HomeMy WebLinkAbout99-06159VALERIE 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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PROVIDIAN NATIONAL BANK
Plaintiff
VS.
BONNIE L HARDY
Defendant
NO. `7'1 " lp L.?
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.
OR 2 r5u1??
CUMBERLAND COUNTY TiiGGTSE
1 CARLISLE, PA 1701 17013
(717)34000"e
?,21Fti-3 t (oL
THIS IB AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
VALERIE ROSENBLUTH PARK
ATTORNEY I.D. # 72094
PARK LAW ASSOCIATES, P.C.
25 EAST STATE STREET, P.O. BOX 1779
DOYLESTOWN, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
=4BERIAND COUNTY COURT OF COFAION PLEAS
PROVIDIAN NATIONAL BANK
295 MAIN STREET
TILTON, NH 03276
PLAINTIFF
VS
BONNIE L HARDY
530 Enola Rd.
West Fairview, PA 17025-0000
DEFENDANT
NO.
CIVIL ACTION
1. PROVIDIAN NATIONAL BANK, an organization domiciled at 295
MAIN STREET, TILTON, NH 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 BONNIE L HARDY, an individual who resides at
530 Enola Rd., West Fairview, PA 17025-0000.
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 4428231970502735.
4. The terms of said account are stated in the documentation
attached hereto as Exhibit "A."
5. The Defendant
with the account
debt as agreed.
has failed to pay the amount owed in accordance
agreement and has failed to pay the outstanding
6. The Defendant is indebted to the Plaintiff in the amount of
$11,021.82 as of 08/31/1999, plus pre-judgment contractual
interest at the rate of 12.009 per annum, less payments made.
7. In accordance with the documentation attached as Exhibit "A,"
Plaintiff is entitled to reasonable attorney's fees, and Plaintiff
will incur attorney's fees in the amount of $2,209.00.
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 $11,021.82, plus pre-judgment interest
at the contractual rate of 12.008 per annum from 08/31/1999 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $2,204.00, less payments made, 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.
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS
Valerie Rosenbluth Park, Esquire, being duly sworn according
to law, deposes and says that she is the attorney at law for Park
Law Associates, P.C.;
( ) That the party lacks sufficient knowledge or information
to take a verification;
Outside the jurisdiction of the Court and that the
partiesyverification can not be obtained within the time allowed
for filing of the foregoing;
That I am authorized to take this verification; that the
facts contained in the foregoing matter are true and correct to my
information and belief; and
That the source of my information or facts of documents are
provided by my client.
ZVE5RIEE ROSENBLUTH PARK, ESQUIRE
Complete this short form and return it in the poslage-paid enve:opt provided.
30-Second Response Certificate
j es, i want to accept your lnvita bn for a customized VISA' Gold account!
Iegm to be bound by the Account Agreement (which will be malted to me before my VISA card's Issued) and to repay
principal, Interest, and interest thereon, except that I will have no oaagation If f return the card(s) unused and cancel my account
after reviewing the Account Agreement.
Bonnie L. Hardy d 3 U 8
9 Rebecca Drive # B
Duncennon, Pi 17020-9308091
2705N4 CTOBO GX319 I
GOBA OFBR OACA REDD ADAG 20-
105-5631-1042-2-
Th.'s r eltaw
invitationorpirm November 14, 1994
.? i
signer Cron•TruuknWd
40' 7
So" security Number
HH?ome phwa Wmk/Sftwd I'Mm ,
3 ,7 No Annual Fee
a
$20,000 Credit Llno
e
Immediate Cash
e
Lowest Purchase Rate
GUARANTEED SAVINGS
1
It. Thomas Mazur
Vice President
91YES, 1'd like to end out mate abou thq
Free Ba)anm Trawfer Service.
705-5631-1042-2 uVill
EXHIBIT
Reference Number: 4428231970502735
Box : 481
Year : 94
Batch : 7
SSN : 204405504
Account # : 4428231970502735
AAVIL A
i PROVIDIAN
6ynnnr tit(
Praraan National Bark VISA.T) Or 41asferCard,9
Accourt Agreemenl tot Bonnie L raid,
Please tewKw this document and keep it with your Omer .mp:ftant papers Tits Acccunt A?Ieemenl contains IN lean; wh cn gaen your Fipw do . a io. l r ,,A o slerCard Account
i the'Accori The Account allow: you to make purchases by us.n7 your VISA or Vaste aid cord It" Card') wherever I is ncrofed and to gel cash advances from us or ary other panics airig
manaal institution and from Automated Teller Machines Cornerrence :neck; may aso be CradM to ycu as an adsl.cnai way p asa Ire Accdunt in this Agreement -you' and 'your' mean
each person for whom we have opened a credit card Account 'We "our "ours' an *us* mean Powdian Na!wnal earl, or its assignees as listed on your billing statement Tne Account may be
used only for personal family . household and charitable purposes and not for any business of commercial purpose Any use If his Account shat constitute acceptance of the terms of this
Agreement You end we agree as tollaws
Payments. You will receive a monthly statement showing your ourfanding balarce Payment an Iris Account is requeed in U S dollars (crack: must be payable at a U S office of tre bank the
check it drawn on) for at least the payment due as shown on your statement by IN Tarrant due dare m accordance with payment nstructone on your monthly statement Convenience checks
and Over checks we out to you may not be used to make payments on your Account or to make paymel on any other account you have wan us or our affiliates Tne payment due will be 2%
of the new balance shown on your statement pus the amount of arty past due payment and may include the amount by which 14 new balance epees your Credit line However. the payment
due will not be less than 515 (unless your new balance is less than 515 in which case Ire payment cut tints the amourt of Ire new balance) if your Account is past due of above the credit line
we may te0uee a higher minimum payment but wa will notify you before doing so if your payr d more than the payment due I will be treated as a single paymenl and none of it wdl be applied
to future payments due We may accept Late or partial payments or payments marked pad n run' Or matl,ed with other restrictions without losing our tight to collect as amounts owing under this
Agreement
Credit Review: Special Requirement. In ordef to keep your Account n good standing you agree not to sgifil ry increase !re amount of your Total debt on unsecured revolving accounts We
will review your Account and credit profile regularly to evaluate The amount you owe relative to IN amount G yar then current.ncome (We consider an increase in debt of more Than 52 000 to be
sgTo ficant, unless you rave sufficient income ) If we determine that your Account is net in gwd standing 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 Purchase Balance sedan cf this Agreement. finance cr ages beam to accrue on a debt when it IS included in one of your daily
balances and continue until that balance r reduced by a payment or credit Your Acrunt has IN rdlevil balances Tre Purchase Balance which consists of your evi Purchase glance
and new purchases you make with your Card and fees for cenlam cetonal services. one or more Cuacm Casn Advance Ealanres NrKn Consists of balances that you transfer to your Accol
using balance transfer checks and balances (hat We transfer for yoU, and Ire Cash Ada3nCe Edlanc! which CW;CIS of all Uref C2sn advances Any payment amount we receive that exceeds the
finance charges and fees then due will adnarly be apiched first to the Balance is the lowest Annual Percentage Rate (APR). until that Balances zero. and men to IN Balance with the next
lowest APR until that Balance s zero. and men to any remaining Balance We restive the right to apply payments differently without further notice The Purchase Custom Cash Advance, and
Cash Advance Balances are reduced by payments as of the dale received and by Cracks as of the date posted Purchases are included in your Purshase Balance as of the date made CUStdm
cash advances are included in your Custom Cash Advance Balance as 1011ews funds electronically Transmitted to other lenders to transfer balances as of the date transmuted. checks to transfer
balances. as of Ire date presented to us Other cash advances are included m your Cash Advance Balance as follows cash advances from other financial nstitutons and through Automated
Teller, as of the date made, cash advance checks made payable to you that are identified as cashiers checks and mailed to you at your request as of seven days after the date we print on IN
check, all other checks, as of the date presented to us Other debts are included in your Purcrase 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 daily finance charge for each type of Balance we staff with your previous day's Balance add all debris and subtract all credits for IN current dayy and multpfy the net amount by the
applicabledaily penal rate (see fdlcw.ng paragraphs) The finance charge lot each lips of Balance is Then added to and included in that day's Balance Yea treat a credit balance for any day as
zero We determine the total finance charges on balances for the filling cycle by adfng together the finance charges for each type of Balance for each day within the billing cycle In Calculating
finance charges. an aquelmenl will be made for any transaction or payment that would have affected the finance charge calculation in a prof billing cycle had it been posted in that cycle The
applicable daily periodic rate for such a transaction w.II be the rate in effect for the current billing cycle rather than Ire rate in effect on IN dale of the transaction
Your statement Includes an average daily balance for each Type of Balance You can mull.pry each average dairy balance that is not zero by the number of days in the bills g cycleand the periodic
rata to obtain subtotals, and then add the subtotals together to determine your total finance changes on balances for the billing cycle If a cash advance Transaction fees charged. that amount is
also a finance charge
The ANNUAL PERCENTAGE RATE (APR) for purchases n 12%. corresponding to a dais periodic rate of 003283%
The ANNUAL PERCENTAGE RATE for CUSTOM Cash advances s 12% corresponding to a dairy penoac We of 0 03283%
The ANNUAL PERCENTAGE RATE for cash advances is 12%, corresponding to a da•ly Periodic rate of 003288%
If you do not comply with The terms of this Agreement your ANNUAL PERCENTAGE RATE for purchases 4,11 be 23 3% correspomsi g to a day periodic rate of 0 06384% and the APR lot cash
advances and custom cash advances will be 23 3%. corresponding to a daily perodic rate of 0 i15384% Your Account may be eligible tot the lower regular APRs; alter you have met the Terms of
this Agreement for three months If you contact Us we will review your Account to delermire your eligibility for the lower APRs
Once Period for Purchase Balance. New purchases posted to your Account in bang odes with no ptevous balance cr wren the previous balance was fully pad during the cycle . be not begin
to incur a finance charge until the start of the next p?lbrrgg cycle You will pay no finance charge on such new purchases J you pay me total new balance In full by the payment due data shoen 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 repad wdhoul mcurnrg a finance charge
Fees. We will charge your Account up to $0 far each Card you ask us to teplace ea:h reiurnM l ayment crack each check, ou wife on your Account that we return unpaid each stop payment
order of renewal of such an order, each billing cycle within which your Account is dellri pate charge) and each biling cycle whin which your balance exceeds your credit line even of your
Account is closed Ifyyou request copes of billing statements that were first sent to you more than three months earlier, we may charge a handing fee of $2 to each such copy A cash advance
fee of 3% (minimum 55) may be charged for each cash advance transaction made on your Account
Dehull You will be in default it any information you padded us pones to be incomplete or untrue, if you do not Comply with any pan of this Agreement uooru your death , bankruptcy, or
insolvency, of you do not pry Our debts wtien die J a bankruptcy petition n filed by or against you or if we believe in good faith trial you may not pay or perform your obligations under this
Agreement II you are in default we may, without further demand or notice, cancel your treat privileges off your Account balance immedwey 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 this Agreement, even it
we have filed suit to collect IN amount you owe
Credit Line Your credit line is specified from time to time It a separate nrbce We may ncrea:e or doc else your credit line based on information we obtained from you Of your credit records
Your available credit IS formally, the difference between your credit line and your Account balance including transactions made or aulhonzed put not yet posted) it you send us a large payment
check. we may limit your available credit while we confirm that IN check will clear For certain ransactions. avalabe treat mar be less You wit net use your Account for. and we may refuse to
honor, any transaction which would cause you to exceed your available cleat
Promise to Pay. You promise to pay us when doe an amounts bcircwed when you cr someone ear use your Account lever J the amount chaged exceeds your permission). an other
transactions and charges to your Account, and collection cc-IS we incur including. out not l.mded to reasonable attorney s fees and court costs (II ycu can the suit we cam pay your reasonable
attorneys fees and court costs )
Changes. After we poise you any notice required by law, we may change any pan of this Agreement and add or remove re;mreirents if a orange r made to the Finance Charges section of
Thus Agreement, the new finance charge calculation will apply to your entire Account balance from IN effective dale of Ire charge Cranges will apply to talarces that mdude.lems posted Ili ygyl
Account before the date of the cranne and will a" free, at or not you continue to use tre Account
Foreign ExchangelCurrency Conversion. It you use your Canis for tranactions n a carency ctnet than U S deila , Ire im sactohe cadl be concerted to U S dollars generally using either a (I)
gaenmenl.mandiled rate or (it) wholesale market fate in effect IN my before The Irarsach-n processing Sate increased cy five percent (5%) If a croft is subsequently given fa a transacton. it
will be decreased by the same percentage If the credit has a ditfeent processing dale !lea the excraige rate of Ire crest pn lot g eateusess than that cl the original transaction The currency
conversion tale on the day Cali the transaction processing dale Tay dtfer from irritate .n effect at the !me of the IrarsaVon of on the date ire transaction z posted on your Account You
agree To accept the converted amount m U S donars
The Cad; Cancellation. You may cancel your crPat prNt as at any time by ratifying us n wnl•rg anJ da roymg IN Card(S) t:pcn ire Card e•pdal an at the end of the month shown on a we
reserve the r"?hl noT to renew me Card We may cancei mo Card a^d ycm cfl pnv e)es it amy tme after 30 oars ,ofoe to ycu or without nc!i:e if permdled by law If four Cards cancelled or
rot feninved rmance chnges and Omer ores wdi continue to be prymenis cant ccnhrue L^ be aue and at ether aclo,cat a Slow-ons cl iris Agreement will remain in effect if you
terminate your credil T°rv'ege::,r .f we cancel of dO n A f4i the w ] r^u mar n ^;e• car -fi t . I _n your A a• J i 'u r c-jA)vnr., any vnusr7 chaos we rave ssuwi to vo.u
Personal Information; Documents. You w.d provide u at !east to dal notice if you •Ytr.je yovr ame home of fro ling arise Wepncne numbers employment or income Upon our
Tastiest. you will praise us additional financal Infurnahon 'lye reserve tre right to wa.n n!crmalKa from other, mcluong credo revAlrg agerc as and to provide your alxes: and rlarratan
vent
(Continued on reveli(58460698) 4426231970502735 TOGS Oa0
a00u1 your ACCOUnt To others We may aka sham mlormahcn wdn our aH:Lales t+owever you, may write vo us at arv time nSfrVC rd u• not to snare crept nformataa with our alldatn it you
do nor Min your obligations under mm Agreement. a negatve Crept rlpdei lriat may reflect on your credit may to stemmed to the treat repwi,ng agere os
Customer Service; Unaulhoriaed Use, Loss, or Theft of Checks or the Card. Each Card must be signed on recepl You are resconsble lot safeguarding the Card your Personal lu, tf wtan
Number ('PPP which povdes access to Automated Tel!er Milax l and any checks issued to you hom theft and kem.ng your PIN separate from your Card tl you discover w suspect 1
your Card. PIN. of any unused checks ale lost of stolen or mat mere may be an unauthMSea Iransattion on your Account you will cromprly n0l.N us by caning 14MO33.7221 So we an
immediately act to limit losses and kaWiy, you w,e phone us even though you may alto notary us in waling Your haxi for uni utnor.ed use occurring before you ndtiry us is lumled to SW If you
reporl or we suspect unauthorized use of your Account we may suspend your credit privileges until we restive the proVem to our sahafactan or issue you a new Card If yow Card n ksst or
stolen you won promptlydestroy al checks n yow possession To improve customer service and security, you agree that your casts maybe moni',ored of recorded
merchant Relations. We win nol oe It" it any person or Automated Teller Machine refines to homes the Card of acceol your Checks w fads to refurn the Card to you We nave ro respomdkry
V goods and services purchased with the Card of checks excecl as required by taw (See Special Rule below I Certain benefits that are available wan the Account are pwded by thud-party
vendors We are rot lespomble for tM quality availability, or results of and of the services you choose to use
Slap Payment Orden. If you wan b stop payment on a check you may send us a stop payment order by writing to us of our address for cuslomer service Inted on your statement You can
makes stop paymenl order orally by afiug The number listed on your statement When you make a stop payment order, you must prcvde yow Account number and specific nlormall about the
check the exact amount, the dole on the check. the name of the party to whom it was payable the name of the person who signed it and the check number You wit to asked to confirm an oral
slip payment of(* in writing We may disregard your oral ordef we m net receive a sidred written Confirmation *.thin two w ks after t oral order w if we have not reprieved an adequate
description of the item so that payment can De stopped rev order will not be e"recii if trio check was pad by us before we had a reasonable opponurvry to act on the order We may, without
haWiry, disregard a wrilen stop payment order six months $her lei unless d is renewed in wring
Standard of Care. Because IM Account eryderes born credit card and check transactions which are pfocesced though separate national systems before me transactions are consohdaledby us.
and because not every check and Card sip will be sent to us. transactions in your Account win be processed mechanically without our necessarily reviewing every item Our processing system win
all our attention to certain items which we will examine We will e.am err an transactions when you report that your Card or checks have been lost of stolen We au rot miend dediaaf3y to
examine en items, ord we wilt rat be rneghgent d we do not do so This rule establishes me standard of ordinary are which wen good faith wiz exercise in admnateritg your Account Because
of our kmded revew and because neither your cancelled checks nor Card transaction sips *0 ber leturned to you *-In 914111101 statement. you should De Careful to enter an Checks in your
check register or otherwise keep a record of hem You snould alto save your credt card cash advance and purchase sips You agree to check your monmm statements aamst visa record and
to rahh us nmediately of any unauthon.ed aamerchons of errors
Walter of Certain Rights. We may daisy or wave enforcement of any paean of this Agreement without losing our right to enforce it or any other provdidn later You wane the right to
presentment, demand, protesl, or noll of dish", any applicable statute of limitations, and any fight you may have to require us to proceed against anyone before we file suit against you
Applicable Law; Sevenblllty, Assignment like matter whine you Iva. this Agreement and your Account are governed by federal law and by New Hampshire taw TM Agreement n a lwf
expression of the agreement between you and us and may not be contradicted by evidence of any alk!ged deal agreement It any provision of mar Agreement a held to be maid or unenforceade,
you and we will consider that provision modfed to conform to applicable law, and the rest of the prwdions in the Agreement wilt still be enforceable At any time after we determine in good faith
that any proposed or enacted a rslatan, regulatory action, of rydecel decision has rendered or may render any material provisions of this Agreement iwald of unenforceable, of noose any
ncreased W. reporting requirement, Of other burden in connection vain any such provision or it] enforcement we may after al least 30 drys notice to you. or without notice d permilled by low,
cancel the Card and your Credit prwdeges We may transfer of assign our right to all or some of your payments If state law requires that you receive notice of such an event to protect ore
purchaser or assignee, we may give you such notice by filing a financing statement with ire state s Secretary of Stale
Notices. Ocher homes to you shat be effective when deposited in the mad addressed to rou at the address shown on out records. unless a loran notice period is specified in mar Aggrreement or
bylaw, which period shall staff upon mailing Mice to us shall be mailed to our address w customer semce on your statement (or other addresses we may speciry) and shall be eoectwe when
werecover it
YOUR BILLING RIGHTS -KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our resconsorlnes under the Fait Credl Billing Act
Nodk Us In Cue of Erson or Questions About Your Bill If you thnk your bill n wrong or if you need more information about any transaction on you bar. wme us on a separate sheel, at the
address tested in the Selling Rights Summation your bill Wnte Io us as soon as possible We must hear from you noisier than 60 days after we sent you the first bin on which the error of problem
repeated You can telephone us, but doing so we not preserve your ni In your letlef give us the following nfdematan - Your rime and Account number -The dollar amount of the
suspeclederror - Desert* the error and explain, if you can why you beeve there man error If you need more information. describe the item you are not sure about
Your Rights and Our Reaponaiblllties 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 sift correct the error of explain why we believe the bar 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 rho amount you question excluding finance charges, and we can apply any unpaid amount against your treat lire You do not have to pay any questioned amount who we
ire uwestgatug, but you are still onigated to pay the won of your bin trial are not in question
It we fad that we made a mistake on your bill, you will not have to pay any finance charge felated to any questioned amount If we didn't make a mistake, you may have to pay hence charges,
and you we have to make up the messed payments on the questioned amount In either case, we win send you a statement of me amount you owe and the date that it is dude It you fail to pay the
amount we think you owe, we may report you as delinquent However if our explanation does not satisry, you and you white Io us within 10 days teaug us that you still refuse Io pay, we must tee
anyone we report you to that you question your be And . we must tell 1?ou the name of anyone we reported you to We must tell anyone we fewrl you to that the matter has been settled between
us when d fnaty n It we don 'I follow these rubs, we cant collect the first S50 of the questioned amount, even if your bon was correct
Special Rule for Credit Card PurcAnea It you have a problem with the q iS iry of the property or services that you purchased with our weds card and you have trod in good faith to correct the
problem with the merchant, you may rat have to pry the remaining amount due on the goods or services There are two hmnations on this right (a) you must have made the purchase in your
home state of if not within your home state, within 100 miles of your current madeg address. and (b) the purchase price must have been more than S50 These Lmifaticro do not apply it we own
or operate the merchant or it we mailed you the advertisement for the property or Services
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06159 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS.
HARDY BONNIE L
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 HARDY BONNIE L the
defendant, at 13:48 HOURS, on the 13th day of October ,
1999 at 530 ENOLA RD
WEST FAIRVIEW, PA 17025 CUMBERLAND
,
County, Pennsylvania, by handing to CHARLES HARDY (HUSBAND)
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: So answers-
Docketing 18.00
Seryice 9.92 [3
Affidavit .00
Surcharge 8.00 <
'TaB-KSTPi?; 5 --
PARK lp,W OFFICES
10/14/999
by illta"UUPULLY Z011UL L I
Sworn and subscribed to before me
this ,ZawuC day of
19 94 A.D. l
_ Ff a`Yy I I
VALERIE ROSENBLUTH 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
VS.
BONNIE L. HARDY
Defendant
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: NO. 99-6159
PRAECIPE TO ATTACH
TO THE PROTHONOTARY:
Kindly attach the enclosed verification to the
Plaintiff's Civil Action.
PARK LAW ASSOCIATES, P.C.
BY:
VALERIE ROSENBLUTH PARK, ESQUIRE
n
VERIFICATION
I, MARY M. MAXEDON
C1
declare:
I am a designated agent of PRWINAIJ NATtoNAL ?AnUC , A
1J 10tJAL AAAj1 d4 lkrm.,,o,j , in the above entitled action and I
am duly authorized to make this verification on its behalf. I
have read the foregoing complaint and know the contents thereof;
that the same is true of my own knowledge, except as to those
matters stated on information and belief and, as to those matters,
I believe them to be true. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section4904
relating to unsworn falsification to authorities.
I declare under penalty of perjury that the foregoing are
true and correct.
Executed this day of
, 1999 at
AIAMEDA county, in the state of CAUFOHNIA .
0
,Designated Agent
PROVIDIAN NATIONAL BANK
BONNIE L HARDY
4428231910502735
919654-1
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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
PROVIDIAN NATIONAL BANK
Plaintiff
VS.
BONNIE L. HARDY
Defendant
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
NO. 99-6159
PRAECIPE FOR ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff and against
the said Defendant in accordance with the Agreement for Judgment
attached hereto, and assess damages as follows:
AMOUNT OF JUDGMENT $11,021.82
ATTORNEY'S FEES $ 2,204.00
Plus interest from 08-31-99
to 12-11-99 $ 369.61
LESS PAYMENTS $ 750.00
TOTAL $12,845.43 plus costs
I certify that I have enclosed a copy of this Praecipe to be
mailed to each other party who has appeared in this action or to
the attorney of record.
RESPECTFULLY SUBMITTED:
I A ?-
VALE ROS TH PARK, ESQUIRE
/? ?JATTORNEY FOR PLAINTIFF
Judgment
AND NOW, r -N L PICT dt&L'
7/1 144
is entered as abo .
PRO HONOTARY
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
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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
PROVIDIAN NATIONAL BANK
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff
VS.
BONNIE L. HARDY
Defendant
NO. 99-6159
PRAECIPE FOR ENTRY OF JUDGMENT BY AGREEMENT
TO THE PROTHONOTARY:
Please enter Judgment by Agreement this day
of A/,_/Atl l72(. ,j l , 1999. It is hereby agreed between the
parties that Judgment be entered in this action in favor of
Plaintiff, Providian National Bank, and against Defendant, Bonnie
L. Hardy, for the principal amount of $11,021.82 plus interest at
12.00% from 08/31/99, until judgment is entered plus attorney fees
of 2,204.00, less payments of $1,272.00 plus court costs.
PARK LAWr ASSOCIATES, P.C.
BY: 1
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney for Plainti f
Bonnie L. Hardy
Defendant
1
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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
PROVIDIAN NATIONAL BANK : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
VS.
BONNIE L. HARDY
Defendant NO. 99-6159
N O T I C E
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:
Judgment by Default
Money Judgment
Judgment in Replevin
Judgment in Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
X Judgment by Agreement
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE
CALL: PARK LAW ASSOCIATES, P.C. at this telephone number: (215)
348-5200.
PROTHONOTARY:
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
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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
COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
BONNIE L HARDY
Defendant
NO. 99-6159
PRABCIPE TO MARK JUDGMENT SATISFIED, SETTLED, DISCONTINUED AND
ENDED
TO THE PROTHONOTARY:
Kindly mark the above captioned matter satisfied upon payment
of your costs.
PARK LAW ASSOCIATES, P.C.
BY:
VALE E ROSENBLUTH PARK, ESQUIRE