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Home My WebLink About01-6832VALERIE 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. DORIS E SHUMAN 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 AVENUE 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 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 ACT~:4168100013654221 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 VS PLAINTIFF DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 DEFENDANT NO. CIVIL ~CTION 1. 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, DORIS E SHUMAN , is an individual who resides at 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002, ~ 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 4168100013654221. 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 "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 $1,995.79 as of 11/13/2001, plus pre-judgment contractual interest at the rate of 8.00% per annum, less payments made. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $1,995.79, plus pre-judgment interest at the contractual rate of 8.00% per annum from 11/13/2001 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. ANY 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 $1,995.79, plus pre-judgment interest at the contractual rate of 8.00% per annum from 11/13/2001 until the date of the judgment herein, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRK PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS AN ATTEMPT TO COLLECT A DEBT. A/qY INFORF~TION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION I, '-DELORES CHAHLc$ , 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 Alameda County, in the State of California. Date Designated Agent ,VUlqlT ACCOUNT AGREEMENT Your ASSOCIATES account has been UmW-erred to Fimt Select Corporatio~ Your ASSOCIATES account was clceed at the ~ of this lrami'er, and will th,~o~¢o~,u, tobe el~ Th~ A~o~ ~,ot e~th,,~,th, Sovemyour F~ Sel~ct~.~.o. ~. (th'_"A~..~.. '~.. . ~ A~'~._. . ~/ou" =d ~your~ mann ~ach pe~on who is llable for paymonl on the AaconnC We, our, ours, and tm meanrwst~lmeotCoqxa'auonorgsasmsnees l~eeauseyour Account has been transferred to us, you are now obligated to repay the Account to us inslead of ASSOCIATES. If the AccotmI was opted as a joint account, we may act on the insiructiom of any jo/nt acoountholder. Payments / Finance Char~es. As long as you have a balance ontstanding on your Account, finance charges are celculated as follov~: To fl~ffe the finance charges for each billing cycle, we multiply the average daily balance on your Accounl by a daily periodic rate. The daily pe~cdic role we ~ding balance, we will apply lhe Ioweat such Ammai r~rce~age ~ ~o your ema~ an~awm~ o~=. underilgs . .A~. ~' Youmu....y ask Fira $elec~ Co. . rpora~on ~o pay mis accoou~ wy aemung your cuscr, mg or as'nn~ ~,~ouu~ ....... ver~ your idcut~/and eligibil~ for this s~rwce. You may revoke your authonza~on by writing ~o Flr~ Select Corporahon Customer Service. Fee~ We will charge your Accon~ a fee for each billing cycle ~ which your Accouni is del~qu .~t. (late =.h.~. e). ~ amount of the late charge will be as disclceed in your Original T~rns or the maximum lag charge permilled by the law of your stste oire~usnce, wmcusver is wwer. We will charge your Acoouut a fee for each remrned.pa?ment cbec .k... ( , .r ,et. un.~e...., d .cheek~charge)' .Tbe~ an~..°.un£ °f ~e.~ loCheCwerkcharge will be as &sclnsed in your Original Terms, or tha maximum returned cheoc anarge ponmuco wy mc ~aw c~ your sum ox res~aance, wmca~ver is . T ,~,, ~,,.,,, ',~,.~ ;, ,~,,~ c~;oi,,d Tem~ and to the exieni oermil~ed b~ avoliusblo law, in ,,t~l~ion to your obligation to pay the ovlistanding balance on your · oas as disclosed we ma also e you for any collection cosIs we recur, mclmiing but not limited to rensonabl rneys Account. plus mlerezi andii . . h~. y charg .... leas and conr~ cos~. If your Original Terms reded for an award of attorneys' fees and court costs, such provision as incorporated herein shall XPply reciprocally to thc plural in5 pony in any lawsmt arising out of this Agreemeffu Non-Waiver of Certain Rights. We may delay or waive enforcemeot of any provision of fi'As Agreement without losing our right to enforce it or any other desiana~ed az the ao~licable law in your Ori Terms. lxycurOf~gulalicl~smaom.~ontsm-anappucao~eiawp~o~c~;~u~x .u.~a-'~m~'u; you,. · to all or some of Your payments. If state law requires that you recetve nouce oI SUCh an evem [o pm[em [ne purcnasor ~ ~lp~, ..- _--~ ~.- ~ by fdlng a financl~g siatemant with the state's Secretaxy of State. a,~min.d tn ~ or~d~ r,~r~-~rfine s~m~'~c-v hl order to dismRe ally iliforll~ation we are ~ a~out your ~ you mu~ wn~ ~ ua ~u ~ luuu ,wu~ YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE Thio notice cootaim important informa~on about your right~ and our reagousibilitias under the Fair Credit Billing AcL Notify Ua hi Case of Error~ or Qnas~tom Alm~t Your If you think your bill is wrong, or if you mod more information about an ~ on ..y ,our .b.i.ll, writ..us, o~ a sepanste, .sl.~'tLat t h~e,.fo?? _a~:. ~_'.~...,_S_el~ect~ ~'i' Corporation, P.O. Box 9104, Pleasaoton, CA 94566. Write ~o us as soon as pceswle, we musl near Item you no laler man ou usys au~r we acu~ yuu m= m~ u u on which the error or problem appeared. Yon can ~elephone us, but doing so will not preserve your rights. In your letter, give us the following: · your name and Accouot number. · Describe the error and explain, if you can, why you believe there is an error. If you need more inf=,,,~ion, describe the item you are not sure about. Your Rights end Our Responsibilifle~ After We Receive Your Written Noitce We must ac..kn..owtedgc your lcitsr within 3.0 da~, unlass we have correcti.'d the .... byth~ Wi .g~,. 90 days, ~we muat either, c~, ~.'t ~h~e. err?r ~ e~_.~_ l,a~nmswnlrY~we behevo the bill was correct. ~ wa rece,vo ye. ur leWr, we ~ try to collect or r~port you as coun.quan.t, as m any .a~, oont you. qu~?~,., mm~n~ gu are charles. We cen apply any onpmd amount a~a .mst. your. creditlu~, you do not have to pay any quastwnan emount wnue we ar~ mveen§aung, o yo obligated to pay the parts of the bill that are not m qucstior~ , - ffwe find that we made a mistake on your b!ll, you will not have ~o pay any finance charge relate, to .any questi~. ~...amoum. If wa .&.'.d not, mvou~a~a~ake~ oY~U may have to pay finance charges, and .y.o.u wdl have to..n~k..e up ~ missed paym..ents., on the quasUonco amou~ m elm,~.caso, w.e,v~,_u sane y..~ou __ es~ax~lanatiou the amount you owe and the dele that K ts .d.u.e. If you fail ..to pay the amount...we ? yet., owe, we r~a. y, repor~ you as usl~mqu__c_~... _ .~_o.w. ever, .u_ ~o ..u~r_~ ,~o~r bill doas not satis~ you and you wnie to us w~thin 10 days telling us that you ~li remse to pay, we must .tan .,anyon!.we,repo. ~n y_o_u_ ~, _ ~u~ ~.o._u ~u,~.yl~~ ..... ;- is And we must tell you the name of anyone we repmted you to. W.o muat t.e. ll anyone we report.~you to, .,tl~, me mumir, uss ~ s~cuco ~:~ween us w ........ If we do not follow these talcs, we cannot collect the lust $50 of the quashonc~ amourR even uyour OlU 1Nas COlffeCL Special Rule for Credit Card Purchases If you have a problem ~vith the quality of gouas and services that y.o.u purchased with your ASSOCL*TE..S cred~it card and yo,.u l~v! tried i .n..g_o~d_. _,.t'.a} ti} t.o correct. the problem with the merchant, you may not have to pay the rcmammg ammmt, d~e on the .g. ooc~,.or servwes. ~ n.e?. are ,t~,o lumtat.~?,as. ? mis ~gl~l. /~) you m. ns~ have made the purchase in your home slate or, if not wflhin your bemc state, witinn 100 miles o~your currant manmg auoress, aha to) mc purcnase price mus~ have been more than $50. These limitations do not apply ii'either ~vc or ASSOCIATES own or operate the merchant, or LFwe or ASSOCIATES mailed you the advertisement tbr the properly or services. ORDER FOR SERVICE TO: SHERIFF OF CUMBERLAND COUNTY DATE: November 26, 2001 PROTHONOTARY NO: FROM: VALERIE ROSENBLUTH PARK, ESQ. Attorney I.D. 72094 25 East State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CIVIL ACTION COMPLAINT FIRST SELECT, INC. Plaintiff VS. DORIS E SHUMAN Defendants ADDRESS TO SERVE: DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 SPECIAL INSTRUCTIONS: PLEASE DO NOT SERVE OUT OF COUNTY! PLEASE MAKE THREE ATTEMPTS TO SERVE AT DI~'~'mRENT TIMES. THANK YOU! RETURN OF SERVICE TO: PARK LAW ASSOCIATES, P.C. P.O. BOX 1779 DOYLESTOWN, PA 18901 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN CASE NO: 2001-06832 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS SHUMAN DORIS E - REGULAR SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHUMAN DORIS E the DEFENDANT , at 1851:00 HOURS, on the at 1083 MUD LEVEL RD 7th day of December , 2001 SHIPPENSBURG, PA 17257 THOMAS SHUMAN, HUSBAND by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 13.00 Affidavit .00 Surcharge 10.00 .00 41.00 Sworn and Subscribed to before me this /~ day of ~ ~20~7 A.D. ' /P~$t'~onot~ry ' So Answers: R. Thomas Kline 12/10/200z PARK LAW ASSOC~ By: VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 ATTORNEY~I FF CUMBERLAND COUNTY COURT OF COMMON PLEA_~ FIRST SELECT, VS DORIS E SHUMAN INC. Plaintiff Defendant NO.01-6832 CIVIL TERM PRAECIPE 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 $1,995.79 $339.00 $24.50 ($0.00) ($0.00) TOTAL $2,359.29 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~c. VAB~RIE ROSENBLUTH PARK, ESQUIRE Attorney for the Plaintiff AND NOW,~_~~, oQ~)d)~, , 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 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. V~-LERIE 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 PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS DORIS E SHUMAN Defendant NO. 01-6832 CIVIL TERN 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 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 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 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 PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS DORIS E SHUMAN Defendant NO. 01-6832 CIVIL TERM 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 DORIS E SHUMAN, Defendant is over 21 years of age; that his/her place of residence/business is located at 1083MUDLEVELRD SHIPPENSBURG, PA 17257-8002 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 ~ BY: Valerie Rosenbluth Park Attorney for Plaintiff 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 I HEREBY CERI'W¥ THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 1083 MUD LEVEL RD SHIPPENSBURG, PA 1725%8002 PlttLADELPI~IA COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. VS DORIS E SHUMAN Plaintiff Defendant NO. 01-6832 CML TERM NOTICE OF PRAECIPE FOR ENI'RY OF DEFAULT JUDGMENT TO: DORIS E SHUMAN 1083 MUD LEVEL RD SHIPPENSBURG, PA 17257-8002 DATE OF NOTICE: 12/28/01 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 ENfERED 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, Lawyer Reference Service Philadelphia Bar Association 1101 Market St~et, 11e Floor Philadelphia, PA 19107 (215) 238-6300 PARK LA~. BY: VALERIE ROSENBLUTH PARK, ESQ. cc: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT_