HomeMy WebLinkAbout99-06158VALERIE 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
PROVIDIAN NATIONAL BANK
COUNTY
Plaintiff
CUMBERLAND
COURT OF COMMON PLEAS
VS.
PATRICIA J. FREBERG
Defendant
NO. 67?- ??SO &CILt C_
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 SG6iRNgGM &y' /155octa4L v 1
CARLISLE, PA 17013 ) .2- I ,r, n
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
VALERIE ROSENBLUTH PARK
ATTORNEY I.D. N 72094
PARK LAW ASSOCIATES, P.C.
25 EAST STATE STREET, P.O. BOX 177E
DOYLESTOWN, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
cuUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
295 MAIN STREET
TILTON, NH 03276
PLAIN:IFF
VS
PATRICIA J. FREBERG
11 E. Green St.
Shiremanstown, PA 17011-•-,,l
DEFE! : AT
CIVIL ACTION
1. PROVIDIAN NATIONAL 31':K, an o,ei,nization domiciled at 295
MAIN STREET, TILTON, NH Ji.:76, and !::fisting under the laws of the
United States of America, s the of-rn-r of a credit account opened
at the request of the De:idant.
2. The Defendant is PAT;? iA J. FF'TiG, an individual who
resides at 11 E. Green S•:.. Shirem, :: -own, PA 17011-6551.
3. The Defendant is indt! ed t-, P-1 Miff on the credit account
by virtue of charges or :, 1i auvan, incurred by the Defendant or
authorized by the Defenda: on .- cic;_t card or line of credit
owned by the Plaintiff b+?_ing icccnumber 4428001617201409.
4. The terms of said ac., .:nt are ci,:ed in the documentation
attached hereto as Exhib. "A."
5. The Defendant has fa : :1 to pa;. ne amount owed in accordance
with the account agreeme;; and has f:'.led to pay the outstanding
debt as agreed.
6. The Defendant is ind,?; ed to tie .11aintiff in the amount of
$3,599.89 as of 06/17/19)x, plus pie--judgment contractual interest
at the rate of 23.308 per annum, les payments made.
7. In accordance with tha documentation attached as Exhibit "A,"
Plaintiff is entitled to ?,asonabl( .?!:torney's fees, and Plaintiff
will incur attorney's fe,:•; in the e:m,int of $719.00.
COUNT II
8. Plaintiff hereby inc ;orates ia,.igraphs 1 through 7 above as
though set forth in full.
9. The Defendant receive: a monetar, benefit, which was in fact
appreciated by the Defeni{.''_.
10. The Defendant accep t tho bete ts.
11. By virtue of the ci::: .nstance: :rrcunding the request for
funds made, the Defendan• nowingl,.,, : quested the funds at issue
and/or knowingly and vol.i: arily a c,:ted the benefits bestowed.
12. It would be inequit.i, (3 for t.l.i: court to allow the Defendant
to retain the benefits o; he fund: -r to be unjustly enriched at
the expense of the Plain'_ ff' or al'o.. the Defendant to retain the
value of the funds at is:: witnou; :.paying the Plaintiff the
value of same.
WHEREFORE, Plaintif-. :.,,?manc!s 'h: judgment be rendered in
favor of the Plaintiff, `tIDIAN !:A':.o!!AL BANK, and against the
Defendant in the amount )3,5`)9.,9, taus pre-judgment interest
at the contractual rate '3. "11)% :•e: annum from 06/17/1999 until
the date of the judgment !rein, plus: reasonable attorney's fees
in the amount of $719.00, less paymen:,.s made, plus costs and any
other such relief as this 'ourt deem: reasonable and just.
!'ARK LAW AS'OCIATES, P.C.
l y:
VALER .0 BLUTH PARK, ESQUIRE
PURSUANT TO THE FAIR DEB': !OLLECTION PRACTICES ACT, IT IS REQUIRED
THAT WE STATE THE FOLLOW."13 TO YOU: THIS IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATION O7i,AINED WILL BE USED FOR THAT PURPOSE.
STATE OF CALIFORNIA
COUNTY OF ALAMEDA
MARY M. MAXEDON 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 PATRICIA J. FREBERO the sum of $3,599.89 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.
0 1 6 i
91kkzo
Designat d Agent
4428001617201409
i w ICS??
*PROVIDIAN
yr :.]^:, l' n3'Gar" /:$4'J I :x,a; Vr'..ly:
please review INS document and keep it win your Over rpodanl woe's Tr. :_rI A2 wmerl::htars Re trims Anion gb.err y3N P•cv+dan:jmral Bare it Of MasterCard Accounl
IIM'ACCount') The Account aiWws you to make pulUases ty a::rg far 4I;A :'a;:rr„ar7:XJ (re 'ad') A^e'e,er I , r,n rr7 an 71: ;al cash a trances from Us or any oTer pan,Gpating
nail institution and from Automated Teller htachmes Ccnvemence ":is may a s: to:rovSed tO you 3s an 34-AuOral hi to use the ::ant In this Agreement 'you' and 'your' mean
each person for wnom we have opened a credit card Account "Ne "out ' %-,' 3,1 'us' rem Prcil can for onal Bank or is asotrrees as Ia!es on your pilling statement the Account may be
used only for personal family household and chil purposes ans rot fzt an; C.: ress on C.mmH:ol purx:e Any use cr:n3 Ac:curt that CcnS!lule acceptance of Ine terms of m:9
Agreement You and we ayee as follows
Payments. You will receive a mommy st3lemenl Showing your oulstmsng ta'ance nayrenl:n this ACC, url is re'p:ned in U S Jaats tort must be payable 31 3 U S office of the hank the
Check IS drawn on) for at !east?ne payment due as shown cn your sa'erecl tj the car rent ace oaten aces :ante Alh payment rStru,!"3n5:n yar mormty Statement Conyentente checks
and other Checks we issue to you may not be used to mare payments on yCu- r' C::err .r to rare caymerts :n ahy Othl acccurst v:u rave AJh us or our 3ffikales The payment dive hills be 2%
of the new balance shown on your statement plus the amount :f an Cast one p3.rera and r3y'nC!uk the amour) by vi ire -ew balance ercects your Crlat live However. the payment
due will not be less than S15 (unless your new balance Is less than 515 in hr¢h case Ire payment clue war be file amount of me re* baance) if your Ac::unt is past &a or above file credit line
we may require a higher minimum payment but he will notify you be!ae son.; s. I o,r pavrert s more Iran Ire payment l.e it cad be 1reJ'el AS 3 s.ng'e payment and none of II All ca applied
to future payments due live may accept tale or partial payments or pay rents manes in fun' Cr man el Adn crier restrictions *,!hat IOs.rg :ur Ighl to COIIeCI ail amounts owing under this
Agreement
Credit Review: Special Requirement. In order to keep your Account n good sfanang you agree not b sgrit"ritty ?ncre3oe %e amount :1 your Icat debt on unsecured revolving accounts We
will renew your Account and credit profile regularly to evaluate the amount you cure rea:ne to file 3mourt cf your then current income (','4e c:rs4er an increase indebt of mOle than S2 0001o h
significant, unless you have Sufficient income ) If we determine that yar Account is not in goof standing your ANNUAL PERCENTAGE RATES (APR) for purchases, custom cash and cash
advances may be Increased
Finance Charges. Except as descried in the Grace Period for Purchase Balance se,.ron of this Xy"..mert finance charges begin to accrue on a deoa when it it included in one of Your daily
balances and continue until that balance is reduced by a payment or crest Your A :curl has Ire fcltam,, winces The PWcha52 Ba'an:e worth consists of your ernt,ry Purchase our
and new purchases you make with your Card and fees for Certain optional sen ces one of more rustCm ..a;n Advance Balances with COn9SIS of balances Ihal you ?ins err to yCUr Account
using balance transfer checks and balances that we transfer for you. and the Cash A Amte Balance which consists of ad otner assn advances Any payment amount we receive that exceeds the
finance charges and fees then due All ao:nary be applied first to the Ba arce Mlh the lowest Annual Percentage Rate (APR). until that Balance is zeJ and then to the Balance With fine next
lowest APR, until that Balance IS Zero and then to any remaining Balance Yle reserie the right to appty parrents differently wimout tither nc!,,e The Purchase Custom Cash Advance and
Cash Advance Balances are reduced by payments as of the date reserve and ply oeaa as of the dale posted Purchases are,flowes m your Purchase Balance as of the date made Custom
cash advances are Included in your Custom Cash Advance Balance as IOIIews form e'ectwn,caiy Iran:mole to oher enders W iransler Caances as or me disk transmitted. checks to transfer
balances. as Other date presented to us Other cash advances are ihciude to your Cash Advance Balance as fc?kms cash advances from Cher f rancal ,nst:futiom also through Automated
Tellers. as of the date made, cash advance Checks made payable to you that are cenr!ea as ca: tier s checks and male to you at your request 3s of seven days after the date we print on the
check, all other checks, as of the Gate presented to us Other debde are mcrudd:n your Purchase Custom Cash Advance Of Cash Advance Balance as of the date posed Finance charges are
added to your Purchase. Custom Cash Advance. and Cash Advance Balances each 331 aM are then boilers on me last day of Ire pilling cycle There is no grace period for custom cash
advances of other cash advances
To figure the daily finance charge for each yper of Balance we sad won ycUi pnI oar s Balance 3sJ all sects and Sublt3.1 all cretin fcr Ire current day Am multiply the net amount by the
applicable daily periodic rate (See following paragraphs) The finance charge for each Price of Sa ance wren 3oaW to 3rd mCIUJe in that day's Balance We treat a credt balance fa any bay as
Zero We determine the total fihance charges on balances for the billing cycle by adi together the finance charges for each nice of Balance fcr each day within the piling cycle In Calculating
finance charges, an actuslment well be made for any transaction of payment trust wad nave aflec!eJ the finance charge calculation in a pry Cnling Cycle had a been posted in trial Cycle The
applicable daily periodic rare for such a transaction *Pit be the la!e.n effect for tee cucera tdl,ng cycle rather than the rate in effect :n tae dale of the transaction
Your statement includes an average daily oaance for each vice of Balance You can nUBply each average day balance Ihal is rot :ero ty me hurter of days in the piling cycle and the periodic
rate to obtain subtoas. and then add the subtotals logetrer to aolermre your 101316r3rce charges cis ta'ances la the ttil Ing cycle If a cash 3of3nce uaneaclnn fee is charged that amounts
also a finance charge
The ANNUAL PERCENTAGE RATE (APR) for purchases is 23 3% corresCUnan, a a cady pericisc tae of 006384%
The ANNUAL PERCENTAGE RATE IN custom Cash 3dvanes s 23 3% c:rescerd ^.; to 3 obi p2uaJC rate of J CE384'k
The ANNUAL PERCENTAGE RATE IN cash advances is 23 31k conesponing fo a oily pef.,x rate of 0 C•i384%
If you do not comply with the terms Of this Agreement your ANNUAL PERCENTAGE RATE fcr puorla:es Ad to 23 3% cerrr:xncl^ to a Jay cerwdlc rate of 0 Co384% and the APR for Cash
advances and custom cash advances w 1i be 23 3% CereS;Cndinj to a a3?tr period: rate :l O C6384% YAin Account ray Dx! e'+; tae IN Ire !ewer regular APRs aher you have met tre terms of
hit Agreement fa three months If you contact us we wit review your Ac:cunt to x'e'mine your el;too^v la the Inver APRs
Grace Period for Purchase Balance. New purchases Posted to your Account In Cia rj yc!es win no previous balance or wren Ire crev:cus wince was fully paid during ire cycle do not begin
to recur a finance charge until I" sad olive neirCNng c,ve YOU All wy vo t rarce _rar;e on such rem, ;urraCes if you par Ire 1:-al rem taarce m tint by me payment oue d3!e shown on
your statement thew purchases posted in any other tilirg cycle :ncur 3 trance crar;e and :here is ro ptr.rrs'n which such bur:fires may to rrad witnoul incwnrg a finance charge
Rebate. On the last day of each monthly statement perod wo *,it OPdit your Acc,unt cam Pk •;I yell, rep;vcrnce Irersac!Icha pastes luring tre statement period 'Nel Pmehape Transactom'
means Card purchases, less purchase aauslmerfs and purchase Neol c sled ourr j the rercd
Fees. We wit charge your Account up to SO for each Card you ask us to r?toace ea:n reto:ned:aynient cre:k e3:h check you our e on yar Account that we return unpaid each step payment
order of renewal of such an order each pining Cycle within which your Account rs cle ill uent late chaise) 3r1 each ailing circle hill M which your balance excel JS your credit time even if your
Accounl n closed If you request copies of billing statements that were first sent to you more loan three means e3ner tie may charge A n3ncng fee of S2 tot each such copy A cash advance
fee 00% (minimum S5) may be charged for each Cash advance tans3ction M33e cn pour Account
Default. You will be in default if ary information you provided u: proves a te,n:Or;'ete or sripue it god a nW copy ern a^/ cart cf Iris ATNmenl. K/3n your deals baN.ruptGy y
insolvency. if YOU do not par otter debts when Gve if a bankruptcy peraen s fled ty a s;anst you cr if he beoeve m good fan that you maj roil pay or perform your cWlgalans under this
Agreement It you are in de cult we may. w:thoul further demand err noire Ca^:el goer ails? phi:Mes W..'a'e your Account taarce Imm03'eil Just and psy3ble and use any remedy we may
have In the event of your default. the outstanding balance on your Accafl srvl ccrtnue!o accrue interest tar the APR(s) disclose n tre Finance Charges section of this Agreement even if
we have red suit to collect the amount you roue
Credit Line. Your crests line is specd?e from time W lime in a Secaaa nine yJe ray increase of de^re.yse your oral line ta:rJ on infyrahsn he obtained from you or your credit records
Your ava.laDe credit it normally the alference between your :real me anJ cur a:;:unt taarce (n,,u snj !rai:av,ons raar cr aunytzed td list yet poste) It you send us a large payment
check, we may limit your available treat while we con! rm That Ire check win cieal pa cena'n ran;ac; crs av113114 cress ra'y to eSs you Ail rot use your Account for and we may refuse to
tow. any transaction which weUld Cause YOU to exceed your av1Iabe of"!
Promise to Pay. You promise to pay us when due all amounts p cacv.e Aron you'., s:retire else use your ACCanI seven 1 the aro.r! cna,;e excelos your peenr^,;gn) all omen
transactions and charges 10'r 00r Account, and colleitcn costs we iro r rc'udnj but nor rim All 13 reJS:r:,L f a'krrev -a '".s tar] c:url Ccss f you w:n the Suit As will pay your feasoralpe
attorney's fees and could costs )
Changes. After we provide you ary rol,ce resui el by !law Ae tray change 3ry pa! :! Ih's Agile?mert 3-13 Itof remove re:. e-ii-%^ it a orange rS made to ml Finance Charges section of
AtAh, Agreement. t"e new finance cilar;e calcualcn mdl agcy to your erne Acrurt tao^ce'rcm the sines've are ct ^e czar.;e C"a";es III -I xIcy o balances that i?de'tems anted I yQyr
tMlnt Dl17P the dale of me chants and will acisy Avenel, OI nit )cu c;rl nee a A:-% I
Foreign Exchange/Currency Converslon. ffy_uu evour Carsf rfur a:-.,r a -. rl•J:w !err a J s: 1. err a A to e•'eVoUS sours genealyusinglliu lg
governmenbmajlded tale Cf I ill NrCItS3Ie market rate n ef,ecl . e o t tae 1 ] iD ?N a'r ea es ; f . 1 , ' ] Il1t 4 suC PNe Pr gNen IN a if3n;dCldn d
writ be Oeck3std tY pre Stare Ge¢rna,e Inner crew has3l' re. ,u e:,.r, l..?n^+?.. axe hale tie r.a':mte.Tram ru.an131 •t the rg rat rarsac'+:n The curred^y
ConveR,cn flak cis Ire day bx'fye ICP IUrSlrtipn ; rpxs;ing Ga!e. mat is "" "Jr "?' a'r " c"rill AI PA I Ter ;1 I^e I....... bur •n pre .1r, Ire "lrsa.licn is postv"1 on your Account You
agree to accept ire conv?t'r l ail Hrrl n U 5 (I)II m
The Card; Cancellation you may cancel your nettit 1. cvr ' 7s nA,. in I If r !ra.;i r J•fe.: ra?cn tar me emsdlremon'n:n:Ancisd we
reserve Ire rgnl rOI ib rearm, Ir Car] Vie mat ca co r tar 7 l l ,'. + r ,e: JI lr r r J . r toss ... e h ,c lm, _ ,' ce I;erm "e by law if hour Card . c3ncelled a
not renemme LhanC! Cndrgr: and ,.fret rev`s call crisp. u? .s pre a e. , l;^? 1 A cis, ru : b J ? a'?7 a of artrW A r v. r .1 !h s A;lint All reran in effect Ifyou
terminate your cookl;rnilljrs of f ne cancel cis Y n I renew 1 e x,ar 7 311 r.. , uL 2%r:; any unused cr.ecks we have issued to you
/rot
0184 Wit
Personal Informatlon; Documents. You will provvk u; at teast 10 Says roue d you cgnge tour name Pierre or mating awes teephone minters empoymenl or income Upon Syyr
request you w:Il piovpe us addhonai firarctal mlormaticn Pte ,7 Is the rgnt to shorn niormaten from strey, irc!udrg credit reeomng agencies and 10 Pov'de yo.t Mess amt;e5UMdlron
about your Account to others We may also share •nl.;rmatan Win Cur aff•ha'e; N-wev+? v W mar w?'e to 6s it try I a %11o wire cr-hl inf:imalii *,in our atn6auej. If you
00 not fulfill your obgalCr I under INS Agreement a negalrve credit report tnel Mary reflect on you treat may pe si,cmerea ill me ve,11 necoffing 3;0_ C.es
Customer Service; Unauthorized Use, Loss, or Theft of Checks or the Card. Each Card must ea ogned on retest You are respon; tie 1_1 salegwrd.ng me Call your Personai Identification
Number j PIN' which provides access to Automated Teller hlacmresi and ary crecos issued to you from then and keeping your Pill ;ecafale from your Card If you discover or suspecl that
your Card PIN or any unused checks are lost of stolen or that mere may pe an unaumcrzed transaction on your Account You *AI pronbOy Potty us by calling 1.800.932.7221 So we can
immediately act to limit losses and lab NN, you wol prone us even though you may also MCI-fy us an wntmg Your liability tot cnaumon;ed use occurring before you notary us is limited to S50 If you
report or we susciii unauthorized use of your Account we may suspend your credit pmriages until we resolve tire problem to our sahsfacton or issue you a new Card it your Card is lost of
stolen, you will promptly destroy all checks in your possession To improve customer senvCel and security. you agree that your calls may to monitored Of recorded
Merchant Relations. We win not be table if any person or Automated Teller Macnine refuses to momi me Card or accept your cnecks Or rags to return the Card to you We nave no responsibility
for goods and services WrchaSed with the Caro of checks lxCt01 as r i ed by law (See Special Rule below ) Certain berefds In]I are available win the Account are bowed by thitdparty
vendors We are not respcnsibe for the Quality, availability, Of results 'any Tied
Of the services you choose to use
Stop Payment Orders. If you wish to slop payment on a check you may send us a slop payment order by wrl,ng to us at our address for customer service listed on your statement You can
make a slop payment older orally by caatg the number listed on your statement When you make a stop payment order. you must prov de your Account number and specific information about the
check the exact amount, the dale on the check the name or Pie party to whom it was payable. the name of 14 person who signed it and the check number You will be asked 10 confirm an oral
slop payment order in writing We May drsrMLd Your oral order d we da not negSrye a si0^ed wmtlen conM1rmatraa within two weeks after the oral order or if we have not receved an adequate
desorption of Modern so that payment can be stopped he Order will not be effectve d Ire check was paid by us before wa had a reasonable opportunity to act on I" older We may vithout
kal dsregard a written stop payment order am months after recepl unless d it renewed in writing
Standard of Cen. Because this Account involves both credt card and check transactions which are processed through separate national systems before the transactions are comolidated by us.
W because not every check and Card slip will be semi to us, bansaclons in your Account will be processed mechanKaly, without Our necessarily IeViewing every item Our processing system will
Can our attention to certain items which we will examine We win examine all transactions when you report that your Card Of checks have been lost cr stolen We do not intend udnardy to
examine an items. and we will not be negligent it we do not do so This rule establishes be standard of Ordinary care which we in good tank will exercise in aammmilermg your Account Because
of our limited rNiew, and because nether your canceled checks nor Card transaction slips will be returned to you win the mcnny statement. you should be careful to enter an Checkf in your
check register or otheri keep a record of them You should also save your credit card casm advance and purchase sips You asree to check Your monthly statements aaaiMl Your ecod and
to noM1N us immediately of any unauthorized transactions of enrols
Waiver of Certain Rights. We may delay or wave enforcement of any provision of Mrs Agreement without losing out fight to enforce d Or any other provision later You wane the right to
presentment, demand, protest, or notice of dlshonos. any applicdbe statute of limitations and any right you may have 10 require us to proceed against anyone before we file sun against you
Applicable Law, Sewrabllity, Assignment. No mallet where you live Ihm. 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 contradcled by evidence o1 arty alleged oral agreement If any provision of this Agreement is held to be invalid or unenforceable,
you amt we wdl coniKW oral p(oylion modfed to conlym to applicable law, and the rest oft" provisions in the Agreement will still be erforceabie At any time after we determine in good faith
1 arty proposed a enacted legislation. regulatory action, or judicial decision has rendered ol may render any material piov,sans of this Agreement invalid or unenforceable or impose arty
utoreased tax, reporting requirement. or other burden in connection with any such provision or its enforcement we may after at earl ?0 dsys notice to you, Of without notice if permdtedby law,
mxN the Card "your Credil privileges We may transfer of assign our right to an or some of your payments 11 state law relfwas that you receive nolice of such an event to protect 0e
purchaser or assignee, we may give you such Police by riling a finereing statement with the state's Secretary Of Stale
Notices. Other notices to you shall be effective when deposited in the mat addressed to yyou al me adders shown on our records unless a longer Police period is sprrf?ed ut this Agqreement or
bylaw, which period shall start upon mail rig Notice to us shall be mailed to out address for customer service on your statement (or other addresses vie may specify) and shall be effective when
we received
YOUR BILLING RIGHTS -KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our resconstbihters under the Fair Credit String Act
Notlfy Us In Cue of Errors or Ou u dons About Your Bill. If you think you bin is wrong or if you need more information about any transaction on your bin, wife us on a separate sheet, at the
address listed in the Billing Rights Summary on your bin Write to w as soon as post a We must hear from you no later than 50 days after we sent you the first pin on which the error of problem
smeared Youtan teephoro us, but ddrg so win rot peserve your rights In your leper gve us the following informa!On ..Your name and Account number -The dollar amount of the
suspected errs - Describe the error and explain, d youcan wny youbelieve there acs an evor if you need mole Mlormalon, describe the item you are riot sure about
Your Rights and Our Responsibilities After We Receive Your Written Hoots We must acknowledge your letter within 30 days unless we have corrected the error by then Within S0 dap,
we must amts correct the error or explain why we believe the bill was correct After we rri ve your ielter we Cannot try to collect any amount you question on report you as dereva enl We can
continue to bon you for the amount you question, including finance charges and we can acpy any unpaid amount against your treat line You do not have to pay any questioned amount while we
are uwestigahrg. but you are slip cblgated to pay the parts of your bill that are not in question
Nwe fib Thal we made a mistake on your bill, you will nct have to pay any finance charge related to any questioned amount If we don't make a mistake you may have to pay finance charges.
rb you win have to make up the missed payments on the questioned amount In timer case we cam send you a statement of me amount you owe and the dale mat it acs tae If you fml to pay the
amount we flunk you Owe we may report youas dehnq ent However, four explanaton does not satisfy you and you write to us wthm 10 days tellirg us that you VIA refuse to pay. we must ten
rryone we report you to that you question your dill And we must tell you the name or anyone we reported you to 'As must lea aryone ws report you to trial the matter has been silted between
sop when t finaly n If we don't follow these rules, we can't collect the first S50 of the questioned amount, event your bit was correct
Special Rule for Credit Card Purchases. If you have a problem with the quality of the property or services that you purchased without credit card and you have tried in good faith to correct the
=m wth the merchant. youmay not have to pa•II the rema.Ping amount due on the good: or services There are two umna!icn: cn this rgrl (a) you must have movie the purchase in your
home stale, or if not within your home state, within IW miles cf?our current mailing Mess, and jb) the purchase price roust have teen more non $50 These limitations do rot apply if** own
or operate the merchant, or dl we marled you the advertisement or the property or servKes
I ."Om, Ihn •h,rl hFm Jn.) wurn n in IM• 1.wlagr 1•.11J rn., 11,1r pr,nh)rll
.10 , .,..
hclvenllnf 19, 1997
Yes, I'd like the no-annual-fee VISN Cold.
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VALERIE ROSENBLbTH PARK, ESQURIE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
PATRICIA J. FREBERG
Defendant NO. 99-6158
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above captioned matter settled, discontinued
and ended upon payment of your costs.
PARK LAW ASSOCIATES. P.C.
BY
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'
LL. C? 7
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06158 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK COUNTY
VS.
FREBERG PATRICIA J
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within CIVIL ACTION was served
upon FREBERG PATRICIA J the
defendant, at 12:19 HOURS, on the 13th day of October ,
1999 at 11 E GREEN ST
SHIREMANSTOWN PA 17011-6551 CUMBERLAND
County, Pennsylvania, by handing to PATRICIA FREBERG
a true and attested copy of the CIVIL ACTION
together with NOTICE ,
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
1
Docketing 18.0
Service 8.06 6
Affidavit .00
Surcharge 8.00
afiT3?K13Tf?; S
H. 'Ell
S34.U , PARK I,AW ASSOCIATES
10/14/1999
(r?
nc?e? y
by -h,
Sworn and subscribed to before me
this day of
199? A.D.