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Home My WebLink About99-049571 V i V n Y Ta. i d? VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION Plaintiff VS JAMIE L. KREIGER Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. N O T I C E 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 ox 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 ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION 5040 Johnson Drive Pleasanton, CA 94566 Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS JAMIE L. KREIGER 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 Defendant . NO. 9 9- `1957 ??- C I V I L A C T I O N COUNT I 1. FIRST SELECT CORPORATION, a California corporation, domiciled at 5040 Johnson Drive, Pleasanton, California 94566, 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 JAMIE L. KREIGER, an individual who resides at 4301 A CARLILSLE PIKE, CAMP HILL, PA 17011-0000. 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 4168100001957867. 4. The Defendant has failed to pay the amount owed in accordance with the agreement of the parties and has failed to pay outstanding debt as agreed. 5. The Defendant is indebted to the Plaintiff in the amount of $6,381.50 as of 05-11-99, plus pre-judgment contractual interest at the rate of 10.00% per annum, less payments made to date in the amount of $.00. 6. In accordance with the agreement of the parties, Plaintiff is entitled to reasonable attorneys fees, and Plaintiff will incur attorney's fees in the amount of $1,276.00. COUNT II 7. Plaintiff hereby incorporates paragraphs 1 through 6 above as though set forth in full. 8. The Defendant received a monetary benefit, which was in fact appreciated by the Defendant. 9. The Defendant accepted the benefits. 10. 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. 11. 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 $6,381.50, plus pre-judgment interest at the contractual rate of 10.00% per annum from 05-11-99 until the date of the judgment herein, less payments made in the amount of $.00, plus reasonable attorney's fees in the amount of $1,276.00, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE R ENBLUTH 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 JAMIE G. SHFPMOI-?R , states that she/he is the Designated Agent of First Select Corporation 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 JAMIE L. KREIGER the sum of $6,381.50 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. 4168100001957867 `a } N r' 4 :n? Q SHERIFF'S RETURN - REGULAR CASE NO: 1999-04957 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS. KREIGER JAMIE L CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within CIVIL ACTION was served upon KREIGER JAMIE L the defendant, at 20:28 HOURS, on the 18th day of August 1999 at 4301 A CARLISLE PIKE CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to JAMIE L. KREIGER a true and attested copy of the CIVIL ACTION together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service 18.0 8 68 So answe 0 Affidavit . .00 00 Surcharge 8.00 omas ine, eri $3gb8 PAI?K 14AW OFFICES 08/19/1999 by e y eri Sworn and subscribed to before me this /1a day of 19 0,6 A. D. ro ono r 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: 5040 JOHNSON DRIVE PLEASANTON, CA 94566 DEF: 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 CUMBERLAND COUNTY COURT OF COMON PLEAS FIRST SELECT CORPORATION Plaintiff VS E q6 - 7 JAMIE L. KREIGER Defendant NO. 994952CV 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 $6,381.50 $1,276.00 $230.78 $80.18 ($0.00) ($0.00) TOTAL $7,968.46 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. J 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". VALE E RO BLUTH PARK, ESQUIRE Att ne for the Plaintiff AND NOW, fit l Judgment is entered in favor of the Plaintiff ahd Against the Defendant by Default for want of an Answer and damages assessed in the sum of $7,968.96 as set forth in the above certification. t o PURSUANT TO THE FAIR DEBt-tO TICTION 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. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION Plaintiff VS. JAMIE L. KREIGER Defendant : CUMBERLAND COUNTY : COURT OF COMMON PLEAS NO. 994952CV NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: JAMIE L. KREIGER 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 DATE OF NOTICE: 919199 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PARK LA A OCIATES, P BY: VALERIE ROSENBLUTH PARK, ESQUIRE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. --41- , 1 L: f? tU LL C." CTI 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: 5040 JOHNSON DRIVE PLEASANTON, CA 94566 DEF: 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT CORPORATION Plaintiff VS JAMIE L. KREIGER Defendant qq-4-q r7 NO. ° QiCV 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 JAMIE L. KREIGER, Defendant is over 21 years of age; that his/her place of residence /business is located at 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 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 ASSOCIATES, P. . BY: Vale e nbluth Park Attorney or Plaintiff E10 L ` J )Cl rn `j 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: 5040 JOHNSON DRIVE PLEASANTON, CA 94566 DEF: 4301 A CARLILSLE PIKE CAMP HILL, PA 17011-0000 CUMBERLAND COUNTY COURT OF CObWON PLEAS FIRST SELECT CORPORATION Plaintiff VS JAMIE L. KREIGER Defendant NO. 994952CV 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 [ ] Money Ju [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment j Judgment ] Judgment ] Judgment ] Judgment ] Praecipe by Default figment in Replevin in Possession on Award of Arbitration on Verdict on Court Findings on District Justice Transcripts on Judgment Note on Writ of Revival 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. P 71HONOTARY: U 0?- PURSUANT TO THE FAIR DEBT COLLECTION PRAC ES 2T, 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HARLAN J. KAHLER, JEAN H. KAHLER, Husband & Wife Plaintiffs, V. ERIE INSURANCE GROUP, ERIE INSURANCE EXCHANGE and WEITZEL INSURANCE AGENCY, DONALD S. WEITZEL and DONALD S. WEITZEL, JR. Defendants. SCOTT'S PINE TREE INN, INC. Plaintiff, V. ERIE INSURANCE EXCHANGE Defendant. SCOTT'S PINE TREE INN, INC. and GREGORY A. SCOTT and LINDA A. SCOTT, Plaintiffs, V. DONALD G. WEITZEL, JR., DONALD G. WEITZEL, SR., WEITZEL INSURANCE AGENCY, ERIE INSURANCE GROUP AND ERIE INSURANCE EXCHANGE Defendants. Fte 15 2000 ' CIV. ACTION NO. 98-6007 JURY TRIAL DEMANDED CIV. ACTION NO. 98-7325 JURY TRIAL DEMANDED CIV. ACTION No. 99-4857 JURY TRIAL DEMANDED ,JJORDER AND NOW, on this iT~ day of 2000, it is hereby ORDERED and DECREED that Defendants' Motion to Consolidate is granted. Accordingly, the above-captioned actions entitled Harlan and Jean Kahl r husband and wife v Erie Agency D nal S. Weitzel Sr, and Donald S. Weitzel Jr., docketed at 98-6007, Scott's Pine Tree Inn Inc. v. Erie Insurance Exchange, docketed at 98-7325, and Scott's Pine ree Inn Inc. and Gre or and Linda Scott v. Erie Inaurance Grou Erie Insurance Exchange. Weitzel Insurance Agency Donald Weitzel Sr. and Donald G. Weitzel Jr., docketed at 99-9857, are consolidated. 4W4 J. ? 60 04 'q \0