Loading...
HomeMy WebLinkAbout04-4400IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff No. ~(- ~yL~ ~lUt,~~-~''~ vs. COMPLAINT IN CIVIL ACTION JOHN J DYSON Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. IVlolczan, Esquire PA LD. #47437 WELTMAN, WEINBERG & RE1S CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1.5219 (412)434-7955 WWR#03336773 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CACV OF COLORADO LLC Plaintiff vs. Civil Action No. ~~(~ C{C~Od l.;[o ~l. L ~~ JOHN J DYSON Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND 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 any other claim 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 COMPLAINT Plaintiffis a corporation with offices in Denver, CO 80202. 2. Defendant is residing at Carlisle, PA 1.7013. 3. Defendant applied for and received a credit cazd issued by Plaintiff bearing the account number 4225813080356915. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of August 6, 2004, in the amount of $3,898.91. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1"and made a part hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between. the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 24.99% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, John J. Dyson individually, in the amount of $3,898.91 with continuing finance charges thereon at the rate of 24.99% per annum from August 6, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, John J. Dyson individually, in the amount of $3,898.91 with continuing finance charges thereon at the rate of 24.99% per annum from August 6, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG &REIS, CO., L.P.A. Will . Molcza ,Esquire PA LD. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA ] 5219 (412)434-7955 W WR#:03336773 Page: Please indicate Name, or address Telephone changea Home ( ) Work ( ) DUE DATE 4225 8130 8035 6915 4280 8100 AF F X 1 7 02 ACCOUNT NUMBER CREDIT LINE 4225 8130 8035 6915 2000 DATE OF TRANS ~ POST REFERENCE NUMBER 0000 0000 300.00 I 948,25 I 2597.25 JOHN J DYSON 8 HILL DR CARLISLE PA 17013-9650 AI~UNT OF ENT ENCLOSED IN BILL I PAYMENT CYC DATE DUE DATE DESCRIPTION OF TRANSACTIONS 0805 I OVERLIIdIT FEE 0000 LATE CNARGE - MIN PYMT NOT RECD HY DATE FAILIIRE TO MAKE PAYMENT HA.4 DAMAGED YOUR CREDIT RATING. HOWEVER, WE WANT TO WORK WITH YOU TO REBUILD YOUR CREDIT. CALL TODAY TO GET STARTED. ENROLL IN CHASE PAYMENT HROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. *** FINANCE CHARGE CURRENT PURCNASE 1 I!1~J1~1 29.00 35.00 56.76 PREVIOIIS BALANCE PAYI~NT3 CREDITS NEW PORCAA3ES DEBIT AND ADVANCES ADJUSTMENTS FINANCE CHARGE OVERLINE AMODLiT NEW BALANCE 2476.49 ~ .00 .00 .00 64.00 56.76 597.25 2597.25 AN AMOUNT FOLLOWED SY A MIN[JS SIGN(-) IS A CREDIT OR A CREDIT BALANCE UNLESS OTHERWISE INDICATED x~;~ ~ ~ '`q ,, YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY TRIS AMOUNT HY TAE DUE DATE $ 2597.25 ~ND INQUIRIES TO PO HOX 15919 WILMINGTON DE 19350-5919 ZF YOU TELEPRONE YOUR INQUIRY, YOU DO NOT PRESERVE YOUR RIGRTS UNDER FEDERAL LAW. CU3TOtlER SERVICE TELEPHONE NUMBER'S: 500-334-3942, 500-545-0464 TO REPORT LOST/STOLEN CARDS, TOLL FREE 800-334-3942 ANYTIME FRC4! ALL 50 STA283, PUERTO RICO, AND TEE U.3. VIRGIN ISLAtID3. YOU AAE NOT REQUIRED TO PAY ANY SPECIFIC AMOUNT YOV HAVE PROPERLY REPORTED TO U3 A3 DISPUTED PENDING OUR ;OI~LIANCE WLTN APPLICABLE LAW. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is ~~-~ W EY'~~`~- (NAME) (~.x~~.-ors-~ ~~~ of ct~~ .~;C-' co~~Rnr>o, ~~~ ,plaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. --~, --~~ ~ (SIGNATURE} W W R# 03336773 (, ~4 ~- ~ ~ ~ a ) n ti ~ Q ~ -y- ( ~ v - W ,~ ~ , 1 ~ 1 ~ - ~' ,~ ~ n ~ r- -O rn 1,~: ~ o `~ci~ _ `-`r4 \'_ ~ i.. ~. C.1 cn ~~ SHERIFF'S RETURN - REGULAR CASE NO: 2004-04400 P COMMONWEALTH OF PENNSYLVA]vIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS DYSON JOHN J SGT. BARRY HORN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DYSON JOHN J DEFENDANT at 8 HILL DRIVE the at 1325:00 HOURS, on the 8th day of September, 2004 CARLISLE, PA 17013 JOHN DYSON by handing to 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: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this lL = day of .~(aq,~-Q... ~ o7.L~i7 `/ A . Dom'"t. rothonotary So Answers: .~~~ -~,~ R. Thomas Kline 09/08/2004 WELTMAN WEINBERG REI5 By: ~ u Zeriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff No. 04-4400 Civil Term vs. COMPLAINT IN CIVIL ACTION John J. Dyson Defendant ANSWER TO COMPLAINT: I. I assume this is true 2. Yes. 3. I have no knowledge of a credit card with this number belonging to me. 4. This "exhibit 1"credit card statement is unknown to me. 5. I have no knowledge of the terms of this. 6. Again, I have no knowledge of this, 7. This is the first document I received regazding this matter. Sincerely, ~r~.~ John J. Dyson ~~Z3ly ~, ^~ ~ ..: r TI "p lxi S/7 . .--`[' mfl':~ . ' fi fT1 -° T ^Tij ~ 1 r. u> x: N .r n n :; r z r L~ h , Sad ~ '1 ~ ~Ji`rE ~.~ -~ cn ..o N '< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff, vs. JOHN J. DYSON, Defendant. Case No.: 04 - 4400 CIVIL TERM TYPE OF PLEADING: MOTION FOR SUMMARY JUDGMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. # 93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (472) 434-7955 W WR # 03336773 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML DIVISION CACV OF COLORADO, LLC, Plaintiff, Case No.: 04 -4400 CIVIL TERM vs. JOHN J. DYSON, Defendant. PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Summary Judgment against the defendant. In support thereof, Plaintiff avers as follows: 1. On or about August 30, 2004, Plaintiff filed a Complaint against Defendant for payment of credit card debt. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 2. On or about September 23, 2004, Defendant filed an Answer to Plaintiff s Complaint claiming to have no knowledge of the debt. A true and correct copy ofthe Answer is attached hereto as Exhibit "B" and made a part hereof. 3. Defendant's Answer contained no New Matter. 4. Under Pennsylvania Rule of Civil Procedure 1032(a), "a party waives all defenses and objections which are not presented either by preliminary objection, answer or reply..." 5. On or about December 29, 2004, Plaintiff served upon Defendant a set of requests for admissions and requests for production of documents. A true and correct copy of same is attached hereto as Exhibit "C" and made a part hereof. 6. No response to the discovery demands has been received. 7. The requests for admissions are now deemed admitted under Pennsylvania Rule of Civil Procedure 4014(b). Thus Defendant has admitted: he has failed to make monthly payments since December 2001; he has never disputed any of the charges on his monthly statements; he is in default on the credit card account for failure to make timely payments, he signed the attached credit card application; and that the monthly statement attached to Plaintiff s Fixst Request for Admissions accurately reflect charges and the balance due on the account. 8. There are no meritorious defenses against this action and Plaintiff is entitled to judgment as a matter of law against defendant John J. Dyson. WHEREFORE, Plaintiff respectfully requests that this Court grant Summary Judgment in Plaintiffs favor and against Defendant John J. Dyson in the amount of $3,898.91 with continuing finance charges thereon at the rate of 24.99% per annum from August 6, 2004, plus costs. Respectfully Submitted Benjam R`Bibler, Esquire PA 1. . # 93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W WR # 03336773 ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION CACV OF COLORADO LLC Plaintiff vs. JOHNJDYSON - Defendant No. COMPLAINT IN CNIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THI5 PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA ].5219 (412)434-7955 WWR#03336773 EXHIBIT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. Civil Action No- JOHNJ DYSON Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND 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 maybe entered against you by the court without further notice for airy money claimed in the complaint or for any other claim 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. 1F 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 32 South Bedford Street Carlisle, PA 17013 (717)249-3166 COMPLAINT Plaintiff is a corporation with offices in Denver, CO 80202. 2. Defendant is residing at Carlisle, PA 1.7013. 3. Defendant applied for and received a credit cazd issued by Plaintiff bearing the account number 4225813080356915. 4. Defendant made use of said credit cazd and has currently a balance due and owing to Plaintiff, as of August 6, 2004, in the amount of $3,898.91. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a par[ hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 24.99% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed altd/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, John J. Dyson individually, in the amount of $3,898.91 with continuing finance charges thereon at the rate of 24.99% per amlum from August 6, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG &REIS, CO., L.P.A. William T. Molczal{!Esquire PA LD. #47437 // WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (4]2)434-7955 WWR#:03336773 ._. _ q~ Page: 1 Please indicate Name, or address Telephone changes Home ( ) Work ( ) ACCOUNT NUMBER PAYMENT DUE DATE PAST DUE MIMINUM Ab~UNT PAYMENT NEW BALANCE At~UNT OF PAYMENT ENCLOSED r I 4225 8130 5035 6915 08/30/2002 300.00 948.25 2597.25 $ 4280 8100 AF F X 1 7 02 JOHN J DYSON B HILL DR CARLISLE PA 17013-9650 ACCOUNT NUMBER CREDIT CREDIT DAYS IN HILL PAYMENT MINIMUM LINE AVAILABLE ILLING CYC DATE DUE DATE AYMENT DUE 4225 8130 8035 6915 2000 - 33 08/05/2002 08/30/2002 948.25 DATE OF 3 POST REFERENCE NOMBER DESCRIPTION OF TRANSACTIONS AMOUNT 0000 0805 OVERLIMIT FEE 29.00 0000 0000 LATB CHARGE - MIN PYMT NOT RECD HY DATE 35.00 FAILORE TO MAP.E PAYMENT AAS DAMAGED YOUR CREDIT RATING. HOWEVER, WS WANT TO WORK WITH YOII TO REBUILD YOUR CREDIT. CALL TODAY TO GET STARTED. ENROLL IN CHASB PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING. *~* FINANCE CHARGE CURRENT PIIRCHASB 1 56.76 PREVIOUS NEW PURCHASES DEBIT FINANCE OVERLINE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJUSTMENTS CHARGE AMOUNT BALANCE 2476.49 .00 .00 ,00 64.00 56.76 597.25 2547.25 AN AMOUNT FOLLOWED SY A MINUS SIGN(-) ZS A CREDIT OR A CREDIT BALANCE IINLESS OTHERWISE INDICATED ~X~~ ~ 1 ~ ~~~ k YOU MAY AVOID ADDITIONAL PINANCB GARAGES ON PVRCHASES IF YOU PAY THIS AMOVNT BY TeE DUE DATE $ 2597,25 END INQUIRIES TO PO BOX 15919 WILMINGTON DE 19850-5919 IF YOV TELEPHONE YOUR INQUIRY, YOU DO NOT PRESERVE YOUR SGHTS VNDER FEDERAL. LAW. VSTOMER SERVLCE TELEPHONE NUMBER'S: 800-334-3942, 800-545-0464 O REPORT LOST/STOLEN CARDS, TOLL FREE 800-334-3942 ANYTIME FROM ALL 50 STATES, PUERTO RICO, AND THE U.S. VIRGIN SLANDS. YOV ARE NOT REQUIRED TO PAY ANY SPECIFIC AMOUNT YOV HAVE PROPERLY REPORTED TO US AS DISPUTED PENDING OVR OMPLIANCE WITH APPLICABLE LAW. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is ~~+~~ W ~.~UC~-- (NAME) ~a~~T~-+-~ ~,~,~ of G~.s .~ c-=~c.~'~, ~~` ,plaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. i ~~~ / (SIGNATURE) WWR# 03336773 IN 'tHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. John J. Dyson Defendant ANSWER TO COMPLAINT: 1. I assume this is true 2. Yes. No. 04-4400 Civil Term COMPLAINT IN CIVIL ACTION 3. I have no knowledge of a credit card with this number belonging to me. 4. This "exhibit 1"credit cazd statement is unknown to me. 5. I have no knowledge of the terms of this. 6. Again, I have no knowledge of this. 7. This is the first document I received regazding this matter. EXHIBIT Sincerely, ~~~~ John J. Dyson `~j~-3f 033 3C~~7 ~ 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION CACV OF COLORADO, LLC, ) Plaintiff, ) v. ) JOHN J DYSON, ) Defendant. ) NO.: 04 - 4400 CIVIL TERM Plaintiff demands that the defendants answer and respond to the following Request for Production of Documents under oath pwsuant to the Pennsylvania Rules of Civil Procedwe within 30 days from the date of service hereof. Plaintiff also demands that defendants answer and respond to the following Request for Admissions pwsuant to Pa. Rules of Civil Procedwe 4014. You aze requested to admit the truth of each of the statements of fact hereinafter stated. You aze instructed that: 1. These requests aze made under Pennsylvania Rules of Civil Procedwe 4001, et seq., and each of these matters of which an admission is requested shall be deemed admitted unless your sworn statement in compliance with such Rules is timely made. 2. If you do not admit each of such statements, you must specifically deny each one not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each such matter. 3. Yow answer, signed and properly verified, must be delivered to the undersigned attorney of record for the Plaintiff within thirty (30) days after delivery hereof. 4. If you fail or refuse to admit the truth of any such statement of fact and the Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses incurred in making such proof, including attorneys' fees, witness expenses, etc. 5. If, in response to any of the following statements of fact, it is your position that the statement is true in part or as to some items, but not true in full or as to all items, then answer separately as to each part or item. 6. If you have been sued in more than one capacity or if your answers would be different if answered in any different capacity, such as partner, agent, corporate officer or director or the like, then you aze requested to answer separately in each such capacity. Failure to do so constitutes an admission in any such capacity. In these Requests for Admissions: EXhI' B ~T Ci A. The word " erson s " means all entities, and, without limiting the generality of the foregoing, includes natural persons, joint owners, associations, companies, partnerships, joint ventures, trusts, and estates; B. The word "documentfsl" means all written, printed, recorded, graphic, or photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any manner to the subject matter indicated; C. The words "identity". "identify". "identification", when used with respect to a erson s means to state the full name and present or last known address and business address of such erson s and, if an actual person, his present or last known job title, and the name and address of his present or last known employers; D. The words "identity" "identify" "identification" when used with respect to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name(s) of the addressee or addressees if any and the name(s) and address(es) of each ep rson who have possession, custody, and control of said document(sl. If any such document was, but is no longer in your possession, custody, or control, or in existence, state the date and manner of its disposition; and E. The word "identi "when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means to (1) describe the substance of the event or events constituting such an act, and to state the date when such act occwred; (2) identi each and every erson s participating in such an act; (3) identi all other erson s (if any) present when such act occurred; (4) state whether any minutes, notes, memoranda, or other record of such act was made; (5) state whether such record now exists; and (6) ident~ the erson s presently having possession, custody or control of such record. 8. Unless otherwise indicated, all Requests herein relate to those certain events, persons, and period of time more fully described in the pleading in this case. 9. These requests aze of a continuous nature These Requests fot Production of Documents shall be deemed continuing so as to require supplemental answers and documents if any information of documents aze acquired subsequent to the filing of responses hereto, which information or documents would have been included in the answers and documents produced had it been known or available at the time the answers and the documents provided pwsuant hereto were produced. Defendants shall supply such information and documents by supplemental answers and production of documents as soon as such information becomes known or available and in all events, prior to trial of this action. If objection is made to any requests for production of documents, it is demanded that the requests for which there is no objection be answered and furnished within the aforesaid period. Al] documents identified in response hereto shall be organized and labeled to correspond with the request to which it pertains. For al] documents produced, list the individual and his or her job title and department from whose files it was produced and the current custodian of said document. If a document called for is believed to exist or is known to exist, but is in the possession, custody or control of another person or party, the existence of the document, the identity of the possessor, custodian and one in control of such documents shall be provided along with any applicable common description or citation utilized by the publisher, possessor, custodian or disseminator of such document. If any document called for by this request is withheld on the basis of any claim of privilege or any similaz claim, identify that document as follows: author; addressee; indicated or blind copies, date, subject matter; number of pages; attachments or appendices; all persons to whom distributed, shown or explained; present custodian; and nature of the privilege or similaz claim asserted. REQUEST FOR PRODUCTION OF DOCUMENTS 1: List all payments on the subject Credit Cazd referenced in the Complaint and produce any and all documents evidencing proof of those payments, including, but not limited to, cancelled checks, receipts, coupons, statements, accountings, memoranda, invoices, fmancial statements, accounting entries, diazies, charts, lists, phone records, data compilations etc. REQUEST FOR PRODUCTION OF DOCUMENTS 2: Produce any and al] documents you intend to introduce and/or provide testimony on as evidence at the time of trial. REQUEST FOR ADMISSION NO. 1: Defendant has made no payment on the credit cazd since December 2001. Admitted Denied If the answer to Request for Admissions No. 1 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION N0.2: Defendant failed to submit any written dispute as to billing inaccuracy concerning the credit cazd in question. Admitted Denied If the answer to the Request for Admissions No. 2 is "denied", then supply copies of specific written disputes as to any billing inaccuracies. REQUEST FOR ADMISSION NO. 3: Defendant is in Default on the Credit Cazd account referenced in the Complaint for failing to provide timely payments. Admitted Denied If the answer to the Request for Admissions No. 3 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION N0.4: The attached monthly statement correctly identifies the balance on the account. Admitted Denied If the answer to Request for Admissions No. 4 is "denied", then supply copies of canceled checks, both front and back, and/or if not available, specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 5: Defendant signed the attached credit cazd application. Admitted Denied If the answer to Request for Admissions No. 5 is "denied", then supply copies of canceled checks, both front and back, andfor if not available, specific written documentation supporting the dental. THI5 IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION RECEIVED FROM YOU WILL BE USED FOR THAT PURPOSE Benjamin Bi ter, Esquire Pa. I.D. 8 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsbwgh, PA 15219 (412)434-7955 WWR:03336773 Page: 1 Please indicate Name, or address Telephone changes gone ( ) Work ( ) ACCOUNT NOMBER PAYMENT DUE DATE PAST DUE AMODNT MII4INUM PAYMENT NEW BALANCE AMOUNT OF - -- PAYMENT ENCLOSED 4225 6130 6035 6915 12/28/2001 .00 32.00 1620.39 $ 1260 B10D AF 1 7 02 JOB'N J DYSON B HILL DR CARLISLE PA 17013-9650 ACCOUNT NUMBER CREDIT CREDIT DAYS IN HILL PAYMENT MINIMOM ~ LINE AVAILABLE TEEING CYC DATE DUE DATE AYMENT DUE 4225 8130 8035 6915 2000 379 32 12/04/2001 12/28/2001 - 32.00 DATE OF BANS POS2 REFERENCE NUt~ffiER DESCRIPTION OF TRANSACTIONS AMOUNT 0000 0000 PAYMENT PROTECTOR AT $.690 PER $100.00 11.10 1109 1109 24692169TOOFZH873 ADAM MAIL 800-794-3316 NC 24.63 1111 1111 24136299%HJGEQZVB BESS $ 38252 CARLISLE PA 13.64 1119 1119 242263BA39EEZPYK6 WAL MART MECHANICSBi7RG PA 65.60 1119 1119 7422636A59ELGRBbA1 WAL MART MECHANICSBIIRG PA 65.60- 1119 1119 7422561A309FD11P7 PAYMENT THANK YOII 26.00- 1121 1121 2443565A60333MSY2 WINE S SPIRITS 2110 CARLISLE PA 28.59 1121 1121 2461043A503PQJHAM VICTORIA SECRET 800-BBB-1500 OH 30.55 1121 1121 2469216ASOOX1F60S LEI*LAND3 END CLOTHING 800-332-4700 WI 28.45 1123 1123 2476501A700RXPYL2 SAWPALMETTOHARVESTING CO 663-324-1647 FL 70.89 YOII BUY IT. THEN IT GOES ON SALE. OUT OF LUCK? NOT NECESSARSLY. (SEE ENV&LOPB FOR DETAILS) IMPORTANT MESSAGE ABOUT AN Il4MEDIATE PHONE PAYMENT FEE. WE MAY IN OIIR DISCRETION PERMIT YOII TO MARE PAYMENTS BY AUTHORIZING US ON YOUR BEHALF TO TRANSFER FONDS FROM A DEPOSIT OR OTHER ACCOUNT PREVIOIIS NEW PURCHASES DEHIT FINANCE OVERLZNE NEW BALANCE PAYMENTS CREDITS AND ADVANCES ADJIISTMENTS CHARGE AMOUNT BALANCE 1416.51 28.00 65.60 273.65 .00 21.83 .00 1620.39 N AMOL)NT FOLLOWED HY A MINIS SIGN(-) IS A CREDIT OR A CREDIT HALANCE UNLESS OTHERWISE INDICATED YOU MAY AVOID ADDITIONAL FINAlOCE CHARGES ON PURCHASES IF YOU PAY TBIS AMOUNT 8Y THE DU8 DATE $ 1620.39 '.ND INQUIRIES TO PO HOP. 15919 WILMINGTON DE 19850-5919 IF YOU TELEPHONE YOUR INQUIRY, YOU DO NOT PRESERVE YOUR GHTS UNS1FSt FEDERAL LAW. 'STOMER SERVICE TELEPHONE NUMBER'S: 800-441-7681, 800-545-0464 REPORT LOST/STOLEN CARDS, TOLL FREE 800-441^7681 ANYTI!!E FROM ALL 50 STATES, PUERTO RICO, AND THE U.S. VIRGIN LANDS. YOD ARE NOT REQUIRID TO PAY ANY SPECIFIC AMOUNT YOU HAVE PROPERLY REPORTED TO VS AS DISPUTED PENDING OUR MPLIANCE WITH APPLICABLE LAW. Page: 2 Pleases indicate Name, or address Telephone changes Home ( ) Woxk ( ) ACCOUNT NUMBER PAYMENT DVE DATE PAST DUE AMOUNT MI24IN01•f PAYMENT NEW BALANCE AL~UNT OF ~ PAYMENT ENCLOSED 4225 8130 6035 6915 12/26/2001 _ _ .00 32.00 1620.39 $ 280 8100 AF 1 7 02 JOHN J DYSON S HILL DR CARLISLE PA 17013-9650 ACCOUNT NOMEER CREDIT LINE CREDIT Avtn anLE DAYS IN SEEING CYC BILL DATE PAYMENT DUE DATE MINIMUM AYMENT DUE 4225 6130 6035 6915 2000 379 32 12/04/2001 12/28/2001 32.00 DATE OF N RAMS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTIONS AMOU T TO YOUR ACCOUNT. FOR EACH SDCH PAYMENT, YOU WILL BE CHARGED AN IH&fEDLATE PHONE PAYMENT PROCESSING FEE OF $12. +++ FINANCE CHARGE CURRENT PURCAA.SE 21.83 PREV'IOIIS BALANCE PAYMENTS CREDITS NEW PURCHASES AND ADVANCES DEBIT ADJUSTMENTS FINANCE CHARGE OVERLINE AMOVNT NEW BALANCE 1416.51 28.00 65.60 273.65 .00 21.83 .00 1620.39 N AMOUNT FOLLOWED BY A MIN[7S SIGN(-) IS A CREDIT OR A CREDIT BALANCE UNLESS OTHERWISE INDICATED YOII MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY T8I8 AMOUNT HY TH8 DUE DATE $ 1620.39 ;ND IN4UIRIES TO PD HO$ 15919 WILtQNGTON D& 19650-5919 IF YOU TELEPHONE YOUR INgUIRY, YOV DO NOT PRESERVE YOUR CGHTS UNDER FEDERAL LAW. 1STOMER SERVICE TELEPHONE Nfk~ER'S: 500-441-7681, SOD-545-0464 J REPORT LOST/STOLEN CARDS, TOLL FREE SDO-441-7681 ANYTIME FROM ALL 50 STATES, PUERTO RICO, AND TAE V.S. VIRGIN >LANDS. YOU ARE NOT REQUIRID TO PAY ANY SPECIFIC AMOUNT YOU HAVE PROPERLY REPORTED TO US AS DISPUTED PENDING OVR R2PLIANCE wITH APPLICABLE LAW. JCCnC ^anhattan Can®CO~C^ ~ r Platinum Vlsa ~ Credit Line Up To $100,000 N Offer Expires: August 28, 2001 ibc fo)fowmg lnla~lhn u necewiy pdor ro opening smw attounC rtPase I%E A 6USE OA aL1rA BADPGL6'4'r PfN. SlPOaiv ~bN, atl Ve p SOCIRL SEC wgd9FP PIPE9F801IN (9t - y~ -(z7y o8- J7 •19,5Y u~a~sgP~awF Jh~llcr . NONE FH0.~ tt t 717 ~tY3 S2)G t'Jt7 ~ 98`-39gt rFrxrxou~gtnxt~F+ uraorEaswaa $ U 9 G°° •fN) •7nC. (.D-1 V/1:7. lnG I (l ./ hWadtlbaAdaug.atlsgpgmg0oaatlmmrce WasMmmgolararcaaa bmNEUe1 FR7689508463 1030011702 P rinte ^~'~-Cffi~I^~ ~ I(ynu aroWd tike ~ addtionil e~d'm mdber ~, P~ mm~e below. FWSi wwrarxmu IASi '~ I was a Irc~pmao my perk raring, Plea enmE me in de Co~ae PrY+ne4 Pmlaw Pkn. I lucre m.+d and arpcmnd da edoxd dic. 1 undemnod tlW emo0mm fs optiwd ad f w, orael a mry tie k11xtH:gEFOg OPadN4l PAYbEgFPlroi&TOq p_„ bVE 7/w ~~ John J. Dyson 81iiE Dr, Carlisle, PA 170139650 VR-213302-021091 aEnsEFFa~ w nnu un nEtuAelitg FN161EF9FM wn~cn+~oP¢ Par>NOen. PLATINUM VISA BALANIE TRANSFER FORM Complete this form today to pay ogyour outstanding balances at a low fixed APE of just 1.9990! You can transfer one, two, or thine bahnces to }roar nea+ Platinum Visa.# 1) ecmum xnmbet: 2) ,Mouum Numbe: 3) Aaaunt Nmrbu: y3i q. o4ro•ojab- vfl37 ~~ " // t,~..k q ~Ka ~ra Parmmt Address: P o ~bx ~z~° ~~~~~ Coro ~ f('yC[w~ ~ TL daQ1-Sz79 SLUE z~~ EoriAmooot Tb & P.ddMd TraadcrrE; Paymmt/,ddrox 51PEEi PDDPES51PO B0X ran SfAtE ZIP (ASE fsxt Amwot to & Paid Aud Aaosfined: rn~ PaymmtAddress 5Rt~T ADO~SSfPO Bn% cn 50.1E ZIP ODE Eaact AmmudTo & Paid MdTreasferred: s^©,®©~.~C] sDD,DDD.DD $DD,DDD.D^ • Sa reverse side for Nodtt, Summary of Term{ and addidoenl Dkrtosmes. F27689508463 ~ see revere sMe for 9ahaa transfer Dlscloswes. ~a~ 5~s ~ 3~ ~ 035 t~ q t s J 0 0 0 rn a c.a .o. Pa Dv ^ ,3 ~ CERTIFICATE OF SERVICE A true and correct copy of Plaintiffls First Request for Production of Documents and Request for Admissions has been served by U.S. Mail, on the ?~ day of -~' 2004, upon the following: John J. Dyson 8 Hill Drive Carlisle, PA 170]3 By: VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and(or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiffs Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set forth in the foregoing pleading aze true and correct to the best of his knowledge, information and belief. ~Z ~Y ~~ Date CERTIFICATE OF SERVICE A true and cottect copy of the within Plai(n`tif/fls Motion for Summary Judgment has been served by U.S. Mail, Postage Pre-Paid, on a~~ of (0005 upon the following: John J. Dyson 8 Hill Drive Carlisle, PA 17013 BY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff, Case No.: 04 - 4400 CIVIL TERM vs. JOHN J. DYSON, Defendant. ORDER OF COURT AND NOW, to-wit, this _ day of 2005, upon this Court's consideration of Plaintiffls Motion for Summary Judgment, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is GRANTED and Plaintiff is awarded judgment against defendant John J. Dyson in the amount of $3,898.91 with continuing finance charges thereon at the rate of 24.49% per annum from August 6, 2004, plus costs. BY THE COURT J. -„ :~ 3 -c, w w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. JOHN J DYSON Defendant TO: John J. Dyson 8 Hill Drive Carlisle, PA 17013 Civil Action No. 04-4400 CIVIL IMPORTANT NOTICE Date of Notice: ~L~ -`~'~~~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. 1F 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 WELTMAN, WEINBERG &REIS CO., L.P.A ~'~ a 0 tY~\~,^~~~~~ By: William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR #03336773 n.~J (~~ ["'' r t tJ~ '~` yl gi1G 'wl, t ,1_. ~,~ ra YL t ~ ~-~ L.> a ~ ~ '~P (.~ a. l.n~ PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be Stated in full) CAC,V of Colorado, LLC (Plaintiff) vs. .John J. Dyson (Defendant) No./+h00 Civil X9 2004 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's damuTer to complaint, etc.) Motion foc Surmiary Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Benjamin R. Bibles, Esq. Address: 2718 Koppers Bidg., 436 7th Ave Pittsburgh, PA 15219 (b) for defendant: Joins J. Dyson, 3?ro se pt3dress: 3 tIill Drive Carlisle, PA 17013 3. I will notify all parties in writing within two days that this case has been listed for a*M~++P~t. 4. Argument Court n3te: 1 __ ~ 1( ~ / C~~ Dated: 4/11/05 ttorney for plaintiff t'-1 lei y-~ Y L' T ! - _ -,7 f'l ry l ~r; Y r J >_- ~`' cn 5:; ~i ~, #23 CACV OF COLORADO, LLC V. JOHN J. DYSON ORDER OF COURT AND NOW, this 18~ u day of MAY, 2005, after review of Plaintiff's brief and motion, and the Requests for amount of $4,629.66 and interest. By tlfe Court,`•: w`~!/ Edward E. Guido, J. Benjamin R. Bibler, Esi 2718 Koppers Building 436 T" Avenue Pittsburgh, Pa. 15219 John J. Dyson 8 Hill Drive Carlisle, Pa. ] 7013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2004-4400 CIV IL TERM BEFORE HESS, GUIDO. JJ, having failed to respond to said motion as well as to Plaintiffs Plaintiff s Motion for Summary Judgment is GRANTED in the 2a,~c:~ ~ivi~~a.~.~':~L. _ Jim-D Sr i,~ , sld 4~.7 ~Y~ ~).. C (' ) C--~ v .. P•a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff vs. JOHN J. DYSON, Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND USED FOR THAT PURPOSE. Case No.: 2004-4400 CIVIL TERM TYPE OF PLEADING PRAECIPE FOR JUDGMENT PER ORDER OF COURT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A, 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15215 (412)434-7955 WWR # 03336773 $4629.66 ANY INFORMATION OBTAINED SHALL BE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff Case No.: 2004-4400 CIVIL TERM vs. JOHN J. DYSON, Defendant. PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: kindly enter'~udgment agai sOheeDefendant,SJOHN J.IDYSON,'nn theca ounf otf $462 66 compu0t0ed as follows: Amount Awarded per Order: $4629.66 Interest from the date of judgment at the legal rate of 6% per annum: $0.00 TOTAL: $4629.66 Attached is a copy of the Court Order in favor of Plaintiff for Judgment. WELTMAN, WE~gERG & REIS, CO., L.P.A. By. J William T. Molcza , Es ire PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A, 2718 Koppers Bldg, 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 Plaintiffls address is: c/o Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 7`"Avenue, Pittsburgh, PA 15219 And Defendant's address is: 8 HILL DRIVE, CARLISLE,PA 17013 #23 CACV OF COLORADO, LLC : IN THE COURT OF COMMON PLEAS OF V :CUMBERLAND COUNTY PENNSYLVANIA JOHN J. DYSON N0.2004-4400 CIVIL TERM ORDER OF COURT ``» NOW, this 18TH day of MAY, 2005, after review of Plaintiff's brief and motion, and thb Defendant havin g failed to respond to said motion as well as to Plaintiff's Requests for Admissions, Plaintiff's Motion for Summary Judgment is GRANTED in the amount of $4,629.66 plus costs and interest. ~th`e Court,` Edward E. Guido, J. Benjamin R. Bibler, Esquire 2718 Koppers Buildin 436 7TH Avenue g Pittsburgh, Pa. 15219 John J. Dyson 8 Hill Drive Carlisle, Pa. 17013 :sld r~~,~ ~~ ~ In ~ortlt~n, r~C'rRR R~CO~IJ fiat y ~~~~'f, 1 I3i3C@ Uft'.A ~:.~:~ ~4tRonobry ~U333 ~~~s t~EFORE HESS GUIDO JJ. VERIF-- IC?TION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczai , Es PA LD.#47437 re Wellman, Weinberg & Reis Co., [,.p,q. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#03336773 ~ -~' ~_ ~~~0c D ~ U ~ a` ~ ~ ~~ ~ ~ Q 2~ 1:: C 1 : T ~ j P. z 7 ~ - rr~~ - , . ? ~, ~ ~~ - ~ ~ v ~~ ~ m C ~ <'? ~ N -~ F' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pE1~SYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC, Plaintiff Case No.: 2004-4400 CIVIL TERM vs. JOHN J. DYSON, Defendant. NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendants )Garnishee You are hereby notified that [he following Order or Judgment was entered against you on 0.S (xx) Assumpsit Judgment in the amount of $4629.66, plus interest at 6% per annum, plus costs. Trespass Judgment in the amount of $ plus costs. ~ ) [f not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA, (xx) Entry ofJudgment of (xx) Court Order ~ ) Non-Pros ~ ) Confession ~ ) Default ~ ) Verdict Arbitration Award ~ ) By Consent JOHN J DYSON Prothonotary 8 HILL DR CARLISLE,PA 170]37 By: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION} USED FOR THAT PURPOSE. SHALL BE ~-, r.a _ (i -r! -I - T -l-= CJ - _~ 1 {'. ~ (,~: i I V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. JOHN J DYSON Defendant No. 04-4400-CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#03336773 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. Civil Action No. 04-4400-CIVIL JOHN J DYSON Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and before m his day o ep rr WELTMAN, WEINBERG &REIS CO., L.P.A. rmbrodt WELT AN WEINBERG &REIS CO., L.P.A. 2718 op ers Building 436 ev nth Avenue Pi sb rgh, PA 15219 ( 434-7955 By: James C PA I.D WWR #03336773 e": r: NOTAR ~'', O ~~ ~`~ ~ .~ ~; 2'~' (,J ~~ ~y k ~'~~