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Home My WebLink About99-07625y 0 M, -L c•J V V >r t t t?l 1i1 htry' ?{Y r ?? , hXyr? 4 Cl X? ?y <CJ al3,,a, r ,' 4 i 'f 9N f?f'. i r yr d?? ? 1> VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROVIDIAN NATIONAL BANK Plaintiff VS. GUY W. BURFORD Defendant NOTICE NO. W -'y(-? aiuV -? 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 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 GUY W. BURFORD 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065-1604 DEFENDANT I NO. /c 7? ?S eu :? T« 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 GUY W. BURFORD, an individual who resides at 411 N BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065-1604. 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 4428232272302782. 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 contractual amouintof $8,086.39 as of 08/25/1999, plus pre-judgment c at the rate of 21.90% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $1,617.00. 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $8,086.39, plus pre-judgment interest at the contractual rate of 21.90% per annum from 08/25/1999 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,617.00, less payments made, plus costs other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P BY: ROSENBLUTH PARK, h5UU1KLi 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 K00REMAN , 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. I Designated Agent PROVIDIAN NATIONAL BANK GUY W. BURFORD 4428232272302782 929864-1 i C:1 ! i ;??? - IL a ?w 'LxI VV Yv w. '.V?PRDV I DIAN ( 411110ul promos National Bank VISA® or MaslerCardsl Account Agreement for Guy W Burford 1the'Accounl'). The Account allows you to make purchases by usmri Your VISA or Mastro and card 10 yo You a as s an wherever l is honored and to gel cash advances hom us a any The other part may please review lhrs document and keep d with your other important ,cerchecks may also te provided (th contains heeve al way to useto use t nt In vi Agreement •you and'your' mean Bnancal mstitulion and hom Automated Teller MacWne this used ocenN torlpersanal, tam hi. h0useholQ erne charitable poiposes and not for any business oecammercal puatryosel Any sretofthm Accou laelh3115onshtute billing a of the terms of IWSay be Agreement. You aM we agree as folaws. Payments. You w41 receive a monthly slalement sharing your oulstandmg balance Payme nt on this Account is required in U S dollars (checks must be payable at a U S office o the n date in payments on any other payment instructions on your monhN statement Convenience checks ens rates The payment due will be 2°h merits accordance other account you have with us or our Or s menl due as shown on your sltson your r the Account or payment due make pay ^Y check rs drawn on) for al least the pay aM other checks we rssue to you may not be used to make pay y . and may include the amount by of which lie new balance exceeds your creel hire However, the paymen 15 et pine, be applied of he new balance shown on your statement plus the amount of any past due payment menl due will be the amount t of the new balance) ad as your a single Account is past payment due and n none of above it the wtll credit before doing so if your payment is more than the payment due it will be treated due will not be less Than 515 (unless your hex balance is less than efof in which case the pay we may require higher minimum payment id ,n full' or marked with other restrictions, without losing our right to celled all amounts axing under this a , but we will irony you , future payments due. We may accept late f pantal payments, or payments markedpa harges into accrue on a debit when it is included in one of our daily Agreement. ry .,,....^<n lava navment or credit Your Account has the followin balances Thee rp hype, which consists afyouruish Purchase rice Finance Charges. Except as described in the Grace Period for Purchase Balance section of fi q9T <h Arfuance BalanSeS which consists of balances that you lensf prNe Thaour t Accou tthe urther nonc alancas Thal we Iransrena yv?. •^?•- the he • menls "rent' without fe. zsThe of Purchase ce as age I" aenarily be applied first to the Balance wish khvast A Annual Pe en aas: t to apply pay aHe ro, and hen to am/ remaining Balance. We reeserve the righ I 'c a Is en lol funds eleetron!wly trot ms l ed to oher lenders to Iransfen balances Balance dolt as or 0 0' no Ea and mer ash Advance a Cu?stan C low mmailed to you et yarrrequesl,ras of s?evensaday! pay to rel. Other cashm advances lee incouulhl a eeident fled as cash es chec ash k ks ante 'no advance checs ade payab Y deb C ,is presented land CaOsh e'dy are1,nces eachyday and are sthen posted on he last day of he bi Lng an e?There h no grace US he a ash Advance, Finance charges are custom cash advanceso ethar cash advances. ryc in calculating The To figure the easy finance charge for each type of Balance, we start with your previous days Balance, add all debits a daily peno6c rate (see following Paragraphs Of Ball). The finance charge If each type of Balance is then added to and included in that cCZY e f Balance. a treat the creel balance or zero. We del mice the total finance charges on balances for the billing cycle by addng together the finance charges for each typ e Balance for each day had it he billing es, i nc be made for any transaction or payment that would have affected the finance charge calculation in m a prior billing cyan had it been posted in Thhal ryes. The on the date the . applicable finance char9 an adlustment w in the bills the period ty each cl averather rate raa deli than Ibahnce11ha1 iscnol zero by Ihefnumlber of cloys. ^9 cycle and h applicable daily penoee rate for such a transaction will be the rate nlaect for tthe?^rent billing c Your statement includes an average daily balance for each W of rate to obtain schargle to&,. and then add the sublotals together to determine your total finance charges on balances to the b4 cycle. If a cash advance transaction fee is charged, that amount is The ANNUAL PERCENTAGE RATE (APR) for purchases is 21.9%, comesponding to a daily per.cdic rate of 0.060W°•6. The ANNUAL PERCENTAGE RATE If cash advances is 21.9%, conesporldng to a daily periodic role of 0.06000°.6. If your payment is received tale twice in any 12-month period, the APR for purchases may increase, to but a will daily periodic exceed 2 rate 10° of h. 0 0654a% corresponding to a daily periodic rate of 006546%; and the APR . cash advances and custom cash advances may increase, but will not exceed 23,9%6, canesW^din9 Your Account may be eligible for lower APRs after you have met he terms or this Agreement for three months. I fully you contact us, we will review your Account lly paid ddetermineuring your the rycle cycle.iry fa no t Grace Pedod for Purg cycles with no previous balance, or when the previous balance was APRs. chase Balance. New purchases polled to your Account in bilkin the total new balance in full by the payment due dale shown or pay will pay no financecharge on such new . purchases if you nod in which such purchases may be repad without Incumng a finance charge. to incur a limos charge until the shad ai the next bills ry cy You your slalement. New purchases posted in any other tilling cyan incur a finance charge, and here rs no pro yy rig ask us to replace; each relumed payment check; each check ou write on your Account that we velum nrpad' lineheveon If our Oder which your Account is delinquent (tile charge); and each billing rycle within whoa your balance exceeds You Fees. We wi8 charge your Account up to SO la: each Card you yy A cash advent a renewal of such an equorder,est each btlling rycle caithin Accou bahrtatements Cam? firs, sent to for each pshmadvance Ira^sacl'onlmsaderion your Acwu charge a handling fee of 521f e bankruptcy. or ISO nt is closed. If you copies of fee of 3% (minimum 55), rhch h a FINANCE C s HARGE, may 9 with any n of this Agreement uPon your ste your death, bankr under . ity obligations Of . DetauR You will be in default: it any inform at dionuyou provided us proves to beIncomplete a untrue; or if we nee e perform a and use am/ remedy we M titan is filed by or against you: or if we believe in good faith that you may not pay a g es section of this Agreement, even i not pay other debts we; if a bankn?try pro Agreement. I Youare m default we may, wlhoul funkier demand a notice, cancel your creel pnvdegas, declare your Account balance e due and payola, imoNency: dYW do In en have. In the event of your default, the ext nding balance on your Account shall continue to accrue interest at the APR(s) disclosed in the Finance CMrg dit line based on information we obtained from you or your creel record hav e. II you send us a large paymei e filed suit to tdlec 1 the amount you ow Crca Llne. Your credit line is specified from time to time in a separate notice. We may increase or decrease your cre Y Your available creel a namely the eHerence between your credit line and your Account balance (including transactions made or authorized but nor et Se your . Y wem check, we may limit your available credit while we confirm hell he check will clear. For certain transaclam, available credit may be less. You will not use yauaAuaunnnrs gn)?II chary refine honor, envy lensaclan whch world cause you to exceed your available creel. win he soil, we will pay your reasonaW Promise to Pay. You promise topay us when due all amounts borrowed when you or someone else use your Account (even if the amount charged exceeds Y De Iramactans end charges to Your gccounl, and coileclion costs we incur including, but not limited to, reasonable altomeys fees and court costs. (11 you items ousted to atlome/s lees and coon costs.) rt of his Agreement and add or remove requirements. If a change is made to the Finance Charges see to Changes. ABer we Provide you am/ mtice required tr9law, we may change any pa Nis Agreement, the new financa charge cakuhtan until appy to Your entire Account balance from the effective date of the change. Changes will apply to balancers that tide rs the transactions will be converted Ira U S. eaters generally using eith, -_ml talon the dale of the chance, and will apply whether a not you continue to use the Account. before the transaction n her than inc realareased ,by three percent (3%). If a credit is subsequenty,given for a rramaclx Foreign EschangaCurrenry Conversion. If you use yet Car beforath itr a currency other than processed, inc d for I the day u be deceeased by the same percentage. The currency conve onversion cote used on the conversion dale may diller from the rate m effect on the dale you used You Card. YOU agree to accept ovemme ased le tele or Qi) wholesale market role in will shOWnOnI convened amount in U.S. dollars. notice to Yau, or without notce d permitted W law. If your Card is canal The Card; Cancallatlon. You may cancel your uedil pmd11, s al any time credit pr fie es m time after 30 days and destroying Ile ce to po^ n olxhis Agreement slew I remain eHec You in t, reserve the nghl not to renew the Card. We may cancel he Gard and you r credit pm'w91 continue to be due, and all ocher applicable provisions unused checks we have issued to yo not renewed, fimnce charges and ocher tees well wnanue to be assessed, ou may no longer write checks on your Acceunl, and you should destroy any marl Of income. Upon our i lermimle your anal privileges, a if we cancel a do rat inner he Card, yt ou change your name, home or mailing address, telephone numbers, employ. the tight 1 Personal Infotmatlon; Documents. You will provide us al least 10 daysoutoe Y ou will wife us additional financial inlormalan. We reserve is attic to obtain information from others, including credr reporting agencies, and eleo provaa'tanyour address a inform requesl,y M oher nfonnalbnwlh our atfihates_ li r m nl 1 I lim n t ^I ire not to share cre ml^^ withanaffiliates. if about you Account to others. W m oue crest report that may reflect on your credit may be submitted to tae credit repa6ng agerores ng thCY rd,?PUe°^adecar do not fulfill your obligatons under tars Agreement, a nega yy .? sepaele Irom your Card. I ou 933.721. So we e car Cusomer5arvice; Unauthorized Use,Loss, orTheH of Checks or the Card. Each Card mustbe signed on receipt YOUeraspsblefor Safuardcalling prize ttr you Fran the H, and keeping your PIN .8W Number ('PIN', which provides access to Automated Teller Machines) and arty checks issue f Card, PIN, a am/unused checks are lost or slaen, or Ihae (here maybe an unaullonzed transaction on your Account. Y will WPly Iry i's by your 1048 46 (Continued on reverse) (5846-0698) 4428132272302782 -?? -wan Immedately act to limn losses and hab lyp . you will phone us even though you may also richly us in writing Your haohry, for unauhorized use occurnng before you noliry us is limited to 650 If your. report awe suspect unauthorized use of your Account, we may suspend your credit privileges until we Iesohve IN problem to our sauslacwn or issue you an" Card If your Card is lost a stolen, you will promptly, destroy all checks in your possession To improve customer service and security, you agree that your calls may be monitored or recorded Merchant Relations. We will not be liable if any person or Automated Teller Machine refuses to honor the Card oraccept your checks, or fails to return the Card to you We have no responsibility for goods and services purchased with the Card of checks except as required by law (See Special Rule below ) Certain benefas trial are available with the Account are provided by third-party veMOrs We are not responsible for the quality, availability, or results of any of the services you choose louse Stop Payment Orden, ll you wish to stop payment on a check, you may send us a stop payment order by writing to us at our address for customer service listed on your statement. You can make a slop payment order orally by calling the number list on your statement When you make a stop payment order, you must provide your Account number and specific information about the check. the exact amount, the date on the check, the name of the parry to whom it was payable, the name of the person who signed it and the check nurri You will be asked to confirm an oral slop payment order in writing We may drsreeaid your oral order f w do of none y ed car iron conhmal on within two weeks after n t hie , or d we have not received an a description of the item so that payment can be stopped The order will not be enwive d the check was pad by us belore we hail a reasonable opportunity to act an the order We mayor ilhout habhy, disregard a written stop payment order so months after recept unless it is renewed in writing Standard of Care. Because this Account involves bath credit card and check transactions which are processed through separate national systems before the transactions are consolidated by us, and because not every check and Card slip will be sent to us, transactions in your Account will be processed mechanically without our necessany, reviewing every item. Our processin system will cal our atenhon to certain items when we will examine. We will examine all transactions when you report [hat your Card or checks have been lost or stolen We do not intend ordinaorij to exammerall items, andwewillnotbe negligenhrwedonoldoso This rule establishes the standard of adnary Care which we in good faith will exercise in administering your Account. Because of our limited review, and because neither your cancelled checks nor Card transaction slips will be returned to you with the monthly statement, you should be careful to enter all checks in your check register or otherwise keep a record of them You should also save your credit card cash advance and purchase slips You agree to check your monthly stal m nr=giminst your record to nohN us immediately of any unauthorized transactions or ror$ and Waiver of Certain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. You waive: the right to presentment, demand, protest, or notice of dishonor; any applicable statute of limitations. and any right you may have to require us to proceed against anyone before we file su9 against you. Applicable Law" Severahlllty; Assignment llo matter where you live, Ihh A regiment and your Account are governed by lederal law acrd fn' New Hampshire law. This Agreement is a final expression of the agreement behveen you and us and may not be conlnddad qby evidence of any allegedaal agreement. If airy pravsion of Ihn Agreement is held to be invalid or unenforceable, rya end we will consider that prwisron modified io conform to applmable low, and the rest of the prai"" s b Ile Agreement will arty shit be enforceable At any time after we determine in good faith Thai arty proposed or enacted legrslatwn, regularay action, or cial decrsion has rendered a may render arywe may. provisions of this Agreement invalid or unenforceable, or impose any ircreased lax, reporting requirement, or other burden m "Inv tron waft such prov"of a its enforcement, we may, ocher at least 30 days mike to you, or without notice if permitted by law, cancel the Card and your Credit it"' "gas. We may Imnsler or assign cur right to all or sane of your payments if state law requires tha ee t you receive notice of such an event to protect the purcha set of assign, we may give you such hohce by filing a financing statement with the states Secretary of Slate. Notices, Other notices to you shall be eHoclrva when deposited in the mail addressed to you at the address shown qn our records, unless a longer notice period is specified in this A regiment or bylax, which period shall elan upon mailing. Nolte to "' shall be mailed to our addressee customer servke on your statement(oralher addresses we may specify and shallbeeffective when we receive it. YOUR BILLING RIGHTS-KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act Nadly Us In Cause of Errors or Questions About Your Bill. If you think your bill is wrong a if you need more information about any transaction on your bill, write us on a separate sheet, at the address listed in the Billing Rights Summary on your bill. Write to us as soon as possible. We must hear him you no later than 60 days after we sent you the first bill on which the error or problem appeared You can telephone us, but doing so will not preserve your nights. In your letter, give us the following information: -Your name and Account number. - The dWlar amount of the suspected error. - Describe the error and explain, if you can why you behave there is an error. If you need more information, describe the item you are not sure about. Yourilghts end Our Responslbllities After We Receive Your Wdhen Notice. We must acknowledgeyour letter within 30 days, unless we have corrected the error by than. Within 90 days, we must either correct the error of explain wiry we believe the bill was correct After we receive your letter, we cannot try to collect any amount you queslion, or report you as delinquent. We can continue to bill you for the amount you question, inducing finance charges, and we can apply any unpaid amount against your credit true. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. If we find that we made a mistake an your bill, you will hot have to pay any finance charge related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to makeup the missed payments on the questioned amount. In either case, we will sendyou a statement of the amount you axe and the date that it is due. If you fail to pay the amount we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you while to us within 10 days telling us [hat you still refuse to pay, we must tell anyone we report you to that you question your bill. And, we must tell you the name of anyone we reported you 10. We must tell anyone we report you to that the mailer has been settled between us when d finallyis. If we don't follow, these rules, we can't collect the first S50 of the questioned amount, even if yourbili was coned. SpeddRule for Credit Cad Purduses. If you have a problem with the quality of the property or services that you purchased without credt card and you have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or services. There are two limitations on this right (a) you must have made the purchase in your have state, or if hot within your home state, wilco 100 ratio of your current mailing address. and (b) the purchase price must have been more than 550. These limitations do not apply if we own of operate the merchant, or if we mailed you the advedisement for the property or services. xr I,r Complete this short form and return it in the postage-paid envelope provided. 30-Second Response Certificate -- Yes, I want to accept your invitation for a custornized VISA' Gold account! I have read the terms on the back of the brochure. I agree to be bound by the Account Agmernent (which will be nailed to me before- my VISAeerd Is issued) and to repay principal, interest and Interest thLmon, except that I will have no Obligation if I retum the cod(s) and dudes unused and amccl my account after reviewing the Account Agreement. Guy W. Burford 5 3 2 4116 5 411 N. Baltimore Ave. MT Holly Spgs, PA 17065-1604118 2723HI IC323 GX027 OHCL VRM NCFB SDBD BDBB 13T 723-08962-0313-6 ea e.r NeaeM This invitation expires; . ?V ?? - Sao.] Sekudty Number November 27, 1995 (NomTrem(e k) 4 R - o y` 6.3 H1 17? tf 16 63 --I? (` Work/ i Sre = (! g l . if Amu.] H Fuld inrome No Annual Fee $20,000 Credit Line Immediate Cash a Lowest Purchase Rate GUARMISID SAVINGS ?.ereM IC'7T 154e lL Thuma. Marur vice Prnident Credit Protection Plan (Optional) YES, I would like to help protect my VISA Gold account and credit rating with the optional Credit Protection Plan described on the enclosed flyer. YES tl.UUl here to enroll) 723-08962-0313-6 uvlsa . . _. IMIT Reference Number: 4428232272302782 Box : 3080 Year : 95 Batch : 21 SSN : 193420963 Account # : 4428232272302782 KACONTR n O(A j ? a 0 ? N VALERIE ROSENSLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 17065-1604 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: C , PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 4428232272302782 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GUY W. BURFORD Defendant N0.997625 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of against the said Defendant for failure otherwise respond to the Complaint and as follows: AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL the Plaintiff and to plead or assess the damages $8,086.39 $1,617.00 $878.18 ($0.00) ($0.00) $10,581.57 PLUS ADDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW, ?? r)/?? Judgment is entered in favor of the Plaintiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above ctificatio-\ PROTHONOTARY PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,:v 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 17065-1604 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff EXHIBR VS ` GUY W.BURFORD Defendant N0.997625 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: GUY W. BURFORD 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065-1604 DATE OF NOTICE: 2/9/00 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 41° FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. BY: VALERIE SENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 17065-1604 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA CUMBERLAND COUNTY COURT OF COMMON PLEAS i PROVIDIAN NATIONAL BANK j Plaintiff VS GUY W. BURFORD , Defendant i NO. 997625 VERIFICATION OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS VALERIE ROSENBLUTH PARK, Esquire, being duly sworn according to law, deposes and says that she will make this affidavit on behalf of the within Plaintiff, being authorized to do so, and that she believes and therefore avers, that GUY W. BURFORD, Defendant is over 21 years of age; that his/her place of residence/business is located at 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065-1604 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 ASSO TES, P.C. BY: Valerie Rosenbluth Park Attorney for Plaintiff E10 VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 17065-1604 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 411 N BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS GUY W. BURFORD Defendant NO. 997625 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: [X] Judgment [ ] Money Ju [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Judgment [ ] Praecipe by Default 3gment in Replevin in Possession on Award of Arbitration on Verdict on Court Findings on District Justice Transcripts on Judgment Note on Writ of Revival to Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. PROTHONOTARY : PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. g N ? l '- c I [? WILU /V t-- Z Tl]4. SHERIFF'S RETURN - REGULAR CASE NO: 1999-07625 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS BURFORD GUY W CHRISTOPHER EVANS Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to late, says, the within NOTICE & COMPLAINT was served upon BURFORD GUY W the DEFENDANT , at 0009:30 HOURS, on the 13th day of January , 2000 at 424 N. HANOVER ST APT 1 CARLISLE. PA 17013-1604 GUY BURFORD by handing to a true and attested copy of NOTICE & COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 .00 29.10 Sworn and Subscribed to before me this 1. p day of ,,2 c7rD A. D. a ?6" << . P othonotary So Answers : R. 7Thomas Kline i 01/14/2000 PARK LAW/AA ASSOCIATES By: U I +1 v ?I' ? P '?/1 yj\? Dep ty Sheriff C