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Home My WebLink About01-03329 ... \ 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 VS. APRIL WHITE: Defendant NO. 01- 2:102'{ Go'J..'T~ NOTICE: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or obj ections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -y ~ '0 ~ _ '. ,',-"" -',- ) ,__ w_, . " ~ ., ~.~ 0'- ~"',.,-,--. ... 1 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#:4168100013205578 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS APRIL WHITE 147 N EAST ST CARLISLE, PA 17013-2507 DEFENDANT NO. 01- ..13.29 &;xl ~ CIVIL ACTION 1. The Plaintiff, First Select, 'Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, APRIL WHITE, is an individual who resides at 147 N EAST ST CARLISLE, PA 17013-2507, 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 4168100013205578. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .0 -c''''T'"1'''' - -y~ , . . ~ " ~ '""",~ .. , 4. The terms of said account are stated in the documentation attached hereto as Exhibit "An. 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 $4,374.29 as of 01/11/2001, 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 $743.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $4,374.29, plus pre-judgment interest at the contractual rate of 18.00% per annum from 01/11/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $743.00, 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 this Court to allow the Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. !~-,'~"" . , . !- - , 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. WHEREFO~E, Plaintiff demands that Judgment be rendered in favor of the plaintiff, First Select, Inc. and against the Defendant in the amount of $4,374.29, plus pre-judgment interest at the contractual rate of 18.00% per annum from 01/11/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $743.00, 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. - -, ,-~__ ~,' ,. T'"'- ", -. , ., , 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 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 e of California. Date Designated Agent ,.-{., --~- '.' ./i~, ~_"",__ -! - .. ''''''''''''' H ~ ~. "h f\ - ~YHIBIT f_ ThlPORTANT LEGAL NOTTCE t Federal law gives vou 30 davs after vou receive this I,tter to dispute the validity of the debt or any part of it. If you do not dispute the validit of the'debt. or anv' part of it: within iliat period. we WIll assume that the debt IS vaM. .If y.ou dIspute the debt. or any part of q. m \mung-t mailing us a notice to that effect on or before the 30th dav folloWIng ll\e dat, you recelvea tlus letter-we WIll optam and 1]1aIl t9 Y.9u proof (verification) of the debt. And if. within the same period; you request m wntJng the name and addres~ of the qngmal creditor (if aifferent from the current creditor) we will furnish vou willi that lrt(onuatJon too. If we do reCeIve a umely wnnen nouce, all efforts to collect thIS debt will be suspended unUl we mail any required mfonuatJon to you. ACCOUNT AGREEMENT Credit Reporting. Ifvou fail to fulfill the tenus of your credit obligation. a negative credit report reflecting on vour credit record maY-:he submittea to a credit ~poning agency. lh order to dispute anv mfonuatJon we are reportmg about vour Account, vou must write to us at the following address: FirSt Select, P.O. Box 9104, Pleasanton. California 94)66. Sharing Information. We mav share infonnation with our affiliates includin without lnllltatJon Provl<tJan National Bank an roY! an . owever v u mav wn e to us at nv ume mstrucung us not to s are cre t I onnauon WIt our lates. YOUR BILLING RIGHTS. KEEP TillS NOTICE FOR FUTURE USE This notice contains important iDfonnation about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more infonuation about an enttv on your bill. write us, on a separate sheet, at the following address: First Select, P.O. Box 9104, Pleasanton, Califorrua, 94566. I 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 wl1icli the ,rror or problem appel)red. You can telephone us, but domg so will not preserve your nghts. In the letter, give us the following: - Your name and Account number. - The dollar amount of the SUS])ected error. - A description of the error and an explanation, if possible, of why you beheve there is an error. Ifvou need more mformation, describe the item you are not sure about. Your Ril!hts and Our Responsibilities After We Receive Your Written 'N orice We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either carree the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect or reQort y'ou as delinquent as to any amount you !l.uestion, incluiling finance charges. We can apply any unp:U;u amount against. your credit line You ao not have to pay any qjlestIoned amount while we are investigating, but yo.u are Still obligated to pay the parts of the bill that are not m questIon. If we find that we have made a mistake on your bill, you will not have to pav anv finance charge related to any questIoned amount. we 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 01 the amount vou owe. And the date that it is due. If you fail to pav the amoun.t we think you. owe, we may r~port you as delinQu~n( . However, if our explanatJOn uoes not satJm you and you "TIte to us within 10 days felling us that you still reliise tOfav, we must tel anvone we report you to that you question your bil. And we must tell you the name of anyone we reported you to. We must tell anvone we report you to that the matter lias been settled between u: wlien if finalTv is. If we do not follow these rules, we cannot collect the first $50 of the questioned amount even if your bill was correct. Special Rule for Credit Card Purchases If you have a problem with the quality of -oods and senices that vou purchased with your FIRST UNION credit card and vou have trie, in good faith to correct the problem with the merchanl, vou mav nc have to pav the remaining amount due on the goods or services: There are hvo limitations to tlus right: (a) vou must have made the purchase in vour home state or, if not within your home state. witlun 100 miles ofvour current mailing aMiess: and (b) the purchase price musfhave been more than 550. These lImitations c not applv if either we or FIRST UNtO;r O\\TI Or operate the merchant or we or' FIRST UNION mailed you the advertisement for the prope~ or ser'/lces. Your FIRST UNION accounI has been transferred to First Select. Your FIRST UNION account was closed at the time of tlus transfer and will therefore continue to be closed. . This Account Agreement contains the tenus that govern vour First Select account (the "Account"). In this Agreemen( "you" and "vour" mean each ,person who is liaole for payr;nent on the Account. "We," !lour," and I us" mean First Selecc or its assignees. Because your Account has been transferred to us. vou are now obligated to repay the Account to us instead of FIRST UNION. If the Account was opened as a joint account, we may act on the instructions of any joint accounl holder. PaymentslFinance Charges, As long as vou have a balance outstanding on your Account, finance charges are calculated as follows: To figure the finance charges for each billinjUil'c1e, we multiply' the average daily balance on vour account by a aaiLy periodic Jate. The 9aily Reriodic rate we .illJply is your Account's Anhual Percentage Rate divided bv 365. The AnnUal Percentage Rate will be Calculated as disclosed in your most recent FIRST UNION account tenus (the "Original Tenus"). If your Origiual Terwurovided for different Annual Percentage Rates to be applied to cli1rerent ~omponents of your outstanding balance, we will apPlv the lowest sucli Annual Percentage Rate on your entire outstanwhg balance. We mav accept late or partial payments, or payments marked "paid in full". or marked willi other restrictions, Wliliout losing our right to ~ollect all amounts owing under this Agreement. You may asK First :select to Q..~ your Account by debiting your checking or savinl(s account. -Fust Select will first verify your identity ana eligibili'tv for this service. You mav revoke your authorization "by writing to First Select Customer Service. Fees. We will charge your Account a fee for each billinlLcycle within which your Account is delinqjlent (late charge). The amount of the late cha'rge will be as disclosea in your Origiiial Terms or the maximum late charge pennitted bv the law of your state of residence. whichever is lower. . We will charge your Account a fee for each returned payment check (returned cheCk charge). The amount oithe returnecfcfieck charge will be as disclosed in your Original Tenus, or the maximum returned check charge pennittea by the law of your state of residence, whichever is lower. To the extent provided in your OrigijJal T errns and to the extent pennitted bv applicable law, in addition to vour obligations to pav the outstanding "balance on your Account. plus interest and fees as disclosed herem, we may also char..ge yoti for any collection costs we incur, including but not limitecrto reasonable attorney's fees and court costs. If your Original Terms provided for an award of attorney's fees and court costs, such provision as incorpoJated he.r,in shall :!PPlY reciprocally to the prevailing party m any lawsnit ansmg out onfus Agreement. Non-Waiver of Certain Rights. We may delav or waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. Applicable Law, SeverabilitYAAssignment. No matter where YOU live, tlus Agreement and your ccount are governed bv federal raw and by the raw of the state desigI)J!ted as the applicable law in your Ori!!ihal Terms. Ifvour Original Tenus did not contain an . applicable law provision, then this AgJ:eement and Your Account are -overned by federal law and the law of your state of residence. This Agreement is a final expression orthe agreement between YOU and us and maV not be contradicted by evidence of any' alleged oral agreement. Ifa provision ofthis agJ:eement is held to be invalid or unenforceable, vou and we will consider that provision modified to confonn to applicabie law. and the rest of the provision in the A-reement will still be enforceable. We mav transfer or assign our right to all or some of your pavments. [f stale law requires tliat vou receive notice of such an evenl to protect the purchaser or the . assignee. we may give YOU such notice bv tiling J. tinancing statement with the state's Secretary of Siate. Customer Service. For jjOeneral questions reg3rding your First Select account.J'lease ea our toll-free service nUffioer. 1-888-92-1-200 . For quality assumnce purposes. and [Q impro,e customer semce and secunt\d' telephone C:lfls to or from our 0111ces may be monitored or recorde . -'t.~Wl-. -" -'--~' -,- -, ." ." <- ,~, " ~III..~~ ~~~ iZl ~- ~ 1- ., n'. ,,,,.>,,,. ,,-~-,"- ,< -- '" ","O~~H -,,. ,-",--"'.__,,~.- '., .,,,. ,'~ -. """~'-O''',"'" " '--""liisC_"1tt''J~ 1 () ~ ~ ~ ~ h & " r:" rQ 0 6 - 8 TJ - ~ f~-': ~ ~ .. : , ....... I (I) ,: }.J }.J 1J - ~ ~ '-""" ~ 6' ' . ,- If' , '_'_.I ~:? -, ""- ):..: ~ C''-) ~J -< "j -< '-l, ~" ~ ';~~_ ~ ,~,~lI'Il"_",~_, ~ \.. .. .UltllJ"'_ ~" ' ~., w!'lii~~~-,,",,,,w.w,-,,,, ..q":,,_-'__'~-"'f'~~";'~i,,,"*~!~iff)'!lJ1lt_&~_<t~nm;jf;IWf'.,]J;P~~'iiif~~~ :<-',<',,1'0 SHERIFF'S RETURN - REGULAR CASE NO: 2001-03329 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS WHITE APRIL BRIAN M, BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WHITE APRIL the DEFENDANT at 0915:00 HOURS, on the 4th day of June 2001 at 147 N EAST ST CARLISLE, PA 17013 by handing to CHARLES BOYLE, ROOMMATE 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 18.00 3.10 .00 10.00 .00 31.10 So Answ~?J './ ~ ~~"J~"-f:.~~~ R. Thomas Kline Sworn and Subscribed to before me this ;,2S'cV day of 06/07/2001 'ARK LAW A~TES ~ By: f/I Deputy Sheriff ~ :kvl A.D. ~ntia~' o/Yi... ':-"','"........,~ ~~ -, I - ~ ~ ~~ l' ~~.._~~~ ! \ " 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: PLAINT!FF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 147 N EAST ST CARLISLE, PA 17013-2507 4168100013205578 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS APRIL WHITE Defendant NO.01-3329 PRAECIPE 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: $4,374.29 $743.00 $303.62 ($0.00) ($0.00) $5,420.91 PLUS ADDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the notice pursuan~ to Pennsylvania Rule of Civil .cedure No. 237.1 is attached hereto and marked Exhibit" I. 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,.... ),< Ii lb _, " ;:;)C>6! ,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. _7'%~~,~ ~~ .~~_" '~..,. -.,..,.,~" i- , ~ _ 'T +-,-, ~~ ~-~""~~,~~~ _H_ ~ I"?\~)I!L~ ,,<~,..,...~_ ~ ~VL/~j~.4 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. ,.,--,--- . -'1' ~, "'m~w "= ~ _ m ""~_n'''''''''--~~'' .~~ .~.. ~_.~~~ < ' ,'i~~ I HEREBY CERTIFY mAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD VALERIE ROSENBLUTH PARK ATTORNEY !.D. # 72094 PARK LAW ASSOCIATES,P.C. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY,COURT OF COMMON PLEAS PLEASANTON, CA 94588 DEF: 147 N EAST ST CARLISLE, PA 17013-2507 FIRST SELECT, INC. Plaintiff VS APRIL WHITE Defendant NO. 01-3329 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: APRIL WHITE 147NEASTST CARLISLE, P A 17013-2507 DATE OF NOTICE: 6/26/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITIIIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE, PAl 7013 (717) 240-6200 PARK LAW ASSOCIATES,P.C. BY 1!1- ~// VAL E ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~XHIBIT fI-- ,-, , , ,-< - -!: ~~I~ ,~_~~ ~~ ~_ , 1,~ttTI-'~,""~=. , ~',' . 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 HERE~Y CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 147 N EAST ST CARLISLE, PA 17013-2507 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS APRIL WHITE NO. 01-3329 Defendant VERIFICATION 0," 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 APRIL WHITE, Defendant is over 21 years of age; that his/her place of residence/business is located at 147 N EAST ST CARLISLE, PA 17013- 2507 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 an its amendments. PARK LA AS IATES, BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 " - =, .- ~ "~'"" ~"" Wi"'_L , . VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 147 N EAST ST CARLISLE, PA 17013-2507 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS APRIL WHITE NO. 01-3329 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 Ver4ict [ ] Judgment on. Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on.Judgment Note [ ] Judgment on writ of Revival [ ] Praecipe to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. P PURSUANT TO THE FAIR DEBT COLLECTION 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. ~ '- , ~ _ r - ,. . -~ ~ - ~~~,-< ~~~~, _,RI!ll ~" ' 'I ,- <, ~ H. , '^-'-, ,-,,,, -",,, ,~, "'i""',,_ '"~"'''--''''~~'''~"''''''~-'''="~~'..OIfllJlllll[((ufJ&t' ~ . . ~ t ~ ~ C) c: -:\ 0 .. (). lJ.::;fP r :;-;.;;..--- 9J / .......... u;"- - C' ~ ... ~ ~ l::~-: i,_ ' 3 ZS c ~ r ./',- flf '-t .- :."J - 1- ~- .~< c::) "'_'''''''''''_'T= .1I'l',,~,1IQlIIIi'. <:;l!1 "~M""~~it'11H,'f'*':;1;I'",,,W'i'-1:;r,'p,!"i~"-~'-':"~1':,m~1!!~~,~~J~II~J~ll!111~t~