The URL can be used to link to this page

Home My WebLink About99-07624 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 COUNTY, COMON PLEAS OF PENNSYLVANIA CUMBERLAND AND First Select Corporation Plaintiff VS. ROBERT P. MARTIN Defendant NO-99- 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 Complarsonal yN or cby aan served, by entering a written appearance p attorney and filing in writing with the Court yoYuroudefareenses warned objections to the claims set forth against you without you and a that if you fail to do so, the case u may thProceed e Court without further judgment may be entered against you by notice for any money claied in the Complaint or the Plaintiff. You may oloseh money claimsor or relief requested by by property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A OFFICE ET FORTH LAWYER BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Courthouse C 4th Floor, mbslen PA County 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 First Select Corporation 5040 JOHNSON DRIVE PLEASANTON, CA 94566 PLAINTIFF VS ROBERT P. MARTIN 1089 NANROC DRIVE MECHANICSBURG, PA 17055-4468 DEFENDANT I NO. 9 9- 7 (- -2 /- 0'; ' 71 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 ROBERT P. MARTIN, an individual who resides at 1089 NANROC DRIVE, MECHANICSBURG, PA 17055-4468. 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 4168100002308276. 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 $17,508.59 as of 05/21/1999, plus pre-judgment contractual interest at the rate of 24.00% 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 $3,501.00. COUNT II 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as though set forth in full. 9. The Defendant received a monetary benefit, which was in fact appreciated by the Defendant. 10. The Defendant accepted the benefits. 11. By virtue of the circumstances surrounding the request for funds made, the Defendant knowingly requested the funds at issue and/or knowingly and voluntarily accepted the benefits bestowed. 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, First Select Corporation, and against the Defendant in the amount of $17,508.59, plus pre-judgment interest at the contractual rate of 24.00% per annum from 05/21/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $3,501.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. STATE OF CALIFORNIA COUNTY OF ALAMEDA JILL PULLIAM _ _ Y states that she/he is the Designated Agent of First Select Corporation and is authorized to take this affidavit on its behalf and that the facts set forth in the foregoing complaint are true and correct to the best of her/his information, knowledge and belief; that there is now due and owing from ROBERT P. MARTIN the sum of $17,508.59 plus interest and attorney fees; and that there are no deductions or offsets of any kind, except as are therein specified and credited in the complaint. She/He 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. Design, ate A tent JILL PULLIAM 4168100002308276 nnn LTI J i 11 ?. Fla SE?'LEC I EXHIBIT - 7-A-711, ACCOU`[T AGREEMEN Y. Your CH .45E amaum has !seen iram(ared to First Select Carparuion. Your CHASE acaaum was C!as.•d u LS<:1.1 t of the tramlcq and vvill4hrefare continue tote closed. Tnis um(has A;:ms<nt contain the terms that;avr your : sr^r S<le^.?e.ount the "Aapunt7. [n this Ar:-mL "vati and -your" mean ach C :an r its Olin. p<rean'who is liable for payent nom obligated an the Ac-cunt.rprv Lhe Arrant to us innead of C?,LSE. if d:a Ar_aant vutend do AS a itlint arou l we may ac an the as be." trrsfe:red to us, y car- i"ntictian of any joint accrunthalda:. Payments I Finance CFurges. As fang u'you have a balance outstanding on your Aecur.4 flame, coat;¢ art calculated AS Follows: Ta figure the fuunee chsrgn Cor ac`s billing o/cle, we multialy the av .rage daily balance an your l.ecaurt by jdaily pmadic rate. The daily periodic rte we apply u Yauc Acaaunt's Arutual Pare- Orie coal Tde:ntsrravtdedfar didcrr-Fit?rnu l Par :nu3 R Ites to be aeali<d to C Gerrit eameonenu of yours tstandingun[ tec:sts (the'Originat Terns•?. ICY gi 7 6slanee, we will apply the IawCt wds Atusual P:ro-age Rate to your rntir outstanding halsnea aviLhcut lasin our right to callece all amounts owing under this Agcemrnt _ 'rhe Fees We will eh <&,??T °u't e<f r° hue dgiar3epmsunadwhY 'Lie law ofyaurr teaaCr3id<Ce- wfu ea is lowerunc aCshe late charge will h<ss r. duelnsed is ya a Tie amoune ac the rewmed check charge will be as disclosed in W e will Charge your Accaunl a Ce for cacti rewmed payment check ([ewmed check ch its sate aCcazid<nt; svhich<ver is lower. . , y°r:r Ori ginal Terms, or the madmum rwmed check charge patieed by U:a law of Y° Ta the e•Cent provided in your Original Tents, and to the extent pemitzed by applicable law, in addition to ;'our obligation to pay Lhe outstanding to kcee an your Account plus interest and fee AS; disclosed F.erio, we may also charge YOU far any collection cosss Iva incnar, including but not limited to reasonable =mays y i Provided Car as award of acameYS fees and court Cora, such c.ovision as inCsrported herein shall apply eci and mutt casts. vai •our Original Te rms reciprocally to the prevailing Certain Rl parry he any lawsuit arising out of this of any Y --scat without losing our ri ght to enCosca it or any other on-tiVaiver oCCertalrs Rlghb. We may delay or waive enfarcmcat rnta provision of this Age--• ' provision lacer. Ap plicahle Lr, Sevenbilitr. Assignment. No matter where you live, this Agra:menc and your..=punt tar governed by federal law and by the law other state era. And designated as the applicable law in your Original Tcrnts. If your Ongial terms did nrm contain i' 3il u^ai "tan oFth<sir. ?.etnchhan? you and usyour Cray Account are governed by federal law and the law oEyour sure of rsidecee. This Agr - And not be cantrdired by evidence oCany alleged oral agreement If any provision oFthis Anset is ::e!C to :e utvalidarunentorablya° =data such snider toaall qns vision modified to confirm t or sumo oFyou payments. ? oatt law regeuirees Chat You receive no r of ueh an event to -Mt&'::.;h ;'a a or assignee may tnnfu usuc our tie crifircri or by filing a Cheaneiag aru=m( with die-states Secretary of State. Credit Repcrting?n l tdef toaCisaute anyinformation ve u: rpan. mgts. uc yauur Accou t, y'a a?-•t?'''si° -s it the credit addreso: First Select reproving Agency. Corartiom P.O. sox 9104, Pleasanton. Califomiw 9°355. YOCR B ILLRIG RlCF:TS . KEr-P THIS -.';OT[CE FO 2 _1:_LL•'RE USZ Tnis cootie-- cantairs important information about your rights and our reseowibilities under: Lot r:. Crc.:• ACL iYOdFr Us In case of Errors or Questions About Your Bill sheet at the following sd'r_•as: rust Select Cn . a_... rite us- .rnt We mar, ieeu =- vats ,a late: than 50 days site. we sent you Qie bill if you think yourhill is wrong, or if you rte ' nary irlarmadan about an entry ssYaur bill •• Carror-tiaa P.O. 30.19 104. Pksm[oa CA 9-355. %V - to us ss sacn as coibk• . . an which the-.- rcar problem. appeared You can telephone 0, but doing so will not prerer•••e vw: in your least, give us the following: Your name and Account number. O.doll n- da.:ibe the item vats car not star sue • Tne dollar unountaFthe suspected env.. • Lhe rare ande suxa4 if yours. why you believe there is an crcer. If you need more inicrnI -a Your Rights and Ou r Responsibilities A n a r We Receive Your %Vr men Notice _• u:[ei4her acre...:::... or_nolain why vve We mars. acknowledge your lace within 30 da}s. unlesawehavecar. s:ed We error Sy'ht . tVie d_. r': s•'?="' believett•e billwaseon.ecru?mer eve rmeive Yaur 1<rc,we<arnat a coil. car rpar. year s !_queme s :o any Imoun you querian, ind hut yo tmanc: v<srie. = =•ount while we a cv invrs:igatirg, utyou are Hill charges We can apply any unpaid amount agaiats: your erdit line. You do Fiat hive to pay any 9 obligated to pay the parts °[ the bill that car rat in quc[iaa If we rod Chu we made a mistake on your bill ,hyouave w to will not make h up hive the to mpayiss<C any fuunca charge related to d cucialn a thereat If we did not mate s mizcat- You „aunt to either case, a ill srnd ye?us vshen it 5n:lly is Payments an the wi querirn< C (na\ t??'rf ?'rLL AS delinquent. However ifoura your Inll.a may have to pay finance ehargea and you will o starmenta Can tell _wane we repart you to that you qu theurount you owe and Lhc due that a is due tf you fail to pay the Amount we think you ovve, you m to t`at C:e mama hss been stated benveen us ` does not sate:/ you and you write to us svittin l0 days telling WthRiti s?C-11 t ana we sport we ' And we must tell you the name at anyone we repafed you to. Y Twe do not follow these roles, we cannot collect the Cuss S30 of the quenianed amount even if your bill V= Corset Special Rule-for Credit Card Purchases -• •• tad you have tried in good faith to ce rcect the L a oarmust rhssed with Yaur C:'..:5E = e=:r he purchase shPia must IF you have a problem with the quality of goads and'serviess that you pu i<a problem with the merchant, you may not hive to pay the rrnaining amount due an the goads err --=: car if coot CtHASE mailed yt the advertisement or, . h ir wiur home within na[taPP YidOdera < onC[HASE owe or upas of your --r. cat mailing address: and at! the have =.d: the your ave hem thanurchase se in These lihommitations st to do far the property or services. :ate moor P of F 0 U U fir= I - r i u> c. V• N C.: L O? J CJ _1=l :J r? r?l zr- c? SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-07624 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS MARTIN ROBERT P R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MARTIN ROBERT P but was unable to locate Him in his bailiwick. He therefore returns the CIVIL ACTION NOTICE NOT FOUND , as to the within named DEFENDANT , MARTIN ROBERT P DEFT. NO LONGER RESIDES AT ADDRESS STATED, ATTY UNABLE TO PROVIDE ALTERNATE ADDRESS PRIOR TO EXP. Sheriff's Costs: So answ s? Docketing 18.00 Service 6.20-G NOT FOUND RETURN 5.00 R. /Thomas Kline Surcharge 8.00 Sheriff of Cumberland County .00 37.20 PARK LAW ASSOCIATES 01/21/2000 Sworn and subscribed to before me this -31.-f day of -2 &IrO A. D. L1?<1 P o onotary F r i t _ U g a go - x • ? j , a; S - . t, x 82 .. - - s?7?l11 (?? :--? ,< ; ` ; t , . x. . ,,._;: _.; 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 VS. ROBERT P. MARTIN Plaintiff Defendant ORDER : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : NO. 99-7624 AND NOW, this 19 ' day of gr+„1i ,2000, upon consideration of the Plaintiff's Petition and upon Motion of Valerie Rosenbluth Park, Esquire, it is ORDERED and DECREED that the Defendant may be served in accordance with Pennsylvania Rules of Civil Procedure, by mailing a true and correct copy of the Complaint to the Defendant at the Defendant's last known address by both certified mail, return receipt requested, and by first class mail, postage paid. A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. BYE COURT: / AA- ?t ? 1 v? ?i. 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. ROBERT P. MARTIN Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 99-7624 PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of the Plaintiff by its attorneys, PARK LAW ASSOCIATES, P.C., respectfully represents that: 1. The Complaint was filed on DECEMBER 21, 1999. 2. The Sheriff of CUMBERLAND County made a "Not Found" return of service of the Complaint on JANUARY 21, 2000. A true and correct of the sheriff's return of service is attached hereto, made a part hereof and marked Exhibit 11P-111. 3. The last known address of the Defendant is 1089 NANROC DRIVE, MECHANICSBURG, PA, 17055. 4. Subsequent to the Plaintiff's attorneys' receipt of the Sheriff's "Not Found" return, Plaintiff's attorney made the described efforts to locate the whereabouts of the Defendant as indicated in the attached Affidavit of Investigation. 5. Despite Plaintiff's attorneys' inquiries, the Plaintiff has been unable to locate the Defendant. 6. The Plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff's attorney shall file an affidavit of service showing service of the Complaint as set forth herein. PARK LAW ASSOCIATES, P.C. BY:_ VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF j? Ll 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 Plaintiff 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. VALERitE ROSENBLUTH PARK, ESQUIRE SHERIFF'S RETURN - N07 FOUND CASE NO: 1999-07624 COMMONPIEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT CORPORATION VS MARTIN ROBERT P R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MARTIN ROBERT P but was unable to locate Him in his bailiwick. He therefore returns the CIVIL ACTION NOTICE NOT FOUND as to the within named DEFENDANT MARTIN ROBERT P DEFT. NO LONGER RESIDES AT ADDRESS STATED, ATTY UNABLE TO PROVIDE ALTERNATE ADDRESS PRIOR TO EXP. . Sheriff's Costs: So answ ` s? Docketing 18.00 Service 6.20 NOT FOUND RETURN 5.00 R. /Thomas Kline Surcharge 8.00 Sheriff of Cumberland County .00 37.20 PARK LAW ASSOCIATES 01/21/2000 Sworn and subscribed to before me this A. D. day of Prothonotary i L 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 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS VS. ROBERT P. MARTIN Defendant : NO. 99-7624 CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a) A check of the local telephone directory shows that ROBERT MARTIN does not have a telephone number listing at the address of 1089 NANROC DRIVE, MECHANICSBURG, PA, 17055. b) A letter addressed to the Defendant with the notation typed thereon, "Address Correction Requested, Do Not Forward" was not returned by the Post Office. C) A letter addressed to the Office of Voter's Registration shows ROBERT MARTIN is a registered voter with an address of 1089 NANROC DRIVE, MECHANICSBURG, PA, 17055. The office's response is attached hereto, made a part hereof and marked as Exhibit "A". d) A letter addressed to the Office of the Board of Assesment shows ROBERT MARTIN is not the owner of the property at 1089 NANROC DRIVE, MECHANICSBURG, PA, 17055. The Office's response is attached hereto, made a part hereof and marked as Exhibit "B". e) A letter addressed to the Postmaster shows that mail addressed to ROBERT MARTIN at 1089 NANROC DRIVE, MECHANICSBURG, PA, 17055 is not delivered. The new address is given as 375 CLAREMONT DRIVE, CARLISLE, PA, 17013. The Postmaster's response is attached hereto, made a part hereof and marked as Exhibit "C". 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. PARK LAW ASSOCIATES, P.C. V BY: I VAL IE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ARK LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLUTH PARK' ROBERTE.ANGST- 'ALSONRNRRRNI MR 'ALSONIE MRRRAR February 16, 2000 Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: ROBERT P. MARTIN 1069 NAtJROC DRIVE MECHANICSBURG, PA 17055-4468 OUR FILE NO: 919069-1 Dear Sir/Madam: TELEPHONE (215) 3-08.5200 PACSIAIII.E (215)348-4015 I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the address for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Vary truly yours, PARK LAW ASSOCIATES, P.C. BY : Tracy lWafttiamms Legal Assistant Enclosure Name of Person: ROBERT P. MARTIN Current Address: )ORII ?1Mfrr' 1?v Date of Registration: f11Qv $ 1, (, I 0 Date of Birth: \p - (o - N? Previous Registration Address: IfCI- : ,f? can o? ? , PARK LAW AssocIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET. SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 VALERIE ROSENBLU II PARK. ROBERT E. ANGST. .ALSO MEMBER NI BAR .AL MEMBERMRAR February 16, 2000 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: ROBERT P. MARTIN TELEPIIONE (215) 748.5200 FACSIMILE (215)3484015 Dear Sir/Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 1089 NANROC DRIVE MECHANICSBURG, PA 170554468 Please note the name and address of the owner below and return this letter to me in the enclosed self- addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES, P.C. BY: Tracy Williams Enclosure Property Address: If " 89 NANROC DRIVE,MECHANICSBURG, PA 17055-4468, Name of Owner: e rr 13A G n. "? Address of Owner. Fal ) O5 c- .n h,? n Deed Book and Page No.: k -P ?ial?wwr?la?swli?®>®nilma'?nnl?t w 0? 93, VALERIE ROSENBLUTII PARK' ROBERT E. ANGST' •AEMIMEMIIERNIIIAR .A MEMOERRMR Post Master United States Post Office MECHANICSBURG, PA 170554468 PARK LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 February 15, 2000 TELEPHONE (215)348.5200 FACSIMILE (215)3484015 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Ourfile#: 919069 NAME: ROBERT P. MARTIN ADDRESS: 1089 NANROC DRIVE MECHANICSBURG, PA 170554468 ?r,?r0 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney): 3. The names of all known parties to the litigation: First Select Corporation VS. ROBERT P. MARTIN 4. The Court in which the case has been or will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: CCP 6. The capacity in which this individual is to be `er eevd: Defendant THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CIIANGE OF ADDRESS INFORMATION OR BOVIOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION IMPRISONMENT OR O TO AVOID PAYMESULT IN C INCLUDING A FINE OF UP TO NT OF THE FE MINAL FOR CHANGEIO ADDRESS INFORMATION OF NOT MORE 0THAN 5 YEARS. (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of I gal process in connection with actual or prospective litigation. K &Zk 25 East Slate Street V eric Rosen luth Park, Esquire Doylestown, PA 18901 FOR POST OFFICE USE ONLY _No change of address order on file. NEW ADDRESS OR BOXHOLDERIS REGISTERED ADDISS Not known at address given ?5 l?/e e mow7` I?r. ?,4 /poi 3 Moved, _left no forwarding address. POSTMARK: WHAT such address WHAT COUNTY IS THIS ADDRESS IN? C63 THIS IS AN A17C•MPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 11; ; .j i ir•.S PLAINTIFF'S_ EXHIBIT:' , MpR 0 g ?? 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. ROBERT P. MARTIN Defendant : CUMBERLAND COUNTY : COURT OF COMMON PLEAS NO. 99-7624 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. PARK LAW ASSOCIATES, P.C. BY: VALERI OSE PARK, ESQUIRE ATTO Y FOR PLAINTIFF r aN tr. z r WO d -?,- C,7= Up ? 'L c J? 1 bt,: ;lJ w • +' U O .J U VALERIE ROSENBLUTH PARK, ESQUIRE PARK LAW ASSOCIATES, P.C. ATTORNEY I.D. ()72094 25 E. State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. ROBERT P MARTIN Defendant NO. 99-7624 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did serve the Defendant, Robert P Martin, at his/her last known address located at 1809 Nanroc Drive, Mechanicsburg, PA 17055, by United states certified mail on 05/16/00, Article No. 7099 3400 0008 6905 3599, Return Receipt Requested, Postage Paid, with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter with the appropriate notice to plead as set forth in Pennsylvania Rules of Civil Procedure. Service was accomplished in accordance with Pennsylvania Rule of Civil Procedure. The Defendant received said notice on 05/19/00, as noted by the certified return receipt card attached hereto, made a part hereof, marked Exhibit "A That in accordance with the order of Court, Valerie Rosenbluth Park, Esquire did serve the Defendant, Robert P. Martin with a true and correct copy of the Complaint by United States Mail, Postage Paid, First Class on 05/17/00. The Certificate of Mailing is attached hereto, made a part hereof, marked Exhibit "B". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 PA C.S.4904 relating to unsworn falsification to authorities. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF Pursuant to the Fair Debt Collections Act, it is required that state the following will be used attempt to collect said purpose. a debt. . Any information ° SENDER: I also wish to receive the ttr? 1 , : na m:3.4a. nd p. kkn%iny serVkea (for an •Rmt?o u r wnaw.da.uontlrmereedeY.rampmewetanabena8 extra fee): y o u ¦ Aaacb aYa =b ant frontof eN meAoleoe, W m the Wdt ilepmi dm not 1. ? Addreswe?0 Address E Pvew"afthimRooWReptefeemaw d.?.bwmtheeod,M,6r, ? 2.0 Restricted Delivery e The el Realer VAN Mm to wtsorn lr¦. iud. w.. d*nmd and the date Consult postrnaster for fee. 3. Artlde Addressed ro: eO/Xif P4 7141h,7 Aeq Aanfz brie IV&kant?shm( i 70SS-Cfb 5. R•g??elv d By. (Print Name) U ?{Joo 5. Signatu e: (Addressee orAgeno x'4 ? `l? c? ?cf 1 S PS Form 3811. December 1894 704q 3140 aa5 9 ?O 57357i ! 4b. Servoo Type ? Replstered B'Certtfled ? Evreas Mall ? Insured ? Rd=RO egtforMerdraMlee ? COD 7. Date of DoUnry -19-D6 8. AddremWs Address (Only ff requested and fee is paid) tosssaeaoag oomestic Retum Receipt Ir or r m or Ln Postage O or CeNeed Fes CE3 Return Receipt Fee (Endonamenl Peeutred) O C3 3 Res1XV(ited 00'M (End Mweet Roo heal C O Tote, Postage a Feel O m Nemape}se nar,CCNO -r 1 ( J / ? Er- Ir . .- ....... .. . . SireoG?tppXt 1/.V..... .. C-3 . z; iiitnta. ZtP•?n! " o Q n u vi m d o Q L= N N = o ¢ 2 v'qp- u b 'a8 x a E 2-4 -„ q 3 E n O N C N d d m x - O m q O ? q m V a g p '? N G G C m'rn33 ¢?? IL E? m oD d•q=Q'C b¢=UU c® d 3 m u 'O e? F v N G c ?o El ldihkl ? N d ddD a+ y u cDN rl N t S 610, A zm .:7 Y , NJ VY t 2 C h 'iv N :, b ? ?.y min s'` ??HIB[T ' { „m ,TO aO c v 'a 4 N r g A co Q N b g 2E N?9? ° 'a W?52 C s?? a a9? ' 3 aS i3 r nt3P5 J„a gm 3 ? - c° r .k,3 <c ==s.3m. U 099W2D > V,T. ]2?? 1 j§. 0 O q 6?'?V1b v? Qd ]eoE?U? ? I F i c i L LLIC ? ? ?'s = ? a al L r: r - ' r U O I jr •FIRST SELECT CORPORATION 5040 JOHNSON DRIVE PLEASANTON, CA 94566 Plaintiff Vs. ROBERT P. MARTIN 1089 NANROC DRIVE MECHANICSBURG, PA 17055-4468 Defendant NO. 99-7624 Civil Term ANSWER 1. Admitted. 2. Denied. Defendant resides at the Claremont Nursing Home, 375 Claremont Drive, Carlisle, PA 17013, where he is a patient-resident. 3. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 4. Admitted. 5. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 6. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 7. Denied. The amount of $3,501.00 is unreasonable. Furthermore, this averment pleads a conclusion of law and requires no further answer. 8. No further answer required. •r 9. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 10. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 11. Denied. Defendant, after reasonable investigation is unable to determine the truth of this averment. The same is therefore denied and proof demanded at trial, if relevant. 12. Denied. This averment pleads a conclusion of law and requires no further answer. NEW MATTER 13. Defendant is an incapacitated person, lacking mental capacity, due to his being affected with Alzheimer's disease, for which he is currently hospitalized and has been for some time. 14. No court has ever adjudicated Defendant to be an incompetent. 15. Defendant has no guardian appointed for him, nor a guardian ad litem. 16. This action cannot proceed until a guardian or guardian ad litem is appointed for Defendant pursuant to Pa R.C.P. 2056(b). 17. Debra Baker is the attorney-in-fact for Defendant under a power of attorney heretofore executed by Defendant. J ? WHEREFORE, Defendant requests the court to dismiss the Complaint. Yoffe & Yoffe, P.C. Attorney for Defendant and Deborah Baker, Attorney-in-Fact For Robert Martin 214 Senate Ave * Suite 203 Camp Hill, PA 17011 Martin\answer l1- i, J x.21 lr 1 1 `. f . ? Itll it , t `? O U I VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72099 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215) 398-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT CORPORATION Plaintiff VS. ROBERT P. MARTIN Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 99-7629 PLAINTIFF'S RESPONSE TO DEFENDANT'S NEW MATTER 13. Denied. Plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of this averment and the same is therefore denied. 19. Denied. Plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of this averment and the same is therefore denied. 15. Denied. Plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of this averment and the same is therefore denied. 16. Denied. Plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of this averment and the same is therefore denied. 17. Denied. Plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of this averment and the same is therefore denied. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff for the amount requested in Plaintiff's Civil Complaint. Respectfully submitted, PARK LAW ASSOCIATES, P.C. BY: VA ERIE ROSENBLUTH PARK, ESQ. 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 Plaintiff in the forgoing matter; that she is authorized to take this Affidavit on its behalf; and that the facts contained in the foregoing Pleading 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., §4904, relating to unsworn falsification to authorities. VALZ'E ROSENBLUTH PARK, ESQ. it .'I v C L.J y l n 7 Eli =? C]Ll -'J ?= v U 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 COPPOORATIOf VS. ROBERT P. MARTIDefendant Valerie Rosenbluth attorney for the above that on June 12, 2000; Plaintiff's Response to Mail, postage paid, to below: CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 99-7624 CERTIFICATE OF SERVICE Park, Esquire certifies that she is the named Plaintiff in the instant action and she served a true and correct copy of a New Matter, by mailing the same by U. S. the person and at the address set forth Attorney for Defendant Deborah Baker, Esq., Attorney in Fact for Robert Martin, Esq. 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 PARK LA' ASSOCIATES, P.C. BY: VALE IE ROSENBLUTH PARK, ESQ. 1 C C) L CV 1J ?% CJ b7 7 t , LL... ' `? G C_'. . • ji J? ? :?. ?c..i - - r,.' ''= z. ;??2.1 C_l O J U 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 CUMBERIAM, PENNSYLVANIA First Select Corporation Plaintiff VS. ROBERT P. MARTIN Defendant NO. 997624 SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: Kindly note that it has been suggested that the Defendant in the above-captioned matter has filed a Petition for Bankruptcy in the United States Bankruptcy Court, and thus this case must be stayed. Respectfully submitted, PARK LAW ASSOCIATES, P.C. BY: V ERIE ROSENBLUTH PARK, ESQ. `` v. l'J c+: