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HomeMy WebLinkAbout01-03328 ~ .t:0~~" , 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 PROVIDIAN NATIONAL BANK Plaintiff VS. KIPP E ZAHLER G()~ (/~ Defendant NO. 01- dJ~rf NOTICE: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . 'I) ~ r ,_~ T' . ....~,..,.,..=~ , 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#:4428671059924708 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS KIPP E ZAHLER 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 DEFENDANT NO. 01. 33.2S' ~ -r~ CIVIL ACTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, KIPP E ZAHLER, has a mailing address at 583 GRAHAMS WOODS RD, CARLISLE, PA 17013-8942, 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or authorized by the Defendant on a credit card or line of credit owned by the Plaintiff bearing account number 4428671059924708. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i~h .t' ~ .~"'"'- - ,~"""~ ., , ~~- ~, . - 4. The Defendant requested an account, account number 4428671059924708, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit "A" and made a part hereof. 5. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the outstanding debt as agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $9,609.07 as of 03/06/2001, plus pre-judgment contractual interest at the rate of 23.30% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,633.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $9,609.07, plus pre-judgment interest at the contractual rate of 23.30% per annum from 03/06/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,633.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT I - ALTERNATIVE 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as though set forth in full. 9. The 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~;,~~ - ~.- 'r'"" I '^--' ~ . - . and/or knowingly and voluntarily accepted the benefits bestowed. 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $9,609.07, plus pre-judgment interest at the contractual rate of 23.30% per annum from 03/06/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,633.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERI 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 ORDER FOR SERVICE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -,,~~~- ~ "' ._0 '" " ~" .".... cKt%,;j;2~i\R':~)';;;t'ii~l;:j" VERIFIcATION I, HEATHFR KOQREM.^.N , declare that: I am a Designated Agent of PROVIDIAN NATIONAL BANK, the Plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in Date Designated Agent ~1:,_:", ~~ ~, . ,~ -", , - "- ~ .- ,<. PROVIDIAN EXHIBIT k . Previdian National Bank VISA@ or MasterCard@ Account Agreement for Kipp E Zahler January 26, 2001 Please review this document and keep it with your other important papers. This Account Agreement contains the tenns which govern your Previdian National Bank VISA or MasterCard Account fthe "Account"). The Account allows you to make purchases by using your VISA or "MasterCarQ card (the "Gard") wherever it is honored and to get cash advances from us or any other partici~ng fiDanClal institution and from Automated Teller Machlnf es. Convemence checks may also be provided 10 you as an additional way to use the Account. In this Agreement, "you" and "vou~' mean each person or whom we have opened a credit card Account. ''We,'' "our," "oursJ" and "us" mean Providian National BanR or its assignees, as "sted on your billing statement. The Account may be used only for personal, famllrltihouseholu, and charitable purposes, and not for any business or commercial purpose. Any use of this Account shall constitute accepfance of the tenns 0 is Agreement. You and we agree as follows: Payments. You will receive a monthly statemen.t showing your outstanding balance. PaYl1)ent on thi.s Account is re.. quired in U.S.' dollars (checks must be ~vable at a u.S. office of the bank the check is drawn on), for at least the'payment due as shown on your statement by the paYl)1ent due d<ile In accordance wiID Piilyment instructions on your monthly statement. The back of your statements shows the. rules we follow when we post payments, Convenience checks and other checks we issue to you may nolbe used to make payments on your Account or to make payments on any otheraccouht you have with Us or our affiliates. The payment due will be: 2% of the new balance shown on your statement plus the ~mount of any past due payr)1ent, and may include the amount by which the new balance exceeds yourcreditline. However, the payment due will not be less,than $15 (unless your new balance~ is less thahn $15, iD which case the payment due will be the amount of the new balance1- If your Account is past due,or above the creait line, we may l!equlre a igher minimum paY!J1ent, bul we will notify you before doing so. If your paymenl is more than the payment due, It will be treated as a single payment and none of it will be appli~ to future payments QUe. we may ~t late or parnal payments, or payments marked paid in fuil" or ma~ed witn other restrictions, without losing our nght to collect all amounts owmg unaer thiS Agreement. . . Finance Charges. Except as describad in the Grace Period for Purchase Balance section of this Agreement finance charges begin to accrue on a debit when It is incluaed in one of your daily balances and continue until that balance Is reduced by a p. ayment or creait. Your Account has the foilowing balances: The Purchase Balance which consists of your existing Purchase Balance and new purcnases you make with your Card and fees for certain optional services; one or more ustom Cash Advance Balances which consists of balances that you transfer to your Account using balance transfer checks and balances that we trans er or yo ; an e a nce Balance which consists of ail other cash advances and cash. aovan'ce transaction fees. Any Qayment amount we receive that exceeds me IInance cnarges ana fees then due wiil ordinarily be apQlied first to the BalanCe with the lowest Annual Percentage Rate (APR1, until that Balance is zero, and then fo the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balance. We reSeNe \fie right 10 apply payments differently without further nolice. The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by pljyments as of the date received, and by credits as of the date posted. Purchases are included in your Purchase Balance as of the date made. . Custom cash advances are included in your CustolJ) Cash Advance 8alance as follows: funds electronicallY transmitted to other lenders to transfer balances, as of the date transmitted; checRs to transfer ibalances, as of the date gresented to us. Other casn advances are included in your Cash Advance Balance as fellows; cash advances from other fmal\lCial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are identified as cashie(s checks and mailed to you at your r[!quest, as of seven days after the date we print on the chec~ all. other checks, as of the date presented to us. Other debits are included in your Purchase, Custom Cash Advance or Cash Advance Balance as of the uate posted. Finance challJ!ls are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last day of the billing cycle. There. is no grace penod for custom cash advances or other cash advances. To figure the daily finance charge for each ~ of Balance, we start with your previous day's Balance add all debits and subtract all credits for the current day and multiply the net a!'Jounl by the applicable daily penodic rate (see following parag[!1phs). The finance charge for each type of Balance is then added to and includ6d in that days Balance. we.treat a cni<:lit balance for any day as zero. We detennine the total fin<\nce Charges. on balances for the billing pycle by adding t9961her tl\e finance charges lor each type of Balance fer eech day within the billi!1Q cycle. In ca~ulating finance cll~ an adiustmenl will J be made for any li1msaction or payment that would have affected the finance charge calculation in a prior billing cycle nad it been postea in thal c;ycle. The applic~le daily pariodic rate for such a transaction will be the rate in effect for the current billing cycle rather than the rate in. effect on the date of the lfansactlon. Your statement includes an average daily balance for each tvoe of Balance. You can multip,lyeach average dfiily balance that is not zero by the number of daysb.iln,. the billing cycle and the pariodic rate to obtain subtotals.. and then add the subtotals together to defennlne your total finance charges on balances for the I In9 cycle. If a cash advance transaction fee is charged, rrlat amount is also a finance cnarge. The tenn "Prime Rate" as used in the Agreement means the highest pnme rate published in the Wall Street Journal on the first business day of the previous palendar month. Any increase or decrease iD the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight Increase or decrease m the amount of your minimum payment. The ANNUAL PERCENTAGE RATE (APR) for purchases is 7.9%, corresponding to a daily periodic rate of 0,02164%. YOU can arrange to have a vanable APR for custom cash advaQces that is lower than the weighted average of the non-introductory APR you have been Qayl1ng on the total balance~ Y9U have transf~ from other credLt card\tiretail, and Installment accounts proVided your other accounts were open in JanufllY 200 . In calculating this APR we will take Into account the APRs on e credit account balances you have transferred from other lenders This APR is available only if you provide proof in the form of copies of your most recent billing statements, showing your othernOn-introd~tory APRs. Your new APR will. bde variaoleJ_basSd on .Pnme Rate and Will take etfect in. the billing cycle follOWing our review of y.our P(QQ.f. but nQ! earllel lall the en.d of your courtesY peno . If we uu not receive such proof your APR for custom cash ad\tances will lie as follows' The ANlIIlJAL PERCENT GE RATE for custom casn advances is 21.99%, corresponding to a deily periodic rate of 0,06025%.' . The ANNUAL PERCENTAGE RATE for cash advances Is 21.99%, corresponding to a daily periodic rate of 0.06025%. If we receive your Account paymept late 2 or .more ~m~s in any 6-month !Jened, op each such occurrence we mllY .increase the APR for purchases up to a maJqmum 0If2233'3030o~ (corresponding toa qally p~nQdlc rate of 0.06384Yolt and mcrease the APR for cash adVances and custom cash advances up to maJ(lmUlll 0 . ,. (ccrresP.CT1ding to a daily penodlC.rate of 0,06384%). after you receive the hjgher rales yourpa,ymenls are received on time and you meet all other tenns of .thlS Agreement, for 3 consecullve months, you may contact our Customer salVlce department and at your request we will review your Account for a posslbie APR reduction, . " Grace ~erio~ for Purchase Balanc~. Ne:ov purchases posted to yoyr Account in blllingcyq1es with no previous balance or when the previous balance was fully paid d~nng the cycle do not begin to l\)Cur a finlll1Ce cha~ until the start of the next.billlng cyqIe. You will pay .no nnance charge on such new pUfircnases Ihf you pay the 1011I1 new be anpe In full by the payment due date shqwn on yo~r statement. New purchases posted in any other billing cycle incur a Inance c arge, and there Isno paned In which such purcnases may be repaid without InculTing a finance charge. Fees, We may charge your Account $0 for: each Card you ask us to replace; each retumed payment. each check you write on your Account that we retum unpaid; each stop payment order or renewal of such an order; each billing cycle within which your AccOunt is delillCluent (late charge); and each billing cycle (Continued on revelSe) (5846-0698) 4428671059924708 1531 561rs028 ':~WII;f ;:"('\'~lW'C""""'I"W1V~IWi'll;1'flI'lj"il~il'1_!~~~~I4!'I!UI'~~I'!"'~.. 1 ~=, ..- _"~,,~ ""~~=="'l'~~,,",,~ , "",~~~~~r. -"eC__ within which your balance exceeds your credit line (overlimit fee), even if your Account is closed. If you request copies of biiling stat.ements.that were filllt sent to you mare than three months earlier, we may charge a Mandling fee of $2 far each such copy. If you request that:He m~ke a one-time automallc pa~ment from your personal checking account, we may charge your creait card account a fee of $4.95 far each request. This fee IS a FINANCE CHARGE, ana it will applY regardless of whether funds are ava"able in your personal checking account to make the payment. We maY ,harge a transaction fee Qf 3% (minimum $5), which is a one:time FINANCE CI:IARG~, an the amount of each cash advance, including cash from financial mstifutions, and A TMs, wire transfers, money orders, lottery tickets, casmo gaming ChiPS, and similar transactions. Defaull You will be in default: if any information yOU provided us p'roves to be incomplete or untrue; if you dfQI ndotbcomply w.itht any pa(\f of thbisl.Agreamenta; \IP.9llyour death, bankruptcy, or insolvency; if YQu (10 not pay ather aebts when due; if il ba.nkruolcY petition is Ie. y or agams you; or I we. e leve In goo faith that you may not payor perform your otiligatlons uncfer thiS Agreement. If you are In default we may, Wltholit furtlier demand or notice, caefncel your credit privileges declare your Account balance immediately due and payable and use any reme!:iY we may have, In the event of your dault, the outstqnding llalance on your Account shall continue to accrue interest at theAPR(s) disclosed In the Fmance Charges section of this Agreement, even If we have filed suit to collect the amount you awe. Credit Line. Your credit line is specified from time to time in a separate notice. Your monthly statements shaw your credit line and the ar)1ount of Yllur ava"able credit. We. may increase or decreese your credit line based an information we obtained from you or YQurcredit. records. Your available credit IS normally the-difference between your credit line and your Account balance (including transactions made or authorized but not yet eosabtled). dilf you sebndlus a iarge payment check, we may Iimi.t your ava"able credit while we confirm fhat the check wiil ciear. For certain transactia,nl s'lavared" .te cre It may e ess. You will not use your Account far, and we may refuse to honor, any transaction which would cause you to exceed your aval au e c I. Promise to Pay. You p(OIll\se to pay us when due all amounts borrowed when you or someone else use VO\lr Account (even if the amount charaed exceeds your permission), all other liansactions and charges to your Account, and collection costs we incur including, but not limited to, reasonable attomey's fees and court costs. (If you win the suit, we will pay your reasonable attorney's fees and court costs.) . Changes. A!\er we p'rovide you any notice f!lCluired by law, we may change any part of this ooreement and add or remove requirements. If a change is made 10 the Finance Charges section of this Agreemeri~ the new finance cnarge calculation will apply to your entire Account balance from the effective aate of the change. Changes Will apply to balances that inc,uda items pasted to your Account before the dale of the change, and will apply whether or not you continue to use the A"ccount. . Foreign Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U.S. dollarsb. the transactions will be converted to U.S, dollars, generally using, either a Ii) govemment-mandated rate or (ii) wholesale market rate in effect the day efore the transaction is processed, increased by three percent (j%). If a credit is subsequently given for a trimsaction, it will be decreased by the same percentage. The currency conversion rate used on the conversion date may differ from the rate in effect on the date you used your Card. You agree to accept tfie converted amount in U.S. dollars. The Card I' Cancellation. You may cancel your credit p.rivilrnes at any time b~ notifying us in writing and destroying the Cardls). Upon the Card e@irationat the end 0 the mon shown on it, we reserve the ri lit not 0 renew lhe ara. We may cancel the Card and your creditp 'vileges at any time after 30 days notice to youl or Wlmout notice if permitted by law. qf ~our ard is cance9led or not renewed, finance charges and other rees will continue to be assessea, payments wll continue to be due, and all other applicable provisions of this Agreement will remain in effect. If you terminate your credit privileges, or if we cancel or do not renew the Card, you may no longer write checks on your Account, and you should destroy any unused checks we have Issuedlo you. Personal Information; Documents. you will provide us at least to days notice if you change YQur name, home or mailing address, teleJ;lhone numbers, employment or. income. Upon our request, you will provide us additional finan. cial informanon. We reserve the right to obtain information from others, in_Qluding credit reporting agencies anc to provide your agdress and information ~out your Account to others. We may also share information with our alfiliates, However, you may write 10 us at any time lnstructing us not to share credit Information with our affiliates. If ypu dO not fulfill your obligations under this Agreemen~ a negative credit report that may reflect on your credit may be submitted to the credit reporting agencies. Customer Service;. Unauthorized Use, Loss or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safecusrding the Card.. , your Personalldentifica~on Number I"PIN", which provides access to Automated Teller Macliinesl and any checks issued to you fromlheft, and keeping your PIN separate from your Card. I you discover or suspect that your Card PIN or any unused checks are lost or stolen or that there may ba an unauthorized transaction on your Account, you will promptly notifY us by caning .1-80b-933-7221. So we can immediately act to Iimi\ losses and liability/., you will phone us even though you may also notitv us In writing. You will not be liable for unauthorized use occurring before you notify us of a loss or thell If you report or we suspect unauthonzed use of your Account, we may suspend YQur credit privileges until we resolve the problem to our satisfaction or issue you a new Card. If your Card is lost or stolen, you will promptly deslr'ay all checks in your possession. To improve customer service and security, you agree that your calls may be monitored or recorded . Merchant Relations. We will not be liabie if any person or Automated Teller Machine refuses to honor the Card or acceJ;lt ypur checks" or fails to return the Card to you. We have no I'$$l)Qnsibililv for gooOs and services purchased with the Card or checks except ~s required by law. (See "pecial Rule below.) Certain lJe~efils that are available with the Account are proVided by third-party vendors. We are not responSible far the qua ity, availability, or results of any of the seMces you choose to use, Stop Payment Orders. It you wish to stop payment on a check, you may send us a stqp P!I~t order by writing to us at our address for customer setVice listed on your~tatement. You can make a stop DllVI11ent order orally by. calling thenumtier listed. on your statement. When you make a stop payment order I you must proVide your Account number and speciffc information abOut lhe check: the exact amount, the date on the check, the name of. the ~ to whom i was flByable, the name of the person who signed it, and the check number, You will be asked to confirm an oral stop. payment order in writing. We may disregai!:l yoyr oral order if we do not receive a signed written confirmation within two weeks after the oraborder, or II we have not received an adequate dascop.tion of the item so that ll8Ymant.qan ~ stopped. T~e order will not be effectiv.e if the check was ~id y us !lefore we had. a rea~onable opportunity to act 00 the order. We may, WithOut liability, disregard a wnllen stop payment order SIX months after receipt unless It IS renewed In wnting. Standard of Care. Because this Account involves both credit card and check transactions which are processed through separate national s~stems before the transactions are consolidated by us, and because not every check and Card slip '11111 be sent ki us, transactions In YQur Accounl will be processed mechanically with04t our necessarily reviewing every item, Our processing system Will call our attention to certain items Whi.ch we wil examine. We will examine I' all transactions when you [llport that your Card or checks have been lost or stolen. We do not intend ordinarily to examine all items, and we will not be nag 1gent If we do not do so. THIs rule establishes the standard of ordinaN care which we in good faith will exercise in administering your Account. Because of our limited review, and because neither your cancelled checks norC'ard transaction sliD!! will be returned to you with the monthly statement you should be careful to enter all checks in your check ~ister or othelWise keep a record of them. You should also save your credit card c~sh advance and purchase slips. You agree to check your monthly statements against your record and to notify us immediately of any unauthorized transactions or errors. Wai1/llr of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without lasing our light to enforce it or any other proviSion latar. You waive: the ~ght to presentment, demancJj pro!est,or notice of dishonor; any applicable statute Of limitations' and any right you may have to require us to proceed against anyone before we file SUI against you, .' !\ppllca~le Law' ~everability; ~signmenl NQ matter where you live, this Agreement and your Account are govemed by federal law and by New Hampshire law. ThiS ~9.reemen! IS a final eJg:1resslon of the a!lreement between you and us and may not be contraCicted by evidance of any allegild oral agreement. If any proViSIon 0{ thiS Agreement IS held to be Invalid or unenforceable, you and we will consider that provision mOdified to conform to ap'jllicable lav.:, and the resl of the proVlsiQns,ln the Agreement will still be enforceable. At any time after.we determine in good faith. that any Ilroposed or enacted legislation, regulatory acDon, or JudiCial daclslon has rendered or may render any ma1enal provIsions of thiS Agreement Invalid or unenforceable, or Impose f"~~. 1 ~'.. , ., ~ " ~ ~ ,~, ~~ ",",,","," , PROVIDIAN . any increased t/IXj reporting requirement, or other burden in connection with any such p'rovision or its enforcement, we may, after at least 30 days notice to If you, or without no ice if permitted by law, cancel the Card and your Credit privileges. We may transfer or assign our right to all or some of your payments. state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you suc~ notice by filing a financing statement with the state's Secretary of State. Notices. Other notices to _you shall be effective when dep,oslted in the mail addressed to you at the address shown on our recordsl unless a longer notice period is specified in this Agreement or by law, which period shall start upon mailing. Nonce to us shall be mailed to our address or customer service on your statement (or oUler adaresses we may specify) and shall be effective when we receive it. . YOUR BILLING RIGHTS.. KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. NQtify Us in Case of Errors or Questions Aboqt YOII' Bi/l. If you fhink ~our bill is wrong or if you need more information about any transaction on your bill. write us on a separate sheet, at the address listed In the Billing Rights Summary on your bill. Write to us as soon as possible. We must hear from you no later than 60 days after we sent you the first bill 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 information: - Your name and Account number. - The dollar amount of the suspected-error. -- Describe the error and explain, if you can why you believe tnere is an error. If you need more information, describe the item you are not sure about. If you have authorized us to p'ay your credit card bill automatically from .your checking account, you can stop' the payment on any amount you think is wrong. To stop the payment, your letter must reach us three business dBys before the automatic payment is scheauled to occur. Your Rights alld Our Resp.rl/'l.sibilities 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 0111 was correct. After we receive your letter, we cannot try to collect any amount you queslion, or rep,ort you as deiinquent. We can continue to bill you for the amount you question, including finance charges, and we can app,ly any unpaid amount against your credit line. You do not have to pay any questioned amount whne we are investigating, but you are sli11 obligated to pay tlie parts of your bill that are not in question. If we find that we made a mistake on your bill, you will not have to pay any finance charge related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you 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. If you lail to pay the amount we think you owe, we may rep,ort you as delinquent. However, if our el,(planation 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 !"!!port you to that you question your bill. And, we must tell you the name of anyone we ~rted You to. We must tell anvone we report you to that the matt:er has been settled Detween us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct. Special Rule for Credit Card Purchases. If you have a problem with the qualilY of the property or seryices that you purchased with our credit card and you have tried in good faith to correct the problem with the merchant, you may not ~ave to pay the remaining amount due on the goods or services. There are two .limitations on this right: (a) you mus.t have made.the purchase in your home statil, .or jf not within your ~ome state, wilf1in 100 miles of your c4rrent mailing address: and .(b) the purchase pnce must hqve been more than $50. These limitations do not apply If we own or operate the merchant, or If we mailed" you the advertisement for the property or selVlces. T5028 , "'flJ,J,i ~ '" " ,..Ja.. - i ~!llJIl! ": -, .-.- v"", ,,,,,,",,,-,..-,,,,,,,,,,,,,,"", 4: ! ! I I I: Ii i! II II '. Ii il, ~".~~" !" ~ " _ _~H. ~ " (J p -Iq. to ~ fi:- f{ r> vtO 8 8 ~ .:::::- It> --. , I "-> --. fV) 1.) !:6 ~ '~ :g --:t:- i~'"i\ S;;' ~~~ r::~ "'- J> ;C~; C) ~; C) -) .' 18 c~'" :.:( ~o ~.Alffi.,..,,,,,, _" "r'~''''''''''''_'"- "~_ ~~~1;~Ili1~'II*Ij\f~Jliilf*-"",,,,,,.,,,~,,"~..,li[J1F"i'F-'>f'r.iffa!!m~%l;ljl!'<i~""iom~~r;I~'\'i'tf!~!liIW>~~1 SHERIFF'S RETURN - REGULAR CASE NO: 2001-03328 P , . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS ZAHLER KIPP E RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ZAHLER KIPP E the DEFENDANT , at 1838:00 HOURS, on the 8th day of June , 2001 at 583 GRAHAMS WOODS RD CARLISLE, PA 17013 by handing to KIPP ZAHLER 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 4.96 .00 10.00 .00 32.96 r~.-e,,-t:~ R. Thomas Kline 06/12/2001 PARK LAW ASSOCI Sworn and Subscribed to before By: me this ,U <e day of ~ :l-uvl A.D. ~ Q. 7J1Ji~._,~ P 0 honotary ."",-. . ~ ,,~ ..~, 'I =~ ~'- ~ /... -... <tommonweaftfj <t)f ~en1t5l'f"ania . COUNTY OF CUMBERLAND COURT OF COMMON PLEAS NO. 01-3328 Praecipe for Writ of Execution PROVIDIAN NATIONAL BANK plaintiff vs. KIPP E ZAHLER Defendant 583 Grahams Woods Road Carlisle, PA 17013-8942 and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee 4 M8.rket Way Mechanicshurg; PA 17055 TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County; (1) against MEMBERS 1ST FEDERAL CREDIT UNION garnishee(s) (2) AMOUNT DUE $ $12,009.56 INTEREST AT 6% PER ANNUM from 07/16/2001 $ PLUS PRIOR COURT COSTS $ PLUS COSTS OF EXECUTION $ (TO. BE COMPUTED BY PROTHONOTARY AND --tS'1'.45" SHERIFF) \ jL-- Attorney(s) for Plaintiff 'ij:--- "cLtL ~ ~ ~ ., ~" . ~ ~," '4 ',h' '", .'-f ',.' '-~_,L"_'" ,"",' '"'''' '~'-C~~/"' '-"-"-"--" ,"-~-"~ "'-"-' ""'~'''''{!~'-'',, '!iT" '"~-_. IlnWJII") ~. J' 1<0 ~ ~ fL C) ~ b ~ (') C) ~ V} ~ ..0 ~ fv ;~ ~ ~ ."i """ d , I ""00:; --.:1 W J: '" "- 0 01 ...0 U m". :,.iI:J G'\ 0 z"'r-'\ ,- )..j () Ii' C f' :z~ I ~- r0 ~ I'-~ "'" ~ () (J)~,; co "."j ...... ( I -,<_c_ !:~.~~:> ~ -.() I I , r:::C c7 ~~~~; ~ r~ ~O -...- ......;) " fjJ ~ -0 {..) .. ... J>c ~ l' ~ " ~ :z c. ~ ~ ~ ..,-..1 -< " ~ - .~ ~ ..... ~ "'- n!r,'''\~~'m,,-_ _7__ . _J!II!I!~~fJi'f;,'~':<""'!';"if';"~"':I"""~H,,",,;c>5-q"-,"l"""""-;')'V';.!:{"-'HfF~fJl;~Ff,,;I"l!',~.ft'fJ{},!irm~i't'''W'lil;:;0'~.aw!';,fi~~~_itM~~J WRIT OF EXECUTION and/or ATTACHMENT '. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due PROVIDIAN NATIONAL BANK, Plaintiff (s) From KIPP E. ZAHLER, 583 GRAHAMS WOODS ROAD, CARLISLE, P A 17013-8942 NO 01-3328 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant (s land to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1ST FEDERAL CREDIT UNION, 4 MARKET WAY, MECHANICSBURG, PA 17055, GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $12,009.56 L.L. $.50 Interest AT 6% PER ANNUM FROM 7/16/01 - $459.45 Arty's Comm % Arty Paid $105.46 Plaintiff Paid Date: APRIL 8, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division BY: ~<1~ P 77;~~A<'~~ REQUESTiNG PARTY: Name VALERIE ROSENBLUTH PARK, ESQUIRE Address: 25 EAST STATE STREET P.O.BOX 1779 DOYLESTOWN, PA 18901 Attorney for: PLAINTIFF Telephone: 215-348-5200 Supreme Court ill No. 72094 t'''~L~,,___,J.8 ,.- - ~- t 't SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-03328 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS ZAHLER KIPP E And now BRYAN WARD ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:48 Hours, on the 12th day of April , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT ZAHLER KIPP E in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FED CREDIT UNION 4 MARKET ST MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to TODD SHIMKO (SUPPORT SVCS) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 S~~ ~ rr~ 'l-C~~ R. Thomas Kline Sheriff of Cumberland County 00/00/0000 this 17 'Z;: day of a,,,1 ;)",,;L, A.D. ~.. ()-7h,,;;~.) ~ Pro onotary , By /~ ~~)~ J Deput~ Sheriff Sworn and subscribed to before me ?,"~,~""~-, -~~ <~ ." ,n, '.. , .....," '^1~ "~ ,._ . .. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 4428671059924708 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAHLER Defendant NO.01-3328 PRAECIF,E FOR JUDGMENT TO THE PROTHONOTARY: \ please enter Judgment in favor of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS $9,609.07 $1,633.00 $767.49 ($0.00) ($0.00) $12,009.56 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 COMPLAI~T. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237._l is attached hereto and m rke xhibit "A". TOTAL VALERI ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW, ~ t L~ / G.. ,~ , , 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. ;,-"ft,1<~~~~ ','~ _ . "v...l .~- ...~..._,,.,,,.,,.,,.=lL~ ~ ,!!);ltg.", .' ~"1- - n,d;,2 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. ~;'J!_ .' , .,.,,_.4..,,!>!,~mrlCl:l!I.I!lI, --". " ~ r'!~ , ~ _~;.., u _ .h . '. ^~'~~"'m ~ I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAlN STREET TILTON, NH 03276 DEF: 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 VALERIE ROSENBLUTH PARK ATTORNEY !.D. # 72094 PARK LAW ASSOCIATES,P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATIORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAHLER Defendant NO. 01-3328 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: KIPP E ZAHLER 583 GRAHAMS WOODS RD CARLISLE, P A 17013-8942 DATE OF NOTICE: 6/29/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITIIIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WTIHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th 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 ~ ~ ~ ",~_" m_ '" , .1 VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAHLER NO. 01-3328 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 KIPP E ZAHLER, Defendant is over 21 years of age; that his/her place of residence/business is located at 583 GRAIlAMS WOODS RD CARLISLE, PA 17013-8942 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 ASSOCIA;Jf' P. C. BY: e&cLJ, ------ Valeri osenbluth Park Attorney for Plaintiff EID " -;-'fl'~!"~""-'T'''''''~"=' 1l1" ,~" ~" -,,,,,",,,,,,,,,, . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAHLER NO. 01-3328 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 ~OTICE, 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. ;"1i\!i'~4jI!!%.l " ~~ _ . _~, __\I!l!Iftlr_~ . ... ..~ "'~ ~,",-~" ~ ,","'It ~ . 1'l'IlOO_ '" - ~'--"~ ~" '" ,-. __,""~c_.'_"_~ .'~"~-'",-,,,-,- ""'-.'.,;__"'~~____~"," ---'.,.c,c_'-''''.-..... "'~-'.,""'''--' "''','-, c (0 () .(q. ~ fl:. ). ~ r " ~ ~ ~ :z; ~ F -. ~ N !? ~( r- ~ I u' . , ,.~ ..c_; -- ---~ -< '.J ~. "-' _!tlil'~,... ,2WJ!!\!I!i~l'!~~jIN!i~~~'1'~J:f"1""\"'-'"":<';;;1'flo'-"I'.~,,,,:~1}1i"!!;'i'<lY~"!Wt"'''~l",m;!!,!'[''ffi'~~~~ , , VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIP? E ZAHLER Defendant NO. 01-3328 PRAECIPE TO DISSOLVE ATTACHMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly dissolve the attachment entered against , Garnishee only in the above captioned matter. Respectfully submitted, PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQ. -, -"1, ~ J ~ "'~ - ,~ , r 1 - ~"'''''''~, .i~ .~- '" ~,~. .-~. -"~ -.~<' .,,,, . ~ ,~.""!"'" )WI~o~~,,,,,,,,,,""r"-.~ ~''"' ~",~,.- ""'~-""'__ "". >>~'~','",.r>\-,,-r.,. '.. - .,. N~~ ~t~ !::l 0 ~FE! i? ~ ...t:::: r J (} c <' ,)I"~{- [nfr .,2:.::;.:. 0~'- ~< r:::'-- ~"-. C;C: ..:......,......, 5> ~"'~.~ Z --, -< - ~._"~ _. '~,.-'" -'-'"' ,,< 0.,) C8 ~~.~ '--1", 1"...') .; ~.< ['1; '-."~ -:r::~: >> --< ~..,.,~!i!l~,jj~fij!r~l;1'IIf)iWWi!m'-li'''''"''P~'f"~+;''' "'"."':,,, 'f~'z"",,:r:=,~%'l'~c';~i,,,,:w,""'!11E",J,"~~,"~.~'~~!~.I1!R~ , .. 'Ii' Wl ([5.) = Ibf.h, Ibf.h, ~ '-1"'~J~_, _~ ~~,_ !'!1iI R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee 18.00 1.53 .50 1.00 8.28 20.00 20.00 9.00 78.31 Sworn and Subscribed to before me this I A-k dayof ~ 2003 A.D. ~Q. ~.PP,. ) ,~ pro onotary . Advance Costs: Sheriff s Costs: 150.00. 78.31 71. 69 Refunded to Atty on 3/21/ 0 3 ~ '- So Answers; Vv ~. 'V r.- ~..~~/ R. Thomas Kline, Sheriff , I' BY(~ rrii;Z{;,,-, l{ ~6~ \j \ 'A&1 lb!:Ql (i'5) = il-fb., {1!i:=J (]::;?) . 'J \01 -j d ~\ \ <._ ,_, \ 'C, :J \j \. \'k ~~f" ',i', ,,: \'<~ ',~': 7\\ \\~ as t, '-..-.'~ ' ~1\ii.V.\ :I:I\l.I3\\'> ,,,;\0 . h.,''':l'O .1\) ;1-'\ . I ,$1) ek. 'I 0 3 J..D IlL. /3"- f ,'/ ~. ~, L<~.~ ." ,~,---, . .--~, ,- '~,. , ,. ~_..',,,~ ... --'. ^ -- <'>,-~'''C';. -"" '.,-~1='~.~,,,-"r."'-' ,,~"~ <. .-,-~.., ' ~ ~,=,~-~-<-,~"","""".",. '-'-" .-,''''; -,,'~ ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANTA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PROVIDIAN NATIONAL BANK, Plaintiff (s) From KIl'P E. ZAHLER, 583 GRAHAMS WOODS ROAD, CARLISLE, P A 171H3-8942 NO 01-3328 Civil CIVIL ACTION - LAW (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1ST FEDERAL CREDIT UNION, 4 MARKET WAY, MECHANICSBURG, PA 17055, GARNISIIEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $12,009.56 L.L. $.50 Interest AT 6% PER ANNUM FROM 7/16/01 - $459.45 Atty's COlnm % Due Prothy $1.00 Other Costs Atty Paid $105.46 Plaintiff Paid Date: APRIL 8, 2002 CURTIS R. LONG Prothonotary, Civil Division ~: 40'1-0 - P. 71;.Il/MY' r: J)~~ REQUESTING PARTY: Name VALERIE ROSENBLUTH PARK, ESQUIRE Address: 25 EAST STATE STREET P.O.BOX 1779 DOYLESTOWN, PA 18901 Attorney for: PLAINTIFF Telephone: 215-348-5200 Supreme Court ill No. 72094 .'- "~",j_~~.~~~_~~~ ",. JJ_.W;f~~f,lIOlR'lMllIIJ~.~n[~':,.",,_~l~~,'~,~~W;W)lff'i'!c""h.,,"''''''Fe'r'-" ,-"-~j'-' -'-"'~~f""'.i~*",fl.!tiMJJrH!j'~'\'~~~""frp:"1""'~'I'iWf~~'