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Home My WebLink About01-1772 FX ^ -, I ~ 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 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VB. ROGER A HOOVER Defendant NO. 01- 1'77~ Guf/~ 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 ect,ions 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. h';>i~lL'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#:4168100012337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 DEFENDANT NO. 0/-/71L c;J /....t.-<.--- CIVIL ~CTION 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, ROGER A HOOVER, is an individual who resides at 68 STAMY RD NEWVILLE, PA 17241, . 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 4168100012337620. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. - ~ , L"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 $10,372.99 as of 12/06/2000, plus pre-judgment contractual interest at the rate of 18.00% 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 $1,763.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $10,372.99, plus pre-judgment interest at the contractual rate of 18.00% per annum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,763.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT II 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 tpis Court to allow the Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPO~~, ~ -- L" t. p ~ 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 $lO,372.99, plus pre-judgment interest at the contractual rate of l8.00% per annum from l2/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $l,763.00, 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. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. >-' ~-. ~ ., .' - ~ < # ..... VERIFICATION I, I::IEATHEB KOOREMAN , 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 l8 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 Date Designated Agent ,~-i~i', I I I I ! ,_ ".' ._t) J. -hi" F1R-ST ~E1ECT IL eXHIBIT G- ACCOUNT AGREEMENT I You!" DISCOVER accou~t has been transferred to Firnt Select Corporation. Your DISCOVER account was closed at the time of this transfer, and will therefore contmue to be closed. ~~ AcCount Agreement contains the terms that govern your First Selea account (the "Account"). In this Agreement, "you" and "your" mean each person who lS hable for payment on the Account "We," "our," "ours," and "us" mean First Select Corporation or its assignees. Because your Account has been transferred to us, you are now obligated to repay the AccOunt to us instead of DISCOVER If the Account was opened as a joint account, we may act on the instructions of any joint accountholder. Payments I Finance Charges. ~ long as you have a balance outstanding on your Account, fmance charges are calculated as follows: To figure the fInance charges for each billing cycle,. we multiply the average daily baJance on your Account by a daily periodic rate. The daily periodic rate we apply is your Accountts Annual Percentage Rate divided by 365. The Annual Percentage Rate will be calculated as disclosed in your most recent DISCOVER account ~erms (the "0ri~1 Terms"). If y~ur Original Terms provided for different Annual Percentage Rates to be applied to different components of your outstandtng balance. we WIll apply the lowest such Annual Percentage Rate to your entire outstanding balance. We may. accept late or partial payments, or payments marked "paid in fun" or marked with other restrictions, without losing our right to collect all amounts owing under this .A.greement.. You may ask. First Select Corporation to pay this account by debiting your checking or savings account First Select Corporation wiU first verify your identity and eligibility for this service. You may revoke your authorization by writing to First Select Corporation Customer Service. Fees. We will charge your Account a fee for each billing cycle within which your Account is delinquent (late charge). The amount of the late charge will be as disclosed in your Original Terms or the rna.'cimum late charge permitted by the law of your state of residence, whichever is lower. We win cJ;targe your Account a fee for each returned payment check (returned check charge). The amount of the returned check charge will be as disclosed in your Origmal Tenns. or the maximum returned check charge pennitted by the law of your state ofTe$idence, whichever is lower. 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 for any collection costs we incur, including but not limited to reasonable attc>rneys' fees and court costs.' !fyour Original Terms provided for an award of attorneyst 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~Wai'Yer 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; Assigronent. No matter where you live, this Agreement and your Account are governed by federa1law 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 resic.hmce. This Agreement is a final expression of the agreement between 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 law, and the rest of the provisions in tIle Agreement will still be enforceable. We may transfer or assign our right to all or some of your payments. Ifstate law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such notice by filing a fmancing statement with the state's Secretary of State. Credit Reporting; Personal Information. 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 infonnation we are reporting about rour Account, you must write to us at the followin~ address: First Select Corporation. P.O. Box 9104, Pleasanton, California, 94566. We- may share inffmflamm -witlr our ajfililltu including. .."itlr9Jlt limitmon. Proyidian National Bank an d Pr9.,iJian Bank. H 9lPevO'. ~o" may write- t9 JQ' at any time- instntUing "s not to slrau aerJit Ut/9rmation with olD' allUiata. YOUR BILLING RlGHTS - KEEP TIllS NOTICE FOR FUTURE USE This notice contains important infonnation about your rights and our responsibilities under the Fair Credit Bilting Act. Notify Us in Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more infonnation about an entry on your bill, write us, on a separate sheet, at the following address: First Select Corporation, P.O. B01(9104, Pleasanton. CA 94566. Write to us as soon as possible. We musl:hearfrom you no latertlJan60 days after we sent you the firs!: bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following: . Your name and Account number. . The dollar amount 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 Written Notice We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the wor or explain why we believe 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 sl:iU obligated to pay the parts of the bill that are not in question. Ifwe fmel that we made a mistake on your bill, you will not have to pay any fmance charge related to any questioned amount. Ifwe did not make a mistake, you may have to pay finance charges, and you will have to make up the missed 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. !fyou fail to pay the amount we think you owe, 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 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 it finally is. Ifwe do not follow these rules, we cannot collect the flfSt $50 of the questioned amount even if your bill was correct Special Rule for Credit Cnrd Purchases If you have a problem with the quality of goods and servl'ces that you pllfchased with your DISCOveR credit card and you have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the_goods or services. There are two limitations to this right: {a) you must have made the purchase in your home state or, if not within your home state, 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 DISCOVER own or operate thll merchant, or if we or DISCOVER mailed you the advertisement for the property or services. r~A)()~ :Q~!i/!;jj~l;~~ai\il",,,,,j!dMlliil4!iffllili<'iiri'_I1.."'''''lII.;j;m.,.~,,,,t:rJbi;j.;f/i~;'''''~"H;"\,~"':j,O.ij!!"':I!<~'l,lI~<4l_~~~"'>"-'". ' C\ "0 W ~ % ..~ -_~'m ,~= ._ .. ~,- ~,"'~ .,~, "~ ~\ "- ~ ~ 1i' " ... ~ ~ !'l~~ ~~~ -cJ~ ~~ --:t:- J!ilIIll""'"~~~~ o c ~~: -a 0'::' rnrt""i Z::r) :z ~;~ CI).-/ ~i=3 ~O s;2 z ::;!. o ~ .-'~"'" "',..... "" r-.,) eJ' ,---l ~i -c 3' -Cd :.n 0J '-"II;j -'s~i~ -~:;: (-) ~rn '::~ :>> 3!. 1 B ~ . ""'-= .~, . J. ,,i,'! t . SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01772 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS HOOVER ROGER A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HOOVER ROGER A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HOOVER ROGER A DEFENDANT WAS. NOT ABLE TO BE SERVED AT ADDRESS STATED PRIOR TO EXPIRATION DATE. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 8.06 5.00 10.00 .00 41.06 '~~ R. Thomas Kline Sheriff of Cumberland County PARK LAW ASSOCIATES 04/27/2001 Sworn and subscribed to before me this "tA day of ~d d..{;of A.D. (.,~ tl-- AJ> AoA P, ~ V prothonPt~'; ~~7J--" , , <.J . . ."'~ ~ '-'VA I HEREBY CERTIFY THAT THE wiTHIN is It TRUE AND CORRECT COpy OF THE ORIGiNAL ON FILE AT'!' NEY FOR PLAINTIFFI TRUE COPY FROM RECORD tn rlllllimony wbereof.>i.euntoset my halllll - tile -ahaidCOUtt at ~: PI c ~~'j~~~ VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA l890l (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS. ! i I i NOTICE ROGER A HOOVER Defendant NO. Ot-/77~Co~(~~ 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 l70l3 (717)249-3166 (800) 990-9l08 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "I; . . I VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA l890l (2l5) 348-5200 ATTORNEY FOR PLAINTIFF ACT#:4l68l000l2337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE,PA l724l DEFENDANT ! NO. i , CIVIL ACTION l. The Plaintiff, First Select,ilnc. 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, ROGER A HOOVER, is an individual who resides at 68 STAMY RD NEWVILLE, PA l7241, . 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 4168100012337620. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. - - ~..... ">, I ,=', I -........"'i^ , , 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 $lO,37::!.99 as of l2/06/2000, plus pre-judgment contractual interest at the rate of l8.00% 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 $1,763.00. WBEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $lO,372.99, plus pre-judgment interest at the contractual rate of l8.00% per annum from l2/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $l,763.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT II 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. ll. 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 THIS IS AN ATTEMPT ,TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .- , ,~ < "" .1, i.:[ ,.. 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 $lO,372.99, plus pre-judgment ~nterest at the contractual rate of 18.00% per annum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $l,763.00, 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. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .J ,,",,'~ ~ .,- "- - i~ .~W "1 , I, VERIFICATION HEATHER KOOREMAN , 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 l8 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 Date Designated Agent Jl. .-1 ~ , ,1 '"' ,>I " Fl-RST SELECT eXHIBIT k ACCOUNT AGREEMENT I y ou~ DISCOVER account has been transferred to First, Select Corporation. Your DISCOVER account was closed at the time of this transfer, and will therefQ['e contmue to be c10sed This Account Agreement contains the terms that govern your F4'st Select account (the "Accoum"). In this Agreement. "you" and "your" mean each penon who is liable for payment on the Account. "We/' "our/' "ours," and "usl' mean F"U'St Select Corporation or its assignees. Because your Account has ~een ~ferred to .~ you are now obligated to repay the AccOunt to us instead ofDISCq'VER. If the Account was opened as a joint account. we may act. on the InstntctlOns of any Jomt accounthotder. Payments I Finance Charges. As tong 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 a 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 DISCOVER acCOunt terms (the "'Original Tenns1. If your Original Terms provided for different Annual Percentage Rates to be applied to different components of your outstanding balance, we will apply the lowest such Annual Percentage Rate to your entire outstanding balance. We may. accept, late or partial payments, or payments marked "paid in full" or marked with other restrictions, without losing our right to collect all amounts owing under this Agreement You may ask First: SeJect Cccporation to pay this account by debiting your checking or saving5' account. First Select Corporation will first verity- your identity and eligibility for this service. You may revoke your authorization by writing to First: Select Corporation Customer Service. Fees. We will charge your Account a fee for each billing cycle within: which your Account is delinquent (late charge). The amount of the late charge will be as disclosed in your Original Terms or the ma.'Cimum late charge permitted by the law ofyout 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 disclosed in your Original Terms. or the maximum returned check charge permitted by the law of your state of residence, whichever is tower. To the extent provided in your Original T IWlS, and to the extent pCmmted by applicable law. in addition to your obligation to pay the outStanding balance on your Account, plus interest and fees as di3closed herein. we may also charge you for any collection costs we incur. including but not limited to reasonable attorneys' fees and court costs. If your Original TermS provided for an award of attorneys' 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 state designated as the appUcable law in your Original Terms. If your Original terms did not contain an applicable law provision. then this Agreement and your Act:ount are governed by federal law and the law of your state of residence. This Agreement is a final expression of the agreement between you and us and may not be contradicted by evidence of any aUeged 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 law, and the rest: oftbe provisions 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 assignee,. we may give you such notice by tiling a financing statement with the state', SecretaIy of State, Credit Reporting; Personal Infonnation. If you fail to fulfill the tenns of your credit obligation, a negative credit report reflecting on your credit record may be submitted to a credit reporting agency. In orderto dispute any information we are reporting about :your Account, you must 'Write to us at the followin~ address: First Select Corporation. P.O. Box 9104, Pleasanton, California, 94566. We mq ,hare hiformat'GIIlf'it1t OAr' "g;Uatu uu:lJldinr. lfltheNt limumen, PT",.,iJiGlt National BaltA alHl PToyiJian Ball". H rrwe.,a, yow may.rite to rB' at any time mftnfctinr lIS not t9 sl"ue aeJit in/fR'lflatioll liPith OAr' offdilltu. i i i I,; v YOUR BILLING RIGHTS. KEEP TRIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Nottty Us in Case orErron or Questions About You.r Bill If you think. your bill is wrong, or if you need more infonnation about an entry on your bill" write us. on a separate sheet. atthe following address: FirSt Select Corporation. P.O. Box 9104, Pleasan1on, 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 bill on which the en"OJ' or problem appeared. You can telephone us, but doing so will not pmerve your rights. In your letter, give us the following: . Your name and Account number. . The donar amount of the suspected error. e 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 Written Notice We must acknowledge your letter within 30 days. unless we have corrected the error by then. Within 90 days. we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect or report you as delinquent as to any amount you qlJestion. 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 ar~ still obligated to pay the parts of the bill that are not in question. Ifwe fmd that we made a mistake on your bill. you will not have to P8;Y any fmance charge relate~ to any questioned.amount Ifwe ~d not make a mistake, you may have to pay fmanc:e charges. and you will have to make up the nussed payments on the qUestIOned amount .In elther 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 amount \'Ve think you owe. 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 repon you to that you question your bUt. 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 it fmally is. Ifwe do not follow these roles, we cannot collect the fU"St $50 of the questioned amount even if your bill was correct. Special Rule for Credit Card Purcbnscs If you have a problem with the quality of goods and services t~a~ you purchased with YO\lr DISCO"'~R credit card and y~u ~a":C tried in. go?d faith to conect the problem with the merchant, you may not have to pay the remammg amount due on the ,goods or services. Th<<e are two lumtatlons to tillS nght: (a) you must have made the purchase in your home state or, if not within y<;mr home statCi. within 100 miles of)'l)ur current mailing ~ddress; and (b) the purchase price must have been more than :S50. These limitations do not apply if either we or DISCOVER own' or opcr.\te the merchant, or- if we or DISCOVER mailed you the a.dvertisement tor the property or services. ' ~!,on,> '-~J~l;j:~~~~'\S~rnfl:,"I,KC0_;;l;w<1;[","I'-li~i"#i;.;;",~~,..&~"",,."b,,,"' "'L>iti;o".JH'~"!IWJfJOif~,'I;,*";,;,,,,.vI&';);i'~il..~lYl~ IiIlmi!;WI__JWa~ t) ~ '~ rn.n.l i~~~ 1~ frt"j::iJ U.:H~t!~JI.;II!lIt.Jlll!!Y J In! ~. ... ,~~>-~,"-'-." ,.~ -.'- . . .... 'il"'d'" c;;p'''Jd 1" \ \"'\. 1 ! ~ \ t, ,.1 ' ~: \ 1 .,J. _I, (<,," \-;l\ _.~ i"" ,) \G, Wi (1(1 \3 LI ll~~ JJ."PO} c .cua"fI() :!:lI\1:!IlS :Wl. dfj :Pl;UO ." ,_",_,,=., ..v,c, _=~. ~........ . 'llillIiliii . ~ ~-, . 'I " (:,~>i) ;i:n.J .......=:::::; ~:~ ~ ,.._~ .""!."" . .~~ ~ Ll "'WL lIllt>lliii II I c CUMBERLAND County Court Of Common Pleas JUN 0 1 20~ tJ ')?- ~~ FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA l724l DEFENDANT NO. Ol-l772 ORDER AND NOW, this I.f~ day of ~ ' 20~, upon consideration of the Plaintiff's petition and upon Motion of Plaintiff, it is ORDERED and DECREED that the Defendant may be served in accordance with Pennsylvania Rules of Civil Procedure, by mailing a true and correct copy of the Complaint to the Defendant at the Defendant's last known address by both certified mail, return receipt requested, and by first class mail; postage paid. A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. . l' \ ~J. .~ t ~))f\ m '"liiil""-'--'''"" ~",""",,>"W~;&j fld'Ll'!,""...".",=",-, !""L "'d ~''''lilJ'I:~'~AAg~,".',y"" ~ _~_liIllli!I~bim:IM,",ful,;"f;[;,,_,"_ 'r/f1V'vA.7J..SNN3Q !JNnQ.'J OM'71:!3$Vmo CO:cIlM ?-Nnr 10 AI:!V10NOr;lC\I;i ji/i .10 EOH-t>-aE7IJ '" - "III =%"'_'_~',~o"'_,,~~,,_",_ _ ~,,'~~"~~"__ ,~, ~ ~, ~. jXil.i)I,_,~,UI!"",,,.,,,,,,,". llI!l' -- i&i:jJiltilill!,iDll~.~~_ ;1 III , ~"^ lci CUMBERLAND County Court Of Common Pleas FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA l724l DEFENDANT NO. 01-l772 PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The petition of the Plaintiff by its attorneys, PARK LAW ASSOCIATES, P.C., respectfully represents that: L- A Civil Action for assumpsit was filed on 03/26/2001, with this Honorable Court to recover monies owed to Plaintiff as a result of credit extended to Defendant. 2. The Sheriff of CUMBERLAND County made a "Not Found" return of service of the Complaint. A true and correct of the sheriff's return of service is attached hereto, made a part hereof and marked Exhibit "P_l". 3. The last known address of the Defendant is 68 STAMY RD, NEWVILLE, PA l724l 4. Sheriff's efforts indicated Subsequent to the Plaintiff's receipt of the "Not Found" return, Plaintiff made the described to locate the whereabouts of the Defendant as in the attached Affidavit of Investigation. 5. Despite Plaintiff's inquiries, the Plaintiff has been unable to locate the Defendant. , .' " ,I l, 6. Plaintiff's counsel is aware of the footnote under Pennsylvania Rule of Civil Procedure No. 430(a) regarding a good faith effort to include 11 . inquiries of relatives, neighbors, friends and employers of the Defendant. . 11 ; however, such a communication, in the opinion of Plaintiff's counsel, would be in direct violation of the Federal Fair Debt & Collection Act, Section lS USC l692c(b) which prohibits communication with third parties without the prior consent of the Defendant. 7. The Plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff I s attorney shall file an affidavit of service showing service of the Complaint as set forth herein. PARK LAW ASSOCIATES, P.C. BY: VALERI ATTORNEY OSENBLUTH PARK, ESQUIRE FOR PLAINTIFF "~ -I"._A .. , I i I ~ I - 1~",L"""'_!llI\Wfl " SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01772 P' 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS HOOVER ROGER A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn accord~ng to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HOOVER ROGER A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HOOVER ROGER A DEFENDANT WAS NOT ABLE TO BE SERVED AT ADDRESS STATED PRIOR TO EXPIRATION DATE. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 8.06 5.00 10.00 .00 4l.06 '~~. R. Thomas Kline Sheriff of Cumberland County PARK LAW ASSOCIATES 04/27/200l Sworn and subscribed to before me day of this A.D. Prothonotary EXHIBIT ~ \ - ,~ " , ,l ''''1ili1l1l,hj, " AFFIDAVIT Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she is the attorney for the Plaintiff in the foregoing matter; that she is authorized to take this affidavit on its behalf; and that the facts contained in the foregoing Petition are true and correct to the best of her knowledge, information and belief. Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. VALERIE ROSENBLUTH PARK, ESQUIRE '. ~"",";l CUMBERLAND CountY,Court Of Common Pleas FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA l724l DEFENDANT NO. Ol-l772 CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a} A check of the local telephone directory shows that ROGER A HOOVER is not registered with a telephone number at the address of 68 STAMY RD, NEWVILLE, PA l724l . b} notation Forward" A letter addressed to the Defendant with the typed thereon" "Address Correction Requested, was not returned by the Post Office. Do Not c} A letter addressed to the Office of Voter's Registration shows ROGER A HOOVER is not a registered voter with an address of 68 STAMY RD, NEWVILLE, PA l724l. The Office's response is attached hereto, made a part hereof and marked as Exhibit "A". d} A letter addressed to the Assessment shows ROGER A HOOVER is at 68 STAMY RD, NEWVILLE, PA l724l is attached hereto, made a part hereof Office of the Board of the owner of the property The Office's response and marked as Exhibit "B". - ~ . ~l , . ~;,-~'_'I e) A letter addressed to the Postmaster shows that mail addressed to ROGER A HOOVER at 68 STAMY RD, NEWVILLE, PA l724l is delivered. The Postmaster's response is attached hereto, made a part hereof and marked as Exhibit "C". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S.A., Section 4904, relating to unsworn falsification to authorities. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF '",^'-' ~ l -. , . ~ -",.;\ " J 9ARKLAW ASSOCIATEO A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK' ROBERT E. ANGST' TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 "ALSO MEMBER NJ BAR +ALSOMEMBERFLBAR May 8, 200l Voters Registration Office Cumberland County COurthouse 1 Courthouse Square Carlisle, PA l7013-3387 RE: ROGER A HOOVER 68 STAMY RD NEWVILLE, PA l724l OUR FILE NO: 24543-1 Dear Sir/Madam: I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the address for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Very truly yours, PARK LAW ASSOCIATES, P.C. BY: Tracy Williams Legal Assistant Enclosure EXHIBIT t\ Name of Person: ROGER A HOOVER Current Address: Date of Registration: Date of Birth: Previous Registration Address: Cl (~~Ic:((a::lvob-& ~{! 'i'SfiCU hue - lJxj/lbL ~ O}iNt.. - (Q...J-e( ~((Q::i to-~::on lS nest U,X'(\\:Xf-lcurO- ~,*LI \~. ~~"i8lJ'iAU~~l'AIJ-in~''iWiY.~;'!I~Iol, "'~"""""tMl . ., L 0........... , . ~-" ,- ~~, " -~ -.~ o - ~,...."'" HAY 1 4 2001 AiNnO::J (]nE!'Jl~n:J I (:i dOl A \I;': IDOl " , ~ _. I L , . .. ,. ~ -" ~ t- \ii- '1 "". QARKLAW ASSOCIATE. '-~~ A PROFESSIONAL CORPORATION <" 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENIlLUTH PARK' ROBERT E. ANGST' TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 . ALSO MEMBER NJ BAR +ALSOMEMBERFLBAR May 8, 2001 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013-3387 RE: ROGER A HOOVER Dear Sir/Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 68 STAMYRD NEWVILLE, P A 17241 Please note the name and address of the owner-below and return this letter to me in the enclosed self- addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES,P.C. Enclosure Property Address: 68 STAMY RD,NEWVILLE, P A 17241, Name of Owner: Address of Owner: Deed Book and Page No.: ElM'S'" co - Jj, r FacetWin Screen priOfor public, from "CAMA_Login" 000/2001 3:03:52 PM CUMBERLAND COUNTY ASSESSMENT OFFICE ,. CONTROL # 30000110 . DISTRICT: 30 - NORTH NEWTON TOWNSHIP SD: 1 PARCEL: 30-08-0593-005. I SPEC ID: LOT: Short Name HOOVER, ROGER A ' Tback: I I I LAST NAME HOOVER PROPERTY TYPE: R FIRST NAME ROGER A C/O NAME & GALE M GUTSHALL SALES ADDRESS1 DEED BK/PG, . . . .0036B-00676 ADDRESS2 PO BOX 173 DATE OF SALE.. .12/31/1992 POST OFFICE: NEWVILLE SELLING PRICE: 800 STATE & ZIP: PA 17241 Situs: 68 STAMY ROAD J CURRENT VALUES ~ Prop Descri p. : Assessed Fair Market LAND USE TYPE: 101 FMV - 70730 L - 35000 NEIGHBORHOOD: 30 C&G - B - 35730 DEEDED ACRES: 2.70 approved? -> T - 70730 Screen 1 Enter Selection> Record: 56039 Number -Switch Screens, X -Exit, J -Jump Mode, F - Forms, I -Image Down Arrow -Next Entry, Up Arrow -Previous Entry, ? -Screens, B -Browse l"1~"""' Ii ,-, , , . t" At!,' '. . . . . . PARK LAW ASSOCIATES ;.., A PROFESSIONAL CORPORATION 2S EAST STATE STREET. SUITE 101 P.O. BOX 1779 DOYLESTOWN. PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK' ROBERT E. ANGST'" TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 .At.SOMEMllERNIBAR +ALSO MEMBER!'L BAR Postmaster United States Post Office NEWVILLE,PA 17241 May 8, 2001 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Our file #: 24543 NAME: ADDRESS: ROGER A HOOVER 68STAMYRD NEWVILLE, PA 17241 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney): 3. The names of all known parties to the litigation: FIRST SELECT, INC. VS. ROGER A HOOVER 4. The Court in which the case has been or will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifYing nnmber if one has been issued: 01-1772 6. The capacity in which this individual is to be served: Defendant WARNING TIlE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. (TITLE 18 D.S.C. SECTION 1001). I certifY that the above information is true and that the addre8s information i8 needed and will be u8ed solely for service of leg a proce~s in connection with actual 'Jf r~ective litigation. S ! '~ 25 East State Street V. ene Rosenbluth Park, Esquire Doylestown, P A 18901 FOR POST OFFICE USE ONLY _No change of address order on file. NEW ADDRESS OR BOXHOLDER'S REGISTERED ADDRESS _Not known at address given _Moved, left no fOlwarding address. _No 8uchaddre88 u . POS1MARK: ." .WHAT COUNTY IS TIllS ADDRESS IN? {l rvJd4AIl C63 . .._~...u THIS IS AN AITEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Q",P-~ f\D~~\~~ ~ ~~Mlii.~il~~Jti!@f.11L~~a~,-,,;,,,;,i;',"'\[h:'~"'Ji'M#~i1rll--i11I~-'-' ~ "",~:,J J~tL.,..1 "[I c.."'.... ;: ", ,.J \ 1:" r VI ~!' \ << '. IJJrL~_~~~, _>^~~, ~.." "~~ ~,,= , ..__' ~ ~, ~_ " .~~ n"; ~. 'itl'rr'!i"'I'h~~IlIl""'"'~'-'. ~ c, ~.... o '.' ~ :~:- >~~' );~ ~;:~ :~ .-< rtto.'f 1 8 2t}tt\ ?, ~.""'<""'."."'....'..'.'...... . . , ',": . < . < . c :. -.,,", ...;-~ '-;-'" ~ ',"~ c:::' -":">0\ s_~ ~ (,::; l!!l L- . ~ _J: ~ ~~ d~..} VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box l779 Doylestown, PA l890l (2l5) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA FIRST SELECT, INC. Plaintiff VS. ROGER A HOOVER Defendant NO. Ol-l772 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTRY: Please reinstate the enclosed Civil Action. Respectfully submitted: PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~~ili<<;;!I$>':,~,H"h",ci<:->lI<iif,""*J'll~~Ol."1it~ill~,t~,*,L:.w".'",,,:o.,~--,;,;"!Oit!~'~i<-",;",~~ll!;,j~~1lil!Jltii I '~ot'" ' "" -,~~~ " Ili\<l.~~' ".....~ ~.-I ,,-,' " 0 C) c:: () -0=5: ~f'] '- mF::: (-:: L-:'T1 .,,{'.. ~ 'r-: Zi" N ,~3r :':2:2:' C:) "' ,~.. ~c .---- () PC, '...-' 'T --,,~ , - ZC" :o~_:() J;:' 1';-;) C~ s:~ 1"71 :s :n ~. -< (::> xi -<: ~~ =,." ~'I.~' .." ""''''"'''''''''''......''"'''''_.."4"~'"~"~ '".." ,. ,~~- " ~~ i ~,I ~, '.....- ....-nl,. k-~,i . .., VALERIE ROSENBLUTH PARK, ESQUIRE PARK LAW ASSOCIATES, P.C. ATTORNEY I.D. #72094 25 E.' State Street P.O. Box 1779 Doylestown, PA l8901 (2l5) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FIRST SELECT, INC. Plaintiff VS. ROGER A HOOVER Defendant NO. Ol-l772 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did serve the Defendant ROGER A HOOVER , at last known address located at 68 STAMY RD,NEWVILLE, PA l724l, by United States Certified Mail, Return Receipt Requested, Postage Paid, and First Class Mail with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter and with the appropriate Notice to Plead as set forth in Pennsylvania Rules of civil Procedure. Service by mail was accomplished on 06/29/200l in accordance with Pennsylvania Rule of civil Procedure and the prior Order of this Court allowing for alternate service. Proof of service by Certified Mail is attached hereto, made 'a part hereof, and marked Exhibit "A". Proof of service by First Class United States Mail, Postage Paid is a Certificate of Mailing attached hereto, made a part hereof, and marked Exhibit "B". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of l8 PA C.S.4904 relating to unsworn falsification to authorities. P.C. BY: VALER ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF .~.."~~< " "'...~ ,~~~ ~ " v Postage $ $0.55 Certified fee Cl Re'i:um ReceIpt fee Cl (Endorsement Required) Cl Resbicted Delivery fee Cl (Endorsement Required) $ n.95 Cl Total Postage & Fees ..D 1TI Cl M Cl Cl ["- :u ~XHIBIT ~ ,~.l..--.kl~ ~ " '. TJ m cii 3 Co) ~ :-a -n " C" 2 " .:c ~ "' "' ... ~-g "" ~z ~o ~g. w. il." .2. 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'" -I K'" ! ," . ,l"1 ~ VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, FA l890l (2l5) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 68 STAMY RD NEWVILLE, PA l724l 4l68l000l2337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS ROGER A HOOVER Defendant NO.Ol-1772 PRAECIP!E FOR JUDGMENT TO THE PROTHONOTARY: I 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: $10,372.99 $1,763.00 $1,093.57 ($0.00) ($0.00) $13,229.56 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 (lO) 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.l is attached hereto and marked Exhibit" .w: 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, fJrr!l 'l , 0200 I , Judgment is entered in favor of the PIa ntiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. , .L_~~:,; . (L-L, J2 ~ 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. -,""""~ ~. ,,~ -0 .= _. I I , " I_~ ~~~~"i ~ VALERIE ROSENBLUTH PARK ATTORNEYLD. # 72094 PARK LAW ASSOCIATES,P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 1&901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS I'HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 68 STAMY RD NEWVILLE, P A 17241 FIRST SELECT, INC. Plaintiff VS ROGER A HOOVER Defendant NO. 01-1772 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: ROGER A HOOVER 68 STAMYRD NEWVILLE, P A 17241 DATE OF NOTICE: 7/20/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITIllN 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, 41h FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT A ~ "'""""~'" ,.,-~~~.- ~ -, , u . ~l_~..,.,L; VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA l890l (2l5) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 68 STAMY RD NEWVILLE, PA l724l CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS NO. Ol-l772 ROGER A HOOVER Defendant 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 ROGER A HOOVER, Defendant is over 2l years of age; that his/her place of residence/business is located at 68 STAMY RD NEWVILLE, FA 17241 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 SSOCIATES, BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 -~ ~~~~, II ~' ~,..l, j . ~. ~,,; . . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA l890l (2lS) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 68 STAMY RD NEWVILLE, PA l724l CUMBERLAND CO~Y COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS NO. 01-l772 ROGER A HOOVER 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: (2lS) 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. .~iiliillli~jilMlMillii~@f~~~_im"'t;:H~"j.:t,;"t"""d;.ll"0""",,".-_Lj, :Jd<'",,"~~." - ,~,' ~, "'''' .,~~ "",' """"-"_~'_~"'''''' _, ''-,,,~_h-.-'' &." .iii' ~~" ;,- ,'- -. i ,"-~"",---," < . I t jV (J ~ ~ (") C) r'....... It=- ~ c ':"F; :;: l'!: -;-1 - ""t:JC.c ~ L~, "Ti r" [!l (l) c;, "t~ ....... Z.J_' I ~ ~ Zt;-" <~J ...... ~~~." ...j ~~l ~ ~ r:: CJ 3> -~ -0 :-'-,,,;,1 Iv ~ -...'- ,,- Zl..' -"'. 5~~ IlJ' V. ~~ -.-0 r- :PC: "" - :z N "., ""'c.!t.:. :;! 0 ~ " '"",, ".,' ,,", . . '. .,~. "CO _""",_"~ -, ',_. . ._ n' "" ".C~ ~ , .> '" ,,~,,~_o_._-. ,. ,.. ~,~,,_ ~,:) "'L. , ,; ,~~~,. <J.;,L VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA l890l (2l5) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC Plaintiff VS ROGER A. HOOVER Defendant NO. Ol-1772 PRAECIPE TO MARK JUDGMENT SATISFIED, SETTLED I DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark the above captioned matter satisfied upon payment of your costs. PARK LAW ASSOCIATES, P.C. BY: h ~/ VALERIE ROSENBLUTH PARK, ESQUIRE >- t:s ~?:: ~J'~~ (. ~', V;) ~ ~ 54: Oz ':_14: '::13 ?~~ iL1LLl Y)Q.., ~ ::::;J <:.) 9 -;::) :>~ ""-J ....;:'u L,,' . - ^-",~ ,~ ,-' I"-~_" ~