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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
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PROVIDIAN NATIONAL BANK
Plaintiff
VS.
LORETTA YOUNG
Defendant
No.oo-t:.635 (],u~(/~
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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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, PA 17013
(717) 249-3166
(800)990-9108
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#:4217391250505298
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
295 MAIN STREET
TILTON, NH 03276
PLAINTIFF
VS
LORETTA YOUNG
303 E MAIN ST
MECHANICSBURG, PA 17055-6516
DEFENDANT
NO. O-o_(,oSj~ ~ I~
CIVIL ACTION
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, LORETTA YOUNG, has a mailing address at 303 E
MAIN ST, MECHANICSBURG, PA 17055-6516.
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 4217391250505298.
4. The Defendant requested an account, account number
4217391250505298, 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 "A" 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
$7,821.40 as of 07/29/2000, plus pre-judgment contractual interest
at the rate of 21.90% 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 $1,329.00.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $7,821.40, plus pre-judgment interest
at the contractual rate of 21.90% per annum from 07/29/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $1,329.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
COUNT I - ALTERNATIVE
8. Plaintiff hereby incorporates paragraphs 1 through 7 above as
though set forth in full.
9. The Defendant received a monetary benefit, which was in fact
appreciated by the Defendant.
10. The Defendant accepted the benefits.
11. By virtue of the circumstances surrounding the request for
funds made, the Defendant knowingly requested the funds at issue
and/or knowingly and voluntarily accepted the benefits bestowed.
12. It would be inequitable for this Court to allow the Defendant
to retain the benefits of the funds or to be unjustly enriched at
the expense of the Plaintiff or allow the Defendant to retain the
value of the funds at issue without repaying the Plaintiff the
value of same.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $7,821.40, plus pre-judgment interest
at the contractual rate of 21.90% per annum from 07/29/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $1,329.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
PARK LAW ASSOCIATES, P.C.
BY, l/\ ~
VALE IE ROSENBLUTH PARK, EBQUIRE
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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VERIFICATION
HEATHER KOOREMAN
I, , declare that as of
June 19, 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.
Designated Agent
Executed at Alameda County,
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~PROVIDIAN
Financial
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Providian National Bank VISA@ or MasterC~H 1 BIT 4
May 5, 2000 E:A I
.
Plea;e review this document and keep it with your other important papers. This Account Agreement contains the terms which govern your Providian National Bank VISA or MasterCard Account
(the ~cC?un.l").. The Account allows you to make pu!chases by uS.lng your VISA or MasterCard card (the "Card") wherever it is honored and to get cash advances from us or any other participating
financial institution and from Automated Teller .Machlnes. Convemence checks may also be provided to you as an additional way to use the Account. In thIS Agreement, "you" and "your" mean
each person for whom we ~ave opened a credit car.d Account. "We,n "our," 'ours," and."us" mean Providian National Bank or its assignees, as listed on your billing statement. The Account may be
used only for personal, family, household, an~ ~harltable purposes, and not for any bUSiness or commercial purpose. Any use of this Account shall constitute acceptance of the terms of this
Agreement. If the Account was opened as a JOint account, we may act on the instructions of either joint accountholder. You and we agree as follows:
Paym~nts. You will receive a monthly statement showing your outstanding balance. Payment on this Account is required in U.s. dollars (checks must be payable at a U.S. office of the bank the
check IS drawn on) for at least the payment due as shown on your statement by the payment due date in accordance with payment instructions on your monthly statement The back of your
statements shows the rules we f~lIow when we p~st payments. Convenien~e checks and other checks we issue to you may not be used to make payments on your Account or to make payments
on any other ~ccount you have With us or our affillat~. !he payment due Will be: 2% of th.e new balance shown on your statement plus the amount of any past due payment, and may include the
amount by which the new balance exceeds your ~redlt line. However, the payl!1ent due Will not be less than $15 (unless your new balance is less than $15, in which case the payment due will be
the amount of the .ne~ balance). If your ~cc:ount IS past due or abov~ t~e credit li~e, we may require a higher minimum payment, but we will notify you before doing so. If your payment is more than
th.e payment d~e,.lt will ~e treate~ as a Sl~gle payment and none of It Y{III be applied to future payments due. We may accept late or partial paymenls, or payments marked ~paid in full" or marked
With other restnctlons, Without lOSing our nght to collect all amounts owing under this Agreement.
If you have made special payment arrangements with either First Union or Providian, you need to continue making the agreed upon payments.
Finance Charges. Except as described in the Grace Period for Purchase Balance section of this Agreement, finance charges begin to accrue on a debit when it is included in one of your daily
balances and continue until that ~alance is reduced by a payme~t or ~redit. Yo~r Account has the follOWing balances: The Purchase Balance, which consists of your existing Purchase Balance
an~ new purchases you make With your Card and fees for certain optional services; one or more Custom Cash Advance Balances, which consists of balances that you transfer to your Account
uSing balance transfer checks and balances that we transfer for you; and the Cash Advance Balance which consists of all other cash advances and cash advance transaction fees. Any payment
amount we receive th~t exceeds the finance charges and fees th~n due will ordinarily be appli~~ first to the Balance with the I~est Annual Percentage. Rate (AP~), until that Balance is zero, and
then to the Balance with the nextlowesl APR, until that Balance !S zero, and then to any remaining Balance. We reserve the nght to apply payments differently Without further notice.
The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date posted. Purchases are included in your
Purchase Balance as of the date made. Custom cash advances are included in your Custom Cash Advance Balance as follows: funds electronically transmitted to other lenders to transfer
balances, as of the date transmitted; checkS to transfer-balances, as of the date,presented to us. Other cash advances are included in your Cash Advance Balance as follows: cash advances
from other financial institutions and through A~tomated Tellers, as of the date made; cash adJance checks made payable t.o you l.hat are j~entified as cashier's checks and mailed to you at your
request, as of seven days after the date we pnnt on the check; all other checks, as of the date presented to us. other debits are Included In your Purchase, Custom Cash Advance or Cash
Advance Balance as of the date posted. Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last dIDj of the
billing cycle. There is no grace period for custom cash advances or other cash advances.
To figure the daily finance charge for each type of Balance, we start with your previous day's Balance, add all debits and subtract all credits for the current day and multiply the net amount by the
applicable daily periodic rate (see following paragraphs). The finance charge for each type of Balance is then added to and included in that day's Balance. We treat a credit balance for any day as
zero. We determine the total finance charges on balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle. In calculating
finance charges, an adjustment will be made for any transaction or payment that would have affected the finance charge calculation in a prior billing cycle had it been posted in that cycle. The
applicable daily periodic rate for such a transaction will be the rate in effect for the current billing cycle rather than the rate in effect on the date of the transaction.
Your statement includes an average daily balance for each Iype of Balance. You can multiply each average daily balance that is not zero by the number of days in the billing cycle and the periodic
rate to obtain subtotals, and then add the subtotals together to determine your total finance charges on balances for the billing cycle.
The term "Prime Rate" as used in the Agreement means the highest prime rate published in the Wall Street Journal on the first business day of the previous calendar month. Any increase or
decrease in the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight increase or decrease In the amount of your minimum payment.
The ANNUAL PERCENTAGE RATE (APR) for purchases will vary and may be adjusted each billing cycle up to 13,4% above Prime Rate, but will in no event be less thall 21,9%, Usin9 thIS
formula, the APR lor purchases ill the May 2000 billing cycle is 22-4%, corresponding to a dai~ periodic rate 010,06137%,
The ANNUAL PERCENTAGE RATE for cash advances is 21,9%, corresponding to a daily periodic rate of 0,06000%,
lfwe receive your Account payment late 2 or more times in any 6-month period since October 1, 1999, on each such occurrence we may increase the APR for purchases up to a maximum of
23.3% (corresponding to a daily periodic rate of 0.06384%), and increase the APR for cash advances and custom cash advances up to maximum of 23.9% (corresponding to a daily periodic rate of
0.06548%). If after you receive the higher rates your payments are received on time and you meet all other terms of this Agreement for 3 consecutive months, you may contact our Customer
Service department and, at your request, we will review your Account for a possible APR reduction.
If at this time the APRs in your Account have already increased because you did not meet the existing terms of your Account Agreement, your existing APRs will continue to apply. If you meet all
terms of this Agreement for 3 consecutive ri1o~ths and lOU contact our Customer Service. department, we will. revi~ your Account for. a p~ssible APR reduction. Starting July 2000, however, the
APRs described in the preceding paragraph wdl apply, If your Account payments are receIVed late 2 or more times In any 6-month penod smce October 1, 1999.
Grace Period for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, do not begin
to incur a finance charge until the start of the next billi~g. cycle. Y~u will pay no finance charge on ~uch new. pu~has~ if you pay the total new ba1anl?6 i~ full by the payment due date shown on
your statement. New purchases posted in any other billing cycle Incur a finance charge, and there IS no penod In which such purchases may be repaid Without Incurnng a finance charge.
Fees. We may charge your Account $0 for: ~~h C~rd you ask us to ~epla~e; each returned payment; each ~~eck you w~t~ on your Account that we return unpaid; ~.ch stop p.ay.ment order ~r
renewal of such an order; each billing cycle within ~hlch your Account IS delinquent (late charge); and each billing cycle w!thm which your balance ex~eeds your credit line (overilmlt fee), even If
your Account is closed. If you request copies of billing statements that were first sent to you more than three. months earlier, we may charge a handling fee of $? for e.ach such cOey'. If you request
that we make a one-time automatic payment from your personal checking account, we may charge your credit carel account a fee of $4.95 for each request. ThiS fee IS a FINANCE CHARGE, and
it will apply regardless of whether funds are available in your personal checking account to make the payment.
We may charge a transaction fee of 3% (mi~imum ~5), w~ich is a o~8:'time FINA~CE CHARGE, on the amount of each cash advance, including cash from financial institutions, and A TMs, wire
transfers, money orders, lottery tickets, casino gaming ChiPS, and SImilar transactions.
Default You will be in default: if any information yo~ provided us prov~ to.be incomplete o~ untrue; ify.ou do n~t co,:"ply with ~ny part of this Agreement; upon your death! ba.nkruptcy, or .
insolvency; if you do not pay other debts when due; If a bankruptcy pet~tlon IS filed by or agEl:lOst.y.ou; or If we believe In good faJth that ~ou may not payor perform your obligations under thiS
Agreement If you are in default we may without further demand or notice, cancel your credit prIVIleges, declare your Account balance Immediately due and payable, and use any remedy we may
have, In the event of your default, the outstanding balance on your Account shall continue to accrue interest at the APR(s) disclosed in the Finance Charges section of this Agreement, even if we
have filed suit to collect the amount you owe.
Credit Line. Your credit line is specified fri?m time to t!me in a separate notice. Xour monthly statem~nts show Y.9ur credit line an~ the amount of your availa~le .credit. We may increase or
decrease your credit line based on information we obtained from you or your credit records. Your available cred!t I~ normally .the dlffere~ce ~tween your credit line and yo~r Account balanc~
(including transactions made or authorized but not yet posted). If you send us a large payment check, we may limit you.r avall~ble credit while we confirm that the ch~k Will cl8'!-r. For certain
transactions, available credit may be less. You will not use your Account for, and we may refuse to honor, any transactIon which would cause you to exceed your available credit.
Promise to Pay. You promise to pay us when due al! amounts bOl!owe~ whe~ you or so~~ne else use your Account (~en if the amount charged exc~ds your 'permis~ion), all other
transactions and charges to your Account, 13nd collechon costs we Incur Including, but not limited to, reasonable attorney s fees and court costs. (If you wIn the SUit, we will pay your reasonable
attorney's fees and court costs.)
Changes. After we provide you any notice required by law, we may change any part of this Agreement an~ add or remove requirements. If a .change is made to the FI~ance ~harges section of
this Agreement the new finance charge calculation will apply to your entire Account balance from the effectIVe date of the change. Changes WIll apply to balances that Include Items oosted to ~
Account before'the date of the chanae, and will apply whether or not you continue to use the Account. .
Foreign Exchange/Currency Conversion. If you use ,Your Card tor transactions in a curr~ncy other than U:S. dollars, the transactions w~ll be convert~~ to U.S. dollars, Qeneral\y using ei1~er ~ (I)
government-mandated rate or (ii) wholesale market rate In effect the day before the transaction IS processed, mcreased by thr~ percent (3 Yo), If a credit IS subsequently gIVen for a transactton, It
will be decreased by the same percentage. The currency conversion rate used on the conversion date may differ from the rate In effect on the date you used your Card. You agree to accept the
converted amount in U.S. dollars.
(Continued on reverse) (5846-0698)
4428024501197533
1532
004 Z561
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Foreign Exchange/Currency Conversion. If you use your Card for transactions in a ~rrenq otRer than'U.S. dolla~, the transactions will be converted to u.s. dollars ~enerally using either a (i)
government-mandated rate or (ii) wholesale market rate in etf6ct the dayoefore the transaction" processed, increased by three percent (3%), If a credit is subsequently 'gwen for a transaction it
will be decreased ~y the same percentage. The currency conversion rate used on the conversion date may differ from the rate in effect on the date you used your Card. You agree 10 accept the
converted amount]n U.S. dollars.
The Card; C.ancellatlon. You may cancel your credit privileges at any time by notifying us in writing and destroying the Card(s). Upon the Card expiration at the end of the month shown on it we
reserve the nght not to renew the Card. We may canc.el the Card and your credit pnvileges at any time after 30 days notice to you, or without notice if permitted by law. If your Card is cancelled or
not r~fnewed, finance c~.rges and ?ther fees Will continue to be assessed, payments will continue to be due, and all other applicable provisions of this Agreement will remain in effect. If you
terminate your credit prIVileges, or If we cancel or do not renew the Card, you may no longer write checks on your Account, and you should destroy any unusecl checks we have issued to you.
Personallnfo~atlo~i Documents. You will provide us at least 10 days notice if you change your name, home or mailing address, telephone numbers, employment or incom~,. Opon v~j
request, you Will prOVide us additional financial info~mation. .We r~serve the. right to obtain information fr?m others, inclu~ng ~redit ~orting agencies, and to provide your address and information
about your Account to others. We mav also share Information With our affiliates. However vou mav wnte 10 us at anv time tnstructlnC us not to share credit Information with our affiliates If you
do not fulfill your obligations under this Agreement, a negative credit report that may refiect on your credit may be submitted to the credit reporting agencies.
Custome! Se~lce; Unaut.horized Use, Loss, or Theft of Chec~s or the Card. Eac~ Card must be signed on receipt. you are responsible for safeguarding the Card, your Personalldentificalion
Number ( PIN, which prOVides access to Automated T eUer Machines) and any checks "sued to you from theft, and keeping your PIN separate from your Card, If you discover or suspect that
your Card, PIN, or any unused checks are lost or stolen, or that there may be an unauthorized transaction on your Account, you will promptly notily us by calling 1-801).933-7221, So we can
ImmedIately act to limit losses. and liability, you will phone us even though you may .a1s~ ~otify us i~ writing. Your liability for unauthori~ed u~e occ~rring before you notify us is limited to $50. If you
report or we suspect unauthonzed use of your Account, we may suspend your credit pnvlleges until we resolve the problem to our satISfaction or Issue you a new Card. If your Card is lost or
stolen, you will promptly destroy all checks in your possession. To improve customer service and security, you agree that your calls may be monitored or recorded.
Merchant Relations. We will not be liable if any person or Automated Teller Machine refuses to honor the Carcl or accept your checks, 0( fails to return the Card to you. We have no responsibility
for goods and services purchased with the Card or checks except as required by law. (See Special Rule below.) Certain benefits that are available with the Account are provided by third-party
vendors. We are not responsible for the quality, availability, or results of any of the services you choose to use.
Stop Payment Orders. If you wish to stop payment on a check, you may send us a stop payment order by writing to us at our address for customer service listed on your statement. You can
make a stop payment:order orally by calling the number listed on your statement. When you make a stop payment order, you must provide your Account number and specific information about the
check: the exact amount, the date on the check, the name of the party to whom it was payable, the name of the person who signed it, and the check number. You will be asked to CQnfirm an oral
stop payment order in writing. We may disreoard vour oral order if we do not receive a sianed written confirmation within two weeks after the oral order, or if we have not received an adequate
description of the item so that payment can be stopped. The order will not be effective if the check was paid by us before we had a reasonable opportunity to act on the order. We may, Without
f1ability, disregard a written stop payment order six months after receipt unless it is renewed in writing.
Standard of Care. Because this Account involves both credit card and check transactions which are processed through separate national systems before the trans13ctions are consolidated by us,
and because not eNeflj check and Card slip. will be sent to us, transactions in your Account will be processed mechanically without our necessarily reviewing eNeflj item. Our processing system will
call our attention to certain items which we will examine. We will examine all transactions when you report that your Card or checks have been lost or stolen. We do not intend ordinarily to
examine all items, and we will not be negligent if we do not do so. This rule establishes the standard of ordinary care which w~ in good faith will exercise in administering your Account. Because
of our limited review, and because neither your cancelled checks nor Card transaction slips will be returned to you with the monthly statement, you should be careful to enter aU checks in your
check register or otherwise keep a record of them. You should also save your credit card cash advance and purchase slips. You aaree 10 check vour monthlv statements aasinst vour record and
to notify us immediatelv of anY unauthorized transactions or errors.
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 later. You waive: tlie right to
presentment, demand, protest, or notice of dishonor, any applicable statute of limitations; and any right you may have to require us to proceed against anyone before we file suit against you.
Applicable Law; Severabllltyj Assignment. No matter where you live, this Agreement and your Account are governed by federal law and by New Hampshire law. This Agreement is a final
expression of the agreement between you and us and may not be contradicted by evidence of any :all~ed 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. At any time after we determine in good faith
that any proposed or enacted legislation, regulatory action, or judicial decision has rendered or rTlay render any material provisions of this Agreement invalid or unenforceable, or impose any
increased tax, reporting requirement, or other burden in connection with any such.provision or its enforcement, we may, after at least 30 days notice to you, or without notice if permitted by law,
cancel the Card and your Credit privileges. We may transfer or assign our right to all or some of your payments. If state 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.
Notices. other notices to you shall be effective when deposited in the mail addressed to you at the address shown on our records, unless a longer notice period is. specified in this Agre~ment or
by law, which period shall start upon mailing. Notice to us shall be mailed to our address for customer service on your statement (or other addresses we may specify) and shall be effective when
we receive it.
YOUR BilLING RIGHTS _ KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act
N08fy Us I. Case of Errors or Qu.s80.s About Your Bf/f. If you think your bill is wrong or if you need more information about any transaction on your bill, write us on a separate sheet, at the
address listed in the Billing Rights Summary on your bill. 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 your letter, give us the following Information: - Your name and Account number. - The dollar amount of the
suspected error. - Oescnbe the error and explain, if you can Why you believe there is an error. If you need more information, describe the item you are not sure about.
If Y9U have authorized us to pay your credit card bill automatically from your checking account, you can stop the payment on any amount you think is wrong. To stop the payment, your letter must
reach us three business days before the automatic payment is scheduled to occur.
Your Rights and Our Responsibilities After We Recelv. Your Written N08ce. We must acknowledge your letter wrihin 30 days, unless we have corrected the enor by then" Wilhin 90 days,
we must either correct the error or explain why we believe the bill was correct. Aflerwe receive your le~er, we canno~ try to collect.a':'Y amount you questlQn, or report you ~s delinquent. W~can
continue to bill you for the amount you question, including finance charges, and we.can ap~1y any unpaid amount against your credit Ime. You do not have to pay any questioned amount while we
are investigating, but you are still obligated to pay the parts of your bill that are not In quesllon.
If we find that we made a mistake on your bill, you will hot haye to pay any finance charge related to any questioned amount. If we didn't make a mistake, you may ~v~ to pay finance .charges,
and you will have to make up the missed payments 9n the questioned ~ount. In eith.er case, we will .send you a statem~t of the ~m~unt you owe ~nd the date that. It ]s due. If you fall to pay Ihe
amount we think you owe, we may report you as delmquent. However, If our explanation does not satisfy you and you wnte to us Within 10 days telhng 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 any~ne 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 don't follow these rules, we can't collect the first $50 of the questioned amount, even If your bill was correct.
Special Rule for Credfl COld Purchas... If you have a problem with the quality of the property or services that you purchased with our credit ~ and you have tried in good faith to correct the
problem with the mercl1ant, you may not have to pay the remaining amount due on the goods or services. There are !'No limitations on thIS nght. (a) y_ou must haye. m~de the purchase!n your
home state, or if not within your home state, within 100. miles of your current mailing ac!<fress; and (b) the purchase pnce must have been more than $50. These IImltatrons do not apply If we own
or operate the merchant, or if we mailed you the adverllsement for the property or services.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06035 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS
YOUNG LORETTA
CPL. MICHEAL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
YOUNG LORETTA the
DEFENDANT , at 0019:05 HOURS, on the 11th day of September, 2000
at 303 EAST MAIN STREET
MECHANICSBURG, PA 17055
by handing to
BETTY BROWN (DAUGHTER)
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
6.20
.00
10.00
.00
34.20
So ?~~i
R. Thomas Kline
09/12/2000
PARK LAW ASSOCIATES
Sworn and Subscribed to before By:
me this IJ~ day of
_ 417M~.2kuiJ A. D.
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rothonotary I
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VALERIE ROSENBLUTH PARK, EBQURIE
Attorney 1.0. #72094
PARK LAW ABSOCIATES, P.C.
25 E. Btate Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
LORETTA YOUNG
Defendant
NO. 00-6035 CV
PRAECIPE TO SETTLE. DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above captioned matter settled, discontinued
and ended upon payment of your costs.
PARK LAW ASSOCIATES, P.C.
BY:
VALERIE ROSENBLUTH PARK, ESQUIRE
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