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Home My WebLink About01-3328 VALERIE 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 ATTOR/gEy FOR PLAINTIFF CUMBERLAND COUNTY COURT OF CO~9~ON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS. KIPP E ZAHLER 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 INFOHNATION OBTAIh~,, WiLL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK ATTOR/gEY I.D. # 72094 PAR/{ LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT#: 4428671059924708 CUMBEI~aA~D COUNTY COURT OF COMMON PLEA~ PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 PLAINTIFF VS KIPP E ZAHLER 583 ~RAHAMS WOODS RD CARLISLE, PA 17013-8942 DEFENDANT NO. 1. The Plaintiff, PROVIDIAN NATIONAL BANK, is a national banking association organized and existing under and by virtue of the laws of the United States of America. Plaintiff solicits and maintains consumer credit accounts in Pennsylvania and is the owner of this account, which is the subject matter of this action. 2. The DefeDSnnt, KIPP E ZAHLER, has a mailing address at 583 GRAHAMS WOODS RD, CARLISLE, PA 17013-8942, 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 owned by the Plaintiff bearing account number 4428671059924708. THIS IS AN ATTemPT TO COLLECT A DEBT. ANY INFORNATION OBTAIns,, WILL BE USED FOR THAT PURPOSE. 4. The Defendant requested an account, account number 4428671059924708, which is owned by the Plaintiff, and an Account Agreement was sent to the Defendant. A copy of the Agreement is attached hereto as Exhibit ~A" and made a part hereof. 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 $9,609.07 as of 03/06/2001, plus pre-judgment contractual interest at the rate of 23.30% 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 $1,633.00. WHEREFORE, Plaintiff demands that judgment be rendered in favor of the Plaintiff, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $9,609.07, plus pre-judgment interest at the contractual rate of 23.30% per annum from 03/06/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,633.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. COUNT I- ALTEI~IATIVR 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 THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORNATION OBTAINED WILL BE USED FOR THAT PURPOSE. and/or knowingly and voluntarily accepted the benefits bestowed. 12. It would be inequitable for this Court to allow the Defendant to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defen~_nt 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, PROVIDIAN NATIONAL BANK, and against the Defendant in the amount of $9,609.07, plus pre-judgment interest at the contractual rate of 23.30% per annum from 03/06/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $1,633.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY:vJ~~iRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: TRIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE OEDER FOR BERVIC~ TRIS IS AN ATTKHPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PUP. POSE. VERIFICATION I, HEATHFR ~00~ , declare that: I am a Designated Agent of PROVIDIAN NATIONAL BANK, 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 lifornia. Date DesignatedAgent PROVIDIAN EXHIBIT Provi~a__n_Na.ii .onal Bank VIaA~ or MasterCard~ a,~oum agreement for Kino E Zahler Janumy 26, 200 f it is nonomd an to trash ~:n~;~,orr~nw. ~,w,,. .tuma~e ~usin yourVlSA ardcerd the" rd' a . t=a 'Ac=Jn 'wo,"our," '''''''""'' an ~unaummacsepmnceot met~msoTthisAgrsemenL You and ~-~e~,s"t,(~l~t: .... ,x,,,.,=,.=a.u~ uc~.m~==, puqosee. /u'~Y use ot this ,qccount shall Ila. t~. ntduewill~, paymants on your Account or to make .. entsonanyo~-~:~i' ~.~ n~)psecaecl(s ur -,,,,,. u,~, ar~. yeurcme ne.. me ILa,/in.~L~., ~ we wi~, noii.ly ~ ~ doing se. If your cevm~'is ~ ~tl~ ~n¥~'~rita~'ebem~' ane' .wq may mq~.m a gner .m..ini.m..u.m {btam ent~ ~ue. 'labor . Flnan~ Chames. Except as dascfibed in the Grace I~fod for Purchase Balance cedi of this ant. fi · ' . u~ yuu o~lao [cpase t:lalance a new rcnasea make wi r :'° '-"'~: ==m*,.,~. we msewe me ngrl! to apply payments Elffef~dy without further nolice. -' '=''u' u,m ==~m~u m =alu, an= men ~o any remaining ~mPurchace, .Cus ~ash , and ah Adva Bal rices are by as of b~ te ' and c ue/a r cemwe monroe nee 'allomer,, ~- fo'"'T ~j~l'"=~'ll""~?~'~a ~r t~ ual se reachdavwithl e.biiil e. celculali Your ?th~ ~ incl · an . 'ly balance ~ each of ante. Y Ii ~il beJanse is no zam ~ncmase or oe,~mase in me amour~t-6f'y~-r-r~in~mum i~T'm~[''''-~' ""' ~" "','~ ~ me "~ aaY m Yo~' ~mng cycm an,~ may result in a m~gnt The AN~IJAL PERCEKrA~E EATE (APE) for purchases ia 7.9%, cofrsepunding to a daily parloci¢ into of 0.02164%. ~l.~~nc~n~ nN:l~aE~t~mCaot~ c~S~rd~, tm[i ,.~ itt~a~l~.n~ava'~g~:o~ ._l~e,r o~ ~ntmd~~ APR you ~ been The ANNUAL PEECENTAGE EATE for cash advances is 21.99%, com~oo,~ing to a daily pe~x:ic rate of 0.060'25%. If w~. receive Account payme..nt late 2 or more limes nar~. 'od, on sech such nance we ' ma.~.mum n toa i '(xicmto ' m~y. ncmase the APR for mhaaasuptoa meet ,~ol~?.tmms .. _m~nln~.eg~n~f~r.d~Cl~ mon~'~m~· ~f a~ u r e cave ~e h, ~ rotes r ..am ~ lime., nd a ,,,range charge, ano t~ere m no punno m whic~ s~Fl'~Fc(.~'~ m a y'~-r e~ ~'I ~ '~ o~ ;1 ~: ~'~ 't~ r ~r ~e I~a~g~.ses pusmo m any omer I:Xlling cyme incur Le~[d;We~h cha~ t r Account $0 f~. hard ask ace retu nt; each ~.e(.(.(.(.(.(.(.(.~k u to on your nt we mtom (Continued on tm. else) (5846.0698) 4428671059924708 1531 561r~o28 eno ,[ ~n,,~.~ = ~,~,,o--,, ~.- .~o~ ,_,.~_._ o~, ..~.,_,. __~__~..________applY reghrdess of whelt~- funds am available i~' ~d'r~r;o~ ch~g~t~l~m~p~t.~lues;' /n,s ~ee ,s a P, rIANCI~ CHARGE, Default Y will be in default: ~f i--~ - - -----. ----, --..- u-,,-,,u -,,p,,, o,,~o,.,,,,u u,u,~uum.l~on provided us be 'nco I~ete ~ unbue ~ yoq not 'Ih of r ~alh, ban , or l ~ani~ not other ts . . CCXTlpl y,1 ~ pa this.Nl~ment; ~uu, ,i .~.~nceOec~are unt~c°U~llnt Da~anlinnC~iuem~o~inC~eres~,d a use a ~ It~n~,t to collect e a~°~ you owe. t at ~/e~sln~scl~d~n f~nce f~arges 8eca~ of he~s ,~reement, even if. Cavar~l'laEbleLl=l~liYt.°UrweC~.~.ir~fi~,etj,~xJr~f~:lir~li~eabaS~rat~e~no~.,~m~.r_m~_,.n,~_y_s~_tef~e_ . n ts show your ~ .n~i_ _t _1[~ a..~l lite a ..mq.r. lnt of your nomlall thedff b~ ~urcre~tl' · ~"~ r untbala""'"-~'"q!'m-u~'w~m~nuunumyouory~, rcre~[_.?~8_._. Youravaua~lecre~tis !,~rge ~t ~, .w~~ mt~. imit .ygur ~q~b~ c~t~w;l~;'~ we ~e~li~/~ ~1%~l~en~kb--a~ ~J~lS~rr~-~-a~ut~-'-','-°~-- ~ not yet go~..ted). I.f..vou ~ld usa 8[[omey'S Tees and CoiJrt(~,i~ts [Ifwuwinlh~R.Jt =--.''.'~lf'-u-~'~.-~..!~--u~- .--n~- ,u?h~u u¥flF~uon COSZS We incur Ir~01UCllng DU[ not mted to rMson~e -- · ,.-, ............. wu w.. p~]~ y~u, wescx~:xe a[[omey'$ lees a~d court costs.) · ' Chang~ A.~er we I~wide you ..ally ~b.'~. required by law, we Elay charge my ~rt of h~is ..~ merit and a~ re . immen~... If a is Ln?~ ~ .m. ree pelc~.t (3.%[. If a ch~..t is.s .~. ~.tJy glen for a ~f~on, it use(] on [ne (~nve~oh oa[e dffer from the late in , ~,, - ,,= ~,,,= ~,,,,,~! . .w sun~cy convemlon ~am. may effect on the date you used your Card. ~(~u agree to ac~o~'~e (;owerted amount in U.S. ~-e--Ca~r~l-; "Cancell~°'n' Y°u m~Y cancel y°ur--cr~- tp-rivil-ege~ at any. lin~ b~ m~ ~ in ~n;~d ~m ~e ~ s ~e ' ' uw.m(~;memoq, msnownon~,we d not renew[ne Wen - .( ' ~ ~ ra at no~ce to ~ or ,thout no~k~'~' ~D~;~e~n~t,~,~,! ~.r~ ,. v..~_~l~ _[~ _n~_ _~n~L~ Ca~ and y~u('.c~t p~l~;~ at .aCly lime ~ ~c~ ~ will conlinue due, and all o'- - '; -'"~-it~r'""'.j']~l~le' ~-o~i'~ "~n''= ''y~'J~ '~- n~ -~m'~-'- 'np s of th reement mil ma'nan~' Cl ~flntn~f~am o.~. ~ ~all cmbnue.to be assMM:l",ten~l r t ' iliaTe8 _.-.~. ...~-..~ and i ,.~. ~ [ to alSO re i ' ' · rt .o~ver, ~u. w~..tetou$ t time b~cti us ~e"'~ it o 'mM our ' .qnwtol r ~'~greement, a ~ aJ~t~vem~'t report ~an~ ~ on ~L~r mt may ~ecr~tm~tte~ '~~a~u~fT~ not ,u~ yourm°~b.s un~r Cuslome~ ~eMce; ' ~ere~ be anee~l t~/~u, r .PiN mmte fror~ yo~'~ It you a~r~r~ect~~ ~?~?,,.a~,,.In~,~--a~- - any r.p~. KS i.' .8~ed to you. .and I~!J[ty.~ y~u will l ~om us even h · .. . ~o~ ~1~! ~ ,.~ ~ u mo useo~ r ~,we ur ' -- - ' and se~u~i[Y, you agd · that your oalls m~ly be monitored or ~-' ,...-.,,~.~ ,.--~ ,.z -, ,.,,=.,~, ,- ~.~ ~.. ~o ~mprove customer se~aoe _u~__~_._rl~_...o~__~are.c(xl~B~amc117y u~. an~. Decau~. not e~fy c . re.us, ban .8~,i. 'o~ jn . wil u~ ~.T, qu ertl Eo nooly US imme~stely o/8ny U~l'LdJlOfized t/ansacUo118 or elTl~8. require us to ~ against ar~Qne~(~f~'~ve-'~l'6~it ~'~'you. ,.~ ,,, ,.o,,,u~, any Ul~r.a~e statute OT ,m~Tam3ris; ar~ any fight you may eg reg atay acuon, or jua,cJal decision has rendE~:l or may render any ~e~,~'p~a~s ~ ~,s ;~ i~al~r u~, or i~ PROVIDIAN $.m..(ela~ .u, lres~a! u ive no§ca of such an event to tact ~' '"'~"~'"' !"axua'=*=uf-.~lgn°urrlgn[~all°r...sPrna°lyourpay~enla. lf w~th tha s~n~l~ s Secm~ ~te. pm the purchasor or assignee, we may g~ve you sucl~ notice by §l~ng a financing stotement Notfoes..O___th~. _n~cO n.~icas to shall be effoc~ve .wf)e delT~.'tod in the mail addressed to at the ddress I~la ~t~.~u in this reemant or law, afnir~ od shall la " ~ url our unlass a r .notJca ~ staterhant (or other ~ we ~ spa~fy)a~sl~ll be ~e~l~wl~i~s~' N'~°t~u~. to us ~al, be ma,led to our ~dSto~ cus[~nerl°~r~ on ~tBIoi~lll~ ~t.lrrS - KEB~ THIS IiOTICE r-oR FUTURE USE. This no,ca contains impo~nt informatio~ about your rights and our respor,.sibilitJes under tha Fair · inC, aseof£ or Abaft Yo~.Ollll..ff...y~..~.n.k rbilliswmn or'f ~eedmoreinfoo~alfonabout ' ua a se ~[~etu~aaa~d 4m~ .te~l n ,e B~II/h ' . ~anaac~on on r · . ~. bill on which the error orI~,n a red Y · . you n__gh~m, in. youuetter, g~ve.us the ~ol o~nng~nformalion: - Your name and ~,.~p~b,~ ,.. a_a_a_a_a_a_a_a_a_~. -~,._ ~,,~n ~el .el:X~..e. us, ~t dping so mil n__ot presage your ,.anu explain, ,i. you can why you uelieve Olere ia an error. If you need momm~n "~~'~r, d~ril~ethU~X~arma,~m~, ?.,?~e...~_ .Sl~'t~_.,error. - Des~ibe the error v,~ uo ~.~ / C~I[ ~ Dill a~ornaacall r chackin · - .~ ,o~ a~sy Ol~l~Ullt yOU ~$~on, or ~or[ as i L ....................... cha . , we can an u i~r~ nt you . Wa can continue to bill ~ for I~ amount u qnastJpn, ir.~'.U~.'n finance am r~ ~ar~ed to ~y~ ~:~ ~Y~ n~r bil~a tagaar~ ~not ~;~u~ ~q~ere~sfi tco?n ~.nq~°o u! do not have to pay ~y questioned amount wh~e we are ,nvestigafl~g, but you If we find fhat we made a miatoke on your bill, u will not have to anyfina cha erela toa eslt ~ may have to pay finance cha e~, and ~11 have to ke mi rg qu oned a unt, If we ~do't ma · a mistake, 'lalam'~'"ofthe-maunt' u- r~the ........... .mp ~ Ina.,s~.,ae~p~/~-.e~lonaa~.~.~ldne:lamoun[.m~nUethercasewe~,~send u OUr ' ~. Oa~ .[[k1[ I[ 15 QUa. Ii' I Tall [0 ~ mourn mi K . YO .a. · analJ . not ,.,,tis and wnto to . · YO~ owe, we may rt you as dol~nquenL H if , ,, ,.,~,,~,~ a ,~., o~ e~ u~ u~ ~uesuoneu arnouni', eve~ ii' your bill ~as COTT~Ict. mai ,rig .a(lcl[ess; iand.lbJ'thej~ir~..hase race must he/ye ~'~o'~t~'$~'.~U~l~e~-,~,!i.-m)-[..,-~-m-~.n--Y~-[. ~?~._ s_.~..m,_ ~n_!O0~ niJles ~ yofir cu.rrent mallea YOU Itle adve~someni./or Ele properly or sent/cea. . ~ ,,,,,,mu~ m uu nut app,/n w~ u~m~ ~f operam ~e mercllarli., or if we T5028 SHERIFF'S RETURN - REGULAR CASE NO: 2001-03328 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS Z~T.RR KIPP E RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ZANT.~R. KIPP E the DEFENDANT , at 1838:00 HOURS, on the 8th day of June , 2001 at 583 GRAHAMS WOODS RD CARLISLE, PA 17013 by handing to KIPP ZAHLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Service 4.96 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.96 06/12/2001 PARK LAW AS~~,~ Sworn and Subscribed to before By: me this 2~ ~ day of / Deputy Sheriff ~ ~ ! A.D. P~othonotary COUNTY OF CUMBERLAND COURT OF COMMON PLEAS NO. 01-3328 Praecipe for Writ of Execution PROVlDIAN NATIOND~L BANK Plaintiff vs. KIPP E ZAHLER 583 Grahams Woods ~ad Defendant Carlisle, PA 17013-8942 and bXEMBERS 1ST FEDERAL CREDIT UNION 4 ~rket Way Garnishee ~chanicsbur$, PA 17055 TO THE PROTHONOTARY: Issue writ of execution in the above ~tter, directed to the Sheriff of CUMBERLAND County; (1) against MEMBERS 1ST FEDERAL CREDIT UNION garnishee(s) (2) AMOUNT DUE $ $12,009.56 INTEREST AT 6% PER ANNUM from 07/16/2001 $ q~'-q~ PLUS PRIOR COURT COSTS $ PLUS COSTS OF EXECUTION $ (TO BE COMPUTED BY PROTHONOTARY AND SHERIFF) Attorney(s) for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-3328 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PROVIDIAN NATIONAL BANK, Plaintiff(s) From KIPP E. ZAHLER, 583 GRAHAMS WOODS ROAD, CARLISLE, PA 17013-8942 (I) You are directed to levy upon the proper~y of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS IST FEDERAL CREDIT UNION, 4 MARKET WAY, MECHANICSBURG, PA 17055, GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from payin8 any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject m auachment is found in the possessinn of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Dne $12,009.S6 L.L. $.50 Interest AT 6% PER ANNUM FROM 7/16/01 - $459.45 Atty's Corem % Due Prothy $1.00 AU'y Paid $105.46 Other Costs Plaintiff Paid Date: APRIL 8, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: ~~~ Name VALERIE ROSENBLUTH PARK, ESQUIRE Address: 25 EAST STATE STREET P.O.BOX 1779 DOYLESTOWN, PA 18901 Attorney for: PLAINTIFF Telephone: 215-348-5200 Supreme Court ID No. 72094 SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-03328 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PROVIDIAN NATIONAL BANK VS ZAHLER KIPP E And now BRYAN WARD ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:48 Hours, on the 12th day of April , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDA/qT , ZARLER KIPP E , in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FED CREDIT UNION 4 MARKET ST MEC}tANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to TODD SHIMKO (SUPPORT SVCS) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His Sheriff's Costs: S.~~//~ Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 .00 00/00/0000 Sworn and subscribed to before meBy /~'~-~.~ ,.~ ~-~ ~ this /7 ~ day of ~ Deput~ Sheriff _~ A.D. ProSh~notary' ' ' . VALERIE ROSENBLUTH PARK I HEREBY CERTIFY T~ATTHE ATTORNEY I.D. # 72094 TRUE AND CORRECT ADDRESS IS: PARK LAW ASSOCIATES, P.C. PLAINTIFF: 295 MAIN STREET 25 EAST STATE STREET TILTON, NH 03276 DOYLESTOWN, PA 18901 DEF: 583 GRAHAMS WOODS RD (215) 348-5200 CARLISLE, PA 17013-8942 ATTORNEY FOR PLAINTIFF 4428671059924708 CUMBEPJ~AND COUNTY COURT OF COMMON PLEAS PROVIDIANNATIONAL BANK Plaintiff VS KIPP E ZAHLER Defendant NO.01-3328 P~a. ECIP~ 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 $9,609.07 ATTORNEY FEES $1,633.00 PLUS ACCRUED INTEREST $767.49 LESS PRINCIPAL PAID ($0.00} LESS OTHER PAYMENTS ($0.00) TOTAL $12,009.56 PLUS ADDITIONAL COSTS I CERTIFY TEAT THE FOREGOING A~SESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUN 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~~' VALERI~'ROSENBLUTH PARK,ESQUIRE Attorney for the Plaintiff AND NOW,~_~__, ~ , Judgment is entered in favor of th~ Plaintiff and the Defendant by Default for want of an Answer and damages assessed in the sum set forth in the above certification. PROTHONOTARY PURSUANT TO TEE 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 I HEREBY CER l'ff¥ THAT THE ATTORNEY I.D. # 72094 TRUE AND CORRECT ADDRESS IS: PARK LAW ASSOCIATES, P.C. PLAINTIFF: 295 MAIN STREET 25 EAST STATE STREET, P.O. BOX 1779 TILTON, NH 03276 DOYLESTOWN, PA 18~01 DEF: 583 GRAHAMS WOODS RD (215) 348-5200 CARLISLE, PA 17013-8942 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAI-ILER Defendant NO. 01-3328 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: KIPP E ZAI-ILER 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 DATE OF NOTICE: 6/29/01 IMI:ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TI-liS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE EN'I';e2F. D 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. I~ YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C-O TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4tb FLOOR CARLISLE, PA 17013 (717) 240-6200 PARK LAW ASSOCIATES, P.C. 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 I HEREBY CERTIFY THAT THE ATTORNEY I.D. # 72094 TRUE AND CORRECT ADDRESS IS: PARK LAW ASSOCIATES, P.C. PLAINTIFF: 295 MAIN STREET 25 EAST STATE STREET TILTON, NH 03276 DOYLESTOWN, PA 18901 DEF: 583 GRAHAMS WOODS RD (215) 348-5200 CARLISLE, PA 17013-8942 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 01-3328 KIPP E ZAHLER Defendant V~RIFICATION OF NON-MILITARY SERVIC~ CO~4ONWEALTH 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 KIPP E ZAHLER, Defendant is over 21 years of age; that his/her place of residence/business is located at 583 GRAHAMS WOODS RD CARLISLE, PA 17013-8942 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 ASSOC , P.C. BY: // ~ ~-" Val erie/~K~osenblut h Park Attorney for Plaintiff · VALERIE ROSENBLUTH PARK I HEREBY CERTIFY THAT THE ATTORNEY I.D. # 72094 TRUE AND CORRECT ADDRESS IS: PARK LAW ASSOCIATES, P.C. PLAINTIFF: 295 MAIN STREET 25 EAST STATE STREET TILTON, NH 03276 DOYLESTOWN, PA 18901 DEF: 583 GRAHAMS WOODS RD (215) 348-5200 CARLISLE, PA 17013-8942 ATTORNEY FOR PLAINTIFF CUMBERLAND CODNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS NO. 01-3328 KIPP E ZAHLER Defendant 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 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 ~RACTICES 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 ROSENBLD~fH 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 COUNTY COURT OF COMMON PLEAS PROVIDIAN NATIONAL BANK Plaintiff VS KIPP E ZAHLER Defendant NO. 01-3328 PRAECIPE TO DISSOLVE ATTACI~M~NT AGAINST TO THE PROTHONOTARY: Kindly dissolve the attachment entered against , ~arnishee only in the above captioned matter. Respectfully submitted, PARK LAW ASSOCIATES, P.C. BY.. VALERIE ROSENBLUTH PARK, ESQ. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriflt's Costs: Advance Costs: 150.00 Sheriff's Costs: 78.31 Docketing 18.00 71.69 Poundage 1.53 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 3/2 !/03 Mileage 8.28 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 78.31 Sworn and Subscribed to before me So Answers; this /~..l- day oft~9 R. Tboma~ Kline, Sheriff prothohotary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-3325 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PROVIDIAN NATIONAL BANK, Plaintiff(s) · From KIPP E. ZAHLER, 58~ GRAHAMS WOODS ROAD, CARLISLE, PA 17013-8942 (l)You are directed to levy upon the property of the defendaot (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS IST FEDERAL CREDIT UNION, 4 MARKET WAY, MBCHANICSBURG, PA GARNISHEE(S) as follows: and to notify the gamisbee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any properly oftbe defendant (s) or otherwise disposing thereof; (3) If property of the defandant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/sbe has been added as a garnishee and is enjoined as above stated. AmoantDue $12,009.56 L.L. $.-~0 Interest AT 6% PER ANNUM FROM 7/16/01 - $459.45 Aiiy's Corem % Due Prothy $1.00 Atiy Paid $105.46 Other Costs Plaintiff Paid Date: APRIL 8, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name VALERIE ROSENBLUTH PARK, ESQUIRE Address: 25 EAST STATE STREET P.O.BOX 1779 DOYLESTOWN, PA 18901 Atiorney for: PLAIN'I'Ip'I~ Telephone: 21 ~348--~200 Supreme Court ID No. 72094