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