Loading...
HomeMy WebLinkAbout01-07069 "Tilil ,en, 1 ~~I ,'~i{M<.~i.^,~ . 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, PATRICIA A MARLEY CABS Defenciant NO, 01- "'lObe:; CIU.t I~ 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. , ~" w, "' '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#:4428472276204671 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS PATRICIA A MARLEY CASS 15C CREEKSIDE LN CARLISLE, PA 17013-7833 DEFENDANT NO. 01... 76" 9 (]e:, d" Y 'ii<..~ CIVIL il.CTION 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, PATRICIA A MARLEY cASS, has a mailing address at 15C CREEKSIDE LN, CARLISLE, PA 17013-7833, 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 4428472276204671. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ;(}"M\l"n.-~ ~~"_,-,~, ".' ,~- ,., "~ ,.. e" " ?n, _ "'~---r~,1'.1P<., ,~ :"'ti' 4, The Defendant requested an account, account number 4428472276204671, which is owned by the plaintiff, and an Accou~t 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 $5,994,51 as of 11/30/2001, plus pre-judgment contractual interest at the rate of 17.15% 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 $1,019.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,994.51, plus pre-judgment interest at the contractual rate of 17,15% per annum from 11/30/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,019,00, 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. !'~<,,,,w,'W:RlI,";,,,~~ ,.,"",~,,,t ~"~,, 'I, ~ ,~,~, ' ~ ,~ -,~ ~ ~-r">-~, -~ :__-!i<if 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 $5,994,51, plus pre-judgment interest at the contractual rate of 17,15% per annum from 11/30/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,019.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just, PARK LAW ASSOCIATES, P,C, 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. -"#,*~1_ -~ < ' ~ .. 1~' ,-_ ~l-'-&,;;.-i"^-''- ~':~'"rr' T VERIFICATION I, d'(liY swAll , declare that: I am ",j.rr 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 Jefferson County, in the State of Kentucky. )(_/S-O\ ~,CM~ De ignated gent - Date l,>,' - ,i*'~'''',*''!l;J1f',~ ^ , L:: ,_. ~ _ jf",^""" ~..4, ,I _ '~'f'l 'IF, ,,~ ~ ,-,"- ,,""._, ""'1""''''''''''';''::::;'' ~o PROVIDIAN Providian National Bank VI SA@ or MastarCard@! Account Agreement for Patricia A Marley Cass April 11 , 2001 Please review this document and kee~ it with your other ImJl!lrtant paP.!lrs, This Account Agreement contain~ the terms which govem your Provldian Natlon~1 Bank VISA or MasterCard Account (the "Account"), The Account allows, you ,to make pUJ:Cha,se~ by uSing your VISA or "MasterCarQ card (the "Gard) wherever it is honored and to get cash advances from us or any other participating finanCial institution ~d from Automated T elle, r Machines, Convenience checks may also be provided 10. you as an additional way to use the Acpount. ,In this Agree\l1ent, ~you and "your" mean ea9~ person for whom we have opened a credit card Account. "We," "our," "ours a" and "us" ,mean Provldlan National BanR or It~ assignees, as listed on your billing statement. The Account may be used only for personal famll'!l househol ,and chantable purposes, and not for any bUSiness or commerCial purpose, Any use of thiS Account shall constitute acceprance of the terms 0 his Agreement. You and we agree as follows: Payments. You will receive a monthly statement showing your outstanding balance, Payment on this Account is required in U,S, dollars (checks must be payable at a U,S, office of the bank the check is drawn onJ.!or at least the payment due as shown on your statement by the payment due dale iQ accordance with payment instructions on your monthly statement. The beck of your statements shows the rules we follow when we post payments, ,Convenience checks and other checks we issue to yoU may not be used to make payments on your Account or to make payments on any other account you have with us or our affiliates, The paY\l1ent due win be: 2% of the new balance shown on your statement plus the amount of any past due paYJ!1ent, and may include the amount by which the new balance exceeds your credit line, However, the payment due will not be less than $15 (unless your new balance is less than $15, in which case the payment due will be the amount of the new balance), If your Account Is past due or above lhe creait line, we may require a higher minimum peyment, bUt we will notify you before doing so. If your payr:nent is more than the payment due, it :MI) be traated as a siQgle payment,aQd non~ of it will ,be applied to future payments Que, We mayacc'Wt late or pattial payments, or payments marked paid in full" or marked With other restnctions, Without lOSIng our right to collect all amounts owing unaer this Agreement. Finance Charges, Except as described in the Grace Period for Purchase Balance section of this Agreement finance charges begin to accrue on a debit when It is Incluced In one of your daily balances and continue until that belance is reduced by a payment or credit. Your Accounthas the follow, ing balances: The Purchase Balance whiCh conSIsts of your existing Purchase Balance and new purchases you make with your Card and fees for certain optional services; one or more Custom ~ash Advance Balances, which consists of balances that you, transfer to your Account using balance transfer checks and balances that we tranSfer lor Y' u; ana me (,;asn Aavance Balance which consists of all 0, ther cash advances and cash aavance transaction fees, Any Qayment amount we .receive that exceeds me "nance cnarges ana fees then due will ordinarily be applied first to the Balance with the lowest Annual Percentag~ Rate (APRl, until that Balance is zero, and then fa the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balance, -We reserve the right to epply payments Cif!erenUy without further notice, The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments 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 casn advances are inciuded in your Custom Cash Advance Balance as follows: funds electronically transmitted to other lenders to transfer balances, as of the date transmitted; cheCKS to transfer b~lances, as of the date P.resented to us, Other cas/i advances are included in your Cash Advance Balance as follows: cash advances from other financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are identified as cashier's checks and mailed to you at your rC\OCluest, 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, ustom Cash Advance or Cash Advance Balance as of the uate posted, Finance chafll!ls' are added to your PUI'Ghase, Custom Cash Advance, and Casli Advance Balances each 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 advances, Tdo figure the daily finance charge for each Jype of Balance, we start with your previous day's Balance, add all debits and subtract all credits for the current ay and multiply the net amounl by the ~plicable daily penodic rate (see following paragraphs), The finance charae for each type of Balance is then added to and included in that day's Balance, We traat a credit balance for any day as zero, We determine the total finance charges on balances for the billing flYCle by adding together tfie finance charges for each type of Balance for each day within the billing cycie. 10 calCUlating finance charges an adiustment win be made for any tiansaction or payment that would have aIIected the finance charge calculation in a prior billing cycle fjad it been posted in thal qycle. The applicaqle daily periodic rate for such a transaction will be the rate in effect for The current billing cycle rather than the rate in effect on the dilte of the transaction, Your statement Includes an average daily belance for each tvce of Balance, You can multiply each average daily balance that is not zero by the number of dthays.in the billing cycle and the periodic rat~ to ob~in subtotals..and then aod the suqtotals together to defermine your total finance charges on balances for e billing cycle, If a cash advance transaction fee IS charged, mat amount IS also a finance cfiarge, The term "Prime Rate" as used in the Agreement means the highest prime rate published in the Wall Slreet Journal on the first business day of the previous calendar month. Any increase or decrease in /he Annuai Percentage Rate will take effect on the first day of your billing cycle and may result in e slight Increase or decrease In the amount of your minimum payment. You can arrange to have a variable rate for purchases which is lo.wer than the lowest non,introductory ANNUAL PERCENTAGe RATE (APR}.y.ou are paying on any of your other credit card or retail accounts, This APR is available only if you provide proof, in the form of a l;OPy of your most recent billing ~statement, showing your other non,introductory APR. Your new APR will take effect in the billing cycle followi!Jll our review of your proof, but not eariier than he end Nor YAoLurpcoEyrtcE~Y.mriod'RAUntil yoyrjJew APR takes !lffect, or if we do not receive proqf of yqur ,lower APR,,your APR for purchases will be as follows: e AN lIJ R ;ENTAGE TE (APR) for purchases IS 17:15%, corresponding to a dally penodlc rate of 0.\14699%, You can arrange to have a variable APR for custom cash advances that is lower than the weighted average of the non,introductory APR you have been paying on the fatal balances 'you have transferred from other credit card, re~ih and installmenf accounts provided .your other "accounts were Qlien in ADril 200,1, In calculating this APR we will take Into account the APRs on the C,tKIjf account balances y.ou 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 other non-introductory APRs Your new APR will,be variaDled based on 'pnme Rate and will take effect in the billing cycle follOWing our review of 'lour groof"but not earllar than The end of your courtesy penod, If we ojJot receive such proof your APR for custom cash advances wlllce as follows: The ANNuAL PERCeNTAGE RATE for custom cas/i advances is 17,15%, corresponding to a daily periodic rate of 0,04699%. The ANNUAL PERCeNTAGE RATE for cash advances is 17, 15%, corresponding to a daily periodic rate of 0,04699%, If w~ receive your Account payment late 2 or ,more \im!ls in any' 6,month seriod, on each such occurrence we may increase the APR, for P, urchases up to a m8X\mum of 23,90% (corresponding to a dally pjlnodlc rate of 0,06548*'/1 and Increase the APR for cash advances and custom cash advances up to maximum of 23,90% (cOff!lspol1ding to a daily periodic, rate of 0,06548%), after you receive the higher rates your payments are received on time and you meet all other terms of )hls Agreement,for 3 consecutive months, you may contact our Customer SelVlce department and at your request We will review your Account for a pOSSible APR reduction, ' , Grliace Pderio~ for Purchase Balance.. Ne)N purchases posted to yo~r Account in billing cy'cl~s with no previous balance or when the previous balance was fu y pal dunng the cycle, do not begin to mcur a fmance charge until the start of the next billing cycle. You Will pay no r,nance charge on such new .t\- -- EXHIBIT (Continued on revelSe) (5846,0698) 4428472276204671 0730 4515028 ';'-'I"'~:""'-~"i';'1f"","J;:!';-<~';_?i"'!'''''-":t'ilr?~''''fj''P'~1'm11J\l~_~~"'''~'I'1'''''',.-.r'''!''''11''''''i'''~ '"'> ' ~. Jl~~~~!___ """'P"""'.~ PROVIDIAN Hampshire Jaw, This Agreement is a final e:>q<ression of tne agreement between you and us anq may not be contra9i9ted by ~yidence of any ailege,d oral agreement. If any provision of this Agreement is held to l;>e Inyalld or unenforceable, you,and we will conslder,tha\ provlslon"mod!fled to, conform to applicable lal'(, and the rest of the provlslQns,ln the !l,greement wlil stiil be enforceable, At any time after,we determine In good falth,tnat any proposed or enacted legislation reguiatory acUon, or JudiCial deCISion has rendered or may render any matenal prOVIsions of thiS Agreement Invahd or uneriforceable, or Impose any increased tax reporting requirement, or other burden in connection with any such provision or its enforcement, we may, aller at least 30 days notice to you, or without no\ice if permitted by iaw, cancel the Card and your Credit privileges, We may transfer or assign our right to all or some of your paY\11ents, If state iaw 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 deposited in the mail addressed to you at the address shown on our recordSI unless a longer notice period is specified in this Aareement or by law, which period shall start upon mailing, Nonce to us shall be mailed to our address or customer sel1lice on your statement (or other 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. Notify Us in Case of Errors or QUB$tions Abol,/t YOllr Bill. If you fhink ~our bill is wrong or if you need more informalion about allY transacfion on your bill, write us on a separate sheet, at tne address listed In the Billing Rights Summary on your bill, Write to us as soon as pOS$/b/e, 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 telepJ:rone us, but doil1Qso'wlll not ~erve your rights, In your letter, give us the following information: - Your name and Account number, .. The dollar amount of the suspected-error, '. Describe the erro, r 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 biil automaticaily from your checking account, you can stop the payment on any amount you think is wro,;g, 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 lette( 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 DliI was correot. After we! receive your letter, we cannot try to collect any amount you question, or reRort you as delinquent. We can continue to bill you for the amount you question, including finance charg~s, and we can apply any unRaid amount against your credit line, You do not have to pay any questioned amount '/ihije we are investigating, but you are slll1 Obligated to pay tiie parts of your biil that are not in question, , If we find that we made a mistake on your bill, you wiil not have to pay any finance charge reiated to any questioned am, Qunt, ' ,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. Iln eitherc&se, we will send you a statement of. the amount you, owe and the date that it is du~, ,If YQU fail to pay the amount \NIl think you owe, we may repprt Y<!l,~ as ~liqquent. However, If our explanation does not satisfy '{OU and you wnte to us Within 10 days tening us that you stili refuse to pay, we must tall anyonawereport you to that you question your bill. And, we mus tell you the name of anyone we reported ','ou to, We must tell anyone we repqrt you to that the matter has been settled !ietween us when it finally is, If we dOn't follow these rules, we can't collect lI1e first $50 of the questioned amount, even if yollr bil,ll'{as correct. Special Rule for Credit Card Purchases. If you have a problem with the quality of the proRerty or sel1lices that you purchased with 'our credit card and you have tried in good faith to correct the problem with the merchant, you may not nave to pay the remaining amount due on theqoodSjor sel1lices. There are two limitations on this right: (a) y,ou must have mada the purchase in yqur home state, or if not within your home state, witfiinlQO miles of your current mailing address; and ,(b) the Rurchase price must have beeh more than $50, These limitations do not apply if we ow~ or operate: the merchant, or if wa mailed you the advertisement for the proparty or Sel1llces, T5028 ''''''~;\~'''~'''' f' "H' Ie:,' , '",- > -, .~ ._.~ I "'"'""."""''''''"''''''''~-~''tuq,i<~:''''W",';:'' '" ,o~""''''Jrj1'trrt'ni1m~~~i!Uil''r~<~~:~11r~nr:mr'Y1!!i4it~ , . f::J ~ (') (::i (-'" -lQ.. ~ , r ~ C -:1 t .t' "' ;:::J --"---:;c'- 8 h 0 Q,i~: ~-) ~ (1 0 . ~,c _ ~ () u~ ",- () -"~ ~' . ().J ~:~ " ..Q ~ I I ~: ; ~ ~f 'v;,';' ',) UJ J ", ~ ,~" 'j ~,_, ,_ J '-"" . I: 1 I:: I I I I: i: t I I' ,mrVI5{~~jl ""'~___~"~"_"~ ,__~"""'^r~~~~,;;~"t("";Y~",W'''':'''-'''''''~''''Il'':i,...!?, '~"'}W~8)j!l~dijd'JiJ~Iim~!~i~;'li ",--'~t'."~~ll'X:'j" '__T~'T~r ,- ,-: _ T L_ SHERIFF'S RETURN - REGULAR CASE NO: 2001-07069 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS - ,- .... .. CASS PATRICIA A MARLEY ".,- JASON VIORAL , Sheriff or Deputy Sheriff of ... '... ." Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CASS PATRICIA A MARLEY the DEFENDANT , at 2115:00 HOURS, on the 20th day of December, 2001 at 15C CREEKSIDE LN CARLISLE, PA 17013-7833 by handing to PATRICIA CASS a true and attested copy of COMPLAINT & NOTICE together with - .... .... .... ,,- and at the same time directing Her attention to the contents thereof. ... .. ... Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 3,25 .00 10,00 ,00 31.25 So Answers: 1T'~vt:~ R, Thomas Kline 12/26/2001 PARK LAW ASSOC. Sworn and Subscribed to before By: ~~ //,/~I y Sheriff V '. ..Ii -10 ~... me this ~'!:< day of C)AA~ J()().2- A.D. Cfrr~ 0_ Jl1d{w ,n~~ rothonotary) I ' . . ;'~niiW~ ~.~,"" ~ ~ I" - " , , _.~~. .~ "' _ 0 ~'I~.' ,__lfIl1i '~p.,r?,F,' ,'J,-~l " -"atf~~,rJ:. ::,"_ ~ . , 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: 15C CREEKSIDE LN CARLISLE, PA 17013-7833 4428472276204671 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS PATRICIA A MARLEY CABS Defendant I NO, 01-7069 CIVIL TERM PRAECIP,E FOR JUDGMENT I 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: $5,994,51 $1,019.00 $152,10 ($O.OO) ($0.00) $7,165,61 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 Procedure No. m.l i" '''ached hm'o =t;1d ~. VALERIE ROSEnsLuTH PARK,ESQUIRE Attorney for the Plaintiff AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL "'l AND NOW, ~ .~~ 4, o:2~6a , Judgment is entered in favor of the Plaintif and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification, _"~ c , " ~ , ,~ - "~"'~~-'~' ,..! ""''''~'1-~ " (':!f"ll'-',,!,'-' T Jil CM'7.;;, 1<. ~) OT ONOTARY ::J:/Y) 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. :;~jl;~~-,.I __, -' ""~ '_~='UA_, . _ , 11 H'~ VALERIE ROSENBLUTH PARK ATTORNEYLD. # 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 I HEREBY CERTIFY THAT TIrE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 15C CREEKSIDE LN CARLISLE, PA 17013,7833 PROVIDIAN NATIONAL BANK Plaintiff VS PA1RICIA A MARLEY CASS Defendant NO, 01-7069 CIVIL TERM NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: P A1RICIA A MARLEY CASS 15C CREEKSIDE LN CARLISLE, PA 17013-7833 DATE OF NOTICE: 1/11/02 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TIllS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIIE DATE OF TIllS NOTICE, A nJDGMENT MAY BE ENTERED AGAINST YOU WIlliOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIIER 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 TIIE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR CARLISLE,PA 17013 (717) 240-6200 PARKLA:SSO~='7 BY: ~ VALERIE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATIEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAlNED WILL BE USED FOR THAT PURPOSE. EXHIRIT 4 ~,,~~ Jfn -,'3 ,,~,,~ ", ' ^ " I" ' " ";,,, - --'I""""""'" ~ r VALERIE ROSENBLUTH PARK ATTORNEY LD,# 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: 15C CREEKSIDE LN CARLISLE, PA 17013-7833 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS PATRICIA A MARLEY CASS Defendant NO, 01-7069 CIVIL TERM 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 PATRICIA A MARLEY CASS, Defendant is over 21 years of age; that hiS/her place of residence/business is located at lSC CREEKSIDE LN CARLISLE, PA 17013-7833 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 19 ~ and its amendments, PARK LA ASS TES, P,C, E10 ,?"-;'::;O;'~!".1ir'J~ -.--,.----,~.'" '"",' BY: Valerie Rose Park Attorney for Plaintiff "_.","~_,o_,,,,,,,, ~. .~_ e, "F''1''''~ ''''~''-''':'~'t ,~,'=. -,!."'~,,w~v;;-_ . , 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: 15C CREEKSIDE LN CARLISLE, PA 17013-7833 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO, 01-7069 CIVIL TERM PATRICIA A MARLEY CASS 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 indicattedbelow: [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 NOTICE, PLEASE CALL: Park Law Associates, P,C, at this telephone number: (215) 348-5200. PURSUANT TO THE REQUIRED THAT WE STATE TO COLLECT A DEBT, ANY PURPOSE, PR~HO~ARY? ~~ ~/J 'J?~ FAIR DEBT COLL~ON PRACTICES ACT, IT IS THE FOLLOWING TO YOU, THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR THAT - ~-, - .~. ','" , ~ ,~~ ~- . w~ " .. ._....."""""...~"~,~l!5al!'l;Il,i!',liW~ ~ ~ ~ !~,',.,-.-~ "~~ "''''' ~E ~" '" ,,'" 'Y,'~' . "~, ~>~" "'<~:'''',a"- 'n~"" ;(""\'nh"'~"~-<"~~~""j0i'\'T7~\mr~rill'~Yl\~Fi0'~;;j'r;;lffr}<r'{"lr~l1YF\l~.'~iil!1I@~L5:"~1"Yd :U~T'l': r-p(J.fIJ. t fl:-~b - '- iJ () F ~ ~ ~ ~~cv~ t ~ JiI!l:1" , _ _, ,1 !i)i\ll'MrV; ,~~ , ~~~"fll..~'!~f~~~("'f.{'ii,,"";}:^f,;f~~~--O;:;;' o C ? gJfP --;;;"r- ~'~:" ~:~ C~, ~:I::' 5(J L "7 :;=-{ ,.< o I"'v 'Tl ,-T'j CJ r-:- .~ .'D '.,1"': T:-? ( --;r:-I ,..,!i ~~rJ -, tD 'f',,:<c:c;,\',W::,,' ;i<n',ii~~I~",I'\1l'~;;;l:(9!~\''''?!-f'ihllii;)~F,)f.'W'lJii.f*1i~1\:~'~JfM.~j->,;