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Home My WebLink About99-06484 N _G X; 14iC>` ? r X , f r1 ~ HHHYYY ? r r . i:'i`e l a t S . M1' -- Y _ tiles r .. ry ` A k oaf l a , I&u x. ri t t 1 Y+ y ; i t 1?Gw9d: ? ? '" ? v e Y r r?? q b t i, } rr } y,ri?w ?t r C Q ' rl t 4t 1Y {{ .. \Y T ?1 0 t ? v h Kip } -Qi c?? F -iOl r Y' n .. ` rJ IJ 00( 1 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 COUNTYp PENNSYLVANIA PROVIDIAN NATIONAL BANK Plaintiff VS. MARYANN A. FORRY aka MARYANN A. MCNALLY Defendant NO. ar 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. #1 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS MARYANN A. FORRY aka MARYANN A. MCNALLY 207 BERKELEY DRIVE MECHANICSBURG, PA 17055 DEFENDANT No. 99- G `/S yOTcu-- 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 MARYANN A. FORRY, an individual who resides at 207 BERKELEY DRIVE, MECHANICSBURG, PA 17055, and aka MARYANN A. MCNALLY, an individual who resides at 207 BERKELEY DRIVE, MECHANICSBURG, PA 17055. 3. The Defendants are indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendants or authorized by the Defendants on a credit card or line of credit owned by the Plaintiff bearing account number 4428562305502606. 4. The terms of said account are stated in the documentation attached hereto as Exhibit "A." 5. The Defendants have failed to pay the amount owed in accordance with the account agreement and have failed to pay the outstanding debt as agreed. 6. The Defendants are indebted to the Plaintiff in the amount of $8,631.86 as of 09/24/1999, plus pre-judgment contractual interest at the rate of 6.008 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 $1,726.00. COUNT II 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as though set forth in full. 9. The Defendants received a monetary benefit, which was in fact appreciated by the Defendants. 10. The Defendants accepted the benefits. 11. By virtue of the circumstances surrounding the request for funds made, the Defendants 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 Defendants to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendants to retain the value of the funds at issue without repaying the Plaintiff the value of same. I WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendants in the amount of $8,631.86, plus pre-judgment interest at the contractual rate of 6.009 per annum from 09/29/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,726.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALE I ROSE U , 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. :T r , 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 parties verification 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. • r r I rj le- c fS 2s?,f ?tic !1 S-e k F EXHIBIT !b`'?y,'a!i^? `?]r??Slf?j!?,]?,{T? IJ..• : \ ?.1SN?r.`!?.'?114"sSl.1 NON NEGO ?Ltr -tom/f {f1?t4 t-??3 ? f - ? rfll•?f ???,+1'??r 1 5 ?•- AttefN• ? 1 ?..? {I• .r ?+ ti ?? pod INdma talk 4m ltaripbJre. SEVEN THOUSAND FIVE-) t IS L !. 'n;?r. •?ti?1 INDRED. DOLZARS PAY TO THE ORDER OF to cob or 4011L Maryann A. Forry ` 207 Berkeley Drive r? Mechanicsburg, PA 17055-2355 ABSOLUTELY! Nothing to lose and everything to gain. Respond today! r nct.ki i YES, I'd like tit olxn a Capital Cash Aatntnt. i'Iease wnd me a check. I agree to the Capital Cash Aa-uunt Agrentent (which will bL tmailai to me with my check) and to repay principal, interest, and interest theron, eu-ept that I will have no obligation if 1 return the check umuccl after rctietting the Aat]ont Agreement. This imitation expires: march 1 , 1993 Maryann A. Forry 207 Berkeley Drive Mechanicsburg, PA 7155C1 TI120 GX138 KOE11 QDJR OBHB RCCD 155-3898-6693-2 17055-2355 ABAE 10C I" Mir n1.TA01 -- -- Credit Protection Plan (Optional) - YES, t aouht like to help protest my Capiw Cish account artd credit sting with the optional Crain Prowkn Plan dexsibed tat the reverse side. - . - `'•'`'' , . YES (W _-here •; _ V ? -. /. S. - S. V :aklal kwntyq Mlinter '?7/ r n? j np?J I Inmc Thane %%,rrk?Scavnd Phone Fst? t t Ttm Ilomrt Rent Armful I1vtochnid Inc=e S red / Frnploymcnt Retfrtd `YI6l'.tnpln}ttil ? F:mplacnt Employer"Namc: `l'vavz _-------.-. ---- •/ Ir?•?M rrum •we.l nu?AU U...?.1 C1W EXHIBrr ik" PROVIDIAN ?-nhrm rs( lint Deposit National Bank VISA' of MasufCard' t. • . ACCOUNT AGRE!MENT FOR Maryann A fully le [trerhrt alter Patine Nantletty or other !geed upon cais adr.mreft/ Aire been completed Your First Deposit National Bank VISA or MastuCaid account Iee'Accaunl•l aoews you 10 nuke purchates III nnnl vnu' VISA or MasterCard card nha'Card I w never at is Goof and to gel cash advances from us or any other parloryarng financial institution Convenience checks may also be provided In v„ it to additional war to use the Account. In this Agreement. 'you' and 'your' mean each person for whom we have opened a credit card Account. 'We,' 'our.' 'ours' and 'us, mean ethr fell O.1,ovl NAtwnal Bank. of its at3,gneet. You My Act be eligible lot in Account I You or a member of Your household already have a credit account with foil Oepout Nalmnal Bank or Praindan Natmn,d flanker the Account may be used only for personal, family, household. and charitable purposes, and not far any busmen or commerical purpose You and we agree as lopows: Special Requirement at this Account: Credit Review Program. In order a keep your Account in goad stando 1. y"G have agreed not to increase the amount latter any balance tra if,11 have heel congleted) of your total debt on unsecured reralfnq credit accoune with other lenders without our autho"t11,an. We writ renew your credit recorw periodicity and contact you d we believe you its not meetmg this special requuemnt. Cash Advances, Balance tors tender to toil Account Ism alher lenders will be posted Assists advances You me request cash advance checks by calling our top Iret number kited on your slil'th . You may also get A cosh advance tram any VISA financial in sheloon Id Your Card I a VISA card) of MesltoCAid I.,.mnal mstduloan I,I your Card is a Mntat Card tafill. al selet led Automated Tell, Machines. and by check. Fitymenn. You will rcnve a rromMy sla,two, showing rout outstanding balance You will pav us in U S. dollar Ichechs nml be payable it a U.S. al face of the bank the check is down on) at leas) the Peyment due as shown on your Scalawnl by the poisonings due data in accordance with payment numctmns on year nvmlhlY statement. You may not use your convenience checks to make psym mil on your Account Or to make pAe^r"ts an any other account you have with us at our alfihares. The payment due "IN be.. 24 at ace new balance tboom an your slatnrnt plus the amount al any past due Pascal plot the amount by which the new balance eaCeeds your credit line plus lees lot [,tan oplmnal terfe;G+. flowerer. the payment due will mat be less than 115 runless your new balance is less than 115, in which case she payment due will be the amount al the navy balancer. We my Iequve a higher nu,vran pAYmnt If vout Account is past due or above the Ueda line but we w.A notify you bolero doing so. 11 your paymml n mate than the pay^knt due. it will be treated is a 3,1194 payment and none of it will be applied la future payments due. We may accept late or partial paymnls, or Payments marked "paid in lull" or marled with other restrictions. without losing our right to collect ad ar yin aft owing under tAn Agreemo finance Charges. Eetpt as described an the Grace Period A( Purchases section of this Agreement. finance chanpe herpn to accea an a debit when it is included in ether the daily purchase balance rpurchase Balance) or the daily cash advance balance ('Cash Advance Balance) and continue wild that balance ?s reduced by a Palmas or traffic Any payment amount we receive that esoeds the IMAACt charges and lees then due will first educt The removing Purchase Balance. and ton. U the Purchase Balamre of min. wit reduce the remaining Cash Adverse Balance. The Purchase and Cash Advance Balances are reduced by p litrnls as of she date rcered. and by credos restrict tar reversals at late.. over hills. told enscelaneaw charged is of the dale posted. Purchases art included on your Purchase Balance as of she data made. Cash advances ice included in your Cash Advance Balance as lopnws cash advances from other financial institutions and through Automated Telhe, as of the date made, cash advance checks nude payable to You that are identified as cashier's checks and mailed so you as ymv U,Saesi. as at seven days alter me data we print an the check; all other checks. as of the date Presented to us: funds electionKalr' transverses to other leaden to transfer balances. as of she data Ir.1,1Y el. Other debris lessees far late. over total. finance. and miscellaneous stiffest are included in your Purchase of Cash Advance Balane as of she date posted. Finance charges are added to yOm I"nel,Att and Call Advance Balances each day and are then posted on the fast day of the billing cycle. There is no poorest within which cash advances may be repaid without ncunng a Inanct charge. To fugue the daily finance charge lot purchases and the daily finance charge for task advances. wa start with your prrvimn dads Purchase Balance and Cash Advance Balance. add AN debris and subtract Ap Credits for the current day to the AP0loable Balance lei esplamed an TM paragraph abarel and multiply she net aneanl by the applicable daily periodic fate Isle Meaning paragnphst. The Inane charge for purchases is then added to And included in that day's Purchase Balance and she finance thailt tar cash advanes is tern added to and included in that day's Cash Advance Balance We treat a credit the ing each day chases L'a Inane charge calculalwn balance fat an Sit as finance cha for cash advances for each oday within Ae falling cyclleInterco . In calculating flnance charge .tan adjustment wdi"o theide fnrrp y"Ira nation for parties that would rh ve sail cued thcycle n a prior billing cycle had it been posted in that cycle. The appi"b a daily periodic rate tar well a lenecimn will lie tlo late in effect fat the current billing cycle ether loan the fate an ellct on the are included in she and Ca es drown m • lance stused I t computing finance charges. because the Purchase and Cash wb?o from date Balances do not Tinclude he balance any ?amounts Shown o a your sl e0m nt my s differ Advance The daily periodic rile for purchases is 0.060004. corresponding to an ANNUAL PERCENTAGE RATE I'APR"I Ior purchases 01 2190% The daily periodic fete tot cash advances is 0.060004. cwespandng to in APR for cash advances. mcluding balance Ilantlen. GI 2190%. To dalerfnae she avenge daily balance shown an your staterrcnt lot purchases, add each day's Purchase Balance Ira knlnaal Silly finance charge) in the billing cycle and divide by the numb, of days in the billing cycle. To determine she Image daily balance shown on your stateernt for cash advances, add each d.q's C,nh Advance Balance dncluding duly Imance cha,gel in the being cycle and divide by the number at days an the billing cycle. You can multiply each at these areaye daily balances by the numb, nI dap At she bolin9 cycle and by the applicable daily periodic isle to obtain subtotals, And then add the two wbialals together to determine the total amount at your Imance charges far the billing cycle_ Grace Period for Purchases. New purchases posed to your Account tat brainy cycles when the previous galan,:r was ern. Of when the previous balance was luny pad during the cycle, do not begin to incur a finance charge SPIN the sect of the near billing cycle. You can avoad any finance charge on Such new cmcfiaaes it you pay the total new balance in fug by the paymeml due dale shown on your stalernent. New purchases posted many other billing cycle incur a finance charge from the date the purchase war aruale and there n no period in which such purchases may be repaid without Lai a finance charge. Thee is no period in which cash advances my be repaid without ncurring a Imance charge Fes. Wt will charge your Account up to I to lot, each Card you ask us to replace: each returned payr^ent check: radr ehrti you wills on your Account that we return unpaid; each stop payment order or renewal of such an alder: each billing cycle within which your Account is delinquent Ilale chArgel; and each "duml rple within which your balance eaceedt your credit line. If You oquell copies of billing slalementa that well lust sent to you mime than three months Allies, we may charge a handling lee of 12 UU ter each copy DefaulL You will be in default: s You wee not eligible for the Account at the time at was opened; if you lad to Uutyaly with any pan of this Agftemenl; it any nfanulon you gife us profits to be nconplese Or false; upon your death. bankruptcy, or mselvency; it you Iml to pat other debts when due; it a bankngnrv Vetnon n filed by or against you, at if we believe in goo laith that you may not pay at perform your obligations under this Agreement. On your default we may, without further demand of "aloe. cancel Your credit prvileges, declare frour Account balance weredulely due and payable. and Invoke any remedy we may hire In the event at your default. the outstanding balance on your Account shad commas to accrue interest it the APR41 disclosed in the Finance Charges sectors of this Agretmens, even if we have sued you to collect the amount you owe. Credit tine Your credit line is specified from time to hone in a separate notice. Your available credit I normally dm old Feavoe between your credit line and you, Account balance (incli dnq tfanuctions made at authorized but not yet posted). For cassava cash advance, available credit nay be less. You will not use your ArtGaGgs Ior, and we may refuse to honor. any transaction which would caws you to esceed your available credit. Promise to Pay. You planse to pay us when due all amounts bargained when you at soineane else use your Annual (even it the amount charged emeeds your permssioal. Ad other transactions and charges to your Account, and collection casts we incur including. but not lured to. reasonable aitomey's fees and taus costs (t you win she suit. wt nun pay your reasonable attorney's less and court casts.) Changes. We may change any part of this Al eertens or add at remove equeemrnle else notice as required by law ll we change the Finale Chupn section GI this Ageemmt. the new finance charge calculation will apply to your whole Account balance from the effective dale of she change, whether m tl t r d 'n ems purred m tour Aaount before the change date and whether or not you continue to use the Account. Foreign EsctingelCurrency Conversion. If you use your Card for transactions n a Currency other than U S dollars, the transactions woo be converted to U S. dollars, generally using nth, a u ov rnnensmandated fall or in) wholesale marht late in effect the day before the transaction p ocessnq date maeased by are percent floor If a credit it subsequently given lot a transaction. it be decreased by one pescent hoot. If she credit has a different processing data, them the enhinge rate of the crm7n can be grit, less man that of the original transaction. The currency conyoosion tale on the day before the transaction processing date may differ from the rate in effect at the ire of the tranwctmn or as tae date me transaa,an is posted on yaw Account. You agree to accept she converted amount n U.S. callus The Card; Cancellation. You will return the Card to w at our request. The Card stories al the end of the month drown 011 It his have Toe nghs not to renew the Card. At any titre sitter at legal 20 dap notice to you, or without notice it committed by law, we may cancel the Card and your credit privileges II y"m Card as canceled or not renewed, finance charges and other feet will continue to be assessed. paym oils wail continue to be due. and all other applicable coalitions of this Agreement *In emu, nt fillets. you may cancel your credit privileges by notifying us in *film q. returning the Cardbl to us cut n half. and paying your emae tfalemrnl balance by the paymml due dale on the statement which includes lour final purchases. cash advances, charges. and lees. Your credo privileges will be cancelled and no additional finance charges wall be amposed. ll we cancel or do nag rnew the Card. of It YOU ermnala your crtdlt erivdt9et. You MY no Ong, woe ccks on your Account. and you should destroy any unused checks we have issued ta vnu. Personal Information; Documents. You wee give us as least 10 days notice it too change your name. home or mihnq address. Telephone numbers. or pb. You Will promptly give us information about 5712 Maryann A Ferry P21.90F 1 C21.90F ZIPS yew financial ellass .1 wet ask lot n. We may get such information from others. including credit reporting agencies. and Provide you' address and mlarmilon about row Account to 61*1. We MY also share such Affiliation with our alliatrs. II you lad to finite any of your obagalons under lhit Agreements. I negaive credit report nllechrg an your credit record may be Wamlled is Wedri ripottng agencies. Customer Service, Unauthorized Use. Loll. or Theft of Checks or the Card. Each Card nit be signed on receipt. You oil safeguard the Cud. your personal denulKKwn number lvihah prarides access to Aulomalyd Ttaer Machinist. and boy thick, awed sa you from their. you wo keep your DHwnal dentrfoatron number separate from your Card. H 11??ou dncov n or suspect that the Card at any unused checks are lost or stolen, at that there may be in unauthauced Iransactan on your Account. you w.l 0461IIrr us pmapdy by leltplianmg 1100 903-1221. You rte phone, tyro though you may not ly us in writing. so we an act fast to halt losses and liability. Your readily for unawhonted use occurring betas you 1101,11 us S limited to 150, If yaw flows or we suspect unauthorized use at your Account, we nary wsp"d your credit privileges until of resort the problem to our satisfaction at issue you a new Cud 11 your Cud is lost at stoen, you rte promptly destroy as checks n your possession. To +rgmve Custner triIXe and security. you agree that your caps my be monitored of recorded. Merchant Relations. We will not be rebl d any prison or Automated Tiger Machine refusal to honor the Card at accept your chicks, of fads to return the Card to you. We have no nsponpbity lot N ods and sermKe yurchased with the Cud of checks accept as required by law. ISee Special Rule below I Ceram benefits that are available with the Account are provided by thedputy meadows. If are not responpble for the quality, availability, at recalls of any of the serrde you choose to use. Slap Payment Orders. It you wqh to stop payment an a check, you may send us a stop payment order by writing to us at our adders for customer senvrze listed on your bill. You can make a stop payment order, only by akay the number listed on raw ttatmsent. Whm you mks a staff paynenr order. you mtsl provide your Account number and specific nforrtation about the check: the filet amount, the dice on the chick. the new of the party to whom it sun payable. the name of iM person who pgned I. and the check number. You will be asked to carriers an ool stop p4•fwn order in writing. We ma dies Hit our oral order,1 w do nor receive a u led ii conlumatn, w9hm two wells Sher tha ores order or d You have not adequately described the nom so fait paymnt an be Stopped by our carpular. a ar w w not of e ective. too c K car pa y m e fan we a a ruana a aaDOrtumry to act On the alder. We may• w.IhOUI readily, disregard ) wntlom slop payment order as months alter receipt unless it is renewed an writing. Sanded of Care. Because this Account involves both credit card and check transactions which are processed through %spuats national systems before the transactions its consolidated by us, and because net every check And Card sap sod be sent to us. transactions n your Account rte be processed Mechanically without our necessawdy reviewmg every item. Our processing system wit ill our attention to carton items vi we will erarnne. We sod wmha at Innarwns whim you report that your Card or checks have been lost or stale. We do not mind ordinarily to fsamine AN items. and we will not be negligent it we do not do a. This full esablishes the standard of ordinary are which we in good Inlh wig eterbse in administering your Account. Became of our rented review, and because neither your emerged checks nor Card tianseCldn sfpa will be returned to you with the monthly statement. you should be Careful to Inlet IN ChKks m our check a9siri or otherwua keep a record 41 Man. You should also are your credit card cats evince and purchase slips. You agree to chi ck your monthly stalerrcms against your rKord and to ,.1, 1, us grain y al any umuthonlml transactions or error. Waives of Certain Rights. We may delay at want enforcement of any provision of this Agreement without lasing our fight to enforce it or any other provision later. You waive: the tight to pre3enlmi demand, protest, or notice of dishonor; any applicable statute of limitations; and any fight you my have to tequila us to passed Against anyone belare we we you. Applicable sow, Seveabilitp Assignment. No matter white you has. this Agreement and you, Account are Classified by federal law and by New Hanpshee law. At any tore offer we determine in good Ilnh ilal any proposed or muted legidaton, tegulat4q action. or pdical decision ha rmdertd of My tender any national ofowpon of this Agreement unsold at unenforceable. of Impose any increased a4 ltporing toqutemenh or other burden n confusion with any such provisory or its enforcemmi, we ma , alter at least 20 dill relief to you, or without office d primirted by sow, cancel the Card and your credit pprnepes and declaa your Account balance a redalely due and payable. II any provision of this Agreement is hold to be niHd or uninteresting. you and we wig consider that provision modified to conform to Applicable law, and the rest of this provisions an she Agreement will stint be enforceable, but we will have the right no cancel your Account and declare your balance immediately due. as provided an the prKedng sentence. We may transfer or assign out right to ag or same at your pallmena. II state law Squats that you rename notice of such an areas to protect the purchaser K assignee. we may give you well notice by fang a financing statement with the states Secretary at Slate. Notice. Olhri notices to you shaft be effective when deposited an the fall addressed to you at the address shown an our records, unless a longer notice period is specified in this Agreement at by law, which period "it start upon mating. Notice to us Nat be ruled to our address far cusr4mer service an your statement for other addresses we may morcilyl and shaft be elfeclwe when we tecnve it. Your Billing Rights - Kelp This Notice let Fulwa Use This notice coattail initiations nfometan about your this and our ntponubd.Ge under the Fan Credit Befog Act. Notify Us in Case of Errors or flotations About Your Bill, II you think your be is wrong, or,1 you need man mfoematen scout in "try an your big, write us. on a separate Ntat, at our address lot customer service listed an your bid. Wine to us as soon as possible. We rtit bear from you no later thin 60 days after we sent you the lest bit on which the error or problem appeared. You can telephone us, but doing w Ad not preserve yow rights. In your letter, give us the lolowng: Your name and Account number The doer amount of the suspected error. • Describe the error and upiam, it you can. why you believe there is an error. II you need morn mmtmauan. derelict the item you are not sure about. Your Rights And Our Responsibilities Alter We Receive Your Written Notice. We must acknowledge tow letter within 00 days. unless we have corrected the vital by than. Within 90 days. we mutt Hlher cartel the error or eiplam why we believe Iha bill was correct. Alter we reserve your latter, we cannot try to cotta any amount you question, at report you as delinquent. We can conimua to lime you lot the amount you question, including finance charges. We can apply any unpaid amount Against your credit line. You do not have to pay any questioned amount while we set me rogatng, but you art tug obligated to pay the parts of your limp that its not by question. If we laid that we made a mastiff on yaw but. you we not have to pay any finance charge related to any qunimntd amount. It wt didn't make A marble. you miry have to pay finance charges, and you we have to mete up the allied psymmis on the questioned amount. In either case, wt will send you a statement of the amount you art and the dale that it is due. II you lad to pay the Amount we think you owe, we may report you it delinquent. However. it out Hplanation doer not saMly you and you write to us within 10 days lining us that you site Wusa to ply, we must tee anyone we report you to that you question your bid. And. we must lee you the name at anyone we reported you to, We must tell anyone or report you to that the matter has bin settled reform us whom it Italy is. It we don't lotow these fulls. we can't copKt the lust 150 at the questioned amount. even ,1 Your bit was correct 'Poll" Ruts fat Credit Card Purchases. It you have a problem with the quality of the goods or services that you purchased with our credit card and you have tried ai good faith to correct the problem with the merchant. you may not have to Cay the renaming amount due an the goods or sinvicee. There an two limitations an this tight: let 11iou must have made the pwcMtA n your horn state, or it not Within your home sate. within 100 miss of your current awarding adders: and Ill the purchase price nit have been man than 350. Irate amations do not apply it we own of operate the mercMn6 or if we maded you the advertisement lot the PAPrily or servor. 5172 Maryann A Forty P21.9OF I C21.9OF ll7 ?a "' ? ?n v m m 1.0 1 I It SHERIFF'S RETURN - REGULAR CASE NO: 1999-06484 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS. FORRY MARYANN A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon FORRY MARYANN A A/K/A MCNALLY MARYANN the defendant, at 17:46 HOURS, on the 3rd day of November , 1999 at 207 BERKELEY DRIVE MECHANICSBURG, PA 17055 CUMBERLAND , County, Pennsylvania, by handing to ERIC SHARBAUGH (BOYFRIEND) 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: Docketing Service Affidavit Surcharge So answers: 18.00 6.00 8.00 RR II?? R-I 3-KI3PiS; SPf?f 11/04/199 by Sworn and subscribed to before me this 1-3 &I day of jrun. 4 19 ' 9 A.D. ?Jw Lc lStl?a A 'I I VALERIE ROSENBLUTH PARK, ESQURIE Attorney I.D. 472094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaintiff VS. MARYANN A. FORRY Defendant : CUMBERLAND COUNTY : COURT OF COMMON PLEAS NO. 99-6484 CIVIL PRAECIPE TO ATTACH TO THE PROTHONOTARY: Kindly attach the enclosed verification to the Plaintiff's Civil Action. PARK LAW ASSOCIATES, P.C. BY: PARK, ESQUIRE VERIFICATION it HEATHER KOOREMAN , declare: I am a designated agent of PROVIDIAN NATIONAL BANK, the Plaintiff in this 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. Section 4904 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 Alamedia County, in the State of California. Designated Agent HEATHER KOOREMAN PROVIDIAN NATIONAL BANK MARYANN A. FORRY 4420562305502606 719502-1 Nov"8'r%nEX i` ,. ?. 1 ?, ,.,?. ?, ?.` ?, . ,- ',.. <.,. . U. ? t`? ? ( ... ?: ?.. ?,, i;. ` ?' - i7 . t': ? ?'> G. a .? i,J 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. MARYANN A. FORRY Defendant : NO. 99-6484 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 $8,631.86 ATTORNEY'S FEES $1,726.00 Plus interest from 09-24-1999 to 01-10-2000 $ 153.25 LESS PAYMENTS $1,110.00 TOTAL $9,401.11 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: VALE E ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF AND NOW, Judgment is entered as above P THONOTARY THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. MARYANN A. FORRY Defendant NO. 99-6484 PRAECIPE FOR ENTRY OF JUDGMENT BY AGREEMENT TO THE PROTHONOTARY: Please enter Judgment by Agreement thi day of ? , 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, MARYANN A. FORRY, for the principal amount of $8,631.36 plus interest at 6.0091 from 09-24-1999, until judgment is entered plus attorney fees of $1,726.00, less payments of $760.00 plus court costs. PARK LAW ASSOCIATES, P.C. BY: V RI ROSENBLUTH PARK, ESQUIRE Attorney,for Plaintiff De ..;.,.?? 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. MARYANN A. FORRY Defendant NO. 99-6484 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 CALL: PARK LAW ASSOCIATES, P.C. 348-5200. CONCERNING THIS NOTICE, PLEASE at this telephone number: (215) PRO HOY: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. u 1 1.:. CI ?' u U N i w M F 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 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK PLAINTIFF VS. MARYANN A. FORRY aka MARYANN A. MCNALLY DEFENDANT NO. 99-6484 PRAECIPE 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: VALERIE ROSENBLUTH PARK, ESQUIRE