The URL can be used to link to this page

Home My WebLink About01-2679 FX i. 4 Ron Z. Opher, Esquire Attorney for Plaintiff Attomey#57507 P.O. Box 2245 Southeastern, PA 19399 (610) 902-0530 FIRST SELECT, INC. 4460 Rosewood Drive Pleasanton, CA 94588 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. CIVil.. ACTION - LAW DAVID R FORDYCE 3023 HARVARD AVE APT 2 CAMP HILL, PA 170115237 NO. /':)/- :1~19 ~oJ'--r-'Tfi-Y{ Defendant COMPLAINT - CIVil.. ACTION NOTICE TO DEFEND A VISO You bave been sued in court. If you wish to defend Le han demando a usted en la corte. SI usted qniere defenderse against the claims set forth in the following pages, de estas demandadas expuestas en las paginas siguentes, usted you mnst take action within twenty (20) days after tiente veinte (20) dias de plazo al partir de la fecha de la this complaint and notice are served, by entering a demanda y la notification. Hace falta asenlar una comparencia written appearance personally or by an attorney and escrita on en persona 0 con un abogado y entregar a la corte filing in writing with the court your defenses or emorma escritas sus objectiones a !as demandas en contra de objections to the claims set forth against you. You su persona. Sea avisado que si usted no se defende, la corte are warned that if you fail to do so the case may tomara medidas y puede continuar la demanda en contra suya proceed without you and a judgment may be entered sin previo aviso 0 notification. Ademas, la corte puede deCldir against you by the court without further notice for a favor del demandante y requiere que usted cumpla con todas any money claimed in the complaint or for any other las provisiones de esta demanda. Usted puede perdes dinero 0 claim or relief requested by the plaintiff. You may us propriedadedsu otros derechos Importantes para usted. lose money or property or other rights important to you. LLEVE ESTA DEMANDA A UN ABOGADO YOU SHOULD TAKE lHIS PAPER TO YOUR INMEDIATAMEN1E. SI NO TIENE ABOGADO Q SINO LAWYER AT ONCE. IF YOU DO NOT HAVE A TIENE EL DINERO SUfoFICIEN1EDE PAGAR TAL · LAWYER OR CANNOT AFFORD ONE, GO TO OR SERVlCIO, VA YA EN PERSONA 0 LLAME POR TELEPHONE TIIE OFFICE SET FORTH BELOW TO TELEFONO A LA OFFICINA CUY A DIRECCION SE FIND OUT WHERE YOU CAN GET LEGAL HELP. ENCUENTRAESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. CUMBERLAND COUNfY BAR ASSOCIATION 2 Uberty Ave Carlisle, PA 17013 (717) 249-3166 ASSOCIACION DE LICENCIADOS DE CUMBERLAND 2 Liberty Ave Carlisle, PA 17013s (717) 249-3166 '"-, .-", ] -, ~l .,......" .. Ron Z. Opher, Esquire Attorney for Plaintiff Attorney #57507 P.O. Box 2245 Southeastern, PA 19399 (610) 902-0530 FIRST SELECT, INC. 4460 Rosewood Drive Pleasanton, CA 94588 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. DAVID R FORDYCE 3023 HARVARD AVE APT 2 CAMP HILL, P A 170115237 Defendant No. OJ- ;((,,79 fJ...;;;( --r:-_ COMPLAINT - CIVIL ACTION COUNT ONE 1. The Plaintiff herein is FIRST SELECT, INC., a Delaware corporation located at 4460 Rosewood Drive, Pleasanton, CA 94588. 2. The Defendant herein is DAVID R FORDYCE, an adult individual located at 3023 HARVARD AVE APT 2, CAMP HILL, PA 170115237. 3. Plaintiff is the owner of Defendant's credit account number 4168100113666992. 4. The Defendant, at all times relevant hereunder, knowingly requested the funds at issue, and knowingly and voluntarily accepted the benefits bestowed and the terms and conditions linked thereto. 5. The balance due and owing on said account as of April 5, 2001 was $8019.54. A true and correct copy of an account sununary is attached hereto and marked Exhibit "A". 6. Under the terms of the parties' agreement, additional interest has accrued, and continues to accrue, from April 5, 2001, at the rate of 18.00% per annum. A true and correct copy of the relevant account agreement terms is attached hereto and marked Exhibit "B". 7 . In addition, Defendant agreed to be liable for Plaintiffs actual costs of collection, including court costs and attorney's fees. See Exhibit "B". -" ~""",e ~~, _" , _ _ , ," )--1 . , - - , - ~1 ~, ""'" -.- r \ 8. The actual attorney's fees in this case are contingent on recovery, at 10% of amounts recovered before entry of judgment and 30% of amounts recovered after entry of judgment. 9. Plaintiff has in all respects fulfilled all conditions precedent to its obligations on the contract and forbringing this Complaint for damages. 10. There is no offset known to Plaintiff on the amount setforth in Paragraph 5. 11. Despite repeated demand by Plaintiff, Defendant has refused and continues in failure and refusal to pay Plaintiff. WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $8019.54, plus interest at the contract rate of 18.00% per annum commencing on April 5, 2001, plus attorney's fees at the rate of 10% pre-judgment/30% post-judgment, and costs of this action. COUNT TWO Plaintiff also claims alternatively on the basis of quantum meruit or Quasi Contract. 12. set forth. Paragraphs 1 through 11 above are incorporated herein by reference as though fully 13. Plaintiff was neither a volunteer nor an officious intermeddler. 14. Plaintiff is the owner of said credit account. 15. forth above. Plaintiff expected payment from the Defendant for said credit in the amount set 16. The amount claimed is the fair and reasonable market value for said credit. WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $8019.54, plus interest at the contract rate of 18.00% per annum commencing on April 5, 2001, plus attorney's fees at the rate of 10% pre-judgment/30% post -judgment, and costs of this action. Dated: April 30, 2001 BY /Do Ron Z. Opher, Esquire Attorney for Plaintiff ;t", , , I'-f' ' , ~ ~-"""" JANET ANSTEY TCSI 001 CODE IHB ACCT 4168100113666992 CYCLE 05 AGENT 0747 ( 12 MONTH HISTORY )::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: PAYMENT SCREEN SELECTION ( 1 2 3 4 ) MIN PYMT PURCHASE CASH ADV CREDITS MISC CHG INS FEE LATE CHG OVRL FEE PURC F/C CASH F/C LIMIT BALANCE CURRENT o .00 160.00 o .00 o .00 o .00 o .00 .00 .00 .00 .00 343.92 1.00 8,019.54 (01) 04/05/01 (02) I 0 I I .00 I I 160.0~ I .00 I o I .00 I o I .00 I o I .00 I .00 I .00 I .00 I .00 I 120.15 I 1.00 I 8,019.54 I 03/05/01 (03) o I .00 I 158.00 o .00 o .00 o .00 o .00 .00 20.00 .00 .00 107.04 1. 00 7,899.39 => FORDYCE DAVID R 02/05/01 (04) 01/05/01 o I 0 .00 .00 310.00 I 305.00 o I 0 .00 .00 o I 1 .00 I 7,635.62 o I 0 .00 I .00 o I 0 .00 I .00 .00 I .00 20.00 I .00 .00 I .00 .00 .00 116.73 I .00 1. 00 I 1. 00 7,772.35 I 7,635.62 :::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ::::::::::::::::::::: ";H ~ "'""" ..II""' -I,t rc'.'CC ~B c... I.. aD 00 "6IT,,~ r I 4 FIRSI_SELE.CT IMPORTANT LEGAL NOTICE <; Federal!a" giveS you 30 days a:l\er you receive this letter to dispute the validity of the debt or any part ofiL If you do not disp11te thevalidity of the debt, or any part ofit, within !hat period, we willllSS11ll1e that ~'e debt is valid If you dispute the debt, or any part ofit, in writing-by mailing us a notice to that effect on or beforethe 30th dayfollowing the date you re<:eived this lellc;r-wewill obtain and mall to you proof(vermcauon) of the debt And if, wi~Un the same period, you reqnest in writing the name and address of the . original creditor (if diif~t Ii'om the CUIIl>ll1 cred~or), we will furnish you with thet infonneuon too. Ifwe do receive a timely written notice. all efIbrts to collect this debt will . besuspendedunti!wemili.anyrequiredinfonnatiOl'toyou.. . . ...... . The purpose of this communication is to collect a debt; any infonna~on obtained will be used for collecting the debt. .' "ACCOUNT AGREEMENT Your ASSOCIATES sceount bas been Irll1lSferradto First Select. Your ASSOCIATES s.c:<:oui1t was closed at thetime of this 1ransfer and will therefore eontinue to be closed.. This Aecount Agreement contains the tenns thet govern your Fim Seleataccount ('the h Account". In this Agreement, "you" and "your" mean - each person who is liable for payment on the Account. ''We, II "our.1t and "usll mean Pint Selector its assignees. Because your Account has been transferred to u~ you are now obligsted to repaytbe Account to us instead of ASSOCIATES. rfthe Account was opened.. a joint acccunt, we may act on the instructions of any joiut sccount bolder. . Pay:men.fslFlnance Otarges.. As long as you have a balance outstanding on your Account, finance chllQles .... calculated .. follows:. . . To figure the finance eharges for each bi11inli cycle, we multiply the average daily balance on your a_ by a dallypllriodicrate. The dally.periodic rate we apply is your Accounl'a Annual Percenlage Rato divided by 36S. The AnnualPeroentage Rate will b. calculated .. di",IOllld in yourmoslllOCatlt ASSOCIATES accOunt tenus (the "Original Tenus'~. If your Original Tenns providedfor di1ferent Annual . Perceritage Rates to be.app1ied todifl'erent.componenlsotyotll',outatanding balance, w. will'applythe lowestailchA11nual Poreentago Rato OIl your entireoutaflulding .. balance. We may accep11ate orpartial paymCll14 orpaymen1s marked "paid in fullll or marked with otber resIricti_ without losing our right to collect ali amounls owing underthis Agreement. . Y. OIl may askFirst Se1ectto pay your Account by debiting your ebecking or savings 'account.: F'1rIlt Seloct'wiIllirst verifYy<iur identi1y and .1i1dbi1ity fortbis service. You may revoke youraulhorizationby writing to First sefect Customer Service. . . . Fees. W. will charge your A<:count a feefor each billing cycle within which your Account is delinqueat(late charge). The amount of the late charge will be.. . disclosed in your Original Terms or the maximum late eberge peoni!ted by the law ofyouratate ofresidence, whicheveris lower. . .. w. will charge yolU' Aix. ount... a feefor eachreturned paymeDt cheek (ret\lmed cheek ~e} Theamountofthe returned cheekcharge will be as diee10sed in your . Original Torma, or the maximum retumed cheek chargepennitted by the law of your state of residence, wi1iebever is lower. To the _provided in yourOrigina1 Tenus and toth. extent permitted by applicable law, in addition to your obligations to pay the ontstanding balance on your Account, plus interest and fees as disclosed berein, we may ala. charge you for any collection COSlswe incur, incllUlingbntnot limited to reasonable attomey's foea and court costs. lfyourOriginal'Tenus provided for an award ofaltemey's te.. and court costs, such provIsionasin~ herein shal1 apply reciprocally to the prevailing party in ~y la.wsuit arismg out oftbis Agreement. "Non-Waiver or Certainltigbt$. . We may delay.or waive enforcement of any provision oflhis Agreement without losing our right to enforee it or any other provision later. . Appllcable~. SeverabDi~, Ass1gnmeat. No matter whare you Ii';'" this . AgreementsadyolU'AcClluat are governed by federal law and by1l1e law of the state de'signated asthe a11l'licable law inyolU' 0rigina1 Terms. If your Original Terms did nOl contain an applicable law provision, than this Agreement and your A<:count are g,?vemed.by ,federa11aw ~d thQ law of your state ofresidellce. 'Ibis Agreement is a fiilal ~onof~~ b~ you and us andmaynetbe contradicted. . by !""d,:"ce of any alio/Wd oral a_nont. rf a provisiou oflhis agreement is bald to be invalid or unenforceilble. you and we will consider that provision modified to eOI!form to applicable law, and the real oftbe provision in 1I1e Agreement will still ha eilfbrceeble. ~emay~!>!, asaill" our right to all or seme ofyolU' pa)'ll1en1s. If state law nqnuea t1latyou receive netice ofsuclt an event to protect the purchaaer or the assignee, we may give you such notice by filing a financing statement with the . stat... Secretary of State. .. .'. CUatomer Sam... Fer general qtlestionsregarding your First Select account, please call our toll-free service munber, 1-88S-924-2OO0. For qnality assurance pllIpOses, and to improve customer service and aecurity, telephone calls to or ftom our offices may be monitored or recorded. . . "~j~L _"~"' ~ , ,'f"'"'"~ = I . Credit Reporting: Peraonallnfonnatlon. If yon fail to fulfillthetenns of your credit obligation, a negative cred~ report reflecting on yolU' eredit record may be submitted to . credit repcrting agency. In order to dispnte any infonnation we are reporting abont your AccolUll, you muat write to us at the following address: First Select, P.O. Box 9104, Pleaaanton, California 94S66. We mav share information with OUT affiliates. inoludinll. without limitation. Prcmdisn National Bank and Providian Bank. However. 'YOU mav write to us atanvtime instnIctinl!: us not to Rhare credit infornurtion with CI11!' affiliates . YOUR BILLING RIGHTS -KEEP THIS NOTICE FOR FUTURE USE This notice eontaina imp'ortant infonnation abont your rights and our respOl1Slbllities underthe Fair Credit BlllingAcl. . . Notify Dsm Case of Errors or Questions About Your Bill If you think ~ bill ia wrong, or if you need mcre information ahont an emry on your bll~ wnte ua, on a scpara1e sheet, at the following address: First Select, P.O. Box 9104, Pleasanton, California, 94566. Writeto us as aoon.. possible. We moat bear from you no later1han 60 days..after wesentyou'thenm bill'OIl~ch1he'Orror or problem appeared. You cantelepbone n~ but doing so will not preserve yolU' rights. . In the letter, give us the following: - YournameandAccountnumber~ - Thedoilaramountofthesuapectederror.. . - A description of the error sad nnexp1anation, ifpoSatble, ofwltyyou believe there is an error. If you need more irifonnation, describe the item you- are not sure about. Your Rights and Our Responslblli~es After We R~eive Your Written Notice W. muataeknowledge y.,ur 1i:tter witbin 30 days, Ull!ess we have Con:ecled the error by than. Within 90 days, we muat either col1'eclthe atTOr or explain w~'we bolieve the bill was eotrect. Afterwe receive your letter, we cannot l1y to oo1lect or report yon as delinquent.. to any amount you question, including finance eharges. We can apply any unpaid amount againat your credit line. You do nOl bave to pay any questioned amount while we are investigating, but you are atill obligated to payth. parts of the bUl that.are aot in qnestlon. Ifwe find that we have made .inistake on your bill, you will oct baveto pay any finanee charge related to any questioned anlOUnt. Ifwe did nOl make a mistake, you may have to pay finance charges, and you will have to make up the missed payments on the questioned llIl1OlUIi. In either caae, we will send you . statement oftbe amount you owe. And the date that it is due. If you fail to pay the amcunt we think you owe, we may tq)ort you as delinquent. HQWeVer, irour explane1::ion does not satiafy you sad you write to us within 10 days t01lin~ us that you stil1 refuse to pay we must tell anyonewe report you to1bat you qnestionyour bill And we must t.n you the name of anyone we reported you to. We musttell anyone we report you to that the matter bas been settled between us wlten iffinally is. rfwe do not follow these roles, we cannot collect the first SSO dfthe questioned amount even if your bUl was correct.. . ' Special R1;de for credit Card Purehaies ,-~. If you have a problem wllh the quality of goods and awces that you purcheaed with yolU' ASSC?C1ATES credit can! and you have 1ried in goodAith to .COlrecttl.. problem Wltb themercbant. yon may nOlhave to pay the remaining amount due on the goods or services. Thare are two limitatlonsto this right: (a) yon musthave made the purchase in your home state or, ifnot within your home state, within 100 miles of your CUIIl>ll1 mailing address; and (b) the purchase price must have been more 1I1an SSO. TIles. limitations do net apply if.ellher we or ASSOCIATES OW11 or operate1ba merobant, or we or ASSOCIATES mailed you the advertisement for the property or services. .' t1l8,r nu~' I l- 1.::, <!f!1 , -~ ~,~ ,. = ~.' "- , . .1.(!f\ 1'1 : +, I 'F.!i'~~ \ VERIFICATION HEATHER KOOREMAN , hereby state: I, 1. I am an authorized agent of the plaintiff in this action; 2. I verify that the statements made in the foregoing Complaint - Civil Action are true and correct to the best of my knowledge, information and belief; and 3. I understand that the statements in said complaint are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to aut oritie . '-- DATED: 5/1/01 . ,. , >, " ....' ler" " -, . . Q t I 1",-, .," " . '__,^, ' [lJ, _.' , ~ ~~ ~ ........... ........ '........ ........ 'Iv ~ --", <__'O""^,~~"_"._._,._,, ",._,__&o",.".<_,,,,~.,,_y-,< ~" ~_ o ~~ ;:J rJ- rnr'~~ :.-:-::: :-J, ~~: Zl,! ,-u ..>c: 2: --j ~- 'IT'r1nlir , , C) 1;.:.- ..~-,. .", {G, C::' . .. ~C'~ ~ ~:!;~h-'{ ~ ~ ~ h ~C> Cj ,- ~ ' ct~() ~~ ~~ w N 2:"--1 5J -< :.oJ (":1 ,_-r,~'~<;""' _"M:!JI~~~!~t!li!lllll!t'Pl'Ni'F~"~j7.';l!)"""W,'R'-",;~'t""i"'i\Pj'Vr",",j'"f!,'Ii,Iij;j<,~~l@ll!"-1'"J"~~I""l;R!'l~~1ll~~i ,-, -" ~" SHERIFF'S RETURN - REGULAR CASE NO: 2001-02679 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS FORDYCE DAVID R STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FORDYCE DAVID R the DEFENDANT , at 0012:30 HOURS, on the 18th day of May , 2001 at CUMBERLAND CO. SHERRIF'S OFF 1 COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to DAVID R. FORDYCE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 , ~~r~c~:.., R. Thomas Kline 05/18/2000 RON Z. OPHER Sworn and Subscribed to before me this ':<3M-. day of BY:~ ~~ \ I, Deputy Sheriff ~ ~{ AD L.l a. 1M ,0&1:. " . ~rothonotary ,~ 'r~~ =~I.-_~ "' 1'1' , ~~ _'It ~,""'~ ( to- - ,~:" , ", ,~.~ Ron Z. Opher, Esquire Attorney for Plaintiff Attorney#57507 P.O. Box 2245 Southeastern, PA 19399 (610) 902-0530 FIRST SELECT, INC. 4460 Rosewood Drive Pleasanton, CA 94588 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. CIVIL ACTION - LAW DAVID R FORDYCE 3023 HARVARD AVE APT 2 CAMP HILL, PA 170115237 NO. 2001-02679 P Defendant PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, FIRST SELECT, INC., against Defendant, DAVID R FORDYCE, for want of an answer. Assess damages as follows: Debt Interest (per contract and complaint) Attorney's Fee (per contract and complaint) TOTAL $8019.54 $240.59 $2478.04 $10738.16 (plus 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 after the default occurred and at least ten days prior to the date of the filing of this praecipe. Copies are attached. R.C.P.237.1 /062' Ron Z. Opher, Esquire IV #:, 1:,07 Attorney for Plaintiff AND NOW ...J Lt.!. \c:' _ ::U.... , 20 1'lL , Judgment is entered in favor of FIRST SELECT, INC., against Defendant, DAVID R F'()lU)YCE, by Default for want of an answer and damages assessed at the sum of Ten Thousand Seven Hundred Thirty Eight Dollars And Sixteen Cents ($10738.16) plus costs as per the above certification. .. 1, 1" " " ,,-~,~' .. f OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE 1 Courthouse Square Carlisle, PA 17013 TO: DAVID R FORDYCE 3023 HARVARD A VB APT 2 CAMP HILL, PA 170115237 FIRST SELECT, INC. 4460 Rosewood Drive Pleasanton, CA 94588 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. CIVIL ACTION -LAW DAVID R FORDYCE 3023 HARVARD A VB APT 2 CAMP HILL, P A 170115237 NO. 2001-02679 P Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. {,/J.o!o/ ~k, Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL RON Z. OPHER, ESQUIRE, at 610-902-0530. - -::l\( >~ .,-^,,( ~, '1 -1' .: ' - ,,, "j - .. Ron Z. Opher, Esquire Attorney for Plaintiff Attorney#57507 P.O. Box 2245 Southeastern, PA 19399 (610) 902-0530 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA First Select, Inc. 4460 Rosewood Dr. Pleasanton, CA 94588 Plaintiff v. CIVIL ACTION - LAW DA VlD R FORDYCE 3023 HARVARD A VB APT 2 CAMPHllL, PA 170115237 NO. 2001-02679 P Defendant TO: DAVID R FORDYCE 3023 HARVARD A VB APT 2 CAMP HILL, PA 170115237 DATED: June 8,2001 IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HA VB FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Court Administrator's Office Courthouse, 4th Floor 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 :!$l..o_,,,"__, .~ 0 _,1lII ~ . ~ ,~ I, I" - " ~ ". "1,' , . .. \ ~,-- "-"--"'<'".' U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NO]. PROVIDE FOR INSURANCE POSTMASTER .':". 1 /~:~/;..-' !~,;/ fj..;.'; !Iv'/ l-""r---" \U1' \-;>.\ \..::..':....-- \-c~~-... , :,~::"r"-h R. Ron Z Opher, Esq. P.O. Box 2245 Southeastern, PA 19399 if~"","'I'-.." .'1 , _.' , I' " FIRST SELECT, INC. 4460 Rosewood Drive Pleasanton, CA 94588 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. CIVIL ACTION - LAW DAVID R FORDYCE 3023 HARVARD AVE APT 2 CAMP HILL, P A 170115237 NO. 2001-02679 P Defendant CERTIFICATION OF ADDRESSES AND AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS I, Ron Z. Opher, Esquire, being duly sworn according to law, depose and say that I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the address of the Plaintiff is 4460 Rosewod Drive, Pleasanton, CA 94588. Defendant's address is 3023 HARVARD AVE APT 2, CAMP HILL, P A i70115237. In addition, Defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 or the amendments thereto. I verify that the statements made in the foregoing certification and affidavit are true and correct to the best of my knowledge, information and belief; and I understand that the statements in said certification and affidavit are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATED: June 19, 2001 BY: Ron Z. Opher, Esquire ~ .,"~ ~[ ., --, ~ --,' ','>1"' ",,~ ~- '_ "..,,~~;,:~ '''-',', .' / ',' r \ '- ~ ~-{' . ~~ en I ;r ,.., - 1"., ~,.~.~~ ~ . 0' _". ~~." . , . ~ ~. '-><" '." "''''"'-' ","~., "",~,~,,,,,,*~,,. "".' ,=""~~ filiiu t (J <iq. ~ ...Q \ 8 () c::/ C <'"' r - lJfTj ..() U)11' ~~-- , t ~ "'-- ,; " ,gi5; /"'..) ~ '.J C) & <:- c., ~~ --.., ~ ~c;' >c.~ ~ ....... c:- w R~" L'::: .sj ~-I--.. ::::! =:> (11 ::':-0 -< ~ !!!'>-<~~, ~~_I,"~~~L. <!. ::'Il:sr~~,,,?:~Y~"""'"i'.i~,,y,,&,,,,,,1~,f,j2"J>,"r-.",-i_-'_'"c'''W,!,lil-1'l""~$WH'W"""lJ(fV-'''llfi'','t%3f''''W'''-0'~r~"l'ff&'l(l,ll@:~:'