The URL can be used to link to this page

Home My WebLink About99-06366O- VALERIE 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. GRACE E. HOLLEN Defendant NOTICE NO. 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. AND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (800) 990-9108 THIS IS 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 COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS GRACE E. HOLLEN 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 DEFENDANT NO. 99.6364 ew' a T. "4r 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 GRACE E. HOLLEN, an individual who resides at 107 E. Allen St., Apt. 6, Mechanicsburg, PA 17055-3392. 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 4428470500016259. 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. i 6. The Defendant is indebted to the Plaintiff in the amount of $4,103.97 as of 07/07/1999, plus pre-judgment contractual interest at the rate of 23.908 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 $820.00. 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 $4,103.97, plus pre-judgment interest at the contractual rate of 23.908 per annum from 07/07/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $820.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE R ENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION I, MARY M. MAXEDON , declare: I am a designated agent of //CpyidiAn/ OVAr/e4114& 13,4,v/( , A AIAnoaA? 6AA1&1416-9SSst1A7-iog1 , in the above entitled action and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section4904 relating to unsworn falsification to authorities. I declare under penalty of perjury that the foregoing are true and correct. Executed this day of , 1999 at ALAMEDk county, in the state of CAIIFOHNIP MARY I??I. IUi Designated Agent PROVIDIAN NATIONAL BANK GRACE E. HOLLEN 4428470500016259 919969-1 i -' ' . El(HIBIT t?' PROVIDIAN y l'uwvri lay ?':? :..)r t:ar-:ra r3^? v"??! fir 14'.•,'.:3•!:. A C:er r 3.? ru,r..r! !.;r .:Lie : •'.. Cr Please rev4w ilm ji CLrtrt and keep d cam ,oW "tty e'es,: l "'I -.:r !I r; :rv't^^: xf-, ':3 !ialMral Bar kIf ISA If S,fls!Kad A•qun! Iiri'ACCJurt') The AC:l." alto«s yW U maze plat?Le! tY •:'7 1'1ur JI$A~:r \13:!d'_3' ] Ca'd (:ri 'C at%•; x^ezv P' A :';r:'±) a"d 4 gel:3:1131v3nCes from us Or any other Dddizpanh.] Lndncal 1ns!autwn ark) hour Automated i Cher f lai;nmeS ':CnSM erce :rick: may 31:C ^." prek Mlr•') Iv ,pu 3s do a]1;rr3. May :] .:e "d %:':un! m 1hd Agreement 'gala' all 'your' mean each perm lots wrwm w! nave eClned a 4CJt C]rd A::Curt i . ' aJl "ours' ]rJ'u: mOn Pry?d3n .'q'Cr.l' Ba 7 as zCS 3S ilsed ^.n roue bilnn7 S!]temenl The ACCouni may to used only for Ceson3l !3my doaencd and cran:atie to:<: Jl`1 %I f.;t ]^q tuS 'r:: Or G;m reTd: Cu .Ce Al/u'., :! .• s A:: J,r! :Hai Cn:ttb;r aCCttlJnCe d Ine tams of lnq Agreement Ycu and we 3gree as fellows Payments. You W41 !eflM1e ]monthly sLalemenl Snowing traits ,ul;;anacg ta!a!iCe Pa'finent cn !MS AU3un! , redced m U ; %_''a•S !:hcC.S must Cr payable Ji a U S office ct me tank Ice crick is damn Cnf for 3t'43SI Ire WYmerl due as Snow^. ;n v:,.r a 3'e^e^a or re C3'r•eri due :.isle n ]._.rv^:e 4 in p3i°r'! ^Yra[trr, :r +:ur monVy st3temerl Corven4nce check: and chef checks we Race to you may not br? used a Hare CayrE^:S on your A°:url Cr !: rile Wire"t::r our, :'he! 3:c:'.'! ,:l "are A In us :t our afhllaros Tf a Wymenl due MII to 2% Of then" baonce shown on yOur Statement plus the 3mCurt of 3ry past due paymerl and may iMC4ul !fie 3mcurl ty lyrics, !te left pa'3r4e Oil eedS your Credit line however the payment dM W111 notCC ter Inan S15IWp!SS your rely bal3nC!12 HS!tsar.j!5:n«'2s,:3:d!fie pa'rmen;a,e xA Ce !'23'•:unl :1 ire: fix ta'd•ce) !Yc,,Account IS past *AV above the Credt line we may revue a figher mnimum paymenl DN we a,l slily ysu before doin7 sd If yca pa/me'! m:'e'rar :he pa/rere,d,e ; w n ;e'rzared m a ; ng'e payment aril none of it wv7 De apdied to future payments due We may accept We or canal pair IS :r pa/-eats ma,vza'pa d n furl' or rer+ta x',h:Ire• reS!I2C%'S Ill '•csrg our rgot to Coilec 134 amounts Owing onder this Agreement Finance Charges. Except as *54101 the Grace Period for Purchase Balance sectors of me A7r",rera fiance charges te7n'a accrue on a debit when it is included in one of your dally balariCes and coctmue LLnt4 that balanced reducedty a paymerl or credit your AC:'uti Has Ire hlwarg baadiCtS the Pur %sr" QY3nce whiCn consists of your anLrp Purchase Balance and nrw purchases you make wan your Card 3nd fees to Ce'tan Cptorar Services ore or more Custom C3sn AdAnce 03'3^CeS xn:n GrS Sts of balances that you transfer to your Account balance transfer checks and Wl3nces that we transfer tot you 3no!re CaSh Advance Ba!d:CS wmcn con; l!% c1 al otter CJSI ab3rceS Any payment amount we recene that exceeds Its I%nce ChaYyeS and fees then due will orararey to appned firs;'; !re 63 once w in Ire os i Annual Peicerl3ge Rate (APR) un; !rat Baa^{e 3 :ero and then IO Ire Balance with ine next Jawed APR. unit that Balance 1s zero and then to Any tem3-firg Ba:arce Yale reSer.e the right to a:ory payments dNeenty wdreul further no!oe The Purchase Custom Cash A{Yance, and Cash Advance Balances are reduced by payments as of the date recened and by credits as of the date pcLe: Ppr:haset are .•cu:ed 1n your Purchase Balance as of the date made Custom cash advances are included Iin your Custom Cash Advance Balance as fI fund: e!CClfonwJlly lansmi i o oiler lenders to t'lnsfer t3'arces as of the date transmitted checks to transfer balances as of IM date presented to us Ciner cash advances are ec'We:.n your Cash Adv arce Balance 3; follows cash ad4h::K faun cater r.nanCal mshlatwns and through Automated Tellers, as or the bate made cash advance checks mace Cdyabe to you flat are aer!iflea as CiI S criUS and made] to 1" At your request 3% or seven days alter ;he date we pro; on the check, all Other Checks. as of the date presented to us Other debits are included in your Purchase Custom Cash Advance or Cash Advance Balance as of the dale posted Finance charges are added Io your Purchase Custom Cash Advance and Cash Advance Balances each dry and are then posted on me last day of tie tII Ill cycle There is no grace period for custom c33111 advances a other cash acl3nces To figure the miry finance charge for each type of Baance we start with your previous coy s Balance add 3,1 dtc,ls and Sill a:I treats for the current day and muff ply the net amount by the applwable daily periodic rate (see following paragraphs) The flrance charge for each Type of Balance is then 30ded!o aM 1ndueed.n ;Hat day s Balance We treat a cli al balance for any day as Zero We deWmme the total finance Charges on balances lot the tiltrg cycle cy adding together the !.farce cl aroyes for each type :f Balance for each day within the billing cycle In calculating finance charges, an adjustment win be made fa any !Ansac;on of parmerl mat «oud nave attec!ed!re !Iraill charge calculation in a 1xv tilling cycle had it been posted in that cycle The applicable dally pefwAC rate for such a trarsacncn will be !Me A!e in effect for Ire ewrenl billing cyc!e ra!nef them the Imam el on ire daro of the transaction Your statement includes 3s, average dally Ca!arce far each Tyro of Balance You an sh lply each average daily taa%e Ran is rot efo by the nurtet or days in the billing Cyc:e and the periodic rate to obtain subtotals. and men add the suorcta!s!oge!ner !c de!ermme your total f.n3rce cnatles on talances f:r Ire targ or* If If a cash advance transaction fee is charged. that amount is also a firance charge The ANNUAL PERCENTAGE RATE )APR) for purchases is 21906 corresDonong 0 a dairy periods ale of 0,,6X`X The ANNUAL PERCENTAGE RATE N custom cash Irav e rs 23 9% correpondng to a daily:etwx rate of 0 Cl The ANNUAL PERCENTAGE RATE for cash "ances rs 23 +k correspondn7 to 3 decry periodic taro of 0 05546% If your payment is reserved late twice in any 12-month period or if you sgnlficanty mcrease your !star unsecureddeist (as e,p'3 red n ine CREDIT REVIEW paragraph) the APR for Purchases may uwrease but win rot exceed 23 9% corresponding to a diary periodic sale of 0 06546% and toe APR for cash ac ances and:usf:m cash advances may increase loss cam not exceed 259%. corresponding to a dally pw odc rare of 0 07095Y Your Account may be eligible for !ewer APRs after you have met !re terms stroll Agreement for three mommy .1 you Cameo us ace can review you, Account to determine your eligibility for tower APRs CREDITREV!E'W SPECIAL RECMJIREVENT Your APR can increase based cn a syrl!icant.naease m wzrured :Jet; II •gLl ;a! unsecured Sett and your total unsecured debt with other lenders each increases by more than 55900 and your annual household hostile is less than four tines your ow unsecured Ceti Grace Period for Purchase Balance. New purchases pcS!e] to your Account in tiling cycies wan Pe previous balance of ere^ !re parlous tlance was fully pad during me cycle do not begin to incur a finance charge until the start of the next billing cycle You call pay no finance charge on such new 0.r."ases 11 you C3, !1e1031 new balance in full by the payment due dale shown on your s!atemen! Ntx pwcwses posted m ary aver Cd!:ng cycle .rcu 3 finance :nar7e and Irene i; r.: ;erw n acts,:n :u:n p.r a:r: nay to roped a!mpur incurnrig a finance charge Rebate. On Ire last day el e3cn monthly statement pefwd lye "61 cr"I your Acccunl *,in 1% of pour ref cuicta:e tram3:iCCS pcS!ed durng the statement period 'Net Purchase Transactions' means Card purchases less purchase adiustments and p ur:h32e Credit; poste] dmng the re!*) Fees. We win charge your Account to to SO for each Card you ask us io replace each returned Wp^erl:re:v e3Ch check I% Arlo on your ACCOL"ll that we return unpalo. each slop payment order or renewal of such an order each billing cycle witnm vI your Account is dekridueni pate charge) and ea:n till ng cyco lk lm finish your balance exceeds your treat line even if your Account is closed If yo'u reweSI copies of b-I4 salements vial were frst sent w ycu more than tc'ee ror!rc e.ml,ef we ray :'arse a."3nd ^g fee of S2 for each such copy A cash advance lee of 3% (minimum $5) . which is a FINANCE CHARGE may be :wr7ea for each :ash 3la%e!r3^e3e!1cn r33e c.n your A=ura Default. You will be in delaull it any information you provided us proves to to incorplee or untrue d you bid not Corpy 1 31, part d rots Agreement upon your death bankruptcy, or insolvency, it you do not pay other debts when die if a bankruptcy petition r, filed N of agmmt you or If we telleve in good !3,m :rat you may not pay of perform your obligations under this Agreemenl It you are m default we orgy. wilnoul turlrir de,31d or Ill cancel y'.r:r clear pr'v''P.Jes de:a•e our A.:pu•t t33r-e Imme^J3!eY due arid payable, and use any remedy we may have in the event of your default. the ouMardng balance cn your A:court srAl Sort rue to acctue 1nleest ache APRls) use:Se:'n me Finance Charges section of this Agreement, even if we have filed suit to collect the amount you owe Credit Line. Your treat line 4 specified from tine to rime in a teca! a nonce 'A e may increase II drtease gain cr:t ! •e t3se] cn rr:rmalwn lye obtained from you Of your credit records Your available treat rs normally ire difference between your c:ew're and yci:f ACC:unt pa!drce (nc!"I Irarsaoicrs made Cr awrcc:ed b.l not yet posted) If you Sena us a Large payment check, we may limit your available credit while we confirm that re check «19 tear For ceram Iransac;ors avadatle :red.t may teless You ail not use your Account for and we may refuse Io Manor, any transaction which would cause you to exceed your 3vBlLabie credit Promise to Pay. You prcmrse to pay us wren die 0 amens tarcwed wren you a s:nr:re e:e use yout A;:Curt (even ?! :'e 3'cu^I c`3ryed exceeds your permission). all other trans3Ctwm and cn3rges to your Account. and toyectwn:Js;s Ae .%ur .m!udrg Dui no111m'P] 10 'Cd;:naCe aCOr'Py s !Ors aV :tuts C:s!S (If you win the suit. we will ray your reasonable attorney's fees and court costs ) Changes. Aoef we provide you any notice rewired by Law we may change ary part ct INS Agr"lle•J and add It ierae re-.. Ii If a change is made to the Finance Charges section of this Agreement. the new finance charge calculation all arpyy, iis soul e^I1'e AC:cunt ba'drwe hcm'he ellec!he :are -f Ile Car;: _r3nges w'd arcy to balances that include die^s mied 10 M scant before the date of tie chance are win appM wne!ss %I you continue to we're Actoor! Foreign Exchange/Currency Conversion. If you use your Card for V3n:3ctwm n 3 urrency Sills, l tan'_' > a le Pa• 3 r Al to ed b U S data': derealrj using either a (1) government marl ra!e x ('g wnoleS3?e raft el ale m e'fe:t I.e dal, t4'I d 3..J 'Cs, . " .,,,.:eI J.. ]. / -e 1 i) ° a 'P ]t,: 7 stn for a Irarsrmrsn it will be decreased try the store percentage Tree t.nency Corve'Sgo fare use- :n !re c:^ve•sdn vise -3/ ;'f2'r:r !re'a'd tu+ i or 24 vise +cu used your Card you ag'ee to accept Ine converted amount in U S dollars The Card; Cancellation. Youmay cancel you crrat prrolexs 103"y' !ire by rc!'ry'r9 s n wr.tn7 a c des;' dig !rd C3 '_ cr're C3'd evoroticn at fire end of ine month srewn on 1t we reserve the rgni nct to tell" I" Card yVe may cancel the Cara 3M your Cea O,Nr3rfS 31 3ry t-e trier l vac: ^c :e is 6Ill nvl:e ! permitted by law If your Card is canceled of not renewed, finance charges and other fees will continue to be aSses:ed W!,I Ali Cdnimue to to dice F134 c'rer top cao e t(of,;,crs :f firs Agreement *Jt remain m effect if you terminate your credit privileges. or d we canal Or do hot revew the Card you may no longer write cne!'k; cn your A: :curd and ,ou should deseoy any unused checks we have issued to you Personal Information; Documents. Yau ail page us 31 e3;i 10 as r.UCe t /ou cran7e rout s,3^e rere :r cnirg aSd't:: fit eprcce r„rCer emrkyment o 1rcrme Upon our Phi (Conhrnved on.everzel lS?46153?I 442947050t>C'E25g 0730 462 request ycu wd provde us adatanal knanoal mfamair_n 'ere receive !re rigm!o ce,ar. ?rlprmarcn hpn mrxn irc!.,anq ao-dt recu!mg a;rrc r- and fo ppvi0e your ad7ess and inlamaton afoul row Account to others r¢r? h "! 02" n Inn r . 11-10 t rhvwr v^u mdv wry o_S ]j?sry_n« t. ?7'.- not m soar. cedt Wormat on win an if J!es II you ,o nor fulhe your x1gaiions urvsef Ihn greemert ] me)aine Great revr Ina, may re"oc! on yp4P aeat may to sutra Iles •J re -0It rKOrtng 340CIeS Customer Sealer. Unauthorized Use. loss, or Theft of Checks or the Card. Esc' :curd must c« : grind cn re]ecl vcu a e ?:::n;clot? :a'e)uardirg !re Car s 'your Perscnm,antcat.0n NumW ('Pitt o nch prdvvk; access to Automated Teller Mach?res) and any crecK -z of to ycu n:m Left anal v ItIM' rcV = I ;ePara!f ":n your Card d you gscaef a suspect!"" your Card Pill a arty unused checks are Iasi a st:+en or !tort !Pere may to an,,nauincr zed iran;act Crt ^n your A-courl you w n:rpmplry np,.ry u: ty caning 1.9009]].7221 So wean Immed llo act to limit losses and babairy you ore Chant us even mougn you may 3oc nCWy us in wchn I vour !rate,ty for unau!r-"'end use xcvnmg before you %1.Py us n hm.ted to S5i! if ypa report a wa su-Mt unauthoh:ed use of your ACCCurt we may su:Cend your aeal;ry4-,es until we rescNe ire crccier, Ip:ur tairfacirr :r issue you a new Card It your Card c lost :t stole. you cad acmpOy destroy a4 checks in your pa::essan TO .maCve cu:icmet service and seCUnry yoU ag!?e that 1Cw :ac: may to mcnrtaed a feCoided Merchant Relations. Yle will rot be kable d any Gerson or Automated Teiler Wachoe refuses to tuna Ine Card cf xceCt y:qf c^ecks a ta'is to femur me Card to you We Move no!es0onsadrry fa goods and services purchased wish the Card a crecks eviceot as required try Law (See Smol Rule teaw I Ceram "ref. : vat are ava.atve won the Account are prwvxd py third wiry vendors We are rot responsible fu Ine quality ava!aoJ.ty, or of 01 any of the seivcas you crime to u•.e Stop Payment Orden. If you wish to stop payment on a check you may send us a stop payment order try wnfty 10 us at cu ad:ess for customer servce listed cn row statement You can make a stop payment order orally by calling the number listed on your statement 'NMen you make A slop payment CrOer you must provide you Account number and smific information about the check the exact amount, Ine date on five check Ine name of tee Daily to whem I was payable the name of:Pe perddn ono s ire?'I and Ire Cneck number You *,fl be asked to confirm an coal stop payment ceder m writing m r r r I n r .I w rv rn n n nh m n. r. : her h r i X r or t we have net received an aalgJale desorption of the hem so that payment urn stopped ine order win rot N Pi «Ine f the check was pad by us before he had a WSCnaoie Cowttumty to act M Ine order We may wdrioul habkry, disregard a written slop payment order six months after rece'pi unless t rs renewed In venting Standard of Care. Because this Account moNes both credl Cafd and check IfaMactcrs vi are processed through fepd!a!e national ityVems before the trallachons are ConsoldYed by us and because riot every Check and Card sip will be sent to us. transactions in your A count w.n Ce processed mechanically without Our necessarily fev"ing every .,en Ot process system win call our allMlion to cellain items winch we wdl examine We wig examine all transactions when you regal that your Card a checks have bee lost of stolen We do not intend ofdinan U examine all terns, and we win rot be negligent d we do not do so This rule estattahes ire standard of ordinary cafe which we m good faith wdl exercise in adminrsterig your Account Because of old limned fevent and because norther yet cancened checks nor Card transaction sips wA be returned Io you won the monthly statement you Scald be careful 10 enter coo checks in your check register a otherwise keep a record of them You should also save your credit card cash advance and putchase sips Yr a-•.e to cI ck vow monlhN statements a0amst vice remd am! t,0 notify u+ mimedtileN Of am unauthor zed Iramactlcms a enon WaNer of Certain Rights. We may !delay a wane enforcement of any provision of this Agreement Pi tndw losing our right to enforce d of airy Other provnron later You wane the fight to presentment, demand. protest, a notice or dshona. any applicable statute of limitations and any fight you may have to reNtfe us to proceed against anyone before we file suit against you Applkable Law, Swersbillry; AsslgnrneM. fro mane where you ine tors Agreement and your Account are governed W Irkfal law and by New Hampshire law Thn Agreemenl n a tonal expassan d ths agreement between you and us and may Pal DQ contradicted b1 cadence of airy alleged oral agreerr+ent if amy prwnan of this Agreement n held to be m ald a unenforceable. you and we carp consder That provnan modfied to conkrm to aCpkcable law. end Ine rest cl the prwlsars m me Agreement cam still to enforceable At any lime aner we determine In good faith Mori arty Apposed a enacted kgrsWtan, reguWtay action, a rydital oecnan has reraered a may render arty ma!enal provnans of this Agreement iiva!ld a unenforceable. a impose any iareased pax. repating requiemel. a other Darden in connecncn wish arty such aovrsain a its enforcement. we may. after at least 00 days notice to you, or without notice d permitted by law. farad dIe Grd and row Credt pfm4ges Wa may Vansfer a assign put rgnl to an a some of your payments If stale law requues that you receive notice of such an went to protect the purWSer a assignee. we may give you surU notice Dy filing a finanou+g statement win ttie state's Secretary of Slate Notlcas. Other notion Ili you snag De eNectne when deported In IM mad a65essed td you al Ine address shown on our records unless a anger rotas period n f and d a Ibis Agreement e bylaw, whiich period shag start uOaM marling Nolae t,0 us snort be mailed to cur address -r customer service on your statement (u other addresses we may specify) and soak De a ective when wa receive t YOUR BILLING RIGHTS -KEEP THIS NOTICE FOR FUTURE USE. This notice contains Impcrianl mformalan abcul your rights and our resDonsbtdles under Ine Fat Credt Brtirg Act Nobly Us in Cue of Errors or Questions About Your Bill if ycu think your NO rs wrong or it you need more information apoui any transaction on your twit, write us on a separate sheet. at the address listed in the Biting Rghis Summary on your d4 Write to us as soon as possEle We must hear from you no later than 60 days after we sent you the first ba on which the error a problem appealed You can telephone us. but doing so win not preserve your rights In your letter, give us pie folIawrng Information •• You: name and Account number •• The dollar amount of the suspected errs - Describe the error and exdarn. If you can why you believe mere n an enor II ycu need more Information, descrce The item ycu are not sure about weumustgeitherncorrect the errorsor extlplain why We believeythe bill was correct dAfter we receive your le1etttter we cannot tttrry to coleci any amsounttyou question, a repatyouyas deelinquent Wee caan continue to bii you fa the amount yyou quesfan. inckdfg fiance charges, and we can acply any unpaid amount agamst your treat tine You do not have to pay any questioned amount while we are iivesigating, but you are shil oagated b pay the pans of yet log trial are not In question 11 we find that we made a mistake on your bill, you win not have to pay any fi wince charge Pealed to arty questioned amount If we di an t make a misake you may nave to pay Mace chargas and you wig have to makeup the missed payments on the questioned amount In tither case we will send you a statement of !re amount you cwe and Ina date That .I n due II you fad t0 pay the amount we think you owe, we may report you as delinquent However, t ow explanation ices not satlsq you and you write td us w.!nin 10 Plays telmg us that you soul refuse to pay, we mull tell anyone we report you to that you question Your tIA Ard we mint Iell ou the name of any pre we fepcvted ycu a 'ere must till anyone we repot you to that the matter has been settled between us when t finally s If wa dart follow' these Niles, wa call l Collect the lust 550 of Pe cr mhoned amount wen t your Dig was correct Special Rule for Credit Card Purchases. If you have a problem win the quality of the property cr services that you purchased wtri our credl card and ycu have tied in good faith td0arecl the problem with the merC aril, ycu may not have to paV the remaining amount due on the goads or services There are two hmlators cn this ngnl (a) you must have made the purchase to your home state. a If not within your hone state hi G miles of your current maihrg address. and (b) the purchase price must have been more than 550 These lrmtations do not app sve own a operate the merchant, or If we marled you the ad+ennell for tre I: cGerry or sevges ilk + 1-?}t SHERIFF'S RETURN - REGULAR CASE NO: 1999-06366 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS. HOLLEN GRACE E BRIAN BARRICK Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon HOLLEN GRACE E the defendant, at 17:16 HOURS, on the 2nd day of November , 1999 at 107 E ALLEN ST APT 6 MECHANICSBURG, PA 17055-3392 CUMBERLAND , County, Pennsylvania, by handing to RON WOLFGANG (SON IN LAW) a true and attested copy of the COMPLAINT , together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 8.00 K. iliomas , .i;?.;20-11/RR03LAW ASSOCIATES by f # Deputy Slieri ff Sworn and subscribed to before me this im, day of 6aca,.&, 19 99 A.D. aa. ????ary 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 I3: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GRACE E. HOLLEN Defendant NO. 1999 06366 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 LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL $4,103.97 $820.00 $411.15 ($0.00) ($0.00) $5,335.12 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 iss attached hereto and marked Exhibit "A". t VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW , Judgment is entered in favor of the Plaintiff aid against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certificatio . OTHONOTARY 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 ATTORNEY I.D. iI 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 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: 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055.3392 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GRACE E.HOLLEN Defendant NO. 1999 06366 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: GRACE E. HOLLEN 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 DATE OF NOTICE: 11/30/99 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE AMON 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. COURT AWNUNISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4" FLOOR CARLISLE, PA 17013 (717)240.6200 PARK LAW ASSOCIATES, BY: V PARK, THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 3 ,-? ? ? ?? 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: 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GRACE E. HOLLEN Defendant NO. 1999 06366 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 GRACE E. HOLLEN, Defendant is over 21 years of age; that his/her place of residence/business is located at 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 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: _ Valerie enbluth 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: 107 E. Allen St., Apt. 6 Mechanicsburg, PA 17055-3392 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GRACE E. HOLLEN Defendant NO. 1999 06366 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 [ 1 Judgment [ ] Judgment [ ] Judgment ] Judgment J Praecipe by Default 3gment 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. 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. ? N {{ (L } ) j. lLLLL1.::?1. ..? LZJ l? C` Q? v V? V ?