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HomeMy WebLinkAbout01-1322 FX -, ...-" , ' ,~ . ~ o~"""~~~, ,~:,:, , . . . , 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 CORPORATION Plaintiff VS. BRIAN E GIPE Defendant NO. 01- /3.;l.;).. euJJ- NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or obj ections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 (800)990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ii' - , ~ " . ,-. , , . " '0' ""----"i,_< .-~"""~~' . , 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#:4168100008156646 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS BRIAN E GIPE 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 DEFENDANT NO, CIVIL ACTION 1. The Plaintiff, First Select, Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware 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, BRIAN E GIPE, is an individual who resides at 941 BOSLER AVE APT A, LEMOYNE, PA 17043-1763. 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 4168100008156646. - ~ '. " , ,;,"',~' I", "-< ,j, '-~,~ """,~i:j'i , 4. The terms of said account are stated in the documentation attached hereto as Exhibit "A". 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 $9,414.87 as of 08/11/2000, 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 $1,600.52. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $9,414.87, plus pre-judgment interest at the contractual rate of 21.24% per annum from 08/11/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,600.52, 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. '",,,,",,,"'''' ~ " j '~, "' .;-" , ,__J....~ -~""~,> 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, Inc. and against the Defendant in the amount of $9,414.87, plus pre-judgment interest at the contractual rate of 21.24% per annum from 08/11/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,600.52, 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. ~ -- ,- ~ ~" ,~-, '" ^", -l-,' -, ,-" --"1 ,',' ::.\'''- - ,'~ ,-;" "~,__,_~,__,o~,,, --, __'~ij'" ,I '_-n','-. JJ_\I,bl,""';';;",,;,','- '",' <",,_--,. _'; ~";~ "'-;>,, 'd,,;;~),~-~L; :',",,,, ',I ~."""'~,,. , ~, ~ VERIFICATION I, , declare that as of March 20, 2000: I am a designated agent of FIRST SELECT CORPORATION, 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, of California. Designated Agent HEATHER KOORE " l, ." u'" ..""t'*~~' . 4:: ~ .~ FrR~' SELE'CT COR P 0 R A TEXH,a,r ACCOUNTAGREEMEN~ ' j) - Your ~.\..'\iK OF .-\..\-IER1C\ accounl h:lS be.:n transferred to First S.::kct Corporation. Your B.-\.'\;K OF .-\.\.IERIC.-\ 3CCOllnt wa~ dos<:d at the time of this 11ansf~r. ~nd \~'dJ Ih:;r<:for,7 contmue LO be dos<::d. !hi.s :l..cc~)lInt ..\gro:emcnt contains the terms that govern your first S.::kCI account (1h..: "Account"). In this Agreement. YOll and your mt:un each person who IS liable tor payment on t!1e Al.:counL "We," "cur." "ours," und "us" mean First Select Corporation or its assignees. Bec~u~e your .-\ccount has been rrans~erred t~ us, you ar~ now ohhgated to rcpay the Account to us instead of SA '\K OF .-\.\-[ERICA. Iftht.: Account was opened as ilJOlnl account. v.e may act on the mstnll;;Uons of any Jomt accounrholder, Payment:; f Fin:mce Cha'.gcs. .-\5 long us you have a balance outstanding on your A,cco~mL financ~ charges are calculated as follows: To fig~re the finance ~harges for each billing c~'c1~, ~ve multirl~ the average daily balance on your Account by a daily periodic rale. The daily periodic rate we apply tS YOLLr .-\CCOUllts .'\nnua! Percentage Rate d1\"lded by 36). The .,),jmual Percentage Rate will be calculated as disclosed in your most recent B.-\.'\K Of A,.'\ifERICA a~count tenns (the ':Origmal Terms"), lfyour Origmal Tenns proVIded for different A.nuua! Percentage Rates to be applied to different components of your outstandlOg balance, we will apply the lowest such Annual Percentage Rate to your entire outstanuing balance. We may. accept late or partial paymen~, or payments marked "paid in full" or marked with other restrictions. without losing our right to collect all <lmounts owing un~er thiS ~greeJ?ent y ~u ,~a.y ask F Ir;t SIlI~ct Corporation to pay this account by debiting your checking or savings account. First Select Corporation will first venfy your Identity and ehglbllity for thiS servIce. You may revoke your authorization by writing to First Selt:ct Corporation Customer Service. Fees. We will charge your Account a fee tOf each billing l:ycle within which vour .-\..:count is delinquent (late char"e). The amount of the late char"e wilt be as disclosed in your Original Terms Llfthe maximum late charge permitted by th~ law of your state of residence, whichever is lower. :.0 We \vill charge your Account a fee for each returned payment check (returned check charge), The amount Llfthe returned .::heck charge will be as disclosed in your Original Terms, or the maximum returned check charge permitted hy the !;:lW 0.fyollr state ofrezidcnc=:, \;-hichcv.:. i", lv~"<::r. To the extent provided in your Original Terms, and to the extent permitted by applicable law, in addition to your obligation to pay the outstanding balance on your Account plus interest and fees as disclosed herein, we may also charge.you tor.any collection costs we incur, including but not limited to reasonable attorneys' fees and court costs. If your Original Terms provided for an award ofattomeys' 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. Applic'3ble Law; Severability; Assignment. No matter where you live, this Agreement and your Account are governed by federal law and by the law of the state 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 and the law of your state of residence. This Agreement is a final expression ofthe agreement bet\Veen you and us and may not be contradicted by evidence of any alleged oral agreement. If any provision of this Agreement is held to be invalid or unenforceable, you and we will consider that provision modified to conform to applicable la\-..., and the rest of the provisions in the Agreement will still be enforceable. We may transfer or assign our rigb,t to all or some of your payments. If state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such notic~ by filing a financing statement with the state's Secretary ofStat<:. ' Credit Reporting; Personal Information. If you fail to fulfijJ the terms of your credit obligation, a negative credit report reUecting 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 Corporation, P.O. Sox 9104, Pleasanton, California,. 94566. We may j'hare informalum willi our afftliates including, without limitation, Providian National Bank and Providian Bank. However, you may write to us at any time instrllcting lIS not (0 share credit information lvi:th ow' affiliates. YOUR BILLING RIGHTS, KEEP TillS :-;OTICE FOR FUTURE USE This notic~ contains important information about your rights and our responsibilities underth~ Fair Credit Billing Act. Notity us in Case of Errors or Questions About Your Bill If you 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 Sel:ct . Corporation. P.O. Box 9104, Pleasanton, CA 94566. Write to us as soon as possible. We must hear from you no later than 60 days after we sent you the fIrst btll on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your le,tter, give us the following: Your name and Account number. The dollar amollnt of the suspected error. Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your W ritten ~otice We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct th~ err~r ore~plain why we believe the bin was correct After we receive your letter, we cunnot try to coll~t or report you as delinquent as to any ax:nount you. quest,IOn.. mcludmg finance. charges. We can apply any unpai.d amount agai!'lSt your: credit line. You do not have to pay any questioned amount whIle we are mvestlgatmg, but you are stIli obligated to pay the parts of the bill that are not m questIOn. . Ifwe tind that we made a mistake 6n your bill, you will not have to pay any finance charge related to any questioned.amount. Ifwe ~idnO[ make a mistake, y?U mav have to pay finance charges, and you will have to make up the missed payments on the questioned amount. In eIther case. we wdl ,;end ~~ou a statemen~ or the-amount you owe and thll' da!':: that it is due. If you fa.il to pay the amount \'ie think you owe. we may report you as delinquent. However. ,fo~r explana.Llon does not satisfy you and you write to us within 10 days telling us that you stili refuse to pay. we must t<:::ll :1I1yooe we report you to that you questIon y~ur.blll. , .lJ1d we must tell vou the name of :my one we reported you to. We must tell :lnyone we report you to that the matter has been settled bd\\-een LIS when It tlOally IS, lfwe do not follow these rules, we cannot collect the first 550 of the qu~stioned amLlunt CV':ll ifyonr bill W<J.$ COn'lzct. Sp<:..:i:.J Rlll~ for C:r~uit C:.lnl PU:'C!l;l$CS lfvoll have a problem with the quality of goods and s.:rvices that you purchased with ;0 our BA..'\'K OF X'dERIC.--\ credit cart.! and YO.lll~av~ tried in ~Ll{~d faith Iv correct the probl.zm with the men.:hunt. YOll may not hav~ to pay the remaining amount d';le?n me go?ds o~ :>..:rvices. Therc,a,rc two \JmllatlOI'lS to tillS nghL: (a) V0ll mllst have maue the purchase in \'our home state or. ifnot within your home ~tal.z. wlthm 100 mtlC$Llt your current mati 109 address: ,U1~ ~b) the pun.:~~~ price must have been mure than 550.' Tho::se limitations uo not apply if ~ilh.zr we Of I3.,\..'\'K OF A\lERIC, \ own or vpcrate the m..:n::hant. or 11 we or SA.'\ K OF' .-'\.\-lERIC."\ mailed YOlllh~ ;J,u\'.:rtis<:m~n{ lor th.: propaty or s<:rviccs. Z5~O ..~ ,.,' '~'''"'iIf'-'';''''''"''"''''''iMr~~''~ ' I ',,' ".. ;""""',_,_""",.*,~.'''''".I..'#-''''''''''_' . . . ,. '......~..,'._'~,_,_'" ....,.. .' ,"" ,~,',' ,- - ~, .~~~- ~'" ,~ < ..,.,'~ ~"_,,,.., ~.. _',,"' 1_., ~ co ~ 'lIiMiiii~",,~~ :~III!W.!l:tiijihlr~lt '-ili' '11~' " (0l ~ 0 ~ ~~~ FU ::It ,-l ;'.~~ ::n ".. ~, I ~l'Tl ;;V ~Or'Tl :0 \ ~Q.Q ~ ~~ CO ~_f.) ~ CJj J -<0 -u ~~ " k ::It '5 0J t.).J ~g tP. 5[T\ -, ~ \y - ~ I.Y ~J ~ v:> 0 ""-., -{::--.. ~.t0 CJ\ Cll "- f{f - ~_ G ,~~~,~~- , r..~ . , "~ ,,~ - "!1'/-" SHERIFF'S RETURN - REGULAR CASE NO: 2001-01322 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS GIPE BRIAN E 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 GIPE BRIAN E the DEFENDANT , at 0009:23 HOURS, on the 13th day of March 2001 at 941 BOSLER AVE APT A LEMOYNE, PA 17043 by handing to BRIAN GIPE a true and attested copy of COMPLAINT & NOTICE together with IN ASSUMPSIT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So?~~~ R. Thomas Kline 03/14/2001 PARK LAW ASSOCI Sworn and Subscribed to before me this .:H ~ day of ~~ :J..oo1 A.D. (;';'-' a. IhtPi.. / , # Prothonotary By: , ",-"4<_~". . I.. l '.,~ ""~, ~'~~y,," , 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: 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 4168100008156646 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS BRIAN E GIPE Defendant NO.01-1322 TO THE PROTHONOTARY: PRAECIP!E I FOR JUDGMENT 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: $9,414.87 $1,600.52 $1,358.71 ($0.00) ($0.00) $12,374.10 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 th~s 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 Pr cedure 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 0 NBLUTH PARK,ESQUIRE Attorne or the Plaintiff AND NOW, () n \ L d.. '{ , .;2CO ( , Judgment is entered in favor of t~PPlaintiff and against the Defendant by Default fo;!:' want of an Answer and damages assessed in the sum set forth in the above certification. c,,",~lij'- , " .' '" C,,' ,_, __ i.:L:.i.i' G-",7~ 12.~ 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. ..;;oN","J . '!i', ".-"', ~ . - - -- ,,-, ~.~ '~ -- ~~" '~~~," li:;.i~ , VALERIE ROSENBLUTH PARK .., ATTORNEY LD. # 72094 PARK LAW ASSOCIATES,P.C. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 FIRST SELECT CORPORATION Plaintiff VS BRIAN E GIPE Defendant NO. 01-1322 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: BRIAN E GIPE 941 BOSLER AVE APT A LEMOYNE, P A 17043-1763 DATE OF NOTICE: 4/3/01 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, 4'. FLOOR CARLISLE, P A ,17013 (717) 240-6200 PARK LAW ASSOCIATES,P.C. BY: V ALERlE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATIEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT II "'~"". ,-. , .'.ffil,~,;%k f 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: 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS BRIAN E GIPE NO. 01-1322 Defendant VERIFICATION Of NON-~ILITARY 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 BRIAN E GIPE, Defendant is over 21 years of age; that his/her place of residence/business is located at 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 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 its amendments. PARK LAW A SOCIATES, P.C. BY: Valeri Rosenbluth Park Attorney for Plaintiff E10 ,w~ . ' " "'" f'rmi-l': . I 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: 941 BOSLER AVE APT A LEMOYNE, PA 17043-1763 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS BRIAN E GIPE NO. 01-1322 Defendant 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. P PURSUANT TO THE FAIR DEBT COLLECTION CTICES 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. , ~l" ~~~~lifl~--m;-"ikf~~&,;,,:tJ.-';;:-""<"',;,.,.u,W"';~o!'J!lli:""-'-\1li'\~~~~liiItJIl "lliiM J:ijf1"<-~""''''iiiM~---~''i ,"'~'"~ ~ ~~ ~ ~ ~ 0 0 " ~ ~ "'" '-I "'IJ] ." j':;l\l B ~m AI ::0 " p.:: ~s,:: N -rJ rn - W ~~'? p; ....... l~ ~Z ..., kO ....., -'iy, :::r, ,~ 0 ~8 :l!: c-j,:!J j -..0 V) S>c ~ Om !F ..{) ~ ~ " .--....0 ~ en ~ R l' ,O~~" ~" ~,~,o '''''='~~_~~'_''__'~~' , ' ~ ~",' ~ ~ - ~> '. I ~