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HomeMy WebLinkAbout01-0910VALERIE 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, JULIE A OTT INC. Plaintiff VS. 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 enterin9 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# :4168100007842253 CUM~EPdSAI~D COUNTY COURT OF COMHON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 VS PLAINTIFF JULIE A OTT 16 E KING ST APT 9 SHIPPENSBURG, PA 17257-1344 DEFENDANT CIVIL ACTION 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, JULIE A OTT , is an individual who resides at 16 E KING ST APT 9 SHIPPENSBURG, PA 17257-1344, 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 4168100007842253. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOE THAT PURPOSE. 4. The terms of said account are stated in the documentation attached hereto as Exhibit UA". 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 $2,013.31 as of 09/25/2000, plus pre-judgment contractual interest at the rate of 24.00% 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 $342.00. W/{EREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $2,013.31, plus pre-judgment interest at the contractual rate of 24.00% per annum from 09/25/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $342.00, 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 T~IS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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, First Select, Inc. and against the Defendant in the amount of $2,013.31, plus pre-judgEent interest at the contractual rate of 24.00% per annum from 09/25/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $342.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: ~L///~ 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 I,' ~,~I~E~ KO0~ , 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,~n/~ Date Designated Agent re of California. EXHIBIT FIRST'SELECT IMPORTANT LEGAL NOTICE Federal law gives you 30 days after you re~ive this letter to dispute the validity of the debt or any part of it. /f you do not dispute the validity of th~ debt, or any part of it, wRhth that p~riod, ~e will .as~. me that the.debt is valid. If.you dispute the debt, or any parl of it, in writ~g--by mailing us a notice to that effect on or befor~ the 30th day following the dale.you r~_wed.~t~.~ I~ter--we will obtain and t~ml to you ?roof ~verifmation) of~e debt. ~nd if,, w~ the sam? [mtiqd, you r~lu~ iq. writing the name ~.nd a..d.d.d.d.d.d.d.d.~? of ti? original creditor 0f diff~mt from the eurr~nt ctedaor), we vall furmsh you with that informatwn too. If we do recmve a mnely written nonce, all efforts to collect this debt will be suspended until we mail any roquired information to you. Your fight to mall us a ~qtten notice of dispute lasm until the 30th day following the day you t~cdive th/s letter. We will wait until sufficient time has elap~d for us to be able to receive a v,~itten notice of dispute from you--even it'you mall it on the 30th day following the date you r~ceived this letter--before referring your account to an attorney in your state to file suit against you should it be necessary. The purpose of this communication is to collect a debt; any information obtained will be used for collecting the debt. ACCOUNT AGI~oN,~,g: e,r, om naon..tio,~ If you fail to ~Lfill the ~nm of your "Original Ternm'9. If your Original T~'nm pro~id~t for diffun~mt Pamual perceutaga Rates to be applied to difforent components of your outst~ balance, we will ~decned by federal law and th~ law of your state of residence. This Agreement is a a'edi~ obligation, a negative credit report reflecting on your credit record may be suba~ted to a credit reporting agency. In order to dispute any ita'orrnation we are reporting about your Accouut, you must write to us at the following address: First Select, P.O. Box 9104, pleasauto~, Galifomia 94566. We may $lmre ~format/on with our ~[51iat~.~n¢ludine. without Ii.tailor. P~ovidi~m N~ional Ba~ and shar~ cr~it information with our a~il/ate~. YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our r~eponsibilities under the Fair Credit Billing Act. Notify Us in Case of Errors or Questions About Your Bill If you ttfink your bill is wrong, or if you need/note information about an ~try on your bill, write ~, on a separate she~ at the following address: First Selac~ P.O. hear from you no later than 60 days aft~' we sent you the first bill on which the error In the tst~er, give us the following: apply any unpaid amouut agains~ your credit line. You do nnt hav~ to pay any questioned amount while we are investigating, but you are still obligated to pay the If we fred that we have made a mistake on your bill, you will not have to .pay any your CHASE credit card and you have tried in good faith to cor~t the problem with the merchant, you may not hav~ to pay the remaining amount due on the goo~ or services. There are two limitations to this right: (a) you must have made tho your current mailing eddr~s; and (b) the purchase price must have boen more thttn mer~ham, or we or CHASE mailed you the edvertisemant for the propeay or SHEiRIFF'S RETURN CASE NO: 2001-00910 P COMMONWEALTH OF PENNSYLVanIA COUNTY OF CUMBERLAND - NOT FOUND FIRST SELECT INC VS OTT JULIE A R. Thomas Kline duly sworn according to law, says, that inquiry for the within named defendant, OTT JULIE A unable to locate Him COMPLAINT & NOTICE .Sheriff or Deputy Sheriff, who being search and he made a diligent DEPENDANT but was He therefore returns the in ibis bailiwick. the within named DEPENDANT , OTT JULIE A , NOT FOUND as to DEFT. MOVED, LEFT NO FORWARDING, AS PER SHANA LEWIS ON 3/14/01 RETURN NOT FOUND Sheriff's Costs: Docketing 18.(]0 Service 12.40 Not Found Return 5.(]0 Surcharge 10.00 .00 45.40 Sheriff of Cumberland County PARK LAW ASSOCIATES 03/14/2001 Sworn and subscribed to before me this /{,~ day o f ~z~_~-~ ~! A.D. Pro~not ary ! -/~ / I HEREBY CERTIFY THAT THE ~;;THIN I$ A TRUE AND CORRECT COPY OF VALERIE 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 TRUE COPY FROM RECORD CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, JULIE A OTT INC. Plaintiff VS. Defendant NOTICE NO. ol- 9/0 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 A_N ATTEMPT TO COLLECT A DEBT. ~ 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# :4168100007842253 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 VS PLAINTIFF JULIE A OTT 16 E KING ST APT 9 SHIPPENSBURG, PA 17257-1344 DEFENDANT NO. CIVIL ACTION 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, JULIE A OTT , is an individual who resides at 16 E KING ST APT 9 SHIPPENSBURG, PA 17257-1344, 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 4168100007842253. 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 $2,013.31 as of 09/25/2000, plus pre-judg~nent contractual interest at the rate of 24.00% 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 $342.00. W-~EREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $2,013.31, plus pre-judgment interest at the contractual rate of 24.00% per annum from 09/25/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $342.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COD-NT 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 TRIS IS AN ATTF~PT TO COLLECT A DEBT. ANY INFOP.~ATION OBTAII~-~D WILL BE USED FOR THAT PURPOSE. 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, First Select, Inc. and against the Defendant in the amount of $2,013.31, plus pre-judgment interest at the contractual rate of 24.00% per annum from 09/25/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $342.00, 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 INFOP~ATION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION I, HEAIH£R , 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,~7~ Date Designated Agent te of California. F1 RST"SELEC_T EXHIBIT IMPORTANT LEGAL NOTICE Fedm~l law gives you 30 days a,~r you receive this letter to dispute the validity of the debt or any p~ of it ffyou do nut dizpute the validity of the d~N, or any part of it. wilhin that period, ye will . .~:s~o that the.d~bt is.valid. If~ou dis'pm the de .~,. or 5ny p .a~.. of ~,~ .,~it~.. ~g--b...y .m~i.,'ling us · n .otic, e to tha effo~ on ~r yef .ore the 3m ,day, ,followi~..g the det~ you l'~lv~d ~ letter--we vail obtain ami mall to you.proof (v~rificatLo~.) or ~ acm. .aha ~, wnnm me san~e penpa, you rs'quest ~ vrclt~g the nam~ aaa a?~ss or original creditor (if~ from the o~mt ~r~itor), we vall ftanish you with that information too. If we do r~c~vo a tunaly va'men nntw,~, ail eft'ora to collea tim debt will be suspended until w~ mail any r~quls~ imeommion to you. Your fight to mail us a ~-itten notice of dispute lasts u.~fl the 3~ day following the day you r~ceiv~ this W~ will wait until sufficient time has elapsed for us to b~ able to receive a wrimn not:es of dlspu~ from you--~vea if you maal it on tho 3 0th day following tho date you received this IcCter~or~ r~ernng your aououtg to m attorney in your state to file suit affalmt you should it be nec~asa~. The purpose of this ~ornmunication is to collect a debt; any information obtained will be used for collecting the debt. ACCOUNT AGl~r,Fae-'~,~Nr~,: ~'er, o~ ~rorma.o,~ If you fail to ~I~1] ~ ~rms of your Your CHASE account Ires be~n transfergd to Fi~t Select. Your CF/AgE gcount was clo~.'d at tho tinm of this transfer and will therefore continue to be closed. This Account Agre~me~ contains th~ taflm that govern your First Salect account (tho "Account"). ~l ~ Ags~m~t, ~you~ an~ ~yogr~' ~ each person who is liabl~ for ~aecaus~3m~nt on the Account "We," "our," and "us" mean Fkst Select.or its aasigeec~. your Accmmt has ~ ti-a~s~e~l to ~, yot~ a~e ~ow obhgated to repay the Account to us instead of CHASE. fftho Account was opened as ajoim account, we may act on thc insfractions of any joiut account haide~. Payments/Finance Clmrge~ As long as you have ~ balance outstanding o~ your Account, finance charges ~e calculated as follows: To figure the finance charges for each billing cycle, we multiply the average daily balance on your account by a daily pe~od!c.rate. The daily periodic rate we apply is your A~ounfs Annual Percentage ~ di~nded by 36J. The Annual percentage Rate will be calculated as disclosed m your mo~t recent CHASE ~ccount terms (the "Original Terms"). If your Ch4~*! Tera~ provided for di~..ere~_t Annual Ra~s to be applied to different components of your outriding balance, we will apply the lowest such A~mual Percefgage Rate on yom' entire ouL~ndi~g balance. We may accept late or partial pa~nenta, or payments marked "paid in full" or marked with other res~ictions, without losing our Hght to cdiin:t all amounts owing under this Agreement. You may ask First Select to pay your Account by debiting your checking or savings accounL First Select will fir~ verify your ide~ity and eligibility For this service. You may revoke your au~orizafion by writing to Fi~t Select Customer Service. l~ee~ We will charge your Account a fee for each billing cycle within which your Accourg is delinquent (late charge). The amount of the late cimrge will be ~ disclosed in your Original Terr~ or the maximum ls~ charge permlited by the law of your state of realdenco, whichever is lower. We will charge your Account a fee for each returaed pa~nent check (returned check charge). The amount oftbe returned check charge will be as disclosed in your Orlg~d Tenm, or the maxLmum returned check charge pe~i~cl by tho law of your s~te of residenc~, whichever is lower. To the cx~nt provided in your Origi~l Terms a~l to the exte~ permitted by applicable law, in addition to your obligations to pay tho ouL~tandhig balance on your Account, plus intereat and fees a~ disclosed hcfe~n, we may also charge you for any collection cos~ we incur, including but not limited to rea~mable afters fees and court costs. If your Original Terms provided for an awazd of attorney's fee~ and court cos~e, such provision as incorporated herein ~hMI apply reciprocally to thc prevailing pa~y in any lawsuit arising om of ~hi$ Agr~menL Non-Waiver of Certain Right. We may dein¥ or waive enforcement of any provision of this Agreement without loalng our ngfil to enforce it or any other provision later. Applicable L~w, Severability, Assignment. No matter where you llve, this Agreement and your Account are governed by federal law and by the law of the state desig~lated as the applicable law in your Original Tern~ If your OrigLnal Terms did not contain an applicable law provision, then this Agreement and your Accouut are governed by federal law and thc law of your stete of residence. This A~eement is a flfml expression of the a~eemcnt betwee~ you arid us a~l may not be couffadicted by eviderge of' any alleged oral agr~rnent Ifa provision of this agse~mont is hold tO be invalid or unenforceable, you a~d we will consider that provialon modred to con~orm to applicable inw, and the rest of the provision in the Asr~m~t will still be enforce~le. We may tramfer or assign our right to all or some of your paints. If state law requ~es Lhat you receive notice of such an event to protect ~ purchaser or thc ~i~11ee, we may give you such notice by filing · ~ma~cing statemeut ~ the state's Sec~ta~y of State. ~ustomer Service. For general qu(~[iom regarding your Fh~t Select ~ccount, pl~se call our toll-fi'ee service number, 1-888-92,1-2000. For quality assurance pu~, and to improve customer service and s~curity, telqthone calls to or ~'om our offices m~y be moaitoi~d or recorded. credit obligation, a n~gative ~-edit report r~fl~ting on yo~ ~ ~d may be mb~ ~ a ~e~t ~Mg ag~. ~ ~ to ~u~ ~y ~fion we ~e ~ ~om ~ ~co~ you m~ ~e to ~ ~ ~ foBo~g ad~: F~ Sel~ P,O. ~x 9104, PI~ ~a 94366. W~ ~v ~ i~ ~s n~ ~ ~ ~fion a~m y~ fi~ ~d ~ ~ihi~i~ No~ Us M C~ of E~ or ~om About Yo~ Bffi VALERIE 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 FIRST SELECT, JULIE A OTT IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA INC. Plaintiff VS. Defendant NO. 01-910 PRAECIPE TO REINSTATE COM~LAINT TO THE PROTHONOTRY: Please reinstate the enclosed Civil Action. Respectfully submitted: PARK LAW ASSOCIATES, P.C. BY: ~ ~~ VALERIE ROSENBLUTH PARK, ESQUIRE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN - REGULAR CASE NO: 2001-00910 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS OTT JULIE A DEP DAVE MCKINNEY , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE OTT JULIE A DEFENDANT , at 1828:00 HOURS, at 329 WALNUTDALE ROAD SHIPPENSBURG, PA 17257 CATHERN OTT (MOTHER) a true Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 31st day of May by handing to and attested copy of COMPLAINT & NOTICE the , 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 10 54 00 10 00 00 38 54 Sworn and Subscribed to before me this ~ day of ,:~,~ / A.D. So Answers: R. Thomas Kline O~/O1/200i PARK LAW ASSOCIATES 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: 329 WALN-gTDALE ROAD SHIPPENSBURG, PA 17257 4168100007842253 CUMBERLAND COI/NTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS JULIE A OTT Defendant NO.01-910 PRAECIi~E 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 $2,013.31 $342.00 $329.63 ($0.00) ($0.00) TOTAL $2,684.94 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 ma~ked~xhibit -'~/~ VALERI/~SENBL[~UTH PARK,ESQUIRE Attorney for t- - he Plaintiff AND NOW,.~J&a~t~[ ~ , ~/ , 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. 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. DRIVE 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CLTMBERLAND COUNTY FIRST SELECT, 1NC. Plaintiff VS JULIE A OTT Defendant I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD PLEASANTON, CA 94588 DEF: 329 WALNUTDALE ROAD SHIPPENSBURG, PA 17257 COURT OF COMMON PLEAS NO. 01-910 NOTICE OF PRAECI~E FOR ENTRY OF DEFAULT JUDGMENT TO: JULIE A OTT 329 WALNUTDALE ROAD SI-IIPPENSBURG, PA 17257 DATE OF NOTICE: 6/21/01 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 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, 4th FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. BY: ~~ VALERIE ROSENBLUTH PARK, ESQ. cci 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: 329 WALNUTDALE ROAD SHIPPENSBURG, PA 17257 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS JULIE A OTT NO. 01-910 Defendant VERIFICATION OF NON-MILITARY SERVICE 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 JULIE A OTT, Defendant is over 21 years of age; that his/her place of residence/business is located at 329 WALNUTDALE ROAD SHIPPENSBURG, PA 17257 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 1940 and its amen~ents. Relief Act of Congress of PARK LAW A/SOC~E~, P C. // BY: Vale ri~Rosenblut~Park Attorney for Plaintiff El0 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: 329 WALNUTDALE ROAD SHIPPENSBURG, PA 17257 CUMBERLAND COUNTY COURT OF COM/~ON PLEAS FIRST SELECT, INC. Plaintiff VS JULIE A OTT Defendant NO. 01-910 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: [X] 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. PR~HON~T,I~¥:'~ /~.~ PURSUANT TO THE FAIR DEBT COLLECTION PR~ICES 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.