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HomeMy WebLinkAbout00-02283 VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST SELECT CORPORATION Plaintiff VS. CASSANDRA R ECKRICH Defendant NO. 00 -~~ Ct.)i.( y~ 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, ~th CO'J;RT Jl QHnJI O'fR.~.'fOR'" ~. _Cb. &12- .fksaC-l::J'.J.,~v I'lvv.L 1 G~eI.:l'-\,.L.Ld l.......uuncy courcnouse cctLlls.Le, ,,"- 1 16lJ J1... /..,I:.EIdy 4oc. ()l7) ,,'!U-b.oUU C:aI21dlL. Pf} /10/.3 , 'l/7~ ~'I9-:;IG./.. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. , ". -.~--" ! , "'. I I I ,l. 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#:4168100005801277 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS CASSANDRA R ECKRICH 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 DEFENDANT NO. 6-0 - .2;( f.J Ct.;;J T ~ CIVIL ACTION 1. The Plaintiff, FIRST SELECT CORPORATION, is a California corporation organized and existing under the laws of the State of California with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2, The Defendant, CASSANDRA R ECKRICH, is an individual who resides at 5304 OXFORD DR APT 90, MECHANICSBURG, PA 17055-4430. 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or authorized by the Defendant on a credit card or line of credit, bearing account number 4168100005801277. - ri .~~ ~ 4. The terms of said account are stated in the documentation attached hereto as Exhibit "A". 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 $3,957.38 as of 12/21/1999, plus pre-judgment contractual interest at the rate of 9.90% 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 $791.48. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT CORPORATION, and against the Defendant in the amount of $3,957,38, plus pre-judgment interest at the contractual rate of 9.90% per annum from 12/21/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $791,48, 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. '-, . ~ ~ M V' -._ ,_. ~l 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands that Judgment be rendered in favor of the Plaintiff, FIRST SELECT CORPORATION, and against the Defendant in the amount of $3,957,38, plus pre-judgment interest at the contractual rate of 9,90% per annum from 12/21/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $791.48, less payments made, plus costs and any other such relief as this Court deems reasonable and just. i PARK LAW ASSOCIATES, P.C. BY: VALERIE 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. ~ ~~,'",-,,- . I, VERIFICATION RACHEL PADAM4 I , declare that as of February 1, 2000: I am a designated agent of FIRST SELECT CORPORATION, the Plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in the State of California. ~Ot0h.J r0r1(l1lY10 Designated Agent .:.=-==-=~~C=-.- EXHIBIT A , ..;'~ j FiRST SELECT COR P 0 RAT o N \:: I ACCOUNT ,\CREE;V1ENT 'x-')ur FL.EET H...\."" \i..;count ha.<; b~tln lransfi::rr'i:d to First $.:lect C"rpllration. Your FLE.ET BA":': u...:count was d()~d at th~ tim~ l.Jl"this tr:ln::;ier. .lntl '.\\11 th~(d~)f<~ continue to be d05<:::d. This Account Agn::err!'ent contains the terms that govern ~our Fir.:;t 's..:k:ct ac;;t)lmt (the ".-\,,:-count"). In lh;s ..\g:n:ern<:::nt. "you" ;tntl "your'. mean each p~r~on who is liable for payment?11 the .-\l.:cour.t. "\l..'~;' "our." "OUTS." and "U~" mCOln fir.:;t Sd~t Corporation or its assign..:es._ B.::cuus.: :mur Ac,;ount ha.o,; been tr:mst~rred to us. you aro.:: now <"bhgatd to n:::o:J.: the. \.::count to 1,.1.<; imtc::::.d of fLeET B."'_"S:. [fthe A,,:collnt was opened OlS ,1. Jomt <1c...;;ounl< w..:: may act on the instructi(ms of an:, joint tl.ecOuntholder. Pa~;mt'nts / Finance Chaq~.es. .-\5 l\lng as you hav..: .J. balance outstanding on ~our Awount. tinanc..:: dwrges are <::a\..::ul::.ted:.1:) t0I10V'i~: To ti~re th<:: finance .:-harges tor each billing cyc1~. ,:ve multiply the J.verag""' daily balance on ;oour '-\o.;:CiJunt by..l daily periodic r.Lte. Th~ daily periodic r::.le We apply IS your '<\.;::count's :\nrHlJ.l Perc~ntage Rate dlVlded by 365, 1h~ ......nnual Percentage Rate WIll be.: calculated. as dlsclos<:d in your most r~cenl F'LEET 8A\:[.( :l.ccount t<:rms (the "Original Terms"), rrYOl.lf Original Terms provided for diff.::reOl Annunl Pcreentage Ra[<::s to be :lpplieci to c!itferent compOnenL<' QfY0ur outstanding balance. we wiU apply the low<::st such .--\.nnual Percenta.g~ Rate to your .::ntire out5~u.nding ba[anc?;:., W~ may accept late or partial payments. or payments mark..::d "paid in full" or marked with otber Nslrictions. without losing ourright to co![ect all .J.mounts o...ving under Ihis Agreemt:nL Fees. W~ will charge your Account a f..::e for each billing cycle within ",hich your A<::count is delinquent(late..::harge). The amount of the late charg<=: will be US disclo$ed in your Original T~rms or the ma.-omum late charge permined by the law of your !,1o.ti: of residence. whiche\.er is low.:::r. W.;; Will charge your Account a. fee for i:ach returned payment chi:Ck (returned ch~ck charge). The amount ofehe returned check charge will be as disclosed in your Original Terms, or the m:l.:<imum returned check charge permin~d by the law of your state of residence, whicheyet' is lower. To the extent provided in your Original Terms.. and to the extent pi:rmined by applicable law, in addition to your obligation to pay the outsUIldlng balance on your Account, plus interest and fees as disclosed herein. we may also charge you fOr any collection costs We incur. including but not limiti:d to rCU$onable attorneys' fees and court costs. U'your Original Tenns provid.o:::d for an award of attorneys' fees ami court costs, such pr.......ision as incorporated herein shall apply reciprocally to thi: prevailing party in any lawsuit :J.rising out of this AgreemenL ~oll-\Vaiver of Certain Rights. We may delay or wo.ive enforcement of any provision ofmis Agreement without losing OUf' right. to enforce it or any other provision 1::J.ti:.. Applkable taw; S..$erability; Assignment. No matter where you live. this Agreemer:t and your Account are governed by federal law aoci by the law of the ::;tate designat~d;tS the: applicable b:Jw in your Original Terms. [fyour Ori%:inal terms did not cont;.in an applicable law provision. then this Agreement and your Account. are govemi:d by fedcrallaw and the law of your state of residence. This Agreement is a final expression of the agreement bi:twecn you and us and mily not be .;:ontrauicteu by evidence of any alleged oral agreement. If any provision of this AgreelTlent is held to bi: invalid or unenforceable, yml and we will c()ru.id~ that proVision moditied to conform to applicable law, and the rest of the provisions in the Agreement will still be "..nforceable. We may transt~r or assi?1 aur righI to ;dl or some ofyoter payments. [fstate law requires chat you receiv~ no~ice of such an ~'Ient ~o protect the purchas~or ;JSSIgnee, we- may gi\'e you such notice b;-, tiilng u iinam:ing statement with the state's S_i:creury of State. Credit Reporting. If you fail to fultill the terms of your credit obligation, a neg:1tive credit report reflecting on your credit record ma~ be submitted to a credit reporting agenc~'. In order to dispute any information Wi: are reporting about your ACcount. you must write to us at thi: following address: First Select Corpvration. P.O. Box 9104, Pleasanton, California, 94566. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR HiTr;RE r;SE This notice contains import::::.m infOTrrUltion about your rights and our responsibilities under the Fair Credit BiUing Act. Notify l's in Case of Errors or Questiol1s About Yl)Ur Bill [fyou think. your bill is "'\Tong, or if you n-::ed more information :;lbout :In entry on your bill, ......rite us, on a separate sh<eet. at the foHowing addr...-ss: First Se[e..::t Corporation, P.O. Box 9104l>Ple.:\Sumon, CA. 94.566. Write to us as soon as possible. We must hear from you no lo.terthan 60 days afterw~ ~<:..t you che firsl bill on v.-hich the error or probli:m appeared. Yau can telephone us, but doing so wilt not pr<:serve your rights. In your letter, give us the following: Your name and A.:count number. The dollar amount of the suspected error. Describe the ~rror and e:(plu.in, if you can, why you bdiev<=: there IS an error. lfyou ni:ed mON inform:l.!ion. describe che item you are not sure about. Your Rights::md Our Responsibilities After We Receive Yom' \Vritten Notice We must acknowledge your letter within 30 days, unless we have corrected the emSr by then. \Vithin 90 da~~. We' musz dther correct the en-cr or e:-:plain wh.:-' we believe the bil1 was correct. Mer we receive your lett<:r, we cOlonol try to colli:ct or report you as delinquent as to any :unount you question, including tinance churges. We can apply any unpaid amounl against yourcredlt line. YmL do. not have to pay an~ quo::stionedamount whilo:: we are invf;Stigating, but you are still obligati:d to pay the par-..s of the bill that are not in question. Ifwe find that we mad.: a mistake on your bill. you will not have to pay any finance charge r<:lated to any qtl~tion.:d amount lfwe did not make a mistake, YOLL may have to ,pay finance charges, and you will have to mak.: up the missed payments on the questionot:d amounL In 'i:i[h~r case, we will s.:nd YOU::l statement cf the amount you owe .:l.nd the date that il isdu.;-. Uyou fail!o P:::I.'j' th.;- ;unGunl we think you owe. we mayrt.'pOr1 you.;!.S delill<llll'nt How<~vt:r, uour expl:uulion does not satisfy you and you write to us within to days to::Hing us that you still refuse to pay, W~ must tell anyone Wr:;; report you to that you llu.:stiQn yt:ur. bill. . .~d we must tell you the name of anyone we: re:pofti:d you to. Wi: mllst tdl anyone we report you to [bat tho:: m.:ltt.::r has b<:ens.ettl~ b~tween llS when Il hnally IS. lfwt: do notfoltow these rules, we: cannot coll<:cl the tirst $50 of the qu.::stioned amount i:v<:n i(your bill was ~orr.:ct. Spedal Rule fo. Credit Card Purchases It'YOLl hJ.ve a problem with the gualitv of goods .J.nd $er....iccs th:li. you !)Llrchased with your FLEET B.4J.~K credit card and you Im\'e tried in good faith to correct the problem with the merchant. yOll may nor have t\J pay thi: rr:;maining amOUlIt dLte On the goods or s.::r.'ic<:::s. There are two Iimi[;!,[ions to this right: (a) y(m lhUS,t havt: made Ill!:: purchilSe in your hom.: state or, ifnot within your home stale. ......Ithin 100 miks of your curren[ mailing ;lddress~ and (b) th.:: purchase priL'e mu~t h:lse bt:~n more than ::550. These lill1imtions do not apply ifdtb~r we oJr FLEET O...\.:.'iK own or <)per:l,[e the m.::rchanr. ()t' il'........:: or FLEET B..\."\a.~ mailed you the .u.lvc:r::lsement for the property or s..:rviceS. 1~'JQ , Hit! ~ Jjma..k.~J1Wj~Ii~MIM'ihi "-i"lJlMjlit~~-- ",--~,~'~"",".. 'fit ~ ~ f0 -...J "? -.....0 ~ " , "~,,",',"- ~ ~ " .". .. ',._t."._' ;__'. _oj" ~ ~ h Y1 C) q ~ ~ ~~ ~ -oCJ:) mr,: ~~ r;:: ~--' ~~~ L~ =< o ~~ ~~~. "" , , ,I .(:J c::> o -n '!:>> '"J :::::J ::j "'~"S ,,,'.In ~.~..~ V) ."C- '1 ft,~~ ~ :D -< ,'0 -r-) -"- C;:) """ ,0 ti 1\')....'fL . " .~. ~ CY~ ~ r ....., ,~. ~ . ~ '-, - ,," . ~-, -,' -~"j . , SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-02283 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS ECKRICH CASSANDRA R 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 ECKRICH CASSANDRA R but was unable to locate Her in his bailiwick. He therefore returns the NOTICE & CIVIL ACTION , NOT FOUND , as to the within named DEFENDANT , ECKRICH CASSANDRA R DEFT. COULD NOT BE LOCATED AT ADDRESS STATED PRIOR TO EXP. , P,O. STATES THIS IS A VALID ADDRESS Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 18.60 5.00 10.00 .00 51.60 R Thomas Kline Sheriff of Cumberland County PARK LAW ASSOCIATES 05/15/2000 Sworn and subscribed to before me this d'/~ day of ~ ~ A.D. p~ta~~/~ ......... " - ,~_ j h _ I ." r .. I HERb:); '.""c;,',,,.,,), "I';Ii\'f'n;l~ WlfHIN IS J.\ Tf'l'l( !::K; , > ',I';,::C:-l COPY OF ThE C'F{1G:I\i!\~_. Ot\J FP.J: 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 ~-_..._....~,...._.,------- VA,L[-:FW:~_ r~~: fH PARK AT 08hlLY r::!::_~.,F; P1,.A.~~\:~~ IFF/r'\.iF~rdQ^MT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST SELECT CORPORATION Plaintiff VS. CASSANDRA R ECKRICH Defendant NO. 00 - ..(~fG C,o~[/~ 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 obj ections 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 TRUE COpy FROM RECORD Carlisle, PA 17013 In Testimonywheroof,I here unto Sit my hand (71 7) 240-6200 and tile _Of said Court at .Carlisle. Pa. ~ ThL')j~YI ~~~~~~ THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "' I .. 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#:4168100005801277 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS CASSANDRA R ECKRICH 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 DEFENDANT NO. CIVIL ACTION 1. The Plaintiff, FIRST SELECT CORPORATION, is a California corporation organized and existing under the laws of the State of California with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, CASSANDRA R ECKRICH, is an individual who resides at 5304 OXFORD DR APT 90, MECHANICSBURG, PA 17055-4430. 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or authorized by the Defendant on a credit card or line of credit, bearing account number 4168100005801277. I'~'-~ ~ """"""-'" c ".~ _, I ~"." , . 4. The terms of said account are stated in the documentation attached hereto as Exhibit "Au. 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 $3,957.38 as of 12/21/1999, plus pre-judgment contractual interest at the rate of 9.90% 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 $791.48. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT CORPORATION, and against the Defendant in the amount of $3,957.38, plus pre-judgment interest at the contractual rate of 9.90% per annum from 12/21/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $791.48, 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, FIRST SELECT CORPORATION, and against the Defendant in the amount of $3,957.38, plus pre-judgment interest at the contractual rate of 9.90% per annum from 12/21/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $791.48, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE 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. It.-~,,,.~ 1:1 " " II I "j , I :1 'I ,il! , , I II Ii ., II I, I' I I I , I Ii ~ 'I I, ,. " :I ,:1 'i 1 II I I , = " , ~ VERIFICATION I, RACHELPADAMAl , declare that as of February 1, 2000: I am a designated agent of FIRST SELECT CORPORATION, the Plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be, true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in the State of California. ~Ot0hJ 'Y()r1(JfYY\(1 Designated Agent -'~'11 ~.~ ","". -...- I ~" ,.mMiJi.>J<ib>J,i:Ii>l'~IlrJ;~~H',__ ~fj FIRST SELECT CO~PO"RAT o N i EXHIBIT A ACCOUi'iT AGREEMEi\T Y\)llr .FLEET .BASK ~ccounl ha_~ b.~~n lransf.:rred to FirSl So:kct Corponlllon. Your FLEET S.;"'" '\ f( U<.:;\,;OUrl[ was -:Io~d at th~ tim~ 0r this Ir:J.n~f~r. and ',~ ill .l,h~r<:I.(:r,: ..;onunLl..: tlJ be closed~ 11\1s .-\CCOtlllt AgrO:';:fT!.;:nt contulI1s the t~rms that govern your Fir~t Sd~q J.";";Ullnt Ithe ".-\...:::ount"). In th~s .-\g:!;ernent. "you" and your rm;;lll ~~ch p~r.;o~ who IS llub!<: for pi.lymenl?n the ."\"':COUr:L "'\\.;, , "our."' "ours." and "w," mean First S~I~tt Corponllion or Its assignc:'i:::~. 8c:cause "our ..-\o.;t.:OUnl ha.o,; b~~n tr:J.lls.krred ,to u:;~';<:ou J.r~ no~~ obflg'J.t<:J to repay tho:- _ \':c:ounl to us Inste::d of fLEET 8.J.S:-'::. If the: _J..t.:Collnt ~vo.s opc:n~d o1S .J. joinr a(,cou'nt. \~<: may act on the mstructlOns at any JOint aCI.:Ountholder Pa':-n1~nts f Finance Chal'g~s. .-~ kmg as you havo:.: a balanc~ outstanding on your .-\":(.;Qunt. tinan..:~ .;harg..:s ar; cakul;J.ted ~s rolluws: To tigure tho:.: finance ~harges for each billing ..::ycl~. ~ve multipl~' th~ :1venl.g~ daily balanl;~ on ~our ,-\ccoum b~' J. u:.Lily penodic ral~. Tho: daily periodic r~te w..: apply IS your :-\.;c;ounts ;\nnual Perct:ntage Rat<: diVided by 36:1. T11t~ .-\nnual P~rcenlage Rate w1l1 bo; calculated as dIsclosed in your most r~cent FLEET B.-\..'\K aCCOunt ~..:rms (th~ "Origin~l Terms"). {["your OnginOl.I Terms provIded ior difft:rent .'\~nual Pt:rcent:tge RJ.tes :0 b<: .lppli<.:cltQ cirT<:nmt compon<:nL<; of ~.0ur outstandmg balance. Vi': will apply tho::: lowo:.::it $uch .-wnuaJ Percencage RaCe co your enflre oucs~andtng balanc<:.- W,;: maY::Lccept late or partial paymt:nts. or payments marked "paid in full" or marked with otber r~lrictiol1s. without losing ()llr right to collect aU J.mounts owin<1 under thiS Agn.::em~nt. ~ Fee~. We will charge your Account a fee tor each billing cycle within ....hich your Account is delinquent (late .:haroe). The amount of the late ch<1r<>e will be as di:;closedln your Original T c:rms or the ma'(imum late charge permim:d by the law of your state of residence. whichever is low<::r. ~ We will ch,U'ge your Account a fee for each returned payment check (returned check charge). The amount oftne returned ch~ck charge will be as disclosed in your Origin.:!.l Terms, or the: m.:!.ximum retumc:d check charge permitt.:d by th.a law of your st.:!.te of residc:nc~. whichever is lower. To the extent provided in your Original Tenns, and to the eXtenl permitted by applicable law, in addition to your obligation to pay the outstmding balance on your AccQunt, plus Interest md fees us disclosed herein, we may also charge you for any collection costs we incur. including but not limited to reasonable anom~ys' fees and court costs. ([your Original Terms provided for an award ofanomeys' fees and court costs, such prv~lsion as incorporated herein shall apply .eciproo:ally to the prevailing party in any lawsuit arising out of this Agreem..:nt. 0on-\Vaiver of Cer"t:Lin Rights. We may dday or waive ~QrCemenl of any provision oftbis Agreement without losing our right to enforce it or any other provision l:J.ter. Applicable L::Jw; Si:ierabilUy; Assignment. No matter where you live. this Agreement and your i\cCC1unt are governed by federal law and by the law ofllie state desig.nal~d ~t.S [he :J.pplicuble law in your Original Terms. If your Original terms did not contg.in an applicable law provision, then this Agreement and your Ao.:<''Qunt J.,e g/)vemed by fedc:ral law and the law of your st.ll:e of residence. This A.greemeitl is a tinal expression of the agre:l::menc belween you and us.:md ma.y nol he .;ontr:1dil.:teu by evidence ot" any alleged ora! agreemenL If any provision of this Agreement is held to be invalid or unenforce=:tble, YOll and we will con.:.id,er that provision OlQditi.::d lo conform to applicable law, and the rest of the provisions in the Agreemo:.:nt will still be enforceable, We may transt~ror assign our righ[ to all or some ofyollr payments. If state law requires that you receive notice of such an event to protect the purch~er or assignee, we may give ~'ou such notice b~' tiling a linuncing stalem.ent with the state's Secretary of State. Credir Reporting. If you fail to fulfill the terms of your credit obligation, a negative credit report reflecting on your credit record may be submined to a credit repOrting agenc~:. [n Nder to dispute any information we are reporting about your Account, you must write to us ilt the following addrl;SS: First Selcct Corporation. P.O. Box 9104, Pleasanton, California, 94566. YOuR BILLlIlG RIGHTS - KEEP THIS :'iOTICE FOR FUCRE CSE This notice contains import:.nt information about your rights and Qur responsibilities under the Fair Credit Billing .-\.ct. ~I)tit'y t:s in Case or Errors or Questions About Your Bill ffYOll think your bill is wrong, or if you n-eed more informatiOn about an o:-ntry on your bill, INrite us, on:J. separate sheet, at the fOliowing addrt.'Ss: First Selel.:t Corporation, P.O. Box 91041>Pleasanton, eA ~4566. Write to us as s?on as pc;>ssible. We must hea:- from YOll nQ lat~r than 60 days after we ::er;.t you the first bill on which tbe error or problem appe:lfed. You can telephone us, but dOing so will not preserve your nghts. In your letter, give US the roUowing: Your name and Account number. The dollar amount of the suspecced eCTor. Describe the error and e:<plain, 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 Responsibilitie.s.-\fter We Receive "four Written Notice We must acknowledge your letter within 30 days, unless we have corre..."'ted the error by then. '.Vithin 90. days. WI;: must either correct th~ err~r or e~lain why we believe the bill \....as correct. After we rel.:eive your I..:tter, we c~nnot try (0 collect or report you as delinquent as to uny :unount you. qW:St.lOI1.. IOcludmg financl;:. charg~. We ":.tn apply any ~mpajd amount against your credit line. You do not have to pay any questioned amount while wo:: are Invoi;stlgaltng, but you ::Lre still obtigate-d to pay the parts ofth..: bin that afe not in question. If we tind that we made a mistake on your bill. you will not have to puy any finance charge related to any qlL~tionc:d J.mounL 1f~'iC: ~id not m:l.ke a mistakt;, you may hnve to.pay finance charges, and you will have to make up the missed payments on the questioned amounL In eithc:r.case, we Will s..::nd ~.~u a Slatemf:n~ of the amount you owe and the date that it is due. If you fail to pay the ;unount we think you ow<::. we may repor1 you as delmqll~nt How<wer, 11 (J~r exp!ana.tlon does not satisfy you and you write to us within 10 days to::lling us that you stilt refuse to pay, we must tell anyont: we report you to thut you qu..::swm y~ur.b~U. .' .~d we must tell you the name of anyone we report.ad you to. We must tell anyone we report you to that the m:t.tt<:r has been r-ert\.::d hdween us when Il hnall: IS. If we do not tollow these rules, Vle- cannol calkc! the tits! S50 orlh.: qUClstjoned amount e....en if your bill was correct. Special Rule l'or Credit Card Purch.:lse-s If you have a problem with the quality of good:> und ser....ices [hat ~o~ purchased with yotlr FLEET BA."'i.K cr~it card ;tnd :'o~ l~a'i~ {ri~d in ~~ fa.ith. !O,,~~m~c~. the problem with the merchant, you may not have tQ puy the remaUllng amount due on the goods or s~r,itC~S. Th..::re are two Inntt:ltlOns lJ thl:; n~ht. (~) _ (u musl hav..: made tho:.: purchase in your horn.: stat~ or, if not within your home Slnlt:. within lOO miles of your ..:urr..:nt mailing ad~~ess~ an~ (b) _the pur,:h.ase ~nl.:e :nust havc been more than S50. Th..:s..: limitations uo nol apply it"::ither we or FLEET B.-\..:......K o.....n or oper:1le the m.:rchant. or 11 we or r-LEET B..\..~K mailed lOU the advertisement tur the property or services, Z5~O " (!H) u;:ra ~ m -~, , ~,,' ,.- ~~~."," Of-OF' "'" " i~. " ", :-'.'r.: I'"! i '.;, _,,'\',-r . r. . .~,' -~HEHjFF ':J!~ iY "Ill!MilW~~"1WM~<l!i~I!iI)I!W!~J;"f'<;;I~:!\!l\ff.l"'T.i!~",-jj\C~'~"" ~ IiW 63 ~ c;;;a lIlf7""," ~r"''''''T[ - ,,--' T .--, I,"; , "'" FIRST SELECT CORPORATION, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW CASSANDRA R. ECKRICH, Defendant NO. 00-2283 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of August, 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 by both certified mail, return receipt requested, and by first class mail, postage paid, and by publication once in the Cumberland Law Journal and once in a newspaper of general circulation in Cumberland County. A verification of service shall be filed by Plaintiffs attorney showing service of the complaint as set forth herein. BY THE COURT, ~ , '. IT i , ..,-"-- u~ .. ~-~~ I ...' ~, :_"_c ~~. C ~s , c:-: ~ ,- ' :"-~) _.J, -.,) -< co -< Valerie Rosenbluth Park, Esq. PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 Attorney for Plaintiff :rc " 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 FIRST SELECT CORPORATION Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CASSANDRA R ECKRICH Defendant NO. 2283-CV-00 ORDER AND NOW, this day of ,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 by both certified mail, return receipt requested, and by first class mail, postage paid. A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. BY THE COURT: J. .................... ~............... ~ . , . ,,--- .....-.- -- .--- . ~'"" "'''''''''1 " -,r ~"'"; ,~"'" ,'_" _ - , _', ""...",~~-" " 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 FIRST SELECT CORPORATION Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CASSANDRA R ECKRICH Defendant NO. 2283-CV-00 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 APRIL 12, 2000. 2. The Sheriff of CUMBERLAND County made a "Not Found" return of service of the Complaint on MAY 15, 2000. A true and correct of the sheriff's return of service is attached hereto, made a part hereof and marked Exhibit "P-1". 3. The last known address of the Defendant is 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055. 4. Sheriff's described indicated Subsequent to the Plaintiff's attorneys' receipt of the "Not Found" return, Plaintiff's attorney made the efforts to locate the whereabouts of the Defendant as in the attached Affidavit of Investigation. 5. Despite Plaintiff's attorneys' inquiries, the Plaintiff has been unable to locate the Defendant. ~. ". ",:,",'. "fij J :1 ,I .! '--=1' ",,~ ....- .. "I j . -I .. ....- '--~ -- :1 " " .1 , :1 "! J -. "01' ,..-- ........... -- ,",,;' ,. -'#1,__._ ~, ",.,;,:.J-_ ", ,~";,,,.,( c_"~,~,. ~'_ . ," " 6. The Plaintiff believes the Defendant is obstructing or concealing the Defendant's whereabouts. either 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. .C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF , ~~"'. :'W ., ~ .......-.......... .~~~ ......- ,~ .: .: . .._- ............ -- , .:! ., , .i , ~, -I ~I .:1 ~ ,.-- .~.~ -- ....' --"I """",'I' ,.", ,','" '1,;"'" _'.0<0, '" ,",', " 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 ROSENBLUTH PARK, ESQUIRE ..,j , ~ .. " ...-- ...,.......... .......- .-..... .. ... ""'- .'..~,~' -'<-' ~, ." . - ~' .,- '-~ _..~ SHERIFF'S RETURN ~ NOT FOUND " CASE NO: 2000 - 022 8:;!" COMMONWEALTH OF PENNiSt.LVANIA COUNTY OF CUMBERLAND VS EXHIBIT . ~' 1-/ ,. . FIRST SELECT CORPORATION ECKRICH CASSANDRA R 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 ECKRICH CASSANDRA R but was unable to locate Her in his bailiwick. He therefore returns the NOTICE & CIVIL ACTION , NOT FOUND , as to the within named DEFENDANT , ECKRICH CASS~~RA R DEFT. COULD NOT BE LOCATED AT ADDRESS STATED . PRIOR TO EXP. , P.O. ,STATES THIS IS A VALID ADDRES5 "":11'1.'. 18.00 18.60 5.00 10.00 .00 51. 60 County Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge PARK LAW ASSOCIATES 05/15/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ,',,- ,'~, "',~, '{~: I: _: "^",, .'" '"' "r:< ",,=,,'" ,'" - _" _ ' _, ,~<. ",'," " " 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 FIRST SELECT CORPORATION Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CASSANRA R ECKRICH Defendant NO. 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 CASSANDRA R ECKRICH does have a address of 5304 OXFORD DR APT 90 telephone directory shows that telephone number listing at the MECHANICSBURG, PA 17055 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 the Office of Voter's Registration shows CASSANDRA R ECKRICH is not a registered voter with an address of 5304 OXFORD DR. APT 90 MECHANICSBURG, PA 17055. The Office's response is attached hereto, made a part hereof and marked as Exhibit "A". d) A letter addressed to the Office of the Board of Assesment shows CASSANDRA R ECKRICH is not the owner of the property at 5304 OXFORD DR. APT 90 MECHANICSBURG, PA 17055. The Office's response is attached hereto, made a part hereof and marked as Exhibit "B". " 1 '. " .. .,~ ,...-..- , ....- , . , , ., ~I .1 . ~I "- ~..-..- -- '. " . . ~:~~ ...".............. ,,-- -," .. ;:- .,",,","" <~ -, " l' ~~....,:'.- fu'--' , );,,-,~ --, " " e) A letter addressed to the Postmaster shows that mail addressed to CASSANDRA R ECKRICH at 5304 OXFORD DR. APT 90 MECHANICSBURG, PA 17055 is delivered. The Postmaster'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: VALE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF I I I :1 ..-... , ~ "- ,...~ '......- ~ ~ ~ ..---..0 ..~ . .............. I I " I I ., .----.... _,__~--..l -'"- ,---~""~ P ARK LAW ASSOCIATES A PROFESSIONAL CORPORATION_,,,,, ' r' , 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 .AL~O MEMBER NJ BAR _ALSO MEMBER FL BAR May 26, 2000 " , ~ ' ,~ .: Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 . ..'...,EXHII3IT ~ ..;4 RE: CASSANDRA R ECKRICH 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 OUR FILE NO: 8101~l 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. //tv~// BY: MELISSA FLAK Legal Assistant Enclosure Name of Person: CASSANDRA R ECKRICH Current Address: Date~ of Registration: Date of Birth: Previous Registration Address: ~ ~oh:NQ..~~~\s"0bo..azo.i.~<a:Lrtr&~~, " ~~~ ~,~ , , ~ .~~, , - ~~~ ..\ \:\ "L ~\\\" ,~ > W" ~, " " .. ... a <= '.... :x ..... .... lID .... r;q % ::0 >- r -< )> w :z 0 0 (") 11J <:) <= - ~ N ,-<' J) ~~WlII!I~~~~"-.."-,~~"":,,,!",,,~'"'9' ~, , ~ ., PA:RI<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 FACSL\1ILE (215) 348-4015 * ALSO MEMBER NJ BAR +ALSOMEMBERFLBAR May 26, 2000 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013..3387 EXHI61T l ,/J, '~ 0 RE: CASSANDRA R ECKRICH Dear Sir!l\!Iadam: ~, I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 5304 OXFORD DR APT 90 MECHANICSBURG, P A 17055..4430 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 1ruly yours, PARK LAW ASSOCIATES,P.C. By:7fU~~L MEUSSA FL"-.K Enclosure ~ , , . 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. ANGSP' TELEPHONE (215)348-5200 FACSIMILE (215) 348.4015 OAl-'>O MEMBERNJ BAR +ALSO MEMBER FLBAR Poslmaster United States Post Office MECHANICSBURG, PA 17055.4430 May 26, 2000 ExHlalT C- REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please fll.rI1ish the new address or the name and strej')t address (if a boxholder)for, the following: Our' file #: 8101 NAME: ADDRESS: 11 " ]I I CASSANDRA R ECKRICH 5304 OXFORD DR APT 90 MECHANICSBURG, P A 17055-4430 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 boxho1der information, The fee for providing cbange of address information is waived in accordance with 39 CFR 265..6(d)(l) and (2) and corresponding Administrative Support Manua1352,44a 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: FIRST SELECT CORPORATION VS, CASSANDRA R ECKRICH 4. The Court in which the case bas 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 OBTAlN 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 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 information is needed and will be used solely for service of legal process in connection \Vith actual or prospective litigation. o - e M 25 East State Street Val ne senbluthPark, Esquire Doylestown, PA 18901 FOR POST OFFICE USE ONLY No cbange of address order on file, NEW ADDRESS OR BOXHOLDER'S REGISTERED ADDRESS _Moved, left no forwarding address, _No such address POS1MARK: WHAT COUNTY IS TInS ADDRESS IN? ",G~ ,\/--::! ~ 7Y~~ \i ., '\ i" 'f~ '1~ 1-:. ,::: ~ - _/".'? .....:~~ \);/ ""-'- _Not known at address given C63 THIS IS AN ATTEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .. 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 FIRST SELECT CORPORATION Plaintiff VS. CASSANDRA R ECKRICH -V, "'-' ,', _ ,,,,). _ ^",,~. ,. 0, .c' ",,, .,','~ . , - ~. "~<'I CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2283-CV-00 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. PARK LAW ASSOCIATES, P.C. E ROSENBLUTH PARK, ESQUIRE EY FOR PLAINTIFF ;aJ , ~_ ,_,' 'L_1J~,~lilaI~~IJii~-~ ":'..l' L1' ;"~,,C o ,,_~ '11I)"""" d.. ,"i"'&"'<,',,,",,.... ,,",.'CL """1 I I (') 0 0 C 0 ,," s:. "'" ,-, ""'0 CO c= :T- ::n rnrl' '" ,,1\ Z:D -rrTI '9 zc -~ ~2" a> 60 ~o -v '~~~~ '?Eo -ri~ -" -0 '--!? om ;J>c -t Z N ~ =<! ,.:> '-< .....~'- ......... - -,' ~~ PARK LAW ASSOCIATES, P.C. VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY I.D. #72094 25 E. state Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CASSANDRA R. ECKRICH Defendant NO. 2283 CV 00 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 serve the Defendant, CASSANDRA R. ECKRICH, at her last known address located at 5304 Oxford Drive, Apt. 90, Mechanicsburg, PA 17055 on 08/26/00 by United states certified mail, Article No. 7099 3400 0008 6906 1433, 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. Service was accomplished in accordance wi th Pennsylvania Rule of Civil Procedure. The Defendant received said notice on 09/11/00, as noted by the certified return receipt card attached hereto, made a part hereof, marked Exhibit "A". That in accordance with the Order of Court, Valerie Rosenbluth Park, Esquire did serve the Defendant, CASSANDRA R. ECKRICH with a true and correct copy of the Complaint by United States Mail, Postage Paid, First Class on 08/26/00. The Receipt for First Class Mail is attached hereto, made a part hereof, . ~ ~- ~> . -'~~:; .... marked Exhibit "B". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 PA C.S.4904 relating to unsworn falsification to authorities. PARK LAW ~SS~ATES' P ~ BY: ~~ VALE IE 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. / _'c. . Complete 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 mailplece, or on the front if space permits. 1> Article Addressed to; CO:fLiroro.. '<Z .. EcKr Ich Q:O+ Oxfcrd or. AptC\O n~Xun Icso~3l PJ.. \ SEP 1 4 2000 . Service Type o Certified Mail o Registered o Insured Mail DYes 2, ~~y'(~);CC!10D uPiCiJJ '1'+'0:)' PS Form 3811, Juiv 1999 Domestic Return Receipt r: .r r (-:::;~ m ,.." ::I" "" -II t::l cr ....IJ "" CJ CJ CJ PostagE! 1$ Certified Fee Return Receipt Fee (EndorsernentRequired) RestrlcMd Deliva!)' Fee (Endorsement Required) CJ C'J Total Postage & Fe<:lS $ ::I" ,.." cr cr CJ ...... 10259S-99-M-1789 /I , . EXHIBIT j II Name and ~ Address of Sender Urye Article Number ~icaletypeofmaJl RegIstered D AelUm Receipt Insured for Merchandise COD B Inl'l RCCOfded Del. Certllled Exnres5 Mall Name of Addressee, Slreel, and Post Office Address Postage 1 7tY1f.P~%g;o'6 I1lYrT.T Ga/!ad~r ~~I~~;'~~"^,' 2 ]O~1n:}d,dD OO~f -/ '-U J J U 1/10 CAme;f{er ,Sr. /)M pi . '1yj", (,ot.., oni n(>C.1CDPhiln, fa. ')1111-7 3 70J~0~:D~)Stbo {)!iver T"': J ',H' '*J~la ~<ta~1~IVD 4 1;'Ij JJlr..\!xe~L'V J Yl t ,gL/1f. r);.,s'0J~(lQ)0;ST', ' 43010 ("",;:;"1' ' . , 71011/!1'5 "h'; (], ih'1/3 '-t- , 5 tmq r.?,'I ()~,' qpOOI , ti'iq<j. Oxford D(,:'ltJf c.:.- l?'1I.J!p 1,+,"')3 Ilif'01/ii1!r5hJYll rA 170.;" 6 7D~ ~iii:O(}f{~~ Ia trK ncK 't~f,:l' W;~.i~ l 7 7Cq!A~~O~(,,63o/ U))n6rO 0nwld g~;fe;f:lm /l , :, 8 7o?M~~Di,e~rS;rti/Rl)d.r;rd 'Wh~lo6.&g~~~j: !~ 9 Z Ie/I fb3 b&O l;eo;, (lIJj) ~f!I!.;S Lj~ffi:fY:;~1~' !b 10 7..1111 ['6) &!tl rr;l'\et-K5ChD~eld 1f5~~lj~tl!:5~r~ [ 11 '7oq1 31.fiJO oM? . i' j 'J {I 1/.11 /l 57'1D N/Y'*.;;;t. .8 ___ i~,Cft)a FjIXi.-'1: fVllrt11ii'J (), 1\!Utltr.Y! "'ph ',ku-'a I'll ~ 12 U.I:! ~D3 2..310 Jil.Vld ,J nne.S 1)ZI;,t ~rvf4?g..5t . I /,~_"....,,- 0/' '.5.<1&/, (f(~G\,J I~~':" "'\' \.i.iJ, 'u ,,:,:,1 \ (y "...:, y -......<,..\ '/ Postmaster I Per (Name of Receiv7h;l@~r~B)~ " !rI/CJUw~ tabb!<r ~~ lD ::j' 13 14 15 Tolal Number 01 Pieces listed by Sender Total Number of Pieces Received at Post OUlce jJ- PS Form 3877, February 1994 Check appropriate block for Registered Mail: D With Poslal Insurance D Withoul Poslallnsurance Handling ~cl. Valu~ Insured Charae' III Aeals,) Value Fee - ~rfi' IIL~ 3 l!~\~l'l,.>~)~:tf~~"';'~ I.> ~.,~;::: , f,;>~ ~hl.lco $till ~:;5j~~ I!/ (\~ ' "~"iiL '-'-' I~;::\:j,ii-'\ ' IV Co j..... <:;> C/J u-, <-: u1, ~ D_ .> ~ UJ q:O~ --- - - - AWl( slamp here II Issued as certificate of mailing or lor ac.ldil1onal copIes 01lh15 bill. Postmark and Date of Receipt Doe Sender A. R. S. D. S. H. II COD Fee Fee Fee .. Res!. oak Fee. Re[1la1k.L- The lull dedarallon 01 value Is requIred on all domesUc and Inlernallcmal reglslered mall. The maxImum Imlonmlry payable lor lhe reconslrucllon 01 nonnegollable docomenls under Express Mall document recollshuclioO In:surilnca /s $50,000 per pIece subJecllD a IImll of $500,000 per occurrence. The maximum Indemnity payable Dn Express Ma~ merchandise Insurance Is $500. The maxImum Indomnlly payabla Is $25,000 lor reglstlilred mull, senl wll!h opUonal pos\allnsuraIl'CB, Seo Domaslfc Ma" ManuIJ/R900, $913, and S921 lor IIm1la1l0ns 01 coverage onlnsUled and COD mall, See Infernal/anal Mail Manuflllor DmllaUons 01 coverage on InlemaUooalllUll1. Special handling charges apply only to Ihlfd and 100111\ class parcels, ...,'.,...,:! Form Mual ba Compleled by Typewriter, Ink or Bait Polnl Pen ,I." " {.!:tU'k:',!~!.'\':';' . , ,(.llfjlr~l!r. ~}', . , ~i' I 'i1'GU" ;. : '. .:'.J :;~!f " '-~f~lit -"'1 ~"~j ':/;,;~1\1~j:'jj/; . 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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: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 4168100005801277 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CASSANDRA R ECKRICH Defendant NO.00-2283CV 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 $3,957.38 $791. 48 $317.72 ($0.00) ($0.00) TOTAL $5,066.58 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 tne 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 P cedure No. 237,1 is attached hereto and arked Exhibit" VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff ,~~~^""_.~=~~~ 'n' '" , ~ .. AND NOW, Od .:to ,:J.('Y57) , Judgment is entered in favor of the Plaintiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. /~ (]..,h. J ~.~ _ , OTHONOTARY 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. -'- " _,jib' , VALERIE ROSENBLlJTH PARK ATIORNEY!.D. # 72094 PARK LAW ASSOCIATES,P.C. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATIORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CASSANDRA R ECKRICH Defendant NO. 00-2283CV NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: CASSANDRA R ECKRICH 5304 OXFORD DR APT 90 MECHANICSBURG,PA 17055-4430 DATE OF NOTICE: 10/2/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WTI1IIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE EN1ERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE, P A 17013 (717) 240-6200 BY: VALERIE ROSENBLUTH PARK, ESQ. PARK LAW ASSOCIATES,P.C. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EDltBit I A ~. " ," . 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: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CASSANDRA R ECKRICH Defendant NO. 00-2283CV 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 CASSANDRA R ECKRICH, Defendant is over 21 years of age; that his/her place of residence/business is located at 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 and that he/she is employed and that he/she is not in the Military or Naval Service of the United States or its Allies or otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 its amendments. PARK W ASSOCIATES, P.C. BY: Va rie Rose Attorney for E10 ----_6'~ - .~ I<~->' . ~ 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: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5304 OXFORD DR APT 90 MECHANICSBURG, PA 17055-4430 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CASSANDRA R ECKRICH Defendant NO. 00-2283CV 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 ES 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. ;~!ill.!Jl~i;~'iMiIil;;lIlfl!~'~lli'Mr'O''''';1''''"~if~B "^ ._~ ~ ~, . _,^4" , ~fl ~~~~ ~~ 4 . t (:J ~ ~ It:. ';'0 0 i:::J B C ,::J .... <0 a .,; r 1.]\:,:'- ,:-) rn,;"-_ < --l ~ ~ Z:-::::J i"'J "---"-' . '- /' ~ S?~: c' ~ ~ c' j ~ " ,~ -- 6' c;c:' ;.1 "':.... ,-' r! -....J ~ 5"" ~'? c: Z j"V f"- =< (11 A ~ .