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Home My WebLink About01-6319VALERIE 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 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS. CAROL K NOWICKI Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAF~E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ~ INFOP. MATION OBTAI~D WILL BE USED FOR THAT PUI~POSE. VALERIE ROSENBLUTH PARK ATTOP~NEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTOP~NEY FOR PLAINTIFF ACT#: 4168100213540295 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS CAROL K NOWICKI 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 DEFENDA/~T CIVIL ~CTION The Plaintiff, First Select,~Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, CAROL K NOWICKI , is an individual who resides at 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411, 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, bearing account number 4168100213540295. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4. The terms of said account are stated in the documentation attached hereto as Exhibit 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 $1,996.76 as of 09/14/2001, plus pre-judgwaent contractual interest at the rate of 18.00% per annum, less payments made. WMEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $1,996.76, plus pre-judgment interest at the contractual rate of 18.00% per annum from 09/14/2001 until the date of the judgment herein, less payments made, plus costs and any other such relief as this Court deems reasonable and just. 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. THIS IS AN ATTEMPT TO COLLECT A DEBT. ~ INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff demands that Judgment be rendered in favor of the Plaintiff, First Select, Inc. and against the Defendant in the amount of $1,996.76, plus pre-judgment interest at the contractual rate of 18.00% per annum from 09/14/2001 until the date of the judgment herein, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: //~ V~RIE RO~A~UTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED T}{AT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5040 JOHNSON DRIVE P.[J. BOX 9104 PLEASANTON, C.A 94566 888-964-4000 ~]1 FtRST SELECT ACCOUNT AGRI~;EM~ENT EXHIBIT VERIFICATION I, SUSANCOWHERD , declare that: I am a Designated Agent of FIRST SELECT, INC., 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 at Jefferson County, in the State of Kentucky. Date Designated Agent SHERIFF'S CASE NO: 2001-06319 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLA/~D FIRST SELECT INC VS NOWICKI CAROL K RETURN - REGULAR CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPI~AINT & NOTICE was served upon NOWICKI CAROL K the DEFENDANT , at 2010:00 HOURS, on the 9th day of November , 2001 at 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 by handing to CAROL K NOWICKI a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this ~--~ day of ~/~ ~_~ ~ A.D. ~Fothon~tary , , - so Answers: R. Thomas Kline 11/ 3/200 PARK LAW ASSOC ~W// ~'~'~ Deputy VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASD~NTON, CA 94588 DEF: 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 4168100213540295 FIRST SELECT, CUMBERLAND COUNTY COURT OF COMMON PLEAS INC. Plaintiff VS CAROL K NOWICKI Defendant N0.01~6319 PRAECIP~ FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: AMOUNT OF CLAIM ATTORNEy FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS TOTAL $1,996.76 $0.00 $60.07 ($o.oo) ($0.00) $2,056.83 PLUS DJDDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT A/gD 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,~, in favor of th'e Plai~tif~d-~'~- , Judgment is entered against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. 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. 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 PLAINrlFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTI~'F: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5A RICHLAND LNAPT 101 CAMP HILL, PA 17011-2411 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. VS CAROL K NOWICKI Plaintiff Defendant NO. 01-6319 NOTICE OF PRAECn~E FOR ENTRY OF DEFAULT .FU'DGMENT TO: CAROL K NOWlCKI 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 DATE OF NOTICE: 11/30/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WrrHIN reN (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, 4a FLOOR CARLISLE, PA 17013 (71T) 240-6200 VALERIE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AIVD CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 FIRST SELECT, VS CAROL K NOWICKI Defendant CU~IBERLAND COUNTY COURT OF COMMON PLEAS INC. Plaintiff NO. 01-6319 VERIFICATION OF NON-MILITARy SERVIC~ 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 CAROL K NOWICKI, Defendant is over 21 years of age; that his/her place of residence/business is located at 5A RICHLAND LN APT 101 CAMp RILL, PA 17011-2411 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 PARK LA~ ASSOCIA~. Congress of 1940 and its amend~lents. VaI~rie Rosenbluth Park Attorney for Plaintiff VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY T~AT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 5A RICHLAND LN APT 101 CAMP HILL, PA 17011-2411 CUMBERLAND COUNT. Y COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS CAROL K NOWICKI Defendant NO. 01-6319 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: IX] Judgment by Default [ ] Money Judgment [ ] Judgment in Replevin [ ] Judgment in Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings [ ] Judgment on District Justice Transcripts [ ] Judgment on Judgment Note [ ] Judgment on Writ of Revival [ ] Praecipe to Reassess Damages PLEASE CALL: number:(215) IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, Park Law Associates, P.C. at this telephone 348-5200. 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. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COS~ON PLEAS FIRST SELECT, INC Plaintiff VS CAROL K NOWICKI Defendant NO. 01-6319 PRAECIPE TO MARK JUDGMENT SATISFIED, SETTLED, DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark the above captioned matter satisfied upon payment of your costs. PARK LAW ASSOCIATES, P.C. // BY: ,..~. VAL~IE ~N~L~ PARK, ESQUIRE