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HomeMy WebLinkAbout99-04312:1,. :. `]'Ii; 4'3f+ ?, Hr, ?'?:?. !:x ,?' ".•:`r 1'lYr tiKk ::j, i:`<?. ?? i.. .0 '. .Q 1 L Ma 'J 1 Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PROVIDIAN NATIONAL BANK NO. 99. 4/3/a C? IN CIVIL ACTION -vs- Plaintiff(s) BERTHA M. RICHMAN Defendant(s) COMPLAINT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: James R. Apple, Esq. PA I.D. No. 37942 Charles F. Bennett, Esq. PA I.D. No. 30541 Joel E. Hausman, Esq. PA I.D. No. 42096 Marylouise Wagner, Esq. PA I.D. No. 61095 APPLE AND APPLE, P.C. Pirm No. 719 4650 Baum Boulevard Pittsburgh, PA 15213-1237 Telephone (412) 682-1466 Fax (412) 682-3138 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PROVIDIAN NATIONAL BANK NO. IN CIVIL ACTION -vs- Plaintiff(s) BERTHA M. RICHMAN Defendant(8) NOTICE TO DEFEND 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 upon you, by entering a written appearance personally or by 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 any other claim 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 Telephone (717) 249-3166 Toll free: 1-800-990-9108 2 COMPLAIN 1. Plaintiff is a National Banking Association located in Tilton, New Hampshire. As of January 1, 1998, Providian National Bank was merged into First Deposit National Bank, and the resulting entity took the name Providian National Bank." The account that is the subject of this lawsuit may have been either a First Deposit National Bank account or a Providian National Bank account prior to the merger, but is now an account of the new" Providian National Bank, which is the plaintiff herein. 2. Defendant is an individual whose address is 208 Senate Avenue, No. 920, Camp Hill, Cumberland County, PA 17011. 3. At a specific instance, the Defendant applied for and was granted credit by the Plaintiff at the terms and conditions agreed upon by the parties, as is more specifically shown by the Account Agreement, a true and correct copy of which are attached hereto, marked Exhibit A" and made a part hereof. 4. Defendant made purchases and/or received cash advances using said credit. 5. Plaintiff avers that the terms of the Agreement provide for acceleration of the entire balance due and owing upon Defendant's breach of the Agreement. 6. Thereafter, in breach of obligations under the Agreement, the Defendant failed to make payments as they became due. 7. Plaintiff avers that the balance due amounts to 86,586.19. 8. Plaintiff avers that interest has accrued at the rate of 21.90% per annum on the balance due from February 10, 1999. 9. Per the terms of the agreement, the Defendant has agreed to pay to the Plaintiff as liquidated damages, the costs of collection, including all reasonable attorneys' fees incurred in the collection of monies owing. 3 10. Plaintiff avers that pursuant to Plaintiff's agreement with Plaintiff's attorneys, Plaintiff's attorneys are to receive attorneys' fees of 33 1/3% of the debt due. 11. Plaintiff believes, and therefore avers, that said attorneys' fees rate is just and reasonable compensation for the services rendered by said attorneys. 12. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the amount due Plaintiff or any part thereof. WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $6,586.19 with appropriate additional interest, attorneys' fees and costs. APPLE AND APPLE, P.C. By: U4, )U ?- Attorneys f Plaintiff(s) 4 ljj' PROVI DIAN l•mmnvii Providmn National Bank VISAM or MasterCard® Account Account Agreement far Bertha M Richman February 16 1999 Please review this document and keep d with your other important Papers This Account Agreement contains the terms which govern your Prowdran National Bank VISA or MasterCard Account (Ihe'Accouri The Account allows you to make purchases by using your VISA or MasterCard card (the 'Card') wherever it is honored and to get cash advances from us or any other Participating mancial inflation and from Automated Teller Machines Convenience checks may also be provided to you as an additional way louse the Account In this Agreement, "you" and "your' mean each person for whom we have opened a credit card Account 'We,"ow "ours' and *us* mean Provision National Bank or its assignees, as listed on your billing statement The Account maybe fami household usedemmlor PYou erand we agree as to lows and charitable purposes, and not far any business or commercial Purpose Any use of this Accounl shall constitute acceptance of the terms of this 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 5 office of the bank the check is drawn on) for at least the payment due as shown on your statement by the payment due date In accordance with payment instructions an your month lIyy statement 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 Pr our al61ates The payment due will be '. 2% of the new balance shown on your statement plus the amount of any past due Payment. plus 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 the cretil line, we may require a higher minimum payment, but we will notify you before doing so If your payment is more than the payment! due, It will be treated as a single payment and none of it will be applied to future payments data We may accept late or Partial payments, or payments merkeo'paid in full' or marked with other restrictions, wdhool losing our right to collect aft amounts oong under this Agreement. Credit Review: Special Requirement In order to keep your Account in good standing, you agree not to significantly increase the amount of your total debt on unsecured revolving accounts. We will review your Account and cremt profile regularly to evaluate the amount you owe relative to the amount of your then current income (We consider an increase in debt of mare than $2,000 to be slgmficam, unless you have sufficient income.) If we determine that your Account is not in good slanting, your ANNUAL PERCENTAGE RATES (APR) for purchases, custom cash, and cash advances may be increased Finance Charges. Except as described in the Grace Period for Purchases section of this Agreement, finance charges begin to accrue on a debit when it Is included in one of your dally balances and continue until that balance is reduced by a payment or credit. Your Account has three balances the P r It I which consists of purchases you make with your Card and fees tar certain ophona! services; the Custom Cash Advanc n whnh consists of balances that you transfer to your ccount using balance transfer checks and balances that we transfer for you, and the no lent which consols of all dlhen cash advances Any payment amount we receive that exceeds the finance changes and fees then due will womanly be applied first to the Balance with the lowest nnual Percentage Rale (APR), until That Balance is zero and then to the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balarice. We reserve received , and by credits (except the right to appy payments dfferenlly without further notice The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the dale for reversals of lace, overhmn, and miscellaneous charges) as of the date posted Purchases are included in your Purchase Balance as of the date made. Custom cosh advances are Included in your Custom Cash Advance a as follows. funds electronically transmitted to other lenders to transfer balances, as of the date transmuted, checks to transfer balances as of the date Presented to us Other cash 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 request, as of seven days after the date we pant on the check; all other checks, as of the date presented to us Other Is (except for late, over-limit finance, and miscellaneous charges) are Included in your Purchase, Custom Cash Advance, or Cash Advance Balance as of the date posted Finance charges are added to your Purchase, Custom Cash Advance, and Cash Advance Balances each day and are then posted on the last day of the tilling Cycle There is no grace period for custom cash advances or other cash advances To figure the daily finance charge for each type of Balance, we start with your previous day's Balance, add all debits and subtract all credits for the current day and multiply the net amount by the applicable dally periodic rate (see following paragraphs). The finance charge for each type of Balance is then added to and included in that day's Balance We treat a credl balance for any day as zero. We determine the total finance charges on balances for the billing cycle by adding logether the finance charges for each type of Balance for each day within the billing cycle. In calculating finance charges, an adjustment will be made for any transaction or payment that would have affected the finance charge calculation in a prior billing cycle had it been posted in that cycle The applicable dally periodic rate far such a transaction will be the rare in effect for the cal l bitting cycle rather than the rate in effect on the date of the transaction Your statement Includes an average dally balance for each" of Balance You can multiply each average dally balance that is not zero by the number of days in the filling cycle and the penodic rate to obtain subtotals. and then add the subtotals together to determine your total finance charges on balances for the billing cycle If a cash advance transaction fee rs charged, that amount is also a finance charge The ANNUAL PERCENTAGE RATE (APR) for Purchases is 211 corresponding to a dally pri rare of 0 06000% The ANNUAL PERCENTAGE RATE for Cash advances is 219%. corresponding to a daily periodic rate of 0 06000% If you do not Comply with the terms of this Agreement your ANNUAL PERCENTAGE RATE for purchases will be 2199/6, comespondny to a dally periodic rate of 0 06000%, and the APR far cash advances and custom Cash advances will be 23.9%, corresponding to a daly periodic rate of 0.06548% Your Account maY be etigtble for the lower regular APRs after you have met the terms of this Agreement far three months if you contact us we will renew year Account to determine your eligibility for the lower APRs Grace Period for Purchases. New purchases posted to your Account in billing cycles with no previous balance. or when the previous balance was fully paid during the cycle, do not begin to incur a finance charge until the start of the next billing 7cle You will pay no finance charge on such new purchases if ou pay the total new balance in full by the payment due dale shown on your statemenl. New purchases posted in any other billing cycle incur a finance charge. and there is no period in whlcK such purchases may be repaid without incurring a finance charge Rebate. On the fast day of each monthly statement period we will credit your Accounl with 1% of your net purchase transactions posted during the statement period 'Net Purchase Transactions' means Card purchases less purchase adjustments and purchase credits posted during the period Fees. We will charge your Account up to S29 for each Card you ask us to replace each returned payment check 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 balance exceeds you r credit line, even d our 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. A cash advance lee of 3% (minimum 55) may be charged for each cash advance transaction made on your Account 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 pan of this Agreement, upon your death, bankruptcy, or msoNenCy, if you do not pay other debts when due, if a bankruptcy petition is filed by or against you, or if we believe in good faith that you may not pay or perform your obligations under this Agreement If you are in default 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 APR(s) disclosed in the Finance Charges section of Ihrs Agreement, even d we have filed suit to collect the amount you owe Credit Line. Your credit line is specified from fire to time in a separate notice We may increase or decrease your credit line based on information we obtained from you olyour credit records. Your available credll is normally the difference between your credit line and your Account balance (including transactions made or authorized but not yet pasted) II you send us a large payment check, we may limit your available credit while we confirm that me check will clear For certain transactions. available credit may be less You will not use your Account for, and we may refuse to honor, any transaction which would cause you to exceed your avallaole 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 tansactmns and charges to your Account, and collection costs we incur including, but not limited to, reasonable attorney's lees and court costs (Il you win the suit. we will pay your reasonable attorney's fees and court costs ) Changes. Alter we Provide you any notice required by law, we may change any part of this Agreement and add or remove requirements If a change is made to the Finance Charges section of this Agreement, the new finance charge calculation will apply to your entire Account balance from the effective date of the change Changes will apply to balances that include items posted to Y99L Acrdunl before the date of the draftee, and will apply whether or not you continue to use the Account Foreign ExchangelCurcency Conversion. If you use your Card for transactions in a currency other than U S dollars the transactions will be converted to U S dollars, generally using either a (t) government mandated rate or (n) wholesale market rate in effect he day before the transaction processing dale increased by five percent (5%) If a credit is subsequently given for a transaction, II will be decreased by the same percentage If the credit has a different process.ng date. then the exchange rate of the credit can be grealerdess lium that of the original transaction The currency Conversion rate on the day before the transaction processing date may differ from the rate .n effect at the time of the transaction or on the date the transaction Iis posted on your Account You agree to accept the converted amount in U S dollars The Card; Cancellation. You may Cancel your credit privileges at any 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 light not to renew the Card We may cannel the Card and your credit privileges at any!Ime after 30 days notice to you or without nonce if permitted by law If your Card is cancelled or not renewed. finance charges and other fees wAI continue to be assessed, paymerus will continue to be due. and all other appl cable provisions of this Agreement will remain in eff 1 terminate your credo privileges or if we cancel or do not renew the Care, you may no longer write Checks on your Account, and you should destroy any unused checks we have Iss ftv (Continued on reverse) 158460698) 4426231000200722 1048 Personal Information; Documents. You will provide us at least 10 days notice if you change your name. home or matting address, telephone numbers, employment or income Uponour request, you will provide us additional financial information We reserve the fight to obtain information from others, including treat reporting agencies, and to prgwde your address and information about your Account to others We may atio share information with our al Ig eii However you m; vin t us at any time ^Iruct ng s not to share i dIl nlOrmair with our affiliates If you, do not fulfill your obligations uncer this Agreement, a negairvo credit repon that may reflect on your credit may be auomnted to the creod 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, yyour Personal tdentiftcabon Number ('PIN', which provides access to Automated Teller Machines) and any checks issued to you from (hell and keeping your PIN separate from your Card If yyou discover or suspect that your Card. PIN, or any unused checks are lost or stolen a that there may be an unauthorized transaction on your Account, you will promptly notify us by calling 1A00.933.7221 So we can immediately act to limit losses and liabdil you will phone us even Inough You may aiso ngtify us in writing Your liability for unauthorized use Occurring before you rally us is limited to S50 If you report or we suspect unauthorized use of your Account, we may suspend your credit privileges unit] we resolve the problem to our satistaclion or issue you a new Card If your Card is lost or stolen, you will promptly destroy all checks in your possession To improve customer service and security. you agree that your calls may be monitored or recorded Merchant Relations. We will not be liable if any person or Automated Teller Machine refuses to honor the Caro or accept your checks, or falls to return the Card to you. We have no responsibility for goads and services purchased with the Card or checks except as required by law (See Special Rule below j Certain pertains that are available with the Account are provided by Ihr"rty vendors. We are not responsible for the quality, availability, or results of any of the services you choose to use Stop Paymem Orders. If you wish to stop payment an a check, you may send us a stop payment order by canting ;o us at our address for customer service listed on your statement. You can make a stop payment ardor orally by rolling the number listed on your statement. When you make a slap paymem order, you must provide your Account number and specific information about the check: the exact amount, the date on the check, the name of the parry to whom it was payable, the name of the person who signetl il, and the check number. You will be asked to confirm an oral stop payment elder m writing We may disregard vour oral order it we be not receive a awned wntlen conf rmatron w thin Ica we>k? dinar the oral ceder, or if we have not received an adequate descnpuan of the item so Thal payment can be stopped The order viii] not be effective it ]he check was paid by its before we had a reasonable opportunity to act on the order We may, wdMut lial lliry, disregard a written stop payment order six months after receipt unless n Is renewed m canting Standard of Care. Because this Account involves both creel card and check transactions which are processed through separate national systems before the ]r3nsachems areccnso'rdi tedby us, andbecauser not every check and Card slip will be sent to us, transactions in your Account will be processed mechanically without our necessanly reviewing every item Our prooessi gsystem will call our attention to certain items which we will examine. We will examine all transactions when you report that your Card or checks have been krst or stolen We do not inlendorchit to examine all items, and we will not be negligent if we do not do so. This rule establishes the standard of ordinary care which we in good faith will exercise in administering your Account. Because of our limited review, and because neither your cancelled checks nor Card transaction slips will be returned to you with the monthly statement, you should be careful to enter all checks in your cfreckreiister or otherwise keep a record of them. You should also save your treat card cash advance and purchase slips You agree ticcheck your monthly Siatilli against your (mod and to noli y tie immedraterv of any unauthorized transactions or errors Wainer of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it of anp other provision later. You waive. the night to presentment, demand, protest, or notice of dishonor, any applicable statute of limitations, and any right you may have to require us to proceed against anyone before we file suit agaiml you Applicable Law; Se"mbilKy; Assignment No matter where you live, this Agreemenl and your Account are governed by federal law and by New Hampshire law This Agreement is a final expression of the agreement between you and us and may not be contradided by evidence of any alleged as] agreement. II any provision of this Agreement is hell to be invalid or unenforceable, you and we will consider that provision modified to conform to applicable law, and the real of the provisions in the Agreement will still be enforceable. At any time after we determine in good faith that any proposed or enacted legislation, regulatory action, or judicial decision has rendered or may render any material provisions of this Agreement invalid or unenforceable, or impose any increased tax, reporting requirement, or other burden in connection with any such provil or its enforcement, we may, after at least 30 days notice to you, a without notice if permitted by law, cancel the Card and your Credit privileges We may transfer or assign our fight to all or some of your payments If 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 Sate. Notices. Other notices to you shall be effective when deposited in the mail addressed to you at the address shown on our records, unless a longer notice period is specified in the Agreement or by law, which period shall start upon mailing. Notice to us shall be mailed to our address for customer service on your statement (or other addresses we may specify) and shall be effective when we reserve 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 questions About Your Bill. If you think your bill is wrong, or if you need more information about any transaction on your bill, write us, on a separate sheet, at our address for customer service listed on your bit!. Write to us as soon as possible. We must hear from you no later than 50 days after we sent you the first bill on which the choral 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 Amount number. -1 he dollar amount of the suspected effor. - 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 Your Rights and Our Responslblilties After We Receive Your Written Notice. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Wilhin90days, we must either correct the error or explain why we believe the bill was correct. After we reserve your letter, we cannot try to collect any amount you question, or repon 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 your credit line You do not have to pay any questioned amountwhi]e we are investigating, but you are still obligated to pay the pans of your bill that are not in question. five find that we made a mistake on your bill, you will not have to pay any finance charge related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to makeup the missed payments on the questioned amount. In either case, we will send you a statement of the amount you we and the date that it s due. If you ail to pay the amount we think you axe, we may report you as delinquent However, if our explanation does not satisfy you and you white to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you question your bill. And, we must tell you the name of anyone we reported you to We must tell anyone we report you to that the matter has been sealed between us when it finally is. If we don't follow these rules, we cant collect the first $50 of the questioned amount, even if your bill was correct. SpedN Rule for Credit Card Purchases. If you have a problem with the quality of the property or services that you purchased with our credit card and you have tried in goad faith to correct the problem with the merchant you may Trot have to pay the remaining amount due on the goods or services. There are two limitations on this right (a) you must have made the purchase in your home state, 'If not within your home state, within 100 miles of your current mailing address, and (b) the purchase price must have been more than $50 These limitations do not apply If we own or operate the merchant, or if we mailed you the advertisement , the property or services VERIFICATION NEIATRERKOOREMWProvidian National Bank, Plaintiff herein, verify that the statements of fact contained in the foregoing Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 13 Pa.C.S. 4904, relating to unswom falsification to authorities. Date Pleasanton, CA. 94566 Title - Designated Agent Address -P.O. Box 9053 f a O T C7 O n M SHERIFF'S RETURN - REGULAR CASE NO: 1999-04312 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS. RICHMAN BERTHA M DAVID MCKINNEY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon RICHMAN BERTHA M the defendant, at 15:58 HOURS, on the 21st day of July 1999 at 208 SENATE AVENUE NO 920 CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to BERTHA M RICHMAN a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 9.30 Affidavit Surcharge 8.00 R-as 57_ . OPPLE & APPLE 7/23/1999 by ?z?n 3 ep SFieri Sworn and subscribed to before me this Z 9.e,.t day of 191717 AA.D.., A ¦ IN THE COURT OF COMpEN PLEAS OF CUMBERLAND COUNTY PROVIDIAN NATIONAL BANK -us- Plaintiff(s) BERTHA M. RICHMAN Defendant(s) NO. 1999-04312 IN CIVIL ACTION PRAECIPE FOR DEFAULT JUDGMENT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: James R. APPle, Esq. PA I.D. No. 37942 Charles F. Bennett, Esq. PA I.D. No. 30541 Joel E. Hausman, Esq. PA I.D. No. 42096 Marylouise Wagner, Esq. PA I.D. No. 61095 APPLE AND APPLE, P.C. Firm No. 719 4650 Baum Boulevard Pittsburgh, PA 15213-1237 Telephone (412) 682-1466 Fax (412) 682-3138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PROVIDIAN NATIONAL BANK -vs- Plaintiff(s) BERTHA M. RICHMAN Defendant(s) TO THE PROTHONOTARY: NO. 1999-04312 IN CIVIL ACTION Kindly enter Judgment against the above-named Defendant(s) in Default of an Answer, in the amount of $9,887.82, computed as follows: Amount named in Complaint $ 6,586.19 Interest from February 11, 1999 to September 11, 1999 on $6,586.19 829.86 Attorney Fees 2,471.77 Payment TOTAL $ 9,887.82 I certify that Notice of the intention to enter this Judgment was given pursuant to Pa. R.C.P. 237.1. A copy of said Notice is attached, and was mailed on August 11, 1999 by Regular mail, postage prepaid and, addressed as follows: Defendant: Bertha M. Richman 208 Senate Avenue No. 920 Camp Hill, PA 17011 APPLE AND APPLE, P.C. Dated: By: Attorne for PlAinti 4s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PROVIDIAN NATIONAL BANK NO. 1999-04312 IN CIVIL ACTION -ss- Plaintiff(s) BERTHA M. RICHMAN Defendant(s) Bertha M. Richman 208 Senate Avenue No. 920 Camp Hill, PA 17011 Date of Notice: rh IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN 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 EUN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone (717) 249-3166 Toll free: 1-800-990-9108 APPLE AND APPLE, P.C. By: rames R. Apple, Esq. Attorneys for Plaintiff(s) 4650 Baum Boulevard Pittsburgh, PA 15213-1237 Telephone (412) 682-1466 S `L,+ ?C a U e f=' Li V7 m [T V y li