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Home My WebLink About09-3777COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff : No. CA - 3'777 aivi t Ter% vs. PATRICIA THOMAS Defendant CIVIL ACTION 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 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 ANY OTHER CLAIM 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 AMATO A 0 ATES, P.C. By: ona d Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 \.,0aniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 09. 37,77 dD 721-- vs. PATRICIA THOMAS Defendant(s) : CIVIL ACTION COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $8,949.65, with interest thereon as hereinafter stated, upon the following causes of action: 1. Plaintiff, BLUESTONE INVESTMENTS, INC., is a Pennsylvania corporation with an address of 107 N. Commerce Way, Bethlehem, PA 18017. 2. Defendant, PATRICIA THOMAS, is an adult individual located at 613 Silver Spring Road, Mechanicsburg, PA 17050. 3. FIA Card Services N.A., a wholly owned subsidiary of Bank of America Corporation, is the successor in interest to MBNA Bank, N.A., Fleet Bank, and Bank of America Card Services. 4. At the request of Defendant a Visa credit card was issued to the Defendant by the aforementioned credit grantor. 5. Defendant made various purchases, in which transactions Defendant made use of said Visa credit card. A true and correct statement of Defendant's account is attached hereto, made a part hereof and marked Exhibit "A." A true and correct copy of the final monthly billing statement sent to Defendant by Plaintiff is attached hereto, made part hereof and marked Exhibit "B." 6. For value received, all rights, title and interest of FIA Card Services N.A. in this claim were assigned, transferred and set over to Plaintiff. True and correct copies of the bills of sale selling and assigning all rights, title and interest in this claim to Plaintiff are attached hereto, made part hereof and collectively marked Exhibit "C." 7. By virtue of said assignment, Plaintiff acquired legal title to Defendant's aforementioned credit card account and became the legal holder of the claim against Defendant. 8. Defendant has not adhered to the agreed-upon repayment obligations that govern the aforesaid Visa credit card account, by reason of which Defendant is in default thereof. 9. Defendant received, accepted and made various purchases using the credit card described in Exhibit "A," and a total amount which became due as a result thereof, after allowance for all proper credits for payments and/or adjustments, if any, was $8,710.53. 10. Plaintiff is entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.00% per annum to the past due balance. 11. As of June 2, 2009 the total amount of interest due to Plaintiff is $239.12. 12. Plaintiff is entitled to have the 6.00% interest charge continue to accrue, as set forth above, from June 2, 2009 on down to the date of judgment in this matter. 13. Plaintiff has made demand against Defendant for the aforesaid sum, but Defendant has failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendant for $8,949.65 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from June 2, 2009, costs of suit and all other relief to which Plaintiff may be entitled. COUNT II Alternative to Count I - Unjust Enrichment 14. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 15. At Defendant's request, Plaintiff conferred a benefit upon Defendant by providing the credit card services described in the exhibits attached hereto. 16. Defendant received and accepted the benefit of said credit card services provided by Plaintiff. 17. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid credit card services to Defendant and that Plaintiff expected to be paid for such. 18. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide said credit card services and to incur damages. 19. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said credit card services without paying Plaintiff fair and reasonable compensation. 20. Allowing Defendant to retain the benefit of said credit card services without paying fair compensation would be unjust. 21. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs expense, an implied contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff the quantum meruit value of the credit card services described in the exhibits attached hereto in the amount of $8,710.53. WHEREFORE, Plaintiff demands judgment against Defendant for $8,710.53 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from June 2, 2009, costs of suit and all other relief to which Plaintiff may be entitled. AMATO AN S ATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM VERIFICATION Michelle Bright, hereby states that she is the Legal Case Manager of Bluestone Investments, Inc., Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. BLUESTONE INVESTMENTS, INC. CREDITOR NAME: ORIGINAL CREDITOR: ORIGINAL ACCOUNT #: DEBTOR NAME: BLUESTONE ACCOUNT # DATE OPENED: DATE LAST PAID: PRINCIPAL: INTEREST: INTEREST RATE: COLLECTION CHARGES: TOTAL: c/o Amato & Associates, P.C. 107 N. Commerce WAy Suite 100 Bethlehem, PA 18017 STATEMENT OF ACCOUNT Bluestone Investments, Inc. BANK OF AMERICA-FLEET 4888930228116866 PATRICIA THOMAS 1090008 4/8/2001 4/4/2008 $8,710.53 $239.12 6% $.00 $8,949.65 (Gqcioo? Prepared for PATRICIA E THOMAS Account Nu-ber.• 4888 9302 2811 6888 November 2008 Statement Credit Line. $7,000.00 Cash orCredrtAva%1ffi/e. e Summary of Transactions Billing Cycle and Payment Information Previous Balance $8,483.18 Days in Billing Cycle 29 Payments and Credits - $0.00 Closing Date 11/21/08 Purchases and Adjustments + $39,00 Periodic Rate Finance Charges + $188.35 Payment Due Date 12116108 Transaction Fee Finance Charges + $0.00 Current Payment Due $312,00 New Balance Total $8 710 53 Past Due Amount + $2,022.00 , . Total Minimum Payment Due ''' BankofAmedca www.bankofamerica.com Call toll-free 1-800-789-8885 TOO hearing-impaired 1-800-348-3178 Mei/PeHrrerns ta• BANK OF AMERICA P.O. BOX 15728 WILMINGTON, DE 19888-5728 A&#8#/AyIn7uares to: BANK OF AMERICA P.O. BOX 15028 WILMINGTON, DE 19850-5028 --to nanxtcwn riererence Account Purchases and Adjustments Offer ID Date Date Number Number Amount LATE FEE FOR PAYMENT DUE 11/17 11/17 11/17 8483 3900 maaleremnn ee.m.a3l ? Allr"fifif"lfr?IF1? ?i ?i® tuai?ri®r ?iiw crier ii?-? YOUR PAYMENT WAS NOT RECEIVED BY THE DUE DATE. TO AVOID FUTURE FEES OR RATE INCREASES, PLEASE MAKE YOUR PAYMENTS ON TIME AND REMAIN UNDER YOUR CREDIT LIMIT. REMEMBER, IF TWICE IN 12 MONTHS YOUR PAYMENT IS RECEIVED AFTER THE DUE DATE AND/OR YOUR CREDIT LIMIT IS EXCEEDED, YOUR APR MAY INCREASE. OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE Fhornotlbnat Transaction Tfa CorresponoWgAnnual APR Balance Subject to Petiodre Rate Percentage Rate Type Finance Charue Offer BCQ9-Z2BSQ BT, CB, DB 0.013699% V X5.00% P X$487.32 Cash Advances 0.079425% V 28.99% S 7.37 Purchases $1,619.37 0.079425% V 28.99% S $6,000 .01 Annual Percentage Rate for this Billing Period: 27.62% (includes Periodic Rate Finance Charges and Transaction Fee Finance Charges that results in an APR which exceeds the Corresponding APR above.) APR Type Definitions: Promotional Transaction Types: ST = Balance Transfer, CB = Check treated as Balance Transfer, DB = Direct Deposit treated as Balance Transfer; Daily Interest Rate Type: V= Variable Rate (Interest Rate may vary); APR Type: S= Standard APR (APR normally in effect), P= Promotional APR (APR for limited time on eligible transactions) 19 008710530023340000079500000488893022811,6866 BANK OF AMERICA P.O. BOX 15726 WILMINGTON, DE 19886-5726 InIIIIIInIII if 1n1a,11..111111n11oil 91111n111 INI PATRICIA E THOMAS 613 SILVER SPRING RD MECHANICSBURG PA 17050-2873-133 Chock here for a change of malling address or phone number(s). Please provide all corrections on the reverse We. ACCOUNT NUMBER.- 4888 9302 2811 8888 NEWBALANCE TOTAL: $8,710.53 PAYMENTDUEDATE.• 12/16/08 check or 1:5 240 2 2 2 501: 1M70228i16866III, W& OF 'eas w N MW OiRTANT WFORMATWN ABOUT TM ACCOUNT USE 211 Rev. 04/08 ? CUSTOM 3'DiyENwUT or DISPUT1(ID h= - Please eall toll free 1.866.266.0212 Monday-Thu>sday Sam-9p?n (fFasia°r?i Time), Friday Sam-7pm (Eastern Tim ens) and Saboday 8am-6pm (Eastern TFme). For prompt service please have the merchant reference member s) available or the charge(s) fn question. Pi FASF. T)O NOT ALTER WORDING ON THIS FORM AND DO NOT MAIL YOUR LETTER OR FORM WITH YOUR PAYMENT. Choose only one dispute reason. Your Name: Transaction Dare: Posting Date: Amount f: Disputed Amount : 1.1'heammtofdiedmxwasimeasodkomS m$ or my Saks 2.1 omifythatthetwefstedabove was notatadeby near apesm audwited by meto use myycard,nor wirettx aserviaesrepresmmdbydintrainacdoareoeivedbymeorapersmauthotiud6yrtx I /(MM?DDlYY1• 3.[have nanealvedthemmefiandethawavtobeshipped tome m_l have asked the muchant to credit my aocoune 4.1 was inueds ueditsGpthatwasnotshownon my stammem Acopy ofmyaeditdipisendosed. Themerchant hasupto30daystocredit youraowunt. 5. MadoxIise dutvvas te me atoned andfor defective. i returned it on / (MMNU andasiaedtheta roeetdcmysomunt.Attach aleawdesrnh;ng oil-w the nwc&Tewasdamagedardkrddediveatdacopy ofthepmofofrerum. f? 6. Although [didmgagcindieaboveo9aaieon,ihave ca> themetd:any returned the madtandise return. a you are unaae ro reran me,,,m.a,"w, t+ m ? tw . 07.1onti(ydhatdhechatgeinquestionvvasa iratnacdon,butwaspnstedtwice romystatement. audwrizedi Sale#1$_._ Rtkivace # #2s # GRACE PERIOD Grace period" means the period of time during a biUityg cycle when you will not amme Periodic Rau Funri ace C haMn on certain transarnons or noes. There is no Grace Period for Balancee Transfers and Cash Advances if you pay in full this statement's New Balance Total by its Payment Due Date and if you paid in full this sta tetruerhtb Previous Balance in this statement's billing cycle, that yyorwu will have a Grace Period during the biniog cycle that began the day after this statemer? Cbsitng Date on the Purchase portions of this soaument's New Balance TotaL During a 0% Promotional Rate Offer. 1)) no Periodic Rate Finance C?harp accrue on balances with the 0% Promotional Rate; and 2)you must pay the Total Nii rimurri Pa t Due by itsPaytt?t Due Date (and avoid any other "promotion turn-off event" as de in your Credit Card Agreement) to maintain the 0% Pranotional Rate. " If a corresponding Annual rage Rate in the Finance Ch?vF Schedule on the from of this statement contains a """symbol, then wutlu uespea to tllae 1) the 0% Promotional Rau will expire at the end of the netm bdlliutg cycle, and 2) must pay ills statenran's New Bal. Tote) by its Paymaht Due Date to acid Pciodi Rau Finatice C]targes after the end of to 00% Promotional Rate Offer on those balances existing as of the (losing Date of this stattmenc CALCULATION OF BALANCES SUBJECT TO FVWICE CKARGE Average Balance Method (including new Balance Ttansfers and new Cash Advances): We calculate separate Balances Subject to Finance Charge for Balance Transfers, Cash Advances, and for each promotional Offer balance consisting of Balance Transfers or Cash Advances. We do this : (1) caiai6ring a daily balance for each day in this smurnentis billing cycitm. (2) calculating a daily balance for each day prix to this staternenAbilling cycle that ha a "Pre- Cyde balance" . a Pie-Cycle balance is a Balance Transfix or Cash Advance with a transaction date prior to this stammenil; billing cycle but with a date within 'his staternern's billing cycle; (3 mall the daily balances the, and 4 di the sun of the daily balances by then of dyiseinthissiatemem's . To calculate daily balance for S2?ym thisstatements billing e, we take the beginning balarim, add an amount equal to the applicable Daily Periodic Rate multiplied ul? by the previous ayls daily balatiee, add new Balance Transfers, new Casts Transaction Fees, and subtract applicable payments and credits. If any daily balance is less than zero we treat it as zero. To calculate a daily balance for each day prior to this statements billi cycle that had a Pre• Cycle balance, we take the beginning balance attributable solely to P balances (which will be zero on the aiansactim date of the first PrewCyde balaneeti add an amount equal to the applicable Daily Periodic Rate mu ' , Bed by the pp?revvauouuss desA ?y balance, and acid only the a bk Pte Cycle balances, am related Traneactioh fines *e exclude from this ctilatan an transactions in previous billing cydm Average Daily Balance (irulud'tng new Purchases): We calculate separate Balanoes Subjat to Finance Charge for Purchases and for each Promotional Offer balance consisting of Punchases. We do this by (1) calculating a daily balance for each day in the billing cycle; (2) adding all the daily balances together; and (3) dividing the sun of the daily balances by the number of days in the billing cycle Merchant Name: F-7 8. 1 noded themm6ot on ! / (MMIDDMtocxnodthepregutharimdorder (teservatim).Ptemnowcat-aunt#0 available,mdaeeacopyof your mmtactands copyofyaw Wephwe bill showing date and timeofaoodlatim. Reasm forranodadm /canmllation # ? 9. ?I did et?gaaggeein the above I haves die madhata foraeditTheservices hobs m_,l I (MIN weremtmreivadorwessmso<idaaory:Attadtaletc deam'biog the servio:s er:pate?yanr atteotpts to readae viith the rocdf am and a copy of yaa carman oenifytltnrldomtraco?tizetberranva?m Metttuorra?tdtptovidetdeptimeawnbasttextmtfar r] 10.1 namem yourbigt?gsmtemnit. Ptraseanmaptrocaracttk madam forinfatitietion. l? 11.If yaudisyxixis fora differentreaveq pkaseemcact us nitre above tdephonenumba Signature (required): Date: Best contact telephone #• Home#: Billing ct' is are only preserved by written inquiry. To preserve your billing rights, please return a copy of this form and anpp information regathe merchant charge in question to: Ana: Billing Inquiries, RO. 15 6, Wilaringtoa, DE 1 50 5026, USA. PLEASE KEEP THE ORIGINAL FOR YOUR RECORDS AND SEND A COPY OF THIS STATEMENT. To calculate the daily balance for each day in this statement s (?? cycle, we take the balaraoe, add an amount equal oo the applicableDarily 1?iam?c Rau mukipW by pprevious day's daily balance, add new Purchases, new Account Fees, and newTrat>sactian Fees, and subtract applicable payments and credits. If any daily balarxx is less than zero we treat it as zero. if the Previous Balance shown on this statement was paid in full in this smonCiA billing cycle, then on the day after that payment in full date, we eodude from the beginning balance new Purchases, new Account Fees, and new Transaction Fees which posted on or before that paymerm m Rill date, and we do not add new purchases, new Account Foes, or new Transaction Fees which post after that payment in full date. We include the casts for the credit card debt cancellation plan or credit insurance purchased through us in calculating the beginningbaiaztiCefor t1xf?stday of the billing cycle after the billing cycle in which such acts are billed. TOTA1. PEiIOR>?IG RATE FlIAIICE CIIr*I?I?IE CO?ATiON Periodic Rau Finance (?hatges aaaire and ate compounded on a daily basis To detemilM the Periodic Rau Furnace we multipl each Balance Subject to Finance Charge by its a pliable Daily Periodic Rau rtes that result byy the number of days m the billing cycele. To detentrine the wtal Periodic Rare Finance for the billing le, we Periodic Rau Finance Charges together: Each Daily Perm te is ca lated vi its corresponding Annual Percentage Race by 365. NOW WE ALLOCM YOUR PAYMR:IM We will allocate your pay?me is in the manner we determine. In most instances, we will allocate your to balattoes (ittchxk$ transactions made afar this ?o merit) with lower APRs before with higher APRs. Tbs will result in balances with lower APRs (stuh as new balamccs with promotional APR offers) being paid before any other existing balances. Pap-mm-t Due Dan acid Kaapilp 11Ca11' Aowtnt Ira Goad Sbaxiq Your Payment Due Date will not fall on the same day each month. In order to help maintain arty promotional rates, to avoid the imposition of Default Rates (if applicable), to avoid late fees, and to avoid overlimit flees, we must receive at least the Total Minimum Payment Due by its Payment Due Date each billing cycle and you must maintair your account balance below your Credit limit each day. Important li tbranatian about PwInmsto by Phom When using the optional Pa Phone servicq you authorize us to initiate an electronic payment from your account at the fiiariaal institution you designate. You must autioriu the amount and timvtgg of each payment. For your p we win ask for security information. A fee may apply. To camel, an us before the sdied payment date. Sanre-day paym arms cannot be edited or canceled. NNSCO.L.AIlI?IIiS For the complete temps and conditions of your account, consult your Credit Card Agreement. F'lA Card Services is a tradename of RA Card Servioes, N.A. This account is issued and administered by FIA Card Services, N.A. PAYNUNTS We credit paymants as of the date received, if the payment is 1) received by 5 p.m. comer of the front (Eastern Time), 2) received at the address shown in the ob ttott left-hand of this statement, 3) paid with a check drawn in U.S. dollars on a U.S. financial institution or a U.S. dollar money ordey and 4) sent in the enclosed return envelope with only the bottom portion of this statement accompanying it. Payments received after 5 p.m. on any day will be vududing the Payment Due Date, but drat otherwise meet the above requtranentas,,credited as of the next day. We will reyect ytnmts that are not drawn in U.S. dollars and those drawn on a financial institution toa?tod outsides of thre United States. Credit for any other payments may be delayed up to five days. No payment shall te as an accord and satisfaction without the prior wrrttm ceppproyal of one of our Senior Officers. We most payment checks ehectronically by treeing the information found on your check. eck authorizes us to create a one ttmt electronic funds transfer (tit process it as a check or paper draft). Funds may be withdrawn from your amount as soon as the same day we receive your paymentt. Checks are not returned w you. For move information or to stop the electronic funds transfers, call us at the number listed on the front. If you have authorized us to pay you credit card bin automatically from your savings or checking amount with us, you an stop the payment on business days d nee the automatic o three stop the payment your letter mum reach us at least payment is scheduled to occur. if pour billing address or contact information has changed, or if your address is incorrect as it appears on this bill, please provide all corrections here. Address 1 Address 2 City State Area Code & Home Phone Area Code & Work Phone Zip v m 0 to Bankof America EXHIBIT A BILL OF SALE FIA Card Services N.A. (USA) is a wholly owned subsidiary of Bank of America Corporation and is successor in interest to MBNA Bank, N.A, Fleet Bank and Bank of America Card Services ("Seller"), for value received and pursuant to the terms and conditions of a Account Sale Agreement ("Agreement") between Seller and Absolute Resolutions Corp. ("Buyer"), dated January 13, 2009 does hereby sell, assign and convey to Buyer, its successors and assigns, all right, title and interest of Seller in and to those certain Accounts as defined in the Agreement and as set forth on Exhibit B, without recourse and without representation of or warranty of collectibility, or otherwise, except to the extent provided for within the Agreement. EXECUTED this 20th day of January, 2009. FIA Card Services N.A. (USA) By: Debra L. Pellicciaro, Assistant Vice President ACKNOWLEDGMENT STATE OF DELAWARE COUNTY OF NEW CASTLE SS This instrument as ckn ti11 d before me on by as of FIA Card Services N.A. (USA) Signature ? o ial 0 i r ANDREA L NAM My Commission Expires: r(W NOTARY IC S1AIE OF OE(A EtA1lARE MY CMISS101 Er?!Pcs )A dfaY 20.2010 Fax 302A5S.043S BS1002 February 24, 2009 EXHIBIT "B" BILL OF SALE AND ASSIGNMENT OF LOANS Absolute Resolutions Corp., ("Assignor") hereby absolutely sells, transfers, assigns, sets-over and conveys to Bluestone Investments, Inc. ("Assignee") without recourse and without representations or warranties, express or implied, of any type, kind or nature, except solely that Seller does hereby represent and warrant that Seller is the owner and holder of the Evidence of Indebtedness for each of the Loans: (a) all of Assignor's right, title and interest in and to each of the Loans identified in the Loan Schedule attached hereto as Exhibit "A" (the "Loans") , together with all promissory notes or other evidence of indebtedness, if any, and together with all instruments and documents constituting the Loan Tiles pertaining to such Loans, if any; and (b) all unpaid balances or other proceeds of any kind with respect to the Loans (including but not limited to proceeds derived from the conversion, voluntary or involuntary, of any of the Loans into cash or other liquidated property, but excluding any payments or other consideration received by or on behalf of Assignor prior to February 24, 2009, with respect to the Loans. This Bill of Sale is being executed and delivered pursuant to and in accordance with the terms and provisions of that certain Purchase and Sale Agreement made and entered into by and between the Assignor as Seller, and the Assignee as Buyer dated February 24, 2009 (the "Agreement"). The Loans are defined and described in the Agreement and are behig conveyed hereby subject to the terms, conditions and provisions set forth in the Agreement. Assignor represents that this Bill of Sale has been duly authorized and that the person signing for same has full power and authority to do so. THIS BILL OF SALE SHALL BE GOVERNED BY THE LAWS OF THE STATE OF CALIFORNIA WITHOUT REGARD TO THE CONFLICTS OF LAWS RULES THEREOF. DATED: ? ( ??'?-;?( orp. Seller: Absolute RAug By: o Name (print): N cTitle: Exe cutive Vice President Page 13 Initia Initial FILED-01 r1CE OF VE PR4T "JCYARY 2009 JUN -8 PM 1: 3 8 v +u JJ CLIME, Pr-i"INSYLVANIA P78-60 PU ATr-t cew 2/vaqo s RTC 0?011o3&S COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. : Plaintiff No. 04 - 3x7,7,7 &V?i Terw VS. PATRICIA THOMAS CIVIL ACTION Defendant(s) ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, BLUESTONE INVESTMENTS, INC., in the above-captioned matter. AMATO AN CIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Dated: June 2, 2009 OF THE PROTHONOTARY' 2009 JUN -8 PM 1: 38 CUM B, 11 11 ° - NN WN? YLV h Sheriff s Office of Cumberland County R Thomas Kline ~~wtixtr of ~umg~rtgy~ Edward L Schorpp Sheri, ff' Solicitor ,° :r Ronny R Anderson ~~~* ~~~ Jody S Smith Chief Deputy o~cE of T~+~ ors€R!F~ Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/10/2009 03:52 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states th2jt on June 10, 2009 at 1552 hours, he served a true copy of the within Complaint and Notice, upon the vV~ithin named defendant, to wit: Patricia Thomas, by making known unto herself personally, defendant ~t 613 Silver Spring Road Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and ~t the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, June 11, 2009 R THOMAS KLINE, SHERIFF 2009-3777 Bluestone Investments v Patricia Thomas ~a O ~ ~~p -}`1 S, ~,., ~ ~a ~ ~ ~ ~ rv `..~ r "„ -ga ~'' -~l ~' ~ 31 t y f°~T'I .~' 'p. O '<