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HomeMy WebLinkAbout00-05609 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 INCORPORATED plaintiff VS. JAMES A ZEIGLER Defendant NO. ~ - .s?Cl Cu~l T~ 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. 4t:h COURT lllJ1Vl.LlU::ilK1UUK ~. (1. ~::uz....IksocI-::"'-.t.~ Flo6Y, G1i:;tmQgrl~El CouLLLy Cuu...LLL.,-,tl~(. CaYliale, I?" 1 70) 3 ~ .{'l.e.d-'( ~ ()1'7) 2413 621313 ~~&:( fJA-- l?o-J3 1/7- ,),L/9-J /I,.{. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ii,,~.'Pl!1 . nl - 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#:4168100008906081 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS JAMES A ZEIGLER 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 DEFENDANT NO. bil, S~O'1 ~7:l..u- CIVIL 1,..CTION 1. The Plaintiff, First Select, Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, JAMES A ZEIGLER, is an individual who resides at 1395 LETCHWORTH RD' CAMP HILL, PA 17011-7520. 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 4168100008906081. -,w;t,,_, --,~ " _e -,' ~ , ~ ~ e' 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 $5,714.61 as of OS/22/2000, 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 $1,142.92. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $5,714.61, plus pre-judgment interest at the contractual rate of 19.80% per annum from OS/22/2000 until the date of the judgment herein, plus reasonable attorney"s fees in the amount of $1,142.92, 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. \:R - , ~ , 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 $5,714.61, plus pre-judgment interest at the contractual rate of 19.80% per annum from OS/22/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,142.92, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY, ~. VALERIE OSENBLUTH 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.' " " -'" ,- "",- -' ,,~'" T ' ~,,' .... VERIFICATION I, SUE GORRIEA , declare that as of May 31, 2000: I am a designated agent of PROVIDIAN NATIONAL BANK, 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. ~.~ / Designated Agent I ;:,1 "'" ","'",,~,", ~, "-:^,',"j""~>~,)",:,,,",~,,,, 'co',," ,>", "-"" --',:--~-'".- p" . , 5040 JOHNSON DRIVE P.O. BOX 9104 PlEASANTON. CA 94566 888-964-4000 ~. ._" '. , :' :' F1RST SELECT CQRPORAT1QN ACCOUNT AGREEMENT Your DISCOVER account has been transferred to First Select Corporation. Your DISCOVER account was closed at. the tirn1:l of this transfer, and will therefore continue to be closed This Account Agreement con[ains the terms that govern your First Select account (the" Account"). In this Agreement, "you" and "your" mean each person who is liable for payment on the Account "We," "our," "OU1'3," and "us" mean First Select Corporation or its assignees. Because your Account has been transferred to us, you are now obligated to repay the Ac:::ount to us instead of DISCOVER. If the Account was opened as a joint account, we may act an the instructions ofany joint accountholder. Payments I Finance Charges. As long as you have a balance outstanding on your Account, fmanee charges are calculated as. follows: To figure the finance charges for each billing cycl~, ~e multiply the average daily balance on you.r ."'-.ccount by a dail~ periodi~ rate. The daily periodic rate we apply is your Account's Annual Percentage Rate dlVlded by 365. The Annual Percentage Rate wdl be calcul.:ued as disclosed m your most recent DISCOVER account terms (the "Original Terms"). If your 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 Rate to your entire outsUnding balance. We may accept late or partial payments, or payments marked "paid in full" or marked with other restrictiocs, 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 delinquent (late charge). The amount of the late charge will be as disclosed in your Original Terms onhe maximum late charge permitted by the law of your state of residence, whichever is lower. We will charge your Account a fee for each retumed payment check (returned check charge). The amount of the returned check charge will be as disclosed in your Original Terms, or the maximum returned check charge permitted by the law of your state of residence, whichever is lower. - To the extent provided in your Original Terms, 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 charg.: 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. Wi:. may delay or waive enforcement of my provision of this Agreement without losing our right to enforce it or any other provision later. Applicable Law; Severability; Assigmnent. 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 Terms. If your Original terms did not contain an applicable taw provision, then this Agreement and your Account are governed by federal law and the law of your state of residence. This Agreement is afinai 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 confonn 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 fitiancing statement with the state's Secretary of State. Credit Reporting. If you fail to fulfiU the terms of your credit obligation" a negative credit report reflecting on YOUT credit record may be submitted to a credit reporting agency. 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 THIS NOTICE FOR FliTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill [fyou aunk. your bill is wTong, or if you need more information about an entry on your bill, write 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 ftrst bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights_ In your 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. !fyou need more information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice We must acknowledge your tetter within 30 days, unless we have corrected the error by then. Wiiliin 90 days, we must either correct the error or explain whvwe believe the bill was correct. Mer we receive y~ur letter, we cannot try to collect or report you, as delinquent as to any amount you question, including finanC'e 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. Ifwe find that we made a mistake on your bill, you will not have to pa.y any finance charge related to any questioned amount Ifwe 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, we will send you a statement or the amount you owe and the date that it is due. If you fait to pay the amount we think you owe, we mav 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 t~n 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. Ifwe do not follow these rules, we cannot collect the first $50 of the questioned amount even if your bill was correct. Special Rule for Credit Card Purch:lSes If you have a problem with the quality of goods and services that you purchased with your orSCO'l/ER credit card and you have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining :J.mount due on the goods or services. There are two limitations to this right: (a) you must h:J.ve made the purchase in your hO,m7 st~te or, if not withi~ y?ur home state, with!n 100 miles of your curr~nt mailing ~ddress~ and (b) the purchase price must have been more than 550. These IimltatlOI1S do not apply If eIther we or DISCOvER own or operate the m~chant, or If we or DISCOVER mailed you the advertisement for the property or services. EXHIBIT ,. - b :;; j If Z586 l586 -~" - r- -~ .' " F". '. ',,-> " - ~ " ~_ '~"' u.,..,.,....". -, ~~~- "'~ ~"~ ". .;;""\-0'* 7 'W ~ '''-~" ,"",- , -~* n a 0 c: c) t ~ ;;: -n p ~ -Of", "" Q.f1' ~- --n j:l ~f:i Q ~ .~ 0 -;-;,Tf 8 (j) ~";, .f,:.-' -,='V <3 -<:< I",,),L. ..Q ~ D 0 ~CJ ~'O .,-~~>, " 0 ~C~ .-:0'" :;:=:- ~t, ~ I --0 :;S:~~ \ S>c: c..~) u ~ ~ Z :.:::-J =< :::> J> ~ Ul :n -< -i . ' ~,,~" ~'" ,"~ "'''''''''"."., ===="'011lllll1(,'E;f*ii1!1!l!!P!II~i'\\10~~t~Eml~""""",,,, ....'f'-'~ (m"~'~,~",,,,"., '''r' ,. , ," '-"-" -- , , ! ___J SHERIFF'S RETURN - REGULAR CASE NO: 2000-05609 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INCORPORATED VS ZEIGLER JAMES 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 ZEIGLER JAMES A the DEFENDANT , at 0018:42 HOURS, on the 17th day of Auqust , 2000 at 1395 LETCHWORTH ROAD CAMP HILL, PA 17011-7520 by handing to DAVID ZEIGLER (BROTHER) 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 18.00 8.06 .00 10.00 .00 36.06 So Answers: ~~ .,..~~! R. Thomas Kline; - 08/18/2000 PARK LAW ASSOC Sworn and Subscribed to before By: tt.- me this ~ - day of s:~ c2rn>n A.D. Qt. (] n", tiP;. , ~f'-'P P othonotary , ,<1Il. " I VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 4168100008906081 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS JAMES A ZEIGLER Defendant NO.00-5609CIV PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS $5,714.61 $1,142.92 $387.50 ($0.00) ($0.00) $7,245.03 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". TOTAL VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff I"fR,;' - ~ ., ,,?, AND NOW, c:;;J<;{ , '"'y d~ Judgment is entered in favor of the Plaintiff and aga'nst the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. /5/ !uA;!;" .P-X~ PROTHONOTARY //2 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. ~~-- ~ '-~ ~ ~_~ ~ _ _'_If!""C VALERIE ROSENBLUTH PARK ATTORNEY !.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: PLAINTIFF: 4460 ROSEWOOD PLEAS~ON,CA94588 DEF: 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 FIRST SELECT INCORPORATED Plaintiff VS JAMES A ZEIGLER Defendant i NO. 00-5609CIV NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: JAMES A ZEIGLER 1395 LETCHWORTH RD CAMPillLL,PA 17011-7520 IMPORTANT NOTICE DATE OF NOTICE: 9/7/00 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIIE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIIER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4" FLOOR CARLISLE, P A 17013 (717) 240-6200 PARK LAW ASSOCIATES,P.C. BY: 1(\ --- . ~RIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,-,"';1!,~,w. .~_.~ -, > - -" 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: 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS JAMES A ZEIGLER Defendant NO. 00-5609CIV 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 JAMES A ZEIGLER, Defendant is over 21 years of age; that his/her place of residence/business is located at 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 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 llors Civil Relief Act of Congress of 1940 an ' its amendm s. PARK LAW AS ATES, BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 'W"l1I' ,~ J;""""_' , . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1395 LETCHWORTH RD CAMP HILL, PA 17011-7520 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS JAMES A ZEIGLER Defendant NO. 00-5609CIV NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: [X] Judgment by Default [ ] Money Judgment [ ] Judgment in Replevin [ ] Judgment in Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on Judgment Note [ ] Judgment on Writ of Revival [ ] Praecipe to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE. PROTHON~ARY : I~l tuA -.e.~ /,e L- FAIR DEBT COLLECTION PRACTICES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT '-F"1ft ~,"' -~, .-<"' . "..1"!:i; 11 '. .e e ."".", . ,~, " ~ -. ~ ~ ~ \~ ~ " D , ~ 10 ~ 2 (.:? ",_.J ~ ~ ~ 0 ":1 ~ .-;; ,\,fl s" r ""- -C.crl '"'"' ~ mrn '-0 ; ~'\ ~~,; Z:;J; r--" zc;:::. 'i..J:J ~');'!:S ~'2-:' I.2.C) ..", ," .' ~9 ..-;~ i~f~\ ,-' yc'--' tf? 0' c:: :,::; ~ I'"" ::0 Iv 0< ~ ,~ ~ ,'-~"\-'"' . ~ ~B1~~~-- " ~'~~!I\"~,~~ , ~,-~,-", ~ e. 'T':=""r~~'-' "" ... VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT INCORPORATED CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. JAMES A. ZEIGLER Defendant NO. 00-5609CIV PRAECIPE TO STRIKE JUDGMENT TO THE PROTHONOTARY: Kindly strike the judgment entered on September 28, 2000 because the Defendant In the above-captioned matter filed a Petition of Bankruptcy on September 28, 2000 in the United States Bankruptcy Court for the Middle District of Pennsylvania case number 00-03937RJW. PARK LAW ASSOCIATES, P.C. BY: ~A___________ VAL IE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF I,,, ~. "c ,'. ',-.'c"':.-__;~,1?':"r"_' "',,..,,....,,,?,: " !d.."-,~ ",~,,,,",,,' ", ~;__'t_____=_'-C ".. .---- . li i I I I I '":."~,, ~ " -.~ .. t~ t;- ~ ~ ~ --....t . ~ ~ , .1.,. .", ~'" ". "."'''''~O''''M~,d ,,'"' ~. ~ ~ o o (") C ::,",. ~;I ~}~ ~~::: ;-- r J .~-'. ,'-" .-::: ~-...;;: .~> (~::i ".-,-~~ .,' ,; ~, =-~ ~C __ ." E ,..) :",) " c .