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Home My WebLink About05-0162 1227 MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 NO. o t - I l:.;;l.... COUNTY, PENNSYLVANIA C;U: l ~€R..l IN THE COURT OF COMMON PLEAS OF CUMBERLAND Plaintiff VS. CIVIL ACTION - LAW DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 Defendant (5) 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 (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 or any other claim or relief requested by the Plaintiff. You may lose money or property 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 HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NOTICIA Le han demandado a used en la corte. Si used quarere defensas de esas demandas expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a last demandas en corta de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una orden contra used sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Used puede perder dinero 0 sus propledades 0 otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. 51 NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE 5E PUEDE CON5EGUIR AS5ITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle 800-990-9108 PA 17013 CVRNOT/PACCP W&A FILE NO. 122959777 1231 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 NO. (X - J&'~ C,-"L~~ Plaintiff VS. CIVIL ACTION - LAW DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 Defendant(s) COMPLAINT Now comes the Plaintiff, MBNA AMERICA BANK, N.A. , by and through its attorneys, and the law firm of Wolpoff & Abramson, L.L.P., and files this Complaint and in support avers as follows: 1. Plaintiff, MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 is a business entity doing business within the Commonwealth of Pennsylvania and the other states of the United States. 2. Defendant, DONNA M ENSOR a last known address of , is an adult individual with 1024 TEAKWOOD LN ENOLA PA 17025-2046 COUNTY OF CUMBERLAND 3. It is averred that Defendant(s) was/were issued an open end credit card account. The Terms and Conditions governing this account is attached hereto, incorporated herein and marked as Exhibit "A". 4. At all relevant times material hereto, Defendant(s) has/have used said charge card for the purchase of products, goods and/or for obtaining services. 1DSOA1/PACCP W&A FILE NO. 122959777 1235 5. showing account Plaintiff provided Defendant(s) with copies of the Statements of Account all debits and credits for transactions on the aforementioned credit card to which there was no bona fide objection by Defendant(s). 6. Pursuant to the Agreement concerning this account, the parties agreed that this matter be referred to Arbitration in the event of any claim and/or dispute if the account is referred for collection. See Exhibit "A" as previously identified and incorporated herein. 7. This matter was referred to Arbitration for determination and disposition, whereby an Arbitration Award was entered against the Defendant(s) and in favor of the Plaintiff for the outstanding balance due. A true and correct copy of the Arbitration Award is attached hereto, incorporated herein and marked as Exhibit "B". 8. As of the date of this Complaint, the remalnlng balance due, owing and unpaid on Defendant's credit card account, as a result of charges made by said Defendant(s) and/or any authorized users is the sum of $ 6201.50 9. Despite reasonable and repeated demands for payment, Defendant(s) has/have failed, refused and continue(s) to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 10. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff, MBNA AMERICA BANK, N.A. , respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendant(s), DONNA M ENSOR , in ,the amount of $ 6201.50 plus costs of this action and such other relief as the Court deems proper and just. Respectfully submitted, 1)J~ 11_~- Amy F. Doyle -P~V~87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #18837 Philip C. Warholic #86341 David Schertz #81925 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff lDSOA2/PACCP W&A FILE NO. 122959777 1240 ATTORNEY VERIFICATION I hereby state that I am the attorney for the Plaintiff, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, am authorized to take this verification on behalf of said Plaintiff in this action and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understand~ that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: (JJ~ f j -~-- --. Amy F. Doyle ~V~O~ Daniel F. Wolfson #20617 Bruce H. Cherkis #18837 Philip C. Warho1ic #86341 David Schertz #81925 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff PAVERF/PACCP W&A FILE NO. 122959777 1231 EXHIBIT IIAII 1\ Account Agreement Genenl: In this Agreement, the words "you" and "your" refer to each and aD of the persons in whose names this account was issued and who obtai credit in any way provided for under this Agreement. The ivords "we," "us," "OUT," and "MBNA America" mean MBNA America Bank, N.A. The wor, M Advance" means any 101Jl you obtain from us under this Agreement Our Agreement with you consists of this Agreement and the terms and conditions printed on the required federal disclosures section of the accOlJ1Sanyilq Tenns of Your Account letter, which is incorpo/lited herein and made a part hereof. Please keep these documents, and subsequent amendmerits, if lUlJ': ~~. ' When you, or anyone whom you authorize or pennit, use your account, you agree to the terms of this Agreement You consent to and authorize MBNA America, any of ilS affiliates, or ilS marketing associates to monitor and/or record any of your telephone conversations with our representatives or the representatives of any of those cOlJ1lanies. AlJ capitalized tenns not defined herein shall have the meaning as defmed in the required federal disclosures section of your Terms of Your Account 1ctta. Credit Reporting Agencies: Jf you belieVe we haVe fumisbe,ii inaccurati: or ineOnlJJcte inforination about.you or your account to a credit reportin, agency, write to us at: MBNA, Credit Reporting Agencies, P. O. Box 17054, Wilminston, DE 19884-7054. Please include your name, address, home phone number, and account number, and explain what you believe is inaccurate or incomplete. Bow To Use Your Account: You may use your account to purchase or lease goods or services from penonI who honor checb. You may obtain NdI credit under your account by requesting cbeclcs or drafts payable in U.s. Dollars that wiD be: ICDt either dilectJy to your designated payees or to you for forwardin, to your designated payees. We may offer the direct deposit of Advanc:es into your banJdngllCCOUlJt or those of your c:n:ctiton. .A Ya11a1n1ity or funds IICIIt through direct deposit dependl upon the policies and procedures of the receiving bank. If this account includes a special feature to purchase loods or services nom a merchant, we may send Advances directly to the merchant on, your bebaJl. From time to time, ~ may iaue )IOU additional checks or offer other additional Advances in response to your request. You may not use any Advance soJc1y to make a JllIyment on thilllCCOUDt or IOJeJy to make a payment on any other credit account with us. If you pcnnit any person to have access to your checks or account number with the authorization to maJce a c:harp, you may be: liable for aU Ad'll8.llCeS made by that person includinS Advances for which you may not have intended to be liable. You agree not to use a postdated check to obtain credit Imder your accounl If you do postdate a cbec1c by which you propose to obtain credit under your account, we may elect to honor it upon presentment or return it Impaid to the party which presented it for payment, without in either case awaiting the date shown on the check. We are not liable to you for any loss or expense incuJTCd by you m:ising out of the action we elect to 1akc. You must retlim all checks to us on requesl Credit Umlt: Your crcditlimit is shown on your Terms of Your Account Ielta' and generalJy on each monthly statemenl We may cbanae your credit limit or limits from time to time, and we will notify you if we do. The total amount of credit outstandinS at anytime must not be: more than your credit limit We may also establish a separate credit limit for certain balances. If we dq, your oUlStanding balance on these typeI of items may not exceed tbis separate m:ditlimil . Request lor Credit Over Your Credit Limits: If you request credit in any fonn which, if JlI"IIIted, would result in either your total outstandins balance or your separate outstanding balance, including authorized transactions not yet posted to )'0\11' account, beina more than your credit limit or your ICp8tate creditlimil, if we have established one for you, (whether or not such balances before the request were more than the respective credit limit), we may. (I) Honor the request without permanently raisins your credit limit; . (2) Honor the request and treat the amount which is more than your credit limit as due immediately, or (3) Refuse to honor the request. We may advise the person who made the request that it bas been refused. If we refuse to honor a check, we may do so by advising the person presenting the check that credit has been refused, that there are insufficient funds to pay the check, or in any other manner. If we have previously honored requests for credit over your credit limit, it does not mean that we wm honor further overlimit requests. If we decide to honor such a request, we may assess an overlimit fee as provided in this Agreement. Additional Advances: You may obtain adcfitional Advances from time to time provided that you continue to meet our income and credit standards without any significant adverse chanle. The approval of one request does not mean the approval of other requests. Additional Advances posted to your account cause the term of the loan to re-start, resulting in a revised minimum monthly payment and revised length of time to repay the Joan. Additional Advances must be at least $200.00. Term of Your Loan: Your repayment term is disclosed in another document location. Your monthly payment amount will be disclosed as the Current Payment on your monthly statemenlS. Certain evcnlS may result in your account balance not being paid off during the term. In this case, we do not change the minirrum monthly payment amount Instead, we extend the tenn to repay the balance. For example, the follOwing events will extend the term: (i) a payment holiday which you take; (ii) an increase in the prime rate for any variable annual percentage rate account; (iii) all fees iqlOsed on your account, such as check transaction fees, late fees, over the -credit limit fees and insurance premiums; and (iv) payments received later than the payment due date. . . ~ p' e Charges assessed on AdVances , " tak into account the effect of adding unpaid penoehc ie mane Also the minimum monthly payment does not e daily Advance balance. This will extend the tent\. . . . . t due each month}: (i) a temporal')' reduction m the annual pen: The following events will teCluce the tcnn (but wi~\ not cha~ge the ~n,:,:= annual percentage rate; and (Hi) payments greater than the n rate, such as a promotional rate; (ii) a decrease 1n the pnme tate Of . minimlm payment. 'to us the amounts of all credit you obtain; this includes a\1 Advances, any fees, charges. and inS\I1'8I1U premi\J Repayment: You prOl11lSC pa~ charge against your account; and Fmance Charges. '" Y ~e entire amount outstanding at any time without penalty. You mast pay each month at least the minil1llm payment shown 0 m:~~':~t. The minimum payment will be the total of (i) the turreIIt payment ~mount shown on your monthly statement; plus (ii) the ami any past due payments. The cunent payment amount ~ based upon the a~t outstandJ?I' the term of your Joan. and the annual percentage rate. BY or if a credit balance is otherwise created m your account, we WI\1 not pay mterest on such amounts. Payments greater than the R ovcrp . h' bIb minimlm payment will reduce the total amount ofFmance Charges ot ct:WISC paya e y you. We will allocate your payments in the manner we de~inc: In ~ instances, we wil~ allocate )'0\11' payments to balmccs ~including !,CW trans81 with lower APRs before balances with higher APRs. This Will result m new balances With lower APRs (for examplc, tboac With promotional APR I being paid before ~y other existing balances: All payments will be credited. to your. ac:count for ~ biDing cycle in which ~' payment is rec MinilBlm monthly' payments cannor-be made m advance and payments JIIIdc m any bJ1lmg C)Il:\I: which arc greater thIIl,~ 1DUImMn payment ili not affeet your obligation to make subsequent minimnn payments each II1lIrlth. We can Rject payments not cIenominated in U.S. dollars or not dn a U.S. Ban1c.. No payment shall operate as an accord and satisfaction without the prior written lIppI'OV81 of a senior officer ofMBNA America. All persons who initially or subsequently request, accept or use the account are individually n:sponsible for any llUlS1lmlSiaa ba1allc:e. 1f two 01 persons an: responsible to pay any outstanding balance, we may refUse to release any of them ftom liabllity UJltil all Df the checks outstandina UIIl account have been returned to us and the balance is paid in full. Payinent Holidays: We mayallDw you, from time to time, to omit a monthly payment. We wiD notify you wilen this option is aftllablc. If you payment, Finance ChaJ'seS and insurance premiums, if any. will accrue 011 your balance in IICCOr'dance with this A&recment. The requirement th make a minimum payment each month will resume following your payment holiday. A payment holiday will increase the term of your 10811. Billbl' Cycle: A billing cycle begins on the day after the closing date shown 011 your account's pn:eeding monthly statement and CDda on the closill that appears on your account's statement for the cunent month. Insurance: Group credit insurance may be offered to you from time to time. Purehasc of this insurance is strictly optioIIal. Jf pun:hased. the ins! will protect us if an event occurs for which benefits are provided. We determine the cost of this insurance by multiplying the insurance rate then in by the average of your Advances and other cbargc:s outstanding during the bilHng cycle. The premium i. charged to ~ account u an Other Cbq BeneRts: You may be offered c:crtain benefits from time to time, which Will be subject to the restrictions outlined by MBNA America in a brocl otherwise. MaNA America reserves the right to adjust, add, or delete benefits and services at any time and without notice. ReasoDs for Requiring Immediate Paymeat: You will be in default and we can requite immediate payment of all amounts you owe if: (J))'OI ~ke any required ~aymcnt by the ~aymcnt Due Date; (2) your New Bal~ ~otal excceda ~ur ~it limit, or if we have established a scparaf ltmit for you, your separate outstandmg balance exceeds your separate credit lmut; or (3) you fall to abide by any other tcrmI of this Aareemc:nt. If you default, unless prohibited by applicable law. we can also requin: you to pay the co11c:ction and court costs we incur in any collection proccccl a reasonable attomcy's fee if we refer your account for collection to an attorney who is not our salaried employee. Our failure to exercise any of our rights when you default does not mean that we an: unable to exercise those rights upon later default Refusal to HODor Your Account: We are not liable for any n:fUsal to honor your account, including any fann of Advance, or for any relent' checks by us, any other bank, or any seller or lessor of goods or services. Termination: We may suspend or terminate your rights to obtain credit at any time for any reason. Your obligations under this Aan:cment I after your rights to obtain credit have been suspended or tenninated. Amendmenta: We may amend this Agreement at any time by adding. deleting, or cbangingprovisions in compliance with the applie- requin:ments of federal law and the laws of the State of Delaware. If an amendment gives you the opportunity to reject the change and change in the manner provided in such amendment, we may terminate your right to receive credit and may ask you to return ail C' condition of your rejection. The amended Agreement (including any higher rate or other higher charges or fees) will apply to the cnti including the balance existing before the amendment became effective. We may replace your account with another account at any time Assignmellts: We may ae any time. and without notice to you, assign your account, any sums due on your sccount, this Agreer obligations under your account or this Agreement to any person or entity. The person or entity to whom we make any such assignm all of our rights and/or obligations under this Agreement, to the extent assigned. . . . thorizcd use of ur account. You should immediately notify us at MBNA Arne Unauthorized Use of Y.our Account: You are ha:1e forl~::':~-8349) orallY:: in writing, of the loss, theft, or possible: unauthorized use of P.O. Bo~ 15021, WilmuagtoR, DE J.9BSD, (Telep one , account. Llti .don: The Arbitration provisions below apply to you unless you were given ~ ~ortunity to rej~c:t the Arbitration provisions ~d you did so 1 ~ in which case you agree that any litigation brought by you against us regardmg this account or thlS Agreement shall be brought 10 a court local the State of Delaware. Arbitration: Any claim or dispute ("C1aim") by either you or us against the other, or against the employe~, agents or assigns oftbc o~. arising !rei relating in any way to this Agreement or any prior Agrc:e~t or ~ ac:~ount (w~ under ~ sta.~te. In ~~ ~ or o~ and ~~thc money damages. penalties or declaratory or equitable relief). m~lu~mg C1~I1~ regardm~ ~e applicablbty of tillS Arbltra~on Section or the vahdity (I entire Agreement or any prior Agreement, shall be resolved by bmdmg arbitration. "ClaIm shaD have the broadest meanmg possible. ThC arbitration shall be conducted by the National ArlIitration Fonrm ("NAF"), under the Code of Procedure in effect at the time the claim is filed. ~ and fonns of the National Arbitration FOI'IIm may be obtained and Claims may be filed at any National Arbitration Forum office, www.arb-forum.cOll P.O. BOll 50191, Minneapolis, Minnesota 55405, telephone 1-800-474-2371. lrule NAF is unable or unwilJins to acl as arbitrator. we may subst another national1y recognized. independent arbitration organization that uses a sinnl. code of proc:eciIJR. At your written request. we wiD advance arbitration filing fee, administrative and bearing fees which you are required to pay to pursue a Claim in aJbitration. The arbilnter will decide who wi] ultimately responsible for paying those fees. In no event win you be required. to reimburse us for any arbitration filing, administrative or hearina fea il amount. greater thm.r what )'OUT court costs WOIlJd have been if the claim had been resolved in a .slate court .with jurisdictiOn. Any arbitration bearin which you appear will take place within the federal judicial district that includes your billing. address at the. time the Claim is filed. 1'his arbilnll ' agreement. is made pursuant to a .~tion involving intc:rsta~ commen:e, an~ s~. ~ ~vemed by the ~I Arbilntion Act, 9 U.S.c. If 1 ("FAA j. Judgment upon any arbItration award may be ent~ 111 any court having Junsdlc:tion. Tbe arbitration shan follow cxistingsub.tanCive Ia\l the ~t consistent ~th the ~~ and a~1icablc statutes oflimitations and shal1 honor any claims or privilege rec:ognized by law. If any....... the arbItrator shall wnte an opmlon cOIItammg the reasons for the award. ,....~ reque No claim submitted to arbitration is beaid by a jury and no Claim may be brought as a clasl action or as a private attorney scnc:ral Y do right to act as a class representative or participate as a member of a class of claimants with respect to any Claim. This Arb'trati . s:: not ~ve Claims now in existence or that may arise in the future. I on lion applIes to This Arbitration Section shaJJ survive the termination of your account with us as Wl:1I as any vohm"'.... -t f the "'''''bt . by you or sale of the debt by us. -~ pa....._. 0 uc m full by)lOU, any bankrupl For the purposes of this .AJt;itration Section, "we" and "us" means MBNA America Bank, N.A. its su' . . . succ:~IOIII, assi~. and ~y pun:baser of your account, and all of their omeen. directors, · = bsidJancs, affi~ates, Iic:enseea. predecCSSCll AddltionaJly, "we or "us shall mean any thin! party providing benefits services or produc:q . eqr . · agents and 8SalJDI or any and all of tber credit bureaus, merchants that accept any credit device issued under' the ~ t, reward m connection wida the account (including but DOl Jjmilcd collectors and all of their officers. directors, cr."P1oyces and agents) if, and O:y if, ~ a third or ~nment services, credit insurance companies, del ~c:rt ~gainst us. ~~o, for the purposes of tlns Arbitration Section, '"you" or "'-urs" shallJl8rtY IS named by )IOU as a co-defendlllt in any Claim Including but not limIted to all ~ or entities contractually obi' led the:;TV mean any person or entity approved bv III to U.. the )'G Iga on account and all authorized users of the account or .... acCOll1l If ~y ~ of ~is Arbitration Section is found to be invalid or unenforceable . Arbitration Section shall be enforceable without regard to such invalidity or unenru::.:r.:.w or stature ConsIstent with the FAA, the remainder of tb 11m RESULT OF nns ARBITRATION AGREEMENT IS 1liA COURT, INCLUDING SOME CLAIMS lliAT COULD HAVE ~E~C~ PROVIDED ABOVE. CLAIMs CANNOT BE UTJGA TE A TrORNEY GENERAL ACTIONS. BEFORE A JURY, AS CLASS ACTIONS OR AS PRJV~ ~ Governlnl La,,: This Agreement is made in Delaware I . principles. and by any applicable federal laws. . t II governed by the laws of the: State of Delaware'tbou . . WI t regard to Its conflict of lal If any part of this Agreement is found to be invalid, the rest remains effecti does not mean that WI: are unable to exercise those rights later. ve. Our failure or delay in cxcn;ising any of our rights under tbiJ Aarceme MBNA America~ is a federally registered service mark of MaNA Al1llrica Bank, N.A. C 2001 ~NA America Bank. N.A. Privacy J Your privacy is important to us At MBNA, we are committed to providing you with the finest fmanciaJ products and services backed by consistently top-quality service. And while information about you is fundamental to our ability to do this, we fully recognize the importance of keeping personal and account information secure. '. To offer you the widest range of products and services, MBNA may share information about you both within MaNA and outside of MBNA with other companies. This allows us to offer you products and services that may interest you and best meet your needs, whether they are available directly from MBNA or through our relationships with other companies. We want you to understand our information safeguards, what information we collect, wbat information we share, and the benefits you receive when we share information about you. This notice describes the privacy practices ofMBNA Corporation and all MBNA affiliates, including MBNA America Bank, N.A.. MBNA.America (Delaware), N.A., Palladian Travel Services, Inc., MBNA Hallmark Information'-Servi~.'IDc., MBN,A Marketing .... Systems, Inc., and MBNA Insurance Agency, Ine. (collectively, "MBNA'i, for financial products and services governed by the laws of . the United States of America. This notice explains MBNA's information collection and sharing practices and lets you choose whether or. not MBNA may share certain information about you, either within MBNA or outside ofMBNA with other companies. Our Security Procedures: MBNA understands the importance ofprotccting and securing infonnation and using it appropriately. Access to information about you is restricted to the people ofMBNA who require it to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards for the security of information. When MBNA shares infonnation about you with companies outside ofMBNA, we require them to impose safeguards, use it only for . permitted purpose, and to return it to us or destroy it once that plUpOsc is served. .We limit the amount ofinfonnation shared to what is appropriate to offer a product or service efficiently. MBNA requires any company receiving information from MBNA to sign . Confidentiality Agreement containing these requirements and obligating that company to protect the information as we would. IDformatioD We CoDed: MBNA collects and uses nonpublic personal information about you to conduct our business and to consistently deliver the top-quality Customer service you expect nom us. Sources of this information include the following: . Information we receive from you on applications and other forms or through your correspondence or communication with us including through the mail, by telephone, or over the Internet; Information we receive nom third parties, such as consumer reporting agencies, to verify statements you've made to us, or regarding your employment, credit, or other relationships; and Information about your transactions with MBNA and with other companies outside ofMBNA. . . Information We Share WIthin MBNA: We may share all of the information we collect about you with financial service companies within MBNA to offer additional products or services that may interest you and best meet your needs. We believe this is convenient for you and may save you both time and money. To do so, we share identification information (such as name and address), transaction and experience information (such as purchases and payments), credit eligibility information (such as credit reports and applications), and other information. The decision to purchase any such products or services is yours alone. You may tell us not to share credit eligibility information about you within MBNA, but please understand this'does not prohibit us nom offering you additional products and services or from sharing transaction and experience, identification, and other information within MBNA. Information We Share With Others: From time to time, we may allow companies outside ofMBNA to offer you their products and services that may interest you. These products and services may be offered by financial service providers (such as banks, loan brokers, account aggregalors, insurance agents, insurance companies, mortgage bankers, and securities broker-dealers), by nonfinancial companies (such as retailers, direct marketers, communications companies, Internet service providers, manufacturers, service companies, travel agents, cruise lines, car rental agencies, hotels, airlines, publishers, and organizations endorsing MBNA financial products or services), and otbers (such as nonprofit organizations). Subject to applicable law, we may share all the infonnation we collect with these companies outside ofMBNA, unless you tell us not to. Additionally, we may share all the infonnation we collect with companies that perform marketing or other services on our behalf or to other financial institutions with which we have joint marketing agreements. We are also permitted by law to share information about you with other companies in certain circumstances. For instance, we may share all of the infonnation we collect with companies assisting us in servicing your loan or account, with companies that endorse our products and services through affinity agreements, with government entities in response to subpoenas or regulatory requirements, and with consumer reporting agencies. If you tell us not to share information with companies outside ofMBNA that wish to offer you their products and services, as described above, please understand that we will continue to share information in these additional circumstances. Important Information About Your Choice: We're dedicated to serving your needs - and to respecting your choices related to privacy. You may tell us not to share credit eligibility information within MBNA, and you may tell us not to share information with companies outside ofMBNA that wish to afTer you their products and services as described above. If you wish to opt out of such infonnation sharing, please can toll-free 1-866-751-1255. We win ask you to verify your identity and the specific accounts to which the opt out applies, so please have an your account, membership, or reference numbers and your Social Security number or T~payer Identification number for deposit accounts available when you call. MBNA applies opt outs at the account level, not by individual Customer. When any person listed with others on an account oPts out (for example, a co-applicant, joint account holder, or authorized user), we wm list the entire accoiJnt as having opted oul MBNA will continue to adhere to its disclosed privacy practices for an account even if it becomes inactive or is closed. An opt out from information sharing on an accOlmt as described above, either within MBNA and/or with companies outside ofMBNA, remains effective unless revoked in writing. Federal regulations require us to provide this notice on an annual basis, whether or not an account has previously opted out from either type of information sharing. Please remember when you receive our subsequent notices that an account previously opted out from either or both types of infonnation sharing (and not revoked in writing) does not need to be opted . out again. . This notiCe 'uPdates and rq,laces ~y previ~us ~otices from MBNA about the privacy, security, and protection of information. j:~r additional infolmation regarding MBNA's privacy practic:es c:onc:eming the Internet, and to view the most rec:ent version of this privacy notice, please go to ~.mbna.com and click on "'Privacy Notic:e." You may have other privacy protec:tions under state laws. We may amend this privacy notice at any time, and we win inform you of changes as required by law. ~ 1235 EXHIBIT IIBII III NATIONAL ARBITRATION FORUM e MBNA America Bank, N.A. c/o Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 702 King Fann Blvd, Two Irvington Centre Rockville, MD 20850-5775 CLAIMANT(s), AWARD RE: MBNA America Bank, N.A. v Donna M Ensor File Number: FA0408000315872 Claimant File Number: 74981017476146 Donna M Ensor 1024 Teakwood Ln Enola, P A 17025-2046 RESPONDENT(s). The undersigned Arbitrator in this case FINDS: 1. That no known conflict of interest exists. 2. That on or before 08/19/2004 the Parties entered into an agreement providing that this matter shall be resolved through binding arbitration in accordance with the Forum Code of Procedure. 3. That the Claimant has filed a Claim with the Forum and served it on the Respondent in accordance with Rule 6. 4. That the Respondent has filed a Response with the Forum and served it on the Claimant. 5. That the matter has proceeded in accord with the applicable Forum Code of Procedure. 6, The Parties have had the opportunity to present all evidence and information to the Arbitrator. 7. That the Arbitrator has reviewed all evidence and information submitted in this case. 8. That the information and evidence submitted supports the issuance of an Award as stated. Therefore, the Arbitrator ISSUES: An Award in favor of the Claimant, for a total amount of $6,201.50. Entered in the State of Pennsylvania ~L~ ANDREW B, COHN, ESQ. ARBITRATOR ACKNOWLEDGEMENT AND CERTIFICATE OF SERVICE This Award was duly entered and the Forum hereby certifies that a copy ojJ:hi~ard was sent by first class mail posta~ZP(~j~It~Jtte'i\m:ties at the above refereJIce~dresses'~ ~ date. r/ ---- \\ ~~,;;:l J \~, '\ c-__ b~,r,--" ~ HoIl.m.~ ~." ,'et. \~", Dh'ector /~:/ '(Y,(' ..., ~ ~-::,"/ '<,A R8Tfi ~:),/ ~_.._,.__._-_.-'" Date: 11/05/2004 7-? t ~ W D -0 (J -to. ~ ~ :i V( ~ C> ~~ l~ J:- ....,.....!- \ --T ;. ~ ~'-- ~:: - -j,~. ~~~ n ~~~, - .j -<. ......, c:;.:> c''"') c.71 o -11 --I ::L-n {n -.- ,.. -nl'q "0 C1 l.:) r _.,(.J "-;~: ~4 '~~:2 f\~ ,..J .,.-1 "." """'.a --< C- :--- ....,....1" ""- o ::r'" :J,i: o N N 8 SHERIFF'S RETURN - REGULAR CASE NO: 2005-00162 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MBNA AMERICA BANK NA VS ENSOR DONNA M SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ENSOR DONNA M the DEFENDANT , at 1855:00 HOURS, on the 2nd day of February, 2005 at 1024 TEAKWOOD LANE ENOLA, PA 17025 by handing to DONNA ENSOR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 35.52 .00 10.00 .00 63.52 ~ //~ .~~~e=-L<4~.~:~ R, Thomas Kline , "" me thlS /1- day of 02/03/2005 WOLPOFF & ABRAMSON By: rJ L '!l~~ (" Deputy fi1 " t! s~eriff Sworn and Subscribed to before j~"~'7 ~ov:{_ A.D. r~. Q !hA(J" ,~ othonotary 2652 o. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 No. 05162CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DONNA M ENSOR Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF "MlftK C1.lme.c~I\1D The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, DONNA M ENSOR , above-named, is over 21 years of age; is last known to reside at 1024 TEAKWOOD LN ENOLA PA 17025-2046 County of CUMBERLAND the United States or Servicemembers Civil , Pennsylvania; is not in the military service of its Allies, or otherwise within the provisions of the Relief Act and its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dina A. Sweitzer, Notary Public Hampden Twp., Cumberland County My Commission Expires Apr. 16. 2008 Amy . Doyle t 8 062 Daniel F. Wo fson #20617 Bruce H. Che kis #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff 4- day of ()::1DbL\ ,20D"). SWORN and SUBSCRIBED to before me this PNMAFF/PANOJ W&A FILE NO. 122959777 ;.." tf lS} (:) "1/ -.. "', ", ..' "0.) "....) 2653 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 No. 05162CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DONNA M ENSOR Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 and certify that the last known address of the within Defendant(s) is: DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 Amy F. oyle 1187062 Daniel F. Wol on #20617 Bruce H. Cher is #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff PCRES/PANOJ W&A FILE NO. 122959777 ...., (:~:) c:::> (:>1 c) -n :::;;J C'J C.) -.J 0) "-, f'-.j ~ 2654 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 NO. 05162CIVILTERM Plaintiff vs. : DONNA M ENSOR Defendant (s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), DONNA M ENSOR and for want of ANSWER TO COMPLAINT. Amount due $ 6201.50 Interest $ Attorney's Commission $ Fi ling cos ts $ TOTAL $ 6201.50, plus interest ( X) I certify that the foregoing assessment of damages amounts alleged to be due in the complaint and is calculable as the complaint. ( X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( X) Pursuant to Pa.R.C.P. 237.1, 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 his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. ( X ) and costs is for specified a sum certain from DATE: iO/'1ID ( ( , Signature: Amy F. Doyle /187062 Daniel F. Wol son #20617 Bruce H. Cher is #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff , JUDGMENT IS EN)fRED AS ABOV NOW, ,20_ Pro tho ivision By: Deputy OD ^T:'r T IUA'tJn T lJt.A li'TT l<' N'n 1 ??Qc.Q777 ~; (J c::; -n ';;J' c::-" r.n) __oj _.1 r:-? N r..;; 131 MAIN OFFICE TWO IRVlNGTON CENTRE 702 KING FARM BLVD., ROCKVlLLE, MD 20850 REGIONAL OFFICES 10605 JUDICIAL DR" BLDG. A.S, FAIRFAX, VA 22030 1 toe E. MAIN ST., STE. 1003, RICHMOND. VA 23216 5122 GREENWICH RD.. VIRGINIA BEACH, VA 234132 919 N. MARKET ST., STE 1300, WILMINGTON, DE 19899 1954 GREENSPRING DR., STE. 400, TIMONIUM, MD 21003 1 VALLEY BANK BLDG. BOX 1226, CLARKSBURG, VW 26302 2625 TOWNSGA TE RD #330. WESTLAKE VILLAGE, CA 91361 267 E. MARKET ST., YORK, PA 17403 24360 NOVI RD.. BLDG. 1, NOVI, MI48375 300 CANAL VIEW BLVD.. ROCHESTER, NY 14623 NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS [NOT REGIONAL OFFICES OF WOLPOFF & ABRAMSON, L.LP.] W BIRMINl>HAM, ALABAMA CABOT, ARKANSAS ANCHORAGE, ALASKA ENGLEWOOD, COLORADO PHOENIX, ARIZONA Fr. LAUDERDALE, FLORIDA 122959777 DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 LAW OFFICES W 0 L P 0 FF II< A BRA M SON, L. L. P. Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 267 EAST MARKET STREET FIRST FLOOR YORK, PA 17403-2000 717-848-6203 OUTSIDE YORK METROPOLITAN AREA (TOLL FREE) 1-800-758-0675 FACSIMILE (717) 848-1146 PLEASE DIRECT ALL INQUIRIES TOYORK OFFICE FEBRUARY 24, 2005 Re: MBNA/GOLD RESERVE-GOLD OPTION vs. DONNA M ENSOR Docket No. 05162CIVIL TERM Dear DONNA M ENSOR NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS rNOT REGIONAL OFFICES OF WOLPOFF & ABRAMSON, L.L.P.] * NORCROSS, GEORGIA CLEVELAND, OHIO HONOLULU, HAWAII OKLAHOMA CITY, OKLAHOMA BOISE, IDAHO EUGENE, OREGON MERRllLVILLE, INDIANA PROVIDENCE, RHODE ISLAND CHICAGO, ILLINOIS COLUMBIA, SOUTH CAROLINA KANSAS CITY, KANSAS KNOXVILLE. TENNESSEE LEXINGTON, KENTUCKY HOUSTON, TEXAS METAIAIE, LOUISIANA SANDY, UTAH NEEDHAM, MASSACHUSETTS MILWAUKEE, WISCONSIN MINNEAPOLIS, MINNESOTA RAWLINS, WYOMING ST. LOUIS, MISSOURI GREAT FALLS, MONTANA OMAHA, NEBRASKA LAS VEGAS, NEVADA MANCHESTER, NEW HAMPSHIRE CEDAR KNOLLS, NEW JERSEY RALEIGH, NORTH CAROLINA FARGO, NORTH DAKOTA * Th. N.lional Colklctlon AtlIOrn.y N.twork I. an lIffIllatlon of ..paratelaw firm.. W&A Hours of Operation: 8 a.m. -11 p.m. E.S.T. M.F I W&A File No. 122959777 Enclosed herein please find a 10-Day Notice pursuant to Rule 237,1 of the Pennsylvania Rules of Civil Procedure. Enclosure CC: DONNA M ENSOR Sincerely, ~0 Amy F. oyle #87062 Daniel F. Wolfs #20617 Bruce H. Cherki #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff This is an attempt by a debt collector to collect a debt and any information obtained wi II be used for that purpose. Non ODIP ANOTC LTFlHD1(Ol/11105} ,,-, l'..;. ~ '.._J ~ C) Cl -n ~T! -... fll,-"c- , -'-/:-n '!( ~ ~~., ~_J N ~. ) ",'-1 ;':.J .-< 132 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 NO. 05162CIVILTERM Plaintiff vs. DONNA M ENSOR Defendant (s) TO: DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 DATE OF NOTICE: 02/24/05 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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. IF 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. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle 800-990-9108 PA 17013 By: e LJ Amy F. Doyle #87062 Daniel F. Wolfso #20617 Bruce H. Cherkis #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff IMPNOT/PANOTC W&A FILE NO. 122959777 ....' ~g <.:;....J.l o --n C) t) ~-i -J -:1 -\-" 1;;) ", r....:' ............ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 No. 05162CIVILTERM : : Plaintiff ,--- vs. CIVIL ACTION - LAW DONNA M ENSOR Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ C..um8CvtJ..AND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, DONNA M ENSOR , above-named, is over 21 years of age; is last known to reside at 1024 TEAKWOOD LN ENOLA PA 17025-2046 County of CUMBERLAND . Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dine A. Sweitzer, Notary Public Hampden Twp., Cumberland County My Commission Expires Apr. 16, 2008 Amy . Doyle ~8 062 Daniel F. Wo fson #20617 Bruce H. Che kis #18837 Philip C. Warho1ic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff 4 day of . 20D'5'". SWORN and SUBSCRIBED to before me this PNMAFF/pANO_T W&A FTJ.F. NO _ 122Q.~Q777 i~ (.," .._) 'c.:;.., ."''') ul r::> (") --I r) "n .-1 M~ -co r:--? N r'" ;~ :.<. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 No. 05162CIVILTERM . . Plaintiff : vs. CIVIL ACTION - LAW DONNA II. ENSOR Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 and certify that the last known address of the within Defendant(s) is: DONNA II. ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 Amy F. oyle #87062 Daniel F. Wol on #20617 Bruce H. Cher is #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff PCRES/PANOJ W&A FILE NO. 122959777 , .....-- f' C"} ;"'-f1 .-4 ~(:' .....- _~i _'0 I') <,' r...;. - 2655 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD NO. 05l62CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DONNA M ENSOR Defendant (s) NOTICE OF JUDGMENT ( x) Notice is hereby given that a in the above-captioned matter has be~n entered against you in the amount of $ 6201.50, plus interest, on (p,,-*-, /7 ' 20&. ( x) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. "O,"(J~= By: If you have any questions regarding this Notice, please contact the filing party. Amy F. 87062 Daniel F. Wolf on #20617 Bruce H. Cherk s #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 STNTC/PANOJ W&A FILE NO. 122959777 ~R f~ ...., C:::J 0 c-:::: ~.., "Tl r- --4 c:~ -,- T (';1 r) -- ~ (". '" .....J ~ --- -.t) " ~\ <.h, ~ ;: ~, ~ ';<'\ ~ r..,) - ~ ~ ., l~.....) ~ (f ~ \ ---.. -<::> I q 171 ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND MBNA AMERICA BANK, N.A. Plaintiff vs. DONNA M ENSOR Defendant (s) COUNTY, PENNSYLVANIA : No. 05162CIVILTERM : CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT To the Protonotary: Please mark the judgment in the above-entitled cause as paid and satisfied. Respectfully Submitted, By: m ~ 6~ Date: David R. G 1 owa 8 Philip C. Warholic ~~86341 an r.. nnasz jre`v~69/Robert N. Polas, Jr. ~~201259 Amy F. Doyle ~~87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PRAECV/PA176A FILE ~~ 122959777 181 M IN THE COURT OF COMMON PLEAS OF CUMBERLAND MBNA AMERICA BANK, N.A. Plaintiff vs. DONNA M ENSOR Defendant (s) COUNTY, PENNSYLVANIA : No. 05162CIVILTERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE DONNA M ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 David R. Ga1~oFlay ~~8T3~ilip C. Warholic ~~86341 Sarah E. Ehas2 86469/Robert N. Polas, Jr. ~~201259 Amy F. Doyle ~~87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 The undersigned does hereby certify that a true and correct copy of the Praecipe was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on PACERP/PA176A FILE ~~ 122959777 11L~t ,.,.j l~..r~~~!= v F_,a C..1i:9;:'.~- ~$ . 00 ~U AT't`~ ~^~' ~ 00"11 D (~` a.3oo80 ./~~`..- r~. ..--- . y ,, ~~ ~~