HomeMy WebLinkAbout99-06746l ,
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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. 1172094
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
FIRST SELECT CORPORATION
Plaintiff
VS.
ALFRED PEDUZZI
Defendant
NO. CC ?p 2'16' NOTICE
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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(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. ): 720911
PARK LAP] 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
FIRST SELECT CORPORATION
5040 JOHNSON DRIVE
PLEASANTON, CA 94566
PLAINTIFF
VS
ALFRED PEDUZZI
1527 SPRING ROAD
CARLISLE, PA 17013-1561
DEFENDANT NO. .GYfG, Ctc.I Z«-"
CIVIL ACTION
1. FIRST SELECT CORPORATION, an organization domiciled at 5040
JOHNSON DRIVE, PLEASANTON, CA 94566, 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 ALFRED PEDUZZI, an individual who resides at
1527 SPRING ROAD, CARLISLE, PA 17013-1561.
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 4168100002624060.
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
$4,931.32 as of 07/22/1999, plus pre-judgment contractual interest
at the rate of 19.18°% 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 $986.00.
COUNT 1I
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 ineeuitable 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, FIRST SELECT CORPORATION, and against the
Defendant in the amount- of $4,931.32, plus pre-judgment interest
at the contractual rate of 19.183 per annum from 07/22/1999 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $986.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
PARK LAP] ASSOCIATES, P.C.
BY:
VAL <IE ROSENBLUTH PARK, ESQUIRE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED
THAT VIE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
_ --SA ^1. i:L.:r_".a'.:. ^?`? =.??nk]S`!=.A'?.'F?-ci.'AK?
VERIFICATION
I J(L( sl: _ declare.
I am a designated agent of r-1 1'5'f- Sc` c c C?„ i !Zi i o c/ , 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
county, in the state of
1999 at
JI LL PPUU, IAM , Designated Agent
FIRST SELECT CORPORATION
ALFRED PEDUZZI
4168100002624060
929243-1
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'your' r•_n e:eb carton who is liable ter p faMCabl!61 "' a .....::•< \::curt :a •-t crest of r'- :a< ?.rcunt •.vs: apere. l a jam[ account.
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may -ca an to ,,-»:Ct end es :nv jatnLA?a4.^.L•.CICC:. .
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to eallr__ all :r..cuntz ewmg
W,,=V ==act late ere; s:ial mrar:(:, or paymees marked "paid in S:II" ere ma:kd wtth eL4er r?»:e-ors. •yit.eut laing cur,
Wu will char; ycur Av=cur.(a fr_ fer -all billing cm!e -•Ct n _':y cu. aV-U .•(r-??< ct rr?C= `~?"n'e:e? = ?ca?r..eur,( aitSe latetsar;a will be as
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e_cartei:;<::rmeC C`r'<e:u;-. •••ill b<sd'ueloseC in
CisUrsr•1 in ycur Orginal Terns or '.he rn'inum latex-.a: p •••• 7.1
We will ehsn- ycur Account a fe_ far each r.'-rented pa;.r.:nt cie•.'a (a:?-et e: r".4 thar;e}.
vvuf Original Tar=. of (`•< rsaimum mau-me•! the k cha,e p<.--ire.' S° °Se 1=aGe_ie I?+ ( ?^ai- <• :a tour coli ca :a'^ay the eut:•.andir.;.`.-:afca an vcur
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To he ;<:ant pnyideC in your Crigiral -I a .1 and:a -e eaart C.<C by.
tsp. er,. tar..; m•tswn•as i??arporleC iteot to a^tn 4all aaely `r..<ri
et C ct urn t
s aaC <cur 'eas fL` our Crgirl It "pro d:d rear an awu_ JF:ran<s i2's air.
rtaipra<ally to the prevailing parry in ::.y Iaws4i(arsing out of:Sis Cn, C,an:CrL - '
^nyisien ei L`is A;•c=mcn° "i•_ cut Iesin; cur ng:.c :o crsar: n ur a:.y ethe•.
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r..a• <Iv cr wave -• --•• e
, -'•'icive, of C<r_+t Rl ghLL We 1- -
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pravisien latt. ant and ycur.{coat as p,iemed by tordaMl law u re CSy f?anC au; the sue
nt:. nets
{pplienhle Gw: Sevenbiliq:A=ignmene Ye rnarr. wi:-Ca you live. LSis,gea - (f? CC' '(Scwc:n ccu and us and may
GeaigniCC uthe soolir_Sle law in yea: Crgmal T:.s. :u. Orig.n t_s .aL act c:rtatr.-•s:ite;lec i:n: e reu.<s r_ ale,}'
f:a::d-:ea This s »:+l ....:.. uu acdwe will ta:siter
tf Lrv cravisien Ji tis Ag::em<r_ a ...._ ...'.
:\.::unt ar_ ;auem eC'oy feet.! Isw aaC the Co. af ,cur ; c •c
y _dl :•at x afore--•:` k 'c%e may (: rest"ere ere assi;;t our i;ht
iduree o =:
sa L 31 : *tyt :eau s4G.t toed]
rat beu:n[r_dirouI ev of any allCgcCar_! -core Vets •••._.. S=aa•a+
t. :. eu: <aas<: or
to pram
ac ;:mvisian maCikitt to a ria r. to aFolieable law. and the at < pro•:isicrs in to .:
law ?uirs t:: ycu ^ca(ve: e[iee of seer :a
Nall ac same at Your pavr..enIs If state
+ OF Sc:=•
ba'filing a 6'..,66.3 ititr..r..t with the s•'ates Sean! r; ey;ive Cu:_-Q:t record me,v be subnic:C to a 'M it
ing= dr=-: nrssClact
cc mud:tar::»afol! aw
CrtCit Repnr.'.ng. II you f:il :o Pu1B1l to :_s of youc-des
reporting agt.:<y. in crde: (a ci:due cry iriamarcn ••+e r_ ?pcria 3 a:cu:yea: A? :u: L :a 4: at y
C-rer_:int. ?.O. 8os 9l0°• ?leamr.<o Csliler._a. 94 id6.
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Tnisratie contains ;,cr_:(imforrna:;an=Gut ya.. igt:_::cr:-pcrc.z.
.,,n(4., Cs Ln Case of cr:on or Que:::uns ASOU:you: 3U - ;,t;t Selav:
aLr
t e •-. =r : tcare:_ f.:rL a; Ca .as(ow"g --s:
(: r.. x ao I.:CCthan i0 ayz :'Q.ve are; you the fist Sill
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you lhi:'t yoc:Sill is •vrang cr is '!Cu ra:•! mcr.'s3cr..sicr, ficu::n :n»+:n yoc: `.+.1._."rit
act pratr:<ycu::.'rest
Cer_ar_eion. ?.C. Box 9104. ?les-:ca_ C: 3aiae. W:: a:C !'-t to txr. a'. ;es:ml<. ' .
an ".hies t.:-are cf problca appca,, Ycu .:rte^C:d=.cu.doing IQ ill
Ed ?cur len:q ;;ve a the fallowing:
'!our dd;nC rd Account m-%be:. uL .,
rdollar tic. YCU?:(ef Luc f4-'ACC:•-Q -,Mr. .. '-vau e:u; t :he^. is an armf. Ifycu ter! r..cr u-•••••iter_ desrtce t.<u.. cu ar_ not sure: -
• Tile
• Decac<t.<esec nod wry you be(iw eglur tt,
Your ti;hu and Ouc Responsibilities A-er %7- Reeeivt your %Yrren 2ioCee
w<n?: else: acre-a: t.<errar :plain ahy oe
in irdcung fmarct
1 • taiC'n i0
v uniatc; iace-.•__.h<:^.rby ut veu:re sti0
t r-ct;rr rn oiled Cr r:;a,, Cu yas '1;.!C,-, ::.: n (a any r..eur: }•w
W. mu; aek:.awledge ycur le_^ 'it, i0 '?•, s. c.acx =:ncum..nile..e
was Jere= are tn"<sti, sLn¢ S
we r:zr:c ycur .eceq wtr .,.
bell<ct he Sill L L .4e I
Chad;ei W <=,: apP!y Y.v 4npa'd'nCu.-.t agars. ya4r Q:'=:(tc0. '!J4 des no, i.ay<ta aa'r an( did fet Mail-' 6 r'Rt-fit-• Ye4
L IfwC tementei
caltgated t0 pay the par, are the Sill that r_ not in querwa •.. 4 tereC -aun
v :nv $rxc: cha,C : - __ :a c. < a+ill send ycu a s- Lien
veu will ref ave to pn, r_ ever, it cut Ij
Lr we Fad tsar vy<rncCeamistake en your hilL'• eC ?rmera on [.:e 54CSUC-. e,n,L -Cu ss •=eGru;ae. a`v cu: Sill.
.
tray nave to pay "=.ca enarg?. ar••d °au will have to rsaa W Fe r..iss r newt :oar, ycu co that ycu Gccs;icn you.-
the ammunt you owe and the 0` :ate W that tt is a<. if you cad :a ,_y t.< -our( we k= t!ea e_}'. aeu sc :.`::'-:e ma.^.::::es .C-^ _.. sent.
Cca oat sa:is. r ycu and vau writes to us within l0 C:vt t<.lingLhat ye4 RiII NC m`:l - )- 4 "<d bCVSCn lLL when It finally is
a1.d we r..ust tell ycu t.e r.-r••e o <a Y at _ilr aha the Si0 of th<,.a !un<d -mounter i; `04r :iii "vas te r.::
If aye So not Callow these -lest `•
;ace faith to r _rr_e:
jpe<ial Rule for Credit Card ?u rehasa _Mir Cate! ar;C vau Save tralin u nut
Ut66"
Cunt due an the 'Ced: Jf SC::e t.:<r::r: Ia+O lhna(b) tth:e puc. L tI<daaan(A.
'LIU If you h?v< a ei;cad... s o i he t:.ar.ou pur.._<d .•ith tee r•__-t 9A_V'`
creblem '.vith t.e S=lity prlCe mutt
the problem a,i[h the exr4h111 vau nrr nut have ro pay he remamng :m -
hanlbl tl th neNndcur hand u:[eur. ifnat a.iinin•au:.ame sa te. ",;thin 100 "d as Jt }au::urn :rt.mdin;:CCrl; and -
ur Ft apT 9A?h Jaarurr..:c :.:: .-.tart. nr I k eur pL'aT m=
naa'<Sra mu. than SiO. Trte4ilmia[iuns Ca rat apply it eidtc:•+e
calvaru<mcnt cur the praptny are wrv'Nad.
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PARK LAW ASSOCIATES
A PROFESSIONAL CORPORATION
25 EAST STATE STREET, SUITE 101
15,0)61 4
P.O. BOX 1779
VALERIE ROSENBLUM PARK-
ROBERT E. ANGST'
-AM SMIMR 11 HAR
.ALTO MGNRER M OAR
DOYLESTOWN. PENNSYLVANIA 18901
TELEPHONE (215)348-5200
FACSIMILE (215)348-4015
August 19, 1999
ALFRED PEDUZZI
1527 SPRING ROAD
CARLISLE, PA 17013-1561
Our File Number: 929243
RE: FIRST SELECT CORPORATION
Account # 4168100002 624060
Balance Due as of August 19, 1999. $5,989.88
Dear ALFRED PEDUZZT--
This law office represents FIRST SELECT CORPORATION who has
requested that we make demand for payment of the account referenced
above. Your account is in default and has been closed to prevent
further use. Formal demand is hereby made upon you for payment of the
delinquent unpaid amount referenced above.
Federal law requires that you have thirty (30) days after you
receive this letter to dispute the validity of the debt, or any part
of it. If you do not dispute the validity of the debt, or any part of
it, within that period of time, it will be assumed that the debt is
valid.
If you dispute the
effect, on or before the
this letter, you will be
Also, if you request the
it may be different from
with that information.
debt by mailing a written notice to that
30th day following the date that you receive
sent evidence (verification) of the debt.
name and address of the original creditor (as
the current creditor) you will be provided
929243, C69
Page 2
Additionally, when you send written notice requesting validation
of the debt, all efforts to collect this debt will be suspended until
verification of the debt has been sent to you. You have the right to
mail written notice of a dispute of the debt until the end of the 30`h
day following the date you receive this letter. Our client will wait
until sufficient time has elapsed for us to be able to receive written
notice form you - even if you mail it on the 30th day following this
letter, before authorizing our Office to file a legal action against
you to collect this debt.
If you want to resolve this matter without a lawsuit, you must
take one of the following actions: You must either pay the balance in
full or contact our client at (800) 280-0559 to work out a payment
arrangement that is acceptable to them. Notwithstandi g
n partial in
payments made directly to our clidnt, your enire
full. Acceptance of partial payments made directly to our client in
no way nullifies their contractual right to demand the entire balance
once the account is in default, as it is currently.
Our client considers this -tobe a serious lmatter. A awsuit is feted, it
proceeding is a matter of publ '- record.
result with the court in your local jurisdiction entering a
judgment against you for the entire balance of your account plus
attorneys' fees, interest, and court costs if provided in your account
agreement and to the extent permitted by law.
If a judgment is entered against
your
credit record and may affect
employment.
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
very truly yours,
PARK LAW AS?SOCI?ATES,/P.C•
BY: a
C69 ROBERT E. ANGST, ESQUIRE
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06746 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST SELECT CORPORATION
VS.
PEDUZZI ALFRED
JODY SMITH , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within CIVIL ACTION was served
upon PEDUZZI ALFRED the
defendant, at 9:31 HOURS, on the 12th day of November
1999 at CUMBERLAND COUNTY SHERIFFS OFC 1 COURTHOUSE SQUARE
CARLISLE, PA 17013-1561 CUMBERLAND
County, Pennsylvania, by handing to ALFRED PEDUZZI
a true and attested copy of the CIVIL ACTION
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 3.10
Affidavit 00
8.00 P-i?ne
Surcharge as-f iT ne,i S eri
0 PARK LAW ASSOCIATES
11/12/1999
by O ?
?qq -(t/
/n e eLiL
Sworn and subscribed to before me
this 13=? day of 19 A. D.
V
`ro 1?ono?a+ry
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
FIRST SELECT CORPORATION
Plaintiff
VS.
ALFRED PEDUZZI
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Defendant NO. 99-6746 Civil
CERTIFICATE OF SERVICE
Valerie Rosenbluth Park, Esquire certifies that she is the
attorney for the above named Plaintiff in the instant action and
that on June 12, 2000, she served a true and correct copy of
Plaintiff's Request for Admissions, Interrogatory and Request- for
Production of Documents, by mailing the same by U. S. Mail,
postage paid, to the person and at the address set forth below:
Alfred Peduzzi, Defendant Pro Se
1527 Spring Road
Carlisle, PA 17013-1561
PARK LAW ASSOCIATES,
BY:
VALERIE ROSENBLUTH PARK, ESQ.
ATTORNEY FOR PLAINTIFF
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Sworn and Subscribed To Before Me
Tttis_ Day of ( .
2'000. A. D.
Notary Public
NOTARIAL SEAL
PATRICIA A. SHATTO. Notary Public
Catlisla Suro. Cumberland County
My Connoi;soon Expires December 11. 2001
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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. It 72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
FIRST SELECT CORPORATION
Plaintiff
VS.
CERTIFICATE OF SERVICE
ALFRED PEDUZZI
Defendant
Valerie Rosenbluth Park, Esquire certifies tha
the attorney for the above named Plaintiff in the
action and that on August 14, 2000, she served a
correct copy of the Plaintiff's Motion for Summary
and Memorandum of Law to Defendant by mailing the
U.S. mail, postage paid, to the person and at the
set forth below:
NO. 99-6746 Civil
t she is
instant
true and
Judgment
same by
address
Alfred Peduzzi, Defendant Pro Se
1527 Spring Road
Carlisle, PA 17013-1561
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
PARK LAW ASSOCIATES, P.C.
BY:
VALERIE ROSENBLUTH PARK
ATTORNEY FOR PLAINTIFF
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
1
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
-----------------------------------------------------------------------------------•
CAPTION OF CASE
(entire caption must be stated in full)
I
{ FIRST SELECT CORPORTION
i
( Plaintiff )
{ vs.
ALFRED PEDUZZI _
(Defendant)
No. 6746 Civil 19 99
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurer to crnplaint, etc. ) :
NOTION FOR SUPAIARY JUDGMENT FILED 8116100
2. Identify counsel who a
(a) for plaintiff:
Address:
(b) for defendant:
Address:
ill argue case:
VALERIE ROSENBLUTH PARK
25 E. State St., P.O. Box 2284
Doylestown, PA 18901
Alfred Peduzzi, Pro Se
1527 Spring Road
Carlisle, PA 17013-1561
3. I will notify all parties in writing within two days that this case has
been listed for argument-
4. Argument Court Date:
i
J
;i Dated: Attorney for
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in f1111)
FIRST SELECT CORPORTION
Vs.
ALFRED PEDUZZI
( Plaintiff )
(Defendant)
No. 6746 Civil
19 99
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurrer to canplaint, etc.):
MOTION FOR SUMMARY JUDGMENT FILED 8/16/00
2. Identify counsel who will argue case:
(a) for plaintiff: VALERIE ROSENBLUTH PARK
Ness: 25 E. State St., P.O. Box 2284
Doylestown, PA 18901
(b) for defendant: Alfred Peduzzi, Pro Se
Address: 1527 Spring Road
Carlisle, PA 17013-1561
3. I will notify all parties in writing within two days that this case bas
been listed for argunent.
4. Argunent Court Date:
Dated:
Attorney for
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
FIRST SELECT CORPORATION CUMBERLAND COUNTY
; COURT OF COMMON PLEAS
Plaintiff
VS.
ALFRED PEDUZZI
Defendant NO. 99-6746 Civil
O R D E R
II 2000, upon
iI AND NOVI, to wit, this day of
consideration of the motion for Summary Judgment, Memorandum of
If
Law, and the Motion of Valerie Rosenbluth Park, Esquire, Judgment
it is hereby entered on behalf of the Plaintiff, First Select
ii
Corporation, and against the Defendant, Alfred Peduzzi, in the
?j amount of $4,931.32, plus interest at the contract rate of 19.18%
I from July 22, 1999, plus attorney's fees of $986.00 and costs of
ii
this action.
j,.
BY THE COURT:
J.
?t
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
FIRST SELECT CORPORATION : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
VS.
ALFRED PEDUZZI
Defendant NO. 99-6746 Civil
MOTION FOR SUMMARY JUDGMENT
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
The Plaintiff by its attorneys, Park Law Associates, P.C.,
moves the Court to enter an Order for Summary Judgment and states
the following reasons therefore:
1. The complaint in the above captioned matter was filed on
November 8, 1999 and service was made upon the Defendant on
November 12, 1999.
2. On or about June 12, 2000, the Plaintiff, by its
attorney, served upon the Defendant, an original Request for
Admissions addressed to the Defendant, and original
Interrogatories addressed to the Defendant. A Certificate of
Service was filed with the Prothonotary reflecting service upon
the Defendant. A true and correct copy of said Request for
Admissions and Interrogatories are attached hereto, made a part
hereof, and marked Exhibit "A". A true and correct copy of said
Certificate of Service is attached hereto, made a part hereof, and
marked Exhibit "B".
3. As of this date, the Defendant has failed to file its
Answer to the Request for Admissions and Interrogatories within
thirty (30) days after service as mandated by Pennsylvania Rule of
Civil Procedure No. 4014.
4. In accordance with Pennsylvania Rule of Civil Procedure
No. 4014, as a result of Defendant's failure to respond and answer
the Request for Admissions, all of the Request for Admissions are
deemed admitted.
5. There are not genuine issues as to any material fact and
the Plaintiff is entitled to Judgment as a matter of law.
6. The Defendant, by its failure to answer the Request for
Admissions, admitted its obligation to the Plaintiff and admitted
there are no facts upon which it relied as a basis for any defense
in this action.
WHEREFORE, Plaintiff prays that the Court enter Summary Judgment
in its favor and against the Defendant in the amount of $4,931.32,
plus interest at the contract rate of 19.18°% from July 22, 1999,
plus attorney's fees of $986.00 and costs of this action.
PARK LAW A SOCIATES, P.C.
BY:
V RIE ROSENBLUM PARK, ESQUIRE
ATTORNEY FOR PLAINTIFF
V_,.T-:RZE ROSEN3LUTH ?A-RK, ESQUIRE
Attorney Z.D. =72091
ppRn I,AW `SSOCIATES, ?•C•
25 E. State Street
Doylestowr; PA 18901
(215) 318-5200
ATTORNEY FOR PLAIDT-Z
CUMBER-- _7 COLiTTY
FIRST SELECT COR?OR TION COURT OF COMMON PLEAS
Plaintiff
iL
L°
VS.
ALFRED PEDUZZI
Defendant NO. 99-5715 Civil
000e4?Pa W Z DIG
PL-ZN^IcF' S REQUEST- FOR PDMZSSIOPIS AND
INTERROGATORY TO DEFEND;INT
TO: Alfred Peduzzl
1527 Spring Road
Carlisle, PA -.7011--l-561
7
Pursuant CO ?ennSylvania Rllle Of C1'Jll rOC_dllre NO. L01G,
Select CorpOrat'-OR Cergjy
the undersigned attorneys for F=rst .
request -Rat Al Fred Peduzzi ma.:e the -fol O'aing dd ^.155_OnS C 1R
th_rty (30) days after S-r"r-C2, or t.. ?L:r- to e- S action
0[ll?/ is subject t0 all perC_ne.^.t OC] of t'-ORS as t0 re leyd'1CV
Set Fort-
o
_aC', OL the Matte-
zd^,;'t to the trutR OL _.
Request .Or Admiss'_On ir:Cluded here-R; rm'a to t-2e-a-zornev/ for the
C, n?
sign the same, swear CO it, and del 'J?'` ~ - of
(30) days att_r the cote of
Plaint l : -_ ',---rein wichi_n chin:Y
sere Ce .
YOU ARE INSTRUCTED:
1. These Reauests for Admissions and accompanying
Interrogatory are directed to the Defendant, its/his/her officers,
emoloyees, agents, servants, assigns, reor_sentatives, past and
present, and unless pr='i_lege is claimed, each and every attorney,
past and oresent, of each and everv such individual or emit!!. As
used herein, "Defendant," "you" and "your" means the Defendant to
which C.nese Reauests for Admissions and accompanying interrogatory
are addressed, its/his/her officers, employe=_s, agents, servants,
assigns, reoresenratlves, past and present, and unless privilege
is claimed, each and every attorney, past and present, of each and
every such individual or entity.
2. These Requests for Admissions and accompanying
Interrogatory encompass all infor..mation, doc--=.entss and records
that are in the possession, control, or custc G'? of Defendant or
any of its officers, employees, agents, se_?a__n.ts, attorneys and
assigns.
3. If any objections are made to =/ aeauest for Admissions
or to the accemoanli Interrcgatory, the reasons therefore shall be
stated.
4. If there is arv claim or privilege relating to e.nv
recruest to admit, or T_nterrogatorv, you Shall set forth fully the
basis for the claim of pr_vilege, including th2 facts upcr Which
you reiv to Suooort the claim of pr_'izlege in suff'_c'_e:^.t detail t0
permit the Court to rule on the propriety of the privilege.
5. L vour response to any reclueSt 1f not ap unqual:flcd
admission, your ans'.cer shall SJec'_f'_cally derv the matter or set
forth in detail the reasons :•i*- !iou cannot CrL'thf Lilly ad-lit or
deny the ^dt:__ .
5. denial Shall fairly meet the supstance of t^°
r?auested admission, and L..c.. good _a__.. rcG• __eS C:at V0,; C13'_1_J
vour answer or deny on!,,, a part of the r,.atter .f an
admission is requested, you should specify so much of it as is
true and qualify or deny the remainder.
7. You may not
reason for failure to
have made reasonable
or readily obtainable
admit or deny.
give lack of information or knowledge as a
admit or deny, unless you state that you
!nauiry and that the information known to you
by you is insufficient to enable you to
8. These Request for Admission and Interrogatory are
continuous in nature ar_d must be supplemented promptly if
Defendant obtains or learns further or different information
between the date of t.^.e response and the time of trial by which
Defendant knows that previous response was incorrect when made, or
though correct when made, is no longer true.
9. Unless otherwise indicated, the time period to which
these Requests for Admission and Interrogatory are directed is
from the date of the account opening through the present.
10. This Request seeks the admission of the genuineness of
various documents. In some cases, there are printed number and
letter codes that run along the bottom of particular documents.
In other cases, the word "evidence" and other identification marks
may be affixed to the document. Such numbers, letters and
identifying words were affixed to the document. Such numbers,
letters and identifying words were affixed during the accumulation
and copying of the documents for this case and are not to be
considered part of the document itself, except for purposes of
referencing the document.
The Request does not seek Defendant's admission regarding the
accuracy and genuineness of those numbers and letters, but only
the document on which t'aose numbers and letters have been placed.
11. If you are held or are sued more than one capacity,
or if your answer would be different if answered in anv different
caoaclty such as a partner, an agent, corporate officer/dlrector,
or the like, then you are required to answer separately in each
such capacity.
Further that pursuant to Pennsylvania Pule of Civil Procedure
No. 419, if at Trial or during hearing, a party who has requested
Admissions as authorized proves the matter which the other party
has failed to admit as requested, the Court or. Motion, may enter
an Order passing as costs against the other priority, the
reasonable expenses incurred in making such a proof, including
attorney's fees.
DEFINITIONS:
1. All verbs are intended to include all tenses.
2. References to the singular are intended to include the
plural and vice-versa.
3. "Anv" as well as ,all,, shall be construed to mean "each
and every."
4 "And" as well as "or" shall be construed disjunctivel-v
as well as conjunctively, as necessary, in order to bring within
the scope of these requests all information that might otherwise
be construed to be outside their scope.
5. "Refer to" Or "relate to" means constituting, defining
describing, discussing, involving, concerning, containing,
embodying, reflecting identifying, stating, analyzing, mentioning,
responding to, referring to, dealing 'wlth, commenting upon, or in
any way pertaining to.
REQUEST FOR ADMISSIONS
1. DO you admit that account number 4423-3743-0007-0514 4las
asslgnea to First Select i.^. accordance with t^e O=-.Cer's
Certificate and Assignment a_-_ached hereto, made a Dart he`so:,
and marked Exhibit "P-1"? -
2. Do you admit that after the account was assigned you
received the First Select Coroorat'_on Account Agreement, a true
and correct copy of which is attached hereto, made a part hereof,
and marked Exhibit "P-2"?
3. Do you admit that you have a current balance owed on the
account in the amount of $6,809.10, which includes interest,
attorney's fees, and court costs as of June 11, 2000?
4. Do you admit that there are no offsets or credits which
are due to you from the Plaintiff since November 8, 1999?
S. Do you admit that you agreed to pay the collection cost
the Plaintiff is incurring or will incur including, but not
limited to, reasonable attornev's fees and court: costs as more
particularly set forth in the First Select Corporation Account
Agreement (Exhibit, 110-2" attached hereto)?
6. Do you admit that $986.00 is equal to 20° or less of the
outstanding balance and is a reasonable attorney's fee to
effectual collection of the past due balance?
7. Do you admit that there are no facts on .-ihici !iou rely
as a basis for anv defense in this action?
8. Do you admit that there are no documents, writings,
papers, or letters which you intend to utilize as evidence of or
as a basis for any defense in t:-is action?
9. Do you admit that you have not paid Plaintiff any
payments since Movember 1999?
lo. Do you admit that you agreed to pay a finance charge to
Plaintiff pursuant to the First Select Corporation Account
Agreement (Exl-iibit "P-2" attached he~eto)?
11. Do you admit that attached hereto, made a part hereof,
and marked collectively Exhibit "P-3" are true and correct copies
of the records of the Plaintiff showing cash advance, charges and
credits incurred through your use of the First Select Account
issued to you?
12. Do you admit that each of the documents attached as
Exhibits to these Requests for Admission and as attached to the
Complaint is a true and correct copy of the original documents and
is admitted as being genuine and authentic?
13. Do you admit that to each document identified above as
an Exhibit is a business record of the Plaintiff for the Du =ose
of its admission into evidence at the Trial o-- this action?
DARK -1- A ! 3SS0CTATI S , r . CC
3Y: v?LER ROSENEN-SLLUT:_ PP4ti, ESQ.
Attorney for ?1ai'ttir=
I understand that false statements made herein are subject to the
penalties of IS Pa.C.S., §4904, relating to unsworn falsification
to authorities.
Alfred Peduzzi, Defendant
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.
OFFICER'S CERTIFICATE
FIRST SELECT ACCOUNT NUNEBER:
4163-1000-0262-4060
ACCOUNTHOLDER NAbEE:
ALFRED PEDUZZI
In my capacity as Operations Officer of First Select, I hereby certify the following:
1. In accordance with the Purchase Agreement dated December 31, 1993, between Fleet, Y.A. ("Seller") and
First Select ("Buyer") (the "Agreement"), Seller did convey all of its right, title, and interest in a portfolio of
credit accounts (the `-Accounts").
2. Attached hereto is a true and correct copy of Exhibit I of the Agreement, vhich is the document evidencing the
actual assignment of the accounts from Seller to Buyer.
3. The following account was among the Accounts assigned pursuant to Eal:ibit 1 of the Agreement:
Fleet Account Number: -1418-S723-000`7-6514
Customer Name: ALFRED PFDUZZl
(the "ALFRED PEDUZZI Account")
4. The outstanding balance of the ALFRED PEDUZZI Account was accurately transferred from the Seller to the
Buyer. The balance as of the most recent First Select billing statement (dated August 20, 1999) was 35003.74.
5. Pursuant to the Buyer's Account Agreement goveming the ALFRED PEDUZZI Account, the Annual
Percentage Rate (APR) aoolicable to the ALFRED PEDUZZI Account is the lowest.-APR that was applicable to
any portion of the balance under the terms of the applicable account ag-eemenr of Seller at the time of the
Agreement (the "Referenced APR"). The Referenced APR applicable to the ALFRED PEDUZZI Account is
19.13%.
By:
Jamie L.1`iol%tnd
Tide: Operations Officer
EXHIBIT
^"t' 1
for -;_i L'° __CLVCC _.C _.'= C _-
L_
CG- - _ ?_-v_ Cn::_??? _:C C.:_t..? ASS:=i
CC i_•= ? 3
-:S C: i._ _ _.? cJ •__ .. a :-...._:i?._ _5..__v __ _ ? ._.:'i_
A -'A CG1Y:is i7 ==Q7 _I, Cs:. CC u:_CC !7:vCOf
'Sf
1 :..' ... _=r no _ ,•. i D °z° :r`:S•CCL :C `d =C'OL=S. 2'`-'-C
-z TS -MTHOI??, RECOURSE !? OR
,_!!0N ?__ S OR C.'r_7i as 5- v?',:G_..: ___-_
Z
SCT 1..:? =G-°C, __^__---=:_S°: ii7 "uC 3 ODD. •ii "C i 'ri -r C__i ?:S'
255=?_:a: Cs =00o=:s -m =_ _ _' = '.ALL C1 _L 'C?"-'C
• / r
EXHIBIT
u
A000UNIT AGREEMENT
Yaur FLEET BANK mcaunt •was closed at the time of this uarsfa, and swill
your FLEET BA.vK account[ has been trarsfered to First Select Cc ,her,.cnuon aercunt(Lh<'Acccunt"), Inthispseem ent' ur
theefo continuetobeclue terns that govem your Firs Selc a jse y
vour' mean each person •cscd. is This liable for paAccount Agreement ymenteemtheat e corsai rs Acanont aur;' our,: and "tai' mean : ir^. Select Ceruntian orts sssi3rc ,. 3eauae your
"hQ on
Account has been tnrafered to us, you are now obligated to rmay the Accourt to us instead of FLEET BANK. If the Account was opened as alomt amount. we
May act on the instructions of any joint accounthalde:.
Payments ! Finance Charges. As long as you have a balance outs oinding on vour Account. fmonce charges are calculated as follows:
To figure the finance chugs for each billing rycle, we multiply the avenge daily balance on your Account by a 'oily periodic rte. The oily perFLEET B n
,at ?,,e Ra will be cMal;j as;
Arm
ferdu)2rrnt utual °eremuge Ratestto he appl eel w di znntt con•F nrnu of you
rate we eremu ancly is i oe , Am u0's Ann Tenses'). I tle Raja divided Terns 3. The l
outstanding balance, we will apply tie lowest vch Annual Peccenuge Rate to your entire outstanding Warer.
.t late or partial paymrnu, or payments marked "paid in full' or marked with other restriR!Ona. withcut losing our right to coil.: all amounts owing
we may seem
under this Agermenl
charge your dis unt ofthe late charge will b< as
,r each
c a liner Original Temtt arrthe a fb- um late nchvg?clc z pernnimd by the law 0t yourrstate ofresid mcecwhich,ver is lo?er
We will charge your .count a.•timum ea teed ne Payr-ge permittedby the law of5 urzsute of adrrc-C=. lower,eharg<wili be as disclosed in
04=1 T d. or the r
the
vour
Ter
n(l To
your the Amount. Plu pNeen and fees as; di scl eelms' an "'e than (Ltcl p . rtt her NVt a le Is-, in add WC it :U is our . including but notli sited to reasonable anorn!W our
er:rs providcd for an award of m fees and court 11,715, such provision ss mcorpuratedh
fees and court costs. U;'our original T erein stall apply
prevailing party in any lawsuit arcing out of this Agreement.
\on it or any other
reciprocally to the pre
•Walver ac,main Righu. we may delay orwalveenfom""m of any provision of this Apes'ment`°n=outluing our right to enfercz
provision later.
adm?na your
AApplicable Law., Scyenbitity: Assignment. No matte. where you live. this Ag mment and your Account u: governed by iedml law and by the law ol'the state
designated ss th<applicsble law in you.Original Terms. If your Original terns did not contain m applicable law provision, thrn :his Agdss a consider
law onirageemrntoItany Pro vision ofth hiis Ageumnt imA is clI rill be eomvaorceable.we eablam on you
Amount nntndiv,m,dbvifcdr Il2w oliogod
andrm(s e us o may and that pr somzofo tar p a?menr.. nlfsutclatw begurtesthe you receivte yea c of s ch in Lid Aeement an eve is to protectit a purchaser orassignce, we ma ayr give au;uch not c?h[
by tiling a financing statement with the state's Sccctary of State.
Credit Repnrtin:!. If you fail to fulfill the terms of,. our credit obligation a negative credit report refec:L•tg on year tt:di[ record ten' be suhmir..d to a credit
: First Select
ropuning agency. In order to dispute any tntormation s,e are reporting about your Ac-aunt, YOU must -.stun :o us at die foilaw'ing address
Carponuon. P.O. Box 91015. Pleasanton. Califomia 94566.
YOUR BILLING RIGHTS • KEEP THIS NOTICE FOR FUTURE USE
This notice ... loins important information about your right and our:cspcrsibiiities order the Fair Credit Billing Act
irs
,fo!fv Us In Case of Errors or Questions About Your Bill if you think your bill is wrong or ify'ou need mom. infuratation about mentryo,vour bile, writs eUS. a on aze YOU m) skirt at :hefollowing address: First Select
an s?sheh the erar orprob em alposu O CA can 66. '-V rt us. cut doing so .111 net preserve your rims. YOU u no Ina than 60 days ad:rive ttn[ you the first bill
In your letter, give us the following:
• Your name and Amount number.
• The dollar amount ofthe snspec%d error.
Th
• De.dbe the error and explain if you zu,' by you beliz'rc the! is vn enter. Lf you need more informatior_ describe the Item you are rat sure about.
Your R!Ghis and Our Responsibilities After We Receive Your Wriaen Notice
•w?e
We in= acknowledge your letter within SO tan. unless we harret 'o aRc' or rr,.onthcn. . you s , Ilrque^: ss to anyaneunt you gcesuen, including finance
believe to bill war.oreet. Adersvcreceiveyourloner,
charges. tYe can apply any unpaid amount against ,vour.O.edit lire. :'ou do not have to par! any quest t a red amount ahi4 we u. imestigatmg, but you are rill
istakt. y?
obligated :o pav the puts of the bill that are not in quest!cn.
I.Xm- charge related to art" U If svt first tF.at w'e matt a mutakeao J' On will h] t`to I a'Ke up the .^. iS 1r1 pa4mtnu on the quc c ,d 4 urL en ei t her aqu-rte 4o?e• er,y?ur .+pi raticn u
may have to pay finarm charges.. e 11
the amour.[ youacre and the Lae:hen it is due. ffyou:ill to pry the Con:.. s<L.L :; cu o`er
ithin l0 •da}s :elliry s'.hx you still :;: :u pa%. "c rust tell u:ycre sve r-rots ycu to that }'au guestian }'our bi .
we neat uii an':are we croon you :o that ..e racer has been scr.led be.wen us svten it finally is.
the es narnhrv you u:d the mite :a art ..w u
do -cu
.S we must tell you the name tai myore.vz : .ported you m. even iiYaur bill was contest
.•V
![\ve do netfbllov ;hose roles. •.vc cannot col!c: the fib[ S50 of a gunr;cned u.:ours
Special Rule fur Credit Card Purchmes -
\.' OY You
H' you have ]problem with the quality of goads and nut^ces that vets purchased ••vith g.ur FLEET BA.' i a_-it cud ]r.J you have ni, in go,,! faith to cent ems.
cu p amount due cn the cut se^: i.a. Taae are two litniutiau:o this right: ] must
and b the price musr
pow the t as r.errm
the problem with the mcnhant you my nut ha%ve and
have 'rLEET BaN?mailed you the
have made the purchase in war home state o mat within your tcme nut:. s•iL.in L:0 mils ul your teiliag a%ds. O purchase
beenmeretun550. Therem st to d .q1 not apply ifeitherwe or FLEET BANKovn arupcruc Lie Merchant or ifsve or
advertisement for the proper:'/ or sm'ices.
),jay 17, 1999
ALFRED pEDUZZI
1527 SFRiHG RD
CARLISLE FA 170'_3-2.5,31
L,dILnIllnnnllol?,ml?J,?,i??n,,,??„LIL,ddl,il
;V,,v First Select Account Number:
4163.1000-0363-4060
Old FLEET BA,V1: Account Number:
4433-3,-43-0007-6514
Current Balance: S4,71-15.17
Dear ALFRED PEDUZZI:
Your FLEET BANK account has been transferred to First Select Corporation, so you will begin receiving monthly statements
from us. Your First Select account number appears above and your new Account Agreement is enclosed.
closed For non-payment and the severity of your delinquency places your
Unfortunately, your FLEET BADIK account was
account in default.
However, we assume that all of our customers are honest people and want to repay their debts. In fact, we bend over
backward to make acceptable payment arrangements to prevent the cost and embarrassment of a lawsuit, which becomes a
matter of public record. If you call us, we promise you the following:
• You will be treated with dignity. respect. and trust
• If you make a payment arrangement and sticky with it:
- We can lower your interest rate to get you out of debt faster.
- We can be an excellent credit reference for you.
- We can help you regain access to credit.
istance Department at 1-333-924= 000. %1/-- want you as a long term customer and would be
please call our Customer Ass
So
honored to serve you. We recognize that customers can have temporary financial difficulties, and we will consider payment
arrangements for as low as S25 per month.
The following is a required legal disclosure re,artlin, your rihts:
Federal law gives you 30 days after you receive this letter to dispute the calidir: of the debt or any, pan of it. If you do not
dispute the validity of the debt, or any part of it, within that period, we will assume that the debt is valid. If you dispute the
debt, or any part of it, in writing - by mailing us a notice to that affect on or befog the 30th day following the date you
receive this letter - we will obtain and mail to you proof (verification) of the debt. And if, within the same period. you
request in writing the name and address of the original creditor (if dif rent Fpm the current creditor), we will furnish you
with that information too. All efforts to collect this debt will be suspended until we mail any required information to you.
ou
Your right to mail us a written notice of dispute lasts until the end of the 30th day fallowing the day you receive this letter. discute We will wait until sufficient time has elasped for us to be able to receive a written notice count to afro myou' ieven r ystate
to atn mail it on the 30th dap following the date you receive this letter - before reizrrir., ,
file suit against you should it be necessary.
If you would like to make a payment, which we encourage, you may use the postage-paid envelope enclosed. We
appreciate your business. we want you as a long-term customer, and we will do everything we can to help you.
Very truly yours.
/ )iIGL cJyilGr.
Brian Smith
President
FD"rF' PURPOSE OFTtIIS COJINIU [CATION IS TO COLLECTA
BT; AN Y' IN FOR3L-kTIO2 OBTAINED WILL BE USED FOR
THE PURPOSE OF COLLECTING TILE DEBT.
ACCOUNT NUMBER
4163-1000-0262-40611
P.%YAIENr DUE D,%rF. AIIN IS1USl 1'.aV'MF.NT AMOUNT ENCLOSED
JUN la, I')99 SP79.U0 ??
?lake Check: Payable To
FIm Select Corporation
ALFRED PEDUZZI
WANDA J PEDUZZI
1527 SPRING RD
CARLISLE PA 17013-1561
Pa; I of I
000000
4 1681001102624 06 0001900004 75514 0
S4)755.14
------------------------------------------------------
NfESSAGES FR01[ FIRST SELECT ---7
WE SPECIALIZE IN HELPING OUR CUSTOMERS GET OUT OF DEBT
QUICKLY AND BUILD NEW CREDIT RECORDS.
Send in your payment today or call us...we can help!
Past Date Description
05.17 CASH ADVANCE FROM.
Transaction Date
ACCOUNT SUNINIARY
--
CUSTOMER SERVICE PHONE NUMBER PAYMENT
----------
Previous Balance
- Credits
S.00
00 INFOR
NEVV B,%LVNCE
1-333-964-4000
- Payments .
,00 Available Credit
Debits 4,745 .17 Account Numhcr 4153 1000 0262 11160 Minimum Payment
+ FI.VA,VCE Cttd R G£ 9.97 Payment Due Date
+ Late Charge .00
Returned Check Charge ,00 Average , N-V-U.4L Dail
NEW BALANCE S4,75J.14 y
Account Balance Daily PERCE.VTd GE Periodic
1521
Balance RATE Rate
Balance 52.103.39 19.18% .0525%
Iryou are able
to pay your
balance IN FULL
now, the
amount due is:
Amount
S4.7 55.14
50.00
SI90.00
Of,/ 141"
at<menl Dale
C 3; _Or99
9 nays in
Billing Cycle
\V< lR mry,ml In 014Ime tl.ll hrnrv ,11.. In ;..v:
OBTAINED IWILL BE USED FOR THE PL1tPODSE OF COL EMNG THE DEBT.
We will match your first payment on this account!
Call us for details.
EXHIBIT
L
3 /'V
1 /
_
IN ??
n
AOCOUNI'NUMBER
4163-1000-0162-3061)
ALFRED PEDUZZI
WANDA J PEDUZZI
1527 SPRING RD
CARLISLE PA 17013-1561
Page I of 1
000003
4168100002624060001930004855100
,01OUNT ENCLOSED
FS
}lake Check: Payable To
First Select Corporidon
If you are able
to pay your
balance IN FULL
now, the
amount due is:
S42835.10
MESSAGES FROM FIRST SELECT
WE SPECIALIZE IN HELPING OUR CUSTOMERS GET OUT OF DEBT
QUICKLY AND BUILD NEW CREDIT RECORDS.
Send in your payment today or call us-we can help!
CUSTOMER SERVICE PHONE NUMBER PAYMENTINFOR:MATION
ACCOUNT SUMMARY NEW BALANCE 54,955.10
Previous Balance 54,755.14 1-333-964-4000
- Credits .00 Available Credit 50.00
- Payments .00 Account Number x169 t000 026'_ 4060 Minimum Payment 5193.00
+ Debits .00 Payment Due Date 07116199
+FINANCE CHARGE 7296
Late Charge
+ Returned Check Charge
NEW BALANCE S 20.00
.00
4,355.10 Average ANSUAL Daily
Aceonot Balance Daily PERCENTAGE Periodic
Balance RATE Rate
Balance 54,755.09 19.13"9 .05]5% Sulemem Datc
C6/? 1199
32 nay: In
9illing C; cl<
UUUAMAJU 1331 1X1
We m Riryir.J to wldtl a thit Inlm.llan In ;au:
THIS IS AN ATTF`IP1'TO COLLECT A DEBT. ANY CtiFORNIATION
OBTAL\ED WILL BE USED FOR THE PLRPOSE OF COLLECTLNG THE DEBT.
P,IYMIEYr DUE 0.%TE MLNIMUM P.NMMENT
JUL 16, I _ 9193.00
We will match your first payment On this account!
Call us for details.
9c?
,%000UNT NUMBER PAYMENT DUE DATE NII,NIAIL:M P.t Yb1ENT I
,tvIOUNT ENCLOSED
4163-I OD04)262-71)00 .1UG 15, 1799 St9'; AO I
? .
Mike Checks Poy161e To
Fin Seim Corpanllon
ALFRED PEDUZZI
WANDA J PEDUZZI Iryou are able
1527 SPRING RD to pay your
CARLISLE PA 17013-1561 balance IN FULL
now, the
Page I of I amount due is:
ammo
S4,931.32
4168100002624060001970004931320
----------------------------
----
I?fESSAGES FROI?f FIRST SELECT
-------------
WE SPECLUIZE IN HELPING OUR CUSTOMERS GET OUT OF DEBT
QUICKLY AND BUILD NEW CREDIT RECORDS
.
Send in your payment today or call us...we can help!
7ACCOUNT SUMMARY CUSTOMER SERVICE PHONE NUMBER PAYMENT INFORMATION
s Balance 54,355.10 EW BALANCE
ts
1-833-964-4000
0 $1,931-2
.
U
- Payments .00 Available Credit
+ Debits 00 Account Number 4168 1000 0:63 4060 Minimum Payment 50.00
+ FINANCE CHARGE 76.13 Payment Due Date
+ Late Charge S197.00
ott ]gjg9
.00
+ Returned Check Charge Average Ah}YLaL Daily
A.c.u
=1YEW BALANCE 54,931.32
.t Balance Daily CEA
4GE P
i
Staemem Date
F
.
er
odc
Balance RATE Rate 07121j99
c
54,935.03 17.18% .0525%
000000000 I52t 1521 Billing Cycle 30 Days In
we e2,vlui, In Jlf;la< Ihit Inbrmannn la ;nu:
OBTA riEDI WILL E SED FOR HE PURPOSE OF COLLECOL °G THE DEBT
1Ye will match your first payment on this account!
Call us for details.
,
ACCOUNT NUMBER
4163-1000-0262-4060
ALFRED PEDUZZI
NANDA J PEDUZZI
1527 SPRING RD
CARLISLE PA 17013-1561
PAY:1IEN7 DUE. DATE MINIMUM P.MNIENT
SEP 14, 1999 SAU08.74
AMOUNT ENCLOSED
Make Checks Payable To
First Select Curpon8on
If you are able
to pay your
balance IN FULL
now, the
amount due is:
Page I cr I
0c0mo
557008.74
4 16810 0002624 06005008740500874 0
ACCOUNT SUMMARY CUSTOMER SERVICE PHONE NUMBER PAYMENT INFORMATION
Previous Balance 54,93132
1-800•?30-0»9 NEW BALANCE 55,008.74
- Credits .00 Available Credit 50.00
- Payments
+ Debits .00
.00 Account Number 4168 1000 0262 4060 Minimum Payment S5,008.74
+FINANCE CHARGE 77.42 Payment Due Date 09114/99
T Late Charge .00
+ Returned Check ^ .00 Average ANNUAL Daily Statement Date
= NEW BALANCE SS,008.74 Account Balance Daily PERCENTAGE Periodic 0812-Oj99
Balance RATE Rate
30 Days In
Balance 54,911.14 19.18':a .0525% Billing Cycle
307676000 1521 1521
we art ¢ Iuvd to Jbume this Inknnuon to wr.
THIS IS AN ATTE3IPT TO COLLECT A DEBT. ANY INFORMATION
OBTAINED w-ILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Access to credit is essential in today's world.
Bringing your First Select account to a PAID status would be an
important step toward improyins your credit record
and restoring your access to credit.
VALERIE ROSEN9LUTH PARK, ESQUIRE
ctorne7 =.D• ;7209:
P'_RK i-M-7 ASSOCT_P.TES, P.C.
25 E. State Street
Doylestown, PA 1390!
(21S) 348-5200
ATTORNEY FOR Pr?k!FITIFF
FIRST SELECT CORPORATION CfTdEERr.a COUNTY
Plainti=' COURT 07 COi`4d0N PLEAS
VS.
I FRED PEDUZZI
Defendant iSO. 99-o'i_$ Civil
NTERROG3TORIES
TO: Al_red Peduzzi
1527 Spring Road
Carlisle, PA 17013-15 51
YOU are hereby required pursuant to 7ennsvivania Rules OL
Civil Procedure NO. iOOS and 4Oo to ans:ie t e 0411 g
Iaterrogacories undeer Oath, 'aiC.^.4 t^_r V (30) Ca_:s a=t°_r ^-=
Service vService OL the I•.^.terrCCjatOrl eS. _nt=rrCCazories are deemed
t0 be COnt 1.^.UinC SO as t0 recuire further a::?.=_o LrORl n0':i unt; 1
the Triawithout. fur[:'-- _r '/O- u .Lear:: i1r_^=_ 1"fz)_mat iO^.
_r Ot1C_ 1_ _
called 'or Herein in accordance :•lit`. _ --.:sY_,---._- o?
ProCedure No. 4007.These -nter_OCa-orles are address to you as a
part of this action and vc r ans,.-,ers snsl l 'e Dasa= upon the
information. ..nOa CO you, vocr or
If you are held or sued in more than one capacity, or if your
answer would be different if answered in any difference capacity
such as partner, agent, corporate officer or director, or the
like, then you are required to answer separately for each such
capacity.
Said Interrogatories refer to the answers which have been
previously given in the Answer to the Request for Admissions,
served contemporaneously herewith; each Interrogatory will refer
to the numbered R guest for Admission.
DEFINITIONS:
The term "you" and "your" when used herein, means Defendant,
its agents, employees and representatives and all other persons
acting or purporting to act on its behalf.
The term "idenc-i fy" when used herein in connection with
natural nersons, means to state their full names, titles, and ]ol,
descriotions if applicable, and their oresent business and
residence addresses, or their last known business and residence
address.
The term "Identify" when used herein in connection with
documents, means to describe the document (e.g. letter,
memorandum, telegram, etc.), setting forth ics date, title,
author, address, parties, the substance thereof, the number of
pages thereof, the identity of all persons contributing to the
oreparation of the document, and the identity of all Dersons who
have copies of that document.
The term "documents" when used herein, means all original
writings of any nature whatsoever, and all non-identical copies
thereof, in your oossess'_on, custodv or control, regardless of
where located, and all other documents of which you have ?nowledge
and includes, but is not limited to, contracts, acreements,
correspondence, memoranda, internal and ex-_e ^ al reports, working
papers, minutes of meet-J:-.es, calendars, d'iar'ies, reports, bank
records, checks and oa,,ment records, and all ..--:_ngs or
documentary material of any nature whatsoever as defined by
Pennsylvania Rules of Civil Procedure, together with all
attachments thereto or enclosed therewith. In all cases where
originals and/or non-identical copies are unavailable, "documents"
also mean copies thereof.
1. If Request for Admission 1 is not admitted, state the
facts known. to you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 1.
2. It Request for Admission 2 is not admitted, state the
facts known to you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 2.
3. If Request for Admission 3 is not admitted, state the
facts known to vou, direct or indirect, which vou contend to be a
basis for denial of Request for Admission 3.
3, if Request for Adm'_ss'_on 4 is not admitted, state the
facts known to you, direct or indirect, which vou contend to be a
basis for denial of Request for Admission a.
5. If Request for Admission 5 is not admitted, state the
facts known to you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 5.
6. If Request for Admission 6 is not admitted, state the
facts known to you, direct or Indirect, which you contend to be a
basis for denial of Request for Admission 6.
sf
I I- ,J
7. if Request for Admission 7 is not admitced, State fully,
completely and at length, each face which const'_tutes the factuai
basis of such and everv defense 'dhic.^: you now assert or 'dii i
assert in this action. Attach hereto copies of writcen memoranda
Which you intend to use as a basis for each and everv defense
',which you may assert.
8. if Rern:est for Admission. 8 is not admitted, attach all
documents, writings, gaoers or letters Which were presented co
VOLT, your representative or atcorniey which. you intend to utilize
as evidence or as a basis for anv defense t.^.is matter.
9. if Request for Admission 9 is not admitted, state the
facts known to vou, direct or 'ind'irect, which !iou contend to be a
basis for deniai of Request for Admission 9.
10. if Request for Ad.mission 10 is not admitted, state the
facts known to vou, direct or indirect, which you contend to be a
basis for denial- of Request for Admission 1o.
11. if Request for Admission. 11 is not admitted, state the
facts known to you, direct or indirect, :a^:ich you contend to be a
basis for denial of Reg ast for rdmission 11.
12. if Request for Admission 12 is not admitted, state the
facts known to you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 12.
13. 1f Recuest for Admission 13 is not admitted, state the
facts known to you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 13.
PARK LAW ASSOC£ATES, P.C.
3y: UAL IE ROSEDI3 UTcI PARK, ESQ.
Attorney for Plaintiff
T_ understand that false statements made herein are subject to the
penalties of 18 Pa.C.S., §?904, relating to unsworn falsification
to authorities.
Alfred Peduzzi, Defendant
Pursuant to the Fair Debt Collection Practices Act, it is required
that we state the following to you: This '_s an attempt to collect
a debt. Ariv information obtained will be used for that ouroose.
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. '"72094
PAR: LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
FIRST SELECT CORPORATION
Plaintiff
VS.
ALFRED PEDUZZI
Defendant
CUQ3ERi`-VD COUNTY
COURT OF CO,.MUMON PLEAS
DiO. 99-0740- Civil
PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS
TO: Alfred Peduzzi
1527 Spring Road
Carlisle, PA 17013-1551
Pursuant to Pennsvivan'a Rule o= C_Vi l procedure =009, You
are hereby requested to produce the below listed documents and/or
items for the purpose of Discovery. This material will be
examined and/or ohotocoD'_edp photograon negatives Will be
processed and photographs reproduced. Said documents/tang_p'_e
things are set to be produced at the timne and at the place _or
such produ'ct'ion set forth below.
These regLe Sts are not directed merely Cc the person or oarty
whose name appears above, but are meant to include that person's
or party's agents, servants, insurers, employers, employees,
investigators, attorneys, and others similarly situate to the
named party or person.
In addition, although the Request seeks these documents
within the next thirty (30) days, the Request should also be
deemed continuing, in that if there are further materials which
come under the ourv'ew of arv c= these requests which. are obtained
after the time of their production presently, the materials should
also be furnished in accordance with this request.
If any document required to be produced by this Request is
claimed by you to be no discoverable because it is privileged or
for ami other reason, t^.en: (1) each such document should be
identified in your response- by date, sender, recipient, persons to
whom conies have been furnished, and the subject matter, and (2)
the basis *_or the claim of privilece or other reasons should be
stated in vour response.
1• The puroose of inspection is to aid the inquiring party
in the preparation at the Trial of this case.
2. The items to be produced for inspection and photocopying
are the following:
(a) Ledgers, journals, canceled checks, invoices, cash
bOO:{S, C'-"°-O'-z- mcmOn, vouchers, ana chacf-=7OO'.{ stubs in
Defendant's possession or control r=elating to any
CransdCtion between tale Defendant and t}'1°-mil al.nti if r=om
the date of t'-e account ooen'_^.C to the Dreesent.
(b) All original and copies of correspondence between the
Defendant and the Plaintiff from the date of the account
opening to the prese:':_.
o..r
(c) All statements of account received by the Defendant from
the Plaintiff from the date of the account opening to
present.
(o) All other memoranda, documents, papers
possession or control of the DefenaanC
sale or proposed sale of or payment fO
to the Defendant by the Plaintiff from
account opening to the present.
and books in the
relating to the
any merchandise
the date of the
(e) All documents identified, consulted, referred to Or
relied upon by you in the preparation of your Azziswers to
Plaintiffs interrccatories and/or Requests for
Admissions served contemporaneously herewith.
3. The entire investigation file or files (excluding
reference to mental impression, conclusions Or OPi.^.ions
representing the value of merit OL the claim or defense or
respecting strategy or tactics and privileged communication from
counsel.)
4. All statements of any and all witnesses includ'ing any
and all sCaCemenCs of Plaintiff's and Defendant's, the'--- agents
and employees.
5.
togethe All
r with Photographs and diagrams taken and/or prepared,
i any and all analyses made of any
a bstances
involved
n this matter,
.
c. Any' and all documents containing the names and home and
business addresses of all individuals contacted as Potential
witnesses.
7. Reports of any and all experts who will- cestlf y at
Trial.
8. Any and all documents, records, evidence and everything
which may be ir-troduced or upon. which you intend to rely at Trial
for use in direct examination, cross-examination and/or
impeachment.
The time and place for such production and inspection is
July 14, 2000 at:
The Law Offices of Park Law Associates, P.C.
25 East State Street
Dovlestown, PA 18901
PARK LASS ASSOCIATES, P.C.
DATED: June 12, 2000 3y: VP_ ERZE ROSENBLUTH P?Rti, ESQ.
Attorney for Plaintiff
Pursuant to the Fair Debt Collection Practices Act, it is required
that we state the following to vou: This 1s an atcemot t o collect
a debt. Any information obtained will be used for that ouroose.
VALERIE ROSENBLUTH PARK,
Attorney I.D. "_72094
PARK LAFI ASSOCIATES, P•C•
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
FIRST SELECT CORPORATION,
Plaintiff
VS.
ALFRED PEDUZZI Defendant
ESQUIRE
CUMBERLAND COUNTY
COURT_ OF COh1M0N PLEAS
N0. 99-67466 Civil
CERTIFICATE OF SERVICE
Valerie Rosenbluth Park, Esquire certifies that she is the
of
attorney for the a 2000,"_ she servedl a true handn y and correc Retctcoion py and
that on June. 12,
Plaintiff's Request for Admissions, intereo samebv U Request
Production-of Documents, by mailing postage paid, to the person and at the address set forth below:
Alfred Peduzzi, Defendant Pro Se
1527 Spring Road
Carlisle, PA 17013-1561
j
PARK LAS4VE :-.SSOCIATES,
BY:
VALERT_E ROSEiBLUTH PARK, ESQ.
ATTORNEY FOR PLAINTIFF
EXHIBIT
:tyl
yyi
)fir
a`
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
Valerie Rosenbluth Park, Esquire, being duly sworn according
to law deposes and says that she is the attorney for the Defendant
in the foregoing matter; that she is authorized to take this
affidavit on its behalf; and that the facts contained in the
foregoing Petition are true and correct to the best of her
knowledge, information and belief. Valerie Rosenbluth Park,
Esquire further understands that false statements made herein are
subject to the penalties of 18 Pa.C.S., Section 4904, relating to
unsworn falsification to authorities.
I -
Valeri osenbluth Park, Esquire
-i
U u v
?o
ea` ?gg
H rbry,.
U?K2
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?i '
FIRST SELECT CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ALFRED PEDUZZI,
DEFENDANT
99-6746 CIVIL TERM
ORDER OF COURT
AND NOW, this 2 ?r day of October, 2001, the motion of plaintiff for
summary judgment, IS GRANTED. Judgment is entered in favor of plaintiff, First Select
Corporation, against defendant, Alfred Peduzzi, in the amount of $4,931.32, plus
interest at the contract rate of 19.18 percent from July 22, 1999, plus attorney fees of
$986.
Valerie Rosenbluth Park, Esquire
For Plaintiff
By the Court
( o$v
Edgar B. `Bayley, J. t
Alfred Peduzzi, Pro se
1527 Spring Road
Carlisle, PA 17013-1561
:saa
r - r?
. i 1' ? .. I ? ..
Vl•
--- ---- _-.J
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
I HEREBY CERTIFY THATTHE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 4460 ROSEWOOD DRIVE
PLEASAN'rON. CA 94588
DER 1527 SPRING ROAD
CARLISLE. PA 17013
CUMBERLAND County Court of Common Pleas
FIRST SELECT CORPORATION
Plaintiff
VS
ALFRED PEDUZZI
Defendant
NO. 99-6746 CIVIL
PRAECIPE FOR JUDGMENT
I
bl
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff and against the said Defendant in
accordance with the Order of Court entered on October 25, 2001 in the amount of
$4,931.32, plus interest from July 22, 1999 at the rate of 19.18 per annum, plus attorney fees
of $986.00, plus costs.
I certify that a copy of the Order is attached hereto, made a part hereof and marked
Exhibit "A".
PARK LAW ASSOCIATES, P.C.
E8 BY:I
Valerie Rosenbluth Park,
Attorney for the Plaintiff
AND NOW, ! J D (.) 2001, Judgment is entered as ab v .
PROTHONOTARY
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
FIRST SELECT CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ALFRED PEDUZZI,
DEFENDANT
99-6746 CIVIL TERM
ORDER OF COURT
AND NOW, this day of October, 2001, the motion of plaintiff for
summary judgment, IS GRANTED. Judgment is entered in favor of plaintiff, First Select
Corporation, against defendant, Alfred Peduzzi, in the amount of $4,931.32, plus
interest at the contract rate of 19.18 percent from July 22, 1999, plus attorney fees of
$986.
By
Edgar
Valerie Rosenbluth Park, Esquire
For Plaintiff
Alfred Peduzzi, Pro se
1527 Spring Road
Carlisle, PA 17013-1561
:sea
Court,
EXHIBIT
---?
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
I I IEREt3Y CERTIFY THAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 4460 ROSEWOOD DRIVE
PLEASANTON, CA 94588
DEF: 1527 SPRING ROAD
CARLISLE. PA 17013
4168100002624060
CUMBERLAND County Court of Common Pleas
FIRST SELECT CORPORATION
Plaintiff
VS
ALFRED PEDUZZI
Defendant
NO. 99-6746 CIVIL
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:
{ } Judgment by Default
{ } Money Judgment
{ } Judgment in Replevin
{ } Judgment in Possession
{ } Judgment on Award of Arbitration
{ } Judgment on Verdict
{X} Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE
CALL: Park Law Associates P.C. at this telephone number: (215) 348-5200.
PROTHONOTAR
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
I HEREBY CERTIFY TI IAT THE
TRUE AND CORRECT ADDRESS IS:
PLAINTIFF: 4460 ROSEWOOD DRIVE
PLEASANTON. CA 94588
DEF: 1527 SPRING ROAD
CARLISLE, PA 17013
CUMBERLAND County Court of Common Pleas
FIRST SELECT CORPORATION
Plaintiff
VS
ALFRED PEDUZZI
Defendant € NO. 99-6746 CIVIL
AFFIDAVIT 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 knows of her own personal knowledge and therefore avers, that ALFRED
PEDUZZI, Defendant, is over 21 years of age; that his/her place of residence is located at
1527 SPRING ROAD, CARLISLE, PA 17013 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:
VA ERIE ROSENBLUTH PARK
Swom to and subscribed
before me this ] h day
of oxn4r20r71.
NOTARY PUBLIC
=Leloc? SEAI
14otary?uoilc
c ks County
s April 14, 2003
°=
c
74
( Y