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Home My WebLink About00-04322 ~~~> " ,'" .; . 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. JONATHAN B MANN Defendant NO. 00 - "-IJ~ C'" ~ C-- '~ NOTICE You have been sued in Court. If you wish to defe~d 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 p~BT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "" _,,","u." ~--.~ - ",;,,-,,~.t,,_ ~'- "",""~"'-<k"~''''''' "),- ... 11 VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72G94 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT#:4168100005510639 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS JONATHAN B MANN 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 DEFENDANT NO. 0-0- </3.2.v ~ y~ CIVIL ~CTION 1. The Plaintiff, First Select, Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware 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, JONATHAN B MANN, is an individual who resides at 4830 EAST TRINDLE RD., MECHANICSBURG, PA 17055. 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 4l68100005510639. 4. The terms of said account are stated in the documentation attached hereto as Exhibit ~N' . . * .. 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 $1,807.07 as of 12/16/1999, plus pre-judgment contractual interest at the rate of 19.24% 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 $361.41. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $1,807.07, plus pre-judgment interest at the contractual rate of 19.24% per annum from 12/16/l999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $361.41, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT I I 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. ll. 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 .. ~',~, ,- ~ . ,.,' ,-' ~ I~J, ,--F"-:.'; "'j",-,-""",,,,~ . . 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, Inc. and against the Defendant in the amount of $1,807.07, plus pre-judgment interest at th~ contractual rate of 19.24% per annum from 12/16/1999 until the date of the judgment herein, plus reasonable attorney's fees in th~ amount of $361.41, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Ie . "...;....;.'.<., ~., _ .4 ,l, - J :.1,' " ~ ~ -, VERIFICATION I, , declare that as of February 28, 2000: I am a designated agent of FIRST SELECT CORPORATION, the Plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in the State of California. ~{/Jk MARY M. MAXEDON Designated Agent ~ '- '- SQA{) JOHNSON ORNE P,O. BOX '3104 PLEA-SANTON, CA 94566 888-964-4000 -.lJ Fl EXHIBIT , -- C 0 ACCOUNT AGREEMENT f UN Your ASSOICATES ~ has been transferred to Fint Sdec;r: Corporu,ion. Your ASSO[CATES ac::ount o..V3s dozed at the time of this tr::J.nSfer, and will therefore continue to be closed. TIlls Account Agree..-nent cOnuIns the tcr:m that govern your First Select :J.l:eOunt (the "Account'). In this Agreement, "you" and ')lour" mem e:te.; pet"S(ln who is linb!e for payment on the Accotfnt. "We," ...our,.....ours.- and "us" mean rU"St Select Corpara.tian or Its 3S$ignecs. Because your Account has been transferred to us. you are noW' obligated to repay the ACCOunt to us inst~d of ASSOICATES. lfthe Account was opened:u a.joint acctJunI,. we m:t.yact on the Lnstructions ormy joine accaunilialdcr. - - - Paymt.:nt3 f Fmanee Char:~. As long as you have a. balance outstanding on your Account, fl!lOUlCe chargl:S are calculated as raHows: To fi~re thll: fmanee chargC3 for c::J.ch billing cycl~. we multiply the .1.ven.ge daily balance on YOUr Account by a daily periodic rate. The dally periodic r:l.te: we apply IS you< ;\.co:)Ul1!'s Ann1ULI Percentage R..:tu- dIvided by 365. The .4nnual Perc:nuge R.m- will be- ca!cubte-d as disclose-d in your most ,ec..-nt ASSOrCA YES account terms (the ~OriginaJ. Terms). If your Ori&inal Terms provided for dtm:rent Annu:tl Perttntaee Rates to be applied to different compone::lts of you. outstanding balance, WI: win apply the lowest such Annual Percentage ~e to you. entire outsUndini ballU1Ce. Wemaya.ccept la..te or partial payments. or payments marked "paid in fuU" or marked with other restrictiom, without losing our right to collcctall Jrnounts owing under this ~eme:nt You may:uk rll'St Sdect Corporation to pay this accoLUU by debitio.S your checking or savings account. Flrn: Select Cotpotl1tioa will fU"St verifY your identity and eligibibty for this service. You may ~voke your lI.uthoriz:Uion by writing to F~ SeleC:: Corporation Customer S~. Fed. We wiU charge your Account a. fee for e:lc.'1 billb& cyde within which you. Account is de(inquent (late charge). The amount of the fate chuie wiU be :lS disclosed in. your Qrigin:tl Terms or the maximum late .:.inrge permitted hy the law of'your stale ot residence, whichever is lower. We will charge your .-\.c:count a fee for C::J.ch ~turned payment check (returned check charge). The amount Qfthe returned check cwge will be as d.isclosed in your Origin::L1 Terms, or the maximum retUrned check chnrie permitIed by the law of your st::Ue of residence, whichever is lowei. To the exter.t provided tIt your Ori~ T erm:s, and to the extent permitted by ilpplicab!e law. in ilddition to your obligation to pay the outstanding balance on your Account. plus interest and f~ as disclO$ed Mrein.. we may also charze you for :my collection co;tS we inco.J.r, including but Dot limited to r~ona.ble ;momeys' fees :uui court COStt. lTYQur Original Te:rms provided for i1n llwaro orattorn~ fees U1d court costs, such provision as incorporated herein slulI apply reciprocally to the prev:Uling party in :my lawsuit:tti5lng out of"this Agreement. Non-W:1lvcX" oCCert::1in Ri~b. We may delay or waive enforccmemofany provision of this Agreement without losing our right. to enforce it or any other provision later, . ApPUc:1ble Law; Scvct':1biIity; As.:denment. No m:!ltterwhcre you live, this Agreement and your Account are governed by fedenllaw and by the Ia.w of the st.lte designated as the app{ica.ble raw in your OriginaITenm. Cfyour arigina! te:ms did not conbin :m applicable taw provision. then this Agreement and your Account are governed by fedtt:1llaw md the law of your !Ute of residence. TIlls A&n:lCtI'1ent is a fuul exprc;ssion ofth~ a.greement betvleen you nnd us and may not be contmdicted by evidence of any alleged orala.gr'eement. If any provision o1"this Agreement is held to be inv::ilid or uncnforc~le, you .1nd we will consider that provision modified to conform to appliobte law, and the rest of the provisions in the Agreement will still be enfot'Cl:abte, We may tnnsfer or assign our right tQ all or some of your payments. [f state: [OlW requires: tbat: you receive notice of such an event to ~tect the purcmuer- or assignee, we mOly give you such notice by filing a fmanc1ng s::nement with the :tate's S~tary of State. Credit Reporting. It you fa.iJ. to fulfill the terms of your credit obli~tion. i1 negative credit report reflectint on Ytlur credit record may be submitted to a credit reporting agency. In order to dispute :my intonn:ttion we arc reporting 3b<:iut your Account, you must write to US at the following address:: FIrSt Settct . Corporn.tion,. P.O. 80l( 9104, PIe:uanton. California., 94566. youn B1LL1NG RIGHTS - KEEP THIS NOTICE FOR FUTURE USE This ootice eont:l.w import.utt int"Qrrru1ticn .:Waut YOW" rief1ts .1I:1d our respQl'1Sibilitid under' thc= Fair Credit BiIlio:g' Acr. Notify Us in Case of Err on or QUe3tion.s About Your Bill If you think. your bilI is wrong,. or if you need more inform:ttion about an ent.'")' On ym:n- bill. write us. on :t separate sheet,. ilt the following address: F"U'St Select Corpor:uion, P.O. Box 9104. Ple:1.1anton. CA 94$66. Write to us ~ scon as possible. We must he:trfrom)'(lu no ta.ter-than 60 cb.ys after we sent you the ftrSt bill -an which the error or problem :tppeued.. You c:c:l telephone u:, but doing so win not ~ your right.!. In yout',te""-er. give us the following: . Y~.name and Account nlJmber. . The-aoU.u amOlJnt of the suspected error. . Descn1lc the e:-ror and explait<-.. if you em. why you believe there i$ an error, tfyou need more i:nf~tion. describe the item you are: not Sll.--C 3bout. Your Riehb md. Our Re3pow:ihilities A!'ttr W If: Ree-ei-ve Y our Writt~n Notice We must ilCXnowtedge your tetter within 30 da.ys. unless we have corrected. the trror by tMn. Within 90 d:1ys. we must either cor:rect the: ~ or ~:q:ttain why we belie~ the bill was correct. After we receive your letter, we cannOt try to collect or report you as deLinquent as to any ~T.ount you question. inctud.1ng fm:mce c1urges. We C1napply myunp:udamount a~ your credit tine. You do not have to pay a.nyquestionc::l. .mrount whilew-= are investiptll1a,. but you arestiII obligilted to pa.y the pans of the bill that are not in question. - I[we fmd that we made a mi$uke on your bill. you will not have to pay any finance charge relattd to:my questioned 3rt1ount. lfwe did not make a mist::llc.e. you m::ty have to pay fInance c~ a.nd you wiilhave to r:W;.e up the ~ed payments on the question.:d 3.InOunt. In either c:u.e. we will ser.d you a sutemoent of the ilInOunt )'QU owe and the d:1te that it is due. If you fail to pay the 3.."'t1ount we think you owe, We !relY report you as de.linqlJc:nt. Howcver, it out expl.u1:1tion dad not s:nuty you me! you write to Wi withia 10 days te:Uing us that you stin refuse to pay, we must teU anyone...te report you to that you qUes"Jon your bill. And we must teU you the n:une of" anyone we reported you to. We must tel! anyone We report you to that: the matter h:1.s been settled betWee:t us when [t finally is. lfwe do not follow these rules.. we cannot collect the rltSt S~O ofth~ questioned amount eVen tfyout'bill W3.S C01Tf:Ct.. Special Rule (or Credit Card Pu.rch:205es lfyou have a pt'obtem with the qua.lity of goods .:md5-l:fVices.that you PUrch3Sed with your A.SSorCATES credit ~ J.ndyou Move tried in ~ood f.utb to ~orr~t the problem with th4:' m~Mnt, you may not luw: to p.1Y th~ rem.:1ir-.ing amount du~ on !.he- goods or scvic.es. There u:e twO lumbtions to this Tighe (;1) you must h:t.ve.m:lde th~ purch::zse in Y<:lurhornc: sbte or, unoI within y<lut home SUle, witiUn 100 miks ofyeur curr-<:nt m::u1ing3.ddres:s: and (b) 1..1.<e pUf1:hase price must have been more th:l.rl S:iC. Tho:s~ limitations do not apply ife:ither we or .A.SSOICATES ev.u or opc-rat.:: th~ m~h:mt, ur uwe or ASSorCATES maikd you m<: :I.dvenlst:mt:m for the property or s~rvict:s. --- zsali ~''''''';'-'--'' "" .~~_1i"'~~~1lIlIlr.ililOili,\[!!ial!~~;;:H:;;~~'" :--1"" "'1'''',' " '~'~j~~M~ (90t is (:t 'l. ~h~ ~ t d () ~ V) -:S f D? ~~ ~t --1- - ~1liIllailllI1t1llfi!_,'~m - ,0 C ;;>- iBW z:x~\ z. L. f.FJ.J:.:"" ""2 r::O ~O :;:;0 ~ ~ cD '- ~ % N IT' .." ::It y o \.0 o -n :..:.:1 (h-~ , ^TIm :,,;1'( 8 ~L) ~~ .Vj ~ ~ " ~ I, I", ~ ,L SHERIFF'S RETURN - REGULAR CASE NO: 2000-04322 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS MANN JONATHAN B BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MANN JONATHAN B the DEFENDANT , at 1512:00 HOURS, on the 10th day of July , 2000 at 4830 EAST TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to AMY STOUGH, ADULT IN CHARGE FOR DET a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: rC?? _.#<:~ 18.00 6.82 .00 10.00 .00 34.82 R. Thomas Kline Sworn and Subscribed to before -a:... me this .,Lv - day of ~ ~ A.D. Qr"'O ~,,l;Cd~M(_ rothonotary , 07/11/2000 'ARK :: ANiv~ ~ Deputy Sheriff . ._1 .' 0 ;,~' , ~, ~ ~ _, " ."",Idc:-;-I-;-. '__,J." '~ ... . 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: 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 4168100005510639 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JONATHAN B MANN Defendant j NO. 00-4322 CV 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 $1,807.07 $361.41 $227.66 ($0.00) ($0.00) $2,396.14 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 rior to the date of the filing of this Praecipe. A true a correct copy of the notice pursuant to Pennsylvania Rule of vil Procedure No. 237.1 is attached hereto and marked Exhi . TOTAL VALERIE OSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff '11:\ ,- ~' ,"..J . -'. > .;. " -"'-"-" ,. ~ ~"-<' ,1"uL.i;..,;;.t -, -'.'-';;,.' "". -"''''-'',! AND NOW, 1J,.I'j JP. ' _J("'V)O ,Judgment is entered in favor of the Pl intlff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above ce~tification. yC,;;-L.> ~ _ ~ ' ROTHONOTARY PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. f["; ~~ L I .. VALERIE ROSENBLUTH PARK ATIORNEY LD. # 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 DEl': 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JONATHAN B MANN Defendant NO. 00-4322 CV NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: JONATHAN B MANN 4830 EAST TRINDLE RD. MECHANICSBURG, P A 17055 DATE OF NOTICE: 7/31/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACf WIT1IIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A nIDGMENT MAY BE ENTERED AGAINST YOU wrrnOUT 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, 4" FLOOR CARLISLE, PA 17013 (717) 240-6200 BY: VALERIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT I A In: - "~ ^ - " J', " - :I",~ 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: 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VERIFICATION I NO. OHm cv Of NON-MILITARY SERVICE VS JONATHAN B MANN Defendant 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 JONATHAN B ~, Defendant is over 2l years of age; that his/her place of residence/business is located at 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 and that he/she is employed and that he/she is not in the Military or Naval Service of the United St~tes or its Allies or otherwise within the provisions of the diers and Sailors Civil Relief Act of Congress of 1940 and amendments. PARK LAW ASSOCIATES, P BY: Valerie Attorney osenbluth Park for Plaintiff E10 , ',~ , ,', ~ ,--, - 1- -, ~'" ) ,- ~""-,, '"".1 ,', -, ,-, ' "I.' ;1, ~ '-< '-, -,"",j<<, -', - > J " . 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: 4830 EAST TRINDLE RD. MECHANICSBURG, PA 17055 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JONATHAN B MANN Defendant NO. 00-4322 CV 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 REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE. PR('t.2!J!'Y' K ~ JrJ VI 'fJ-' . FAI~ ~EBT COLLECTION TICES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT ',!C' ,~~~"',,"';-"< " 1IIl-~ :1 _ MJIi'lJlio~~"~,~.,_"._ ~.. "~, -- 'f~ ~~"- '- ~~ ~ ~ 2- tU 6' - "'<:' X .......' ....... () -'<l -..c . g ~ ~ ~ (.J 'l ~ ~ 6.J >f _~ --.._..,~.... -~ o ~?~ 0J,;-' r::f-: <.~ ~--" j'o ;;'-." :r:,.C :z ~ ,'~ ,,- '-' . ., ",-, C) c; }~ ;;"') r..,) co :p,. --;, '~,~f'~ ~ ~~~ 5.-0 -< N I::> . <' - , , '~, '" 1.;,,,,,,,,,,'1 ,- ~ -". "',,,-,,,,,' ,"eo' c o IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL VANIA INRE: JONATHAN B. MANN, Debtor : IN BANKRUPTCY : CHAPTER 7 PROCEEDING : BK. NO. 1-04-00039 JONATHAN B. MANN Movant v. : c.w-mb2Jl~ : COURT OF COMMON PLEAS OF DAUPIHN : COUNTY, PENNSYL VANIA : NO. 00-4322 : JUDICIAL LIEN AVOIDANCE ORDER OF COURT FOR JUDGMENT BY DEFAULT FIRST SELECT, INC. Respondent AND NOW, this ~-tlYday of Mc..'(~ ,2004, in consideration of the within Motion for Entry of Judgment by Default filed by counsel for the Debtor/Movant, the Court fmds that the Respondent has failed to file an Answer or otherwise plead to the Motion for an Order Avoiding Judicial Lien filed on January 16, 2003 and duly served upon the Respondent; therefore, the Court orders judgment by default in favor of the Debtor/Movant, Jonathan B. Mann and against Respondent, First Select, Inc. to the relief requested in the Motion. IT IS HEREBY ORDERED, adjudged and decreed that the judgment lien held by the Respondent is hereby declared void in its entirety and of no further force and effect as it violates 11 U.S.C. Section 522(t)(1). BY THE COURT: Is! MARY D, FRANCE Bankruptcy Judge CERTIFIED FROM THE RECORD thiS~ day of ".8 -p'r ~ 1 . 20a:i Clerk, U,S. 8ankru~tcy c~ Per. ~ Deputy Clerk HARRISBURG F\LED PA YAft - 4 2J)04 Clerk. 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