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HomeMy WebLinkAbout01-04629VALERIE 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 CUMBERLAND PROVIDIAN NATIONAL BANK Plaintiff VS. RYAN H HURLEY Defendant ESQUIRE COUNTY COURT OF COMMON PLEAS 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. 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#:4428232900215067 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS RYAN H HURLEY 106 W BIG SPRING AVE NEWVILLE, PA 17241-1609 C~ ~~~~~ DEFENDANT ' NO. ~~~ ~ ~ ~ I 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, RYAN H HURLEY, has a mailing address at 106 W BIG SPRING AVE, NEWVILLE, PA 17241-1609, . 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 4428232900215067. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT.. PURPOSE. 4. The Defendant requested an account, 4428232900215067, which is owned by the Agreement was sent to the Defendant. A attached hereto as Exhibit "A" and made 5. The Defendant has failed to pay the with the Account Agreement and has fair debt as agreed. account number Plaintiff, and an Account copy of the Agreement is a part hereof. amount owed in accordance .d to pay the outstanding 6. The Defendant is indebted to the Plaintiff in the amount of $3,204.74 as of 06/26/2001, plus pre-judgment contractual interest at the rate of 21.90°s 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 wX11 incur attorney's fees in the amount of $545.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $3,204.74, plus pre-judgment interest at the contractual rate of 21.90% per annum from 06/26/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $545.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT 2- 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... 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 $3,204.74, plus pre-judgment interest at the contractual rate of 21.90% per annum from 06/26/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $545.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: V RIE ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. V$RIFICATION I, HEATHER K(1pREM~4N 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 the ~Stat¢~of California. Date Designated Agent ;a~~~ ~~ta ~ ~ ~~ ~~: i s '~.APdKRUP7CY t~IM . ae~?.•v+.- :,,ma.;, ;rr.-arrt,'~~aww'~aawmn~arw:~FSSa~ ~~.~~,~sa»vaq. . ,~~^ 'iUPROVIDIAI~ Financial we we WIII notify you I ire payments due. ~Iledt atl amounts o 2°h a ~ ~ _~~: Providian National Bank VISAO or MasterCardO Account Agreement for Ryan H Hurley January 8, 2001 ~ your other important papers. This Account Agreement contains the terms which govern Your Providian National account"). The Account allows you to make purchases by using your VISA or MasterCard card (the "Card") nces. from us or any other participating financal institution and from Automated Teller Machines. Convenience ~addihonal way to use the Account. In this Agreement, "you" and " our" mean each person for whom we have 'ours "and "us" mean Providian National Bank or its assignees, as listed on your billing statement. The Acrount ehold, and charitable purposes, and not for any business or commercial purpose. Any use of this Account shall lreement. You and we agree as follows: ament showing your outstanding balance. Payment on this Account is required in U.S. dollars (checks must be 'k is drawn on/ for at least the payment due as shown on your statement by the payment due date in accordance latement. The back of your statements shows the rules we fallow when we post payments. Convenience checks fie used to make payments on your Account or to make payments on any other account you have with us or our new balance shown on your statement plus the amount of any past due payment, and may include the amount dit line. However, the payment due will not be less than $15 unless our new balance is less than $15, in which of the new balance). If your Account is past due or above 4he cretlyit line, we may require a higher minimum I so. If your payment is more than the pa ment duery it will be treated as a single payment and none of it will be cept late or partial payments, or payments marked paid in full" or marked with other restrictions, without losing this Agreement. the Grace Period for.Purchase Balance section of this Agreement finance charges begin to accrue on a debit ces and continue until that balance is reduced by a payment or credit. Your Account has the following balances: your existing Purchase Balance and new purchyases you make with your Card and fees for certain optional ice Balances which consists of balances that you transfer to your Accaant using balance transfer checks and as vance Balance which consists of all other cash advances and cash advance Vansaction fees. Any e finance c arses and fees then due will ordinarily be applied first to the Balance with the lowest Annual s zero, and then o the_ Balance with the next lowest APR, until that Balance is zero, and then to any remaining :ash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date posted. in your Purchase Balance as of the date made. Custom cash advances are included in your Custom Cash Advance Balance as call transmitted to other lenders to transfer balances, as of the date transmitted; checks to transfer balances, as of the date •asfi advances are included in your Cash Advance Balance as follows: cash advances from other financial institutions and through if the date made; cash advance checks made payable to Vou that are identified as cashier's checks and mailed to ycu at your s after the date we print on the check all other checks, as of the date presented to us. Other debits are included in your Pumhase, or Cash Advance Balance as of the date posted. Finance charcLes are added to your Purchase, Custom Cash Advance, and Cash day and are then posted on the last day of the billing cycle. -there is no grace period for custom cash advances or other cash To figure the,daily finance charcrqte for each type of Balance, we start with your previous day's Balance, add all debits and subtract all credits for the cunent day and multlpl the net aY ouni by the applicable daily penodic rate (se yfollowing paragCaphs). The finance charge for each9 a of Balance is then added to and includedyin that da 's Balance. a treat a credit balance for an day as zero. a determine the total finance char es on balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle. In calculating finance charges, an ad'IUStment will be made for any transaction or payment that would have affected the finance chame calculation in a prior billing cycle had it been posted in that cycle. The applicable daily periodic rate for such a transaction will be the rate in effect for [he current billing cycle rather than the rate in effect on the date of the transaction. Your statement includes an average daily balance for each typpe of Balance. You can multiply each averagge daily balance that is not zero by the number of days irrthe billing cycle and the periodic rate to obtain subtota s and then add the subtotals to ether to de ermine your total finance charges on balances for the billing cycle. If a cash advance transaction fee is charged, that amount is also a finance c~iarge. The term "Prime Rate" as used in the Agreement means the highest prime rate,published in the Wall Street Journal on the first business day of the previous calendar month. Any increase or decrease in the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight increase or decrease in the amount of your minimum payment. The ANNUAL PERCENTAGE RATE CAPRI for~urohases may vary and will be adjusted each billingg cycle to 5.24°~ above Prime Rate but will in no event be less than 12.99%. Using this formula, tthe PR far purchases in the January 2001 billing cycle is 14.74°k, corresponding to a daily periodic rate of 0.04038"k. The ANNUAL PERGENTAGE RATE for custom cash advances (balance transfers) in the Custom Cash Advance #2 Balance may vary and will be ad)usted each billing cycle to 5.24% above Prime Rate, but will in no event be less than 12.99%. Using this formula, the APR for custom cash advances in the Custom Cash Advance #2 Balance in the January 2001 billing cycle is 14.74°~, corresponding to a daily periodic rate of 0.04036%. The ANNUAL PERCENTAGE RATE for cash advances is 21.9°k, corresponding to a daily periodic rate of 0.06000°k. If we receive your Account payment late 2 or more times in any 6-month geriod, on each such occurrence we may increase the APR for purohases up to a maximum of 18.90% (corresponding to a daily periodic rate of 0.051a 8 ~ and increase the APR for cash advances and custom cash advances up to maximum of 23.90% (corresponding to a daily periodic, rate of 0.06548 ~). ~I after you receive the hi her rates your payments are received on time and you meet all other terms of this A reement for 3 consecutive months, you may contact our Customer Service department and, at your request, we will review your Account for a possible A~R reduction. Grace Period for Purchase Balance: New purchases posted to your Account in billing cycles with no previous balance or when the previous balance was fully paid during the c cle do not begin to incur a finance charge until the start of the next billing cycle. You will pay no finance charge on such new purchases if you pay t~e Coto) new balance in full by the pa~ment due date shown on your statement. New purchases posted in any other billing cycle incur a finance charge, and there is no period in which such purr ases may be repaid without incurring a finance charge. Fees. We may charge your Account $0 for: each Card you ask us to, replace; each returned payment; each check you write on your Account that we return unpaid; each stop payment order or renewal of such an order; each billing cycle within which your Account is delinquent (late charge); and each billing cycle within which your valance exceeds your Credit line (ovedimit fee), even if your Account is closed. If you request copies of billing statements that were first sent to you more than three months earlier, we may charge a handling fee of 2 for each such copy. If you request that we make Gone-time automatic (Continued on reverse) (5846-0698) 4428232900215067 1048 431 zser payment from your personal checking account, we may charge your credit card account a fee of $4.95 for each request. This fee is a FINANCE CHARGE, antl it will apply regardless of whether funds are available in your personal checking account to make the payment. We maY cha e a transacticn fee of 3% (minimum $5), which is a one;time FINANCE CHARGE, on the amount of each cash advance, including cash from financial insfi~utions, and ATMs, wire transfers, money orders, lottery tickets, casino gaming chips, and similar transactions. Default. You will be in default: if any information you provided us proves to be incomplete or untrue; if,you do not comply with any part of this Agreement; upon our death, bankmptcy, or insolvency; if you do not pa other tlebts when due; if a bankmptc petition is filed by or against you; or if we believe in good faith teat you may not pay or perform Vour obligations under this Agreement. If you are in defau~t we may, without further demand or notice, cancel your credit privileges, declare your Account balance immediately, due and payable and use any remedy we may have. In the event of your default, the outstanding balance on your Account shall continue to accrue interest at the APB(s) disclosed in the Finance Charges section of this Agreement, even if we have filed suit to collect the amount you owe. Credit Line. Your credit line is specified from Ume to time in a separate notice. Your monthly statements show your credit line and the amount of your available credit. We may increase or decrease your credit line based on information we obtained from you or your credit records. Your available credit is normally the difference between your credit line and your Account balance (including transactions made or authorized but not yet posted). If, vou send us a large payment check, we m limit your available credit while we confirm That the check will clear. For certain transactions, available credit may be less. You will not use your Accoun~for, and we may refuse to honor, any transaction which would cause you to exceed your available credit. Promise to Pay. You promise to pay us when due all amounts borrowed when you or someone else use your Account (even if the amount charged exceeds your permission), all other transactions and charges. to your Account, and collection costs we incur including, but not limited to, reasonable attorney's fees and court costs. (If you win the suit, we will pay. your reasonable attorney's fees and court costs.) Chan~es. After we provide you any notice required byt law, we roay charge any part of this Agreement and add or remove requirements. If a change is made o the Finance Charges section of this Agreemen ,the new tmance arge calculation will ly to your entire Account balance from the effective date of the change. Changes will apply to balances that include items posted to your Account before~t to date of the change, and will apply whether or not you continue to use the Account. Forei n Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U.S. dollars the transactions will be converted to U.S. ~ollars, generally usin either a (i)~ovemment-mandated rate or (ii) wholesale market rate in effect the day before the transaction is processed, increased by three percent (~%). If a cre, it is subsequently, given for a transaction, it will be decreased by the same pementage. 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 the converted amount in U.S. dollars. The Card• Cancellation. You may cancel your credit privileges at env time by notifying us in writing and destroying the Card(s). Upon the Card expiration at the end of the month shown on It, we reserve the rigght not [o renew the Cana. We may cancel the Card and your credit privileges at any time after 30 days notice to you or without notice if permitted by law, tf your Card is cancelled or not renewed, finance charges and other fees will continue to be assessed, payments will continue to be due, and all other applicable provisions of this Agreement will remain in effect. If you terminate your creditprivileges, 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 issuedgto you. Personal Information; Documents. You will provide us at least 10 days notice if you change your name, home or mailing address, telephone numbers, employment or income. Upon our request, you will provide us additional financial information. We reserve the right to obtain informatipon from others, including credit reporting agencies and to provide your address and information about your Account to others. We ma also share information with our affiliates. However, you may write (o us at any time instructing us not to share credit information with our affiliates. If you do not fulfill your obligations under this Agreement, 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 safeguarding the Card, your Personal Identifica{ion Number ("PIN" which provides access to Automated Teller Machines) and any checks issued to Vou from theft, and ke~ina your PI N separate from Your Card. If you discover or suspect that your Card, PIN, or env unused checks are lost or stolen, or That an or viii ~ we can use occ to we and security, you agree that your carts maybe monitoretl or recortled. Merchant Relations. We will not be.liable if any person or Automated Teller Machine refuses to honor the Card or acceppt your checks or fails to return the Card to you. We have no responsibility for goods and sevices purchased with the Card or checks except as required by law. (See Special Rule below.) Certain benefits that are available with tthe Account are provided bythird-party vendors. We are not responsible for the quality, availability, or results of any of the services you choose to use. of the item so that ppaayment can be stopped. I ne order will not r irder. We may, withcut liability, disregafd a written stop payme ~f Care. Because this Account involves both credit card and cl bons are consolidated by us,, and because not every check a I without our necessarily reviewing every item. Our processii transactions when you report that your Card or checks have be it if we do not do so. This rule establishes the standard of c. our limited review, and bepause neither your cancelled checks areful to enter all checks m your check register or otherwise k ips. You agree to check your monthly statements against your Certain Rights. We ma delay or waive enforoement of any ter. You waive: the ngh~ to presentment, demand protest, of uire us to proceed against anyone before we file suit against yc Law• Severability; Assignment. No matter where you live law. 'phis Agreement is a final expression of the agreement bi If env provision of this Acreement is held to be invalid or unenfr or your send us a stop payment order by writing to us at our address for customer service ling the number listed on your statement. When You make a stop pa merit order :heck: the exact amount, the date on the check, the name of the party to whom if ;r. You will be asked to confirm an oral stop payment order in writing. We may ~n within two weeks after the oral order, or if we have not received an adequate ie effective if the check was paid by us before we had a reasonable opportunity to nt order six months after receipt unless it is renewed in writing. ieck transactions which are processed through separate national systems before rid Card slip will be sent to us, transactions in your Account will be processed ig system will call our attention to certain items which we will examine. We will en lost or stolen. We do not intend ordinarily to examine all items, and we will not binary care which we in good faith will exeroise m administering your Account. nor Card trans ction sli swill be returned to you with the monthly statement, you eep a record o~ them. ~/ou should also save your credit card cash advance and record and to notify us immediately of any unauthorized transactions or errors. provision of this Agreement,without losing our right to enforce it or any other notice of dishonor; any applicable statute of limitations; and any right you may u. this Agreement and your Account are governed by federal law and by New itween you and us and may not be contradicted by evidence of any alleged oral irceable, you and we will consider that provision modified to conform to applicable ble. At any time after we determine in good faith.that any proposed or enacted ter any material provisions of this Agreement invalid or unenforceable, or impose h any such provision or its enforcement, we may, after at least 30 days notice to privileges. a may transfer or assign our right to all or some of your payments. If ~. PROV I DIAN Financial state law requires that you receive notice of such an event to protect the purchaser or assignee, we may give you such notice by filing a financing statement with the state's Secretary of State. Notices. Other notices to you shall be effective when deposited in the mail addressed to ~ou at the address shown on our records unless a longer notice period is specified in this A reement or by law, which period shall start upon mailing. No ice to us shall be mailed to our address }or customer service on your statement (or other ad~resses we may specify) and shall be effective when we receive it. youR Bi~uNC RicHrs --Keep THIS NoTice FoR FuTURe use. This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us in Case of Errorrss or Questions About Your Bill. If, you think your bill is wrong or if you need more information about an~vv transaction on your 6i11, write us on a separate sheet, at fhe address listed m the Billmg Rights Summary on your bill. Write to us as soon as possible. lie 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 there is an error. If you need more information, describe the item you are not sure about. If you have authorized us to pay your credit card bill automatically from your checking account, you can stop the ppayment on any amount you think is wrong. To stop the payment, your letter must reach us three business days before the automatic payment is scheduled to occur. Your Rights and Our Responsibilities After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days ,we must either correct tha error or explain why we believe the bill was correct. After we receive yeur letter, we cannot try to collect any amount you question, or report you as. delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against Vour credit line. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the 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 f Hance 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 df the amount you owe and the date that it is due. If VVou tail to pay the amount we think you awe, we may report you as delinquent. However, if our explanation.does not satisfy Vou and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that Vou question your bill. ,And, we muss tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when d finally is. If we don't follow these rules, we can t collect the first $50 of the questioned amount, even rf your bill was correct. Special, Rule for Credit Card' Purchases. If you have a problem with the quality of the properly or services that you purchased with our credit card and you have tried m good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or services. There are two limitations on this n ht: (a) you must have made the purchase in your home state, or If not within your home state, within 100 miles of your current mailingg address; and (bJ the purchase price must have been more than $50. These limitations do not apply if we own or operate the merchant, or if we mailedyou the advertisement for the property or services. 2561 w'I Complete this short form and return it in the postage-paid envelope provided. ~~ 30-Second Response Certificate Yes, I want to accept your invitafion for a customiied VISAm Gold account! I agree to be bound by the Account Agreement (which will be mailed to me before my VISA card is issued) and to repay principal, interest, and interest thereon, except that I will have no obligation if I return the.card(s) unused and cancel my account after reviewing the Amount Agreement Ryan H. Hurley ~ ~ 3 5 1 106 W. Hig Spring Ave. Netrtville,'PA 17241-1609063 ' 2703N1 CTOAO GY119 GREG I,H3R OFFS UKBD ABA,7 20- 703-8649-6377-1 so wet aar~<a 77+is invitation expires: September 6, 1994 Signatua (NmaT ) .._- Social Security Npmher (7l7> 77d~ -3lo3tj (7/?)~ 77/0 -~1a5 / Hopi Phone Work/Semnd phone No Annval Fee • $20;000 Credit Line Immediate Cash ' • Lowest Purchase Rate s 6YARANTEED SAVINGS ~' `~ ,I J /~~~~ R. Thomas Mazur Vice President wtw Boxerence N 58ber: 210i~5241)33 ~ ~~ ~` ~~~ I <~~)~,~ Year :94 L `~ ~- Batch :4 SSN :2105241.33 /~~ Account# :4428232570301551 LLWRIGH /' _~ ~~- ~ ~ ,~ ~ G ~, ~ ~ ~ c _ ~ ~= _;~ N ~ ~-n r., ~ ~ -G ,4q :..~s r ~, -~ -n y, ~ ~~ GL= .~ Jt~' SHERIFF'S RETURN - REGULAR CASE NO: 2001-04629 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS HURLEY RYAN H BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HURLEY RYAN H was served upon the DEFENDANT at 1447:00 HOURS, on the 6th day of August 2001 at 106 W BIG SPRING AVE NEWVILLE,__PA 17241 by handing to RYAN HURLEY 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 18.00 Service 7.80 Affidavit .00 Surcharge 10.00 .00 35.80 Sworn and Subscribed to before me this ~ day of r2rc j A. D . ~°~ rothonotary So Answers: ~~~i~ R. Thomas Kline 08/07/2001 PARK LAW AS CIATES By . /~' GY Deputy Sheriff 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 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS RYAN H HURLEY Defendant NO. 01-4629 PRAECIPE TO SETTLE, DISCONTINiJE AND END TO THE PROTHONOTARY: Kindly mark the above captioned- matter settled, discontinued and ended upon payment of your costs. PARK LAW ASSOCIATES, P.C. I7 BY: VALERIE ROS TH~'AR'K" .~, , ~ `~ . a ' ~~ _= :r ~~ ~ ~ .1 r ~ ~ ~ .H ~~S ''P~,