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HomeMy WebLinkAbout01-0566 FXI 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 CUMBERLAND PROVIDIAN NATIONAL BANK Plaintiff vs. BRENDA L. DIMPSEY Defendant ESQUIRE COUNTY COURT OF COMMON PLEAS NO.dI- Job ??U?? ` 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. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX DOYLESTOWN, PA 18901 (215) 348-5200 "ATTORNEY FOR PLAINTIFF ACT#:4310390318106632 CUMBERLAND COUNTY PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 VS BRENDA L. DIMPSEY 82 LINDA DRIVE LOT 12 MECHANICSBURG, PA 17055-154 DEFENDI C, { - S(, (- l? 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, BRENDA L. DIMPSEY, has a mailing address at 82 LINDA DRIVE, LOT 12, MECHANICSBURG, PA 17055-1547. 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 owned by the Plaintiff bearing account number 4310390318106632. 4. The Defendant requested an account, account number 4310390318106632, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is 1779 COURT OF COMMON PLEAS PLAINT] THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 $4,132.62 as of 08/03/2000, plus pre-judgment contractual interest at the rate of 23.30% 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 $702.55. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $4,132.62, plus pre-judgment interest at the contractual rate of 23.30% per annum from 08/03/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $702.55, 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 $4,132.62, plus pre-judgment interest at the contractual rate of 23.30% per annum from 08/03/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $702.55, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: zz? V RIE 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION I, WAONICAYANKOWSKI , declare that: 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. Date Designated Ag t iPROVIDIAN CAPITAL CASH® F`'a°``°` EXHIBIT Account Agreement for Brenda L Bimpsey Your Capital Cash account (the "Account") is a reusable personal loan that allows you to access your account by writing checks. In this Agreement, "you" and "your" mean each person for whom we have opened a Capital Cash Account. "We," "our," "ours, and "us" mean First Deposit National Bank or its assignee. You may not he eligible for an Account if you or a member of your household already have a credit account with us, Providian National Bank, or Providian Credit Services, Inc. The Account may be used only for personal, family, household, and charitable purposes, and not for any business or commercial purpose. Any use of this Account shag constitute acceptance of the terms of this Agreement. You and we agree as follows: Special Requirement of the Account: Credit Review Program. In order to keep you Account in goad standing, you agree not to significantly increase the amount of your total debt on unsecured revolving accounts. We will review your Account and credit profile quarterlyp to evaluate the amount you owe relative to the amount of your then current income. (We consider an increase in debt of more than $2,000 to be significant, unless you have sufficient income.) If we determine that your Account is not in good standing, your Annual Percentage Hate may he increased. Cash Advances. The Account is available only with the initial loan amount ("cash advance). This initial loan amount may include payments that we have made to other lenders on your behalf in order to transfer your other balances to this Account checks mailed to you for the purpose of transferring your balances to this Account, and funds electronically tramenitted to other lenders to transfer balances. However, if you re lect the initial loan amount and have not used the Account we win close the Account and you will have no obligation. If you reject the initial loan amount but have used the Account, we will close the Account and demand fmmedfate full payment only of the balance and charges not related to the initial loan amount. You may request additional cash advances by calling the ton-free number listed an your monthly statements. Payments. You will receive a monthly statement showing your outstandfnp balance. You will pay us in U.S. dollars (checks muer ha payable at a U.S. office of the hank the check is drawn on) at least the payment due as shown on your statemeet by the payment due date in accordance with payment instructions an your month)9 statement. You may not usb your convenience checks to he peymeets an your Account or to make peyrranta on any other account ou A eye with us or our atti0atex The rrdnimum payment due will normally he: 2.0% of the new balance shown on yourstatemmt plus the 'mount of any peer due paYmeet plus the amount 6y wkich the new hakmce eaceeds your cmdit Ifne plus fees far certain optio yme0, wit out as n , ht o cc fac nal services. Hawevm, the payment due wN uat he kus. tAan $l5 pxdess lie to a it in it in YMEis M NT your gnaw balance is less then 575p, in which case the payment due will he thepapmount of rthpe g naw balance)..iff your pa ant is more than the pant due, (t will be treated ties a stn le payment and at it ants us. We SUA N MT MTEISeONLY THEaRE4UIRE0nPAYMENT?T PAYdgOWN YOU; oIN M in in ft 0, h I 11 is more OA FASTEp? YOU MAY PAY MORE ITHANoTNE MINIMUMt PAYMENT 11 ? OU and M Y SEND Eund XT AT A Fire OR Y no do 0 on fund Finance Charge. Finance charges begin to acerue on a debit when included in the daily balance ("Balance") and continue until the balance is reduced by a payment or credit. The Balance is reduced by payments as of the date received, end bV credits.lexcept far reversals of late end miseellaneeua charges) as of the data posted. Debits other then finance charges are included fn the Balance as at the dates they are pasted which are as follows: cash advance checks that are ideetified'as cashiefs checks thatwe mailed to you at your request, as of seven days after the date we print an the check; all other checks, as of the date presented to us; funits electronicalty transmmtted Is other lenders to transfer balances, as of the date transmitted. other debits Imicept for late, finance, and miscellaneous charges) are included in your Balance as of the date posted. Finance charges are added to your Belence each day and are then pasted an the lest day of the killing cycle. To figure the daily finance charge we" mart with yyour previous dog's Belence, add all debits end subtract all credits for the current day 'as explained in the paragraph above) end naltiply the net amount hp the dairy periodic be (see fallwing paragraph). The finance charge is then added to and included in that day's Balance. We treat a credit balance for any day as zero. Wa determine the total finance charges for tie hillmg cycle by adding together the finance charge far each day within the billing eycie. To determine the averagge deny balance shown on pour matemeet add each day's Balance (including daily finance charge) in the billing cycle and divfde by the number of daps in tM1e billion cycle. You can multiply this average daily balance by the number of days in the billing cycle and by the dally periodic rate to determine the total amount of your finance charges for the billing rycle. In calculating finance charges,. an adjustment w01 he made for any transacnon ar payment that would have affected the finance charge calculation in a prior billing cycle had it been posted fn that cycle. The balance amounts shown on your statement may differ from the Balances used in computingg finance charges, because the letter do not include any late or (rdmellaneous charges which are included in the balances shown on your statement. There is no periad within which credit exteetied may be repaid without incurring a finance charge. - The ANNUAL PERCENTAGE RATE( APR") is 23.30%, corresponding to a daily periodic rate of .06384%. If you do net comply with the terns of this Agreement your ANNUAL PERCENTAGE RATE (APR) will he 23.30%, corresponding to a daily periodic rate of .06384%. We reserve the right to change the Annual Percentage Rate calculations if you do not compy with the terms of this Agreement. Fees. We will chargge your Account up to $10 tar each bilnng cycle within which your Account balance exceeds your credit lini t lover limit fee) even if your Account is closed. We will charge your Account up to $29 for: esch returned payment check; each check you write an your Account that we refund unpaid; each stop payment order or renewal of such an order; each billing cyme within which your Account is delinquent Pate charge). If you request copies of billing statements that were first sent to you more then three months earlier, we may charge a handling fee of $200 for each copy. Default You will be in default: if you were not eligible for the Account at the time it was opened; if you fail to comply with any part of this Agreement; if any information you gave us proves to be incomplete or false; upon ppour death, bankruptcy, or insolvency; H you fail to pay other debts when due; if a hankmptcy petition is Mod by or against you; or If we believe In goad faith that you may not pay or perform your obligations under this Agreement. On pour default we may, without further demand or notice, cancel your credit privileges, declare ppour Account balance immediately due and payable, and invoke any remedy we may have. In the event of your default, the outstanding balance an your Account shag continue to accrue interest at the APRIs) disclosed in the Finance Charge section of this Agreement, even if we have sued you to confect the amount you owe. Credit Line. Your credit line is specified from time to time in a separate notice. We may increase or decrease your credit line based an information we obtain from you or your credit records. Your available credit is normally the (Utterance between your credit line and your Account balance (including transactions made or authorized but not yet posted). If you sand us a large payment check, we may limit your available credit while we confirm that the check will clear. For certain transactions, available credit may be less. You will not use your Account far, and we may refuse to honor, any transaction which would cause you to exceed your available credit. Promise to Pay. You prondse to pay us when due all amounts borrowed when you or someone else use your Account loved if the amount charged exceeds your permission), all other transactions and charges to your Account, and collection costs we incur including, but not Burned to, reasonable attorney's fees and court costs. (If you win the suit we will pay your reasonable attorney's fees and court casts.) Changes. We may change any part of this Agreement or add or remove requirements after notice as required by law. If we change the Finance Charges section of Its Agreement, the new finance charge calculation will apply to your whale Account balance from the effective date of the change, whether or not the balance includes items posted to your Account before the charms date and whether or not you continue to use the Account. Cancellation of Account At any time after at least 30 days notice to you, or without notice if permitted by law, we may cancel the Account and your credit privileges. If your Account is cancelled, finance charges and other fees will continue to be assessed, payments will continue to be due, and all other applicable provisions of this Agreement win remain in effect. You may cancel your credit grivfeges by notifying us in writing and paying your entire statement balance by the payment due date on the statement which includes your final checks, cash advances, charges, and fees. You will still e responst Is for paying any accrued finance charges. If your credit privileges are cancelled you may no longer write checks on your Account, and you should destroy any unused checks we have issued to you. Personal Information; Documents. You will give as at least 10 days notice if you change your name, home or mailing address, telephone numbers, employment or income. You will promptly give us information about al, financial affairs if we ask for ft. We may gat such information from others, including credit reporting agencies, and provide your address and information about your Account to others. We me e se share such information with our affiliates. However, oyou may, write to us at an time instructing us not to share credit information with our a f Elates. If you fail to fulfill any of racer may a su notte to cre it reporting agencies. your obligations un er t rs greemant, a negative cre rt report reflecting on your cre it Customer Service; Unauthorized Use, Lass, or Theft of Checks. You will safeguard all checks ismed to ypou from theft. If you discover or suspect that any unused checks are lost or stolen, or that there may he an unauthorized transaction on your Account you wig notify us promptly by telephoning 1.800 9649212. You will phone, even though you may notify us in writing, so we can act fast to limit losses and liability. If you report of we suspect unauthorized use of our Account, we may suspend your credit privileges until we resolve a problem to our satisfaction. To improve customer service and security, you agree that your calls may be monitored or recorded. Stop Payment Orders. If you wish to map payment on a check, you may send us a map payment order by writing to as at our address for customer service fisted an your hill. You can make a stop payment order orally by calving the number listed an your statement. When you make a mop 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 wham it was payable, the name of the person who signed it and the check number. You will he asked to confirm an oral stop payment order in writing. We may disregard our oral order ifwe do not receive a signed written confirmation within two weeks after the oral order or if you have not adequately described the hem so that payment can be stofiled by our computer. e order will not as structure i me check was pat y us aware we e a reasons a opportunity to act on the order. We may, without liability, disregard a written stop payment order six months after receipt unless ft is renewed in writing. 5851 0598 zs?s Standard of Care. Transactions in your Account will he processed mechanically without our recession! ty reviewing every item._11or processing system will call our attention to certain item which we will examine. We will examine all transactions when you re art that your checks have been last ar stolen. We do not intend ordinarily to examine all hems, and we well not he negligent if we do not do an. This rule establishes the standard of ordinary care which we in good faith will exercise on edministeriag your Account. Because of our limked review, and because your cancelled checks will not . be returned to pon with the monthly statement, you should be careful to enter all checks in your check register or otherwise keep a record of them You some to check your monthly statements against your retard and to nov us promptly of env unauthorized transactions or armrs. Waiver of Certain Rights. We may delay at waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. You waive: the 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 sue you. R pllca6le Lew, Severahility; Assignment. No matter where you Ove, this Agreement end your Account are governed by federal few and by New has law. The Agreemerit !s a final expreadon of the agreement between you and us end may not be wniradlcted by evidence of any alleged are" agreement. At any ume or we detemdne in good faith that any propose ar enacted legrslmion, regulatory action, or judicial decision has rendered or may render any material provision of this Agreement inve0d en uneniomeehle, or lmpoea any increased tax, re porting requirement or other burden in connection with any such provislan ar its onfarcemen1, we may, afar at least 30 days notice to you, or without nat!a0 if permitted by law, cancel the Card and your credit privileges and declare our Account balance lminedletely due and payable. If any provision of this Agre ement h heW to he inva0d a unenfaceahIs, you and wa wN considw that provider monfied to canimm to epp0ee6k law, and the rest of the provers 3 in the Agreement well still be enforceable, but we well have the right to cancel your Account and declare your balance immediately due, as provided in the preceding sentence. We may transfer or assign our right to all or some of your payments. If state law requires that you receive notice of each an event to protect the pure our or assignee, we meY give you such notice to filing a financing statement with the state s Secretary of State. Notices. Other notices to you shag he effective when dep?osited in the mad addressed to yen at the address shown on our records, unless a longer notice period is reified in this Agreerseent or by law, which period shall start upon malting. Notice to us shall he =!led to our address for customer service on your statement for other addresses we may specify) and droll he effective when we receive it. Your Billing Rights - Beep This Notice for Future Use This Police contains important information about your fights and our responsibilities under the Fair Credit Belling Act. - Notify Us In Case of Errors or Questions About Your Bill. If you think your hill is wrong, or if you need more information about an entry on your hill, write us, on a separate sheet at our address for customer service fisted on pour 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 an which the error or problem appeared. You can telephone us, but doing so will ootpreserve your fights. In your letter, give us the following: - your name and Account number • the dollar amount of the suspected error. ^ Describe the error and explain, it you can why you believe there is an error. It you need more information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must sit her correct the error or explain why we believe the bell was correct. After we receive your letter, we cannot tryry to collect any amount you question, or report you as dentgeent. We can continue to hill you for the amount you question, including finance charges. We can apply any unpaid amount against your era line. You do not have to pay any mentioned ned amount while we are investigating, but you are still oblgated to pay the pans of Vow hifl that are not in question. If we find that we made a mistake on your bell, you well not have to pay any finance charge related to any questioned amount If we didn't make a mistake, you may have to pay finance charges, and you well have to make up the interest payments on the questioned amount. In either case, we well send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount we think you awe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you unation your ton. And, we must tell Van the name of anyone we reported you to. We must tog anyone we report you to that the matter has hews smiled between us when it finally is. If we don't foqllow these rules, we can't collect the first 150 of the questioned amount, even if your bill was correct. ell, ?. 3 E ?? eu II - rY0Y1?..,17.tLWeldY?t -'?'..-J --- YltriW??WW?!Y'd `°??,? :?M?14NNWI?iV?=..OYWtkF?t ..r!plkxe EXHIBIT A L;?? Minimum Unpaid Balance Monthly Payment $},3(M) $90 $•},000 $80 $3,5(x) $70 $3.000 $60 $2,500 $50 $2,000 $40 $1,500 $30 $1.000 $20 $ 750 or less $15 XFS, I'd like to open a Capital Cash ammnt. Please send me a check. I agree to th•• Capital Cash Account Agreement (which will be mailal to toe with eery chuck) and to spay prindpal, interest, and interest thereon exmpt that 1 will hoer no ohligtuion if I mturn the check unused after miewing the ;Viiunt Agreement. This Invitiawn expires: May 2, 1994 i?t??mPraeeatkaPhmCOptlaua>)- ;z?, , 'tr(:i C1pWCarkaeobmtahtk'' aed4mioLwhhgr?FPt t>ptlml Ptetagloa Pdmdetttt &adaa?' i the Wife. YES (Inhlal Mete to mtolq. `?' .. .lkvial 4ivnty Wntther Brenda L. Dimpaey ll-lt y3a s3gt 41-225012 ??Plt -T _SLU3 8805 Carlisle Road (Ionic l'hune Wmk/.%o)nJ Phime ---NF Wellsville, PA 17365-9740053 Own Ilume ? Rent 518101 IC1A0 GY317 Annwl I fi l ctwki Inmme: $ .J? • V ?" - KGCM KFHR OCHS MCAD AEDD 12- Empkwmamt: -.: Retied . Sdt-8mploWd xhmphxad • /_ ._._.._.. _.-._-__. RmpA,wr',a \amr `^t? 1`* ?'1t/ 00, _ Sipan= ?jfy-. IP. ?Ie mun wium,?Am?InlJ camel (\SSt-ituns(vvablr) v J /I 01131 Reservation) 181-5449-1841-8 l.1 „ A rL_r?-c?r-Flcc OF T; _ , !„r;p:OTMY Q1 UA.N 26 Phi 3: 55 CUMBEPIU6D COUNTY PENNSYLVANIA IZ90. s-b qg(, I /2-W /v(,Pp SHERIFF'S RETURN - REGULAR CASE NO: 2001-00566 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS DIMPSEY BRENDA L 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 SEY BRENDA L the DEFENDANT , at 0005:27 HOURS, on the 6th day of February , 2001 at 82 LINDA DRIVE LOT 12 MECHANICSBURG, PA 17055-1547 by handing to KEN REISINGER 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 18.00 Service 5.58 Affidavit .00 Surcharge 10.00 .00 33.58 Sworn and Subscribed to before me this 102 `I day of -?3 o2aa / A. D. u ?? ") . ? Prothonotary So Answers: - R. Thomas Kline 02/07/2001 PARK LAW ASSOCIAT S/ / By : Deput?herif A s VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: C. PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 82 LINDA DRIVE MECHANICSBURG, PA 17055-1547 4310390318106632 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS BRENDA L. DIMPSEY Defendant E FOR JUDGMENT TO THE PROTHONOTARY; Please enter Judgment in favor of the Plaintiff the said Defendant for failure to plead or otherwise the Complaint and assess the damages as follows: AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL NO. 01-566 and against respond to $4,132.62 $702.55 $601.49 ($0.00) ($30.92) $5,405.74 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 "All 'rO EVALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW, &n cl a (? a06f , 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. i PROTHONOTARY 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. VALERIE ROSENBLUTH PARK I HEREBY CERTIFY THAT THE ATTORNEY I.D. # 72094 TRUE AND CORRECT ADDRESS IS: PARK LAW ASSOCIATES, P.C. PLAINTIFF: 295 MAIN STREET 25 EAST STATE STREET, P.O. BOX 1779 TILTON, NH 03276 DOYLESTOWN, PA 18901 DEF: 82 LINDA DRIVE (215) 348-5200 MECHANICSBURG, PA 17055-1547 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS BRENDA L. DIMPSEY Defendant NO. 01-566 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO:13RENDA L. DIMPSEY 82 LINDA DRIVE MECHANICSB.URG, PA 17055-1547 DATE OF NOTICE: 3/7/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIJOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, 4°h FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. BY: cc: VALERIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT 1 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: 82 LINDA DRIVE MECHANICSBURG, PA 17055-1547 COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS BRENDA L. DIMPSEY Defendant NO. 01-566 VERIFICATION O] COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS 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 BRENDA L. DIMPSEY, Defendant is over 21 years of age; that his/her place of residence/business is located at 82 LINDA DRIVE MECHANICSBURG, PA 17055-1547 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 lors Civil Relief Act of Congress of 19 0 and its amend S. PARK LAR,/ASSOCIATES, . . BY: `i Valerie Rosenbluth Par Attorney for Plaintiff €10 VALERIE ROSENBLUTH PARK ATTORNEY I.D. ## 72094 PARK LAW ASSOCIATES, P. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaintiff VS BRENDA L. DIMPSEY Defendant I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: C. PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 82 LINDA DRIVE MECHANICSBURG, PA 17055-1547 COUNTY COURT OF COMMON PLEAS NO. 01-566 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 [ ] Money Ju [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Praecipe by 3gmi in in on on on on on on to Default ant Replevin Possession Award of Arbitration Verdict Court Findings District Justice Transcripts Judgment Note Writ of Revival Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number:(215) 348-5200. PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT. ANY PURPOSE.. PR HONOTARY: FAIR DEBT COLLECTION P TILES ACT, IT IS THE FOLLOWING TO YOU. THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT i II ':'..i "Jr. IC ;l l 1?:'I?!UThF?Y Ui IIIA''.'26 Aii10:34 CUt, L! d COUNTY PENNSYU'JiiNIA Gkn=ll- f 913 ?, fZ,-14 I093a7 VALERIE ROSENBLUTH ANGST, ESQUIRE ATTORNEY ID#72094 ANGST & ANGST, P.C. P. 0. BOX 492 HARLEYSVILLE, PA 19438 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS BRENDA L. DIMPSEY Defendant NO. 01-566 PRAECIPE TO MARK JUDGMENT SATISFIED, SETTLED, DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark the above captioned matter satisfied upon payment of your costs. ANGST & ANGST, P.C. BY: [14 VALE IE R S BL H ANGST, ESQ. r) CD r? ;? rTl