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HomeMy WebLinkAbout00-04745 , "-.,- 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. JOSEPH E RHOADES III Defendant NO. OJ - 1./7'-1.j 6.;d 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 YOli. 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#:4168100107451674 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS JOSEPH E RHOADES III 517 W CUMBERLAND RD ENOLA, PA 17025-2514 DEFENDANT NO. {nJ- '-17'15' e;;;J~ CIVIL ACTION 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 businessat-4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, JOSEPH E RHOADES III, is an individual who resides at 517 W CUMBERLAND RD, ENOLA, PA 17025-2514. 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 4168100107451674. - , ~~ ~'" 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 $2,948.54 as of 02/16/2000, plus pre-judgment contractual interest at the rate of 19.80% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $589.71. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $2,948.54, plus pre-judgment interest at the contractual rate of 19.80% per annum from 02/16/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $589.71, 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. WBEREFORE, plaintiff demands that Judgment be rendered in favor of the Plaintiff, First Select, Inc. and against the Defendant in the amount of $2,948.54, plus pre-judgment interest at the contractual rate of 19.80% per annum from 02/16/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $589.71, 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. ~".... 1>-7IT "',' ,< ACCOUNT AGREEMENT Your DISCO"I/ER aCaJunt fu1s been tr:msferred to Fus: Select CCIForation. Your DISCOVER account was dQ5~d ~t tlze time oftltis tmns&r: and will r.herefore continue to be closed. This Account Agreement contains the tenns that govern you. First Select account (t.'1e "Account"). In this Agreement. '''you'' and "your" me:m each person wha is liable far paym;:n:: on the Accaunt. "We)' "our," ~'~urs," and "us" mean First S~lect Corporation or its assignee:s. Bet::l.llse yaUl" ACCOUnt has been transferred to us, you are now ooligated to repay the Account to us mstead ofDlSCQ\r"ER. [filie Account wns op~ed as a joint :J.ccount,. we may act on th= instructions of any joint accounthotder. P::syment3/ Fi.n:mce Charges. As tong as yOu. have a balance auts"..;mding on your Account, financ:: charges are calcu!at.:d :lS follows: To figure the ftoaDce charges for each billing cycle, we mUltiely the :lve:-age daily balance on you. Account by a daily p~odic mre. The daily periodic rate we apply is your At::,;;ount's Annual PC:'Ccntage Ra.to= divided by 365. Tl'I.~ An.nw.l Pere=tage Rate will be calculJ1t~ as disclosed in your most recent D[SCOVER account terms (the "Original Tenns"). If your Original Tenns provided for different .-'\nnual Percentage Rates to be applied to di;ffe:-ent comp<ments of your oUlSUlnding balance. we will apply the lowest such Ar.nual Percenug.e Rat~ to. your entire outst:lnding baI:mc~ , . We may ao::ept late or partial payments, or payment:\: marked "paid in full" or marked with otber restric:io~ without rosing-our rigf1t to coIIect aU amounts owing under this Agreement. You may ask First Select Corporation to pay this acctlunt by debiting your checking or savin~ account. First Se!ec:: Corporotion win f11"St verify your identity and eligibility for tlm; service. You may revoke your authorization by .....nting to First S~I<=Ct Corpomuon Customer Service. Fee3. We will ch:u-ge your Account a fee for each billing cycle within which your ACcOl.l.nt is delinquent (late charge). The amount of the tate charge will be as disclosed in your Original Terms orthe rna.'rimum late ch3rge permitt~ oy the law cfyour sure ofresideace. whichever is lower. We will clmrge y()ur Account a fee fur each returned payment check (reNmed check charge). The amount of the returned cb.:r..k charge wiU be as disclosed in you. Original. T mIlS, orthe ma.'fimum returned check ch4:1rge permitted by the l:l,W of your st:Lte of ~idenc~. whicheve;- is lowC:'. To the extent provided in your Original Terms, and to the extent pamitted by applicable law, in adCition to you!" obIigatioa to pay the outstanding balance on your Account, plus interest and fees as disclosed herein, we may also charge you for any collection cos-.s we incur. including but not limited to reasonable attorneys' fees and court costs. If your Origin:l.l Terms provided for an award of attorneys' fees and court costs, such provision as incorporated herein shall apply reciprocally to th~ prevailing party in any lawsuit arising out of this .<\gre::ment. Non-Waiver QfCerttin Right;,. We may delay or waive e:Uorc:::me::u: of any provision aft."tis .-\.gree:::ne:nt with~ut losing our right to entbrt:e: it or any othe:r provision Iater. AppHt::lble Law; Sevcrability; Assignment. No matter where you live, this Agreement and your Account are govem~ by f<=der.U law and by the: law of the state: designated as the applicable: law in you. Original T ~ !fyour Original terms did not contain :m 3.9plic:l.ble law provision,. then this Agreement and your Account are governed by t"ede:.U law and the law of your sute of reside::e~. This ~ent is.a finat expression of the: <Igre~<mt between you and us and may not be contradict.:d by evidence of:my alleged oral agreement. If my provision of this Agreement is held to be invalid or unenrorce:1hle.,. you and we will COI1S~der that provision modilled to conform to applicable law. and the rest of the provisions in the Agreement will stiIl b;: enforceable. We may tr.Jnsfer or ~igo oUt" nght to all or some of you. payments. If state !aw requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such cotice by:fiImg a Iinancing statement with tho: state's Secretary of State. Credit Reporting; Per.30na! T;nformad()1L If you fail to ful:fill the tenns of your credit QbU!ption,. a neg.1tive ct:dit report refl;:cting on your credit record may be st;bmitted to a cn:dit Feporting agency. In o~er.to disput: any. info~~ion_ we are re:portn;g :toout ;:0Ut" .~ccount, yo~ m~ '.vrite to us :t.t the fo!lo:vin~ address:. F:ir.it Select Corporatlon,. P.O. Box: 9104. Pleas:lnt01l, Californ:a,. 94:100. HI ~ maysh,"<: tltfonnaTto" _rlt oW' Ilffili.ara mcludin:. ...rrlrout Umdat~on. ProY'cdi.an 1Vatio/fa/ B4n~ 4nd ProY';dia.., .Ban/&. H '.ffl"OC', 701.l ma;r >nite to ur:rr tlJJ; time in.rtn.u:fill: us nQ( fa rltc<: :::~dir infqrm<rdon ...ttlt qur affiliate. YOUR BILLING RlGHTS -lCEEP THIS NOTICE FOR FUTURE USE This notice contains import:mt information about your rights and our responsibilities under the Fair Credit Billing Act. NotllY Us in Case orErron or-Questions About Your Bill !fyou think your-bill is wrong,. or if you need more informutian aboutan~ on your bilL write us,. on a. separ:ltesh~et,. at the following address: F'U'StSel;a .. Corporation. P.O. Box 9104. .Pl~ron, c.t3,. 94566. Wrireto us :1Ssoon as possible. We mustbe.::u- from you nol:1tertban 50 d:tys a..-'ter-wesentyou the first odl on wbich the errot"" or probtem iJ.ppe:u'ed. You cut telephone us. but doing so will not preserve your rights. Inyaurle~er,giveusthefollowing: .,., .-"----...-- . Your name and Account number. . Th~ clolbr amount of the suspected error. .. Do:=scribe the error and explain. if you ~ why you believe the::: is an .m-or. !fyou rteel! more ir-.formation. ce:scrib~ the it~ you are not sure abOl..t. Your Rights and Our Re:3pomibilities "<\.fter'We Receive YoUX' Written Notice We must acknowledge your letter widun 30 days,. unless we bave <:orrect~d the error by then. Within 90 days, we must either correct t."'te error or e~l~o why w.: believe the bill W:ls correct. After we receive your letter, we c:mnot try to coUect. or report vou as detinquent as to my amount you questior_ including onnnce. charges. We c:m apply .my UIIp::1id .:unOl.1nt aiaiml yoUt" credit line:. Yeu do not have to P:lY any questioned amount while we are investigating. but you are stIll obligated to pay the parts of the bill that are not in ques-.ion. Ifwe find that we made a rnist:tke on your bi11,. you will not have to 7<1Y o.ny fi:tunce ch~ re!.ued to any questioned amount. Ifwe did not make a rnist.1ke, y~u may have to pa.y w.ance cr-.a:rges, and 'Iou mIl .have to make uo the missed payments On the auestioned .mJ.ount. In either case,. we will send,you 11 st:ltemen~ ot Uw amQunt yeu owe and the date th:lt it is due. ffyou fail to p:i.y the :!lTlCt.'ttt We think you owe, we may report you .1S delinquent. Howeve:r, if o~ e.'t'plaru1,!toa does not satisfy you and you write to us within 10 days telIing us ~ you still refuse to pay. W~ :nust tell a:::yone we report. y_ou.to tr..at you question y~ur. bIll .. And we must tell you the name of .anyone we reported you to. W;: must tell anyone we repart you to t.1at t."!e tr.Ol.~ tms been settled betWe1m us when It.finally IS. Ifwe dQ not tbllaw these rul~, we c::umot colle;=t the first S50 of the questioned :unount eVen if your bill w:.tS COIT:ct. Special Rule for Credit Card Purd1:l::Je.:I If you b:J.ve a problem with the Quality of goods .md se3:'Vices that you purc.hased with yaur DISCOVER cr~it c.:I.rd and you ?a,:e tried in.gfJ~ faith to correct the problem with the m~hm1t,. you ~y not h:we to pay t.ie remaining <!IIlount due on the goods or services. The:e ate two limitat1or.s to this rIght: (a) y?u must have made tht: purchase in your home state cr, unot within yout"" homt: sute. within 100 miles of your current mailing :1ddress; :J....d (b) th~ p~~ pnc;.must have b~ more th:ln S50. Yaese limitations do not apply if e:ther we or DISCOVER ovm or op<;:r:lte the merchant, or Lfwe or DISCOVERmail.:d you.....e adver-.lsem.:nt for th.: prop.=rty or ~c=- =,- ~,,'~" . . VERIFICATION I, SUE eORRlEA , declare that as of February 14, 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. yj /' /iA' ' / ~-I '..... , ':J J....(~ G-l/ V !~c.... / 'Designated Agent ~'-" "..,.o..:1lMI<1:i;l(IHil;!tiilrt~i:lli~Ii'''ilW1bl~~J\Ii-~"~~,,,;M~'<'---''' 'm~ .il&iWiIIjiJ~ol;" 1IMl-~~ ." ~ ~,,~ - ,; ~_. ,,",-,. . . ~ fA ~ &' t ~ V\ \j 0 r' (") ,___,I C 0 ~"t 1 ~. ~ \ s, L- ---- ;:R" ' C: :;, '" rI f11 ,- , ,--' ~ ~ Z::U I :.i:!9 . Z~: w ~ ~ ~~;: 'Jo ~ !;20 -U :s:D ~ ~(") :;!:: "~-~,(") '" :>2. r;: 0"" ~ ~, N ~ (1\ ~ ,,- ~ ., -~- SHERIFF'S RETURN - REGULAR CASE NO: 2000-04745 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT CORP VS RHOADES JOSEPH E III WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RHOADES JOSEPH E III the DEFENDANT , at 1400:00 HOURS, on the 10th day of July , 2000 at 517 W. CUMBERLAND ROAD ENOLA, PA 17025-2514 by handing to JOSEPH E. RHOADS III a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers:r~~ 18.00 9.30 .00 10.00 .00 37.30 R. Thomas Kline 07/11/2000 PARK LAW ASSOCIATES Sworn and Subscribed to before By: ~ Deputy Sher' day of me this , i , 1 ,,'.,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: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 517 W CUMBERLAND RD ENOLA, PA 17025-2514 4168100107451674 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JOSEPH E RHOADES III Defendant NO.00'l.745CIV 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: $2,948.54 $589.71 $281. 51 ($0.00) ($0.00) $3,819.76 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 P edure No. 237.1 is attached hereto and marked Exhibit II II AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL VALE IE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff ~ ,:{ I ,. , AND NOW, dJ1' ~, Judgment is entered in favor of the Plaintiff and agaYhst the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. Is( ~. /~ PROTHONOTARY /- 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. ~~~ ,,'. , - ,~ - l' ~ " V ALERlE ROSENBLUTH PARK ATIORNEYLD. # 72094 PARK LAW ASSOCIATIS, P.C. DRIVE 25 EAST STATE STREET, P.O, BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATIORNEY FOR PLAINTIFF IHE~BYCERTIFYTIMTTHE TRUE AND CORRECT A1)D~SS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 517 W CUMBERLAND RD ENOLA, PA 17025-2514 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JOSEPH E RHOAbES ill Defendant NO. 004745CN NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: JOSEPH E RHOADES ill 517 W CUMBERLAND RD ENOLA, PA 17025-2514 DATI OF NOTICE: 8/1/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION ~QUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITIIIN TEN (10) DAYS FROM THE DATI OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED 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 TILEPHONE THE FOLLOWING OFFICE TO FIND OUT WHE~ YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4" FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES,P.C. BY: f/l~ VALE ROSENBLUTH PARK, ESQ, THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. )..71" ~~ ~-- ,",~,_J....' 1il'-~~~llJ!!j!Il~i<p<l~!ll!;!~~k""il-","='{!:. > .~~ lIlIIIl'fi-~"" """' _"c_ oM ~- ,~ ~'"'_'W, '", ~ l ~ 'o\~ (') C"') 0 C a E2~J ~n ~ ~~ "" :~--! ~~ B .,:;,-::D ~ 1 2C N (,~~ " en"", ()j -<"":.:::' ~. ~C) ;po. ~ -, Pc"- r~ :!J \J 7.., --f"" '=0 ::~(! ~ ~ Pc brn 2 j;! I1J :< 1.0 ::n \': -< - .L-' 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: 517 W CUMBERLAND RD ENOLA, PA 17025-2514 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JOSEPH E RHOADES III Defendant NO. 004745CIV 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 JOSEPH E RHOADES III, Defendant is over, 21 years of age; that his/her place of residence/business is located at 517 W CUMBERLAND RD ENOLA, PA 17025-2514 and that he/she is employed and that he/she is not in the Military or Naval Service of the United States or its Allies or otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its amendments. PAR~~~SOCIATES, P.C. B~.'~' 1_____ ~lerie Rosenbluth Park Attorney for Plaintiff E10 ,,".', " '~'JlI!il_~~~J" =~,~.......... -_-.J. . - '; "r o C: ?' ~,,", uu! fiirr< <:" ::?.., , 01];" ~~:~. ~..- ::? () ~O C ::? ::3! . ,,-,' ";"",,~,,",,,," ,,' ".,'<"'" o o ;". c::: .~..., r.~) c.n o ",., '- -"-,,, ~TC '-;'i;D }Z <)-1J .:;::.:() or71 5:! ::0 -< - - - '0 t; ;, -~ 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: 517 W CUMBERLAND RD ENOLA, PA 17025-2514 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JOSEPH E RHOADES III Defendant NO. 004745CIV 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. PROTHON9TARY: Isr t!ud;;,- /!!. ~ /.eL 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.