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Home My WebLink About00-08035 L.',., "- " -,..- ~ - ,~, ;,-" , .. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST SELECT INCORPORATED Plaintiff VS. STEPHEN J RESIG Defendant NO. 00 -ibM (!~(J~( '-r~ NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET. FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. _"",1- '" , J '-"'- '",',- .L ,- ~_ ,",~"~_':_;' ~, 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#:4168100009942473 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS STEPHEN J RESIG 209 GLENN RD CAMP HILL, PA 17011-1134 DEFENDANT NO. HJ. Y035 Cw t.e..-.. CIVIL ACTION 1. The Plaintiff, FIRST SELECT INCORPORATED, 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, STEPHEN J RESIG, has a mailing address at 209 GLENN RD, CAMP HILL, PA 17011-1134. 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 ~I ~ "" ,.-l ~, '-~ ~C i ' ~ ~J ~ . owned by the Plaintiff bearing account number 4168100009942473. 4. The Defendant requested an account, account number 4168100009942473, 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 ~AU 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 $6,874.04 as of 07/27/2000, plus pre-judgment contractual interest at the rate of 24.00% 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 $1,168.59. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT INCORPORATED, and against the Defendant in the amount of $6,874.04, plus pre-judgment interest at the contractual rate of 24.00% per annum from 07/27/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,168.59, 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. ~ -~"- '" . n. "0 "," ~ 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, FIRST SELECT INCORPORATED, and against the Defendant in the amount of $6,874.04, plus pre-judgment interest at the contractual rate of 24.00% per annum from 07/27/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,168.59, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J _, ..~ '>''''.:;t ,~--~ ':"0,," ,~,,~,h,;;;.',,~I;;,,::" -c':"-,:,. ."'0> ., '-"-;o.,,,;'c;,i,_',. .'~"T';"",~,- ~ ~ ~., 1 00-; ""-to I, VERIFICATION MONICA YANKOWSKI , declare that: I am a designated agent of FIRST SELECT INCORPORATED, 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. MONICA YANKOWSKI Date ~ ',', ,".... it''; .~<.;.~~ ~..til!JHlt,~~illiilli~11iiiIl-'~' .,~,-~-, -".--,:~~ c ~ " ". - e;",'" - -",'~~< ,_ _,~ "" ',;,<,,,'_^ _< _ ., " , ~~ , j ..,.. ~,... -lQ. 1 p ~ a '[ ~ 8 V) . IN 8 D 0 0 C) ....... 0 ~ co -11 tG W s-.N Z j ...... I I -oeD 0 f;~ f.Jd --0 rnrl": toe Z:X' ~ ~ ZC;: -"1 :11 F! (/)<c. -,,"" ~~;~ ~~ -<L_ r ~C; 5: '-,"'j, ;e(") ~;~B ~ ~C) cjm Pc -; Z co 55 =< r" -< ,. ,~ . , ~- - J '.",'> ",--, L -' '" '~ ,,",,'~. .U~~~'-i SHERIFF'S RETURN - REGULAR CASE NO: 2000-08035 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INCORPORATED VS RESIG STEPHEN J SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RESIG STEPHEN J the DEFENDANT , at 0017:11 HOURS, on the 29th day of November, 2000 at 209 GLENN ROAD CAMP HILL, PA l7011 by handing to STEPHEN RESIG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge l8.00 9.30 .00 lO.OO .00 37.30 So Answ...e:.; ~ v~ r..~m ~<"~t R. Thomas Kline 11/30/2000 PARK LAW ASSO "'" Sworn and Subscribed to before By: me this /St:.. day of ~ 2twiJ A.D. ~C~~ Prothonotary L!1l'--- ~- HL '- "-",-~. '1- ,. ;'..>'\i .., . ~ VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ArTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 209 GLENN RD CAMP HILL, PA 17011-1134 4168100009942473 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS STEPHEN J RESIG Defendant NO.00-8035CV PRAECIPiE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment infavor.of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: $6,874.04 $1,168.59 $718.67 ($0.00) ($0.00) $8,761.30 PLUS ADDITIONAL COSTS I CE~TIFY 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 AND NOW,.... )d.-U I r ,.,J("')(':)i ' Judgment is entered in favor of the Plaintiff and again t the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. ,~~,.... ,. :""".' .,. ,I ~I~ ~L . Lllli.'~ '. ."",- , '. ~d. 2 12~ P 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. ~ "-.~- ~ - " . '-> , _.1 '~r-'_, -' . " V ALERlE ROSENBLUTH PARK ATTORNEY LD. # 720<.)4 PARK LAW ASSOCIATES, P.C. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY.COURT OF COMMON PLEAS I HEREBY CERTIFY mAT TIIE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 209 GLENN RD CAMPIDLL,PA 17011-1134 FIRST SELECT INCORPORATED Plaintiff VS STEPHEN J RESIG Defendant NO. 00-8035CV NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: STEPHEN J RESIG 209 GLENNRD CAMP HILL, P A 17011-1134 DATE OF NOTICE: 12121/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIIE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIIER IMPORTANT RlGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE FOllOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. / .,y'/' -<,,--- BY: VALERIE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. !':XHIBIT A p';".... .. " 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 '" ' ',<-__,J , -, ~" Jt.,- I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 209 GLENN RD CAMP HILL, PA 17011-1134 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS STEPHEN J RESIG Defendant VERIFICATION COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS I NO. oo-,m"" Of NON-MILITARY SERVICE 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 STEPHEN J RESIG, Defendant is over 21 years of age; that hiS/her place of residence/business is located at 209 GLENN RD CAMP HILL, PA 17011- 1134 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 Soldier~and Sailors Civil Relief Act of Congress of 1940 ~and its ame. nd.mentso ---" PARK LA ASSOCIATES..... . BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 ~.""'..;..,~' J';Mr'ID;i!L~.il."'(;$,i4!:i~~ik;"I};'''~'A!,'il;rl;';;';;;;i;'''.ili;;i,~=llMifS~i8,'''.s,!!;~1~_~.~-T ~,_~ 0 ~, ,. <, ~, "q. t~ ~ g ~ '- - -v ) t [; F ~" t ~ K1 ~ ~~ji!i!i<lf' '_W-I!liMlIlMLmlittw (') -,~ rl"l\"l-' ~~ ~~.- r::ej "- ~'>c; ze )> c-= z =< . ''.1II -I .... " ~ l..,_, :;-.'n -a r:- ~:;:~ ;:CL<it; .~ 'c> "'0 :< .;:-- rfj ,~, "-,,- . _, _~ J. '. ,,', "'.... -" '<" ~, . ~ VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 209 GLENN RD CAMP HILL, PA 17011-1134 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT INCORPORATED Plaintiff VS STEPHEN J RESIG Defendant NO. 00-8035CV NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: [X] Judgment by Default [ ] Money Judgment [ ] Judgment in Replevin [ ] Judgment in Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on Judgment Note [ ] Judgment on Writ of Revival [ ] praecipe to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. DI /" IO( PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE. P FAIR DEBT COLLECTION P TICES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT -~,~"""'~ , .,-,,,~ " , ,~J "-"" ~. ~.,' " -, , '"""'TI.'ltnJf.~t, . .. 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 FIRST SELECT, INC Plaintiff STEPHEN J RESIG Defendant NO. 00-8035CV .~ 0 ~ "" I ~ :i! n rn;!J I ~.~. ~~ -v X:fJ i~ ::z: Q- - z~ ~ ~ N ~ m VS 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. LUTH PARK, ESQUIRE ~"_ ~'_O'~ . "" .;~ , - ~"''',;'':'; 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 FIRST SELECT, INC Plaintiff VS STEPHEN J RESIG Defendant NO. 00-8035CV PRAECIPE TO VACATE THE JUDGMENT TO THE PROTHONOTARY: Kindly Vacate the Judgment entered on 1/11/01 on the above captioned matter upon payment of your costs. PARK LAW ASSOCIATES P.C. BY: VAL IE ROSENBLUTH PARK, ESQUIRE ?~~~~!$"'IIt~~,!!~d!!;;<""~J\1>>i[Jl.~",""~J&!~M?.ff.ti,~'ii-lH'""."",-;;~~~'m'm~il1l-"'IjIit.~~~l'illi,ai!ll!ila&.illftW;j{oo&"" - ~ "' "" ~ <:::I ~ W (:J ~ ~ ~ ~ .~ rn~ t I ~o.f"1'1 D BZ 0 Ke -0 g:r; lJ i~ ::E: r~ ........ i'3 Z '6 ---.) ~ " ~ ro ~ g ~ Oil ~ W ~ L._ ? ::".. !II'