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Home My WebLink About01-2295VALERIE 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: 295 MAIN STREET TILTON, N/q 03276 DEF: 221 MEADOWS RD NEWVILLE, PA 17241-9769 5418255001065304 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NkTIONAL BANK Plaintiff VS DEBORAH TUBBS Defendant NO.01-2295 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 $4,175.56 $709.00 $339.26 ($0.00) ($0.00) TOTAL $5,223.82 PLUS ADDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT A~ND 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 No. 237.1 is attached hereto and marked Exhibl~ "Aj~/ ! AND NOW, ,JLLc3~ // , ~(~O/ , Judgment is entered in favor of the Plaintiff and against'the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. PROTHONOTARY ~_ PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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: PLAIN flFF: 295 MAiN STREET TILTON, NH 03276 DEF: 221 MEADOWS RD NEWVILLE, PA 17241-9769 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS DEBORAH TUBBS Defendant NO. 01-2295 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: DEBORAH TUBBS 221 MEADOWS RD NEWVILLE, PA 17241-9769 DATE OF NOTICE: 5/22/01 IMPORTANTNOTICE YOU ARE 1N 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 BY: VALERIE ROSENBLUTH PARK, ESQ. CC.' THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT VALERIE ROSENBLUTH PARK ATTOP~NEY 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: 295 MAIN STREET TILTON, NH 03276 DEF: 221 MEADOWS RD NEWVILLE, PA 17241-9769 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS DEBORAH TUBBS Defendant NO. 01-2295 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 DEBORAH TUBBS, Defendant is over 21 years of age; that his/her place of residence/business is located at 221 ME/%DOWS RD NEWVILLE, PA 17241-9769 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 LAW ASSOCIAT~ES, P C. /~ Valerie Attorney for Plaintiff VA_LERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 221 MEADOWS RD NEWVILLE, PA 17241-9769 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BA/qK Plaintiff VS DEBORAH TUBBS Defendant NO. 01-2295 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. 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. Ai~Y 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: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 4428472756229180 CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KAREN S STANTON Defendant NO.01-2296 PRAECIP~ 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 $13,284.23 $2,258.00 $1,173.44 (~0.oo) (~o.oo) TOTAL $16,715.67 PLUS ADDITIONAL COSTS I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT A_ND 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 Exhib~.~"l~,,. VALERIE ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff // AND NOW, ~J~/,~ , ~ ~ I , Judgment is entered in favor of the Pla~intiff and against the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. 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 TH3%T THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 CU~ERLAIqD COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KAREN S STANTON Defendant NO. 01-2296 VERIFICATION OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS : VALERIE ROSENBLUTH PARK, Esq//ire, 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 KAREN S STANTON, Defendant is over 21 years of age; that his/her place of residence/business is located at 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 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 Soldi~s and Sailors Civil Relief Act of Congress of 1940 and it~mendments. PARK LAj ASS~ P.C. 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: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 CUMBERLAND COUA1TY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KAREN S STANTON Defendant NO. 01-2296 NOTICE SHERIFF'S RETURN - CASE NO: 2001-02295 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS TUBBS DEBORAH REGULAR RICHA/{D E. SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE TUBBS DEBORA~ DEFENDANT , at 1939:00 HOURS, at 221 MEADOWS ROAD NEWVILLE, PA 17241 DEBORAH TUBBS a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 1st day of May by handing to the , 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 ? Service 6 82 ~"~'~ ' . Affidavit .00 ~ ' Surcharge 10.00 R. Thomas Kline .00 34.82 05/02/2001 PARKBy:LAW ASS~ // D~puty Sheriff Sworn and Subscribed to before me this ~3~ day of ~1 A.D. rothonot ary SHERIFF' S RETURN - REGULAR CASE NO: 2001-02296 P COMMONWEALTH OF PENNSYLVAIqIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS STANTON KAREN S DEP SHANNON SUNDAY , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE STANTON KAREN S DEFENDANT , at 235 S.M.E. SHIPPENSBURG, PA 17257 KAREN STANTON a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon at 1855:00 HOURS, on the 24th day of May by handing to the , 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.40 Affidavit .00 Surcharge 10.00 .00 40.40 Sworn and Subscribed to before me this 3~ ~ day of So Answers: R. Thomas Kline 05/25/2001 PARK LAW ASSOCIATES Deputy S~eriff~