The URL can be used to link to this page

Home My WebLink About01-3325VALERIE 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 CO~ON PLEAS FIRST SELECT, INC. Plaintiff VS. ALICIA J DIMOFF L~-~ NO. NOTIC~ 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 W~ERE 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 INFOP~MATION 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#: 4168100012993620 CUMBERLAND COUNTY COURT OF C0~ON P?.~S FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS ALICIA J DIMOFF 36 TRINE AVE HOL .Y SPRINGS. PA 17065- 14 CIVIL ~CTION 1. The Pla±ntiff, F±rst Select, ~Inc. is a Delaware corporatfon o~an±zed and existing ~mder the laws of the State of Delaware with ±ts princ±pal place of business at 4460 Rosewood Dr±ye, Pleasanton, CA 94588. Plaintiff ±s the owner of this account, which is the subject matter of this act±on. 2. The Defendant, ALICIA J DIMOFF , ±s a~ individual who resfdes at 36 TRINE AVE MOUNT HOLLY SPRINGS, PA 17065-1143, 3. The Defendant is indebted to Plaint±fl on the credit accost by virtue of charges or cash advances i~curred by the Defendant or authorfzed by the Defendant on a cred±t card or l±ne of cred±t, bearing acco~mt number 4168100012993620. THIS IS /tN ATTB~PT TO COLLECT A DEBT. ANY INFOItMATION OBTAII~ism 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 $6,706.26 as of 01/05/2001, 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 $1,140.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, FI~T SELECT, INC. and against the Defendant in the amount of $6,706.26, plus pre-judgment interest at the contractual rate of 18.00% per annum from 01/05/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,140.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COURT II 8. Plaintiff hereby incorporates paragraphs i 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 TEIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFOP. MATION 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 $6,706.26, plus pre-judgment interest at the contractual rate of 18.00% per annum from 01/05/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,140.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAWASSOCIATES, 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 ATTEMlmT TO COLLECT A DEBT. ANY INFOHMATION OBTAI~m WILL BE USED FOR THAT PUP. POSE. VERIFICATION I, ~iLO~ C~ARLE~ , 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, in the State of California. Date Designated Agent o.o,,so, SELBCT P.O. BOX9104 ..... ~' ~ -~- ~ 0 N 986-964-~0 ACCOUNT AGREEMENT a~nt m~ (~e "~1T~ ~. ~ y~r ~g~ T~ ~v~ ~or d~t ~ p~en~ ~m to bo a~ ~ed to d~t c~n~ of your d~cl~ in ~ur ~gin~l Te~ or ~ magnum late ch~ ~ by ~ law o~your ~ ot ~ldeuce, w~che~r ~ Io~. We will ~ ~ur ~ount a tee tot e~h ~me~ p~t ch~k (mm~d ch~k ch~). ~e ~unt ot~ r~ c~ck c~8e will ~ m disc[~ in your Ori~n~[ Te~, or ~e ~um rammed ch~k ~8e ~ed by ~ law ot~r ~ ot ~i&nce, w~c~v~ Noa-W~er of Ce~ ~[hm. We ~y del~y or ~i~ ~eme~ ot~y ~si~ ot~s A~ent ~out I~ our ~ ~ e~ it or my o~r provision I~r. ~i~ated ~ ~e ~licable l~w m your On.al Te~. ~ur O~al te~ ~d not c~t~m ~ ~pphcable ~aw ~visso~ men ~m A~ment ~ ~u~ · at ~vision ~d~ to c~o~ to applicable I~w, ~ ~e ~ o~ p~visiom in ~e A~e~t will ~1 ~ ~orceabl~. We ~y tr~[er m ~i~ our ~t Co~oralion, P.O. ~x 9104. Plem~to~ Cal~ 94~66. YOUR BILLING RIG.S - ~EP T~IS NOTIC~ FOR FUTU~ ~is no6:e con~i~ imposer i~o~ation about your ~ ~ out ~mibiIiti~ under ~e F~ Credit Bi~g .qoti~ Us ~ C~e of ~rro~ or Qu~tlon~ About Your B~ In ~ur le~. give us ~e tollowing: ~lieve ~ bill wm co~. ~ ~ ~i~ your I~er ~ c~ot ~ to col~ ~ mpon you ~ ~l~?ent m to my ~unt you. qu~,.including finale. oblig~ed to pay ~e p~ o~ bill ~ ~ not in qu~l~ · e ~nt ~u owe md ~ ~te ~t it is due. ~u ~li[ to p~y ~ ~unt we ~i~ ~u owe. ~e ~y r~ you m ~I~U~L H~e~r. ito~t e~lana~ion lryou have a ~blem wi~ the quality org~ md s~icm ~t you pu~d with )~ur DiSCOlOR ~dit c~d md ~u have ~ed in good tai~ to conect lh~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-03325 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS DIMOFF ALICIA J R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT DIMOFF ALICE J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , , NOT FOUi~-D , as to the within named DEFENDANT , DIMOFF ALICE J # NEW ADDRESS 1631 SUGAR BUS}{ LANE CHAMBERSBURG PA Sheriff's Costs: So answe .... ~-~° Docketing 18.00 ~ ~~ Service 3.72 Not Found 5.00 Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 36.72 PARK LAW ASSOCIATES 06/07/2001 Sworn and subscribed to before me this ~ ~ ~ day of ~ 2 ~ A.D. pz~t~nonotary · , , HEREBY CERTIFy THAT TI'IE W/THIN 18 ATRUE AND CORRECT COPy OF TRUE COPY FROM RECORD VALERIE ROSENBLUTH PARK, ESQUIRE kITeetkn(mywh - of, l i' euntosetmyhaml Attorney I.D. %72094 ~~a~~,~ PA~K LAW ASSOCIATES, P.C. ~ ~~ 25 East State Street P.O. Box 1779 Doylestown, PA 18901 (215). 348-5200 ATTORNEY FOR PLAINTIFF CUMBEPJ~AND COUNTY CObT{T OF CO~ON pT.~.~S FIRST SELECT, INC. Plaintiff VS. ALICIA J DIMOFF D. fen t .o. NOTICE You ~ve ~en sued in Court. If you wish to defend against the claims set forth in the following pages, ~u ~st t~e action within twenty (20) days after this Complaint ~d Notfce are se~ed, ~ entering a ~itten appear~ce perso~lly or ~ atto~ey ~d f~ling"'in ~iti~ with the ~t your defenses or objections to the claims set forth against ~u. You are wa~ed t~t if ~u fail to do so, the case ~y p~ceed without you ~d a jud~ent ~y be entered agai~t ~u by the Court without fu~her ~tice for any money claimed in the C~plaint or for other claims or relief re~ested ~ the Plaintiff. You ~y lose money or property or other rights importer to ~u. YOU SHO~ T~ ~IS P~ ~ YO~ ~R AT ONCE. IF YOU ~ ~T ~ A ~E~ OR ~OT ~FO~ 0~, ~ ~, O~ T~.~PHO~ ~ OFFI~ SET ~R~ BE~ ~ FI~ O~ ~ YOU ~ GET LE~ ~LP. ~~ ~ ~ ~SOCIATION 2 LIB~ A~ ~ISLE, PA 1701~ (717} 249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEET. ANY INPOP~ATION OBTAINED W~LL BE I~SED FOR THAT P~POSE. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street ." Doylestown, PA 18901 (215 348-5200) ATTORNEY FOR PLAINTIFF CUMBERLAND COURT OF CO~ON PLEAS FIRST SELECT, INC. Plaintiff VS. ALICIA J DIMOFF Defendant NO. 01-3325 PRAECIPE TO WITHDRAW WITHOUT P~umIC' TO THE PROTHONOTARy: Kindly Withdraw the above captioned matter without prejudice upon payment of your costs. PARK LAW ASSOCIATES P.C. BY: VALERIE ROSENBLUTH PARK, ESQ.