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HomeMy WebLinkAbout01-2296VALERIE ROSENBLUTH PARK ATTORigEY 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 ($0.00) ($0.00) 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 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 Exhib~z--~A''. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney for the Plaintiff 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. AI'TOI~NrEy I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESToWN, PA 18901 (215) 348-5200 I HEREBy CER, T/Fy ,THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE ATTORNEy FOR PLAINTIFF SHIPPENSBURG, PA 17257-0000 CUMBERLAND COUNTy COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK VS KAREN S STANTON Plaintiff Defendant NO. 01-2296 NOTICE OF PRAEcIPE FOR ENTR~Y OF DEFAIII,T VALERIE ROSENBLUTH PARK ATTOR/~EY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I ~EREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 CUMBERLAND COUI~TY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KAREN S STANTON Defendant NO. 01-2296 VERIFICATION OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVA/~IA: COLrNTY 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 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~rs and Sailors Civil Relief Act of Congress of 1940 and it,~mendments. PARK LA~W ASS~ P.C. BY: ~' Valerie Rosenbluth Park Attorney for Plaintiff EiO 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 AIqD CORRECT ADDRESS IS: PLAINTIFF: 295 MAIN STREET TILTON, NH 03276 DEF: 235 MOBILE ESTATE SHIPPENSBURG, PA 17257-0000 CUMBERLAND COUI~T.Y COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS VALERIE ROSENBLUTH PAi~K 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 COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KAREN S STANTON Defendant NO. 01-2296 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~q~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. SHERIFF'S RETURN CASE NO: 2001-02296 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS STANTON KAREN S - REGULAR DEP SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STANTON KAREN S DEFENDANT , at 1855:00 HOURS, at 235 S.M.E. SHIPPENSBURG, PA 17257 KAREN STANTON a true and attested copy of COMPLAINT & NOTICE 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 3D~- day of ~ ~7~! A.D. ~notary " So Answers: R. Thomas Kline 05/25/2001 PARK LAW ASSOCIATES - Deputy Sheriff