum $5), which is a FINANCE CHARGE, may be charged for each cash advance transaction made on your Account. Default. You will be in default: if any information you provided us proves to be incomplete or untrue; if you do not comply with any part of this Agreement; upon your death, bankruptcy, or Insolvency; if you do not pay other debts when due; if a bankruptcy petition is filed by or against you; or if we believe in good faith that you may not payor perform your obligations under this Agreement. If you are in default we may, without further demand or notice, cancel your credit privileges, declare your Account balance immediately due and payable, and use any remedy we may have. In the event of your default, the outstanding balance on your Account shall continue to accrue interest at the APR(s) disclosed in the Finance Charges section of this Agreement, even if we have filed suit to collect the amount you owe. Credit Line. Your credit line is specified from time to ttme in a separate notice. Your monthly statements show your credit line and the amount of your available credit. We may increase or decrease your credit line based on information we obtained from you or your credit records. Your available credit is normally the difference between your credit line and your Account balance (including transactions made or authorized but not yet posted). If you send us a large payment check, we may limit your available credit while we confirm that the check will clear. For certain transacltons, available credit may be less. You will not use your Account for, and we may refuse to honor, any transaction which would cause you to exceed your available credit. Promise to Pay. You promise to pay us when due all amounts borrowed when you or someone else use your Account (even If the amount charged exceeds your permission), all other transacltons and charges to your Account, and collection costs we incur including, but not limited to, reasonable attorney's fees and court costs. (If you win the suit, we will pay your reasonable attorney's fees and court costs.) Changes. After we prOVide you any nottce required by law, we may change any part of this Agreement and add or remove requirements If a change is made to the Finance Charges section of this Agreement, the new finance charge calculalton will apply to your entire Account balance from the effective date of the change. Changes will apply to balances that include items oosted to ~ Account before the date of the chance, and will apply whether or not you continue to use the Account. Foreign Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U.S dollars, the transacltons will be converted to U.S. dollars, generally using either a (i) government-mandated rate or (ii) wholesale market rate in effect the day before the transaction is processed, increased by three percent (3%) If a credit is subsequently gNen for a transaction, It (Continued on reverse) (5846-0698) 4217390552605848 1554 013 Z561 will be decreased by the same percentage The currency conversion rate used on the conversion date may differ from the rate In effect on the date you used your Card. You agree to acceot the converted amount In IJS dollars -"~ The Card; Cancellation, You may canc~j your credit pnvileges at any lime by notifying us In writing and destroYing the Card(s) . Upon the Card eXpiration at the end of the month shown onll we reseNe the fight not to renew the Card. We may cancel the Card and your credit pnvlleges at any lime after 30 days notice to you or without nolice if permitted by law. If your Card IS cancelled or not renewed, finance charges and other fees will continue to be assessed, payments will continue to be due, and all other applicable provIsions of this Agreement will remain In effect If you terminate your credit pnvlleges, or If we cancel or do not renew the Card, you may n'-"Ionger wfl'e checks on your Account, and you should destroy any unused checks we have Issued to you Personal Information; Documents. You will provide us at least 10 days notice if you change your name, home or mailing address, telephone numbers, employment or Income Upon our request, you will provide us addilional flllanclallnformalion. We reseNe the nght to obtain Informalion from others, including credit reporling agencies, and to provide your address and information about your Account to others. We may also share information with our affiliates However. you may wnte to us at any time Instruclina us not to share credit informalion with our affiliates If you do not fulfill your obligations under thiS ~reement, a negative credit report that may reflect on your credit may be submitted to the credit reporting agencies Customer Service; Unauthorized Use, Loss, or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safeguarding the Card, your Personalldenlificalion Number ("PIN", which provides access t(}Automated Teller Machines) and any checks Issued to you from theft, and keeping your PIN separate from your Card. If you discover or suspect that your Card, PIN, or any unused checks are lost orstolen, or that there may be an unauthorized transaction on your Account, you will promptly notify us by calling 1-800-933-7221. So we can Immediately act to limit losses and liability, you will phone us even though you may also notify us In writing. Your liability for unauthonzed use occurnng before you nolify us IS limited to S50 If you report or we suspect unauthonzed use of your Account, we may suspend your credit pnvileges until we resolve the problem to our satisfaction or Issue you a new Card. If your Card is lost or stolen, you will promptly destroy all checks in your possession. To improve customer seNlce and secunty, you agree that your calls may be momtored or recorded Merchant Relations. We Will not be liable If any person or Automated T eUer Machine refuses to honor the Card or accept your checks, or falls to return the Card to you. We have no responsibility for goods and services purchased With the Card or checks except as required by law (See Special Rule below) Certain benefits that are available with the Account are provided by third-party vendors We are not responsible for the quality, availability, or results of any of the services you choose to use Stop Payment Orders. If you wish to s~ payment on a check, you may send us a stop payment order by writing to us at our address for customer seNice listed on yourstatement. You can make a stop payment order orally by calling the number listed on your statement. When you make a stop payment order, you must provide your Account number and specific informalion about the check the exact amount, the date on the check, the name of the party to whom it was payable, the name of the person who signed it, and the check number You Will be asked to conflfm an oral stop payment order In writing. We mav Iisreaard your oral order If we do not receive a sianed wntten confirmalion Within two weeks after the oral order, or If we have not received an adequate descnplion of the Item so that payment can be stopped. The order will not be effeclive if the check was paid by us before we had a reasonable opportunity to act on the order. We may, without liability, disregard a written stop payment order six months after receipt unless it IS renewed in writing Standard of Care, Because this Account ~volves both credit card and check transactions which are processed through separate nalional systems before the transactions are consolidated by us, and because not fNery check and Card s~will be sent to us, transactions in your Account will be processed mechanically without our necessarily reviewing every item. Our processing system will call our attention to certain items which we will examine. We will examine all transactions when you report that your Card or checks have been lost or stolen. We do not intend ordinanly to examine all items, and we will not be negligent if we. do not do so. This rule establishes the standard of ordinary care which we in good faith will exercise In administering your Account. Because of our limited reView, and because neltner your cancelled checks nor Card transaction slips will be returned to you with the monthly statement, you should be careful to enter all checks In your check register or otherwise keep a record of them You should also save your credit card cash advance and purchase slips. You aaree to check your monthlv statements aaainst your record and to notltv us Immediatelv of any unauthonzed transactions or errors. Waiver of Certain Rights. We may delay or waive enforcement of any proviSion of this Agreement without lOSing our right to enforce It or any other proviSion later You waive the right to presentment, demand, protest, or notice of dishonor; any applicable statute of limitations; and any right you may have to require us to proceed against anyone before we file SUit against you Applicable Law; Severability; Assignment. No matter where you live, thiS Agreement and your Account are governed by federal law and by New Hampshire law ThiS Agreement IS a final expression of the agreement between you and us and m?y not be contradicted by evidence of any alleged oral agreement. If any proviSion of thiS Agreement is held to be Invalid or unenforceable, you and we Will consider that provision modified to conform to applicable law, and the rest of the provisions in the Agreement will still be enforceable. At any time after we determine in good faith that any proposed or enacted legislation, regulatory action, or Judicial decision has rendered or may render any material prOVisions of this Agreement invalid or unenforceable, or impose any increased tax, reporting requirement, or other burden in connection With any such proviSion or its enforcement, we may, after at least 30 days notice to you, or without notice if permitted by law, cancel the Card and your Credit privileges. We may transfer or assign our right to all or some of your payments If state law requires that you receive nolice of such an event to protect the purchaser or assignee, we may give you such notice by'filing a financing statement with the state's Secretary of State. Notices. Other nolices to you shall be effective when deposited in the mall addressed to you at the address shown on our records, unless a longer nolice period IS specified in this Agreement or by law, which period shall start upon mailing. Notice to us shall be mailed to our address for customer seNice on your statement (or other addresses we may specify) and shall be effective when we receive It. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Falf Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill, If you think your bill is wrong or if you need more information about any transaction on your bill, write us on a separate sheet, at the address listed In the Billing Rights Summary on your bill. Write to us as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preseNe your rights. In your letter, give us the following information -- Your name and Account number. -- The dollar amount of the suspected error. - Describe the error and explain, if you can why you believe there is an error. If you need more information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice, We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to bill you for the amount you question, Including finance charges, and we can apply any unpaid amount against your credit line. You do not have to pay any questioned amount while we are investlgaling, but you are still obligated to pay the parts of your bill that are not in queslion. If we find that we made a mistake on your bill, you will not have to pay any finance charge related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up the missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that il is due. If you fail to pay the amount we think you owe, we may report you as delinquent. However, if our explanalion does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you question your bill. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct. Special Rule for Credit Card Purchases, If you have a problem with the quality of the property or seNices that you purchased with our credit card and you haye tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or seNices. There are two limitations on this right: (a) you must have made the purchase In your home state, or if not within your home state, within 100 miles of your current mailing address; and (b) the purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or seNices. ~ ~\l ~ ~ 6'" ~ ~ --l::.. ~ "'- ~ ~ ~ v...Y'tC;. ~ % - I \ ~ ~~ S- o 0 c 0 S. ~ -0 r;; :; '.'" rn \;-; Z".' ::'0 <.f' C., 0)>' 0 ,;: % z~~i~ Y'C~ ~ N -< _-l o ~~".."1.,Q ",.J \:J i L .".~ (,) . -~.1 '.",} \;:~:?l '..:? ( )''' ~;; ::0 -< ....,.., -'" L ~ \\J- , " . - ... ~ ? SHERIFF'S RETURN - NOT FOUND / CASE NO: 2000-01957 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS GORMAN GERALDINE C R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GORMAN GERALDINE C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GORMAN GERALDINE C DEFT. NO LONGER RESIDES AT ADDRESS STATED, ALTERN ADDRESS NEVER RECIEVED, PAPER EXPIRED 5/1/00. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 6.20 5.00 10.00 .00 39.20 so.) a~.~ rs:/~ ~~b R.I Thomas Kline Sheriff of Cumberland County PARK LAW ASSOCIATES 05/11/2000 Sworn and subscribed to before me this P{1:; day of ~ ~ A.D. ~~oer~/~ II'-:EPG~;,\- IS A TFLL (, THE. OH ~,11 HE WFfHIN '.Ci GOPY OF :~)N FiLE 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 5 -<?)!.L ;-i Pi~qK ,c::"-~'v=rnnHf- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROVIDIAN NATIONAL BANK Plaintiff VS. GERALDINE C GORMAN Defendant NO. DO -/9S7 C"Olr-r~ 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 TRUE COpy FROM RECORD (717) 240-6200 In Testknony whereof,lhere unto set my hand and the seal of said Court at Carlisle,. Pa. ~y~~. oi{J2~4JJf'd-- THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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#:4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 DEFENDANT NO. CIVIL !CTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, GERALDINE C GORMAN, is an individual who resides at 204 ALLENDALE RD, MECHANICEBURG, PA 17055-3401. 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 owned by the Plaintiff bearing account number 4217390552605848. 4. The Defendant requested an account, account number 4217390552605848, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit "A" and made a part hereof. 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 $5,399.14 as of 12/31/1999, plus pre-judgment contractual interest at the rate of 17.90% 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 $1,079.83. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, 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. 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,399.14, plus pre-judgment interest at the contractual rate of 17.90% per annum from 12/31/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,079.83, less payments made, plus costs and any other such relief as this Court deems reasonable and ust. 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. VERIFICATION I, SUSAN Nt WR~GHru , declare that as of January 10, 2000: I am a designated agent of PROVIDIAN NATIONAL BANK, 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. Ikm,;/f . / !/ Des1gnated Agent I I Membership Request Certificate YES, 1'd like the VISN Gold card I with cash up to $10,000. Please ~nd me the vrSA Gold card and immediate cash if I have requested it ""low. I agre<< to bl: bound by the Account Agreemen~ (which will be ~ed to me wn.,n mv account is "E""ed) and to "'pay prirlcipal. interest, and lnb!rese: th~reo'!'. exce-pt that I will have no u~ligation If r return the C3rO(s) ~nd checIU 0 (if app['caflel un~ed after re\"iewing the ~ount Agr~ement. I 'I .1 '. . This inJ italion expires: February 20, 1 995 Ii.' .! ... Geraldine C. Gorman 634 t stephens Crossiri'g Nethanicsburg, FA 17055-2347475 II . i : .. I ' ;1. : . 1526A6 CTM40 GX919 BEB! QJQR aBBB LiH~D AEAD 30-'" I ' 526-09448-8591-7 I I II ,'1 ,I .' I . I . x~AAIdUr /Jb~ 'aA?/7I(1A !fiir~ . . ~n-Tr~B1e)._ ~r! (P 2.-~(L-1.:J ~ 0 Social curity Number . . I ,. . ~tz~-9~t1&!: 1/1f I I" I''''" , I I i ~eference Number: 4217390552605848 ~ox 'ear ~atch ;SN .,r aunt # : 1104 : 95 :8 : 162661563 :4217390552605848 03~::;;l~~~''''': ;1 ''''''''j'- -<:'~l' ..,.....l ~i . ~ ,,,;,J .".~....c ......,.1 . ': n. ~j~ ,.~ .19.:"../. -2) -::'i :. ,.:.1 .") '24,'''.' <~ '":':." .:-..'" ;Ul .; ~:..~:ci'C~'f.-~ 'o'C:"" "fiif.i.~"~~-""'f . "~ VISA GOLD ... No Annual Fee $10,000 Credit Line Immediate Cash Our Lowest Interest Rates j .* ,., / ' '"' / /., /v'ItM 6tfrCt( ---- Eileen Stack Vice President . 'i:'..i~. : ' IMMEDIATE :CAS~ !i!q;..,;:. ",.,,::'. ,;,;.' ':.~~~; ';", :::.:;':~~"':-' ::!.:..~,~~~' ;.;.~:: "; Obtain Cash for Balance Transfers or for any other reason. Check one= o $10,000 0 $8,000 0 $6,000 0 $4,000 0 $2,000 MLHARTS 526-09q4~-a591-7 FGl84 PLAINTI.FF'S I E~IT f ?R? I ----;i I 'I . .. ; F. ., .,-~ IifjPROVIDIAN ~' Fil/al/cia! Ji Ji i1J iJ~ if) io ~~. ~ Provrdran National Bank VISi\@ or MasterCard@ Account Aq.'eement fot Geraldine C Gorman Januarv 13, 2000 PLAINTIFF'S I EXHif ~~~ Please review thiS document and keep It with your other Important papers ThiS Account Agreement contains the terms which gO'iern your Provldlan ~,Iatlonal Bank VISA or MasterCara Account (the "Account") The Account allows you to make purchases by uSing your VISA or MasterCard card (the "Card") wherever Itrs honored and to get cash advances from us or any other partic"pallng flnanclallnstrtutlon and from Automated Teller Machines Convenience checks may also be prOVided to you as an additional way to use Ihe Account. In thiS Agreement, "you" and "your" mean each person for whom we have opeTlj:d a credit card Account. 'We," "our: "ours," and "us" mean Provldlan National Bank or rts assignees, as listed on your billing statement. The Account may be used only for personal, family, household, and charrtable purposes, and not for any business or commerCial purpose Any use of thiS Account shall constitute acceptance of the terms of thiS Agreement. You and we agree as follows Payments. You Will receive a monthly statement shOWing your outstanding balance Payment on thiS Account IS reqUired In U S dollars (checks must be payable at a US office of the bank the check IS drawn on) for at least the payment due as shown on your statement by the payment due date In accordance With payment Instructions on your monthly statement The back or your stalements shows the rules we follow when we post payments. Convenience checks and other checks we Issue 10 you may n:': 'ce used to make payments on your Account or to make oayments on any olher account you have wilh us or our affihates The payment due Will be 2% of the new balance shown on your Slalemer" plus the amount of any past due payment, and may Inclu(le the amount by which the new balance exceeds your credit line However, the payment due Will not be less than $15 (unless your new balance IS less than $15, in which case the payment due will be the amount of the new balance). If your Account is past due or above the credit hne, we may require a higher minimum payment. but we Will notrfy you before domg so. If your paymenllS more than the payment due, It Will be treated as a Single payment and none of It will be applied to future payments due We may accept late Jr partial payments, or payments marked "paid In full" or mrked With other restnctrons, Without lOSing our right to collect all amounts oWing under thiS Agreement Finance Charges. Except as descnbedln the Grace Period for Purchase Balance seclion of thiS Agreement, finance charges begin to accrue on a debit when It is Included In one of your dally balances and continue until that balance IS reduced by a payment or credit Your Account has the follOWing balances The Purchase Balance, which consists of your existrng Purchase Balance and new purchases you make With your Card and fees for certain optional seNICes; one or more Custom Cash Advance Balances, which consists of balances that you transfer 10 your Account using balance transfer checks and balances that we transfer for you; and the Cash Advance Balance which consists of all other cash advances and cash advance transaction fees. Any payment amount we receive that exceeds the finance charges and fees then due Will ordinarily be applied first to the Balance with the lowest Annual Percentage Rate (APR), until that Balance IS zero, and then to the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balance. We reseNe the nght to apply payments differently without further notice The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date posted. . Purchases are Included In your Purchase Balance as of the date made Custom cash advances are included In your Custom Cash Advance Balance as follows' funds electronically transmitted to other lenders to transfer balances, as of the date transmitted; checks to transfer balances, as of the date presented to us. Other cash advances are Included In your Cash Advance Balance as follows cash advances from other financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are idenlified as cashier's checks and mailed to you at your request, as of seven days after the date we print on the check; all other checks, as of the date presented to us. Other debits are Included in your Purchase, Custom Cash Advance, or Cash Advance Balance as of the date posted. Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last day of the billing cycle There IS no grace period for custom cash advances or other cash advances. To figure the daily finance charge for each type of Balance, we start with your prevIous day's Balance, add all debits and subtract all credits for the current day and mulliply the net amount by the applicabte daily periodic rate (see follOWing paragraphs). The finance charge for each type of Balance is then added to and Included in that day's Balance. We treat a credit balance for any day as zero. We determine the total finance charges on balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle. In calculating finance charges, an adjustmentwill be made for any transaction or payment that would have .affected the finance charge calculalion in a prior billing cycle had it been posted in that cycle. The applicable daily periodic rate for such a transaction will be the rate In effect for the current billing cycle rather than the rate in effect on the date of the transaction. Your statement Includes an aver3ge daily balance for each type of Balance. You can multiply each average daily balance that is not zero by the number of days in the billing cycle and the penodic rate to obtain subtotals, and then add the subtotals together to determine your total finance charges on balances for the billing cycle. If a cash advance transaction fee is charged, that amount IS also a finance charge. The term 'Prime Rate' as used in the Agreement means the highest prime rate published in the Wall Street Journal on the first bUSiness day of the previous calendar month Any increase or decrease In the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight Increase or decrease in the amount of your minimum payment. The ANNUAL PERCENTAGE RATE (APR) for purchases will vary and may be adjusted each billing cycle up to 965% above Prime Rate, but will in no event be less than 17.9%. USing this formula, the APR for purchases in the January 2000 billing cycle is 18.15%, corresponding to a daily periodic rate of 0.04973% The ANNUAL PERCENTAGE RATE for custom cash advances will vary and may be adjusted each billing cycle up to 9.4% above Pnme Rate, but will In no event be less than 17.9%. Using Ihis formula, the APR for custom cash advances in the January 2000 billing cycle is 17.9%, corresponding to a dally periodic rate of 0.04904%. The ANNUAL PERCENTAGE RATE for cash advances will vary and may be adjusted each billing cycle up to 11.65% above the Prime Rate, but will in no event be less than 19.9%. Using this formula, the APR for cash advances in the January 2000 billing cycle is 20.15%. corresponding to a daily periodic rate of 0.05521%. If your payment is received late twice in any 12-month period, or if you significantly increase your total unsecured debt (as explained In the CREDIT REVIEW paragraph below), the APR for purchases may increase, but Will not exceed 21.9%, corresponding to a daily periodic rate of 0.06000%; and the APR for cash advances and custom cash advances may increase, but will not exceed 23.9%, corresponding to a daily periodic rate of 0.06548% Your Account may be eligible for lower APRs after you have met the terms of this Agreement for three months. If you contact us, we will review your Account to determine your eligibility for lower APRs. CREDIT REVIEW: SPECIAL REQUIREMENT. You 39ree not to significantly increase your total unsecured debt. Your APR can increase (as explained above) based on a significant Increase in unsecured debt, if your total unsecured debt and your total unsecured debt with other lenders each increases by more than 55,000 and your annual household income is less than four times your tolal unsecured debt. Grace Period for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, do not begin to incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due date shown on your statement. New purchases posted in any other billing cycle incur a finance charge, and there is no period in which such purchases may be repaid without incurring a finance charge. Fees. We will charge your Account $0 for: each Card you ask us to replace; each returned payment: each check you write on your Account that we return unpaid; each stop payment order or renewal of such an order; each billing cycle Within which your Account is delinquent (late charge); and each billing cycle within which your balance exceeds your credit line (overlimit fee), even if your Account is closed. If you request copies of billing statements that were first sent to you more than three months earlier, we may charge a handling fee of $2 for each such copy. A cash advance fee of 3% (minimum $5), which is a FINANCE CHARGE, may be charged for each cash advance transaction made on your Account. Default. You will be in default: if any information you provided us proves to be incomplete or untrue; If you do not comply with any part of this Agreement; upon your death, bankruptcy, or insolvency; if you do not pay other debts when due; if a bankruptcy petition is filed by or against you; or if we believe in good faith that you may not payor perform your obligations under this Agreement. If you are in default we may, without further demand or notice, cancel your credit privileges, declare your Account balance immediately due and payable, and use any remedy we may have. In the event of your default, the outstanding balance on your Account shall continue to accrue interest at the APR(s) disclosed in the Finance Charges section of this Agreement, even if we have filed suit to collect the amount you owe. Credit Line. Your credit line Is specified from time to time in a separate notice. Your monthly statements show your credit line and the amount of your available credit. We may increase or decrease your credit line based on information we obtained from you or your credit records. Your available credit is normally the difference between your credit line and your Account balance (including transactions made or authorized but not yet posted). If you send us a large payment check, we may limit your available credit while we confirm that the check will clear. For certain transactions, available credit may be less. You will not use your Account for, and we may refuse to honor, any transaction which would cause you to exceed your available credit. Promise to Pay. You promise to pay us when due all amounts borrowed when you or someone else use your Account (even if the amount charged exceeds yourpermission)~all other ...- transactions and charges to your Account, and collection costs we incur including, but not limited to, reasonable attorney's fees and court costs. (If you win the suit, we will pay your reasonable attorney's fees and court costs.) Changes. After we provide you any notice required by law, we may change any part of this Agreement and add or remove requirements. If a change is made to the Finance Charges section of this Agreement, the new finance charge calcul.ation will apply to your entire Account balance from the effective date of the change. Changes will apply to balances that include Items oosted to ~ Account before the date of the chanae, and will apply whether or not you continue to use the Account. Foreign ExchangelCurrency Conversion. If you use your Card for transactions in a currency other than U.S. dollars, the transactions will be converted to U.S. dollars, generally using either a (i) government-mandated rate or (ii) wholesale market rate in effect the day before the transaction is processed, increased by three percent (3%). If a credit is subsequently given for a transachon, It (Continued on reverse) (5846-0698) 4217390552605848 1554 013 Z561 will be d~reasep by the same percentage. The currency converSion rate used on the conversion date may differ from the rate ir effect on 'he eate you usee your Care You agree to acceot the converted amount In U S dollars The Card; Cancellation. You may canc~i Y;:;;r c;~ privileges at any time by notifying us In writing and destroYing the Car?!,) Uoon the Card eXpiration at the end of Ihe monlh shown on it we reserve Ihe right not to renew the Card We may cancel the Card and your credit prlVlle!;:.es at any t'me after 30 days nolice to vou 'or without notice If permitted by law If your Card IS cancelled or not renewed, finance charges and other fees Will continue 10 be assessed. payments Will continue 10 be due. and all other aopllcable provIsions of thiS Agreement will remain In effect if you lermlnate your credit privileges or If we cancel or do not renew the Card. you may no longer write checks on your Account. and you snoulc cestroy any unused checks we nave Issued to you Personal Information; Documents. Yoo Will provide us at least 10 days notice If you change your name. home or mailing address. telephone numbers. employment or Income Upon our request, you Will prOVide us additional flIlanClallnformatlon. We reserve the right to obtain Information from others, Including credit reporting agencies, and to prOVide your address and information about your Account to others We mavalso share Information with our affiliates However YOU may write to us at any time I~structlna us not 10 share credit information with our affiliates If you do not fulfill your obligations under thiS Agreement. a negative credit report that may reflect on your credit may be submitted to the credit repcmng agencies Customer Service; Unauthorized U~e.loss. or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safeguarding the Card, your Personal Identification Number ("PIN', which prOVides access tG Automated Teller Machines) and any checks Issued to you from theft. and keeping your PIN separate from your Card. If you discover or suspect that your Card. PIN. or any unused checks are lost or stolen. or that there may be an unauthoflzed transaction on your Account, you Will promptly notify us by calling 1.800.933.7221 So we can immediately act 10 limit losses and liability, you will phone us even though you may also notify us In writing Your liability for unauthOrized use occurnng before you notify us IS limited to S50 If you report or we suspect unauthOrized use of 'lour Account, wemay suspend your credit pnvlleges until we resolve the problem to our salisfactlon or Issue you a new Card If your Card IS lost or stolen. you Will promptly destroy all checks In your possession. To improve customer service and secunty, you agree that your calls may be monitored or recorded Merchant Relations. We Will not be liable If any person or Automated Teller Machine refuses to honor the Card or accept your checks, or falls to return Ihe Card to you We have no responSibility for goods and services purchased With the Card or checks except as reqUired by law (See Special Rule below.) Certain benefits that are avaliable With the Account are prOVided by third-party vendors We are not responsible for the ~lity. availability, or results of any of the services you choose to use Stop Payment Orders. If you Wish to slql payment on a check, you may send us a stop payment order by wrlling to us at our address for customer service listed on your statement You can make a stop payment order orally by calling the number listed on your statement When you make a stop payment order, you must provide your Account number and specific Informalion about the check the exact amount, the date on the check, the name of the party to whom It was payable, the name of the person who Signed It, and the check number You Will be asked 10 confirm an oral stop payment order In writing. We mav Iisreoard Your O~I order if we do not receive a sioned written confirmation Within two weeks after the oral order, or If we have not received an adequate descnption of the Item so that payment can be stopped. he order Will not be effective If the check was paid by us before we had a reasonable opportunity to ael on the order We may, Without liability, disregard a written stop payment order six months after receipt unless it is renewed ;n writing Standard of Care. Because this Account involves both credit card and check transactions which are processed through separate national systems before the transactions are consolidated by us. and because not PNery check and Card slip will be sent to us. transactions in your Account will be processed mechanically Without our necessanly reViewing every item. Our processing system will call our al1ention to certain items which we will examine. We will examine all transactions when you report that ypur Card or checks have been lost or stolen. We do not intend ordinanly to examine all items. and wa will not be negligent if we. do not do so. This rule establishes the standard of ordinary care which we in good faith Will exercise in administenng your Account. Because of our limited reView, and because neilt1er your cancelled checks nor Card transaction slips will be returned to you with the monthly statement, you should be careful to enter all checks In your check register or otherwise keep a record of them. You should also save your credit card cash advance and purchase slips. You aQree to check your monthlv statements aaainst your record and to notify us Immediatelv of any unauthorized transactions or errors. Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without lOSing our right to enforce It or any other proviSion later You waive: the nghllo presentment, demand. protest, or notice of dJshonor; any applicable statute of limitations; and any right you may have to reqUIre us to proceed against anyone before we file suit against you Applicable Law; Severability; Assignment. No matter where you live, this Agreement and your Account are governed by federal law and by New Hampshire law This Agreement is a final expression of the agreement between yoo and us and mi;ly not be contradicted by eVidence of any alleged oral agreement If any proviSIOn of thiS Agreement IS held to be Invalid or unenforceable, you and we will consider that provision modified to conform to app1icable law, and the rest of the provisions In the Agreement will still be enforceable. At any time after we determine in good faith that any proposed or enacted legislation, regulatory action. or Judicial deciSion has rendered or may render any material provIsions of thiS Agreement invalid or unenforceable. or impose any increased tax, reporting requirement, or other burden in connection with any such prOVISion or its enforcement, we may. after at least 30 days notice to you, or without notice if permitted by law, cancel the Card and your Credit privileges. We may transfer or assign our right to all or some of your payments. If state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such notice by'filing a financing statement with the state's Secretary of State. Notices. Other notices to you shall be effective when depoSited in the mail addressed to you at the address shown on our records, unless a longer notice period is specified in this Agreement or by law, which period shall start upon mailing. Notice to us shall be mailed to our address for customer service on your statement (or other addresses we may specify) and shall be effective when we receive it. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responSibilities under the Fair Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill. If you think your bill is wrong or if you need more infor~ation about any transaction on your bill. write us on a separate sheel, at the address listed in the Billing Rights Summary on your biU. Write to us as soon as poSSible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: - Your name and Account number. - The dollar amount of the suspected error. - Describe the error and explain, if you can why you believe there is an error. If you need more information. describe the Item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days. we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit line You do not have to pay any questioned amount while we are investigating. but you are still obligated to pay the parts of your bill that are not in question If we find that we made a mistake on your bill, you will not have to pay any finance charge related to any questioned amount. If we didn't make a mistake. you may have to pay finance charges. and you will have to make up the missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us Within 10 days telling us that you still refuse to pay. we musltell anyone we report you to that you question your bill. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is If we don't follow these rules. we can't collect the first $50 of the questioned amount, even if your bill was correct Special Rule for Credit Card Purchases. If you have a problem with the quality of the property or services that you purchased with our credit card and you have tried in good faith to correct the problem With the merchant. you may not have to pay the remaining amount due on the goods or services. There are two limitations on this right: (a) you must have made the purchase In your home state, or if not within your home state, within 100 miles of your current mailing address; and (b) the purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services \~" ' , nn \.'.~ 0- "'1'. U\)$ ',~. l L, ~ ~ ~; \ \,~ , j .1 ~. ~.,.,:' ~;;':, ' ....r (" \ f. U~\\ I' (;../ ,: ;;l:lC ~. ~ "Q ~ ~ .~ J .~ . ~ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM ORDER AND NOW, this :2..3rd. day of fY\~ ,2000, upon consideration of the Plaintiff's Petition and upon Motion of Valerie Rosenbluth Park, Esquire, it is ORDERED and DECREED that the Defendant may be served in accordance with Pennsylvania Rules of Civil Procedure, by mailing a true and correct copy of the Complaint to the Defendant at the Defendant's last known address br both certified mail, return receipt requested, and by first c ass mail, postage paicn A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. J. ~~ " 'J.3~OO ~K.3 ~ () :H \ :H c;~ ;\ '~; 1.,J 0 0 ArJ':/lC. i~. :JC) VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of the Plaintiff by its attorneys, PARK LAW ASSOCIATES, P.C., respectfully represents that: 1. The Complaint was filed on 03-30-00. 2 . return of the hereof The Sheriff of CUMBERLAND of service of the Complaint on sheriff's return of service is and marked Exhibit "P-1". County made a "Not Found" 05-01-00. A true and correct attached hereto, made a part 3. The last known address of the Defendant is 204 ALLENDALE RD., MECHANICEBURG, PA 17055-3401. 4. Subsequent to the Plaintiff's attorneys' receipt of the Sheriff's "Not Found" return, Plaintiff's attorney made the described efforts to locate the whereabouts of the Defendant as indicated in the attached Affidavit of Investigation. 5. Despite Plaintiff I s attorneys' inquiries, the Plaintiff has been unable to locate the Defendant. 6. The Plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff I s attorney shall file an affidavit of service showing service of the Complaint as set forth herein. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ':g~.--- MAY 11 2000 12:36 FR ~ ~ !M!RIFF717 240 6397 TO 912153484015 .......~'".-, . --. P.e2/e2 CASE NO: 2000-01957 P . COMMONWEALTH OF PENNSYLVMftA COUNTY OF CUMBERLAND P~OVIDIAN NATIONAL BANK --- "'lIiL VB GORMAN GERALDINE C ---~ '. R. Thomas Kline ~ ..~,lhl!!lriff or Deputy Sheriff, who being duly sworn according to 1a~, ~, that he made a diligent search and .-oj. . inquiry for the within ftamedtltendant, DEFENDANT GORMAN GERALDINE C - but was unable to locate ~ in his bailiwick. He therefore returns the COMPlAINT &: NOTICE -, ...... -7" , NOT FOUND , as to the within named DEFENDANT .. ~.' GORMAN GERALDINE C .'.l . DEFT. NO LONGER RESIDES AT .AI)I)RESS STATED, ALTERN ADDRESS NEVER RECIEVED'wp>>a PPlRED 5/1/00. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 11.00 ~.20 5.00 10.00 "'l ...00 39.20 SO~.~ R~~S ~1ne Sheriff of Cumberland County PUK LAW ASSOCIATES 05/11/2000 this day of _ Sworn and subscribed ec ~fort me A.D. Prothonotary ~ ** TOTl=l. Pl=G. e2 ** '''"i . .~ J, '11"""" I:~~~...,"..' ,.' '~ :t~,,'~: '.' "t"t :~, I '\it ,~, ....' t.'. 'tl' .' {{ \ , , t t~~ " Jj\ f:\.' ~.,~~~~j-~\". COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she is the attorney for the Plaintiff in the foregoing matter; that she is authorized to take this affidavit on its behalf; and that the facts contained in the foregoing Petition are true and correct to the best of her knowledge, information and belief. Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. ~ VALERIE ~OSENBLUTH PARK, ESQUIRE VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 CIVIL TERM CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a) A check of the local telephone directory shows that GERALDINE C. GORMAN does not have telephone number listing at the address of 204 ALLENDALE RD., MECHANICEBURG, PA 17055-3401. b) A letter addressed to the Defendant with the notation typed thereon, "Address Correction Requested, Do Not Forward" was not returned by the Post Office. c) A letter addressed to shows GERALDINE C. GORMAN is address of 204 ALLENDALE RD., Office I s response is attached marked as Exhibit "An. the Office of Voter's Registration not a registered voter with an MECHANICEBURG, PA 17055-3401. The hereto, made a part hereof and d) A letter addressed to the Office Assesment shows GERALDINE C. GORMAN is not property at 204 ALLENDALE RD., MECHANICEBURG, Office I s response is attached hereto, made marked as Exhibit "B". of the Board the owner of PA 17055-3401. a part hereof of the The and e) A letter addressed to the Postmaster shows that mail addressed to GERALDINE C. GORMAN at 204 ALLENDALE RD., MECHANICEBURG, PA 17055-3401 is delivered. The Postmaster I s response is attached hereto, made a part hereof and marked as Exhibit "C". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. PARK LAW ASSOCIATES, P.C. BY: k~ VALERI ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF P ARK LAW ASSOCIATES A PROFESSIONAl. CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH P ARK* ROBERT E. ANGST* TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 . ALSO MEMBER NJ BAR +ALSO MEMBER FL BAR April 19, 2000 Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 OUR FILE NO: 8703-1 Dear Sir/Madam: I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the address for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Very truly yours, PARK LAW ASSOCIATES, P.C. MEL1(~ iii- BY: Legal Assistant Enclosure Name of Person: GERALDINE C GORMAN Current Address: Date of Registration: Date of Birth: Previous Registration Address: -0~ G-bc\\fQ-\~-C~:Y.erCfr:::L~~<5cj(1 \~ \'Cy~ G- \~\~J~ . ?~ \(\ CU0\\:ws\0s6.-L~ ,01-\-. Q L7n ,STI-r. j , ~ 1-" f, "nnfl..b( OOOZ L G ~d\f ~(,,"f..o.e'b (';~,"f'''''~. ~. . '.~i-\ \\\t ,\,\ ~ '(\1. ~ .. P ARK LA. W ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH P ARK* ROBERT E. ANGST* TELEPHONE (215)348-5200 FACSIMILE (215) 348-4015 'ALSO MEMBER NJ BAR +ALSO MEMBER FL BAR April 19, 2000 Office of the Tax Assessor of Cumberland County Cumberland County Cowthouse I Courthouse Square Carlisle, PA 17013-3387 RE: GERALDINE C GORMAN Dear Sir/Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 Please note the name and address of the owner below and return this letter to me in the enclosed self- addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES, P.C. BY:~~ MELI SA FLAK . Enclosure Property Address: 204 ALLENDALE RD,MECHANICEBURG, PA 17055-3401, Name of Owner: ~fh ~fk. HW'.:\h) J(' Address of Owner: ~ fSc._ _ ~A lWI:;bEY,: Deed Book and Page No.: 'U. 'f 315 ~ .p l....;:) ,~'* ~ ~ P ARK LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK. ROBERT E. ANGST* TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 "ALSO MEMBER NI BAR +ALSO MEMBER PL BAR Post Master United States Post Office MECHANICEBURG, PA 17055-3401 April 19, 2000 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for tbe following: Our file #: 8703 NAME: ADDRESS: GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, P A 17055-3401 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney 2. . Statute or regulation that empowers me to serve process (not required when requester is an attorney): 3. The names of all known parties to the litigation: PROVIDlAN NATIONAL BANK VS. GERALDINE C GORMAN 4. The Court in which the case has been or will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: CCP 6. The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTNE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address infollnation is needed :lnG will be used solely fer service f legal process in connection with actual or prospective litigation. '6 ... J2.. - 25 East State Street Valerie senbluth Park, Esquire Doylestown, P A 18901 ----------------------------------------------------------------------------------------------------..---------------..---------....------...-----...--...--------------...-------------.. FOR POST OFFICE USE ONLY _No change of address order on file. NEW ADDRESS OR BOXHOLDER'S REGISTERED ADDRESS _Not known at address given _Moved, left no forwarding address. _No such address POSTMARK: WHAT COUNTY IS THIS ADDRESS IN? C63 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY vtl OOOZ 9 <: MdV ....TA t/>nr,\, L.~ . ~-~t1' $ \ I. . " 'Ii , ,1';; . ",. . '~1" .; .~...,...,...#. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. GERALDINE C. GORMAN Defendant NO. 00-1957 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF g o c --- .o'C...,,, '""'t.: t:r.'. fl' \- '~:S-. /' ..- CC j.:;(:~ LC-::(' ~:;::'. ,," '..~ ~ :::2. ..- -,- ~.,.- ...:..... - (~. .j. "'\--. '...;...:} :..) \0 .. "' 06-/9S7 (3~~'( PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication July 4, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. /~ /(/o/r'/ ~2000 Sworn to and subscribed before me this 5 day of July ,2000 ~~~ryPUbIiC My commission expires: Notarial Seal Wendy L. Metzger, Notary Public Carlisle Bora, Cumberland County My Commission Expires June 2, 2001 Member, Pennsylvania Association of Notaries . . RETAIN THIS PORTION FOR YOUR RECORDS REMITTA~CE ADDRESS I BILL TO THE ENTINEL - LEGAL & ASSOC. MELVYN S. MANTZ P.O. BOX 130, CARLISLE, PA 17013 AD NUMBER I CLASS SALESPERSON BILLING DATE LINES 180661 10 PUBLIC NOTICES c30 07/05/00 68 * 2 AD DESCRIPTION START DATE STOP DATE IN THE COURT OF COMMON PLEAS OF CUM 07/04/00 07/04/00 PUBLICATION INSERTIONS RATE NET AMOUNT GROSS AMOUNT 3 THE SENTINEL - LEGAL 1 LGL 71. 40 TOTAL AD CHARGE 71. 40 3 PROOF OF PUBLICATION PROOF 6.25 DAYS RUN 7/'t/ro PURCHASE ORDER PAY THIS AMOUNT 77.65 93.18* Cs# 00-1957 * AFTER 08/04/00 MESSAGE: Thank you for advertising with The Sentinel. Deadlines for in-column legal advertisements: Monday is Friday at 11 a.m. ; Tuesday is Friday at 4 p.m.; Wednesday is Monday at 12 Noon; Thursday is Tuesday at 12 Noon; Friday is Wednesday at 12 Noon; Sunday is Thursday at 12 Noon. If you have any questions regarding your Legal bill please call Sherry Clifford, Classified Manager, at 243-2611, extension 204. Fax your legals to 243-3754, attention Sherry Clifford DETACH AND RETURN THIS PORTION WITH YOUR PAYMENT J.~.~~XE1~JI~~~SLEL~f~~13 Cs# 00-1957 AD NUMBER CLASSo START DATE STOP DATE 180661 PUBLIC NOTICES 07/04/00 07/04/00 AD DESCRIPTION BILLING DATE TELEPHONE NUMBER IN THE COURT OF COMMON PLEAS OF CUM 07/05/00 215-348-5200 GROSS AMOUNT OF 93.18 DUE AFTER 08/04/00 TOTAL AMOUNT DUE 77.65 & ASSOC. MELVYN S. MANTZ 25 E. STATE STREET P.O. BOX 2284 DOYLESTOWN, PA 18901 111111111111.1111111111111111111 ENTER AMOUNT ENCLOSED 20200000001806610000000000000000931800000077655 2, -;.?u (~ c? ~'? -\~' t_;~ ,-\: ~} \ ~~(~ . tOei ~<. .-.::-,_.' L_ ,--.., ?~ ~(~1. ~?"c~ -....:~\ .~ - , -- JUt. :[ 0 2000 ~ \~~. ""\~J ~~ ;,;~~71 ':",\ ::"A~ , ., ";. ~~l .:..-' ()I VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. GERALDINE C GORMAN Defendant NO. 00-1957 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did attempt to serve the Defendant, GERALDINE C GORMAN, on 07-21-00, at his/her last known address located at 204 ALLENDALE RD. MECHANICSBURG, PA 17055-3401 by United states certified mail, Article No. 7099-320-0008-4396- 4848, Return Receipt Requested, Postage Paid, with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter with the appropriate notice to plead as set forth in Pennsylvania Rules of Civil Procedure. The United States Post Office attempted to serve the Defendant several times; however, the Certified Mail was returned to your deponent marked unclaimed, the original which is attached hereto, made a part hereof and marked Exhibit "A". That in accordance with the Order of Court, Valerie Rosenbluth Park, Esquire did serve the Defendant with a true and correct copy of the Complaint by United States Mail, Postage Paid, First Class on JULY 5, 2000 the original which is attached hereto, made a part hereof and marked Exhibit "B". :~- VALERIE ROSENBLUTH PARK, ESQUIRE Attorney for Plaintiff Pursuant to the Fair Debt Collections 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 said purpose. ...a rr /'T'J ::r- Postage $ &:Q I:J I:J I:J Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees ~"'" /" ,.\..... :'.~ \> ( ~ P~tma~ :.: t ~ ~.....tlere i' -'::::,... . .' \ . ..;.~ / '\ /'" ."....._.....-,...., ...Ii!' ..... rr rr c J"- . Comp/ete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. ArtiC~(!>>~ xiii ~ ~ 7Jf~A / 7ZJs-5= 'Y f/(/ / C. Signature x o Agent o Addressee D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: )l(t:!.o 3. i:;:ice Type ~ Certified Mail 0 Express Mail o Registered 0 Retlirn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. 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VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 4217390552605848 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GERALDINE C GORMAN Defendant I NO. 0 0 - 1957 9 6 3 3 J228 0098 ~396 ~8i8 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: $5,399.14 $1,079.83 $638.12 ($0.00) ($0.00) $7,117.09 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. 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 rocedure No. 237.1 is attached hereto and marked Exhibit" AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL VALERIE SENBLUTH PARK,ESQUIRE Attorn for the Plaintiff AND NOW, P~,.,.J.1' , ;:)CiCJn , Judgment is entered in favor of the praintiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. 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. VALERIE ROSENBLUTH PARK ATIORNEY LD. # 72094 rARKLAW ASSOCIATES,P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 A TIORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK. Plaintiff VS GERALDINE C GORMAN Defendant NO. 00-1957 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: GERALDINE C GORMAN 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 DATE OF NOTICE: 8/14/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT 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 HA VB 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: VALERIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 00-1957 7099-3220-0008-4396-4848 GERALDINE C GORMAN 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 GERALDINE C GO~, Defendant is over 21 years of age; that his/her place of residence/business is located at 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 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 19 0 and its amendmen PARK LA ASSOCIATES, P. . senbluth Park for Plaintiff E10 VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 204 ALLENDALE RD MECHANICEBURG, PA 17055-3401 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 00-1957 7099-3220-0008-4396-4848 GERALDINE C GORMAN 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. 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