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HomeMy WebLinkAbout00-05408 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. THOMAS J GALLAS Defendant NO. CD- SJ.tD1 C()~L l~ NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. e:61RU i'!l5IHIH CJTR.' 'Ji:lI< 4th PI............. I <:~UlLe.LlalJ.d Count) C....JI...U. Llluut::il;;:: C~.Ll~ul_, ~A 1~Dl~ .(717') ~46-6~66 ~b. G,. &~ /)SSCcJ"tdI~A..J .;(. I...l:b~ {Joe... ~s&., fJA 170(3 717 ...,d)'l9-.J/~' THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ ,", ~ ,. '.-._ ,--.'c'" ,"<".. . , VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT#:4168100004814644 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS THOMAS J GALLAS 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 DEFENDANT NO, (J-()-S'lOY~ /~ 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 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, THOMAS J GALLAS, is an individual who resides at 1402 BRADLEY DR APT 312, CARLISLE, PA 17013-1248. 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 4168100004814644. " ~- -->~-"' ;}, ,,~ '''''',~'''' -. . ,r_." <"No""'" ~ , ""1",<'1".,,'.",., _ '.', 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 $6,987.74 as of 04/06/2000, plus pre-judgment contractual interest at the rate of 19.80% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,187.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $6,987.74, plus pre-judgment interest at the contractual rate of 19,80% per annum from 04/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,187.00, 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. .-" "~,~,," _;,,~:o.:"~;t. .' :_,!",r"""'~"-'-;'-i,~;'~"'-' '''__''_'C'' _'_',.___ - ~ : - ~J ,T 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, Inc. and against the Defendant in the amount of $6,987.74, plus pre-judgment interest at the contractual rate of 19.80% per annum from 04/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,187.00, 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. - ~,~ ',",,-"';+ ,-- ,'- ~ ", '~"\ >.-. .'~ -__~_ __ ,". > - - _71 , " _'< "., r, .", ,_ , ., "" " HEATHER KOOREMArIFICATION I, , declare that as of June 15, 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, alifornia. Designated Agent ,~'--' ,"" -. -._, ;<;:'-,' , - "'.""" "~," ,,"-" , ,~.,~- - ,---,-,-,.".- "',V""'V,_" 5040 JOHNSON DRIVE P.O. BOX 9104 PlEASANTON, CA 94566 888-964-4000 ~ " ~ EXHIBIT fy f- FiRST SELE.cT CORPORATION . . ACCOUNT AGREEMENT -- Your mSCOVER account has been transferred to rirst Select Corporation. Your DISCOVER account Wa5\:\osed at the t~ of this tra.nsfer, and will therefore continue to be closed. This Account Agrl?ement contains the terms that govern your First Sdect account (the "Account"). In ~is A~eement, "you" and "your" mean each person who is liable for payment on the Account "We," "cur," "ours," and "us" mean First Sdect Corporation or Its assIgnees. Because your Account has been transferred to us, you are now obligated to repay the Ac::ount to us imtead of DISCOVER. If the .-\ccount was opened as ajoint account, we may act on the instructions of any joint accountholder. Payments I Finance Charges. As long as you have a 'Jalance oUtst.lnding on your Account, fmance charges are calculated as. follows: To figure the finance charges for each billing cycle, we multiply the average daily balance on your Account by a daily periodic rate. The daily periodic rate we apply is your Account's Annual Percentage Rate divided by 365. The Annual Percentage Rate will be ca!cul31ed as disclosed in your most recent DISCOVER account terms (the "Original Terms"). lfyour Original Terms provided for different Annual Percentage Rates to be applied to different components of your outstanding balance:, we will ,apply the lowest such Annual Percentage Rale to your entire outstanding balance. We may accept late or partial payments, or payments marked "paid in full" or marked with other restrictions, without losing our right to collect alllUllounts owing under this Agreement. . Fee3. We will charge your Account a fee for each billing cycle within which your Account is-delinquent (1~ charge). The amount of the late charge will be as disclosed in your Original TetlllS or the ma.:cimum late charge pennicted by the law of your state: of residence, whichever is lower. We will charge your Account a fee for each returned payment check (returned check charge). The amount of the returned check charge will be as disclosed in " your Original T enns, or the maximum returned chet;k charge pennined 'ay lb.e law of your state of resiQence, whichever is lower. - To the extent provided in your Original Terms, and to the eKtent pennitted hy applicable law, in addition to your obligation to pay the outstanding balance on your Account, plus interest and fees as disclosed herein, we may also charge you for any coUection costs we incur, including but not limited to reasonable attomeys' . fees and court costs. Ifyaur Original Terms provided for an award of anomeys' fees and court costS, such provision as incorporated herein shall apply reciprocaUy to the prevailing party in aI'!Y lavmiit-.arising out of this Agreement . Non- W alveI' of Certain Rights. W f; may delay or waive enforcement of any provision ofthJs Agr~ement without losing our right to enforce it or any other provision later, r\:pplkahle Law; SevernbUity; A.ssigmrumt. No matter where you live, this Agreement and your Account are governed by federal!aw and by the taw of the state designated as the applicable law in your Original Terms. {[your Original terms did not contain an applicable law provision, then this Agreement and your Account are governed by federal law and the law of your state of residence. This Agreement is aftnal expres.sionofthe agreement between you and us and may not be contradicted by evidence of any alleged or;:l.l agreement. {[any provision ofthis Agreement is held to be invalid or unenforceable, you and we will consider r.hat provision modified to conform to applicable law, and the rest of the provisions in the Agreement will still be enforceable. We may transfer or assign our right to aU or some of your payments. Ifstate law requires that you'receive notice of such an event to protect the purchaser or assignee, we may give you such notice by filing a financing statement with the state's Secretary of State. Credit Reporting. If you fail to fulfill the terms of your credit obligation. a negative credit report reflecting on your credit re~ord may be submitted to a ~redit reporting agency. In order to dispute any information we are reporting about your Account, you must '-'"Tite to us at the followmg address: First Select Corporation, P.O. Box 9104, Pleasanton, California, 94566. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FCTURE USE This notice contains: .important infotrrUltion about your"rights and our responsibilities under the Fair Cr<:dit Billing Act Notify Us in Case of Errors or Questions About Your Bill If you :.hink your bill is wrong, or if you need more information about an entry on your bill, write us, on a separate sheet, at the following address: First Select CQrporation, P.O. Box 9104, Pleas-antoD, CA 94566. Write to us as soon j.S possible. We must heat from you no later than 60 days alter we sent you the ftrst bill on which the error or problem appeared. You can telephone us, hut doing so wiU not preserve your rights. In you.r lener, give us the follo\ving: Your name and ACCount number. The dollar amount of the suspected error. Describe the error and explain. if you can, why you believe there is an error. lfyou need more information, describe the item you are not sure about You.r Rights md Our Resp~msibiliti.e.s AfterW.e. Receive Your Written Notke We must acknowledge your lener within 30 days, unless we have corrected the error bv then. Within 90 days, we must either correct the error or explain why we believe the bill was correct. After we receive your lener, we cannot try to collect or report you (l$ delinquern as to any amount you question. including fmance charges. We can apply any unpaid amount aga.inst your credit line. You do not have to pay anv questioned amount while we are investigating. but you are still obligated to pay the parts of tile bill that are not in question. ~ !f we flOd that we made a rnist.lk.e on your bill, you will not have to pay any finance charge related to any questioned amount. If we did not make a mistake, you may have to pay finance charges, and you will have to make up the missed payments on the questioned amount. In either case, w~ will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount we think you owe, we may report you as delinquent, However, ifour explanation does not satisfy you and you ......nte to us within 10 days tel1ing us that you still refuse to pay, we must tell anyone we reporfyou to that you question your bill. And we must tell you the name of anyone we reported you to. We must tell anyone we report vou to that the maner has been settled between us when it finally is. Ifwe do Il{)t feBowthese [\lIes, we cannet cellec~ the first 550 ofIne qu;:stion-c:d amount even lfyourbiil \\'3.5 correct. Special Rule for Credit Card Purch:lses If you have a. problem with the quality of goods md services tha.I. you purch:1sed ',vith your OtsCOl,/ER c-:-ec.ilcud and you have tried in good faith to com~ctthe problem with the merchant, you may not have to pay the remaining :imount due on the "oods or services. There are two limitations to this right (a) you must have made the purchase in your home state or, if not within your home state, within 100 miles of..-ourcur.;::nt mailing J.ddress; and (b) r.he purchase price must have been more than 550. These limitations do not apply ifeith.:rwe or DISCOVER own oroper-ate the merchant. or if we or DISCOVER mailed you the aJvertis<:ment for the property or services. zsas lS,,;s ''11I ~ _~ . -~- - f? ~i- (\) _~ t & ~ a. i - ~ ~ E ,........_...""'"," -~-__,__""".,_""___",.....1-~..,,.," " ~~;,::.'::4i.:~''';-0+1"*$);~k~}f:-~j~~~~;'{::'';\'lt:;l;.:,~. ':ii;;Y'_':-,"_t'iir:r~ti" ;'!G't~{r ,~'i/..;"-{' .' A -~-"-"..? - '-,--" n" "~,'-~. ~ ,~- , . I 'I :1 I I I 1 ~) , 1 f.:l (J l' ~ 'f~ V1~-& ..()~C3o~ ~ ~ ~ () w --- ~ -- f- t 1- ,i ;) :,j \ \ - -~'"'- _ . _ il , . . -.. 0 0 ::::i'~ C C) < ~ 'J I ,I r-} ,---- "'.~) L:': --'" t'---' I ...:.-- CJ , c,,:, .. ~~- ~~ - 'r, 8 -' - , ; -- :<:::::..:: , , ).-, (c - .-q .-,:," ~- :) '-1:) --' SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-05408 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS GALLAS THOMAS J 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 GALLAS THOMAS J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GALLAS THOMAS J SEVEN ATTEMPTS AT SERVICE WERE MADE, WE WERE UNABLE TO LOCATE DEFT BEFORE COMPLAINT EXPIRED. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 omas Kline iff of Cumberland County PAR W ASSOCIATES 09/11/2000 Sworn and subscribed to before me this 1'1 ~ day Of.~r,:;;,~ ;lirZJV A. D. (l ""'-- GJ ~ ~ p~~onotary , "'""'~r~W ... ~ ~ " , 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, INC. Plaintiff VS. THOMAS J GALLAS Defendant OCT 2 4 2000PjJ , , CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 00-5408 ORDER AND NOW, this ;r'~ day of O~ ,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 Pefendant'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~ J. t. ~ 1Y)aJl /0 - ~5 -00 p.X~ - 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, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. THOMAS J GALLAS Defendant NO. 00-5408 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: I. The Complaint was filed on August 3, 2000 2. The Sheriff of Cumberland County made a "Not Found" return of service of the Complaint on September 11, 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 1402 Bradley Drive APT A312, Carlisle, PA 17013-1261. 4. Subsequent to the Plaintiff's attorneys' receipt of the Sheriff's "Not Found" return, Plaintiff's attorney made the described efforts to locate the whereabouts of the Defendant as indicated in the attached Affidavit of Investigation. 5. Despite Plaintiff I s attorneys' inquiries, the Plaintiff ~.- ~ , " "".. '-'. - --, has been unable to locate the Defendant. 6. The plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff's attorney shall file an affidavit of service showing service of the Complaint as set forth herein. PARK LAW ASSOCIATES, P.C BY: VAL IE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ~ ,. ~-""J '-~-' ,"- "".- "T ,--' 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 aU'boriri",~ VALERIE R~SENBLUTH PARK, ESQUIRE > , " SHERIFF'S RETURN - NOT F\..uND CASE NO: 2000-054~ P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT CORPORATION :. VS GALLAS THOMAS J 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 GALLAS THOMAS J \ but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GALLAS THOMAS J SEVEN ATTEMPTS AT SERVICE WERE MADE, WE WERE UNABLE TO LOCATE DEFT BEFORE COMPLAINT EXPIRED. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 omas Kline iff of Cumberland County PAR W ASSOCIATES 09/11/2000 Sworn and subscribed to before me this day of A.D. fA Prothonotary EXHIBIT 2~ I , " 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, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. THOMAS J GALLAS Defendant NO. 00-5408 CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a) A check of the local telephone directory shows that Thomas J Gallas does a telephone number listing at the address of 1402 Bradley Drive APT A312, Carlisle, PA 17013-1261. 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 Thomas J Gallas is not a registered voter with an address of 1402 Bradley Drive APT A312, Carlisle, PA 17013-1261. 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 Thomas J Gallas is not the owner of the property at 1402 Bradley Drive APT A312, Carlisle, PA 17013-1261. The Office's response is attached hereto, made a part hereof and ~,......,lllI' "~, "'1'_ ~-_. " -, , marked as Exhibit "B". e) A letter addressed to the Postmaster shows that mail addressed to Thomas J Gallas at 1402 Bradley Drive APT A312, Carlisle, PA 17013-1261 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. ::aw~~. VALER E ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF - = "-' , . " o PARK LAW ASSOCIARs A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYlVANIA 18901 VALERlEROSENBLurHP~p 282000 ROBERT E. ANGST' TELEPHONE (2IS) 348.5200 FACSIMILE (215) 348-401S . ALSO MEMBER Nl BAIt +ALSOMEMBERFLBAR September 19, 2000 Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: THOMAS J GALLAS 1402 BRADLEY DR APT 312 CARLISL~, PA 17013-1248 OUR FILE NO: 14588-1 Dear Sir/Madam: I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the address for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Very truly yours, PARK LAW ASSOCIATES, P.C. ~ BY: Amy Schermerhorn Legal Assistant Enclosure EXHIBIT A Name of Person: THOMAS J GALLAS Current Address: Date of Registration: Date of Birth: Previous Registration Address: ~~-\de.re.rLCLl~ (0n6\-f~~~((CJ\-tu V~, \\\ C.\)Sj\~'o.rO.. Co, vA. ,_[)" /, YJ/J, J 'O~~ .J~ {7Udi LAMjiWf/ hJjIS1TCL[ ,~",~,_",_ " ~w ", "~~_~ _..~, ~.,~ , -Wlil~illiIi!l~~Jlll~ <'-""~h~~,~i<>l"im,;w.,iili<-(,~i:Ii>t~;",-",~;;6;j';Mj'j.!i>Mi!W'''lrtS*,IW~k~-\$~~'". -~ ~ ~': ., ,-cl . ?'< > ~ -, . ~~- i.'""'''' C") ~ ~ 'P 6 o .0 c:: :;e. .,.-\ .,,< /;m~ \'<.o~ - " i ~ ~ ~ -0 '" ()1 " i I I t I I 1) is; o cP .""', !iII!LJ!,:,llrlr,Jl"~.:..,,i.) ,I.. ,L.,,\ "'j o ", 0 PARK LAW ASSOCIATES A PROFESSIONAL CORPORATION SEP 2 8 2000 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 .AL50MEMBBRNJBAR +A1.SQMf.MBEltfLBAR September 19,2000 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle,PA 17013.3387 RE: THOMAS J GALLAS Dear Sir/Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 1402 BRADLEY DR APT 312 CARLISLE,PA 17013-1248 Please uote the name and address of the owner below and return this letter to me in the enclosed self- addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES, P,C, Enclosure Property Address: 1402 BRADLEY DR APT 312,CARLISLE, PA 17013-1248, NameofOwner: fur~~ce ~~..~ ~~~ t L. Address ofOwner: -3 -, "<: "" ...~.. ~ >~ C' a...\\ ,,\_ Deed Book and Page No,: \ ~ 0 \ 2.(., EXHIBIT 5 --. ~ . ~. . , . . PARK LAW ASSOCIATES , A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 10 1 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK' ROBERT E. ANGST' TELEPHONE (215) 348-5200 FACSIMILE (215)348-4015 .ALSO MEMBER NJ BAR +ALSOMEMBERFLBAR Postmaster United States Post Office CARLISLE, PA 17013.1248 September 19, 2000 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Our file #: 14588 NAME: ADDRESS: THOMAS J GALLAS 1402 BRADLEY DR APT 312 CARLISLE, P A 17013.1248 NOTE: The name and last known address are required for change of addres8 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 hoxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a and b. l. Capacity of requester: Attorney 2. Statute or regulation that empowers me to serve proces8 (not required when requester i8 an attorney): 3. The names of all known parties to the litigation: FIRST SELECT CORPORATION VS. THOMAS J GALLAS 4. The Court in which the case has been or will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: 00.5408 CV 6. The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE UTIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF uP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. (TITLE 18 U.S.C. SECTION 1001). 1 certifY that the above information is true and that the address information is needed and will be used' solely for 8etV' e of leg a! process in connection with actual or prospective litigation. 'v Valerie Rosenbluth Park, Esquire Doyle8town, P A 18901 '--.-------------.-..-.-.--------.-------.-.-..-.----.-------------------.--.-.-.---.....-.---~'Crn~.-- FOR POST OFFICE USE ONLY / C:~"::-'::~$, _No change of address order on file. NEW ADDRESS OR BOXHOLDER'o/ . SfP .<:;..' REGISTERED ADDRESS '28 11 , V 25 East State Street _Not known at address given _Moved, left no forwarding address. _No such address POSTMARK: a.r"..",( j~ /)AAA., _. .. WHAT COUNTY IS THIS ADDRESS IN? C63 ~..- - ----~~ TIDS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT ~ '''"', ' ~~~ ,. ,"~-__".~~IIO!IJ ;" I" , 'P:_ QC\ ~?.1~ o c:) ,;::, Co -<<::- ~!~~ ~ 2,-- r,-, ",,-. ~:~"] ~S~ ="] -<. ~~ '~, ~ ,-~,-, ".""' . . c:;, -c, 0::-; CJ ::;::1 5i -< Iv """"-- ~""!"",,,~~~"',i~~l[,'Ii\1'i~~~Ifflfj~M!ii~'l!~ !'lIIlJllj!l~q!IJil!M.\ ~ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street DoylestoWfl, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT, INC. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. THOMAS J GALLAS Defendant NO. 00-5408 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ATTORNEY FOR PLAINTIFF ESQUIRE '-W;:~ ~,~~" 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. THOMAS J GALLAS Defendant NO. 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. r; COURT ADMINISTRATOR 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THIS IS AN ATTEMPT 1"0 COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ;"!'lUiM'I!,. 'c" ~"""-'_'" ~~, ,-0 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#:4168100004814644 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS THOMAS J GALLAS 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 DEFENDANT NO. 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 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, THOMAS J GALLAS, is an individual who resides at 1402 BRADLEY DR APT 312, CARLISLE, PA 17013-1248. 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or ~uthorized by the Defendant on a credit card or line of credit, 'bearing account number 4168100004814644, . ,~--~.~ ~, ~ , . 4. The terms of said account are stated in the documentation attached hereto as Exhibit "An. s. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the out~tanding debt as agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $6,987.74 as of 04/06/2000, plus pre-judgment contractual interest at the rate of 19.80% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,187.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $6,987,74, plus pre-judgment interest at the contractual rate of 19.80% per annum from 04/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,187.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. coum 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. , )1!;~ - -:" ~ > - I _~ ., .=-,.", ~;-- ., - ~ 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, Inc. and against the Defendant in the amount of $6,987.74, plus pre-judgment interest at the contractual rate of 19,80% per annum from 04/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,187.00, 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. ~ .~- 0-0 HEATHER KOOREMArIFICATION I, , declare that as of June 15, 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, alifornia. Designated Agent ~ , ~ r_ ~,~~ "" " 5040 JOHNSON ORNE P.O. BOX 9104 PlEASANTON, CA 94566 888-964-4000 l j EXHIBIT ft/ . 1, F 1 R SI-5E1E CT CORPORAT10N ACCOUNT AGREEMENT - Your DlSCOVER account has bem transferred to FirstS~lectCorporation. Your DISCOVER al:t:ount was closed at the tUn!::: ~fthis transfer,ll.nd will therefore continut to be closed. This Account Agr~ement contains the tmr.s that govern your First Select account (the "Account"). In this A~eemenr, "you" and "your" mean ~ch person who is liable for payment on the Account. "We, ~ "cur," "ours," and "us" mun First Select Corporation or its assignees. Because your Account has been transferred to us, you are now obligated to repa.ythe ACCount to us instead of DISCOVER. tfthe A.ccount was opened as ajoint account, we may act on the instructions orany joint accountholder. Paymenu I Finance Charges. As long; as you have a balance outstanding on your Account., finance charges are ca.lculated as. follows: To figure the finance charges for each billing cycle, we multiply the average daily balance on your Account by a daily periodic rate. The daily periodic rate we apply is your Account's Annua.l Percentage Rate divided by 365. The Annual Percentage Rate will be calculated as disclosed in your most recent DISCOVER account terms (the "Original Terms"). If your Original T;mns provided for different Annual P<:rcenb.ge ~ to be applied to different components of your outstanding balance, we will apply the lowest such Annual Percentage Rate: to your entire outSUr.ding balance. We may accept late or partial payments, or payments marked "paid in fun" or marked with other restrictions, without losing our right to collect all amounts owing under this Agreement . . Fees. We will charge your Account a. fee: for each billing cycle within which your Account is delinqu:nt (lal:.: charge). The amount ofUle late charge will be :1S disclosed in your Original Tenns or the ma:d.mum late charge pennitted by the law of your state of residence. whichever is lower. We win charge your Account a fee for ellCh returned payment check (returned check charge). The amount of the returned check charg~ will be as disclosed in your Original Terms. or the maximum returned check charge permitted by the law of your state of residem::e, whichever is lower. . To the extent provided in your Original Terms, and to the eKtent permitted by applicable law, in addition to your Obligation to pay the outstanding balance on your Account, plWi interut and fe~ as dis.closed herein, we may also charge. youJor any collection CO$tS we incur, including but not limited to re:as()nable attorneys' . fees and cou.rt c()Sts. If your Original Terms provided for an award of attorneys' fees and court cosu, such provision as incorporated herein shall apply reciprocally to the prevailing party in any law:s1i"it'-arising out oftrus Agreement. Nan-Waiver ar Certain Rights. We may delay or waive enforcement of any provision ofLhis Agreement without losing Qur rigbt to enforce it or any other provision later. _ Applicable Law; Severability; ..\ssignmenL No matter where you live, this Agreement and your .-tccount are governed by federal1aw and by the law of the state d~ignated as the applicable law in your Original Terms. If YOUr Original terms did not contain an applicable taw provision, then this Agreement and your Account are governed by federalla.w and the law of your state of residence. "This Agreement is a f1l'1al expression of the agreement between you 3lld US and may not be contradicted by evidence of any alleged oralagrecment. If any provision of this Agreement is held to be invalid Or .up.enforceable, you and We. will consider that provision modified to conform to applicable law, and the rest of the provisions in the Agreement will.still be enforceable. We may transfer or assign our right to all or som~ of your payments. If state law requires that you C'l:c:ive notice of such an event to protect the purchaser or assignee, we may give you such notice by filing a financing statement wich the state's Secretary of State. C.redit Reporting. rf you hil to fulfill the terms of your credit obligation, a negative credit report refie::ting on your credit record may be subnucted to a credit reporting agenc.y. In order to dispute any information we are reporting about your Account, you must write to us at the following address: First Select . Corporation, P.O. Box 9104, Pleasanton. California, 94566. YOUR BILLING RIGHTS. KEEP TI>IS NOTICE FOR FTiTURE USE This notic.e contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Cs in Case orErro~ or Questions About Your Bill [{you :hink your bill is \vrong, or if you need more infonnation about an entry on your bill, ......nte us, on a sepante sheet, at the following address: First Select Corpo~tion., P.O. Box9104, Pleasanton, CA 94566. Write to us as soon as possible; We must he:u from. you no later than 60 days alter we sent you the first bill on WhiCh the error or problem app~ared. You can telephone Wi, but doing so will not preserve your rights. In you.t' letter, give us the following: . Your name :uta Account number. . The dollar amount of the suscected error. . Describe the error and .:xpla.i~ if you can, why you believetlrere is an error. lfyou need more infotmatian, describe the item you are not sure about Your Rights:md Our Responsibilities ..\Iter We Receive Your Written Notice , We. must aclc;towledge your tetter within ~O days, unlWl we have corrected the error by then. Within 90 days, we must either correct the error or elqllain why we bebeve the od1 was COm:ct. Mer we receIve yot.zr letter, we cannot try to collect or report you as delinqu~t as to 3l'ly amount you question, including finance c:harges. We can apply any unpaid amount against your credit line. You do not have to pay anv questioned amQunt while we are investigating, but you are still obliga.ted to pay the parts ofche bill that are not in question. . lfwe fmd that we made a mistake on your bill. you will not have to pay any fin:1l1ce charge related to my qu.:stioned amount. If we did not ma.k.e a mist:1ke, you may have to pay [manee charges, and you will ha.ve to make up the missed payments on th.:= questioned amount. rn either QSC, we will send you a statement of the amount you owe and the date that it is due. ffyou fail to pay the amount we think. you owe, we may report you as delinquent. However, ifourexplanation does not Sa.tiSfy you and you write to us within 10 days telling us tha.t you stilt refuse to pay, we must tel13.llyone we report you to that you qu.:stion your bill. And we must tell you the name of anyone we reported you to. We must tell anyone we report you to tl10l1 th~ mOlttl:fhas been settled between us when itfinaUy is. If wJ; do not follow these rules, we cannot collect the first 550 of the questioned amount eV~n if your bill WJ.,S correct. Spcdal Rule for Credit C:1rd Purchase:! If you have a problem with !h~ qU31ity of goods and services that you purchas~d with your DlSCO\."ER. c:-edit cud.wd you haw tri::d in good faith ~o correct ~he problem with the merchwt, you may not have to pay the remaining :unount due on the goods or ser....ices. T:-::ere J.te Mo limita.tions lo this right: (3.) you must have made the purchase in YOllr h~m: st:;'-te or, ifnot withi':l y?ur home state, within 100 miles of~.ourcurr=:nt m:l.iling ~ddress; and (b) the: purchase pric;: must /tom: h.een more thm S5Q. Thot'se fimJt.:1t1ons do not apply lfeltn.:rwe or DlSCOVER own or operate th~ mercnanl, or ifwe or orSCQVER malted you th.:: J.dVtJrtlsc:ment for the prop~rty or services. _Oi!~ z???,. ,1IIl --,~. ~r ,'-" ,~"~ ,"""""'- ~~^ -- "'.'-' <r_',_'., .1' ,oj" '" ".' j';;'--~lilltl~lr~_t'tt'r11;~'V~' -'.--',; (") 0 0 C 0 -n -':i' "- Z -001 C) T, mn; .,.,..:: i'::::'~ Z:J') ZC I '-,', rr~ (J),d-:: G" -:_JC.J -<L~'_ '~:~1~~ ~CJ -0 P',..., ::J;: -:-_:0:;- --n 20 '~.;(') :S:>C Cd (5rn .--{ Z ,..." ~ =< \0 ._c 1q,,"_~.,'~~~~~J'~1M'ii!l'}:!''fi!t.i!'i:''''!~.f'''''''~"~1imf'.i;'!!?l!I$fliIt-~~~''!jll;lI!'jiJ~~IDll!IIfil~~~ , . VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. state Street P.O. BoX 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. THOMAS J GALLAS NO. 00-5408 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did attempt to serve the Defendant, THOMAS J GALLAS, on DECEMBER 5, 2000, at his/her last known address located at 1402 BRADLEY DRIVE APT 312, CARLISLE, PA 17013-1248 by United states certified mail, Article No. 7099 3400 0008 6906 1495, Return Receipt Requested, Postage Paid, with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter with the appropriate notice to plead as set forth in Pennsylvania Rules of Civil procedure. The United States Post Office attempted to serve the Defendant several times; however, the Certified Mail was returned to your deponent marked Uflclaimed, the original which is attached hereto, made a part hereof and marked Exhibit "A". That in accordance with the Order of Court, Valerie Rosenbluth Park, Esquire did serve the Defendant with a true and correct copy of the Complaint by United States Mail, Postage Paid, First Class on NOVEMBER 16, 2000. The Certificate of Mailing is attached hereto, made a part hereof, marked Exhibit "B". - ., "". - "-: -\:<-,,',_:i;.:,,;:,:,<jj'~""j 'J_ '-~-' " "111' _:--- tr.'. , I _e/" BY: V At IE ROSENBLUTH PARK, ESQUIRE orney 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. Ariy information obtained will be used for said purpose. I I i -,,-, '(I ~; ,o'i f; ~": ,") 'I :'-j 'j il ': ',i :-':! 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Pc .c:- 2: 1.._,/ =< ;:, :t:.:! .!:"" ;:0 .< '!MI~f~~~_1<!1'!;,.,O:!",P,~!'fti'll~',_~"rI'~'"",1~'#lI*M~!Ill~ " n i, i'! h Ii l.11 i ~ :1 .1 'I " 'I ! ::roo, "' 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: 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 4168100004814644 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC Plaintiff VS THOMAS J GALLAS' Defendant NO.00-s408 CV TO THE PROTHONOTARY: PRAECIPiE I FOR JUDGMENT 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 $6,987.74 $1,187.00 $659,57 ($0.00) ($0.00) TOTAL $8,834.31 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 Proce~uxe l\Jo. 237.1 is attached hereto and marked Exhibit "A". / V IE ROSENBLUTH PARK,ESQUIRE Atcorney for the Plaintiff AND NOW, '- );;L.. ~ /7 ,.;206 ( , 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. " -.' _"~,_o",_, -"-- , . , ~ - , ~,,*,) ~4 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. --'{ml3i~_ _ < ~~" . ~, - ,. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES,P,C. DRIVE 25 EAST STATE STREET, P,O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348.5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY. COURT OF COMMON PLEAS I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAThITITF:M60ROSEWOOD PLEASANTON, CA 94588 DEF: 1402 BRADLEY DR APT 312 CARLISLE, P A 17013-1248 FIRST SELECT, INC Plaintiff VS mOMAS J GALLAS Defeudant NO. 00-5408 CV NOTICEOFPRAEC~EFOR ENTRY OF DEFAULT JUDGMENT TO: mOMAS J GALLAS 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 DATE OF NOTICE: 12/26/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITIllN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WTIHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IT 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, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P,C. BY: VALERIE ROSENBLUTH PARK, ESQ, cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT 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, CA94s88 DEF: 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC Plaintiff VS THOMAS J GALLAS Defendant NO. 00-5408 CV 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 THOMAS J GALLAS, Defendant is over 21 years of age; that his/her place of residence/business is located at 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 and that he/she is employed and that he/She is not in the Military or Naval Service of the United States or its AlIi or otherwise within the provisions of the Soldiers and ors Civil Relief Act of Congress of 1940 and its amend s. PARK LAW ASSOCIATES, BY: Va rie Rosenbluth Park Attorney for Plaintiff E10 i,:;n ~ ~ ~~ ~ ~'- ~ ~ - """""""""'. ~"~,-~.,>', ~ . 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 PLEASANrON, CA 94588 DEF: 1402 BRADLEY DR APT 312 CARLISLE, PA 17013-1248 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC Plaintiff VS THOMAS J GALLAS Defendant NO. 00-5408 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. //17/0/ PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE. P FAIR DEBT COLLECTION CTICES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT -<f!" . ~,~ ~_........ ~ -. , " ~~ , ,;,~~ I -, ,c_ " .,-- " ~' -. "--'- .~,' ,.- t (V ~ ~ --Q ~ It:.. , B - I' .... - r 0 \' f'- ~ )::) ~ IN ~ ~ C) C.:::' ~ --. c: Rr ~= - 'nO"~ c. rr-- ~ fY-ir", .--,,,. ?'''::~ c:' cc': '- ~ -?..:... ----,," ," ~_~c-"- '<;, <:(~ 5~;:~~ "" _~l --< to , ,~ "",~"<,;~_."",,,_ ~.~ oDllI{I.)lIJ ,",,",li!!!jiJ!',!?W~~~1ffi~_="_.,_>..,.,.,.~IlIIM_,_ '~,,'-""""'"'"._'