HomeMy WebLinkAbout01-0713VALERIE 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
PROVIDIA_N NATIONAL BANK
RONALD E SILER
LIN]DA M SILER
Plaintiff
VS.
Defendant
NOT I CE
NO. OI-
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 TEAT 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#:4479434502515799
CUMBERLAND COUNTY COURT OF COMMON PLEAS
PROVIDIAN NATIONA~L BAi~K
295 MAIN STREET
TILTON, NH 03276
PLAINTIFF
VS
RONALD E SILER
4209 PARK ST
CAMP HILL, PA 17011-4138
LINDA M SILER
4209 PARK ST
CAMP HILL, PA 17011-4138
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, RONALD E SILER, is an individual who resides at
4209 PARK ST, CAMP HILL, PA 17011-4138, and LINDA M SILER, is an
individual who resides at 4209 PARK ST, CAMP HILL, PA 17011-4138.
3. The Defendants are indebted to Plaintiff on the credit account
by virtue of charges or cash advances incurred by the Defendants
or authorized by the Defendants on a credit card or line of credit
owned by the Plaintiff bearing account number 4479434502515799.
4. The Defendant requested an account, account number
4479434502515799, 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 Defendants have failed to pay the amount owed in
accordance with the Account Agreement and have failed to pay the
outstanding debt as agreed.
6. The Defendants are indebted to the Plaintiff in the amount of
$1,890.50 as of 10/06/2000, plus pre-judgment contractual interest
at the rate of 23.90% 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 $321.00.
WHEREFORE, Plaintiff demands that judgment be rendered in
favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the
Defendants in the amount of $1,890.50, plus pre-judgment interest
at the contractual rate of 23.90% per annum from 10/06/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $321.00, less payments made, plus costs and any
other such relief as this Court deems reasonable and just.
COUNT i- ALTERNATIVE
8. Plaintiff hereby incorporates paragraphs 1 through 7 above as
though set forth in full.
9. The Defendants received a monetary benefit, which was in fact
appreciated by the Defendants.
10. The Defendants accepted the benefits.
11. By virtue of the circumstances surrounding the request for
funds made, the Defendants 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
Defendants to retain the benefits of the funds or to be unjustly
enriched at the expense of the Plaintiff or allow the Defendants
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
Defendants in the amount of $1,890.50, plus pre-judgment interest
at the contractual rate of 23.90% per annum from 10/06/2000 until
the date of the judgment herein, plus reasonable attorney's fees
in the amount of $321.00, 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.
VERIFICATION
I, HEATHER K00REMAN , 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
contents thereof; that the same
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 Cou~~
Date
foregoing complaint and know the
is true of my own knowledge,
~California.
Designated Agent
Pravidian National Bank VISA® or Masta~di~..... ~. · m
September 8, 2000 H 1 15 I/
Please review this document and keep it with your other impodant papers This Account Agreement contains the terms which govern your Providian Naficoai Bank VISA or MasterCard Account
(the "Account") The Account allows you fo make purchases by using your VISA or MasterCard card (the "Card") wherever it is honored and to get cash advances from us or any other participating
financial institution and from Automated Teller Machines Conveblen. c,e chec. ks ma.y als.o ~ provided to you as an additiocat way to use the Account In this Agreement, "you" and "your" mean
each parson for whom we have opened a credit card Account "We, 'our," ours, and us mean Providian National Bank or its assignees, as listed on your billing statement The Account may be
used only for personal family, household, and chahtable purposes, and not for any business or commercial purpose Any use of this Account shal~ constitute acceptance of the terms of this
Agreement lftheAcc~untwanopenedasai~intaccouct~wercayect~ntheinstructi~ns~feitherj~intacc~unthdider. Youandweagreeasfollows:
Payments. You will receive a monthly statement showing your outstanding balance Payment on this Account is required in U S dollars (checks must be payable at a U.S office of the bank the
check is drawn on) for at least the payment rive as shown on your statement by the payment due date in accordance with payment instructions on your monthly statement. The back of your
statements showa the rules we follow when we post payments. Convenience checks and other checks we issue to you may not be used to make payments on your Account or to make payments
on any other account you have with us or our affiliates The payment due will be: 2% of the new balance shown on your statement plus the amount of any past due payment, and may include the
amount by which the new balance exceeds your credit line However, the payment due will not be less than $15 unless your new balance is less than $15, in wtsob case the payment due will be
the amount of the new balance) If your Account is past due or above the credit line, we may require a higher minim urn payment, but we will notify you before doing so If your payment is more than
the payment due, it will be treated as a single payment and none of it will be applied to future payments due We may accept late or padial payments, or payments marked "paid in full" or marked
with other restrictions, without losing our dght to collect all amounts owing under this Agreement
If you have made special payment arrangements with either First Union or Providian, you need to continue making the agreed upon payments
Finance Charges, Except as described in the Grace Period for Purchase Balance section of this Agreement, finance charges begin to accrue on a debit when it is included in one of your daily
balances and continue until that balance is reduced by a payment or credit Your Account has the following balances: The Purchase Balance, which consists of your existing Purchase Balance
and new purchasesyou make with your Card and fees for certain optional services; one or more Custom Cash Advance Balances, which consists of balances that you transfer to your Account
using balance transfer checks and balances that we transfer for you; and the Cash Advance Balance which consists of all other cash advances and cash advance transaction fees. Any payment
amount we rece~'e that exceeds the finance charges and fees then due will ordinarily be applied first to the Balance with the lowest Annual Percentage Rate (APR), until that Balance is zero, and
then to the Balance with the next lowest APR, until that Balance is zero, and then to any remaining Balance, We reserve the right to apply payments differently without further not'~e
The Purchase, Custom Cash Advance, and Cash Advance Balances are reduced by payments as of the date received, and by credits as of the date paste3' Purchases are included in your
Purchase Balance as of the date made. Custom cash advances are included in your Custom Cash Advance Balance as follows: fonds electronically transmitted to other lenders to transfer
balances, as of the date transmitled; checks to transfer balances, as of the date presented to us Other cash advances are included in your Cash Advance Balance as follows: cash advances
from other financial institutions and through Automated Tellers, as of the date made; cash advance checks made payable to you that are identified as cashier's checks and mailed to you at your
request, as of seven days after the date we print on the check; all other checks as of the date presented to us Other debits are included in your Purchase, Custom Cash Advance, or Cash
Advance Balance as of the dele posted Ficaese cherges are added to your Purchase, Custom Cesh Advance, and Cash Advance Balances each day and are then pasted es the last dey of the
billing cycle. There is no grace pedod for custom cash advances or other cash advances
To figure the daily finance charge for each fypa of Balance, we stsd with your previous day's Balance, add all debits and subtract all credits for the current day and multiply the net amount by the
applicable daily periodic rate see following paragraphs The finance charge for each fypa of Balance is then added to and included in that day's Balance. We treat a credit balance for any day as
zero We determine the total finance charges en balances for the billing cycle by adding together the finance charges for each type of Balance for each day within the billing cycle. In calculating
finance charges, an ad ustment will be made for any transaction or payment that would have affected the finance charge calculation in a phor billing cycle had it been posted in that cycle Tbe
applicable daily padodic rate for such a transaction will be the rate in effect for the current billing cycle rather than the rate in effect on the date of the transaction.
Your statement includes an average daily balance for each type of Balance You can multiply each average daily balance that is not zero by the number of days in the billing cycle and the periodic
rate to obtain sub®leis, and then add the subtolals together to determine your total finance charges on balances for the billing cydie
The term "Prime Rate" as used in the Agreement means the highest pdrse rate published in the Wall Street Journal on the first business day of the previous calendar month. Any increase or
decrease in the Annual Percentage Rate will take effect on the first day of your billing cycle and may result in a slight increase or decrease ffi the amount of your minimum payment.
TheANNUALPERCENTAGE RATE (APR)for purobases willvary andmay be adjusted each billing cycle upto 13 4%above Prime Rata, butwillin no event be less than21 9%. Using fhis
formula, the APR for purchases in the September 20(~ bitliag cycle is 229%, corresponding to a daily periodic rate of 006274%
The ANNUAL PERCENTAGE RATE for cash advances is 21 9%, corresponding to a daily periodic rate of 0.06000%
If we receive your Account payment late 2 or more limes in any 6-month period since October 1, 1999, on each such occurrence we may increase the APR for purchases up to a maximum of
23 3% (corresponding to a daily periodic rate of 0.06384%), and increase the APR for cash advances and cuslom cash advances up to maximum of 23.9% (corresponding to a daily periodic rate of
006548%) If after yea receive the higher rates your payments are receiveq on time aed you meet ail other terms of this Agreement for 3 consecutive months, you may contact our Customer
Service department and, at your requesL we will review your Account for a possible APR reduction
If at this time the APRs in your Account have already increased because you did not meet the existing terms of your Account Agreement, your existing APRs will continue to apply. If you meet all
terms of this Agreement for 3 coneecut~ve months and yes contact our Customer Service department, we will review your Account for a possible APR reduction Starling July 2000, however, the
APRs described in the preceding paragraph will apply, ~f your Account payments are received late 2 or more times in any 6-month period since October 1, 1999. ·
Grace Perfad for Purchase Balance. New purchases posted to your Account in billing cycles with no previous balance, or when the previous balance was fully paid during the cycle, de not begin
to incur a finance charge until the stsd of the next billing cycle. You will pay no finance charge on such new purchases if you pay the total new balance in foil by the payment due date shown on
your statement. New purchases posted in any other billing cycle incur a finance charge, and there is no peded in which such purchases may be repaid without iesumag a finance charge
Fees. We may charge your Account $0 for: each Card you ask us to replace; each returned payment; each check you write on your Account that we return unpaid; each stop payment order or
renewal of such an order; each billing cycle within which your Account is delinquent (lats cherge); and each billiag cycle within which your balaese exceeds your credit line (ovedim" R fee), even if
your Account is closed If you request copies of billing statements that were first sent to you more than three months earlier, we may charge a handling fee of $2 for each such copy. If you request
that we make a one-time automatic payment from your personal checking account, we may charge your credit card account a fee of $4,95 for each request. This fee is a FINANCECHARGE, and
it will apply regardless of whether funds are available in your personal checking account to make the payment
We may charge a transaction fee of 3% (minimum $5), which is a one-time FINANCE CHARGE, on the amount of each cash advance, including cash fTom financial institutions, and ATMs, wire
transfers, money orders, foftery tickets, casino gaming chipa, and similar transactions.
Default You will be in default: if any information you provided us proves to be incomplete or untrue; if you de not comply with any pad of this Agreement upon your death bankruptcy or
insolvency; if you da not pay other debts when due; if a bankruptcy petition is filed by or against you; or if we believe in good faith that you may not pay or perform your obligations under this
Agreement. If you are in default we may, without further demand or notice, cancel your credit privileges, decfara your Account balance immediately due and payable, and use any remedy we may
have. In the event of your default, the outstanding balance on your Account shall continue to accrue interest at the APR s disclosed in the Finance Charges section of this Agreement, even if we
have filed sui o collec he amoun you owe
Credit Line. Your credit line is specified from time to time in a separate notice. Your monthlystatements show your credit line and the amount of your available credit. We may increase or
decrease your credit line based on information we obtained Eom you or your credit rec. orda Your available credit is normally the difference between your credit line and your Account balance
(including transactions made or authorized but not yet posted. If you send us a ~arge payment check, we may limit your available credit while we confirm that the check will clear, For cedain
transactions, available credit may be less. You wil/not use your Account for and we may refuse to honor any transaction which would cause you to exceed your available credit
Pmmffie to Pay. You promise to pay us when due all amounts borrowed when you or someone else use your Account ,even if the amount charged exceeds your parrniesion all other
transactions and charges to your Account, and collection costs we incur iesludiag, but eel limited to, reasonable attorney s fees and court costs f you w n the su t, we w pay your reasonab e
attorney's fees and court costs )
Changes. After we provide you any notice required by law, we may change any part of this Agreement and add or remove requirements. If a change is made to the Finance Charges section of
this Agreement, the new finance charge calculation will apply to your entire Account balance from the effective date of the change. Changes will apply to balances that include items costed to your
Account before the date of the obanes, and will apply whether or not you continue fo use the Account.
Foreign Exchange/Currency Conversion. if you use your Card for transactions in a currency other than U S. dollars, the transactions will be conveded to US, dollars, generally using either a i
government*mandated rate or ii wholesale market rate in effect the day before the transaction is processed, increased by three percent 3% If a credit is subsequently given for a transaction it
will be decreased by the same percentage. The currency conversion rate used on the conversion date may differ from the rate in effect on the date you used your Card You agree to accept the
converted amount in U S dollars
(Continuedonraverse)(5846~6~8) 4479434502515799 1525 003 z~61
The Card Cancellation. You may cancel your credit pnvileges at any time by not,r/lng us ~n'wnting and destroying the Card s. Upon the Card expiration at the enq of the month shown on it, we
reserve the right not to renew the Card We may cancel the Card and your credit pnvileges at any time after 30 days notice to you, or without notice if permitted by law If your Card is cancelled or
not renewed finance charges and other fees will continue to be assessed, payments will continue to be dua; and all other applicable provisions of this Agreement will remain in effect If you
terminate your credit privileges, or if we cancel or do not renew the Card, you may no anger wr te checks on your Account, and you shou d destroy any unused checks we have issued o you
Personal IrdormaBon; Documents. You will provide us at least 10 Pays notice gyou change your name. home or mailing address, telephone numbers, employment or raceme. Upon our
request you will provide us addifional financial information. We reserve the dght to obtain information from others, including credit reporting agencies, and to provide your address and information
aboutyourAeso~nttoothers Wemavalsoshareinforrnationwthouraffi aes However. youmaywrie ousa any ime instruc ina us no to share credi info~aionwihouraffiliaes Ifyou
do not fulfill your obligations under this Agreement, a negative credit repeal that may reflect on your credit may be submitted to the credit repoding agencies
Customer Service; Unauthorized Use, Loss, or Theft of Checks or the Card. Each Card must be signed on receipt. You are responsible for safeguarding the Card, your Personat identification
Number ("pIN', whioh provipas eccess ta Automatad Teller Machines)and any checks iesued to you from theft, and keeping your PIN separate from your Card If you discover or suspect that
vou~ Car~, PIN, or any unused checks are lost or stolen, or that there may be an unauthorized transaction on your Account, you will promptly notify us by calling 1-800-933-7221 So we can
immediately act to limit losses and liability, you will phone us even though you may also notify us in writing Your liability for unauthorized use occurhng before you notify us is limited to $50. if you
repeal or we suspect unauthorized use of your Account, we may suspend your credit privileges until we reserve the problem to our satisfaction or issue you a new Card If your Card is lost or
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 or accepi your checks, or fails to return the Card to you We have no responsibility
for goods and services purchased with the Card or checks except as required by law (See Special Rule below ) Certain benefits that are available with the Account are provided by third-party
vendors We ~-.~ hal responsible for the quality, availability, or results of any of the services you cheese to use.
Stop Payment Orders. If you wish to step payment on a check, you may send us a stop payment order by wrifing to us at our address for customer service listed on your statement You can
make a step payment order orally by calling the number listed on your statement When you make a step payment order, you must provide your Account number and specific mformafion about the
check: the exact amount, the pate on the check, the name of the pedy to whom it was payable, the name of the pomon who signed it, and the check number You wilt be asked to confirm an oral
stop payment order in writing We mev disregard vour oral order if we de not receive a sioned wdtten confirmation within two weeks after the oral order, or if we have not received an adequate
descripfion of the item so that payment can be stopped The order will not be effective if the check was paid by us before we had a reasonable oppodunity to act on the order We may, w~thout
liability, disregard a written stop payment order six months after receipt unless it is renewed in writing
Standard of Care. Because this Account involves both credit card and check transactions which are processed through separate national systems before the transactions am consofidated by us,
and because not every check and Card slip will be sent to us, transactions in your Account wifi be processed mechanically without our necessanly reviewing every item Our processing system will
call our abention to cedain items which we will examine We will examine all transactions when you report that your Card or checks have been lest or stolen We do not intend ordinarily to
examineallitams, andwewillnotbenegligentifwedonotdoso. This ru~eestabiishesthestanderd~f~rdtharycarewhichweing~dfaithwi~exerciseinadministebegy~urAcc~unt, 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 ail 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 statements aeainst vour record and
to nofifv us immediatelv of any unauthorized transactions or errors
Waiver of cartsln Rights. We may delay or waive enfomement of any provision of this Agreement without losing our nght to enforce it or any other prevision later You waive: the nght to
presentment, demand, protest, or notice of dishonor; any applicable statute of limitations; and any right you may have to require us fo preseed against anyone before we file suit against you
Appllcabfa Law;, Severabllity;, Assignment. No matter where you live, this Agreement and ~/our Account are gevemed by federal law and by New Hampshire law. This Agreement is a final
expression of the agreement between you and us and may not be contradicted by evidence or any alleged oral agreement If any provision of this Agreement is held to be invalid or unenfomeeble,
you and we will consider that provis~on modified to conform to applicable law, and the rest of the provisions in the Agreement will still be enforceable At any time after we determine in gcod faith
that any proposed or enacted legislation, regulatory action, or ud~cial decision has rendered or may render any mater~al provisions of this Agreement invalid or unenforceable, or impose any
increased tax, repealing requirement, or other burden in connection with any such provision or its enforcement, we may, after at least 30 Pays notice to you, or without notice if permitted by law,
cancel the Card and your Credit privileges We may transfer or assign our right to all or some of your payments. If state law requires that you receive notice of such an event to protect the
purchaser or assignee, we may give you such notice by filing a financing s~tement with the state's Secretary of State.
Notices. Other notices to you shall be effective when deposited in the mail addressed to you at the address shown on our records, unless a longer notice period is specified in this Agreement or
by law, which pehed shall stad upon mailing Notice ta us shall be mailed to our address for customer service on your statement (or other aderesses we may specify) and shall be effective 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
NotifyUsinCaeeofError$orQuestierrsAbeutYourBIti. If you think your bill is wrong or if you need more information about any transacfion on your bill, writa us on a separate sheet, at the
address listed in the Billing Rights Summary on your bill Wdte to us as soon as possible. We must hear from you no later than 60 pays 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 rights. In your letter, give us the following information: - Your name and Account number. - The dollar amount of the
suspected error -- Desedbe the error and explain, if you can why you believe there is an enter. If you need more information, descdbe the item you are not sure about.
If you have authorized us to pay your credit cerd bill automafically from your checking account, you can stpp the payment an any amount you thiok is wrong To stop the payment, your letter must
reach us three business pays before the automatic payment is scheduled to occur
Your Rights and Our Responsibilities After We Receive Your Written Notice. We must acknowledge your iottar within 30 pays, unless we have corrected the error by then Within 90 days,
we must either correct the error or explain why we believe the bill was correct After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent We can
continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit line You do not have to pay any questioned amount while we
are invesfigafing, 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 on your bill, you will not 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,
andyouwifihavetomakeuptbemissedpaymentsonthequestfanedamount. In eilher case, wewillsendyouastatementoftheamountyouoweandthedatethatitisdue Ifyoufaiitopaythe
amount we think you owe, we may report you as delinquent However, if our explanation does not safisfy you and you write to us within 10 days telling us that you sfill 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 to We must tell anyone we roped you to that the mafter bas been settled between
us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct.
SpeciaIRule for Credit Card Purchases. If you have a problem with the quality of the property or services that you pumhased with our crepe card and you have tried in good faith to correct the
prdelem with the merchant, you may not have to pay the remaining amount dee on the goods or services. There are two limitations on this hghh (a) you must have made the purchase in your
home state, or if not within your home state, within 100 miles of your current mailing address; and (b) the purchase price m est have been more than $50. These limitafions do not apply if we own
or operate the memhant, or if we maifad you the advertisement for the property or services.
VALERIE ROSENBLUTH PARK, ESQURIE
Attorney I.D. #72094
PARK LAW ASSOCIATES, P.C.
25 E. State Street
Doylestown, PA 18901
(215 348-5200
ATTORIqEY FOR PLAINTIFF
PROVIDIAN NATIONAL BAiqK
Plaintiff
VS.
RONALD E. SILER AND
LINDA M. SILER
Defendant
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: N0.2001-00713 1
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above captioned matter settled,
and ended upon payment of your costs.
discontinued
PARK LAW ASSOCIATES, P.C.
VAL ROSENBLUTH PARK, ESQUIRE
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00713 P
COMMONWEALTH OF PENNSYLVA_NIA:
COL~TY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS
SILER RONALD E ET AL
DAWN KELL ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT & NOTICE
SILER RONALD E
DEFENDANT , at 0017:33 HOURS,
at 4209 PARK ST
CAMP HILL, PA 17011
RONALD E. SILER
a true and attested copy of COMPLAINT & NOTICE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 7th day of February , 2001
by handing to
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.06
Affidavit .00
Surcharge 10.00
.00
36.06
Sworn and Subscribed to before
me this )g~-~ day of
~ ~rothonotary
So Answers:
R. Thomas Kline
02/08/200
PARK LAW ASSOCIATES
Deputy Sheriff
SHERIFF'S RETURN -
CASE N®: 2001-00713 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDIAN NATIONAL BANK
VS
SILER RONALD E ET AL
REGULAR
DAWN KELL
Cumberland County,Pennsylvania,
says, the within COMPLAINT & NOTICE
SILER LINDA M
DEFENDANT at 0017:33 HOURS,
at 4209 PARK ST
CAMP HILL, PA 17011
RONALD E. SILER (HUSBAND)
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 7th day of February , 2001
by handing to
& NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this 72 ~ day of
So Answers:
R. Thomas Kline
02/08/2001
PARK LAW ASSOCIATES
Deputy Sheriff