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Home My WebLink About00-05608 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. CHERYL A BLACK Defendant NO. 60 - ,sl..cR Cic.>~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. -<::Q'.ml' hBI-IINI5Tl'tAJ:OIt ~.l?c. ~'aA.lJa'oc.IW(~1\J 1. th 11.....,-,-,-, a1:1fRl3erlaRe COtllitl COtu: thOU,::H:: .c~~l';'ol~, l'A 1)812 :L J...1"brucl-~ {Joe... (71 ,) >:46-6>:66 IL ( '- ~~~( Ii- 1701.3 ?/7-;;249-.3'" THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '~""'" I '~'r_ ,~' __ > " "'~ , ',J, 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#:4168100107904987 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS CHERYL A BLACK 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 DEFENDANT NO. (H)- S(,,01 ~ 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 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, CHERYL A BLACK, is an individual who resides at 530 HUMMEL AVE APT 4, LEMOYNE, PA 17043-1828. 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 4168100107904987. 4. The terms of said account are stated in the documentation attached hereto as Exhibit nAn. 5. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the outstanding debt as agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $5,653.58 as of 04/05/2000, 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 $961.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $5,653.58, plus pre-judgment interest at the contractual rate of 19.80% per annum from 04/05/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $961.00, 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. ': - ~_"l <, ",,01' .~," --,~,. " ~ , " 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 $5,653.58, plus pre-judgment interest at the contractual rate of 19.80% per annum from 04/05/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $961.00, 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. 1',''-'''''''''' -',-,.- ',,' ,,- '-"'~""',---" ' . "", < = ',-- --~~ - , . :"'. -;./--n,- ,,"- -" ..,~~ . . . ~~ VERIFICATION I, HEATHER KOOREMAN , declare that as of April 19, 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, Designated Agent ~". "'. 1""- ~'," ~,'-~< ,,'''~'''''',' ~"<;"''- -~"-" "",',\ __",'"",,_ ,~,"o, ,__,0-, ,- . -- ,-"" ":"\~~'-' '" - ,",~"'''''', "'"""'-..,, -" . EXHIBIT oJ' '" ~ 5040 JOHNSON DRIVE P.O. BOX 9104 PLEASANTON, CA 94566 888-964-4000 I A . F1RST S_ElECT CQRPORAT10N ACCOUNT AGREEMENT . Your DrSCOVER account has been transferred to First Select Corporation. Your DISCOVER account was closed at the time ?fthis transfer, and will therefore continue to be closed. This Account Agreement contains the tenns that govern your First Select account (the "Account:'). In ~s A~eement, "you" <lnd "your" mean each person who is liable for payment on the Account. "We," "our," "ours," and "us" mean First Select CorporatIon or Its as5ll9;le.es. Because your Account hQ.S been transferred to us, you are now obligated to repay the Account to us instead ofDISCQVER. If the Account was opened as aJomtaccount, we may act on the instructions of any joint accountholder. Payment! I Finance Charges. As long as you have a balance outstanding on your Account, [manee 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 A.nnua[ Percentage Rate divided by 365. The Annual Percentage Rate will be calculated as disc~osed in.your most recent DISCOVER account terms (the "Original Terms"). If your Original Terms provided for different Annual Percentage Rates to be apphed to different components of your outstanding balance, we will apply the lowest such Annual Percentage Rate 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 aU amounts owing under this Agreement. . Fees. We will charge your Account a fee for each billing cycle within which your Account is delinquent (late ch~ge). 1!te amount of the late charge will be as disclosed in your Original Teons or the maximum '.ate charge permitted 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 retum~d check charge will be as disclosed in your Original Terms, or the maximum returned check charge pennitted by the law of your state of residence, whichever IS lower. - To the extent provided in your Original Teons, and to the extent permitted by 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 collection costs we incur, including but not limited to reasonable attorneys' . fees and court costs. If your Original Terms provided for an award of attorneys' fees and court costs, such provision as incorporated herein shall apply reciprocally to the prevailing party in any lawsuit arising out of this Agreement. Non-Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our, right to enforce it or any other provision tater. Applicable Law; Severability; Assignment. No matter where you live, this Agreement and your Account are governed by federal law and by the law of the state designated as the applicable law in your Original Teons. If 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 a fmal expression of the agreement between you and us and may not be contradicted by evidence of any alleged oral agreement. If any provision of this Agreement is held to be invalid or unenforceable, you and we will consider that provision modified to conform to applicable law, and the rest of the provisions in the Agreement will still be enforceable. We may transfer or assign our right to all 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 ref1ecting on your credit record may be submitted to a credit reporting agency. In order to dispute any information we are reporting about your Account, you must vm.te to us at the following address: First Select . Corporation, P.O. Box 9104, Pleasanton, California, 94566. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FliTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify L's in Case of Errors or Questions About Your Bill If you ~nk your bill is wrong, or if you need more infonnation about an entry on your biB, ""rite us, on a separate sheet, at the following address: First Select Corporation, P.O. Box 9104, Pleasanton, CA 94566. Write to Us as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In you,! letter. give us the following: Your name and Account number. The dollar amount of the suspected error. Describe the error and explain, if you, can, why you believe there is an error. If you need more infonnation, describe the item you are not sure about. Your Right! and Our Responsibilities A.fter We Receive Your Written Notice w~ must aci<?owledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we beheve the bill was correct. After we receive your letter, we cannot try to collect or report you as delinquent as to any amount you question, including finance charges. We can apply any unpaid amount against your credit line. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of the bill that are not in question. {fwe fmd that we made a mistake on your bill, you will not have to pay any finance charge related to any questioned amount. lfwe did not make a mistake, you may have to pay fmance charges, and you :win have to make up the missed payments on the questioned amount In either case, we will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount we think. you owe, we may report you as delinquent However, if our explanation does not satisfy you and you write to us within 10 days tellmg us that you still refuse to pay, we must tell anyone we report you to that you question your bill. And we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we do not follow these rules, we cannot coUect the first $50 of the questioned amount even if your bill was correct. Special Rule for Credit Card Purchases 1fyou have a problem with the quality of goods and services that you purchased with your DISCO'v'ER credit card and you have tried in good faith to correct the problem with the merch~t, you may not have t~ pay l~e ~emaining amount du~ o~ the goods or services. There ii!"7 two limitations to this right: (a.) you must have made the purchase m your h~m~ st~te or, If not Wlth!~ y?ur home state, wlthm 100 miles of your current mallmg ~ddress; and (b) the purchase price must have been more than $50. These lImitatIOns do not apply If either we or DISCOVER o\m or oper:J.te the merchant, or If we or DISCOVER mailed you the adv~rtisement for the property or services. Z586 Z5~6 ''l'P>'1 . - ~ ,~. ~- ' L"il , " !', ~ "r ,~l'jl "'~ ,- .,~ ?'-"~', .; .' . '- f~ -()~ -{)~ ~t C> . ~". - " ~~~ d 0 ~ I 9 () ff!(/) t~ ~ HAY... 4 2lIJJ (") c <'" -o6:S nlrn 2::-1::.' ZC ~~?~ r;: CJ ~C; "",0 ~c ~ --" a C> ". ~ {5 ~/8 -.-lrn ~jy Sc) ~~; ;;8 -- \... ~ c5f'l'1 )j ~ .;:-- -ry --'..,.,- -- w :::> .1'"" .- " ,,' ". C 'J',r _ ,_~~iiI",'ffl9f!1""~!~~~_"" J~t~~~,,~",!Ill'~W~ T ~ ~J "~~'~'~F SHERIFF'S RETURN - REGULAR CASE NO: 2000-05608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS BLACK CHERYL A RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BLACK CHERYL A the DEFENDANT , at 0014:55 HOURS, on the 17th day of August , 2000 at 530 HUMMEL AVENUE APT 4 LEMOYNE, PA 17043-1828 by handing to CHERYL BLACK 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 18.00 9.92 .00 10.00 .00 37.92 So Answers: r-~~'~~~ R. Thomas Kline 08/18/2000 PARK LAW ASSOCI Sworn and Subscribed to before me this {, ~ day of _~"'~. I.... .2o-?ro A.D. Ck~ 0 'nt- ii, -' l ~l7 othonotary I . By: ~ Sheriff 0,'7:":"1 " ~I 0'- ",- "~ ~ ., 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: 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 4168100107904987 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CHERYL A BLACK Defendant NO.005608 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: $5,653.58 $961.00 $254.55 ($0.00) ($0.00) $6,869.13 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 Procedure No. 237.1 is attached hereto and marked Exhibit "A" " AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL VALERIE R ENBLUTH PARK,ESQUIRE Attorney for the Plaintiff ;'"''f,', ......--1 . , AND NOW, C'x-} S ,~OOO , Judgment is entered in favor of the Plaintiff and against the Defendant by Default ~or wqnt of an Answer and damages assessed in the sum set forth in the above certification. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ;~~g. c '- - <," . VALERIE ROSENBLUTH PARK ATTORNEY J.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 TIlAT lHE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 530 HUMMEL AVE APT 4 LEMOYNE, P A 17043-1828 FIRST SELECT CORPORATION Plaintiff VS CHERYL A BLACK Defendant NO. 005608 CV NOTICE OFPRAECWE FOR ENTRY OF DEFAULT JUDGMENT TO: CHERYL A BLACK 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 DATE OF NOTICE: 9/7/00 EXHIBIT 4- IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIIIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIIIS NOTICE, A mDGMENT MAY BE ENTERED AGAINST YOU wrrnOUT A HEARING AND YOU MAY LOSE YOUR PROPERlY OR OlHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIIIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.e. BY: V ALERlE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '~"""""JW_~I ~" . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 EARK 4AW 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: 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS CHERYL A BLACK NO. 005608 CV Defendant VERIFICATION Of NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS VALERIE ROSENBLUTH PARK, Esquire, being duly sworn according to law, deposes and says that she will make this affidavit on behalf of the within Plaintiff, being authorized to do so, and that she believes and therefore avers, that CHERYL A BLACK, Defendant is over 21 years of age; that his/her place of residence/business is located at 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 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 amendme s. PARK LAW ASSOCIATES, P. BY: Valerie osenbluth Park Attorney for Plaintiff no ~ - ~" ~ . . -r . 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: 530 HUMMEL AVE APT 4 LEMOYNE, PA 17043-1828 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION plaintiff VS CHERYL A BLACK NO. 005608 CV Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: [X] Judgment by Default [ ] Money Judgment [ ] Judgment in Replevin [ ] Judgment in Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on Judgment Note [ ] Judgment on Writ of Revival [ ] Praecipe to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. 1<,;/ S/Dli PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE. PROT~:dY': ~ ~ ;'( ~ L/J). ~ FAIR DEBT COLLECTION PRACTICES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT ~ "" "Ii!r -" ~~, n_ ,,- ','.,' , . '"~,' ~~~" u, " _ _, u"- _ 'oh"'""~~~'~ ,",'k',' ,. ,~ . , .. ~ /C) ~ -Iq. 0 0 ~', c: = '~~.J -P Z "1; Ii::. ;:g n~ 0 --,~ , n D Z:L,'..; ,-I rr (Y ~~' I .rr ('\ ...... { .' ":+c-: () ~ ":~ \;~ ~ )>0 :\~ ~ ..... Z" ~;~~ ~ ~-(' ~ )>C W gi'fl - Z Z --< 't ::2 ,-::;> -- (;:> ::.0 -< ,<,"_'-o<~1lIIIJl'fIl ~_ ."",_., -,-,"',-'-, ~"',,','" ,~il!Im:~!I1'iI41~m,~;;.. i.,~I~,~ ,,~.,,:J'!1_....,.ll-]'lf" -- -~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION ORIGINAl: FORD MOTOR CREDIT COMPANY OIt/t!7N~t. vs. NUMBER: 2000-05775 GREGORY KOVELESKI alkla GREGORY J. KOVELESKI and WENDY L. KOVELESKI PRAECIPE FOR DEF AUL T JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against the Defendant(s) Gregory Koveleski alkla Gregory J. Koveleski and Wendy L. Koveleski for failure to answer Plaintiffs Complaint, endorsed with twenty (20) day notice to plead, served upon Defimdant(s) on August 25, 2000 and assess damages as follows: Unpaid Balance $ 1,922.26 Plus Interest 86.50 Late Charges .00 Plus Attorney's Fees .00 Less Credits, if any .00 TOTAL DUE $ 2,008.76 Pursuant to PaRC.P. 237.1, I hereby certify that notice to file this Praecipe was mailed to the above named Defendant(s) and the Attorney of Record (if applicable) on September 20, 2000 ARTHUR LASlllN,:ESQUIRE #23425 Attorney For Plaintiff HA YT, HA YT & LANDAU 400 Market Street 6th Floor Philadelphia, Pennsy;lvania 19106 (215) 928-1400 and copy/copies of same is/are attached hereto i"'IIl1i""~,1-~I"""~- ^., ~~ ~O,~, """" , , COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE , FORD MOTOR CREDIT COMPANY vs. GREGORY KOVELESKI a/k/a GREGORY J. KOVELESKI and WENDY L. KOVELESKI STATE OF PENNSYLVANIA SS COUNTY OF ]l>HILl\,p~u.'HIA..' . Arthur Lashin.' , being duly sworn according to Law, deposes .and says :thau:he represents the Plaintiff in the above entitled case; that he is authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant(s) is (are) 18+ years of age; the address of Defendant(s) is 157 Cedar Lane Carlisle, Pennsylvania 17013 Occupation of Defendant(s) is unknown; and the Defendant (s), is (are) not in the Military Service of the United States, nor any State or Territory thereof or its Allies as defined in the Soldiers' and the Sailors' civil Relief Act of 1940 and' amendments thereto. HAYT, HAYT LANDAU ATTORNEY FOR PLAINTIFF Prothonotary Sworn to and subscribed before me this 2nd day of October 20 00 . '",", rk- Notary My commissio~..~:i:res,- --"'-, ,\ ' ____---.- \'.1010\'\'';''\ S~ot8.ry publiC out811,' . County s....ari Deal'^:o philadelphIa e 27,2.002 \ I d@\P\"\l8.., . eS JU\1 . ?h\\a {fIiSsion E.i?\i , , Notaries W1'! corn . .l\SSOclat\On 0 ~en(\s'J\va(\)a tAembN, , 'r=' ,__ ,c" - ~~. .. HAYT, HAYT & LANDAU BY' ID~N,.M~SmN, ESQUIRE SIXTH FLOOR 23425 400 MARKET STREET PHILADELPHIA. PA 19106-2509 (215) 928-1400 ATTORNEY FOR PLAINTIFF DATE: SEPTEMBER 20, 2000 FORD l'IOrOR CREDIT CO}:IJ'Am . One A,me;d.can Rqad Dearb.orn, ~ichigan 48122 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs, TERM. GREGORY KOVELESKI a/k/ a GREGORY J. KOVELESIU 157 Ceda;r Lane Carlisle, Pennsylvania 17013 No. 2000-05775 NOTICE OF INTENTION TO TAKE DEFAULT PURSUANT TO PA.R.C.P. 237.1 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You' should take this notice to a lawyer at once. If you do not have a. lawyer or cannot afford one, golo or telephone the following office to fmd out where you can get legal help: Court Administrator Cumberland County Courthouse Carlise, PA 17013 (717) 240-6200 ARTHUR LASHIN, ESQUIRE; #23425 -"'''''W"""",,,,,'o/l. ,"'=]" ~,",~? ~,~ ~,~ ,~ ,~~"; ~, HAYT, HAYT & LANDAU BY' ID~N~SHIN, ESQUIRE SIXTH FLOOR 23425 400 MARKET STREET PHILADELPHIA, PA 19106,2509 (215) 928,1400 AnORNEY FOR PLAINTIFF DATE: SEPTEMBER 20, 2000 FORD MOTOR CREDIT COMPANY One American Road Dearborn, Michigan 48122 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. TERM, WENDY L. KOVELESKI 157 Cedar Lane Carlisle, Pennsylvania 17013 No. 2000-05775 NOTICE OF INTENTION TO TAKE DEFAULT PURSUANT TO PA.R.CP. 237.1 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other import@t rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Court Administrator Cumberland County Courthouse CarIise, PA 17013 (717) 240-6200 ARTHUR LASHIN, ESQUIRE, #23425 :_~~ "'" <,. llOl ,~ ~ d". . "~,~ . ~. __~". 00. !I,l~'~l!!I!II ~ -{Q. t fJ ..0 ~ () C 0 ~ C c;: 8 ?" ,':::) - ...... -00::- ,-, 0- f! n-lr-, "'Kr! - ..0 2~::-;:-:' I 3 ...c -.. zr' (,,:: ~ I:) g,o, ..0 -"- QJ -l) ~~u '- - .~ -1 ~(-:, -'" r-- <(=0 t..:? ~ ):>c ~ .V ~,~'11'if\!r~~~_. -",_ _ ,,=,.,,]1,"'1 ""~, ''''~ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. CHERYL A. BLACK Defendant NO. 005608 CV PRAECIPE TO MARK JUDGMENT SATISFIED. SETTLED. DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark the above captioned matter satisfied upon payment of your costs. PARK LAW ASSOCIATES, P.C. BY'~ VAL RIE ROSENBLUTH PARK, ESQUIRE '""''''''W~'''-li - ,,' "..,.",~, =-,- -- . . II ji , i i ! -~ ~- . o!!l!!!!BlI_~_ ""~ .. () C ~' ~[~: Z;~..,- 9.:Jl~ r:::C~.: ~~>~: )>>=-,.: :;;; -l .< CJ ~ ~"{:J ::-~":1 <.0 J,:;'" .-.1 ~ """', _'" "~,'-'<> ,,",""'~ ,,~," J,.~...~.~""J."'1~~!f~i>~~jj,ll!lI!5L A...~, ~ ~l~ " ,~~