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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 East State Street
P.O. Box 1779
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PROVIDIAN NATIONAL BANK
Plaintiff
7 q - 7yb3 0?
VS.
THOMAS J. GALLAS
Defendant
NO.
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
by are
within twenty (2)
written appearance Complaint persona 1 personally or Notice
served, by by nter9 a
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
FORTH BELLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOT OFFICE HAVE
COURT ADMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONAL BANK
295 MAIN STREET
TILTON, NH 03276
PLAINTIFF
VS
THOMAS J. GALLAS
1402 BRADLEY DRIVE
APT 312
CARLISLE, PA 17013-1248
DEFENDANT
NO. 99" 7 0 3 P %e?
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 THOMAS J. GALLAS, an individual who resides
at 1402 BRADLEY DRIVE, CARLISLE, PA 17013-1248.
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 5418275002994716.
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
$2,055.43 as of 08/21/1999, plus pre-judgment contractual interest
at the rate of 19.99% 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 $411.00.
COUNT II
8. Plaintiff hereby incorporates paragraphs 1 through 7 above as
though set forth in full.
9. The Defendant received a monetary benefit, which was in fact
appreciated by the Defendant.
10. The Defendant accepted the benefits.
11. By virtue of the circumstances surrounding the request for
funds made, the Defendant knowingly requested the funds at issue
and/or knowingly and voluntarily accepted the benefits bestowed.
12. It would be inequitable for this Court to allow the Defendant
to retain the benefits of the funds or to be unjustly enriched at
the expense of the Plaintiff or allow the Defendant to retain the
value of the funds at issue without repaying the Plaintiff the
value of same.
i
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WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendant in the amount of $2,055.43, plus pre-judgment interest
at the contractual rate of 19.99% per annum from 08/21/1999 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $411.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
PARK LAW ASSOCIATES, P.C.
BY:
VA IE R BLUTH PARK, ESQUIRE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED
THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT
A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
VERIFICATION
I, 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
PROVIDIAN NATIONAL BANK
THOMAS J. GALLAS
54 18275002994 716
929824-1
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
PROVIDIAN NATIONAL BANK NO. 99 - 7403
Plaintiff IN CIVIL ACTION
VS.
THOMAS J. GALLAS
Defendant
ANSWER
FILED ON BEHALF OF
DEFENDANT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
PROVIDIAN NATIONAL BANK NO. 99 - 4314
Plaintiff IN CIVIL ACTION
Vs.
THOMAS J. GALLAS
Defendant
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Denied. Defendant denies that he has willfully refused to pay the
amount due the Plaintiff.
6. Denied. Defendant, after reasonable investigation, is without sufficient
knowledge or information to determine the amount of the balance.
7. Denied. This is a conclusion of law to which no response is required.
8. Denied. This is a conclusion of law to which no response is required.
9. Admitted.
10. Admitted.
11. Admitted.
12. Denied. Defendant is without sufficient knowledge or information to
determine the amount of the balance.
Wherefore, Defendant requests that judgement be in his favor and that
the relief in the amount requested by the Plaintiff be denied until written
verification of the amount of the balance is produced by the Plaintiff.
omas J as
1402 Bradley Drive A-312
Carlisle, PA 17013
I, Thomas J. Gallas, Defendant herein, verify that the statements of fact
contained in the foregoing Pleading are true and correct. I understand that false
statements herein are subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
46mas l as
1402 Bradley Drive A-312
Carlisle, PA 17013
11 r, ? cs?
I, Thomas J. Gallas, certify that I mailed a copy of the foregoing Answer to
Valerie Rosenbluth Park, Esq., PARK LAW ASSOCIATES, P.C., 25 East State
Street, P.O. Box 1779, Doylestown, PA 18901 on January 3, 2000 via first class
US mail, postage prepaid.
4ma0sallas&
1402 Bradley Drive A-312
Carlisle, PA 17013
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07403 P
COMMONOUNTYWEOALTCH OF
PROVIDIAN NATIONAL BANK
VS.
GALLAS THOMAS J
KATHY CLARKE , sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within CIVIL ACTION was served
upon GALLAS THOMAS J the
defendant, at 10:22 HOURS, on the 15th day of December
1999 at 1402 BRADLEY DRIVE APT 312
CARLISLE, PA 17013-1248 CUMBERLAND
County, Pennsylvania, by handing to THOMAS J. GALLOS
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
Surcharge 8.00 omas ine, eri f: r
PARK LAASSOCIATES
12/15/1999
Depuc,y -Serl`f --
Sworn and subscribed to before me
this i4 1 •¢l day of
1'8 .3O-zrO A. D.
Q.,_
rocnonocar
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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PROVIDIAN NATIONAL BANK
Plaintiff
VS.
THOMAS J. GALLAS
Defendant NO. 99-7403 CIVIL
CERTIFICATE OF SERVICE
Valerie Rosenbluth Park, Esquire certifies that she is the
attorney for Providian National Bank in the above captioned matter
and on July 10, 2000 she served upon Thomas J. Gallas, original
Request for Admissions, Interrogatories and Request for Production
of Documents by mailing same first class mail, to the person and
at the address set forth below:
! Thomas J. Gallas
1402 Bradley Drive A-312
Carlisle, PA 17013
PARK 7LAW SSOCIATES P .C.
I RY_
VA LERIE ROSENBLUTH PARK, ESQ.
ATTORNEY FOR PLAINTIFF
1
Cl.
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VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
THOMAS J. GALLAS
Defendant NO. 99-7403 CIVIL
O R D E R
AND NOW, to wit, this day of ,
2000, upon consideration of the Motion for Summary Judgment,
Memorandum of Law, and the Motion of Valerie Rosenbluth Park,
Esquire, Judgment is hereby entered on behalf of the Plaintiff,
Providian National Bank, and against the Defendant, Thomas J.
Gallas, in the amount of $2,055.43 plus interest at the contract
rate of 19.99% per annum from 8-21-99, plus reasonable attorney's
fees in the amount of $411.00, plus costs.
BY THE COURT:
r
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.
THOMAS J, GALLAS
Defendant NO. 99-7403 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
12-9-99 =nd service was made upon the Defendant on 12-15-99.
2. On or about 7-17-00, the Plaintiff, by its attorney,
served upon the Defendant, through its attorney, an original
Request for Admissions addressed to the Defendant, and original
Interrogatories addressed to 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".
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
fora any admitted
Admissions, admitted obligition
rel relied as ea Plaintiff
there are no facts upon wh defense
in this action.
WHEREFORE, Plaintiff prays that the Court enter Summary
Judgment in its favor and against the Defendant in the amount of
$2,0553 1 99, interest lus rate of 9 a
reasonable attorney's fees in the mount annum
from 8- of
$411.00, plus costs.
PARK LAW ASSOC S, P.C.
BY: ? z/
VALERIE ROSENBLUTH PARK, ESQUIRE
ATTORNEY FOR PLAINTIFF
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
VS.
THOMAS J. GALLAS
Defendant
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO. 99-7403 CIVIL
PLAINTIFF'S REQUEST FOR ADMISSIONS AND ACCOMPANYMNG
INTERROGATORY TO DEFENDANT
TO: Thomas J. Gallas
Defendant, Pro Se
1402 Bradley Drive A-312
Carlisle, PA 17013
Pursuant to Pennsylvania Rule of Civil Procedure No. 4014,
the undersigned attorneys for Providian National Bank hereby
request that Thomas J. Gallas make the following admissions within
thirty (30) days after service, for the purpose of this action
only is subject to all pertinent objections as to relevancy:
Admit to the truth of each of the matters set forth in the
Request for Admission included herein; make a written response,
sign the same, swear to it, and deliver it to the attorney for the
''Plaintiff herein within thirty (30) days after the date of the
service.
EXHIBIT
YOU ARE INSTRUCTED:
1. These Requests for Admissions and accompanying
Interrogatory are directed to the Defendant, its/his/her officers,
ers,
employees, agents, servants, assigns, representatives, p and
present, and unless privilege is claimed, each and every attorney,
past and present, of each and every such individual or entity. As
used herein, "Defendant," "you" and "your" means the Defendant to
which these Requests for Admissions and accompanying Interrogatory
are addressed, its/his/her officers, employees, agents, servants,
assigns, representatives, 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 information, documents and records
that are in the possession, control, or custody of Defendant or
any of its officers, employees, agents, servants, attorneys and
assigns.
3. If any objections are made to any Request for Admissions
or to the accompany Interrogatory, the reasons therefore shall be
stated.
4. If there is any claim or privilege relating to any
request to admit, or Interrogatory, you shall set forth fully the
basis for the claim of privilege, including the facts upon which
you rely to support the claim of privilege in sufficient detail to
permit the Court to rule on the propriety of the privilege.
5. If your response to any request if not an unqualified
admission, your answer shall specifically deny the matter or set
forth in detail the reasons why you cannot truthfully admit or
deny the matter.
s 6. A denial shall fairly meet the substance of the
requested admission, and when good faith requires that you qualify
your answer or deny only a part of the matter of which an
admission is requested, you should specify so much of it as is
true and qualify or deny the remainder.
7. You may not give lack of information or knowledge as a
reason for failure to admit or deny, unless you state that you
have made reasonable inquiry and that the information known to you
or readily obtainable by you is insufficient to enable you to
admit or deny.
8. These Request for Admission and Interrogatory are
continuous in nature and must be supplemented promptly if
Defendant obtains or learns further or different information
between the date of the 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 on or about 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 those numbers and letters have been placed.
11. If you are held or are sued in more than one capacity,
or if your answer would be different if answered in any different
capacity such as a partner, an agent, corporate officer/director,
or the like, then you are required to answer separately in each
such capacity.
Further that pursuant to Pennsylvania Rule 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 on 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. "Any" as well as "all" shall be construed to mean "each
and every."
4. "And" as well as ":or" shall be construed disjunctively
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 with, commenting upon, or in
any way pertaining to.
REQUEST FOR ADMISSIONS
1. Do you admit that account number 6011-9001-8661-2508 was
bassigned to Providian National Bank in accordance with the
Officer's Certificate and Assignment attached hereto, made a part
hereof, and marked Exhibit "P-1"?
2. Do you admit that after the account was assigned you
received the Providian National Bank 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 as of August 20, 1999, you were
indebted to the Plaintiff in the amount of $2,055.43?
4. Do you admit that there are no offsets or credits which
are due to you from the Plaintiff since December 9, 1999?
5. Do you admit that you agreed to pay the collection cost
the Plaintiff is incurring or will incur including, but not
limited to, reasonable attorney's fees and court costs as more
particularly set forth in Paragraph 3 of Providian National Bank
Account Agreement (Exhibit "P-2" attached hereto)?
6. Do you admit that $411.00 is equal to 20% or less of the
outstanding balance and is a reasonable attorney's fee to
effectuate collection of the past due balance?
7. Do you admit that there are no facts on which you rely
as a basis for any 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 this action?
i 9. Do you admit that you have not paid Plaintiff any
payments since August 21, 1999?
10. Do you admit that you agreed to pay a finance charge to
Plaintiff pursuant to the Providian National Bank Account
Agreement (Exhibit "P-2" attached hereto) ?
11. Do you admit that attached hereto, made a part.hereof,
and marked collectively Exhibit 11P-3" are true and correct copies
of the records of the Plaintiff showing cash advance, charges and
credits incurred through your use of the Providian MasterCard
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 purpose
of its admission into evidence at the Trial of this action?
PARK LAW ASSOCIATES, P.C.
BY: VALERIE ROSENBLUTH PARK, ESQ.
Attorney for Plaintiff
I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S., §4904, relating to unsworn falsification
to authorities.
Thomas J. Gallas, 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
PROVIDLAN NATIONAL BANK ACCOUNT NUMBER:
5418-2750-02994716
ACCOUNTHOLDER NAME:
THOMAS J GALLAS
In my capacity as Operations Officer of Providian National Bank, I hereby certify the following:
1. In accordance with the Purchase Agreement dated December 9, 1998, between Greenwood Trust Co.
("Seller") and Providlan National Bank ("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 the Assignment addendum to the Agreement, which 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 the Assigament of the Agreement:
Bravo Account Number: 6011-9001-8661-2508
Customer Name: THOMAS J GALLAS
(the "THOMAS J GALLAS Account")
4. The outstanding balance of the THOMAS J GALLAS Account was accurately transferred from the Seller to the
Buyer. The balance as of the most recent Providian National Bank billing statement (dated August 20, 1999)
was 52055.43.
By:
'e L. Holland
J
d Title: Operations Officer
p EXHIBIT
RR l vnrRT nnr 6/10/00=
Tustin 12/5 .a 2:05: ?AG: Gas/is '•iS',*t X
b ¢4TC.1NE
FOR VALUE RECEIVED, Greenwood Trust Co. (C'S o ellerr), does hereeiby 1sell, 998 assign,
transfer and covey to Providian National Bank (Bu_yer") all Of
Seller's rights, title and interest in and to all of the following assCS'a_d agm=cnts as they shall
exist on the date hereof (collectively, the "Assets'), in each case pL' suant to that certain Credit
Card Porfollo Purchase and Sale Agreement dated as of November 13, 1999 between Seller and
Buyer (the "Purchase Agreement'):
1. All Eligible Accounts; and
Each of the following to the extent related to my such Eligible Account:
(i) All Accounts Receivable; ;
(ii) All AccountRxords;
(iii) • All Cardholder Agreements;
(iv) The Cardholder list;
(v) • Interchange Fees; and
(n) unearned fees
Ia accordance with the purchase Agreennt Seller hereby conveys to Buyer all of Seller's
right, title and interest in the Assets without recourse except as provided in the Purchase
Ag cement.
This Assignment is made pursuant to, and caoitali.zed te^s not otherwise defined herein
shall have the meaning set forth in, the Purchase Agreement a. e. h Assipnamcat shall be.
governed by such Purchase Agreement.
N tiYCNE55 Wh'EREOr, .the uadeniped hrs caused ttu Essig ment to be dily
executed this 'jf_day of G 1998.
COD TRUST CO.
B ame: 7. Natbsu F?iII
Tide: President
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ACCOUNT NUMBER PAYMENT DUE DATE MINIMUM PA' 4T
5418-2750-0299-4716 OC71s,.7999 -.,.;.:.; i` $2,091.90
THOMAS J DALLAS
1402 BRADLEY DR APT 312
CARLISLE PA 17013-1248
Page 1 of 1
000000
PROVIDIAN MASTERCARD
5418275002994716020919602091960
IrAMOUNT ENCLOSED
Make Cheeks Payable To
Provldlan
ACCOUNT SUMMARY CUSTOMER SERVICE PHONE NUMBER
AYMENT INFORMA71ON
P
NEW BALANCE
Previous Balance 32,055.43 1-800-280-0559 Credit Line 32,000
• Credits •00 Available Credit Soo
• Payments .00 Account Number 5410 275D 0299 4713.. Minimum Payment 32,091.90
t Purchases 6 Payment Due Date 10115/99
es
Char
h .00
g
er
ot
+ Cash Advances •00 Average ANNUAL Dally Statement Date
t FINANCE CHARGE 30.53 Type of Balance Dally PERCENTAGE Periodic 09/20199
t Late Charge 90 Balance RATE Rate
NEW BALANCE $2,091.00 Purchase $33091 19.99% .0.549X" at Days In
Cash Advance $1,054.91 21.99% .0002% BIIIIn9Cyele
'neir P eriaaa me mer w
307079000 1"J 1? 0
THIS IS AN ATTEMPT TO COLLECT A DEBT.
ANY INFORMATION OBTAINED WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
PROVIDIAN NATIONAL BANK
Access to credit Is essential In today's world.
Bringing your Providlan account to PAID status would be an
Important step toward Improving your credit record
and restoring your access to credit.
IT
ACCOUNT NUMBER PAYMENT DUE DATE MINIMUM PC :NT AMOUNT ENCLOSED
5418-2750-0299 -471 6
SEP,1¢,.1s9g St33.00
Make Checks Payeble To
Pmvldten
THOMAS J GALLA%S
1402 BRADLEY E3R APT 312
CARLISLE PA 1- 7013-1248
Page I of 1
d000W
PROVIDIAN MASTERCARD
5418275002 994716001330002055430
Plop aso solethe eaclesed changes to youraccoum terms
andt bnportant Information about your ProvId4m account
Your accau m is paaat due and must be paid immediately to Vold further credit damage
and posamle mf ffW of your account for addltloml collection actlom
It you are u table to make your payment Immediately ce us at1•e00.733-8192
Your=cu M te a9o *WA3 over your approved credit One. While your Account Agreement
may requlreyou to Pry tlds ovargmltamouny we are giving you the flexibility of prying
onty$133.00. Paying Put this minimum due paymentwgl leave your aecou m In an
overkmhstatus. You saved to work towards bdnging your balance back under your cradt One.
ACCOUNTSUMMARY CUSTOMER SERVICE PHONE NUMBER PAYMENT INFORMATION
Previous Balance $1,991.71 1-$00
6$$
?866 NEW BALANCE S2,O55.43
• Credits .00 ?
? Credit Line S2,ooa
• Payments ,00 Available Credit $00
t Purchases t. Account Number 5418 2750 0299 4716 Minimum Payment $733.00
other Charges .00 Payment Due Dale 09114199
+
Cash Advances .00
t RNANCE CHARGE 34.72 Average ANNUAL Dally Statement Date
+ Late Charge 29,00 Type of Balance Dally PERCENTAGE Periodic 08/20199
= NEW BALANCE $2,055.43 Balance RATE Rate
Purchase $725.47 19.99% .054819.• SO Days In
Cash Advance $1,624.81 21.99% .0602 Y. Billing Cycle
•'•'• •••••• ... .. 'Daly P.nodo fate may very .
PROVIDIAN NATIONAL BANK
We appreciate your business.
Thank You!
ACCOUNT NUMBER PAYMENT DUE DATE MINIMUM W- 'ENT AMOUNT ENCLOSED
5418-2750-0295 -1716 auc?s,1999 "..;:,. -Da s
Make Checks Payable To
Provkllan
THOMAS J GALLAS
1402 BRADLEY DR APT 312
CARLISLE PA 17013-1248
Page 1 of I
000700
PROVIDIAN MASTERCARD
5418275002994716000920001991710
----------------------------
MESSAGES FROM PROVIDIAN MASTERCARD
Your payment dua Includes any past due amount that must W Paid Immadb rely. Your account
may be permanently closed whbout this Pnmem. To avold Nrther co00ctlon calla and lab fees
please pry Immedlately, or oB 1400.7508192 to make arrangements for Payment
CUSTOMER SERVICE PHONE NUMBER INFORMATION
PAY
ACCOUNT SUMMARY - BALANCE
Previous Balance 57,92891 1.800.688-1866 Credit Una 32,0
. Credits
.00
Available Credit 8
- Payments .00 Account Number 5418 27500299 4718 Minimum Payment $92.00
0811549
t Purchases 3 Payment Due Data
other Charges .00
00
ANNUAL Dally
statement Dab
t Cash Advances
t h7NANCE CHARGE .
34.E Average
Type of Balance Daily PERCENTAGE Periodic 07/21/99
+ Late Charge
NEW BALANCE
31,991.71 Balance
15
$320 RATE Rate
19.99% .0548%2
20 Days in
.
purchase
Cash Advance $1,595.71 21.99 Y. .0802 Y. BIIIIn9 Cycle
•Detr Par oda Pala mar ra r
PROVIDIAN NATIONAL BANK
' We appreciate your business.
Thank You!
I! i
assesses"
a.-..,.,......, . _. OSED
ACCOUNT PAYMENT DUE DATE MINIMUM PA" 'H7
-? JUL 76, 1999 -.. Sai.00:
5418-2750-0299-716
THOMAS J GALLAS
1402 DR AP 312
_ CARLISLEOPAY 1701371248
-? Page 1 of 2
000000
PROVIDIAN MASTERCARD
AMOUNT ENCL
Make Checks Payable To
PmvMlen
5418275002994716000530001928610
___--_-_SoIny great savings when You rentaarfmm MarCl Pines, a" lmart for dotalls.
Aaacaddl0amlbans04Ycucanbkoa 2rosgo Your PrevlewAuto Renal lmunna
that comes automadcaly
You an My* axes to your mach and bdorma0on anytime. anY'b'",
Check your avabable b tans, track your charge', or seawhe n YouFmrt PaYMaut Is due'
To learn mom, go to w".ProvIdlawardsam
Please ....t. above amount Includes any pastduo amountand mu'tb*Paid "Immediately.
1101100 ibis m
M You Mve stroody wont a payment, thank you and p lease disregard if you wed to looks arrangements for payment Please all 1.8a0.733.8192.
Post Date Description
a -26HENISE TIRE SERVICE IN YORK PA
06-07SPRINT CORPORATION PLYMOUTH IN
06-14CASH ADVANCE FROM ATM -
PNC BANK NEW JERSY N ATLANTIC CTY
06-14CASH ADVANCE FROM ATM -
PHC BANK NEW JERSY N ATLANTIC CTY
06-21CASH ADVANCE FROM ATM -
PNC BANK PHILADELPHI GETTYSBURG PA
06-21CASH ADVANCE FROM ^ATM'?vemlac Pa
PROVIOIAN NATIONAL BANK
Transaction Data
05-24 803481291455022482 32 163.101
06-04 78464969156206572225650 4814 150.60
NJ 06-11 85422029163231278964519 6011 302.99
NJ 06-12 85422029163103278037135 6011 302.99
06-18 85422029169195870676082 6011 191.50
We appreciate your business.
Thank You!
ACCOUNT NUMBER
5418-2750-0299-4716
THOMAS J DALLAS
1402 BRADLEY DR APT 312
CARLISLE PA 17013-1248
Page 2 of t
PROVIDIAN MASTERCARD
541827500299 4 71 61301153aacil 928610
------------------------------------------------------------------- --
ACCOUNTSUMMARY CUSTOMER SERVICE PHONE NUMBER PAYMENT INFORMATION
Previous Balance $828.54 1-800.688.1866 CNEW redit UneNCE 51,928.
• Credits s .00 Avallable Credit $71
• Payments .00 Account Number 5418 2750 0299 4718. MlNmum Payment $57.00
t Purchases 6
Payment OUa Date
07115199
other Charges 313.51
t Cash Advances 908.98 Avenge ANNUAL Daily Statement Dale
CHARGE:
t Fl 2125 Type of Balance Dally PERCENTAGE Periodic 06/21!99
Balances
On n Bala
Balance
RATE Rate
Cab Ady Fee 29p Purchase 3226.81 19.99% .0548X• 23 Days In
t Lets Charge
NEW BALANCE
? 29.00
31,828.61
Cash Advance $862.67
21.99% .0602%
BIIIIn9 Cyale
ANNUAL PERCENTAGE RA7EIhla billing cycle 53.33%
318383000 1523 1525
PROVIDIAN NATIONAL BANK
D7 awoaa me may vary
..::r. e-r
We appreciate your business.
Thank You!
ACCOUNT NUMBER PAYMENT DUE DATE MINIMUM PAYMENT AMOUNT ENCLOSED
5ri18-2750-0295 .716 JUM17;19t19
Make Cheeks Payable To
Provldlan
THOMAS J GALLAS
1402 BRADLEY DR APT 312
CARLISLE PA 17013-1248
Page I al I
000000
PROVIDIAN MASTERCARD
5418275002994716000150000626540
-------------------------------------------------
You pa have =82s to your credit and ldorma0on anytlme, anywMro.
Chock youravallable tWance, track your charges, or sea whoa your "It Taf"mMQra,gotoww,Provl®ancary.aom Orymadla due.
TRANSACTIONS
Past Data Description
Tmnsactlon Date Amount
05-14CASN ADVANCE E FROM ATM -
PNC BANK NEW JERSY N ATLANTIC CTV NJ 05-13 854220291331400777426,86 6011 99
05-17CASH ADVANCE FROM ATM - 302.
Previous Balance
.00
S'Dg
----.._..._- •^•,•,.^. u.r?nmqu?n -
NEW BALANCE
•
Credits
Do
I'800-688-1866
1 X854
• Payments
.Do Credit Una 52,000
+ Purchases 8,
Account Number 5418 2750 0299 47 Available Credit
16 Mlnlmum Payment 57,777
+ Cash other Charges
Cash Advances
W
Payment Due Date $75.00
pgryygg
+FINANCE CHARGE. 50598
Average
NOMINAL ANNUAL Daily
Sl
t
On Balances
Cash Adv Fee
tag
Type of Balance Daity
PERCENTAGE Periodic a
emant Dale
05/19/99
+ Late Charge 18.18
00 Balance
Purchase $
Do RATE Rafe
NEW BA
= LANCE ,
g•r .
Cash Advance 5140
8
7 19.99% .0548%-
21
99% 28 Days In
. .
.0802 Y. BIIIing Cyele
ANNUAL PisCENTAGERAT8his billing cyde 40.71 Y.
716282000 1527 1525
' 'ONr Palado ibte mW wy
PROVIDIAN NATIONAL BANK
a
We appreciate your business.
Thank You!
J nqr,
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. 972094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
THOMAS J. GALLAS
Defendant
NO. 99-7403 CIVIL
TO: Thomas J. Gallas
Defendant, Pro Se
1402 Bradley Drive A-312
Carlisle, PA 17013
You are hereby required pursuant- to Pennsylvania Rules of
Civil Procedure No. 4005 and 4006 to answer the following
Interrogatories under oath, within thirty (30) days after the
service of the Interrogatories. These Interrogatories are deemed
to be continuing so as to require further answers from now until
the Trial without further notice if you learn further information
called for herein in accordance with Pennsylvania Rule of Civil
Procedure No. 4007. These Interrogatories are address to you as a
part of this action and your answers shall be based upon the
information known to you, your attorney or other representative.
s
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 Lnterrogatories 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 Request 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 "identify" when used herein in connection with
natural persons, means to state their full names, titles, and job
descriptions if applicable, and their present 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 its date, title,
author, address, parties, the substance thereof, the number of
pages thereof, the identity of all persons contributing to the
preparation of the document, and the identity of all persons who
have copies of that document.
The term "documents" when used herein, means all original
writings o any nature whatsoever, and all non-identical copies
thereof, in your possession, custody or control, regardless of
where located, and all other documents of which you have knowledge
and includes, but is not limited to, contracts, agreements,
correspondence, memoranda, internal and external reports, working
papers, minutes of meetings, calendars, diaries, reports, bank
arecords, checks and payment records, and all writings 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. If 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 you, direct or indirect, which you contend to be a
basis for denial of Request for Admission 3.
4. If Request for Admission 4 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 4.
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.
s
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.
7. If Request for Admission 7 is not admitted, state fully,
completely and at length, each fact which constitutes the factual
basis of such and every defense which you now assert or will
assert in this action. Attach hereto copies of written memoranda
which you intend to use as a basis for each and every defense
which you may assert.
8. If Request for Admission 8 is not admitted, attach all
documents, writings, papers or letters which were presented to
you, your representative or attorney which you intend to utilize
as evidence or as a basis for any defense in this matter.
9. If Request for Admission 9 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 9.
10. If Request for Admission 10 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 10.
u
11. If Request for Admission 11 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 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. If Request 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 ASSOCIATES, P.C.
BY: VALERIE ROSENSLUTH PARK, ESQ.
Attorney for Plaintiff
I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S., 94904, relating to unsworn falsification
to authorities.
Thomas J. Gallas, 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.
i
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS
Valerie Rosenbluth Park, Esquire, being duly sworn according
to law deposes and says that she is the attorney for the
Defendants in the foregoing matter; that she is authorized to take
this affidavit on its behalf; and that the facts contained in the
foregoing Motion for Summary Judgment 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 9909,
relating to unsworn falsification to authorities.
I
Valerie osenbluth Park, Esquire
VALERIE ROSENBLUTH PARK, ESQUIRE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215) 348-5200
ATTORNEY FOR PLAINTIFF
PROVIDIAN NATIONAL BANK
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS.
THOMAS J. GALLAS
Defendant
NO. 99-7403 CIVIL
MEMORANDUM OF LAW
HISTORY OF THE CASE'
A Civil Action was filed on 12-9-99 requesting Judgment
against the Defendant in the amount of $2,055.43 plus interest at
the contract rate of 19.99% per annum from 8-21-99, plus
reasonable attorney's fees in the amount of $411.00, plus costs.
Defendant was served with a true and correct copy of the Civil
Action on 12-15-99. Defendant filed an answer. Plaintiff served
upon Defendant Request for Admissions and Interrogatories on 7-17-
00. To date, Defendant has not responded to said Request for
Admissions and Interrogatories.
II. QUESTION INVOLVED'
Is the Plaintiff entitled to have its Motion for Summary
Judgment granted in accordance with Pennsylvania Rule of Civil
Procedure No. 1035 as a result of the Defendant's failure to
respond to the Plaintiff's Request for Admissions within thirty
(30) days as mandated by Pennsylvania Rule of Civil Procedure No.
4014, thus causing no genuine issue as to any material fact.
III. ARGUMENT;
Pennsylvania Rule of Civil Procedure No. 1035 states that
after the pleadings are closed, but within such time as not to
delay the trial, any party may move for Summary Judgment. Summary
Judgment will be granted if there is no genuine issue as to any
material fact and the moving party is entitled to Judgment as a
matter of law. Pennsylvania Courts have developed rules in
helping them decide when there is no genuine issue of any material
fact. First, the records must be examined in the light most
favorable to the non-moving party. Second, all well pleaded facts
in the non-moving party's pleading are deemed accepted as true.
Ritmanich et al. v. Jonnel Enterprises, Inc. et al. 219
Pa.Super. 203 (1971). Third, the moving party has the burden of
proof. Fourth, the Court must give the non-moving party the
benefit of any inferences that can be drawn from the pleadings in
any other support evidence. Kent v. Miller, 222 Pa.Super. 393
(1973); Pocono Int'l Raceway Inc. v. Pocono Produce, 503 Pa. 80,
468 A. 2d 268 (19U). However, the non-moving party may not rely
merely upon controverted allegations of the pleadings but must set
forth-specific facts by way of affidavit or in some other way as
provided by Rule demonstrating that a genuine issue exists.
Ressler v. Jones Motor Co. Inc., 337 Pa.Super 602, 487 A.2d 424
(1985). If there are no issues of material fact and moving party
is entitled to judgment as a matter of law, summary judgment must
be granted. Marriscotti v Tinari, 335 Pa.Super 599, 485 A.2d 56
(1984).
Numerous cases have held that a failure to answer a Request
for Admission will provide admitted facts for a Motion for Summary
Judgment. Innovate Inc. v. United Parcel Service, 275 Pa.Super.
276, 418 A.2 d 720 (1980). See also Civic Center Investors v. REP
Inc., 59 D & C 2d 105 (1971); Central Counties Bank v. Robinson,
14 Centre L.J., 217 (1979).
Pennsylvania Rules of Civil Procedure 4014(b) states that the
matter is admitted unless within thirty (30) days the party to
whom the Re4uest f
or Admission is addressed gives a sworn answer
or objection . Non-answered Request for Admissions are established
as fact for the purposes of the instant lawsuit. See Civic Center
Investors, Supra at 106
The Plaintiff can rely solely on facts
admitted through the failure to respond to the Request for
Admissions. Only affidavits, depositions, or interrogatories are
prohibited from being the sole foundation for the Motion for
Summary Judgment. Rivoli Theatre Co. v. Allison, 366 Pa. 343
(1959). Since the facts in the Request for Admissions are deemed
admitted, Summary Judgment must be granted, if there is no genuine
issue of material fact.
In this action, as a result of the Request for Admissions
being deemed admitted, the Defendant has admitted the following:
Defendant has admitted receiving/applying for a Providian
National Bank credit account, #6011-9001-8661-2508. Defendant has
admitted that at the time he/she received said credit account,
he/she agreed to be bound by the terms and conditions of the
Agreement. Defendant has admitted to failure to pay Plaintiff the
outstanding balance of principal on account, which is in the
amount of $2.055.43. Defendant has admitted that no payments have
been made on account since 8-21-99. Defendant has admitted,
pursuant to the terms of the account agreement, responsibility for
Plaintiff's collection cost, including reasonable attorney fees,
and that Plaintiff's attorney fee of $411.00 is a reasonable fee
to collect Defendant's outstanding balance. Defendant has
admitted responsibility for finance charges on all outstanding
balances at an annual percentage rate of 19.99%. Defendant has
admitted being entitled to no offsets or credits from Plaintiff,
and that there are no facts relied upon as a defense in this
action. Defendant has admitted that the documents attached to
Plaintiff's Request for Admissions are true, correct, genuine, and
authentic and are admissible into evidence in any trial in this
action.
Given the above admissions, there are no genuine facts at
issue in this case. Further, as Defendant has admitted being
bound by the terms of Plaintiff's Account Agreement, Since
Defendant has admitted responsibility for outstanding principal
balance of $2,055.43 and attorney fees $411.00. When principal,
interest. and attorney fees are added together, it is clear that
Plaintiff is entitled to judgment against Defendant in the amount
of $2,466.43 plus interest from 8-21-99 plus cost of this legal
action as a matter of law.
The Defendant may argue that since it answered the Complaint,
thereby denying all the Plaintiff asked for in its Request for
Admissions, there was no reason to duplicate its answers.
However, in both Innovate and Ressler, supra, the Pennsylvania
Superior Court was faced with a similar issue. In Innovate, the
Defendant denied in a deposition prior to the Request for
Admission what the Plaintiff requested to be admitted. The Court
held that even if the deposition is at variance with the Request
for Admissions, the later must be answered. If the Request for
Admissions are not answered, then the non-responding party runs
the risk that the facts set forth in the Request for Admissions
will be conclusively binding on it. Innovate, 918 A.2d at 723.
In this action, there are no depositions which are at variance
with the Plaintiff's Request for Admissions. Similarly, the
Answers facts dueo ththe Complaint e Defendant's r failure o to crespondvto t the Requesttfor
Admissions.
WHEREFORE, Plaintiff respectfully requests that the Honorable
Court enter Judgment in its favor and against the Defendant in the
amount 559 2199, interest
reasonable contract attorney'.st
per annum from 8 fees in the
amount of $911.00, plus costs.
PARK LAW ASSO& S, P.C.
BY: U,
VALERIE ROSENBLUTH, ESQUIRE
C)
?r
C.
1
? L i t .I
?J L.) J
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 full)
PROVIDIAN NATIONAL BANK
VS.
THOMAS J. CALLAS
(Plaintiff)
(Defendant)
No. 7403 Civil. 19 99
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurrer to complaint, etc.):
MOTION FOR SUMMARY JUDGMENT
2. Identify counsel who will argue case:
(a) for plaintiff:
Address: Valerie Rosenbluth Park, Esquire
25 East State Street
Doylestown, PA 18901
(b) for defendant:
Address:
Thomas J. Gallas
1402 Bradley Dr apt. 312
Carlisle, PA 17013-1248
3. I will notify all parties in writing within two days that this case has
been listed for argument.
4. Argument Court Date:
Dated:
Attorney for Plantiff
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
PROVIDIAN NATIONAL BANK : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
VS.
THOMAS J. GALLAS
Defendant NO. 99-7403 CIVIL
CERTIFICATE OF SERVICE
Valerie Rosenbluth Park, Esquire, certifies that she is the
attorney for the above named Plaintiff in the above captioned
matter and that on October 26, 2001 she served upon THOMAS J.
GALLAS, Praecipe for listing Case for Argument, by mailing same
first class mail, to the person and at the address set forth
below:
Thomas J. Gallas
1402 Bradley Drive Apt. 312
Carlisle, PA 17013-1248
PARK LAW ASSOCIATES, P.C.
BY:
V RIE ROSENBLUTH PARK, ESQ.
ATTORNEY FOR PLAINTIFF
C)
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1'
C1 CID
H' li!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
Plaintiff
VS.
THOMAS J. GALLAS
Defendant
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO. 7403 1999
PRAECIPE TO WITHDRAW MOTION FOR SUMMARY JUDGMENT
TO THE PROTHONOTARY:
Kindly withdraw the Motion for Summary Judgment filed in the
above captioned matter.
PARK LAW ASSOCIATES, P.C.
BY:
VAL E ROSENB?LUTH PARK, ESQUIRE
ATTORNEY FOR PLAINTIFF
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