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HomeMy WebLinkAbout01-1772VALERIE 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 ATTORiqEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, ROGER A HOOVER INC. Plaintiff VS. Defendant NO. 01- 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# :4168100012337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 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, ROGER A HOOVER , is an individual who resides at 68 STAMY RD NEWVILLE, PA 17241, 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 4168100012337620. 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 $10,372.99 as of 12/06/2000, plus pre-judgment contractual interest at the rate of 18.00% 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 $1,763.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $10,372.99, plus pre-judgment interest at the contractual rate of 18.00% per aruaum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,763.00, 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 THIS 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 $10,372.99, plus pre-judgment interest at the contractual rate of 18.00% per annum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,763.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LA~'~ 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 OETAINED WILL BE USED FOR THAT PURPOSE. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY iNFORF~%TION OBTAINED WILL BE USED FOR THAT PURPOSE. VERIFICATION HEATHER KOOREMAN Designated Agent of FIRST SELECT, , declare that: I am 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 th~ State of California. Date Designated Agent F1R.ST SELECT =' HIBIT ACCOUNT AGREEMENT Your DISCOVER account has been transferred to First Select Corporation. Your DISCOVER account wins closed at the time of this transfer, and will therefore continue to tm closed. This A~¢ount Agreement contains the t eraxs that govern your Fil'st S¢1~c~ account (the "Account"). In this Agreement, "you" and "your" mean each person who is liable for payment on the Account. "We," "our," "oum," and "us" mean First Select Corporation or its a~ignees. Because your Account has b~en transferred to us, you ar~ now obligated to repay the Acceunt to us im't=ad of DISCOVER. If the Account was op~ned as a joint account, we may act on the instructions of any joint accountholdar. Payments / Finance Charges. ,M long as you have a balance outstanding on your Account, f'manc~ charges ;we calculated x~ follows: To figure the finance charges for each billing cycle, we multiply the average daily balance on your Account by a daily l~'iodic rat~. Th= daily periodic rate we SHERIFF'S RETURN CASE NO: 2001-01772 P COMMONWEALTH OP PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND FIRST SELECT INC VS HOOVER ROGER A R. Thomas Kline duly sworn according to law, says, that inquiry for the within named defendant, HOOVER ROGER A unable to locate Him COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being search and he made a diligent DEFENDANT He therefore returns in his bailiwick. but was the the within named DEFENDANT , NOT FOUND , as to HOOVER ROGER A DEFENDANT WAS NOT ABLE TO BE SERVED AT ADDRESS PRIOR TO EXPIP~ATION DATE. STATED Sheriff's Costs: Docketing 18.00 Service 8.06 Not Found Return 5.00 Surcharge 10.00 .00 41.06 Sheriff of Cumberland County PARK LAW ASSOCIATES 04/27/2001 Sworn and subscribed to before me this .~ ~ day of ~/ Prothor~ot ~ry I HERERY CERTIFY THAT THE ~*iTHIN ~$ A T~UE AND GOgREGT OOPY OF ~¢~,j THE ORIGINAL ON FILE VALERIE ROSENBLUTH PARK, Attorney I.D. #72094 PARK LAW A~SOCIAT~.S, P.C. 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ESQUIRE TRUE COPY FROM RECORD Ta~tmmy wl~'eoL I hale unto set my hand CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS. ROGER A HOOVER Defendant NOTICe. NO. O, -- / ? 7 ~--~ ~__~OLC C'--/--~ 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 CAP, LISLE, 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#: 4168100012337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 VS PLAINTIFF ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 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, ROGER A HOOVER , is an individual who resides at 68 STAMY RD NEWVILLE, PA 17241, 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 4168100012337620. 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 $10,372.99 as of 12/06/2000, plus pre-judgment contractual interest at the rate of 18.00% 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 $1,763.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $10,372.99, plus pre-judgment interest at the contractual rate of 18.00% per annum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,763.00, 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 bythe 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 THIS 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 $10,372.99, plus pre-judgment ~nterest at the contractual rate of 18.00% per annum from 12/06/2000 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,763.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW A~SOCIATES, P.C. BY: VALERIE ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. =XHIBIT ACCOUNT AGREEMENT Your DISCOVER account has been tr-~nsfefr~ to First Select Corpor~ioP~ Your DISCO~R ~=o~ ~ cI~ ~ ~ t~c of~ ~, ~ ~11 ~fore ~e to ~ cl~ ~ ~unt ~t =~ ~e t~ ~a $ov~ ~ur F~ Sel~ ~um (~ "A~om"). ~ ~ ~ "you" ~d ~rr' ~ ~h p~ ~ ~ li~le ~ ~ ~ ~$ ~o~ "We," "our." "~" ~ ~" ~ F~ Sel~ C~fi~ ~ ~ ~i~ ~ your ~unt ~ ~ ~ to ~ ~u ~ now obhgat~ to ~y ~e ~ouflt to ~ t~ of DISCO~ ~ A~om w= ~ = ajo~ ~ ~ may a~ on · e i~om of my joMt apply ~ your .~ ~ P~ ~ ~ ~ a~. ~ ~ P~e ~ ~B ~ ~1~ ~ ~ ~.~ m~ ~t DISCO~R ~t ~ (~' ~ T~ ). ~ ~ ~ T~ ~ ~ ~ ~ P~e ~ to ~ a~hed to d~ ~n~ or,ur We may acc~ l~e or p~ ~ or pa~ ~ ~pMd v~ ~ur t~U ~d eh~bd~ ~ ~ ~. Y~ may ~ke ~ur F~ We ~ll ~ y~r ~um a f~ for ~ billMg ~le di~I~ M your ~ T~ ~ ~e ~m late ch~ ~4-~ K-. *u- ' .... ' '' CUMBERLAND County Court Of Common Pleas FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASAi~TON, CA 94588 VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 PLAINTIFF DEFENDANT NO. 01-1772 JUN 0 1 200~C',~ ORDER AND NOW, this day of ~ , 20~1 , upon consideration of the Plaintiff's Petition and upon Motion of Plaintiff, it is ORDERED and DECREED that the Defendant may be served in accordance with Pennsylvania Rules of Civil Procedure, by mailing a true and correct copy of the Complaint to the Defendant at the Defendant's last known address by both certified mail, return receipt requested, and by first class mail, postage paid. A Verification of Service shall be filed by Plaintiff's attorney showing service of the Complaint as set forth herein. CUMBERLAND County Court Of Common Pleas FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ROGER A HOOVER 68 STD2~Y RD NEWVILLE, PA 17241 DEFENDANT NO. 01-1772 PETITION FOR SERVICE OF PROCESS IN ACCORDANCE WITH PA RULES OF CIVIL PROCEDURE TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of the Plaintiff by its attorneys, PARK LAW ASSOCIATES, P.C., respectfully represents that: 1. A Civil Action for assumpsit was filed on 03/26/2001, with this Honorable Court to recover monies owed to Plaintiff as a result of credit extended to Defendant. 2. The Sheriff of CUMBERLAND County made a "Not Found" return of service of the Complaint. A true and correct of the sheriff's return of service is attached hereto, made a part hereof and marked Exhibit "P-l". 3. The last known address of the Defendant is 68 STAMY RD, NEWVILLE, PA 17241 4. Subsequent to the Plaintiff's receipt of the Sheriff's "Not Found" return, Plaintiff made the described efforts to locate the whereabouts of the Defendant as indicated in the attached Affidavit of Investigation. 5. Despite Plaintiff's inquiries, the Plaintiff has been unable to locate the Defendant. 6. Plaintiff's counsel is aware of the footnote under Pennsylvania Rule of Civil Procedure No. 430(a) regarding a good faith effort to include " .inquiries of relatives, neighbors, friends and employers of the Defendant. "; however, such a communication, in the opinion of Plaintiff's counsel, would be in direct violation of the Federal Fair Debt & Collection Act, Section 15 USC 1692c(b) which prohibits communication with third parties without the prior consent of the Defendant. 7. The Plaintiff believes the Defendant is either obstructing or concealing the Defendant's whereabouts. WHEREFORE, Plaintiff prays the Court enter an Order allowing the Plaintiff to serve the Defendant in the same manner as set forth in Pennsylvania Rule of Civil Procedure No. 403 and service shall be attempted by both Certified Mail, Return Receipt Requested, and by First Class Mail, Postage Paid. Plaintiff's attorney shall file an affidavit of service showing service of the Complaint as set forth herein. PARK LAW A~~ BY: ~OS VALERI ENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF SHERIFF'S CASE NO: 2001-01772 P ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RETURN - NOT FOUND FIRST SELECT INC VS HOOVER ROGER A R. Thomas Kline duly sworn according to inquiry for the within named defendant, HOOVER ROGER A unable to locate Him COMPLAINT & NOTICE in his bailiwick. ,Sheriff or Deputy Sheriff, who being law, says, that he made a diligent search and DEFENDANT but was He therefore returns the the within named DEFENDANT DEFENDANT WAS NOT ABLE TO BE PRIOR TO EXPIRATION DATE. Sheriff's Costs: Docketing 18.00 Service 8.06 Not Found Return 5.00 Surcharge 10.00 .00 41.06 , NOT FOUND , as to , HOOVER ROGER A SERVED AT ADDRESS STATED Sheriff of Cumberland County PARK LAW ASSOCIATES 04/27/2001 Sworn and subscribed to before me this day of A.D. Prothonotary EXHIBIT AFFIDAVIT Valerie Rosenbl~th Park, Esquire, being duly sworn according to law deposes and says that she is the attorney for the Plaintiff in the foregoing matter; that she is authorized to take this affidavit on its behalf; and that the facts contained in the foregoing Petition are true and correct to the best of her knowledge, information and belief. Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. VALERIE ROSENBLUTH PARK, ESQUIRE CUMBERLAND County Court Of Common Pleas FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 VS ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 PLAINTIFF DEFENDANT NO. 01-1772 CERTIFICATION OF INVESTIGATION Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that as counsel for the Plaintiff, made the following efforts to locate the within named Defendant. a) A check of the local telephone directory shows that ROGER A HOOVER is not registered with a telephone number at the address of 68 STAMY RD, NEWVILLE, PA 17241 b) A letter addressed to the Defendant with the notation typed thereon, "Address Correction Requested, Forward" was not returned by the Post Office. Do Not c) A letter addressed to the Office of Voter's Registration shows ROGER A HOOVER is not a registered voter with an address of 68 STAMY RD, NEWVILLE, PA 17241. The Office's response is attached hereto, made a part hereof and marked as Exhibit "A". d) A letter addressed to the Office of the Board of Assessment shows ROGER A HOOVER is the owner of the property at 68 STAMY RD, NEWVILLE, PA 17241 The Office's response is attached hereto, made a part hereof and marked as Exhibit e) A letter addressed to the Postmaster shows that mail addressed to ROGER A HOOVER at 68 STAMY RD, NEWVILLE, PA 17241 is delivered. The Postmaster's response is attached hereto, made a part hereof and marked as Exhibit "C". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S.A., Section 4904, relating to unsworn falsification to authorities. PARK LAW ASSOCIATES, P.C. BY: ~/~/~/~ VALERIE ROSENBLUTH PARK, ESQUIRE ATTORNEY FOR PLAINTIFF ARK LAW ASSOCIATE , VALERIE ROSENBLUTH PARK* ROBERT E. ANGST* A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 May 8, 2001 TELEPHONE (215) 348-5200 FACSIMILE (215) 3484015 Voters Registration Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 OUR FILE NO: 24543-1 Dear Sir/Madam: I would appreciate your checking the Voters Registration in order to determine whether the above-referenced person is registered to vote in Cumberland County. I would also appreciate your advising me of the address for which he/she is registered to vote. For your convenience, kindly note the bottom of this letter and return the same in the enclosed self-addressed stamped envelope. Very truly yours, PARK LAW ASSOCIATES, P.C. BY: Tracy Williams Legal Assistant Enclosure Name of Person: ROGER A HOOVER Current Address: Date of Registration: Date of Birth: Previous Registration Address: VALERIE ROSENBLUTH PARK* ROBERT E. ANGST* ARK LAW ASSOCIATE a PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 1890) TELEPHONE (215) 348-5200 FACSIMILE (215) 3484015 May 8, 2001 Office of the Tax Assessor of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 RE: ROGER A HOOVER Dear Sir/Madam: I would appreciate your providing me with the identity of the owner of the real estate listed at the following address: 68 STAMY RD NEWVILLE, PA 17241 Please note the name and address of the owner below and return this letter to me in the enclosed self~ addressed stamped envelope. Thank you for your cooperation. Very truly yours, PARK LAW ASSOCIATES, P.C. Property Address: 68 STAMY RD,NEWVILLE, PA 17241, Name of Owner: Address of Owner: Deed Book and Page No.: EXHiBiT FacetWin Screen Pri, For public, from "CAMA_Login" Or '0/2001 3:03:52 PM CUMBERLAND COUNTY ASSESSMENT OFFICE CONTROL # 30000110 DISTRICT: 30 - NORTH NEWTON TOWNSHIP SD: 1 Short Name : HOOVER, ROGER A LAST NAME : HOOVER FIRST NAME : ROGER A C/O NAME : & GALE M GUTSHALL ADDRESSi : ADDRESS2 : PO BOX 173 POST OFFICE: NEWVILLE STATE & ZIP: PA 17241 PARCEL: 30-08-0593-005. SPEC ID: LOT: ~ Tback: PROPERTY TYPE: R SALES DEED BK/PG ..... 0036B-00676 DATE OF SALE...12/31/1992 SELLING PRICE: 800 Situs: 68 STAMY ROAD Prop Descrip.: LAND USE TYPE: 101 NEIGHBORHOOD: 30 DEEDED ACRES: 2.70 Screen 1 Number -Switch Screens, Down Arrow -Next Entry, CURRENT VALUES Assessed Fair Market FMV - 70730 L - 35000 C&G - B - 35730 approved? -> T - 70730 Enter Selection > X -Exit, J -Jump Mode, Up Arrow -Previous Entry, Record: 56039 F -Forms, I -Image ? -Screens, B -Browse VALERIE ROSENBLUTH PARK* ROBERT E. ANGST* PARK LAW ASSOCIATES A PROFESSIONAL CORPORATION 25 EAST STATE STREET, SUITE 101 P.O. BOX 1779 DOYLESTOWN, PENNSYLVANIA 18901 TELEPHONE (215) 348-5200 FACSIMILE (215) 348-4015 Postmaster United States Post Office NEWVILLE, PA 17241 May 8, 2001 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Our file #: 24543 NAME: ROGER A HOOVER ADDRESS: 68 STAMY RD NEWVILLE, PA 17241 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for provicYmg boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attomey 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney): 3. The names of all known parties to the litigation: FIRST SELECT, INC. VS. ROGER A HOOVER 4. The Court in which the case has been or will be heard: CUMBERLAND COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: 01-1772 6. The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. (TITLE 18 U.S.C. SECTION 1001 ). I certify that the above information is true and that the address information is needed and will be used solely for service of legal, process in connection with actual o.r pros,~eetive litigation. FOR POST OFFICE USE ONLY No change of address order on file. NEW ADDRESS OR BOXHOLDER'S REGISTERED ADDRESS Not known at address given Moved, left no forwarding address. No such address POSTMARK: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSF/qBLUTH 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, INC. ROGER A HOOVER IN THE COURT OF COMMON PLEAS OF CUMBERLAED, PENNSYLVANIA Plaintiff VS. Defendant NO. 01-1772 PRAECIPE TO REINSTATE COMPLAINT 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. VALERIE ROSENBLUTH PARK, PARK LAW ASSOCIATES, P.C. ATTOR/~EY I.D. #72094 25 E. State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FIRST SELECT, VS. ROGER A HOOVER INC. Plaintiff Defendant NO. 01-1772 VERIFICATION OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS : Valerie Rosenbluth Park, Esquire, being duly sworn according to law deposes and says that she did serve the Defendant ROGER A HOOVER , at last known address located at 68 STAMY RD,NEW~;ILLE, PA 17241, by United States Certified Mail, Return Receipt Requested, Postage Paid, and First Class Mail with a true and correct copy of the Complaint which was filed in the Court of Common Pleas in the above captioned matter and with the appropriate Notice to Plead as set forth in Pennsylvania Rules of Civil Procedure. Service by mail was accomplished on 06/29/2001 in accordance with Pennsylvania Rule of Civil Procedure and the prior Order of this Court allowing for alternate service. Proof of service by Certified Mail is attached hereto, made"a part hereof, and marked Exhibit "A". Proof of service by First Class United States Mail, Postage Paid is a Certificate of Mailing attached hereto, made a part hereof, and marked Exhibit "B". Valerie Rosenbluth Park, Esquire further understands that false statements made herein are subject to the penalties of 18 PA C.S.4904 relating to unsworn falsification to authorities. ATTOP~NEY FOR PLAINTIFF =XHIBIT ~ For Accountable Mail ~ ~. ~ ~ , EXHIBIT VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOW-N, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEAS/kNTON, CA 94588 DEF: 68 STAMY RD NEWVILLE, PA 17241 4168100012337620 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS ROGER A HOOVER Defendant N0.01-1772 PRAECII~E FOR JDDGMENT 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 ATTOP~NEY FEES PLUS ACCRUED INTEREST LESS PRINCIPAL PAID LESS OTHER PAYMENTS $10,372.99 $1,763.00 $1,093.57 ($0.00) ($0.00) TOTAL $13,229.56 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,SA~. VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW, ~6~-~ ~ , ~O~/ , Judgment is entered in favor of the Pla£ntiff 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. 25 EAST STATE STREET, P.O. BOX 1779 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: 68 STAMY RD NEWVILLE, PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. VS ROGER A HOOVER Plaimiff Defendant NO. 01-1772 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: ROGER A HOOVER 68 STAMY RD NEWVILLE, PA 17241 DATE OF NOTICE: 7/20/01 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TH/S CASE. UNLESS YOU ACT WlTlrfl~ 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. ~ 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. EXHIBIT 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 AI~D CORRECT ADDRESS IS: PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASA. NTON, CA 94588 DEF: 68 STAMY RD NEW-gILLE, PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS ROGER A HOOVER Defendant NO. 01-1772 VERIFICATION OF NON-MILITARY SERVICE COMMON-WEJ~LTH OF PENNSYLVANIA: COUNTY OF BUCKS : V/LLERIE 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 ROGER A HOOVER, Defendant is over 21 years of age; that his/her place of residence/business is located at 68 STA24YRD NEWA~ILLE, PA 17241 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 LA~~ BY: Valerie Rosenbluth 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: 68 STAMY RD NEWVILLE, PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. Plaintiff VS ROGER A HOOVER Defendant NO. 01-1772 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 in [ ] Judgment on [ ] Judgment on [ ] Judgment on [ ] Judgment on [ ] Judgment on [ ] Judgment on [ ] Praecipe to Judgment by Default Money Judgment Judgment in Replevin Possession Award of Arbitration Verdict Court Findings District Justice Transcripts Judgment Note Writ of Revival Reassess Damages IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Park Law Associates, P.C. at this telephone number: (215) 348-5200. PURSUANT TO THE FAIR DEBT COLLECTION ~ACTICES 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, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 El State Street Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT, VS CUMBERLAND COUNTY COURT OF COMMON PLEAS INC Plaintiff ROGER A. HOOVER Defendant NO. 01-1772 PP. AECIPE TO MARK JUDGMENT SATISFIED, SETTLED, DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark the above captioned matter satisfied upon payment of your costs. PARK LAW ASSOCIATES, P.C. VALERIE ROSENBLUTH PARK, ESQUIRE