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Home My WebLink About01-06832 , , VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doy1estown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS. DORIS E SHUMAN NOTICE NO.D1-~'J~ C-()~l~ Defendant 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. ~';~~)!fLJt'>:__:'^"'Z""'~"''''-''''''''''('''":\i''':'''__ ^_,,' "_,,,",' "',c' ,dr', e,'.. ,0,0, __ do^", '" '~ ," =-"" 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#:4168100013654221 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANT ON , CA 94588 PLAINTIFF VS DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 DEFENDANT NO. 01- {'P.3;t Cot ;-~ CIVIL ~CTION 1. The Plaintiff, First Select, lIne. is a Delaware corporation organized and existing under the iaws 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, DORIS E SHUMAN, is an individual who resides at 1083 MUD LEVEL RD SHIPPENSBURG, FA 17257-8002, 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 4168100013654221. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -,',~, , '" "tj'"f:!'W':::'-,:',~'_f?'''Y'i<'?__,-,~. -".. "~ .. I r,',v', . -\-- "-'1' .,T_ ~ .. " '. i,_" . - ,~ 4. The terms of said account are stated in the documentation attached hereto as Exhibit "A". 5. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the outstanding debt as agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $1,995.79 as of 11/13/2001, plus pre-judgment contractual interest at the rate of 8.00% per annum, less payments made. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $1,995.79, plus pre-judgment interest at the contractual rate of 8.00% per annum from 11/13/2001 until the date of the judgment herein, 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 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. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i__".^~ "_,,""_,' <. "':,,0' ,__ "', -c'''_'{'>'" '_,"0 WHEREFORE, Plaintiff demands that Judgment be rendered in favor of the Plaintiff, First Select, Inc. and against the Defendant in the amount of $1,995.79, plus pre-judgment interest at the contractual rate of 8.00% per annum from 11/13/2001 until the date of the judgment herein, 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. <~f . ~ "," ~, ~"f", .,-t~"'!1'~',",'~;rr:",,:]!?,,"' "~', .," -"":"'''1',' e, 0 ,N n,~ . . - -" ., . ~~, .. I, VERIFICATION 'DELORES CHAHLt:S , 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 County, in the State of California. ~ Lc-RclA k Date Designated Agent '" tH ,- '~f" -,' ~~ - .' . ....vy.RIT A ACCOUNT AGREEMENT Your ASSOCIATES acoount bas been transferred to First Select COIl'oration. Your ASSOCIATES account was closed at the time of this transfer. aud will therefore continue to be closed. This Account Agreement contains the terms that govern your First Select account (1he" Account:'). In this Agreement, "you" aud "your" mean each person who is liable fur payment on the Account. "We," "our:' "ours, It and "us" mean First Select Corporation or its assignees. Because your Account has been tnmsferred to us, you are now obligated to repay the Account to us instead of ASSOCIATES. If the Account was opened as a joint account, we may act on the instroctions of any joint accountholder. Payments J Ftnanee Charges. As long as you have a balance outstanding on your Account, finance charges are calculated as follows: To figure the finance charges for eaCh billing cycle, we multiply the average daily balance on your Account by a daily periodic rate. The daily periodic rate we apply is your Account's Annual Percentage Rate divided by 365. The Annu!ll Pete_ge Rate will be calculated as disclosed in your most recent ASSOCIATES """ount terms (the "0rigiua1 Tenns"). If your 0rigiua1 Tenns provided for different Annual Percentage Rates to be applied to different compon_ of your outstanding balance, we will apply the lowest such Annual P~ Rate to your entire outstanding balance. . We may accept late Q(' partial payments. or payments marked "paid in full" or marked with other restrictions, without losing our right to collect aU amounts owing under-this Agreement. You may ask First Select Corporation to pay this account by debiting your checking or savings account. First Select COlporation will first verifY your identity and eligibility for this service. You may revoke your authorization by writing to First Select Corporation Customer Service. Fees. We will charge your Account a fee for each billing cycle within which your Account is delinquent (late charge). The amount of the late charge will be as disclosed in your Original Terms or the maximum late charge permitted by the law ofyont state of residence. whichever is lower. We will charge your Ac<:ount a fee lOr each returned payment cbeck (returned check cbarge). The amount of the returned cbeck cbarge will be as disclosed in yonr 0rigiua1 Terms, or the maximum returned check cbarge permitted by the law of your state ofresidenoe, whichever is lower. To the extent provided in your Original Terms, and to the e:lrtent permitted by applicable law, in addition to your obligation to pay1he outstanding balance on your Account, plus interest and fees as disclosed herein, we may also charge you for. any collection costs we incur, including but not limited to reasonable attorneys' fees and court costs. If your Original Ten:ns provided for an award of attorneys' fees and court costs, such provision as incorporated herein shall apply reciprocally to the prevailing party in any lawsuit arising out of this Agreement. . . Non..Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. Applicable Law, Severability; AssIgBment. No matter where you live, this Agreement and your Ac<:ount are governed by federa1law aud by the law of the state desigrune<l as the applicable law in your 0rigiua1 Tenns. If your Origiua1 t."lIS did notoontain1Ut applicable iilwpIOVMOO;1ben this Agreement lUlll.your . Account.m:e govemed'by federa1law,and the law .of.your.~e.-OfrtSidence~.,This.Agreement is,-a final.expressioo of the agreement, between.you-and us,and may not be cnnIn1dicted by evidence of any alleged oral agreement. Ifany pIovision of this Agreement is heldto be invalid.or unenfurceable,.youaud.we will considero. that provision modified to conform to applicable law, and the rest of the provisions in the Agreement win still be enforceable. We mayvansfer or assign our right to aU at some of your payments. lfstate law requires 1hat 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. Credit Reporting; Personal Information. If you fail to fulfill the terms of your credit obligation, a negative credit report reflecting on your ,credit record may be submitted to a credit roporting agency. In order to dispute any infunnation we are reporting about your Account, you must write tQ us at th~ foll~ address: . First Select CorporatiOlJ, P.O. Box 9104, Pleasanton, California, 94566. We.."" .h... Ulf......ari.. ,,;,h .IIT lflIiIiot.. mcIudhiJ. ,,;,h.Ot /i,niton.., Pr...rIi.. . Nfltiotltd B.nk and Prf,..,/Ji.n Bu/l. HtTtPCPeT, yo." may write t9 JU (It fillY time /",""din, .", n'" tf1.IIfJre credit inj'enrumOll witIr 0,"" 'fIjdJatu. YOUR BILLING RIGHTS - KEEP TillS NOTICE FOR FUTURE USE This notice contains imp~ infomtation about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us in Case orEnon or Questions About Your BiD If you think your bill is wrong, or if you need more information about an entry on your bill, write us, on a separate sheet, at the following address: YU'St Select Corporation, P.O. Box 9104, Pleasanton, CA 94566. Write to us as soon as possible. We must hear from you no laterthan 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 ycur rights. fu your lett~! give us the following: .. Yout name and Account number. . The dollar amount of the suspectederror. . Describe the error and explain, if you can, why you believe there is an eJl'or. If you need more information, describe the item you are not sure about Vour Rights and Our Responsibilities After We Receive Your Written Notice W~ must ~wledge your letter within ~O dayS, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we bebeve the bdl was correct. Aft~ we receIVe your letter, we camot try to collect or report you as delinquent as to any amount you question, including finance charges. We can apply any unpaid anIOunt against your 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 the bill thet are not in question. .' Ifwe find that we made a mistake on your b~I. you will not have to p~y any fmance charge rela~ to any questioned .amount Ifwe did not make a mistake, you may have to pay finance charges, and r~u will have to m,ake up the nussed paym~ts on the questioned aroowrt. In either case, we will send you a statement. of the amount you owe and the da~ that It IS .du.e. If you fail ~o pay the amoun~ we think. you owe, we may teport you as delinquent However, if our explanation does Dot satisfy you and you write to us WIthin 10 days tellmg us that you still refuse to pay. we must tell anyone we report you to that you question your bill. And we must ten you the name of anyone we reported you to. We must tell anyone we rq>ort you to that the matter has been settled between us when it finally is. Ifwe 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 Purcbases If you have a ~roblem with the quality of goods and services that ~o!-,- purchased with your ASSOCIATES credit card and you have tried in good faiili to correct the problem WIth the mer:chant, you may not haye to p~y ~Ie remainIng l101ollnt. d~e on the ~;oods or services. There are two limihttions to this right: (a) you must have made th~ purchase In your h~m~ st~te or, if not \V1th~ 'y?LIr home state, wlthmlOO mdes ofyollr current mailing address; and (b) the purchase price must have b:een mon: than $50. These tUlll!AtlOns do not apply if either we or ASSOCIATES own or operate the merchiUlt; or ifwe or ASSOCIATES mlliled VOll the adverusement tor thl: property or servtces. . '.'''!~~!~'~~'!'~~''~'''''''''":'~r'""" ,-, "'" ~- ORDER FOR SERVICE TO: SHERIFF OF CUMBERLAND COUNTY DATE: November 26, 2001 PROTHONOTARY NO: FROM: VALERIE ROSENBLUTH PARK, ESQ. Attorney 1.0. 72094 25 East State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CIVIL ACTION COMPLAINT FIRST SELECT, INC. Plaintiff VS. DORIS E SHUMAN Defendants ADDRESS TO SERVE: DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 SPECIAL INSTRUCTIONS: PLEASE DO NOT SERVE OUT OF COUNTY! PLEASE MAKE THREE ATTEMPTS TO SERVE AT DIFFERENT TIMES. THANK YOU! RETURN OF SERVICE TO: PARK LAW ASSOCIATES, P.C. P.O. BOX 1779 DOYLESTOWN, PA 18901 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "~n~''!'iIiM~I:J~~l!;y~~\,~,~ " -,'" -_~'1"""'''' < ""_,,_",,.",,>,,^h"j" ,', ",", ,'"__ '; 'C',,'."" ; ,,^--, " < ""'-"',,,,., _",,__ --- ., ^, _,~_~_,_ ~~~.__ M~.","~' ~~. _. l ~ ~ h ~ () 0 C~ t ~ II? () Ci) c 8 ......... (J 0- ;:g~ ~ CY :C) ...... ~ Z"1 ",.~ -;I~-: ~ () I ~2 C,C-' .~ f: (,::) I'v ..t l/) ~) 0 w 1 >, :"'4~ L ~-:~ >,,=1 L- t.d :_) -".:-- 2;:! L.. ~) --.t -< '''' _0 -< '-.....( c-- M"",,_'~"_~.1,,_~ ,^,,' " ~~~F~Ji;lry?~.F!Et,.,gJ1f-1'G'@I'?~~1f~~~W!!l!,I;~~~~,.f1':"~^~;'~' ~':"':'??fl'? SHERIFF'S RETURN - REGULAR CASE NO: 2001-06832 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS SHUMAN DORIS E SHAWN HARRISON , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHUMAN DORIS E the DEFENDANT , at 1851:00 HOURS, on the 7th day of December, 2001 at 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257 by handing to THOMAS SHUMAN, HUSBAND \ 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 13.00 .00 10.00 .00 41.00 -r'~~ R. Thomas Kline 12/10/2001 PARK LAW ASSOC. Sworn and Subscribed to before By: <. me thi s j2,'b day of ~..~ d.lJ1)f A.D. O'!'!."- Q fh,pp;" A~~ Prothonotary / .';;-".'~""'o^,i1'l'_~,,= ~~ _, ~ , '^ -- "T'~ , , ' ",i[4~,ITr, ~ VALERIE ROSENBLUTH PARK ATTORNEY I,D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FO NTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBlJR,l3IJ?l. 17257-8002 4-- 21 i CUMBERLAND COUNTY COURT OF COMMON PLEA FIRST SELECT, INC. Plaintiff VS DORIS E SHUMAN Defendant NO.Ol-6832 CIVIL TERM PRAECIPE 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 $1,995.79 $339.00 $24.50 ($0.00) ($0.00) TOTAL $2,359.29 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 pursuant to Pennsylvania Rule of Civil P~ocedure No. 237.1 is attached hereto and marked Exhibit" V RIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW,~ ).::JA.)(.A.,,'\;NJ.~~l{, .;2ClO~ , Judgment is entered in favor of the Plainti f and against 'the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. . ~ , !"'~~'~'::~-""""', '"' 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" 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: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS NO. 01-6832 CIVIL TERM DORIS E SHUMAN 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 ~ 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 P TICES 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. ii:~1.~"",,",-,,,,, \"', ,,,^"" " ","'<,'-' - T'~I,. , '. 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: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS ; NO. 01-6832 CIVIL TERM DORIS E SHUMAN 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 DORIS E SH~, Defendant is over 21 years of age; that his/her place of residence/business is located at 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 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 amendme ts. PARK LAW ASSOCIATES BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 '~S";"'1"""Jl "r,.~",; ____~,','" """, " r~ -'~,~ ^ - c' VALERIE ROSENBLUTH PARK ATTORNEY J.D. # 72094 PARK LAW ASSOCIATES,P.C. 25 EAST STATE STREET, P.O. BOX 1779- DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF PHILADELPHIA COUNTY COURT OF COMMON PLEAS I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 FIRST SELECT, INC. Plaintiff VS DORIS E SHUMAN Defendant NO. 01-6832 CIVIL TERM NOTICEOFPRAEC~EFOR ENTRY OF DEFAULT JUDGMENT TO: DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 DATE OF NOTICE: 12/28/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS yOU ACT WITIllN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT 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. Lawyer Reference Service Philadelphia Bar Association 1101 Market Street, 11 th Floor Philadelphia, PA 19107 (215) 238-6300 PARK LAW ~~CIAT~_. BY: y~ VALERIE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT P1 ;.;'~''''''__'.r.", '":' _ _<_<__,_ ~~ , , . ~.' ",,"""""~" -,~ "~ ' ,"" .' "'-,' ~~'>^ " i d :j ,I ,1 I 'il &~ ~ r- j ~ ~ ("'.. '-"'~ ,~" - ,~, (.) t ........ N ~ ~ ~ ~ Q F r:J- _~ .~~j!J.J~~'9l ij!~~,~._.l~~~I!iW<:lli~,",,~'f'''tH,'~F''- c'-';"''';'W':V,<: --- ,"- ~" -lg, :'0 (). D-. ""'iI-'~" '''H~,<:'__ (") c <- -U 0' m~,; Z'-i 7F:<;' ~1~,: ~Ci -~ ZC) )>0 c ~ -<. " (.7; rv o ,j c_ ::::-. Z ~--, 1:;-" r-.,) ~ .~ -.'r- -n ::r. .::...., > ,~~;? o (:::> --, " :,~~ r=;~ u S"-! "1"1 =< fS gq