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Home My WebLink About00-06168 -- '---,- , ' ;, " _-__"- ..C,_, =__ ,;.,-;_c."___~' --';~ -- .'~ _"'__''''_''~:; . " , , VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State St~eet 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. HAROLD G RHEN Defendant NO. 00 - I..l (.]> CIUll'--~ 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) 240-6200 (800)990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. --,' ""_' -'._c N.d"_ -",'-:- -'_"0__", ->--'iil . 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#:4428471175508471 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS HAROLD G RHEN 1798 MOUNTAIN VIEW ROAD MIDDLETOWN, PA 17057 DEFENDANT NO. O-p _ ~/U' (};,;<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, HAROLD G RHEN, has a mailing address at 1798 MOUNTAIN VIEW ROAD, MIDDLETOWN, PA 17057. 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 . >.., --."'4"''; ..,,;- ."--..i--""";" "'"'-,;{,, /c-,;':>;-:\ ~C"il owned by the Plaintiff bearing account number 4428471175508471. 4. The Defendant requested an account, account number 4428471175508471, 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 $6,265.11 as of 07/28/2000, plus pre-judgment contractual interest at the rate of 13.76% 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 $1,065.07. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $6,265.11, plus pre-judgment interest at the contractual rate of 13.76% per annum from 07/28/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,065.07, 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. "';' ._~",.". ',' """"'-dJ:\..,' - '" .,' ;,;.::i_.:J.~'L'<;,,~',~i;:;~;6_'; "__",t,',, ("..-" ',.'jjj.j 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 $6,265.11, plus pre-judgment interest at the contractual rate of 13.76% per annum from 07/28/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,065.07, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. 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. ::',_,.u ,- .-,'-,'.,'-""' ., ~--'- ",-,;_~"_""_.' _, 0___<,__ _"'-""'""".". '~,. -,c,_ <~ , '" I, VERIFICATION HEATHER KOOREMAN , declare that as of July 3, 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, Designated Agent _.~"-'.J Providian NaliOnaIJ~n~.V~~o@ or MasterCamEXHIBlt * ~PROVIDIAN Financial Ple~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 (Ihe Accounl )', The Account allows you 10 make purchases by uSing your VISA or MasterCard card (the 'Card') wherever il is honored and 10 gel cash advances from us or any other participating finanClallnstitutlon and from Automated T eller ~achlnes. Convenience checks may also be provIded to you as an additional way to use the Account. In this A9reement "you" and "your" mean each person for whom we ~ave opened a credit ca~ Account. "We," "our," "ours, q and."us. mean Providian National Bank or its assignees, as listed on your billing stat~ment. The Account may be used only for personal, famIly, household, an~ ~antable purposes, and not for any bUSiness or commercial purpose. Any use of this Account shall constitute acceptance of the terms of this Agreement. If Ihe Account was opened as a JOint account, we may act on the instructions of either joint accountholder. You and we agree as follows: Payments. You will receive a monthly slatement showing your outslanding balance. Paymenlon this Account is required in U,S, dollars (checks musl be payable al a U,S, office ot Ihe bank Ihe 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 bal:k of your statements shows the rules we follow when we post payments. Convenience checks and other checks we issue 10 you may not be used to make payments on your Account or to make payments on any other accounl you have wilh us or our affil~tes. The paymenl due will be: 2% of the new balance shown on your slatement plus the amount of any past due payment, ana Inay include the amount by whIch the new balance exceeds your~redlt hne. However, the payme.nt due will not be. less ftIan $1~ (~nless your new balance.is les.s than $15, in which case the payment due will be the amount of the ,ne~ balance). If your ~ccount 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 Ihe payment due" It will be trealed as a Single payment and none of It Will be applied to fulure payments due. We may accept lale or partial payments, or payments marked 'paid in full' or marked With other restnctlons, Without lOSing our right 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 Purch~se 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 balance IS reduced by a payment or credit. Your 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 Custo~ Cash ~dvance Balances which consists of balances that you transfer to your Account usmg balance t~nsfer checks and balances that we transfer for you; and ~he Cash .Advance ~alance whIch consISts o! all other cash advances and cash advance trans.action fees. Any payment amount we receNe th~t exceeds the finance charges and fees th.en due will ordinanly be applied first to the Balance With the lowest Annual Percentage Rate (APR), until that Balarn:e is zero, and then to the Balance With the nexllowest APR, until that Balance IS zero, and then to any remaining Balance. We reserve the right 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 dat~ 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 10 transfer balances, as of the date presented to us. Other cash advances are included in your Cash Advance Balance as follows: caslh advances from Clther financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you thai are identified as cashier's checks and mailed liJ you at your requesl. as of seven days afler the date we print on the check: all other checks, as ot Ihe dale prasenled 10 us. Other debits are inc~ded 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 day of the billing cycle. There is no grace period for custom cash advances or other cash advances. To [1Q",e the daily ftnance charge for each type of Balance, we start with your previous day's Ba~nee, add all debits and SubtlaCt all credits for the cu.ent day and multiply the net alllO\ll\t by the applicable dally penodlc rale (see follOWing paragraphs). The ftnance charge for each type ot Balance is then added 10 and Inetuded In Ihat day's Ba~nce, Welreat a credit balancl! for any day as zero. We delerminelhelotal finance charges on balances for Ihe billing cycle by adding logether the ftnance charges for each type ot Balance for each day within Ihe billing cycle. In calCUlating finance charges, an adjustment will be made for any transaction or payment that would have affected the finance charge calculallon in a prior billing cycle had it been posted in that cycle. The applicable daily periodic rate for such a transection will be Ihe rate in effect for the current billing cycle rather lhan the rate in effect on lhe date of thelransaction. Your statement includes an average daily balance for each type of Balance. You can multiply each average d~jly balance that is not zero by the number of days in the billing cycle and the periodic rate to obtain subtotals, and then add Ihe 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 ir.lcrease or decre<lse 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) tor purchases will vary and may be adjusted each billing cycle up 10 13.4%,;bove Prime Rale, bul will in no evenl be less Ihan 21.9%. Usin9 Ihis formula, Ihe APR for purchasas in Ihe May 2000 billing cycle is 22.4%. corresponding 10 a daily pariodic rale of 0.06137%. The ANNUAL PERCENTAGE RATE tor cash advances is 21.9%. corresponding 10 a daily periodic rale of 0,06000%. If we receive your Account payment late 2 or more times in any 6-month period ~ince 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 dai~' periodic rate of O.065d8%}. 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 meel all terms of this Agreement for 3 consecutive months and :tou contact our Customer Service department, we will review your Account for.s possible APR reduction. Starting July 2000, however, the APRs described in the preceding paragraph will apply. If your Account payments are received Iale 2 or more limes in any 6-monlh period sinca 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 cyde, do not begin to incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due dElte shown on your statement. New purchases posted in any-other billing cycle incur a finance charge.. aDd there is no period in which such purchases may be repaid without incurring a finance charge. Fees. We may Charge your Ace.ount $0 for: ~a~h C~rd you ask us 10 ~epla~; each retumed payment; each ~~eck you w~~ on ~our Account that.we return unpaid; ea~h stop ~.ment order ~r renewal of such an order; each billing cycle Within which your Account IS delinquent (lale charge); and each billing cycle Within whIch your balance ex~ your credit line (overllmit 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 ~ach such coPY. If you request that we make a one-time automatIc payment from your personal checking a~count, we may charge your credit card 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% (minimum $5), which Is a one-time FINANCE 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 you provided us proves 10 be incompiete or unlrue: if you do nol comply with any pert of this Agreement; upon your dealh, bankruptcy, or , insolvency: if you do not pay other debts when due; ita bankruptcy pelmon is filed by or against.y.ou; or if we believe In good faith that ~ou may nol pay or perform your obligalions tinder IhlS Agreement. If you are in default we may, without further demand or notice, cancel you~ credit pnvlieges, declare your Accoun~ balan~ Immedl8tely due and payabl~, and u~e any remedy we ~ay 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 conect the amount you owe. Credit line. Your credit line is specified from time to time in a separate notice. Your monthly statem~nts show y,?ur credit line an~ the amount of your avai~Je.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 differe.nee ~etween your credit hne and y~r Accoul!t 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 cl~r. Iwor 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 Credl\. Promise to Pay. You promise to pay us when due all amounts borrowed when you or someone else use your Account (even if the amount charged exce~ds your 'permis~ion), all o'lher transactions and charges to your Account, and collection 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 altorney's fees and court costs.) Changes. After we provide you any notice required by law, we may change any pari of this Agreement and 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 liems casted to llQYL Account before'the date of the chanoe, and will apply whether or not you continl,le to use the Account. .. . Foreign ExchangefCurrency Conversion. If you use your Card for transactions in a cu~nq other than U:S. dollars, the transactions will be convert~ to U.S. dollars, genera~ uSing el\~er ~ (I) government-mandated rate or (iij wholesale market rate in effect the day before the transaction. IS processed, .Increased by thre~ percent (3%). If a credit IS subsequently gIven for cI transaction, 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 reve",e) (5a46-()6911) 442802450f197533 1532 004 Z561 "" .. - ~tMiili__"'''''",' F.rafgn Exch.nge/Currency ~.nve"'.n, If you use.your Card for transaction. in a ~u~ncy olher then U:S. dollOlS, the transactions will be CCIIVerted to u.s. doliaJ!, seneral~1 using either a (i) government-manrlated rate or (Iij wholesale market rate In effect the day before the transacuon ~ pro....ed, II1CIO!I.ed by three percent (3%). If. credit is Subsequently gIVen for a lransact~n it will be decreased by the same pen:entage. The currency col1\lOlS~n rate used on the conversion date may differ from the rale in effect on the date you used y.ur Card V ou .. to acceptlhe converted amount m U.S. dollars. . The Card; Cancellation. You may cancel your credit privileoes at any lime by notil'!ing us in writing and da$troying Ihe Cardls). Upon ~ Card ~iration at Ihe end of the month .hown on it we resOlV8 the nght not 10 ranew the Card. We may ca""ellhe eard and your cred'. pnvlleges at.any time affer 30 dayS notice to you, or without notice ifpermiUed by law. If your Canl i. cancelle;; or not renewed, finance ~rges and other fees will continue to b. assessed, payments will continu.to be dU., and all other applicable plOVll!ion. of this Ag.....enl will r.main in eftilCl. Ifyeu 100000inate your cred\I privileges, or if we cancel or do not renew the Card, you may no longer wnle checl<s on your Account, and you should da$lroy any unused checks we have i.llUed 10 you. P....nallnf.rm.tlon: D.cum~nts. You ~iII provide ~. at least 10 days notice if you ch~nge YO\U nam., home or mailing ~s, I~one numbers, employment or incom~. Upon u~1 reque$!, you Will provida us additional finanClallnfonnatlon. W. reserve the nght to obla," Information from others, includmg credit reporting agenCies and 10 provide your addresS and information about ~ur Acccunt ~ ol~ers. We m~ also share informati~n with ~ur affiliates However YOU may writ~ to us at a~ ti~e instnJctina us rIOt 10 ShaM credit Information with our a~ If you do not fulffll your obligations under thiS Ag,""meni. a negative credil report that may reflect on your credit may be su milled 10 lhe ClBdit reporting agencies. Cuatome! Se!"lcai Unaut!'ortz.d Us., Loss, or Theft of Checks .r the Card, Each Card must be signed on receipt. VOIJ ara respon,ible for .afeguarding the Card, your Persc'nalldentification Number I PIN. which provides access to Automated T ollar Machmes) and any checks ISSUed to you from th.ft. and keeping your PIN ,ap."",. Ie from your Card. If you discover or 'uspect that you< Card, PIN, or '!'IV unused che<;ks.~ 100\ orolOlan, or thetl..... mll'/ be an unaulhoriz.e<l t'"!"ocli!'n on you! ~, you will P.'ompttt notify us by ca\Iing 1-800-833.7221. ~i. we can Immediately act 10 IImltlesses and lIabilllY. you wtll phon. us even lhough you may a~o notll'y us In writing. Your liability for unauthOllZedus. occumng befora you notify us i.limitedlo $50 If you report orwe .u.pect unauthorized use olyour Account, we may .u,pend your credit priv11eges until we resolVe the problem to our satisfaction or issue you a new Card. If your Card i.lost or stolen, you will promptly des1roy all checks in your possession. To improve customer ..lVice and .ecurity, you agree thel your coJ~ may be monitored or recorded. Merchant Relatl.ns. W.win notbe liabl. if any pers.n .r Automated Teller Machin.lBfu.es t. honor the Card or accept your check., or lai~ to IBwm the Card 10 you. W. have no responsibility for goods and seNic.. purohased with the Card or checks except as required by law. (See Special Rul. below.) Certain banefits that are available with the Account are provided by third-party venClors. W. alB n.t responsibl. for the quality, avaiJabjlity, or results 01 any .1 the sONices you choos.to us., Stop Payment Ord.... If you wi.h 10 stop paym.nt on a check, you may .and us a .top payment order by writing to us at cur address Jor customer service li.ted on your .tatemenl. Vcu can mal<e . stop paymant'order orally by calling th. number listed on your .talemant. When you make a step payment .rder, you must previda your Account number and ,pacific infonnation abcut the checI<: the exact amOlJnt, the date on the check, the name .f the to whom it was payable, the name of the poISon who .~ned II, end the check number. You will be asked to confirm an oral sleppaymentorderinwriting. em' u . do . e' . . ., . ..0 orifwehav.nctreceivedllnade<Juale clescripticn of the item so thatpayment can be ,topped. Th. orderwill n.t . effective' check was paid us beforew. had a reasonable opportunity to act on Ih. order. We IlIay WlthCUt Iabffity, di'regard. written stop payment order.ix months aller receipt unless it is lBI1ewed in writing. ' Standard of Care. Because this Acccunt involves both credit card and check transactions which are processed through 'epanlte national systam. before the transactions are co~'olidaled by us and. beCause not every check and Card slip will be sent to us, tran,actions in your Account will be proces.ed mechanically withcut our necessaJily reviewing "'"ry ilem. Our prccOlJSing system will call our altention to certain IIams which we will examin.. We willexamin. all transaction. when you report thet your Card cr checks have been last or stolen. We do not i.ntend crdilierily to examine allllems, and w.Will not b. negligent if we do not do so. This lUl. establish.. the slandard.f ordinary care which Wjlln good faith willexercis. in administering your Acc;<mt. Becaus. of OIJr limited review, and because n.i1h.ryour cancelled checks nor Card transaction .lip. will be IBtumed 10 you with themonthiy ,tal.ment. you should b. carefulto anlar all ch..cks in your check register or otheMise keep a record of them. You'should also save your credit card cash advance and purchase slips. You sores 10 check your monthlY statements aaainst v'Our record and to notif'v us immediatelY of anY unauthorized transactions or errors Waiver of Cartaln Rights. We may deiay orweiv. .nforcement of any provis~n.f this Ag,""ment without lo.ing our righl to enforce il or any other provision Ieter. You waive: Ihll right 10 presentment, demand, prol..t, .r notica of dishonor, any applicable .tetute of limilat~ns; and any right you may hav.'o require us to proceed against anyone before we file .ull aglonst you. Appllcabl. Law; $evarabllllY; AssIgnment No matler where you liv., this Ag,""ment androur Account are governed by federal ~ and by New HampshilB law. This Agreem.nt i. a final expres~on.f lh. agreemenl between you and us and may nol be conlradicled by evidence oanyall!'ll"dorel agreement. If any provision of this A_t is held to be invafid or unenforceable, Y.u and w. will considar t~at proviSion modified to conform I. apprlCable law, and lhe rest of the provisIOnS in the Agre.ment will still be enforceabl.. At any time aflerwe determine in good faith !hat any proposed or. enacted legislation, regulatory a~tion, or judlclaJ:decision has IBI1d~iBd or. may IBnclar any material provision. of this Agreement invalid or u~anforceeb'.,. or Im!>,.e any Increased 1ax,Iep9Illngrequirement, .r otherburdan In connectl.n With al1\'. .uch prov~lOI1.rlts enfo. n:ement, w. may, sflarat leesl30 daYs noliea to you, orwllhout notice If pe"'"ltedby law, cancel the Card aiid your Credit priv~eg... We may l..,.,.fer or assign our Jighlto all or some of your paymanlo. If stale law requiIes that you reteive notice of such an avant to protect the purch..er or assignee. we may give you such notice by filing a financing statement wilh th. stat.'s Secretary of State. . N.Uces, Oth.r noticasto you shall be .ffecliva wh.n deposited in tha man addiessed to Y.U at the address .hown on our records, unlass a longer nolic. period is .pecified in this Agreement or by law, wh~ period .hell.tart upon mailing. Notic.to us shall b. mailed t. our addr... for customer 'ONic. on YOlJr slalement (or other addr..... w. may .pecify) and sliall be ,affeclive when we recOlV. it. . YOUR BILUNG RIGHTS _ KEEP THIS NonCE FOR FUTURE USE. This notic. contains Important information about your rights and our responsibiliti.. under the Fair Credit BIlling Acl. N.Ufy Us In Case.f Errors or Questlo.. Ab.ut V.ur BilL lIyou think your bill is wrong or if you need more inform.fion about any transaction on your bill, write u. en aseparate sheet, at the address listed in \he Billing Righlo Summary on your bill. Wrile \0 us as soon as possible. We mustllear from ~ no laler than &l days aft.. we sant you ths Iilst bill on which theanor or problem appeaiBd, You can telephone us, but doing so will ~ot preseN. your rights. In your leller, give us the following In!ormalicl): - Your name and Account number. - The dollar amouIlt of Ihe suspected error. _ Describe the error and explain, If you can why you believe there IS an error. II you need more Information, describe the item you are not sur. about. IfyOlJ have authorized us to pay your credit card bill automatically from your checking account, you can stop the payment on any amounlyou think is wrong. To step the payment, your I.ller mu.t reaCh us three business deys b.fore the automatic payment is .chedulSd to occur. V.ur Rights and Our Rasp.nalblllll.. After We Re.ce/ve Vour Written N.jfce. W. mus, acknowledge your IeUerwithin30.deys, unlass w. have co~ted the error by then.. Wjthin go days, we muat either correct the enor or explain why we hellave the bill was correct. Afler we rec.lVe your IeUer, we'canno! try to collect atrf amount you que.tion, or report you \'" delinquent. W. can continu.to bill y.u for the amount you question, including finance ch!'fQes, end we.can ap~1y any unpaid amount aga"sl your ClBdit llna. Y.u do not have to pay any qu..tioned alnount while w. are inwStigating, but you are still obligated to pay the paris of your bill thet are not In question. If we find lhet WEt mad. a mistake on your bill you will nol have to pay any finance chefgO related 10 any questioned amount Ifw. didn't make a mi.take, you may heveto pay fin.nce.charges, and you will have to make up the missed payments on lhe questioned amount In either cas., we will.s.nd you a ,talement of the ~~unt you _ .and the date that. it ~ due. II y<u tall to pay the amOlJnt we think you owe, we mll'/ report you as delinqUenl ~er. if our explanatiOn do.. not sattst" you and you wnle to u. within 10 deys lellmg us thel you .till relu..to pay, wa must teil anyone we report y.u to that YOlJ question your bin. And, we must tell you Ih. name of any<me w. reportedyOlJ.to. We must tell anyone w. report you to that the matler has been ,ettled between us when it finally is. If we don't follow these rules, w. can1 collect the first $50 of the questioned amount, aven if your bil w.. correct. Special Rule for Credit Card Purchues. Ify.u have a problem with the quality of the properly or ~ices that you puro/l~.ed with our. credit card and you hav.tried in good laiti, to correct the problem with the merohanl, you may nol havato pay the r.maimng amount due ~ the goods or SONICOS. There are !'NO limitations on llIi.lighl: (aIY~ must~. made 1he purot_ In your home stat., or if not within your h.me stale, within l00.mll.. of your currant mailing ac!dress; and (b) the purohas. plIc. must have been more than 100. Th..e IImltaliens do not apply If we own or operal.lhe m.rchant. or if we mailed you the acIi.rtts.ment for the property or SOMC". ~_'~'~~"'"l>~~,~f~~~i!!!l~'''IliiLil~'$~;fll',t"I~;0!;b,ip-''1llie-!:;l!:~~ "' ~~>, '".- "'~ " -'.'- =-"""'.........." ~~ :p ~ n ~~ CJ 8 8 ........ ..... ~ ~ ~ ~ ;.0 ~ 1- -.,,- o C :c ~~~: -7r" U5~::-': ../ .' t~C~; ;;;c; 5E~ 2: _-1 -< i ~' ! ;" I:; 1" I'; !;i CJ c~. (~ ~T! U) !-'1 --" I OJ .1_-" -i- --"), \:=\ " ~"~g " :~:-J ",--..., ;:~5~r~ ..-I EJ ;> ~o -< -C) _:c'. (..,) :,,11 C> , ~- " """,',,..~--, ~--' ~rik" 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 PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. HAROLD G. RHEN Defendant : NO. 00-6168 CIVIL TERM PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly discontinue the above captioned matter without prejudice upon payment of your costs. PARK LAW ASSOCIATES, P.C. ~. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ~ ,r" . ~ . rt!liilli-'("" iW"""'" ~~ "~. "".,,,y ,,--, , -><;"., '., - , "' '0,"';" ",",.;_,;; ';::'.'Ki'"~ . ..1. 0_ . ~--'""",- ," ..- ".w'"'' ._""""..-- ",,,," n.. .. -'''~'''''- - Ii II Ii II ]i II J,! 'H \~ [:1 ,~ 1 I I I ~ 0 0 0 "';") V) '_:;J .. "'Oca r"T1 :=;'1Fn mrn "'0 z~, i'V "'''!fn ta-~ t.n ;~6 rsC'i " " "'D ~1~ ~o -,.,~ pO '-' c :z; z U1 :<! :D -..J -< .~~ ;