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Home My WebLink About01-6328VALERIE 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 PROVIDIAN NATIONAL BANK Plaintiff VS. R CRAIG KEEBAUGH 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVEAUJE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK ATTORi~EY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORREY FOR PLAINTIFF ACT~:4428001582302752 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS R CRAIG KEEBAUGH 5340 OXFORD CIRCLE, APT 39 MECHANICSBURG, PA 17055 DEFENDANT CIVIL ACTION 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The Defendant, R CRAIG KEEBAUGH, has a mailing address at 5340 OXFORD CIRCLE, APT 39, MECHANICSBURG, PA 17055, 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 4428001582302752. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4. The Defendant requested an account, account number 4428001582302752, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit "A" and made a part hereof. 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 $5,335.21 as of 11/18/2000, plus pre-judgment contractual interest at the rate of 21.99% 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 $907.00. W~EREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $5,335.21, plus pre-judgment interest at the contractual rate of 21.99% per annum from 11/18/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $907.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT I- ALTEP.NATIVE 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 $5,335.21, plus pre£jud9ment interest at the contractual rate of 21.99% per annum from 11/18/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $907.00, 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION HEATHER KOOREMAN , declare that: 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 at Alameda CounCil~ Date of California. Designated Agent ~I~'~P~IAN --- .. 'EXHIBIT mmmmmm ,mnm h .,~, ,.,. ~m~,';m~mm~ ~ nmm nmmnmS. ~mmm~l ~hmcia' imnd ~ch~m:ks w m In VQU may ~ ~ uud U ~ Pm'tmfl~m m ~cu"~°:m"t ~ m ~ mw ----. -., ......... ~d ~.~.~~~ ~ ~ ~ ..,__.._.,..--....,---------..-.----_---------,., ~~~'~"-'--7 ' · ...." Complete this sho~t form and return it in the postal-paid envelope provide. 30-Second Response Certificate Yes, I want to accept your invitation for a customized VISA· Gold account! I have rind t~e ~rms cn th~hack of 11~ brochur~ I ag~ ~o be bound by the Account Agreement (whtc. h will ~ ~ ~ ~ ~ my VI~A clmtis tsnmd) and to mlmy prlndlml, inventor, and tnlen~t thenmn, ex.or that I will have ~ ~n ffl ~ ~ ~ ~ 4747 3 Randall C. Keebaugh 739 Broad St. Cha~bersburg, PA 17201-1288 h,,llh,,I,,l,lll..,,Ih,,Ih, l,li.l,hJ,,,ll,hh,I.LI 2751N1TC3Z4 GX3A9 KLCH 5FLR OBCB RCED i~AF 10- 751-12966-8417-7 ,,me~s.&~n Thbtnvlta~onexpire~ December 23, 1996 bit. Randy K~obaugb ~9 B~d ~r · -- n ~sbw~PA i~01 X / _ No Annual Fee $20,000 Credit Line Lower Rates Starting at 0% GUARANTIlD SAVINGS C~dit Protection Plan (Optional) YE~, I would like to I~elp protect my VIgA Gold account and =edit rntin8 with the optimal Credit Protection Plan described on the endosai flyer. (initial ~ to enrolB 751-12966-SG19-T exHIBIT Reference Number: 208505887 Box : 3892 Year : 96 Batch : 35 SSN : 208505887 SHERIFF'S RETURN - CASE NO: 2001-06328 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS KEEBAUGH R CRAIG SH3LNNON SUNDAY Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE KEEBAUGH R CRAIG REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the DEFENDANT , at 1009:00 HOURS, on the 9th day of November at 5340 OXFORD CIRCLE APT 39 MECHANICSBURG, PA 17055 R CRAIG KEEBAUGH a true and attested copy of by handing to , 2001 COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.15 Affidavit .00 Surcharge 10.00 .00 35.15 Sworn and Subscribed to before me this ~L~ day of ~ ~L~! A.D. ~rothonotary ~ So Answers: R. Thomas Kline ii/i3/200i PARK LAW ASSOC Deputy Sheriff/ VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF BOX 1779 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS R CRAIG KEEBAUGH Defendant NO. 01-6328 PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above captioned matter discontinued and ended upon payment of your costs. settled, PARK LAW ASSOCIATES, P.C. BY: ~~/~//' VALERIE ROSENBLUTH PARK I7