HomeMy WebLinkAbout99-04374
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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney Z.D. #72094
PARK LAW ASSOCIATES, P.C.
25 East State Street
(215) 348-5200
Doylestown, PA 18901
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
VS
PAUL M OSSMAN
Defendant
N O T I C E
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO. 9g y37Si G?+a.?-?
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
VALERIE ROSENSLUTH PARK, ESQUIRE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 East State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
VS
PAUL M OSSMAN
Defendant
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO.
C I V I L A C T I O N
COUNT I
1. PROVIDIAN NATIONAL BANK, a national banking association
domiciled at 295 Main Street, Tilton, New Hampshire 03276, and
existing under the laws of the United States of America, is the owner
of a credit account opened at the request of the Defendant.
2. The Defendant is PAUL M OSSMAN, an individual who resides at 1
WEST PENN, CARLISLE, PA 17013-2346.
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 4168511700002153.
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
$3,266.94 as of 03-18-99, plus pre-judgment contractual interest at
the rate of 23.30% per annum, less payments made to date in the amount of
$.00.
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 $653.00.
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.
WHEREFORE, Plaintiff demands that judgment be rendered in favor
of the Plaintiff, Providian National Bank, and against the Defendant
in the amount of $3,266.94, plus pre-judgment interest at the
contractual rate of 23.30% per annum from 03-18-99 until the date of
the judgment herein, less payments made in the amount of $.00, plus
reasonable attorney's fees in the amount of $653.00, 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.
STATE OF CALIFORNIA
COUNTY OF ALAMEDA
HEATHER KOOREMAN states that she/he is the Designated
Agent of PROVIDIAN NATIONAL BANK and is authorized to take this
affidavit on its behalf and that the facts set forth in the
foregoing complaint are true and correct to the best of her/his
information, knowledge and belief; that there is now due and owing
from PAUL M OSSMAN the sum of $3,266.94 plus interest and attorney
fees; and that there are no deductions or offsets of any kind,
except as are therein specified and credited in the complaint.
She/He further understands that false statements made herein are
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
41il
Designa ed gent
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EXHIBIT
• , ,hill IILi,;. (I*3 V Uk (? w I j?), i?• i f ?, ( ), h t?aF
Providian National Bank VISAT or MaslerCaid9 Account
Account Agreement for Paul M 0-man
Please review this document and keep it with your other important paper; This Account Agreement contains the terms winch govern your Providan Nmional Bank VISA or MasterCard Account
(The'Accounl') The Account allows you to make purchases by using your VISA or MaslerC.hd card ime'Ca c'I wnereve, it c nonorel and Ic get ash a,Ivance5 from us or any other parllopallng
Thermal Inshlueoo and from Aulcma led Teller Machines Convenience rneos may also be provided to you as an additional way to use the Account this wgreemenl
each person for whom we have opened 3 credit and ACobunI ",ye -'Our "CUru " and 'us' mean Promdian Plarenal Bank or ifs assignee; as osted of your billing statement 'yCemU and your' mean
The Account may be
used only for personal, family, household and charitable purposes arid not for any eusmess or commeram purpose Any use of Into Account shall consioure acceptance of The terms of Ihn
Agreement You and we agree as follows
Payments. You will receive a monthly statement showing your outstanding balance Payment on his Account is resulted in U S dollar; (Check: mull be payable at a U S office of the bank the
check is drawn on) for at least The payment due as shown on your statement by the payment due dale in accordance win payment instructions or yam monthly statement Convenience checks
and other checks we issue to you may not be used to make payment: on your Account or to make payments on any other account you have with us or our affiliate: The payment due will be 2%
of the new balance shown on your statement plus the amount of any past due payment plus Inc amount by 4hpn the new balance exceeds year rredn line However the caym ril due will not be
less than $15 (unless your new balance is less Than S 15 in which case The payment sue will be the amount of the new ealarce) If /our Account is past due or above the mean line we may require
a higher minimum payment but we will notify you before doing so If your payments more roan the payment one 14 ill ce treated as a single Calmest and none of it will be applied to future
yments due We may accept late or panlal payments or payments marked 'paid In full' or marked with other restK! % without .osmg our right to sorest all amounts owing un&r this
Pa
Agreement
Finance Charges. Except as described in The Grace Period for Purchases section of this Agreement finance changes begin to accrue on a aeon 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 Purchase Balance which consists of your existing Purchase Balance and new purchases
you make with your Card and fees for certain optional services, the Custom Cash Advance Balance which consists of your existing Custom Cash Advance Balance and certain balances that you
transfer to your Account using balance transfer checks and balances teal we transfer for you antl The Ca2h Advance Bolancz which consists of all other cash advances Any payment amount we
receive that exceeds The finance charges and fees then due will ordinarily be applied first to the Balance with the fewest Annual Percentage Rate (APR), enter that Balance its zero, and Then to the
Balance with The next lowest APR, unlit Thal Balance is zero, and then to any remaining Balance We reserve the right to apply payments Differently wal l further notice The Purchase Custom
Cash Advance. and Cash Advance Balances are reduced by paymems as of the date received and by credits (except for reversals of late over-limn. and miscellaneous charges) as of the dale
posted Purchases are included in your Purchase Balance as of Ine date made Custom cash advances are included 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 balances as of the dale presented to us Other cash advances are included in your Cash Advance
Balance as follows cash advances tram other financial institutions and through Automated Tellers as of the dale 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 print on the check all other checks as of the dale presented to us Other debits (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 billing cycle There is no grace period for custom cash advances or other cash advances
To figure the dairy finance charge for each Type of Balance, we start with your previous day's Balance, add all deals and subtract all credits for The riurent day and multiply The net amount by the
applicable daily 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 credit balance for any day as
zero We determine the total finance charges an balances for [tie 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 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 for such a transaction will be the rate in effect for the current btlhng cycle rather Than the rate in effect on the date of the transaction
Your statement includes an average daily balance for each type of Balance You can multiply each average daily balance that is not zero by the number of days in the billing cycle and the periodic
Tate 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 Is charged. That amount is
also a finance charge
The ANNUAL PERCENTAGE RATE (APR) for purchases is 23 3%, corresponding to a daily periodic rate of 0 C6384%
The ANNUAL PERCENTAGE RATE for custom cash activeness is 23 3%, corresponding to a dally periodic rate of 0 C6384%
The ANNUAL PERCENTAGE RATE for cash advances is 23 3%, corresponding to a daily periodic rare of 0 06384%
We reserve the right to change The Annual Percentage Rate calculations if you do not comply with the Terms of This Agreement
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 cycle You will pay no finance charge on such new purchases if you pay the total new balance in full by the payment due dale shown on your
statement New purchases posted in any other billing cycle incur a finance charge, and there is no period in which such purchases may be repaid without incurring a finance Charge
Rebate. On the last day of each monthly statement period we will credit your Account with 1% of your net purchase hansaclwns posted during The statement Period 'Nei Purchase Transactions'
means Card purchases, less purchase adjustments and purchase credits posted during the period
Fees. We will charge your Account up to W for each Card you ask us to replace, each returned payment check, each check you write on your Account Thal we return unpaid, each stop payment
order or renewal of such an order each btlhng cycle within which your Account is delinquent (late charge), and each bdnng cycle within which your balance exceeds your credit line, even of your
Account is closed If you request copies of billing statements that were first sent to you more than three months earner. we may charge a handling fee of S2 for each such copy A cash advance
fee of 3% (minimum S5) 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 Io be incomplete or untrue, if you do not comply with any part of this Agreement, upon your death, bankruptcy, or
insolvency, of you do not pay other debts when due. If a bankruptcy pefilion is filed by or against you or if we believe in good faith that you may not Day 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 even) of your default, the outstanding balance on your Account shall continue to accrue interest at the APR(s) disclosed in the Finance Charges sec;IOn of This Agreement, even if
we have filed suit ro collect the amount you owe
Credit Line. Your credit line is specified from time to lime in a separate notice We may increase or decrease your credit line based on information we oblamed Irom 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 you send us a large payment
check, we may 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 Account for, and we may refuse to
honor, any transaction which would cause you to exceed your available credit
Promise to Pay. You promise Io pay us when due all amounts borrowed when you or someone else use your Account (even d the amount charged exceeds your permission), all other
transactions and charges to your Account, and collection costs we incur mcWdmg, but not limited to reasonable attorney's fees and court costs (If you win the sun, we will pay your reasonable
attorney's fees and court costs )
Changes. After 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 emne Account balance from the effective ate of the change Changes will apply to balances that Include items posted to your
Apppunt before The date of the chdnne and will apply whether or not you Continue to use.. the Account
Foreign Exchange/Currency Conversion. If you use your Card for transactions in a currency other than U S dollars me transactions will be converted to U S dollars. generally using either a (0
govemmenl-mandated rate or (u) wholesale market retain effect the day before the transaction processing date increased by five percent (5%) If a credit Is subsequently given for a transaction it
will be decreased by the same percentage If The credit has a different processing date then line exchange rate of The cremt can be greater/less than that of the original transaction The currency
conversion rate on The day before the transaction processing date may differ from the rate in effect at the time of the transaction or on fine date The transaction is posted on your Account You
agree to accept the converted amount in U S dollars
The Card; Cancellation. You may cancel your owd l privileges at any time by nehh;mg us in writing and desncvlrg'he Cards! .con the Card expiration at The end of the month shown on it we
reserve The right not to renew the Card We may cancel the Card and your credit privileges at any lime after 30 days nohce m you or without notice if permitted by law It your Card is cancelled or
not renewed, finance charges and other tees will continue To be assessed. payments will continue to be due, and all Cther aapCwGe provisicrs of this Agreement will remain in effect If you
terminate your credit privileges or of we cancel or do not renew the Card. you may no longer write checks on your Acccurn and ycu should destroy any unused checks we have issued to you
Personal Information; Documents. You will provide us at least 10 days notice it 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 Information from others including Cecil reporting agencies and to provide your address and Information
about your Account to others Werra y also share mformat on with out affiliates However, you may wine to ;s it any lime isstructinc. us nor Io share credit inform rt on without affil area If you
do not fulfill your obligations under this Agreement a negative credit report that may reflect on your credit may be sopmnted io me ;redo 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 Identification
Plumber ('PIN', which provides access to Aulomaled Teller Machines) and any checks issued to you from then and keeping your PIN separate from your Card If you discover or suspect That
(Continued on reverse) (5846.0698) 4168511700002153 0412 451 /'r'I
your Card PIM, or any unused creeks are lost or stolen or that (here may be an unautnonxd transaction on your Account . •y,w..'promplly notily us by calling 1.800.972.7221 So we can
immediately act to limit losses and liability, you will phone us even though you may also notify us in xnhng Your liability for unaumeurzed use occurring before you notify us is limited to $50 II you
report or we suspect unauthorized use of your Account we may suspend your credit privileges unlit we resolve the problem to our Satisfaction or issue you a new Card If your Card its lost or
stolen, you will promptly destroy all checks in your possession To imomve 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 i eller Machine refuses to hcnor me Card or accept your checks or fads to return the Card to you Via have no responsibility
for goods and services purchased'knh the Card or checks except as required by law (See Special Rule below ) Certain panels that are available with the Account are provided by third party
vendors We are not responsible for the quality , availability or results of any of the semeec you encase to use
Stop Payment Orders. It you wish Io stop payment on a check you may send us a stop payment vder by wrong to us at our adi for customer service listed on your statement You can
make a slop payment order orally by calling the number listed on your statement When you make a stop payment order you must provide your Account number and specific information about the
check the exact amount the dale on the check the name of the party to whom it was payabe the name of the person who Signed it and the check number You will be asked to confirm an oral
slop payment order in whling We may dsrernard your gal ofder A we do not tilt we a ?gned wnlipn Confirmation w.;hill two weei after the oral order or if we have not received an adequate
description of the item so That payment canbe slopped I ne order wN not ce ene^.We it IM :nett. was paid cy us before we nail a reasonable ccircounay to act on the order Vie may without
tiabntity. disregard a written stop payment order six months alter receipt unless it is renewed in wining
Standard of Care. Because this Account involves both credit card and ^.neck hancagicns wn2 are processed tnf such Cyanide national systems before the transactions are consolidated by us
and because not every check and Card slip will be sent to us transactions in your Account kill ce crccecsed mechanically without our necessarily reviewing every item Our processing system will
call our attention to certain items which we will examine Vie will examine all Iransactions wren you report Thal your Card or Cnecks have teen lost or stolen We do not intend ordinarily to
examine all items and we will not be negligent if we do not do so This rule eafathshep ire standard of ordinary care which we in gcod thin will exercise in administering your Account Because
of our limited review and because neither tout cancelled Checks nor Card transaction Pip: kvl Le iemned to you kiln Ire man;n,y stetemem jr, inculd be careful to enter all checks in your
check register or otherwise keep a record of them You should aLO save yew vedn Cars Ca;n acrance one pwaa:e ?w +a ai•rse to rherrycu• mo lh v statements against your record aril
to not iv us .or of any nai monzed transactions or errors
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 Idler You waive the fight 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 sun against you
Applicable Law; Severabllity; Assignment. No mailer where you live, this Agreement 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 contradicted by evidence of any alleged oral agreement If any provision of this Agreement is held to be invalid or unenforceable,
you and we will consider that provision modified to conform to applicable law and the rest of the provisions in the Agreement will still be enforceable At any lime after we determine in good faith
that any proposed or enacled legislation, regulatory action, or judicial decision has rendered or may render any material provisions of this Agreement invalid or unenforceable, at impose any
increased tax, reporting requirement, or other burden in connection with any such provision or its enforcement. we may. after at least 30 days notice to you, or without notice if permitted by law,
cancel the Card and your Credit privileges We may transfer or assign our right to all or some of your payments It state jaw 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 stales 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 records, unless a longer notice period is specified in this Aggreemenl or
bylaw, 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 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 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 bill Write to us as soon as possible We must hear from you no later than 60 days alter we sent you the fast 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 II you need more information, describe the item you are not sure about.
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 the error or explain why we believe the bill was correct After we receive your 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 your credit line You do not have to pay any questioned amount whine 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 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 owe and the date that it its due If you fail to pay the
amount we think you awe, we may report you as delinquent However, of our explanation does not satisfy you and you wrne 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 settled between
us when it finally is If we don't follow these rules, we can't collect the first S50 of the questioned amount, even of your bill was correct
Special 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 good faith to correct the
problem with the merchant, you may not have to pa 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, or of not within your home state, within 100 miles of Sour current mailing address and (b) the purchase price must have been more than S50. These limitations do not apply lives own
of operate the merchant, or of we mailed you the advertisement y, the property or services
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04374 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS.
OSSMAN PAUL M
PATRICIA SHATTO , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND CIVIL ACTION was served
upon OSSMAN PAUL M the
defendant, at 14:10 HOURS, on the 27th day of July
1999 at 1 WEST PENN # 526
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to PAUL M. OSSMAN
a true and attested copy of the NOTICE AND CIVIL ACTION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 3.10
Affidavit .00
Surcharge 8.00 R-I omas in 5 eri
$zTo.iu PAR I
4AW OFFICES
07/28/1999 epu y ? eri
Sworn and subscribed to before me
this a
,J F _ day of C?
19 A. D.
?•
EL 0 - .x0/4
rotnonotary
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: 1 WEST PENN
CARLISLE, PA 17013-2346
COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
PAUL M OSSMAN
Defendant NO. 99-4374 CI
i
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
PLUS OUTSTANDING COSTS
LESS PRINCIPAL PAID
LESS OTHER PAYMENTS
TOTAL
$3,266.94
$653.00
$348.27
$74.60
($0.00)
($0.00)
$4,342.81
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. 237.1 is attached
hereto and marked Exhibit "A". /
VALEPCP. ROSENBLUTH PARK,ESQUIRE
Att ney for the Plaintiff
AND NOW, Q f ?? G Judgment is
entered in favor f the Plaintiff and against the Defendant
by Default for want of an Answer and damages assessed in
the sum of $4,342.81 as set forth in the above
certification.
e v.
THONOTARY
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.
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. 472094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
FIRST SELECT CORPORATION : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
VS.
PAUL M. OSSMAN
Defendant : NO. 99-4374
NOTICE OF PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT
TO: PAUL M. OSSMAN
1 WEST PENN
CARLISLE, PA 17013-2346
DATE OF NOTICE: August 19, 1999
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN 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
Cumberland County Bar Association
4th floor Cumberland Courthouse
Carlisle, PA 17013
(717) 240-6200
PARK LAW ASS IATES, P
BY:
VALE ROSENBLUTH PARK, ESQUIRE
THiS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBR
w
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: 1 WEST PENN
CARLISLE, PA 17013-2346
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
PAUL M OSSMAN
Defendant
NO. 99-4374 CI
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 PAUL M OSSMAN, Defendant is over 21 years of
age; that his/her place of residence/business is
located at 1 WEST PENN CARLISLE, PA 17013-2346 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 amendments.
PARK LAW AS CIATES,
BY:
Val ie Rosenbluth Park
Attorney for Plaintiff
E10
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: 1 WEST PENN
CARLISLE, PA 17013-2346
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
PAUL M OSSMAN
Defendant NO. 99-4374 CI
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 ANY QUESTIONS CONCERNING THIS
NOTICE, PLEASE CALL: Park Law Associates, P.C. at this
telephone number: (215) 348-5200.
PROTHONOTARY:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,
IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS
AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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