HomeMy WebLinkAbout01-0852 FX
-
,
,
. "
'"_ " '> 1- -,
. .
'0 0
J~ _ ~_ ,
~_f~-
,
-
"
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, INC.
Plaintiff
VS.
DWIGHT E STAMBAUGH
MABEL E STAMBAUGH
Defendant
NO. Ol-P~J.... Cc.>~t '€tl~
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.
-""..." " ,
-'~
~~
-, I
c.~
...:,,;:
,
.
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#:4168100008610725
CUMBERLAND COUNTY COURT OF COMMON PLEAS
FIRST SELECT, INC.
4460 ROSEWOOD DRIVE
PLEASANTON, CA 94588
PLAINTIFF
VS
DWIGHT E STAMBAUGH
2103 FISHER RD
MECHANICSBURG, PA 17055-5123
MABEL E STAMBAUGH
2103 FISHER RD
MECHANICSBURG, PA 17055-5123
DEFENDANT
NO. 01- f 52 Cw.:.e I f.uv--J
CIVIL ACTION
1. The Plaintiff, First Select, Inc., is a Delaware corporation,
organized and existing under the laws of the State of Delaware and
with its principal place of business at 4460 Rosewood Drive,
Pleasanton, CA 94588. Plaintiff is the owner of this account,
which is the subject matter of this action.
2. The Defendant, DWIGHT E STAMBAUGH, is an individual who
resides at 2103 FISHER RD, MECHANICSBURG, PA 17055-5123, and MABEL
E STAMBAUGH, is an individual who resides at 2103 FISHER RD,
~~~"
I __ _~ _ ,
,~<"
~~
, ;
-~-~",
.
MECHANICSBURG, PA 17055-5123.
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,
bearing account number 4168100008610725.
4. The terms of said account are stated in the documentation
attached hereto as Exhibit RA".
5. The Defendants have failed to pay the amount owed in
accordance with the account agreement and have failed to pay the
outstanding debt as agreed.
6. The Defendants are indebted to the Plaintiff in the amount of
$2,085.24 as of 11/11/2000, plus pre-judgment contractual interest
at the rate of 21.24% per annum, less payments made.
7. In accordance with the documentation attached as Exhibit "A,"
Plaintiff is entitled to reasonable attorney's fees, and Plaintiff
will incur attorney's fees in the amount of $354.00.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, First Select, Inc., and against the
Defendants in the amount of $2,085.24, plus pre-judgment interest
at the contractual rate of 21.24% per annum from 11/11/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $354.00, 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 Defendants received a monetary benefit, which was in fact
appreciated by the Defendants.
. -~ ~-" '"
,~-'- '- - < ,--'-
<
""~"-'<+-"
t
10. The Defendants accepted the benefits.
11. By virtue of the circumstances surrounding the request for
funds made, the Defendants 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
Defendants to retain the benefits of the funds or to be unjustly
enriched at the expense of the Plaintiff or allow the Defendants
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, Inc., and against the
Defendants in the amount of $2,085.24, plus pre-judgment interest
at the contractual rate of 21.24% per annum from 11/11/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $354.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
:: ~W MS;:;~~/
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.
"'~.,
. ,
,'~ -
-, I
.,
t!iliil'
~
,
,
VERIFICATION
I,
HEATHER KOORFr'1AN
, declare that: I am
a Designated Agent of FIRST SELECT, INC., 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
State of California.
Date
Designated Agent
"""'"" .
,
I.
. ~ .~
"~",,,,,-,,~,,,;
EXHIBIT --A
<
F1RST SELECT
IMPORT~NT ~EGAL NOTICE
,
Federal law gives you 30 days after you receive this letter to dispute the validity of the debt or any part of it If you do not dispute the validity of the debt, or any part of'it, within
that period, we will assume that the debt is valid. If you dispute the debt, or any part of it, in writing-by mailing us a notice to that effect on or before the 30th day following the
date you received this letter-----.we will obtain and mail to you proof(verification) of the debt. And if, within the same period, you request in writing the name and address of the
original creditor (if different from the current creditor). we will furnish you with that wonnation too. lfwe do receive a timely written notice, all efforts to collect this debt will
be suspended until we mail any required information to you. Your right to mail us a written notice of dispute lasts until the 30th day following the day you receive this letter.
We will wait until sufficient time has elapsed for us to be able to receive a written notice of dispute from you-even if you mail it on the 30th day following the date you received
this letter-before referring your account to an attorney in your state to file suit against you should it be necessary.
The purpose of this communication is to collect a debt; any information obtained will be used for collecting the debt.
ACCOUNT AGREEMENT
Your BANK OF AlVlERICA account has been transferred to First Select. Your
BANK OF AMERICA accOQnt was closed at the time of this transfer and will
therefore continue to be closed. This Account Agreement contains the terms that
govern your First Select accOUnt (the" Account"). In this Agreement, "you" and
"your" mean each person Whll is liable for payment on the Account. "We," "our,"
and "us" mean First Select or its assignees. Because your Account has been
transferred to us, you are now obligated to repay the Account to us instead of BANK
OF AMERICA If the Accollnt was opened as a joint account, we may act on the
instructions of any joint account holder.
PaymentsIFinance Charge!i. As long as you have a balance outstanding on your
Account, finance charges are calculated as follows:
To figure the fmance charges for each billing cycle, we multiply the average daily
balance on your account by It daily periodic rate. The daily periodic rate we apply is
your Account's Annual Percentage Rate divided by 365. The Annual Percentage
Rate will be calculated as disclosed in your most recent BANK OF AMERICA
account tenns (the "Original Tenns"). !fyour Original Tenns provided for different
Annual Percentage Rates to be applied to different components of your outst:qding
balance, we will apply the lowest such Annual Percentage Rate on your entire
outstanding balance.
We may accept late Of partial payments, or payments marked "paid in ~ll" or
marked with other restrictions, without losing our right to collect all ainounts owing
under ~s Agreement. You may ask First Select to pay.,your Account by debiting
your checking or savings acCount. First Select will first verify youiideirtity and
eligibility-for this service. You may revoke your authorizationby writing to First
Select Customer Service.
Fees. We will charge your A.ccount a fee for each billing cycle within which your
AccoUIJt is delinquent (late charge). The amount of the late cl1arge will be as
disclosed in your Original Tenus or the maximum late charge ,permitted by the law
of your state of residence, whichever is lower.
We will charge your Account a. fee for each returned payment check (returned check
charge). The amount of the returned check charge will be as di~closed in your
Original Terms, or the maximum returned check charge permitted by,the law of your
state of residence, whichever is lower.
To the extent provided in YOUr Original Terms and to the extent permitted by
applicable law, in addition tl) your obligations to pay the outstanding'b9:lance on your
Account, plus interest and fees as disclosed herein, we may also charge you for any
collection costs we incur, in~luding but not limited to reasonable attofu~y's fees and
court costs. !fyour Original Tenns provided for an award of attorneY's fees and
court costs, such provision as incorporated herein shall apply reciprocally'to the
prevailing party in any lawsuit arising out of this Agreement.
Non-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.
Applicable Law, Severability, Assignment No matter where you live, this
Agreement and your Account are governed by federal law and by the law of the sta~e
designated as the applicable law in your Original Terms. If your Original Terms did
not contain an applicable law provision, then this Agreement and your Account are
governed by federal law amI the law of your state of residence. This Agreement is a
final expression of the agreement between you and u~ ~d may.not be contra.dicted
by evidence of any alleged llra1 agreement. If a provlSlon of this agreement IS held to
be invalid or unenforceable, you and we will consider that provision modified to
conform to applicable law, nod the rest of the provision in the Agreement will still be
enforceable. 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
the assignee, we may give you such notice by filing a financing statement with the
state's Secretary of State.
Customer Service. For g~eral questions regarding your First Select account,
please call our toll-free service number, 1-888-924.2000. For quality assurance
purposes, and to improve Cl,lstomer service and security, telephone calls to or from
our offices may be monitored or recorded.
Credit Reporting: Personal Infonnation. If you fail to fulfill the terms of your
credit obligation, a negative credit report reflecting on your credit record may be
submitted to a credit reporting agency. In order to dispute any information we are
reporting about your Account, you must write to us at the following address: First
Select, P.O. Box 9104, Pleasanton, California 94566. We mav share information
with our affiliates including. without limitation Providian National Bank and
Providian Bank. However vou mav write to us at anv time instructinl! us not to
share credit information with our affiliates.
YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE
1bis notice contains important information about your rights and our responsibilities
under the Fair Credit Billing Act.
Notify Us in Case of Errors or Questions About Your Bill
!fyou think your bill is wrong, or if you need more information about an entry on
your bill, write us. on a separate sheet, at the following address: First Select, P.O.
Box 9104, Pleasanton, California., 94566. 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 pres~irve your
rights.
" In the letter, give us the following:
- Your name and Account number.
- The dollar amount of the suspected error.
- A description of the error and an explanation, if possible, of why you believe
there is an error. If you need more information, describe the item you are not sure
about.
, Your Rights and Our Responsibffities After We Receive Your WIitten Notice
We must acknowledge your letter within 30 days, unless we have corrected the ~r
by then. Within 90 days, we must either correct the error or explain why we beheve
the bill was correct. After we receive your letter, we cannot try to collect or report
, you as delinquent as to any amount you question, including finance charges. We can
apply any unpaid amount against your credit line. You do not have to pay any
questioned amount while we are investigating, but you are still obligat~:d to pay the
parts of the bill that are not in question.
Ifwe fmd that we have made a mistake on your bill, you will not have to pay any
finance charge related to any questioned amount. Ifwe did not make a mtstake, you
may have to pay fmance charges, and you will have to make up the nili;sed payments
on the questioned amount. In either case, we will send you a statement of the
amount you owe. And the date that it is due. If you fail to pay the am()unt we think.
you owe, we may repo~ you as d~l~quent. Howe:ver, if our expl~tion does not
satisfy you and you wnte to us WIthin 10 days tellmg usthat 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 anyone we reported you to. We must tell anyone we report you to
that the matter has been settled between us when iffinally is. Ifwe do not follow
these rules, we cannot collect the:first $50 of the questioned amount even if your bill
was correct.
Special Rule for Credit Card Purchases
If you have a problem with the quality of goods and services that you purchased with
your BANK OF AMERICA credit card and you have tried in goo~ faith to correct
the problem with the merchant, you may not have to pay the remamm!~ amount due
on the goods or services. There are two limitations to this right: (a) you ~u~ have
made the purchase in your home state or, if not within your home stat~i, WIthin 100
miles of your current mailing address; and (b) the purchase price must have been
more than $50. These limitations do not apply if either we or BANK OF AMERICA
own or operate the merchant, or we o~ BANK OF AMERICA mailed you the
advertisement for the property or services.
f,OOS
-
:~~II;l<)iififfiiW_m-,-,;;:;,g,il."&~",,';~b@,,'!jltk;ij"iiI;#'''':!li!Ii1.;d-.1;liri:iiX\''!"_,,,~(,i,"",,!i:W"-dh\,~;;~~i<cX:;';;;',d"ti',"'~~%.A~Um:k.~IW~ii~~&,,,~1!llIllIi.-..d~"""'"
""" "~~I
~
t:,o
.
.
,
~ (J ~ 0 G:l 0
TI ~ ~ c ~e
<~ -<1
~ -oCCl ,....,
() ~ rnlT: cO
Z::o
....... ~ 8 6 ZS; 1'0 ":;-JCl
0- ~:;?: ~](h
r:; CJ :? ~-~1
~ 2; C) --';" ~~~
~ kCi :.."
~ tJ pc ,~
p: Z '"'0 ~j
=< .0 -<
J 1--
~
~, <-
, .
f'~"-' ~- .; I!!llliJj
I" _,
'"
I
-.~~~ ~- ",c...ri~_ - -~" -""'<I!1r~.',
SHERIFF'S RETURN - REGULAR
."
.-
."-
CASE NO: 2001-00852 P
,
, COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST SELECT INC
VS
STAMBAUGH DWIGHT E ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
STAMBAUGH DWIGHT E
the
DEFENDANT
at 0019:23 HOURS, on the 21st day of February, 2001
at 2103 FISHER ROAD
MECHANICSBURG, PA 17055
by handing to
MABEL STAMBAUGH
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 Answers: //4
~~'u~~~
R. Thomas Kline
02/22/2001
PARK LAW ASSOCIATES
Sworn and Subscribed to before
me this 24 ~ day of
j~",~.", 02-<>v) A.D.
n\
'-t7~ten~~:~') / ~
By:
'@le'
~"l/"7/ ~I-
Deputy Sheriff ~
-~~,l'_.i,,,,,,,,,,,,,~~l-. _L
-" --,
~~v
SHERIFF'S RETURN - REGULAR
1
;.,
CASE NO: 2001-00852 P
\
.
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUlVIBERLAND
FIRST SELECT INC
VS
STAMBAUGH DWIGHT E ET AL
DAVID MCKINNEY
Sheriff or Deputy Sheriff of
Cumberland CQunty,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
STAMBAUGH MABEL E
the
DEFENDANT
, at 0019:23 HOURS, on the 21st day of February, 2001
at 2103 FISHER ROAD
MECHANICSBURG, PA 17055
by handing to
MABEL STAMBAUGH
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
So Answers:
6.00
.00
.00
10.00
.00
16.00
r~N"~<:~t
R. Thomas Kline
02/22/2001
PARK LAW ASSOCIATES
,
Sworn and SUbscribed to before
me this .2 /? t::. day of
J~: ~u1 dUm! A.D.
~c2. !hjt1h(, Af"'7J
Prothonotary I
By:
~~;;~~ '
Deputy Sheriff '~
,~-.... - ~--..
4
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
-. ^ ',' -~ ''q 'j "i.
..
I HEREBY CERTIFY THAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 295 MAIN STREET
TILTON, NH 03276
DEF: 2103 FISHER RD
MECHANICSBURG, PA 17055-5123
4168100008610725
CUMBERLAND COUNTY COURT OF COMMON PLEAS
FIRST SELECT, INC.
Plaintiff
VS
DWIGHT E STAMBAUGH
MABEL E STAMBAUGH
Defendant
NO.01-852 CIVIL TERM
. PRAECIP,E FOR JUDGMENT
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff and against
the said Defendant for failure to plead or otherwise respond to
the Complaint and assess the damages as follows:
AMOUNT OF CLAIM
ATTORNEY FEES
PLUS ACCRUED INTEREST
LESS PRINCIPAL PAID
LESS OTHER PAYMENTS
$2,085.24
$354.00
$163.82
($0.00)
($289.50)
$2,313.56
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 P~ocedure
No. 237.1 is attached hereto and marked Exhibit "A"
TOTAL
AND NOW, D_~~. 11
in favor of t~Plaintiff
VALERIE ROSENBLUTH PARK,ESQUIRE
Attorney for the Plaintiff
,~~I , Judgment is entered
and against the Defendant by Default
""'~"'~,~_...>
>'-
:fllll-'
"'''-''
..
. for want of an Answer and damages assessed in the sum set forth
in. the above certification.
~+-)K.4=
P 0 ONOTARY
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
ATTORNEY !.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 COUNTY COURT OF COMMON PLEAS
I HEREBY CERTIFY THAT THE
, >
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 295 MAIN STREET
tILTON, NH 03276
DEF: 2103 FISHER RD
MECHANICSBURG, PA 17055-5123
FIRST SELECT, INC.
Plaintiff
VS
DWIGHT E STAMBAUGH
MABEL E STAMBAUGH
Defendant
NO. 01-852 CIVIL TERM
NOTOCEOFPRAEC~EFOR
ENTRY OF DEFAULT JUDGMENT
TO: DWIGHT E STAMBAUGH
MABEL ESTAMBAUGH
2103 FISHERRD
MECHANICSBURG, PA 17055-5123
DATE OF NOTICE: 3/14/01
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
THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. 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
THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR
CARLISLE, PA 17013
(717) 240-6200
PARK LAW ASSOCIATES, P.C.
cc:
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMA nON OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT
4
<~"~~ ~ ~--~.-
;'1
."'iII~.;,
, \
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: 295 MAIN STREET
TILTON, NH 03276
DEF: 2103 FISHER RD
MECHANICSBURG, PA 17055-5123
CUMBERLAND COUNTY COURT OF COMMON PLEAS
FIRST SELECT, INC.
Plaintiff
VS
DWIGHT E STAMBAUGH
MABEL E STAMBAUGH
Defendant
NO. 01-852 CIVIL TERM
VERIFICATION OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS
VALERIE ROSENBLUTH PARK, Esquire, being duly sworn
according to law, deposes and says that she will make this
affidavit on behalf of the within Plaintiff, being authorized to
do so, and that she believes and therefore avers, that DWIGHT E
STAMBAUGH, Defendant is over 21 years of age; that his/her place
of residence/business is located at 2103 FISHER RD MECIlANICSBURG,
PA 17055-5123 and that he/she is employed and that he/she is not in
the Military or Naval Service of the United States or its Allies
or otherwise within the provisions of the Soldiers and Sailors
Civil Relief Act of Congress of 1940 and it amendments. /
PARK LAW ASSOC S, P.C.
BY:
Valerie osenbluth Park
Attorney for Plaintiff
ElO
......~,-
_"- i...'.
~~!!\!;l;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: 295 MAIN STREET
TILTON, NH 03276
DEF: 2103 FISHER RD
MECHANICSBURG, PA 17055-5123
CUMBERLAND
COURT OF COMMON PLEAS
FIRST SELECT, INC.
Plaintiff
VS
DWIGHT E STAMBAUGH
MABEL E STAMBAUGH
Defendant
NO. 01-852 CIVIL TERM
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.
PURSUANT TO THE FAIR DEBT COLLECTION P TICES ACT, IT IS
REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT
TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
n
:t~iiuI!~!i)iW$J1'm'~~Hiil'*"~~;i!ilJ\AA,~~'''I&"'';l,",,if''i-!~W4r'''''~~~)'j,;;';W~%!$',"'''l-''<i~~:~~IIli8tt'"~''''''-'',,"'''~-A'f~" -'~,,~, ~~iW';
i
~)"'_'"... ,_u
.,~, " - ",",.," Y,. .~"",,"'_~' ,~."p'. .="~
=,
,
j .
.
~
~
~
-.
~, ,~
"iB'
-
92l;~~
Zf~~
C') '-'-
r'
~'
j;,_.
~~~;:
z
.
o
c::
;:::<>-
-'"
-~
>,'~
,,"
.'C'
r--.
~
~-\.i
-',~
.-.:
-'e>~
t,,j
:- .')
:..~;
(::J
,
=<
"