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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. $72099
PARK LAW ASSOCIATES, P.C.
25 East State Street
P.O. Box 1779
Doylestown, PA 18901
(215) 398-5200
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PROVIDIAN NATIONAL BANK
Plaintiff
VS.
JUNE G. BAILEY
Defendant NO. 7-/ - ?Y
i
NOTICE
?e
You have been sued in Court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by an
attorney and filing in writing with the Court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the Court without further
notice for any money claimed in the Complaint or for other claims
or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 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
JUNE G. BAILEY
168 Amy Dr.
Carlisle, PA 17013-8884
??) GY??? L-?^? ?'•'
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 JUNE G. BAILEY, an individual who resides at
168 Amy Dr., Carlisle, PA 17013-8884.
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 4428472657101868.
4. The terms of said account are stated in the documentation
attached hereto as Exhibit "A."
5. The Defendant has failed to pay the amount owed in accordance
with the account agreement and has failed to pay the outstanding
debt as agreed.
6. The Defendant is indebted to the Plaintiff in the amount of
$12,289.45 as of 07/06/1999, plus pre-judgment contractual
interest at the rate of 12.90% 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 $2,457.00.
COUNT 11
S. 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.
?Jll
'isti
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $12,289.45, plus pre-judgment interest
at the contractual rate of 12.90% per annum from 07/06/1999 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $2,857.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
PARK LAW ASSOCIATES, P.C.
r
BY: y
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.
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VERIFICATION
I, ,JILL PULLIAM declare:
I am a designated agent , A
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
pl AMEI» county, in the state of CAI IFOWNI!
JILL LIAM Designated Agent
PBOVIDIAN NATIONAL BANK
JUNE G. BAILEY
919890-1
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Please review Iris dxumenl arid seep with y ri r mprdart pl : r5 u-I 411eem fl flan •he e A i Pr.:ndan f,auoral Bart VISA or fdas'e•Ca•d Account
(the'ACCcurl') The ACCOUrt a w, you o m3 e; aiei by , ng y ur SA f ito f. _a, II, :at e :a ij Afereve :!'.. r 310 : ,et cash adances from u: cr any ::he, eart:paing
financial institution and from A,,,cmated Teller 3ilacr rei Ccrvemence .'..K may 3„O be p.rn died rcu as a add :r3: Aar '..e 1.e Avcct,nl in this Agreement. 'ycu' and'rOC' mean
each pefSCn fa whom we male opened a creelI caid Al `l'ye "cur "our:' 3rd'uS' --ran Fty+,yan. f;dknal Bari of d' .3::. gre?s as listed cn year billing Statement The AC;curl mar, be
used only for personal family ncu:ercld and :rar.4t:e purposes and not f;r 3ry tL5'fe:: er cChlTi purby.e Any u:? 7th:; A;c:urt shall ccr:;uuie acceclance cl the am: J Ih.S
Agreement You and we agree as follows
Payments. You will recene a monthly statement snow Cog your cutstandrg stance Payment on Iris Account Is fill in U S xi:ars (bteck: must to payabe at a U S office at the tank the
check is drawn on) fu at least me payment due as shown on YOU statement by the payment due Cate n accordance 4In pa/Tent instructions On you, monthly sta!emerl Convenience creeks
and Omer checks me issue td ycu may not N used !c moire payments cm rCUr Account :r a mite payment: on ary .he a-::;ct ya+ nave win a:3f cur affiliate, The payment due wnl be 21'x
of the new balance shown on your statement plus the amount of ar? cast J ,,e payment arid mar ncude the amount by Arrn the rem baance excee s your credit line However me caymenl
due wall net be less than $15 (unless your new Glance is less than 515 n *ram case Lre cayrri :.e AI be the 3mc.r! •f •^e new so 3-ce) f your Account is past d,e of Steve the credit fire
we may real a hghet minimum caymenl but we Mil nctity you befoe doing so If yccr pavmerl d more than the paymet due it 411 to treated as 3 singe payment and mane cf 4 mite acclied
to future payments me We may accept late or partal caymenls or payments maned'Cold 'fir folP or rased him other resvefoirs wehout Io; ^g stir fight to ',effect all amounts owing under this
Agreement
Credit Review: Special Requirement. In crier !o keep your Acceurt,n gad stararg you agree not to sgnraanay rueaSe Ire amount of your total sect on unsecured revolving accounts We
will review your Account and crept profile regularly to evaluate the amount you Core re!x f e m the amoam CI your then cccerl :noire OrVe consider an increase in cost of more than S2 0tv to to
sgnifcant unless you have sufficienl income I if we determine mat your Acceurt s not n good st3rdng yccr ANNUAL PERCENTAGE RATES (APR) for purchases custom cash ali cash
advances may be increased
Finance Charges. Excect as described in the Grace Period for Purchase Balance :I of !h Agreement finance caries tegn to axlue on a deDit when it is included in one of Ya,r It
balances and continue unhi that balance is reduced ty a payment of erect you( ACCCuni has ire!cil:wmg balances The Pufcr3:e Balance which consists of your etrshna Purchase Balance
and new purchases you make with your Card and tees for certain octaral servaei One or more Cu-cm ? 1Sn Advance Bar9n:es trillion consists of balances that you transfer layout Account
using balance transfer checks drift balances that Ae transfer for y;U amid the 1hAA!,v lr;p Baia whom con;4:: of ail :'der cash 313rces Any caymenl amount we receive!Kat exceeds Te
finance charges and tees then die will ordinary be applied first to the Paiarc , win the lowest Annual Percentage Rate (APR) until Cat Balance I, zero and men to the Balance with the next
lowest APR, until that Balance IS zero and then to any remaining Balance 'tie reserve !hie right to acpl'y payment: dtferenty * 1hcot further notice The Purchase, Custom Cash Advance and
Cash Advance Balances are reduced by payments as of the date received and by erects as of lee Sate Posted Purchases ate,nciuded Ir your Purchase Balance as of the date made Custom
cash advances are included in your Custom Cash Advance Balance as falCws furs electronically transmitted to other'ri,i to transfer balances, as of the date transmitted, checks to transfer
balances as of the date presented to us Other Cash advances are:rCluded.n your Cash Advance Balance as follows cash ad/arCls from Other financial institutions and through Automated
Tellers, as of the dale made cash advance checks made Da'yobie to you that are identified as cash ers checks and mated to'ycu at YCUi teGbeSt. as of seven days after its date we print on the
che_a. all other checks. as of Ine date presented to us OIM!f Oetils are included in your Purchase Castor Cash Advance or Casn Advance Balance as of the date posted Finance charges are
added to your Purchase. Custom Cash Advance. and Cash Advance Balances each dry and are men posted on the last day of the billing cycle Tnere d no grace period for custom cash
advances at other cash advances
To figure the day finance charge for each type of Balance we start win your previous day's Balance, add all debits and sutlf3cl all credits for the current day and multiply the net amount try the
applicable dally periodic ra!e (see following paragiapnsl The finance charge for each type of Balance a then added to and :ncuced m m31 day's Balance VV,, treat a credit balance for arty day as
zero We delermme the total finance charges on balances for the tilling cycle by adding lo,etner me finance charges for each rice at Balance for each day within the billing cycle In calculating
finance charges an adlustment will be made for any Iransactan u payment that would nave affected !he finance charge cacuti on in a prier tdhng cycle had it been posted in that cycle The
applicabe dairy periodic rate for such a Iraniactorl will be the rate in eeecl for the surfed being cycle ratrer than tree rate in effect on the date of the transaction
Your statement includes an average dairy balance for each type of Balance You can muliply each average dally balance That is not zera by the number of days in the billing cycle aril the periodic
rate to obtain sublotab, and then adid the sutlotab together to determine your total finance charges on balances for the t:ilhng cycle if a cash advance Iransxlcn fee is charged. that amount i;
also a finance charge
The term 'Prime Ra'e' as used in the Agreement means the highest crime rate pi.tiished m !Coe Wall Sfreef Journal on the first business day of tre previous calendar month Any increase of
decrease in the Annual Percentage Rate will lase effect on the first Sty of your ta!;rg cycle and may resell in a slghi increase G decrease in the amount of your minimum payment
You can arrange to have 3 varlatle rate (not below 5 B%) for purchases wruch is lower man the lowest ran introductory ANNUAL PERCENTAGE RATE (APR) you art paying on any of your other
credit card or retail accounts This APR is av 0luste O71 if you provide prxl in the form cf a copy cf YOU! most recent tdhng statement showing your other non-introductory APR Your rew APR
Will take effect m the bling cycle following Our review our proof cut n:! fairer than me end cf y:ur l tloducWry percd your new APR!i es effect. of If we or., not receive proof cf your
lower APR, your APR for purchases will to as fMbws he ANNUAL PERCENTAGE RATE (APZ- r purchases alit vary and may ce aolusteo each billing cycle up to 4 4% above Prime Rate,
but will in no event be less than 12 g% Using this formula the APR for purchases in the August beng tyc'ie Is 12 R corresponding to a daily Periodic rate of 0 03534%
You can arrange to have a variable APR (Coot below 12 905) for custom can advances mat Is Icwer Iran the avenge man :r1rX liry APR you nave teen paying on the total balances you have
transferred from other credit Card retail and Instalmenl amount Govded your other accounts were open in August 1999 In calculating Iris APR we will lake Into account me APRs on Re credit
account balances you have transferred from other lenders This APR is avaiable only if you provide pto;f in the fun of cotes at,cur most recenl billing statements, snowing your other
non-introductory APRs Yoo new APR will take effect In the bill, rg cycle (citcwm our review of your proof but not earter than !Coe end d your introductoryperiod lists do not receive such ool
your APR for custom cash advances will teas follows The ANNUAL PERCENTAGE RATE for custom cash advances writ vary and me be ousted each billing cycle up to g 86%atove time
Rate. tut will inno event be less than 1836% Using this formula. the APR for custom cash advances in the Augirst ff59 oiling cyc e a f836% corresponding to a dairy pefadre rase of
0 05030%
The ANNUAL PERCENTAGE RATE lot cash advances is 219% conessc ding to a daily periodic rate of 0 C'6l,
II you do not comply with the terms of this Agreement your ANNUAL PERCENTAGE RATE for purchases will to 18 g%. codre:pondng to a dairy periodic rate at 005178% and the APR for cash
advances and custom cash advances will be 23 9%, carespcndng to a dairy periodic rate of a 06548% Your Account may be en, re or the lower regular APRs after you have met the terms of
this Agreement for three months It you contact us we will review your Account to determine your eligibility for Ine IOwem APPS
Ghee Period for Purchase Balance. New purchases posted to your Account m silting 0rC'es with no pfevidu: balance of when Ire previous balance was fully pad during Ine cycta d3 not begin
to incur a firusnce charge until ire start of the next billing cycle You will pay rig finance charge on such new purchases d you err the total raw balance m full by the payment due date shown on
your statement New purchases posted in any other tiling cycle incur a finance orange. aria there d n period in which such purchases may be repaid without incurring a finance charge
Fees. We win charge your Account up to SO la each Card you ask us to replace each retcmed payment check each crack ycu write on your Account that we return unpaid. each stop Payment
order at renewal of such an Order, each billing cycle within which your Accent is delinquent (late charge). and each biding cycle w tmin which your balance exceeds your credil line even if your
Account is closed it you request copies of billing statements that were fast Sent to ycu mcfe INS three months earlier we may charge a handling fee of $210( each suen copy A cash advance
fee of 3%(mrumum S5) may be charged for each cash advance transactor made On your Acceurt
Default You will be in default of any information you provided us pi to be inccmplce or untrue J ycu do not tcmpy Aim 3Cy c3,1 cl mS Agreement. upon your death. bankruPtvy, or
insolvency, it you da not pay other Oetls when due if a Dankruplcy Pe itan IS film sy or against you art we tebeve in good iatn that you may not pay at perform your Obligations under this
Agreement if you are in default we may, without further demand at notice cancel your cre3l pruileges. declare your Account ba'ante immediately cue and payable, and use any remi we may
have in the event of your default. the outstanding balance do your Account small con!mue to accrue interest at the APR(s) diseased m the Finance Charges section of this Agreement. even if
we have filed suit to coflect the amount you owe
Credit Line. Your credit line is :pacified from time to time in 3 separate notice 'We mar :rcrecise or decease your Cre a inn ta:ed on information we chained from you or your credit records
Your available uedil a formally Ire difference terween your credit fine and your Account taunce Including tranachOns mad! N a: ^Crsed tat rot yet pc:!ed1 If you send us 3 Large caymenl
CheCN, we may IMA your arrLa[le credit While we confirm that the shock will diem pCr Certbn tran:actWA. avalof Veit day ce'ess You will rat use your Account for and we may refuse to
honof, any transaction which would cause Y!;u to exams ] yccr avaaabe cref:!
Promise to Pay. You promise to pay us when due all amounts borrowed Ahem you ci someone else use your Acceurt Leven f Pe amount crargM exceeds your permission) all caner
Itaniaotans and charges to your Account. and coed cmais we loaf including t i nit ,in ted In eg:,:natI, a"crrry 1 loe i 3•S :-ua tests 1'JYcu win the suit we will pay your reasonable
attorney's fees and court costs) -
Changes. After we provve ycu any malice relatred ty law we may chi an, part zd fir,; A.;rr,;Irnri 3^d aJJ Y Icm.:',f •r;:;mfr-«n!S If 3 charge , made to the Finance Charges sectcn of
this Agreement the new hllance charge alcuiafron will apprr to your entire Au;v m Glance hem ire f'tehve dllC if 1^e :r-a,,e ,r`an'ges A:f icily Is baurce, that mn?de items c^died t0 pry},!
Ace, nt before the We of Ire Cri and A:II aptly Ane!rer or hd ncu e:rim Le ca ,e Ire ACccari
(Continued on fowler IM CI:596) 4429472557fofe6e 0730 i99 y•
Foreign EachangelCurrency Conversion. If you use your Card fa eansacirns m 3 currency Clher man U S Ir ars me franxaC!icr.: w g to converted to U S dolours gew3N ut i? adhq a U
9cvrmmenPmandated rate a Vi) wholesale market ra!e,n effect tie Gay before the rromarncn ptressing ts;e nuea:,rf ty five percent 15%I !f a :real is sutselluenty given for a transaction n
will to decrea:hl ty the saint Cetcenlage If Ine Credit has, a different pnscesc,ng dwe men !re ercnuge dtr of tie cre31 :an to g e3feraeiS than Inat of the original lansaclior The currency
cor,erfon rate on the di3y tefcre the transaction processing date may dtfef from !ire rile m effect at me time U the Iron:x!.,;n a ion the date me !ransa:hcn nt pasted ion your Account You
agree to x:epr !ire converted amount in U S ocaars
The Card; Cancellation. YOU may cancel your credit prkile^tes at any nmE Cy "I ll,"I :s in or ,no and dill rg the C, irdt3J r;p.,n Ire CalI eICraton at tie end of the mcnih. shown on I we
reserve the might not I0 rer" the CaW We may cancei the, did and i0uf cl,e3t cr r?..e'gei 31 air cure atte' .vj ;ay: hi b: yr,; -:r w n4ut ni it permitted ty aw II tout Card is cancelled cr
not renewed finance charges and oli fees, will Continue to pe asse::ed payment: iv l continue to t+t die art ad )tiler acr<at a cgv.ars :I this agreement wd remain in effect If you
terminate your crept prmogres or d we cancel or do not recce Ine Card y:u mat no •crgef w•.le :rt:i,s ion t:ur aa:b.^! 3n1 tcu :r{u' 3l s'roy any pru:e.d cte.ks we have issued to you
Personal Information; Documents. YOU will provvfe us at least 10 Gays mace d you Orange your name home w matrl'g address telephone rumters employment of income Uten out
request ycu wig provide us additional financial information We reserve the rght to ptfair mlcirt !rpm :roe's ircluorg c!ea! reptmrg agen.el and to pray de v:,f address and mformaticn
about your Account to othNS ppigg ?mgg????Iyy???'r?gle mfprmalidn with I,r at!.bates Mw r n m wr?t+7• t me m Ir in I' n r ^H inf•rm firs wnn r fri f If you
do net fulfid your obig3tan7 under tMS 4eemeni a negative credit report ;hat may re ect Cis yNt credit may be suomd?eg to Ire crept rewoing agencies
Customer Service, Unauthorized Use, Loss, or Theft of Checks or the Card. Each Card must to sgreef en recect You ate resocnsitle for safeguarding the Card your Personal Identification
Number ('PIN' wnirh provides access to Automated Tesler Mach.res) and any Checks Sued to you from their and keeling your Pill seear3!e from ycut Card If you discover Cr suspect that
your Card PIN or any unused checks are W of stolen or that there may be 3n uhaWncfized tr3rsa:!cn ion your Account. you will prcmplry mi us by calling 1A00.931-ItUl So we can
immeoatey act to limn losses and iwbfury you w,If phone us ecen tM:agh ycu may rasa monry us in wnli Your hat,lrtr foor unautlUi use o:curnrg tefore you hoary us a limned to W U you
report a we suspect uhauthorued use o1 your Account. we may suspend your crept prmleges until we resolve the problem to our satisfaction or issue you a new Card if your Card n lost or
stolen you wfa promptly destroy all check: in your possession To ?mcrcve customer service and security you agree that your cats may be mondorm or recorded
Merchant Relations. 'he wig not be kalck d any person or Automated Teller Machine refases to nonce the Card of accept your checks or fails to ratan the Card to you Yke have ra responstilrry
for 9001• and services purchased with Ine Card or checks except as required by law )See Special Rule teavf ) Certain temal that are available won Ine Account ate pafoo t/ thed-parry
venom We are not responsrNe for the Wady avaiabkty, or results of any of Ine services you choose to use
Stop Payment Orden. 11 you wish to stop payment on a check. you may send us a stop payment order by wrung to us at cur address for customer service listed on your statement You can
make a Stop payment order orally by calling the number listed on your statement When you make 3 stop payment Order. you must provide you Account number and speck information about Ire
Check the exact amount Ine date on the check, the name of the party to venom n was payable, the name of Ine person who Sgned d and ma check number You will be asked to confirm an oral
stop payment order fn Ivehm9 rt r r r r I I t if w r . e rr mi n nfirm n wimin r w k fi r m r l r of If we have nol received an adequate
description of the deco so that payment Can DB SiCppu`uf ire order will not tee ective f the check was pace by us pe.ofe we had a rlaSOnabf! cwonUMry to act or th! older Wo mery, r enWl
kablily disregard a winner stop payment older six months after recept unless ft is renewed m writing
Standard of Cars. Because this Account involve: both credit card and check tramat tons which are processed through Separate national systems before Ine transactions ate consolidated by us,
and because wt every check and Card stp will be sent to us, transactions in your Account will to processed mecranmaty without our necessarily reviewing every diem Our processnr?gg system wa
Cal our attention to certam gems which we will examine We wtt examine ail transactions when you report Thal your Card a checks have been lost or stolen We do not intend orpnany b
e+amue erg Hems, and we will rot ha negligent d we 1o rot ed so This rule establishes Ine standard of orpnary care which we in good faith wig exercise m administering your Account Because
of our Ynded review, and because mother your cancelled checks nor Card transacton sips will be returned to you with the monthly statement, you skill be careful b enter all checks fn your
check register or otherwise keep a record of them You should also save your crept Card cash advance and purchase slips Yo amee I n k v r montnH star m Is acaiml v r r ord end
to ncnH us unmedateH of any unauthauzed transactfms of errors
Well of Certain Rights. We may delay or wane enforcement of airy provision of this Agreement wenpul losing our rgm to enforce d a arty other provism later You wake IM not to
presentment, demand, protest. for notice of dishonor, any applicable statute of limitations, and any right you may have to require us to proceed against anyone before we file sat against you
Appikable Law; Savenbllfty: Assignment No matter where you live. Iris Agreement and your Account are governed by federal law and by New Hampshire taw This Agreement n a fin31
expression of the agreement between you and us and may rat be contradicted try evidence o any alleged 0131 3gfeemenl It any provision of this Agreement is held lobe trit or unenforceable,
you end we will Consider that provision modified to conform to acNicabe law, and the rest of the provisions fn the Agreement wilt still be enforceable At arty tune aher we determine in good faith
that airy proposed or enacted legislation, regulatory actim, or Iudcal arisicn has rendered or may render airy material provisicns of this Agreement rv3lfd a unenforceade, of impose any
Nareased tax, regional requirement, or other burden in Connection with arty such provision of cis enforcement, we may, after al least 00 days notice to you, or without notice d permitted by law,
cancel Cie Card and your Carol privileges We may transfer or assign out tight to all or some of your payments if state law requires that you receive notice of such in hart to protect the
purchaser or assignee, sue may give you such notice try filing a financing statement wfin the stale s Secretary of State
Notices. Other notices to you shall be effective when deposited m the marl addressed to you at the address shown os our records, unless a longer notice perod s Specifievd a this Agreement ar
by aw. which period shag sat upon mailing Notice to us shall be mailed to out alless for customer service on your statement (a other addresses wa may specify) and shalt be a ecike when
we fectkeit
YOUR BILUNO RIGHTS - KEEP THIS NOTICE FOR FUTURE USE Thus notice contaas important mfofmaton about yodt rights and o t responsbh!,eS under the Fair Crept Bi Act
Noddy Us In Cut of Errors or Questions About Your Bill. If you think your bit is wrong or d you need more information about any transaction W your bill, write us on a separate sheet, al the
address listed in the Biding Rghts Summary on your big W mile to us as soon as possible We must hear from you no later than t0 days after we sent you the first fog on which the tnor a problem
appeared You can INephone us, but doing so wA not preserve your rights In your letter, gve us Ine fotowing mform3lion •• Your name and Account number - The ddlar amo nt of t e
suspected error - Describe Ine error and explain, if you can why you believe there is an error II you need more information describe the item you are rot sure about
Your Rights and Our Responsibilities After We Recrive Your Written Notice. We must acknowledge your letter within 30 days. unless we have Corrected the error by then Withm 90 days,
we must either Correct die anon of explain why we believe the boll was correct After we receive your letter, we cannct try to cegect arty amount you question. for report you 3S delmat"I We ion
Cmtmue 10 fog you for ore amount you question, actudrg finance charges and we can apply ary unpaid amount against your crept are You do rat nave to pay arty questioned amount while we
are ukestg3nrg, but you are slid obligated to pay the pans .,f your bid Inert are not fn question
If we find Cat we made a mistake on your bp, you will rot have to pay any finance charge related to any questioned amount II we cidn'I make a mistake, you may have to pay finance charges.
and you wig have to make sp the rinsed payments on me questioned amount In either case. we will send you a statement c1 the amount you cove and Ine date that it is die If you fad a poly ge
amount we mmk you owe, we may report you as dehrpuent However, if our explanation does net satisfy you and you write a us wilh n 10 days telling US that you SI3 rehse to pay, we must eel
anyone we report you to that you question your bill And, we must tea you the name ct anryrone we reported you io We must tell anyone we repot you to that t e maser has been settled between
us when a finally n If we don't follow these rules, we can't collect the hill S50 of the questioned amount, even if your fog was correct
Special Rule for CredJf Card Purchases. If you have a pi ctlem with the quality of the picpef y or services that YOU purchased witn cur credit card and you have filed m good faith b rnract the
problem with the merchant you may not have to pay the rem3imng amount due on the goods or services There are two I nflation% on tM right )a) ou must nave made Ce purchase n your
home sate or d not within your home state, within 1C0 miles of you current mailing address, and (b) the purchase price must nave been more the These hmiatam do roh sppy two r ws
of operate the merchant, or 11 we mmled you the advertisement for the property or services ?^l
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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: 168 Amy Dr.
Carlisle, PA 17013-8884
COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JUNE G. BAILEY
Defendant
NO. 99-6475
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
[ J Money Ju
[ ] Judgment
[ ) Judgment
[ I Judgment
[ ) Judgment
[ ] Judgment
[ ] Judgment
[ ] Judgment
[ ] Judgment
[ ] Praecipe
by
3gm
in
in
on
on
on
on
on
on
to
Default
:nt
Replevin
Possession
Award of Arbitration
Verdict
Court Findings
District Justice Transcripts
Judgment Note
Writ of Revival
Reassess Damages
IF YOU HAVE ANY QUESTIONS CONCERNING THIS
NOTICE, PLEASE CALL: Park Law Associates, P.C. at this
telephone number:(215) 348-5200.
P HONO''ARY:
0 -
PURSUANT TO THE FAIR DEBT COLLECTION PRAC CES 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. # 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: 168 Amy Dr.
Carlisle, PA 17013-8884
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JUNE G. BAILEY
Defendant I NO. 99-6475
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 JUNE G. BAILEY, Defendant is over 21 years of
age; that his/her place of residence/businese is
located at 168 Amy Dr. Carlisle, PA 17013-8884 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.C.
BY:
Valerie Rosenbluth Park
Attorney for Plaintiff
Rio
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 I8:
PLAINTIFF: 295 MAIN STREET
TILTON, NH 03276
DEF: 168 Amy Dr.
Carlisle, PA 17013-8884
COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JUNE G. BAILEY
Defendant
NO. 99-6475
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
$12,289.45
$2,457.00
$634.14
($0.00)
($0.00)
$15,380.59
PLUS ADDITIONAL COSTS
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS
FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT
AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to
file this Praecipe was mailed or delivered to the party
against whom judgment is to be entered and to the attorney
of record, if any, after the default occurred and at least
ten (10) days prior to the date of the filing of this
Praecipe. A true and correct copy of the notice pursuant to
Pennsylvania Rule of Civil Procedure No. 237.1 is attached
hereto and marked Exhibit "A".
VALERIE ROSENBLUTH PARK,ESQUIRE
Attorney for the Plaintiff
AND NO??, /?a , Judgment is
entered in favo of t e Plaint ii f and against the Defendant
by Default for want of an. Answer and damages assessed in
the sum set forth in the abo certificat on.
i
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.
VALERIE ROSENBLUTH PARK
ATTORNEY I.D. 8 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 TIME
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 295 MAIN STREET
TILTON, NH 03276
DEF: 168 Amy Dr.
Carlisle, PA 17013-8884
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
Plaintiff
VS
JUNE G. BAILEY
Defendant NO. 99-6475
NOTICE OF PRAECH'E FOR
ENTRY OF DEFAULT JUDG51E ITT
TO: JUNE G. BAILEY
168 Amy Dr.
Carlisle, PA 17013-8884
DATE OF NOTICE: 11/19/99
IMPORTAN F NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A NEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT DAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMWISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
PARK LAW ASSOCIATES, P.C.
BY:
VALERIE ROSENBLUTH PARK, ESQ.
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT
y. ^.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06475 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDAN NATIONAL BANK
VS.
BAILEY JUNE G
HAROLD WEARY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within CIVIL ACTION was served
upon BAILEY JUNE G the
defendant, at 18:42 HOURS, on the 27th day of October ,
1999 at 168 AMY DRIVE
CARLISLE, PA 17013 CUMBERLAND
,
County, Pennsylvania, by handing to JUNE G. BAILEY
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 Costa:
Dockgting
18.00 So answe s:
Aff dav 3.00 I
it
Surcharge 8.00 M . All 111Ctb
:p29-TQ- 10RK 14AW ASSOCIATES
by l , bbn-er9?r-
LJUPULY Sworn and subscribed to before me
this 3 day of kPt , ./ _
199 A.D.
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