HomeMy WebLinkAbout05-2017
22288
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLV IA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
:
NO. OS - JOl1 (!wL
9Li
VS.
CIVIL ACTION - LAW
JEFFREY K SMOLIZER
44 BUTTONWOOD LN
CARLISLE PA 17013
Defendant (s)
NOTICE
You have been sued in Court. If you wish to defend against the claims set
the following pages, you must take action within (20) days after this Compl
Notice are served, by entering a written appearance personally or by an att
and filing in writing with the Court your defenses or objections to the cIa
forth against you. You are warned that if you fail to do so, the case may
without you and a judgment may be entered against you by the Court without
notice for any money claimed or any other claim or relief requested by the
You may lose money or property rights important to you.
orth in
int and
rney
ms set
roceed
urther
laint iff.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OU
YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIN
YER. OR
WHERE
A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE Y
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSON
REDUCED FEE OR NO FEE.
U WITH
AT A
NOTICIA
Le han demandado a used en la corte. Si used quarere defensas de esas dema as
expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo 1 partir
de la fecha de lademanda y la notifiation. Used debe presentar una aparien ia
escrita 0 en persona 0 por abogado y archivar en 1a corte en forma escrita s s
defensas 0 5US objeciones a last demandas en corta de Sll persona. Sea avis 0 que
51 used no se defienda, 1a corte tomara medidas y psedido entrar una orden c ntra
used sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es p dido
en la peticion de demanda. Used puede perder dinero 0 sus prop1edades 0 otr s
dereches importantes para used.
LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI N
EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELE
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
CONSEGUIR ASSITANCIA LEGAL.
TIENE
ONO A
PUEDE
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle
800-990-9108
PA 17013
CVRNOT/PARET
W&A FILE NO. 130463211
22291
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLV
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
NO. DS - .J.ot7
VS.
CIVIL ACTION - LAW
JEFFREY K SMOLIZER
44 BUTTONWOOD LN
CARLISLE PA 17013
Defendant(s)
COMPLAINT
Now comes the Plaintiff, GREAT SENECA FINANCIAL CORP., ,by and thro gh its
attorneys, and the law firm of Wo1poff & Abramson, L.L.P., and files this C mp1aint
and in support avers as follows:
1. Plaintiff, GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
is a business entity doing business within the Commonwealth of Pennsylvania
other states of the United States.
2. Defendant, JEFFREY K SMOLIZER
a last known address of
, 15 an adult individu
with
44 BUTTONWOOD LN
CARLISLE PA 17013
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 h reto,
incorporated herein and marked as Exhibit "A".
4. At all relevant times material hereto, Defendant(s) has/have used aid
charge card for the purchase of products, goods and/or for obtaining service
CCPWRI/PARET
W&A FILE NO. 130463211
22296
5. Plaintiff provided Defendant(s) with copies of the Statements of ccount
showing all debits and credits for transactions on the aforementioned credit card
account to which there was no bona fide objection by Defendant(s). A true nd
correct copy of the Statement of Account is attached hereto, incorporated rein,
and marked as Exhibit "B".
6. As of the date of this Complaint, the rema,n,ng
unpaid on Defendant's credit card account as a result of
Defendant(s) and/or any authorized users is the sum of $
balance due, owin
the charges made b
7878.29.
and
said
7. Pursuant to the Credit Agreement and/or applicable Pennsylvania 1 w, any
unpaid or delinquent balances on said account shall continue to bear intere t at the
rate of 18.00%. See Exhibit "A" as previously identified herein.
8. As of the date of the filing of this Complaint, the amount of int rest
which has accrued is the sum of $ 473.99.
9. As of the filing of this Complaint, Plaintiff has incurred reason ble
attorney's fees from the law office of Wolpoff & Abramson, L.L.P. in the co lection
of the amounts due from Defendant(s) incident to the within action based up n 20% of
the principal amount due and owing, and Plaintiff shall continue to incur s ch
attorney's fees through the conclusion of the proceedings.
10. The amount of attorney's fee which has accrued is the sum of $ 1 75.65.
11. Despite reasonable and repeated demands for payment, Defendant(s) has/have
refused and continue to refuse to pay all sums due and owing on the aforeme tioned
account balance, all to the damage and detriment of the Plaintiff.
12. The amount in controversy is within the jurisdictional amount req iring
compulsory arbitration.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter udgment
in favor of the Plaintiff and against Defendant(s) in the amount of $ 7878.29,
plus attorneys fees in the amount of $ 1575.65, plus interest in the amou t of
$ 473.99, plus costs of this action and any other relief as this Court de s just
and reasonable.
Respectfully submitted,
Amy . Doyle 1187062
Daniel F. Wo f 1120617
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 Co lection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintiff
CPWRI2/PARET
W&A FILE NO. 130463211
~~~yy
ATTORNEY VERIFICATION
I hereby state that I am the attorney for the Plaintiff, who is locat d
outside of this jurisdiction and in order to file the within document in a
expedient and timely manner, am authorized to take this verification on be of
said Plaintiff in this action and verify that the statements made in the f
Complaint are true and correct to the best of my knowledge, information, a
belief, based upon information provided by the Plaintiff.
The undersigned understands that false statements herein are made subject to
the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsificatio
to authorities.
Date:
Amy F. Doyle #87062
Daniel F. Wolfs #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 C llection
267 East Market St., York, PA 17403
(717) 846-1252
Counsel for Plaintiff
PAVERF/PARET
W&A FILE NO. 130463211
222812
EXHIBIT "A"
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FinancIaL
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2058
PROVIDIAN NAT\0I1AL BANK VISA' AND MASTERCARD' ACCOUNT AGREEMENT
Please review this docume/ll and keeo it with your other imoorram papers. This Account Aqreement contains the terms that govern your Providian Nationa
A.CCQUllf (the ".o..ccount"). 'ill\! Account allows you to make purcnases cy using your VISA or MasterCarD creait caro (the ~Cann wherever It is honoree and to
or any otJier ~articlpanng financial institutIon and from Automated Teller Macnines. C(lnvenience cnecks may also lie provided to '{OU as an aooitional way
Agreement. "you" and ~your" mean eaen Qerson tor whom we have opened a creait earO. Account "'We," "\lU,," u(lUrs.~ :ana "us" mean Promian NatinnaS Ban
on your billing statement. The Account may be used only for personaL family, houseilOld. and charitable aurposes. aM not lor any business or commerci
Account shall constitute acceptance oj the terms at this Agreement You ane! we agree as tallows:
?aymenb. 'fau will receive a monthly statement showing your outstanding balance. Payment on this Account is required in U.S. dollm (checks must be Oil ole at a U.S. cffice of the
tank Ihe cneck is drawn on) lor at least tM payme~t due as shown on your srnlement by the payment aue Oate in accordance with payment instruC"Jons on y ur monthly s-..arement. The
baCk at your monthly statement incluaes the rutes we iaUolN wnell 'Ne \lOS1 paymentS to your Account Convenience cl1eckS and other checkS we may issue to y may not be used to make
payments on your Account or to make oayments on any other account you nave With us or our affiliates. The payment due will be: 3% of the new balance shown n your statement PIUS the
amount of any past due payment, ana may include the amount by whicil the new balance exC8lll1s your credit line. However, the payment due will nOt be less :s.15 (urness your m!'N
halallce is less tnan $,15, in which case the payment due will be the amount 01 tne new oalance). Jt your Account is past due or above tne credit line. we ma reQuire a. hiqher minimum
payment. but we will notify you before doing so. It your oayment.is more tnan the payment due, it will be treateti as a single payment and none 01 it will be aopl d to future paymentS due.
We may accept late or partial payments. or payments marked ~pald III fuJl~ or marked with other restrictions, without laSing our ngm: to collect 311 amcul\ts OWl under this Agreement
Ananee Charges. Finance chirqes begin to accrue on a debit wi1en it is included in one at your daily Ilalances and continue to accrue until tnat balance is ret1u d by a ~ayment or credit
Your Account has two daily balances: the Purchase Balance which consists of purcilases you make with your Card and fees, attlef man ca.st\ aawnce tran .on 1ees. Charged ro your
Accoum, including fees tor optional services: and the Ca~n Arlv;;nce Balance wnien consists of all casil advances and cash alfVance transaction tess. Any paym nr amount we receive that
exceeds the iinance cnarqes and fees then due will orainarily be appiled first to the Balal1te with the lOwer ANNUAL PEBCENTAGE RATE (APR) until that a is zero, and then to tile
remaining aalance. We reserve the rigi'lt to apply payments differently w1tMut lurttler ootice. The Purchase- allo Casn Advance Salances are reduceD by paym ts as at the date receivea,
and by credits as ot the date oosteO. Purcllases are induded in your Purt:!lase Balance as of tile date made. Fees are included in your Purdlase Balance as 0 the transaction Qate. Cash
advances are incluaed in your Gash Advance Balance as follows: cash aovances from other financial institUtions and through Automated Tellef Machines at the date made; funds
electronically trans({utteo, 3S af the date tranSmittea: cash adYolJ\ce chec~ matie payable to you that are idetttified as cashier's checks, wl1ich we may mail 10 au at your request. as of
seven days after the date we print on the check; all mller checks, inCluding any convenience cI1eckS, as of the date presented to us. Cash advance transaction f S are inc1uded in the Cash
Advance Balance as of tne transaction date. ather oeMs are included in your Purchase or Cash Advance Balance as at the oate posted. Finance charges are a ed to your PurcN.se aM
Casn Aavance Balancl!.S each day anti are then posted on the last day of the billing c,/cle. There Is no period within whiCh credit extended may be repaid without i urring a finance Charge.
To figure tne daiiy finance charqe for purchases and the daily finance charge for casil .atIvances. we .start with your prev.iQUS day's Pun:hase 8a!ance and Cas Advance Balance, add all
debits and subtract ail credits. far tl\e current Ga.,! to the applicable Balance (as explained in the paragraoh above), and multiply the net amount by the appJica Ie daily peliOdic rate (see
follOWing paragraons). The finance charge for purchases is then added to and induded in that day's Purcnase Balance, ana the finance chall}8 tor casl1 ces is then added 10 and
inc/uderl in that day's Cash Advance Balance. We treat a credit balance for any day as zero. We detennine the total finance charges on your 8aIances lor the biUi cycte bY adding togtther
tne {inane! chaf98 tor P'Urchases tor eacn day within Ihe billing cycle and the finance cIlanJe for cash advances tor eacn day wlttlin the billi~pcle. In cal ling finance charges, an
adjuSUnent will be made for any transaction or payment that would have affected the finance charge calculation in a prior billing cycle had it been posted in tna e. TIte applicable daily
periodic rate for such a tratlsaction will be the rate in effect for the current billinQ cycle: rathertnan the rate in eCfect an the datA of1ht trans~n.
The term "Prime Rate- as used in this Agreement means the prime rate published in nit: ~JI SlTeer Journal an the first business day at the previoUs ca(end month. Any increase or
decrease in tns APF' will talI:e effect on the first day of your billing cycle and may result in a slight increase or decrease In the amount at yaW'" mtnimum payment
The ANNUAL PERCENTAGE RATE for purchases will vary and may be adjusted each billing cycle up to 10.99% above Prime Rate. Using tnls tormula, the PR for pUrchases in tne
April 2.000 billing cycle is 19.99o/a, corresponding to a daily periodic rate of 0.05.48%, and your APR for purchases will not go t1ek)w 19.99%.
Tne ANNUAL PERCENTAGE RATE for cash advances will vary and may be adjusted eacn billing cycle up: to 12.99% above Prime RaW. Using this fonnula, the AP for cash advances In the
April 2000 billing: cycle is 21.99%, co.rresponding to a daily periodic raU! of 0.06020/0, and your APR fof cash alivances will not go belOW 21.99%.
To oet!rmine ttre aYeT3Q8 daiiy balance snown on your statement for purcl'lases, add each oay's Purchase Ba1ance (Including daily finance charQe) in the bUr eye!! and divide by the
number ot days in the billing cycle. To det!rmine the average daily oaJance sl10wn on your statement for cash advances, add eactt day's Casn Advance Balan (including daily finance
cnargej in the billing cyele and divide by the number ot days in the billing cyde.. You can muttq)Iy w:h Gt these awraQe daily balances by the number of dayS in e billing cycle and by me
applicaole daily penodic r.rte to ootain SUbtotals, and then add the two subtotWi togetner to determine the total amount at 1inance charges on your balances for he billing cycle. 11 a cash
attvance transactfon tee, credit line increase lee. or Express Card processing fee is chatqed (see Fees section), tnose amounts ani a!SO FINANCE CHARGES.
Fus. A membership 188: of 'S7.95 will he chaIVed to your Account each month. If you request and we issue an additional Card on your Account tor an authOrized r, a fee of $20 for each
aOditionaf Card will be charged to your Account This fee will be charved to your Account when the additional Card is issued and Mry 12 months thereafter for long as each aadltlonal
Card is outstanding. If you request and use our Express Card Service, a one-lime tee of S19.95. wllici\ is a AMANtE CHARGE. will be chargeQ ttl your In some cases, express
processing may not be available. We may charge your Account $2.9 for: each Card you ask US to replace: eacn returned payment each cneck you write on yo r Account that we return
unpaid; aath stop payment order or renewal of such an order: each billing cycle within which your Account is delinquent (late charge): and each billing cycle itrIin which your balance
exceeds your credit line even it your Account i$. closed. !f ';'OU reQuest copies 01 billing statements that were first sent to you more than two montns earlier, we d\atge a handling tee of
S2 for each slJCl1 COIJY. A cash advant! fee at 3.,.. (minimum $5), which is a FINANCE CHARGE. may be charged for each cash acrvance transaction made on you ount For some credit
line I.ncreases, you may be charged a tee, which is a fiNANCE CHARGE, the amount af which will be disclosed to you before you accept tne line increase atter. If u request that. !Nt make
a ooe-ttme automatic Pl'fmeflt from your personal cnecking account. we may charge your Account a fee at $4.95 tor each request This tee is a fiNANCE RGE. and It will apply
'Nileti'Ier17l'-notfurrds-m4Vlrit!bte In-ytnlTllmtlnal Checidng accoum to make file .oayment.
Defallt. You will be in default if arty in1annatian ycJu \1nMded \IS pl'\MS to be- incomp\ete or untrue; it you eo not comply will'l any part of tnis Agreement; upon
insolvency; it you do not pay other debts wilen due; it a bankruptcy petition is filed by or against you; or if we believe in good faith tI1at you may nat payor perla
Ulis Agreement It you are in default, we may. without further demand or nance, cancei your credit privileges, declare your Account balance immediatelY due
remeciy we may tw4e. In the !'IIent 01 your de1iUlt the outstanding halance on your Account will continU8 to accrue interest at the APR(s) disclosed in the Finan
Agreement. even it we have fi&ed suit to cojlect the amount you owe..
Credit Line. Your credit. line and. cash. adVance line are disc\nsed 'Hhen you tlpen your Account and on your statement each mOnth. Your casn adVanCe line is ti itecl to a portion of your
credit line. We may increase or decrease your' credit line antVor your cash advance line based on infonnation we obtained from you or your credit records. Your available credit for
~ is nonnatly the difference between your credit tine and your Account ~a1ance (includinQ: transactions made or authorized: but not yet !lasted). y, ur allailat1le credit for a
C'Mh iKivana \s mmnally t\'lt difference between your cash advance line and your cash Advance Balance ortnl difference between your credit line and, your At:J:. nt balance, whichever is
lesS. If you send usa large payment we may limit your available creditwnile we confirm that the check will c!aar. For certain tIiInsactions, available credit may be I . You will not use your
Account for, and we may refuse to honor, any transaction that would causa you to axceed your avaiatlle emit Of'1our a'Jailab\l creait for cash advances. '(our It line may be reduced it
you attempt to go over your cash advance credit line.
Promis:e to Pay. You promise to pay us when due aU amounts borrowed when you or someone else uses your AccoUnt (!lMn If ttt.e amount charged exceeds y r \ltrmission). a" ~t!'ler
transactions and ctl1rges to your Account and all collection costs we incur including, but not limited to, reasonaOle attorney's fees and court costs. (tf you win e suit. we will pay your
reasonable attorney's fees and court costS.)
Changes. After we provide 'fOu any BOtiC8 reQuireD by law. we may change any parr at this Agreement and add or remove any terms, conditions. or reQuirern
the Firrance Charges section of this Agreement tne new iinance Ci1a~e calculation will apply to your entire Account balanca from me effective date at the c
balarlces mat inc/rme itl'!rm oosrl!d to Vtlur Ar.r:ount bl'!tnre tl'll! d:;Ie of till'! ch:moe and will applY wrtetner or nor you continue to USll tM Account.
Foraiqn EJchange/Cumncy Conve:l'!ian. If you use your Carli tor transactions in a currency onr than U.S. dollars. tile transactions will be converted to U.S. doUa . generally using either
a (i) govemmllflt.mamiated rate or (ii) whOlesale market rate in effect tlUl day oetoll! the transaCtion is processea, increased Oy 3%. If a credit is suosequentfy give tor a transaction, it will
be decreased by tt\e same per::entaqt. The currency conversion rate used on the conversion dm may Cliffer trom the rate in effect on the date :IOU used your Card You agree to iiCC80t tOe
convened amount i(l U.S. dollars.
The Can!: Cancellation. You may cancel your credit pOlJiteqes at a.ny time ~ notll'jing us in writing and destroYing me CardlS). Ullon the Card exlliration -at the en at the month shown _on
it, we reserve the riqht not 10 renew the Card. We may cancel the Card and your credit privileges at any time aTter 30 days notice to you, or wittlout notice if permitt by law. II your Cata _is
ciincelled or not renewed, finance ctlarges and other fees will continue to be assessed. payments will continue to 011 due. and all orner applicable provisions of tnis reement WllIll!milln In
effect It you terminate !Jour cretlit prMleges, or \f we cancel or 00 nol renew rtle Card: you may no longer write checkS on your Account and yoll shOuld <iestro. any unusea cnecKS WI!
may nave ISSued to you.
Bank VISA Qt MasU.rC<1fO
et casn aC'Jances from us
use tl1eAccount.ln this
or its assignees, as listed
purpose. An'( use of ihis
urd!ath,lJanla'Uptcy, or
your oblig;ltiOns under
Qayatlle, and use any
Chargn section of ttlis
.Ifa change lsmade to
. Changes willapp{y to
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iConrlnueo on re'l/JlSeJ
06019
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Personallnlonnatlon: Documents. You will provide us at least 10 dayS norice if you chAnge your name. home or mailing aadress. telephone numbers, employment. or
you will provide us additional financial information. We reserve the right to obtain informatton from \lttlers. incIIJdinc} credit reparnno agencies, and 1Q proviQe your add
your Account to others. m h' ,. r in' w t ... .
do not fulfill your obligations under this Agreement. a negative credit report that may reflect on your credit may be submitted to credit reportitlg agencies.
Cu$1.ome, Sem!:!; Unauthorized Use, Lou. or Theft of Checks or lh, Card. Each Card must be signed on receipt. You are responsible lor safeguarding the Card. your Personal
Identification Number (PIN), which provides access to Automated Teller Machines. and any checxs issued to you from theft, and for keeping your PIN separa trom your Card. If you
discover or suspect that the card, PIN, or arty unused checks. are lost or stolen. or that there may be an unauthorized transaction on your Account. you will pro ptly nOlify us by calling
1-800-211-5815. So we can immediately act to limit losses and liability, you will phone us evell though you may alSo notify us in writing. Your liability for u utnorized use occurring
before you notify us is limited to $50. 11 you report or we suspect unauthorized use 01 your Account, we may suspend your credit ~rtviteges until we reseNt the p \em to our satisfaction
or issue you a new Cant \1 your Card is lost or stolen, you will promptly destroy all checks that may be in your possession. To improve customer service and s rity, you agree that your
caUs may be monitored or recorded.
Merchant RelatlOM. We win not be nable if any pmon or Automated Teller Machine refuses to honor the Card or accept your checks. or fails to return the ani to you. We have no
responsibility for goods and services purchased with the Card or checks except as required by law. (See Special Rut! below.) Certain benefits that are availa Ie with ttle Account are
provided by third.parry vendors. We are not responsible for the quality. availability, or resutts. of any at the stMces you choose to use.
Slop Payment Orders. If you wish to stop payment on a check, you may send us a stop payment order by writing to us at our address tor Customer Service list on your statement You
can make a stop payment oroer orally by calling the number listed on your statement When you make a stoll payment omer. 'J1Ju must proWje your A nt number and speclflc
imlJrrnatioo about the cheex: the exact amount. the date on the check. the name at the party to whom it was payable. the name of the person who signed it and the check number.
You will be asked to confinn an oral stop payment order in writing.' 'f w ... . n i' w
~ or if we have not received an adeQuate description of the item so that payment can be s.topped. The orcIu d not be ettect:ive it the Check was paid by us be re we had a reasonable
opportUnity to act on [he order. We may, witl10ut liability, disregard a written stop payment onier Six months atter receipt unless it is renewed in writing. .
Standard 01 Cars. Because this Account involves a credit card and may Invotve ch.eck transactions "tt\at are '1mx;esseo through separate national systems be
consolidated by us. and because not every ct1eck and Card slip will be sent to us, transactions in your Account will be processed mechanically without our n
Our processing system will call our attention to certain items. whICh we will examine. We wiU examine all transactions when you report that your Card or any
stolen. We do not intend ordinarily to examine a<< items. and we will not be negliGent if we do not do so. This rute estabrlShes the standard 01 ordinary care
exercise in administering your Account Because 01 our limited review. and because neither your cancelled checks nor Card transaction sUps will be returned
statement, you should be careful to enter all checks in your check register or otherwise keep a record of them. You should also save your credit card cash adlla
anre@. to ched< 'l(l\Jr man1hN statements anainst vour !lM:nm and tn notitv us lmmRdiatetv of anv unauthorized tr:ln.o;actians or l!rTOI'5
Waiver 0' Certain Rights. We may delay or waive enforcement of arrt provision at this Agreement without losing our right to enforce it or any other provision late You waive: the li~ht tc
presentment, demand. protest. or nom of dishonor. any applicable statute of limitations; and any right you may have to require us to proceed against anyone tore we file suit aQaillSt
you.
Apptfubtl tOTW; 3t:v,uClblllb, ~iYlOllllnft. No matter whee! you live. this Aoreement and your Account are governed by fldemllaw and by New Hampshire law. is Agreement is a final
expression of the agreement between you and us and may not be contradicted by evidence 01 any alleged oral agreement If any provision of lf1is Agreement is held to be invalid or
unenforceable. you and we will consider that proviskJn modified to conform to applicable law. and the rest of the provisions in the Agreement will still be enfOn:e Ie. At any time aft!r we
detennine in good failh ttlat any proposed or enacted legislation, regulatOT)' action. or judicial decision has rendered or may render any materiaJ provisions of Agreement invalid or
unenfort:eable, or impose any increased tax. reporting requirement. or other bUrden in connection with any such provision or its enf0f'C8ment;J~!:lJIlIY, after at 30 days notice to you,
or without notice if permitted by law. cancel the Card.and your credit privHeoes. We may uansfBr or assign our right to all Qr some of your p,ayments. If statt laW uires that you receive
notice of such an went to prot8c\ the purchaser or assignee. we may give you such notice by filing a financing statement with the state's Secretaly of State,
HoUm. Other notices to you shan be effectfve when deposited in the mail addressedtoyouattheaddressshowninourrecords.unlessalongernoticep.ad. is spedfied in this
Agreement or by law. wttich period shall start upon mailing. Notice to us shan be maj)ed to our address for Customer Service on your statement (or other addre s we may specify) and
snail be effective whtn we receive it
YOUR BlUING RIGHTS - KEEP THIS NoncE FaR FUTURE USE. This oolite tootains important information abOut your rights and our responsibilities under the 'r Credit Billing Act.
NarJfy Us in (;am allrror$ ar QUIrt/Dill About Your 8111. II you think your bill is wrong. or if you need more information about any transaction on your bill, write us on a separate sheet. at
our address listed 'in the Billing Rights Summary on your biU, Write to us as. soon as \Klssible. We rnIJSt htartrom you no later than 60 dayS after we sent you 111 first biU orrwhlch the
error or problem appeared. You can telephone us, but doinQ so wil not pres8M your rights. In your litter, give us the following: Your name and Account number The dollar amount of
the suspected error - A description of !he error and an explanation, if possible. of why you believe there is an error. If you need more inlonnation, descrtbe the item u are not sure about.
YOUI Rlth#$ and Dur R,spoMibililJu AtW W, RtlUivr Your WrillBn Noll". We must acknowledge your 'IetIer within 30 days. unless we have corrected error by then. Within
90 dayS. we must eittler correct the error or explain why we believe the bill was correct After we receive your letter, we cannot try to collect any amount you Q 'on. or report you as
delinquent We can continue to bill you for the amount you questlOll. including finance charges., and we can appty any unpaKl amount against your cm:Ilt nne, You 0 not /lave to pay any
Questioned amount wtlile we 3l'8 investigating. but you are stitl obngated to pay the parts of your bill that are not In Question.
If we find thai we made a mistake on your bill, you. wi" not have 10 pay allY finance charge retated to any questioned amount. If we didn't makt a mistake, you
cl\aroeS. and you wi\I have to make up the missed paymentS on the Quest:fOned amount. In either case. we will send you a statement of the amount you owe and e date that it is due. It
you lail to pay the amount we think you owe, we may report you as delinquent However, if our explanation does not satisfy you and you write to us within 10 days telling us that you still
refuse to pay. we must tell anyone we report you to lt1at you Question your bin. And. we must tell yoo the name 01 anyone we I'Iportad you to. We must tell anyone f!port you to thai: the
matter I'las been settled between us when it finally is. If we don'11cHkJw trlese rules. we can't collect the first $50 at the questioned amount, even if your bin was co
Special Rula/Dr Crldlt Canl PurdllUS. If you have a problem with the Quality of the property or services that yuu puJd\ased with our Cftdit t:ard and you
camet the problem with the merchant, you may not have to pay the remaining amount due on the property Of servas. Then! are twIJ Jimitttions on Jnis.right {oil
purchaSe in your home state, or 11 not within your home state, within 100 miles 01 your current maiung address: and (b) the purchase price must have been
limitations do dOt apu/y it we own 1)f opmhl the mert:hant, or il we mailed you tt\e advertisement tar the propelt)' or services,
REWARDS PllDGRAM - The Iullawlng Tenns and CondlU""" along with II1e RedompUon Rules dlsdosed In II1e Rewards Brochun! I"-j, apply to lI1e R....nls
Eligibility. Participation In thQ Program is remitted to indMtluals woo maintain a Providian VISA or Mastel'Ca.n:l credlt: card account ("Accounr) in good standin
to approve, deny, or revoke membership or not allow redemption at Rewards. as defined below. to any indMdual for any reason whatsOeVer.
Earning 01 Paints. During the first 12 months your Account Is open. you will earn 2 points rpoints.1 tor ead\ $1 m Net Purtnasa.Thereafttr, at the end of each
you ",ill earn 1 Point tor each $1 at Net Purchases. "Net Purchases- means purchases of goodS or services made by you or any authorized user of the ACCOunt,
refunds, and excluding balanCe transfers, cash advances, ItaYeler's checks. and access checks. Paints do not accrue for interest chal'9es or fees a. any kind, such
annual fees, overllmit fees. and unauthorizeG charges. Changes made to trle above fist are at our sole distl'6Uan. Point accrual wm begin upon your Enronment Oa
retroactive Points will be awarded. The Enrollment Date means the date we approve you as a Program member, Points may only be earned if your Account is open
above the credit line. When your Account is current and is within lIS credit line, you will begin to earn Points again. There is no limit on the number 01 Palms that
do not have a cash valUe. cannot be purcnased or exchanQed fQl casn.. and cannot under afl't circumstance be redeemed tor casl'1 or used as a payment for
obligations to us.
Slatement 01 PolnlS. Program Paints are updated monthly at the time of your Account blUing statement Points earned. dUMg the: month win tie pas1ed at your bill' statement date and
art not available ter redemptiOn until at Ieas1 two business days after your billing statement date.
expiration 01 Polna. Points wiD expire five years after being awarded. Points redeemed and expired will be based on a Ilrst-earnecl. flrst.spent basis.
R~ oa fQia&s. Polati ~ be redeemed fer products or services ('"Rewards-), which are set forth In a Brochure mailed to you from time to time. Points ma
your Account is open and is not past due or above the credit line, All Rewards are SUbject to availability. We reserve ti1e right to modify or cancel any Reward at
are redeemed for a Reward. the number of Points required for the Reward will be subtracted trom your Point balanca. You win contact ttIe parties liSt6tl in the Bro
on how to redt6m your Points.
Tal Ua.lllty ami Fees. You will be responsible for any fed!ral. state. or local taxes due arising out at the accrual of Points or redemption of lt1e Rewards. You will a 0 be responsible far
any tees or other charou due in connection witt1 the redemption m any RNanl.
Chango to Ih. Program. The Program and the benefits an! offered at our sole discretion. We reserve !he right to alter or chanoe any Program feature or be fit, prospectively or
retroactively. inCluding. without limitation, Point accrual or redemption criteria. and to cancel Qr temporartly SUSl18nd rtw Program at any time without notice, In event you commit
any fraud Gr abuse your privileges relating to tlte accrual 01 Points or redemption of Rewards. we reserve the right to cancel any accrued Paints as well as ca I your Account and
participation in the Program. 11 we cancel the Program. we will nonnally provide alleast 30 days written notice 10 you at the address provided to us. However, if yQU alate any proViSIon
01 these Terms and Conditions. you are in default under your Account. or your Account is clased. we may cancel the Program without providing you 30 eays wrine notice ana you will
torltit aflY unused Points. 'tou may cancel your participation at any time. The Program is void where prol1ibited bY federal. state, or local/aw.
Aewards. Maritz Inc. and SRI provide administrative services for redemption ot tile Rewards. Maritz Inc. and SAI are independent contractors and are not attiliated
Maritz Inc.. nor BR/ shall be liable lor l10dily !\arm and/or properlY rlamaQ8 that may result from panlcipating in the Program, nor for the redemption ot Rewards al'l
the .event anV. Rewam that is redeemed is modified. detective. or otherwise unsaliSfactory to you, you will look solely co Ine merchant ar manufacrurer 01 the Rew
any rep<ilr. refund, or satistaction of your claim. We are not responSible for any lost, stolen. descroyed. or expired Rewards.
come. Upon our request
aM information about
. . If you
re the transactlOI'lS are
"Iy reviewing every item.
ecks ha\'e been lost or
at we in good faith will
you with the monthly
and pul'thase slips.. Yml;
tJied in good taittI to
must have made the
ore than $SO. These
onthly bimllQ cycle,
inus any returns or
fate payment tees.
in the Program. No
d is not past due or
be aamed, Paints
ur Account or other
only De redeemed if
time. When Points
uretorinstnJctlons
it" us. Neittlervre,
use at Rewards. In
d and nOI CO us lor
222815
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02017 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREAT SENECA FINANCIAL CORP
VS
SMOLIZER JEFFREY K
CHIEF DEPUTY RONNY ANDERSON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according 0 law,
says, the within COMPLAINT & NOTICE
SMOLIZER JEFFREY K
DEFENDANT
was served upon
th
at 1145:00 HOURS, on the 22nd day of April
, 2005
at CUMBERLAND CO SHERIFF'S OFFICE ONE COUSTHOUSE SQUARE
CARLISLE, PA 17013
JEFFREY K SMOLIZER
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents t ereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
18.00
.00
.37
10.00
.00
28.37
So Answers:
... /'") --r/
::~"t.- ,'':,~:(::-,_~",!,,_:
O(:~ .~~
-";,.-
R. Thomas Kline
04/22/2005
WOLPOFF & ABRAMSON
Sworn and Subscribed to before By:
me this d< -- day of ~
~<D o'J----- A.D.
. 112." .~
r pro~ '~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
NO. 052017CIVILTERM
Vs.
JEFFREY K SMOLIZER
Defendant (s)
PRAECIPE FOR JUDGMENT
Mr. /Ms. Clerk:
Please enter Judgment in favor of Plaintiff and against Defendant(s),
JEFFREY K SMOLIZER and
for want of ANSWER TO COMPLAINT.
( X )
Amount due $
Interest $
Attorney's Commission $
Filing costs $
TOTAL $ 9927.93, 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.
7878.29
473.99
1575.65
and costs
is for specified
a sum certain from
L, 20Q,L,
Amy F. Doyl e 11870
Daniel F. Wolfs #20617
Bruce H. Cherki #18837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
JUDGMENT IS EN ERED AS
DATE:
~/),Io(
I I
Signature:
NOW,
n
)~-t
Division
Protho
By:
Deputy
PRAECJ/PANOJ
W&A FILE NO. 130463211
MAIN OFFICE
TWO IRVINGTON CENTRE
7C2 KING FARM BLVD., ROCKVllLE, MD 208!50
REGIONAL OFFICES
10605 JUDICIAL DR., BLDG. A-5, FAIRFAX, VA 22030
1108 E. MAIN 51.. 5TE. 1003. RICHMOND. VA 23216
5122 GREENWICH AD" VIRGINIA BEACH. VA 234(52
919 N. MARKET ST.. STE. 1300, WILMINGTON, DE 19899
1 VALLEY BANK BLDG. BOX 1226, CLARKSBURG, WV 2e302
2625 TOWNSGI\TE RD 1t330, WESTLAKE VILLAGE, CA 91361
267 E. MARKET ST., YORK, PA 17403
39500 HIGH POINTE BLVD.. STE 250, NOVI, MI48375
300 CANAL VIEW BLVD., ROCHESTER, NY 14623
758 NORTH CARROLL AVE" SOUTHLAKE, 1)( 76092
NATIONAL COLLECTION ATTORNEY NETWORK
AFFILIATED FIRM LOCATIONS {NOT REGIONAL
OFFICES OF WOLPOFF & ABRAMSON, l,L.P.] "
BIRMINGHAM. ALA8AMA PHOENIX, ARIZONA
ANCHORAGE, ALASKA CABOT, ARKANSAS
130463211
JEFFREY K SMOLlZER
44 BUTTONWOOD LN
CARLISLE PA 17013
LAW OFFICES
W 0 L P 0 F F 8< 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 17400-2000
717.848-6200
OUTSIDE YORK METRO POUT AN AREA
(TOLL FREE)
1-800-758-0675
FACSIMilE (717) 848-1146
PLEASE DIRECT ALL INQUIRIES TO YORK OFFICE
MAY 1<.. 2005
NATIONAL COLLECTION ATTORNEY NETWORK
AFAllATEO FIRM lOCATIONS tHOT REGIONAL
OFFICES OF WOlPOFF & ABRAMSON, l,L.P,] *
ENGLEWOOD, COLORADO RALEIGH, NORTH CAROllNP
FT. LAUDERDALE, flORIDA FARGO. NORTH DAKOTA
NORCROSS. GEORGIA CLEVELAND, OHIO
HONOLULU, HAWAII OKLAHOMA CITY, OKLAHOM
BOISE. IDAHO EUGENE, OREGON
MERRIllVlllE, INDIANA PROVIDENCE, RHODE ISLA"
CHICAGO, ILLINOIS COLUMBIA, SOUTH CAROll"
KANSAS CITY, KANSAS KNOXVillE, TENNESSEE
lEXINGTON, KENTUCKY SANDY. UTAH
METAIRIE, lOUISIANA MILWAUKEE, WISCONSIN
NEEDHAM, MASSACHUSETTS RAWLINS. WYOMING
MINNEAPOLIS, MINNESOTA
ST. lOUIS, MISSOURI * The National Collection
GREAT FALLS, MONTANA Attorney Network I. en
OMAHA, NEBRASKA .
LAS VEGI\S, NEVADA affiliation of Mpell'lI""W flrrr
MANCHESTER. NEW HAMPSHIRE WaA Hours of Op8fation:
CEDAR KNOLLS, NEW JERSEY a a.m. -11 p.m. E.S.T. M-F
I W&A File No. 130463211
Re: GREAT SENECA FINANCIAL CORP.,ASSIGNEE OF PROVIDIAN FINANCIAL
vs. JEFFREY K SMOLlZER
Docket No. 052017CIVIL TERM
Dear JEFFREY K SMOLlZER
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the
Pennsylvania Rules of Civil Procedure.
COpy
---
Enclosure
CC: JEFFREY K SMOLIZER
Sincerely,
(
Amy . D #87062
Daniel F. fson #20617
Bruce H. lZherkis #18837
Philip C.iWarholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spear.. #87737
WOLPOFF & ABRAMSON, L.L.P. I Counsel for Pic
Attorneys in the Practice of Debt Collection
267 East Market St., York. PA 17403
(717) 846-1252
-"',-,..
This is an attempt by a debt collector to collect a debt and any information obtained
will be used for that purpose.
NOT 1 OD/P ANOTC
L TAHOl (OS1121O~)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
NO. 052017CIVILTERM
vs.
JEFFREY K SMOLIZER
Defendant (s)
TO: JEFFREY K SMOLIZER
44 BUTTONWOOD LN
CARLISLE PA 17013
DATE OF NOTICE:
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
""""""....v
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Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle
800-990-9108
PA 17013
By:
IMPNOT/PANOTC W&A FILE NO. 130463211
Amy F. Doyle 7062
Daniel F. Wol~son #20617
Bruce H. CherHis #18837
Philip C. Warho1ic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
No. 052017CIVILTERM
vs.
CIVIL ACTION - LAW
JEFFREY' K SMOLIZER
Defendant (s)
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I, hereby certify that the precise residence of Plaintiff is:
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
and certify that the last known address of the within Defendant(s) is:
JEFFREY K SMOLIZER
44 BUTTONWOOD LN
CARLISLE PA 17013
Amy F. Doyl e 1187062
Daniel F. Wolf on #20617
Bruce H. Cherk s 1118837
Philip C. Warho1ic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
PCRES/PANOJ
W&A FILE NO. 130463211
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROCKVILLE, Mil 20849-1651
Plaintiff
No. 052017CIVILTERM
vs.
CIVIL ACTION - LAW
JEFFREY K SMOLIZER
Defendant (s)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF YORK
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,
JEFFREY K SMOLIZER , above-named, is OVer 21 years of age; is last
known to reside at 44 BUTTONWOOD LN
CARLISLE PA 17013
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 #87062
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 #89451
Andrew C. Spears 1187737
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700() ,
aL day of _ oil fUS1 , 20.JJS:
SWORN and SUBSCRIBED to before me this
PNMAFF/PANOJ
W&A FILE NO. 130463211
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Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
NO. 052017CIVILTERM
Plaintiff
vs.
CIVIL ACTION - LAW
JEFFREY K SMOLIZER
Defendant (s)
NOTICE OF JUDGMENT
( x) Notice is hereby
ln the above-captioned matter has
$ 9927.93, plus interest, on
against you in the amount of
, 20~.
( x) A copy of all documents filed with the Prothonotary in support of the
within jUdgment is/are attached.
Prot
ision
By:
If you have any questions regarding this Notice, please contact the
filing party.
Amy F Doyle 1187062
Daniel F. Wol #20617
Bruce H. Cher is #18837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
(This Notice is given in accordance with Pa.R.C.p. 236.)
NOTICE SENT TO:
JEFFREY K SMOLIZER
44 BUTTONWOOD LN
CARLISLE PA 17013
STNTC/PANOJ
W&A FILE NO. 130463211
.
'"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION,
ASSIGNEE OF SHERMAN ACQUISITION
II LP, ASSIGNEE OF PROVIDIAN
FINANCIAL CORPORATION
P.O. BOX 1651
ROC((VILLE, MD 20849-1651
Plaintiff
No. Q52017CIVILTBRM
vs.
JEFFREY K SMOLIZBR
Defendant(sl
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY OF SArD COURT:
Please vacate the above captioned judgment entere~ on 09012005.
has been notified that the Defendant filed Chapter 07 ~ankruptcy.
The Plaintiff
--Jltlr-101!----
Respectfully submitted,
;;;-;:;;;~;;;;;;-;;;;;;;-;:-;;;;;;;--;
Philip C. Warholic #86341 I~drew C. Spears #J
David R. Galloway #87326 / Tonilyn M. Ch~pp1e *
Ronald M. Abramson #94266 I Ronald S. Canter #
Bruce H. Cherkis #18837
WOLPO', & ABRAMSqN, L.L.P. I Counsel for Plainti
Attorneys in the Practice of Debt Collection
4660 Trindle Roa<!, 3rd Floor, Camp Hill, PA 1701
(717) 303~67ao
Date:
PAVAC!PAVAC
W&A FILE NO. 130463211
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CERTIFICATE OF SERVICE
I, Kimberly L. Eisenhauer, an authorized agent of WOLPOFF & ABRAMSON,
LLP, hereby certify that a copy of the foregoing praecipe was served this date by
depositing same in the Post Office at Camp Hill, P A, firs~ class mail, postage prepaid,
addressed as follows:
Sean Patrick Quinlan
Quinlan Law Office
3344 Trindle Rd
Camp Hill, PA 17011
WOLPOFF & I\BRAMSON, LLP
By
4660 Trindle Rd., 3rd Fl.
Camp Hill, fA 17011
(717) 303-6700
Dated: +, 1=\ DI.J,