HomeMy WebLinkAbout00-05672
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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
PROVIDIAN NATIONAL BANK
Plaintiff
VB.
JOSEPH D RONEMUS
Defendant
NO.OO- .$"t.7, Ct~ll~~
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.
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THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
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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#:4638410001826414
CUMBERLAND COUNTY COURT OF COMMON PLEAS
.
PROVIDIAN NATIONAL BANK
295 MAIN STREET
TILTON, NH 03276
PLAINTIFF
VS
JOSEPH D RONEMUS
4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
DEFENDANT
NO. po. Sf., 7.2. ~ I..u.--
CIVIL !CTION
1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking
association organized and existing under and by virtue of the laws
of the United States of America. Plaintiff solicits and maintains
consumer credit accounts in Pennsylvania and is the owner of this
account, which is the subject matter of this action.
2. The Defendant, JOSEPH D RONEMUS, has a mailing address at 4100
CHESTNUT ST, CAMP HILL, PA 17011-4217.
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
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owned by the Plaintiff bearing account number 4638410001826414.
4. The Defendant requested an account, account number
4638410001826414, which is owned by the Plaintiff, and an Account
Agreement was sent to the Defendant. A copy of the Agreement is
attached hereto as Exhibit "An and made a part hereof.
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
$4,389.28 as of OS/22/2000, plus pre-judgment contractual interest
at the rate of 19.24% per annum, less payments made.
7. In accordance with the documentation attached as Exhibit "A,"
Plaintiff is entitled to reasonable attorney's fees, and Plaintiff
will incur attorney's fees in the amount of $877.86.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $4,389.28, plus pre-judgment interest
at the contractual rate of 19.24% per annum from OS/22/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $877.86, 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.
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11. By virtue of the circumstances surrounding the request for
funds made, the Defendant knowingly requested the funds at issue
and/or knowingly and voluntarily accepted the benefits bestowed.
12. It would be inequitable for this Court to allow the Defendant
to retain the benefits of the funds or to be unjustly enriched at
the expense of the Plaintiff or allow the Defendant to retain the
value of the funds at issue without repaying the Plaintiff the
value of same.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $4,389.28, plus pre-judgment interest
at the contractual rate of 19.24% per annum from OS/22/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $877.86, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
PARK LAW ASSOCIATES, P.C.
BY:
VALERI
SENBLUTH 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.
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J~~PROVIDIAN
~ Financial
Proviean National Sank VISA@ or l'vlasterCarco
February 7, 2000
Plea:e relJiew. this document and keep it with your other imj:lortantpapers. This Account Agreeme1'lt contains the ~erms wnlc.' t;cvem your Provtdicin National 'H ...
(the ~c~ou~t J., The Account allows you to make pu.rchases by us.log your VISA or l'vlasterCard ~rd (the .Card") where'Jer it is honored and to get cash advances from u~r o~asterCard Acc...~t
tinanoal tnstltution and From Automaled T eller ~Iad'llnes. Convemen.c; checks may also be provIded t~ y'ou as ~n aCCi!lol'!aJ"'~ay to use the Accounl In this Agreement. ~ny ot~er p:r~c,:atlr.~
each person for whom we ~aveopened a credit cac,dAccount. "We, our,. 'ours,. and,'us. mean Prov~ Nattonal Bank or Its assignees, as listed on yaurbillin stall!m~~ a,nd your me~n IoE
used only for personal, f.lmjJy, housahoJd, an~ :nantable purposas, and 110t fa~ any bU,smes~ a~ carT!l1!et'Cral pu~ase. ArT,! use cf this ACCOtu'lt sltaH COl'TS'tItlJte acc~tance of lh: ;:;cc~u~~ oil<!'I"
Agr~ent If the Account was opened as a jOint account, we may act on lhe instructions or either JOInt accounthelear, 'tau ar.d we agree as follows: sat IS
P;]ym~nts. You will receive a monthly statement showing yeur outstanding bala~c!, Payment on this ~ccount is requir~ in V,S. C~llars (c~ecks must be payable at a V.S, ofiice of the can!< the
cMeek IS drawn on) for at least the payment due as shown on your statement by lhe payment due date In accoreance 'Hlih payment loslructtons on your monthly statement The bad< of, '
statements shows lhe rules we ~now when we e~st payr;tents. Convenien~e c:,ee<s and other checks we issue to you may liot ce used to make payments on your Acco~nt or to ~ak~~~ymenl~
on any olher ~ccount you have With us or our affihate~. ! ne payment due will be: 2% of ~e ne~ balance shewn on your statement plus the amount of any past due paymenl, and may induce the
amount by w~lch the nf!N# balanc:e exceeds: your ~edit Irne. HcweoJer, Ihe payme,nt due will not ce.less ~a~ S:1~ (~ntess your r:e',., balance is less than 515, in which case the ~ayment Cue '}lllI ce
the amount or the ,neo~ balance}. If your ~cccunt IS past due or aboy.e tl:e credit !~e, ~e may reqUJre a hzgher mlrtlmum payment. cut we will netify you before doing so, If your payment is more t/'lal
th.e payment ~e,. It will ~e ~reat~ as a S1~gte payment and none or It '~III be appbe::l to future payments due, We may ac~ept late or partial paymerlts, or payments mar.-<ed "paid in full- or marked
With other restnttions, WIthOut Jo:smg our nght 10 collect aU amounts awing under !hIS Agreement.
If you hav~ made special payment arrangements with either First Union or Providan, you need to continue making the agreed upcn payments.
Firr.1nce Ch<Jrg~ E."'Ccept as dfesoibed in the Grace Period for Purchase Balance section or this Agreemenl ffnance chargss begin to accrue on a debit when it is induded in one of your Cady
balances and continue untillhat ~ce is reduced by a paym~t or ~edil YOlfl Account has the following balances: The Furchase ~alance :",hich consists of your existing, Purchase Balance
an~ nev ptJt'01ase5 you make 'NIUt your Card and fees far cettam optional SeMCeS; ane or mare CiJStam Cash ~oJa/'lCe- Palarrces which consISts of oalal1CeS,that 'ftJU transref' to your Aa:cwt
usIng balance ~fer checks and balances that we transfer for you; and ~he Cash .Advance ~a!a.!lce which consISts o.t all ether cash advances and cash advance transaction fees, Any paymenl
amount we receive th~t exceeds the finance ch~es and fees lh~ due Will ordnarily be appl~ ru'st to the 8alallce WIth the r~est Annual Percentage.,Rate (APR), until that Sa1ance is Z!l'O, and
then to the SaJance WIth the next lowest APR. until that 8alance IS zero, and !hen to arry remaining 8alance. We reserve the nght 10 apply payments differently without further notica
The Purchase, Custom Cash AOiance, and Cash Advance Balances ate redlJcad by payments as'of the date received, and by c:aCits as of the date posted. Purchases are induCed in your
Purchase Balance as of the dale maCe. Custom cash advances are incluCed in your Custom Cash Advance 6alance as Follows: funds e1ectrcnieally transmitted Ie other lenders to tsansfer
balances, as of the date transmitted; chec!<s to transfer balances, as of the date prasented to us, Other cash advances are induCed in your Cash AC'iance Salance as follows: C3sh advancas
irom other financial institutions and through Automated Tellers, as of the date made; cash advan~e checl<s maCe ::Iayable to you that are identiiied as cashier's checks and mailed to you at your
request, as of sS'Jen days after the date we print on the check; all otherchec.f.(s, as of the date presented to us. Other Cebits are included in ycur Purchase, Custom Cash Advance, or Cash
Advance Salance as of the date posted, Finance charges are added 10 your Purci'lase. Custom Cash Acvance, and Cash Aevanca Salances each day and are then posted on the last r3t of the
billing cyde. There is no grace period for CtJStom cash advances or other cash ac!vanC"...5.
To 'guya Iha daily ,nanea ,hag. for eac.i Iyp. of Salanc:o, we start with your preoIious day's Salanca, aCt! all dsbits and scbtract aU credits 10' ill. currant d:<i and multiply the net amount by the
applicable daily pericQc rate (s* following paragraphs). The ffnance charge for asch type of Salance is then aeced to and ir:cluced in that Cay's Balance. We treat a credit balar.ce for any CirJ as
zero, We determine the iolal iina.nce charges on balances for ttle billing cyde by aCCng together the finance charges for eac.1 iype of ealance for each Cay within the billing cyde. In calc.dating
tinance charges, an adjustment will be made for any transaction or payment that would have affected the tinance charge c:afct:ia~on in a prior I:illing t:lce /'lad it been posted in that clc:e. The
applicable daily periodic rate for "-Ich a transaction will be the rate in effeCt fer the current billing C'/de rather than the rate in e:fact on the date of the transaction.
Your slatement includes an average Caily balance for eadt ~JPe of Salance. You C3n multiply each average daily balance lr.at is :;ot zero by the number of da'lS in the billing cycle and the periodit:
rate to obtain subtotals, and then aCd the subtotals together to determine your tota! finance charges on balanc~ for the billing c'fcle.
The term -Prime Rate. as used in the Agreement means the highest prime rate published in the Wall Street Journal on the nrst business d3J of the previous calend:ar month, Any increase or
decrease in the Annual Perc-"fltage Rate 'NiII take effect on the tirst ~ of your billing C'Ide and may result in a slight increase cr c..~e in the amounl of your minimum payrnerlt.
The ANNUAL PERCENTAGE RATe (APR) for purchases will vary and may be adjusted each billing c'lde up to 14.8% aCcve Prime Rate, Using this formula, the APR for purchases in the
February 2000 billing cyde is 2:U%, corresponding to a daily penodc rate of O,C6384-%.
The ANNUAL PERCENTAGE RAre for cash advancss is 21.9%, corresj::ondr.g to a Cady pericoc rate ofO,aeCCG%.
If yeur payment ,is receive:i fate. Lv1ice in any 12.month period. o~ if you sig~ifican!ty !ncraasa'your lota! urrseC'Jred debt (as ;x:=!ai~ad in the CR.E~'T RE'/~E'~/. paragraph b~ow), the AP~ .for
purchases may Increase, out 'HIli not exceed 21.9%, ccrresponding to a Cally ~ef1odic rate or O.C6l.iCO%; and the A?R for cas,' aC'Jancss and C"'75,om casn aovances may Inc."eaSe, out <'4111 not
exceed 23.9%, corresponding to <:! eaily periodic rate ef 0.06548%,
Your Account may be eligible for lower APRs after you have met the terms of this Agrenent for three months, If you contact us, ',lie 'Nill review 'lour Account fa determine your elig:bilHy for lower
APRs,
CREDIT REVIEW: SPECIAL REQUIREMENT. You agree not to signiticantly ir.c:aase your totalunsectJred debt. Your APR can increase, (as explained 3bov~) bas~ on a significant i~cl'a3se in
unsecured Ceot, if your tclal unsecured C!bt and your total l/nSactU'ed debt with other lenCers ea.ch incraases 'cy mere u~n S:S,CCC and your annual household Income ~ less lhan four ~mes your
tolalunsecured debt.
Gr:1ca Period for Purcha:;a, B<1~nce. NeoN purchases posted to your Ac:ount in billing cydes with no prev~us balanc;, cr when the preoliollS balance ~Nas ,fully paid during the ~/?e, Co not ::egin
Ie incur a finance charge until the start of the ne..d ciUing: C'/de, You 'Hill p~ no ManC! c.1arge on such neN purchases if '1cu;ay the telat i'law balart? I~ full 'c;t/ the ?aym~t cue~:. sho'Nn en
'lout statement Ne>N.:putt.~ i:osted in atrf other billing ~/cle incur a finarlce charge, and there is n~.peri~d in wi'!ic., sue., pl.ll'C."lases m~ bet repaid WIthout Incumr.g a itn~~ce ....,...~e,
Fees. We will ~e -'IoU( Acc~unt sa for. each Card you ask us to replaca: egc.1 returned ?aYment; eac.~ c.~ec:~ you writ,!, ~n 'I?lfl, Ac..'"Ouot that we return ur,paicr, ~ step paym,~t ore;: cr ,
renewal of sudf an'er<ter, eac.".biUing c"jde 'Nilhin which your Account IS Celinc;uent (late charge); and e.ach bijling c"fce W!li1Jn '..,nren your balance e.x7~ yc.ur ~t lln~ (O,v~11r::lt 11' _t~ If
your Account is closed. If you r~est CCFies or biUing statements that were ~rst sent to you more than ltrre ",cn~s ~arher, '..e mttj charge a handing Fe! or S2 lor eaCi sue: CCp!. cas
aevanca fee of 3% (minimum 'S5). 'Nhich is a ANANCE' CHARGe, m~ be d'larged for eac.i cash advarlce lransactlcn maCa cn YCtJt Ac..'"Cunt "
D~f:lult. You will be in default iF i!n'J inmrmation you provided ,us prcv~ to, ~ i~plete o~ untrue; if y.~u ~ n~t ~J!lPly witt; ~ part of this Agreement, u~n your des~~ o=~~c~~
insolvency: If you Co not ~ other d...abts when cue; if a l:ankruptC'j pe~tion IS rtled by or 393:Inst. ~u; or If we Celle'Je In geed ~lh (hat you m~ I1(3C pay or ~t~ur ~ lJS~ 3J'r'1 rameel '..e m~1
Agreement. If you are in default 'He m~/, without further demand or nonce, c:artd your Cleat pl'Mleges, dec!are 'JOur AC=I.:~t calan~ Imm~tely CUe ana pa'~.....~, an . 'f'
have. In the event of ycut default, the outstanding ba!an<:e on 'taus Account s.1aII o:mtinue te accrue interest at ~"':e APR{s) cs~osed In the l"'lnance Charges ::lIaction of thIS A~rree:ment. ="/en I Net
have med ,uit to collect iIle amoUllt you owe. , . .
Credit Lint. Ycur c."!dt line is SJ:lecified from time to time in a separate nctK:S. ~OW' mcnthly statem~ts shcw"y~ur cred~ rw.,& an~':he amaunt ot ~ avaPat:lefi:;n~;:r ==~
Cecraase: your cr!Cit line Cased Oil in{csmancn 'Ne.cbtained from you or 'lQ1Jl c:eot l'el:Ord. Your avadal:le crec:t I~ ncrmaily ,~: o~cs ~et'Neen y~t credt , 'U de3t For cartain
rlnc!uCng transactions maCe or al.ltr.cri3f cut nat yet posted). It you send lJS a large paym~t c.,ed<, '~ may lu~ut 'IoU! av31~le ereCt while 'He ccnnliTt that th~ ch~' credt:
transac:tons, availaClecredit ~beress. You 'Nill net u:eyourAc:ount ror, and'Nemay raNSe to hencr, arrl transaction wnlc.''NcuJdcausaycu to ~C!!dyCl.:t.aval , ~
Promi.sa to ?~. You premise to oay us when due aU amounts borrcwed wi'fA..n you or someone else use your Ac:oUl'lt (ev'!!1 if u1e ameunt dt.acged ex~ ycw:,perml~~:~n), al~~~~asCriabl.a
transactiens and c.1arges to your Acc:ount, and coUecticn costs 'He incur incluCing, out not limited to, reasonable-attorney's fees arid court ccsts. (If you Win lne Stilt, we ,'Ill ~ Y - '.
attcmeo!,s fees and court costs.) , ("""_ .;'
. . . d~"'" " If a ~har.I"'''' :s made ~o th<a Financ!! ..""rges sac..cn or
Changes. After we provic& you an<J notice ~ ~ law, we may ch~ ~ pa~ or u1rs Agr!"..menl.~ . ~ or i~::ve .r~.;[r-=merllS, ,'7' '".. I I \ that induCe items :::csta-:: to 1fCIlt'
this lo,g~ment, ~l1e new ~nanca charge ca!C'.uation ...,iil 3pply to your entire ;1.~""Cunt calance from the errec::Ve cate or u.e c::ar.-;e, C:'anGe5 NTII ~ly. to l:a ar.cas
Acccunt cekre the 6!te of th~ c~r:ae and will a;:p!y whether or not yeu c:cntinue to use the Acccunt I~ ' ';.. (i)
. . U S ~'I ..., ,;, '1110 converted to V S cellars genera IY usmg ~IHer a I
Foreign Excb.JngeJCurrencj Conversion. If you use your Card for transactions tn a C'Jrr~t:f other than : . v..l ars" 'I;~ ~-ansac..ortS ~' ...e ..'. ' . 'entiy 'given for a transacticn, it
gcvemment.marrdated rate or (ii) wholesale market rate in effect the day beicr! the transactton IS Pl'CC2SSed. t~Cle.asad:y t.-'r~ p~t (,J~. ~~ ~edit I~'f~ard You agree to ~t the
willce decreased 'r:j the sama pett::entage. The C'"~enC'1 conversion rate used en the conversion date may offer rrcm the ~t~ in affect on ,e 'Iou US yc ,
c::nverted amount in U.S. Cellars. , ' " d f th month shown cn i~ 'He
Th~ C.:J.rd; C.ancell.atlon. You may cancel 'lour c.-eat privileges at ~I time 'of ~otiiyin9 us in 'Hritin9 anc.CesJo'l.ing tl:e, ~arc(s), UP:;~ '~h.e ~ard,,~x~,l~aon 1.t:1~~awo If y~ur Card is C311cailed cr
r~er'Je the ri!;ht nol to P-r.e'H ~he Card. W'3 may c:Ir.ce! the Card and your creet ;::l1'J,I~:!'S 3t any tlm~ after.:O cays r:C:ice !o you, cr NIl.C'IJ r.ctlce I I"ermll "'1 .
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nof r~e'Ned, ~n3nce charges and afilef fees '..,,11 c:onhnue to be assessed, payments '14111 conllnue to be CUe, anc all QU":cr aC::II:'::'Cie ;rCVISlcns or culS Agreemenf wIll remam In ~tf, I (t, u
terrmnate your Cl'edlt pnvIJet"'..;'~,~cr ,f ;~> cancel Of Co nor renew the Card. you may no longer write checks on yeur Ac.:.:ur.r ar.c 'fou snouic cesrroy any unused checks e h ~,a:.. yo
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Person<lllnfarm:Jtlon; Qocuments. You wdl provide us at least 10 days nOl!ca'rf you c.,ange your name, harne or malhnc 3c::':;SS teleonone numbers emoloyment Of '
request. you will provide us addi~onaJ finanoaf informatlon. We reserve lhe,nght to obtqJn InformatIon frem others:, inc:ue:r:g crcdl (eeOr11l19 agences and to provide your Income. Upon our
about your ACCQunl ~o others. We mav alsn share Inform"'tion wilh our affiliates, Howe-Ie( VOu may wnte to us at an'l tlm~ rnst'1't!Ctlna us not to shar~ credit informahon a~ress ~~,d rnfor~alIC"
do "pi fulfill your cbligabons uoeer thIS Agreemenl, a negalNe credit report that may fe/leel all your credIt may ce submJiiec iO the Cfeallepo/Tmg agencies. 'NI aur am lares yeu
Customer Service; Unauthorized Usa, l.os,s. or Theft of Checks or the C.ud. Each Card must be signed on receipt. You are resccnsible far safeguarding Ihe Card P 'Ii 1I
Number (-PIN-, which provides access 10 Automated Teller Machines) and any chedcs issued to you from theft, and keeping YOWPJN secarate from your Card If yOU':: etsonallcentl C3 0
your Card, PIN, ar '7"Y unused ch~ .~re lost or. stolen, or that there may be an unalJthoriz,ed t~sac~?n on you~ A~~cu.nt, you 'NIII prcm'ptly notify us by calling 1-S0Q.53J..r';1 o~~u~~~that
Immediately acllo IImllloss.., and hablhty, you wlil phone us even Ihough you may also nahly us ,n wnhng. Your liability Icr unauthorized use occurring befere yeu nOhly us is limited Ie ~O If eu
repartor 'Ne slJS~tunauth<JrizedliSe ofyourAa:ount, 'lie may suspendyaurcredit~l1Vijeges until we resolve the proclem to cur satisfaction or i:ssue you a ne'N Card If Q Ca d' . Y
~to!en, you will promplly destroy aU checks in your possession. To improve CtJStomer service and security, you agree thaI your calls m~ be monitored or recorded . Y ur r IS Jost ar
Merchant Relatio~ We will nat o~ liab~ if any person or Automated T e!ler Machitre refuses to .honor the Card or ~.( 'fow: C::hec!<s, or rai~ to ret~m the Card to ycu. We have no rasccnsiot!i~
for goads and SafVtceS purcl1ased w,th the Card or check.s exeept as reqUIred ~ law, (See Specal Rule below,) Certatn cenenls Illat are available With Ihe ACCIlunl are praviced by Ihird:party
veneors, We are not responsible for the quality, S\lailablhty, or results of any of the servrc~ you choose to use,
Stop Payment Orders. If 'leu wish !o s~op payment on ? check, you may send us a slop payment order by writing ~o us at cur a.~ess .For customer sef11ic~ listed on your statement You can
make a slop paym8l11 order orally by caUlng the numcer listed on your statement. When you make a stop payment oreer, you must prcvlCe yaur Account number and scecific infcrmation about tl'Te
check: the exact amount, Ihe date on the check, the name of the PartY to whom it was payable, the name or Ihe person who signed it. and the chec.'t n\Jmber, You wiU 'be asked to connrm art eral
step payment order in writing. We may disreoardvour oral oreer if we do not receive a sioned wntten connrma~on within rHO we9ks after the oral order or if we have not received an aCeqJate
desC!ipnon of the item so that payment can oe stepped. The order win not be eifactive if the chec.'<' was paid by us be;o(~ we had a reasarrable appattUl"lity to act Crt the oreer. We may wilhout
liability, disregard a written stop payment order six months after receipt unless it is renewed in writing:. '
Sbndard of Care. Because this Account inv?lves both credit card an~ ch~ transactions '~hich are processed ~a~ S~atale Il3ccna} syst~s b~f~e jhe transactions are cansoliCaled by us:
and because not wary check and Card sflp WID be sent to us, transactions In yaur Account ~IU be processed merJ'1arm:ally 'Nrthcut our necassanly revIewIng e'lery item. Our precessing system WII
call o~ att~tian 10 certain i~s which w: wiD ~ine. We will ex3f!1ine aU trans:icaons when 1jQU report that your C~ or ch~<S have.bee~ lost or,sto~en. We do not inlerld otCinarily to
examine aft (terns, and we will oot be rregligent (fwe do rrot do so. Tins rule establishes t/'fe standard of oranasy care 'Nruc1'l we In geed faith WIll exerCISe In administering your Account. Because
of OUf limi~ review, ~ beause netner your cancelled check3: nor Card transacti~n slips wiD be returned to yo~ with t~e monthly statement, yeti should be careful to enter aU checks in your
checlc: regISter crotherNlSe keep a record of them. You snoutd also save your credit card cash advance anctpurc.i3Se slips. Ycu acre-! ~o c::hec!t 'lour rnonthlv statement! aa'&nst 'Jour record and
to nOON us immediate!v of anv unauthorized transactions or errors
W-aiver of Cet't1in Rights. We may delay or waNe enforcement of arty proviSion at this Agreement without losing our right to enforce it or any other ptlJVision later. You waive: the right to
presentment, demand, protest, or notice of dishonor. any applicable statute of ITmitatiol1S; and any right you may have to reQ.lire us to pl'OCl!ed agairTst anyone bercre 'He fife suit agaiMt you.
Applicable Law; SoM:tubility; As:;ignment. No matter where you liVe, . this Agreement' and your Account are governed 0.1 feCe!allaw and by New Hampshire law. This Agre.'efI1ent is annal
expression of tl'Ie.agreement aet'Neel1 you and us attd may not 1M contradcted ~ eW:ertC! or any alleged oral ~ent If any prcvisicn of this Agreement is heid to be invalid or unenfo~able,
you and we wijl consider that pfOl.'ision modified to conf.crm to .appl~le ~, and the (est at the pl'CNislOOS in the A9!:eernen~ ~i11 sull c~ 8flrcrc~le, ftt aryy time after we detenn.ine in good faith
that arrj proposed or enacted legiSlation, regulatory action, or Judicial decisIon has renCefed or rrra!f reneer arty matenai provISIons of ~'1S Agreement Invalid or wtetlforT:eable, or ImpQse any
increased tax, reporting requirement, or other buraen in connection with any such provision Qr its enforcement, we may, after at least 30 Cays notice to you, orwilhout nolice ifpermitted~ Jaw,
cancel the Card arld your Creet privileges. We may transfer or assign our right to aU or seme of your payments. If state taw reqJiras that you receive nones or such an event t-o protect the
purchaser Of assignee, we may give you such nolice by liIing a financing slatement with the slale's Secrelary 01 Slale,
Notic~ Other notic!s to you shaU be ~~ective ,>!hen deposite:1 in the: mail aCCressed to you at the ~~ shown on ~u~ ~crCs:, unless a longer notite period is,~fi~ in this ~~ent cr
by Jaw, whic, pericd shaIJ start upon mailing. Noace 10 us shall be mailed 10 our address for customer SeNlCa en your sracament (or oll'ler,aCdresses we may speclIY) and snaU be eiteclivewhen
we receive it. .
YOUR BlLUNG RIGHTS - KEEP THIS NOTtCS: FOR FUTURE USE. This notice contains important information ai::cut YOf$ rights and our responsibilities under th~ Fair Crect 8i1ling Act
Notify Us in Casa of EfTof3 or Questfon.s About Your Bill. If you think your bill is wrong or if you need more informancn about atrf transaction on your bill, write us on a separate sheet, at the
adaas listed in the Billing Rights Summary on your bill. Write to us ~ soon as possible. ~e must hear fr~m YO.u!'tO l~tQ! than eo Cays after we sent you ~e first bill on which the error or prcblef1
appeared. You can telephone us, but doing so will not preserve: your ngh~. In your I.atter, gIVe us the fallOWing In~or:mati00: - Your,name ~d Accaunt numcer. - The dollar amount of the
suspected error, - Oescnbe the el'I'or and explain, if you C3n Wfi'1 you belle-Ie there IS an error, lfyolJ need more Inrorrnatlcn, eescnbe Ihe Item 'Iou are not sure about.
Your Rights tlnd Our Re3pon.sjbilid~ After We R~ejve YO'fT Written Notic~ We mus~ acknowlec:ge your Jelter~lm.ir: 3~ days, unless we have CQ~ted the :rror by then., Within ~ Cays,
'He must either correl:t the error or explain 'N~ we belle'le the bdl was correct. After we recetve your letter, we cannot ~rl ~o c::II~~ -any amount you questicn, or report you ~ eehnC;U8l1t. He C3fl
continoe 10 bill YOU for the amount you ques~on, including fin~nca ~~, and we, can ap~ly any unpaid am~unt against 'Jour c;~t line, You Co not have to pay- atrf questlafled amount whde we
are investigating, but yeu are still obligated to ~ the parts or your bdl that are not In question,
If we find that we made a mistake on your biR, you will not have to p~ any finance charge related to any questioned amount. If we Cidn't make a mistake, you may h~: to ~ nnanc.:!,charges.
and you will have to make up the missed payments on the questioned ~ount. In eith.ercase, wewill.s~ndyau a statem~n: oi ihe~m~untyou ewe ,and the date that,lt IS .due. ((you !Cui to pax tnE
amount we think you owe, we may report you as delinquent. However, If our '!Xplanation cces not sabsry you ar.d you .....t1te to us WIthin 10 days tellll1g us that you sl1~ rerusa to pay, we m~t Iell
anyatle we r~ YOfJ Ie Ihat you question yeur bill. And. we must tel! you !he name of any~ we reported you.!o. We. must teJJ anyone we report you to that the matter has been settled belweer
us when it nl'lally is. If we ecn't foilQW these rules, we can't collect the first SSO of the questtaned amount. e"/en lr your bdl 'Has c:rrecl, ,. . .
Sped~ Rule!ot Cf~jt Card PU'~a.seA Jt you have a prcblem with the quality of the ,orcpert"l or ~eNicas that yeu pur~":asa? with o~, cr:at card and you have tned In good 131~ ~o ~~~t the
prcblem with th,e merehant you may not have to r;ay lhe remaining amount CUe on the gcces or Sef\irces. There are two llmlcatiens on thIS n~r. (a) you must tta:'e.~! t.,fiJ p~~ asa .. 1 ur
home state, or it nct within 'your home stat~, within 100 miles at your ClJtT!!tt mailing~: and (b) the purchase price must lwIe been more than s...~. rn~e Iinutaoons Co no "pply Ir we own
or operate tt1e merchant, or if we mailed you the aOiertisemenc for the Prcp-efttl Of Se"'ICCeS.
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VERIFICATION
I,
SUE CORRIEA
, declare that as of
June 13, 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.
XJw ~/>-!L~
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Designated Agent
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SHERIFF'S RETURN -,REGULAR
CASE NO: 2000-05672 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS
RONEMUS JOSEPH D
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
RONEMUS JOSEPH D
the
DEFENDANT
, at 0019:35 HOURS, on the 22nd day of August
, 2000
at 4100 CHESTNUT STREET
CAMP HILL, PA 17011-4217
by handing to
JOSEPH D. RONEMUS
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the ~ontents thereof.
Sheriff's Costs:
Docketing
Service
Aff idavi t
Surcharge
18.00
8.68
.00
10.00
.00
36.68
So ;;~~i
R. Thomas Kline
08/23/2000
PARK LAW ASSOCIATES
Sworn and Subscribed to before, By:
me this 'J!!= day of
4r.::.~ c:),v-vf) A. Ii .
~a~~
rothonotary .
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VALERIE ROSENBLUTH PARK
ATTORNEY LD. # 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: 295 MAIN STREET
TILTON, NH 03276
DEF: 4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
4638410001826414
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
plaintiff
VS
JOSEPH D RONEMUS
Defendant
NO.00-5672
PRAECIF'E 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:
$4,389.28
$877.86
$305.41
($0.00)
($0.00)
$5,572.55
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 ROSENBLUTH PARK,ESQUIRE
Attorney for the Plaintiff
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AND NOW, O&:J. ,.2....)CA ,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.
J~(L~2~
I OTHONOTARY
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.
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VALERIE ROSENBLUTH PARK
ATIORNEYI.D. # 72094
PARK LAW ASSOCIATES,P.C,
25 EAST STATE STREET, P.O. BOX 1779
DOYLESTOWN, PA 18901
(215) 348-5200
ATIORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 295 MAIN STREET
TILTON, NH 03276
DEF: 4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JOSEPH D RONEMUS
Defendant
NO. 00-5672
NOTICEOFPRAEC~EFOR
ENTRY OF DEFAULT JUDGMENT
TO: JOSEPH D RONEMUS
4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
DATE OF NOTICE: 9/13/00
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITIIIN TEN (10) DAYS FROM
THE 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 LA W)'ER 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:
V ALERlE ROSENBLUTH PARK, ESQ.
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT 4
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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: 295 MAIN STREET
TILTON, NH 03276
DEF: 4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
plaintiff
VS
JOSEPH D RONEMUS
Defendant
NO. 00-5672
VERIFICATION Of NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS
VALERIE ROSENBLUTH PARK, Esquire, being duly sworn
according to law, deposes and says that she will make this
affidavit on behalf of the within Plaintiff, being authorized to
do so, and that she believes and therefore avers, that JOSEPH D
RONEMUS, Defendant is over 21 years of age; that his/her place of
residence/business is located at 4100 CHESTNUT ST CAMP HILL, PA
17011-4217 and that he/she is employed and that he/she is not in
the Military or Naval Service of the United States or its Allies
or otherwise within the provisions of the Soldiers and Sailors
Civil Relief Act of Congress of 1940 and its amendments.
PARK LAW ASSOCIATES, P.C.
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VALERIE ROSENBLUTH PARK
ATTORNEY IoD. # 72094
PARK LAW ASSOCIATES, PoCo
25 EAST STATE STREET
DOYLESTOWN, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 295 MAIN STREET
TILTON, NH 03276
DEF: 4100 CHESTNUT ST
CAMP HILL, PA 17011-4217
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JOSEPH D RONEMUS
Defendant
NO. 00-5672
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.Co at this telephone
number: (215) 348-5200.
PURSUANT TO THE FAIR DEBT COLLECTION P TICES 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.
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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
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JOSEPH D RONEMUS
Defendant
NO. 00-5672
r
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:
VALERIE ROSENBLUTH PARK, ESQUIRE
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