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Home My WebLink About05-2019 IN THE COURT OF COMMON PLEAS OF CUM&ERLAND COUNTY, PENNSYLV IA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 NO. DS - ;}6t? Clu~L Plaintiff VS. CIVIL ACTION - LAW DAVID STRONG 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 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 clai forth against you. You are warned that if you fail to do so, the case may p without you and a judgment may be entered against you by the Court without f notice for any money claimed or any other claim or relief requested by the P You may lose money or property rights important to you. tL"'1 orth in int and ney s set oceed rther aintiff. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW ER, 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 YO INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS REDUCED FEE OR NO FEE. NOTICIA Le han demandado a used en la corte. Si used quarere defensas de esas demand expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al de la fecha de lademanda y la notifiation. Used debe presentar una aparienci escrita 0 en persona 0 por abogado y archivar en 1a corte en forma escrita su defensas 0 sus objeciones a last demandas en corta de su persona. Sea avisad 5i used no se defienda, 1a corte tomara medidas y psedido entrar una orden co used sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es pe en la peticion de demanda. Used puede perder dinero 0 sus propledades 0 otro derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEF LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P CONSEGUIR ASSITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carl isle 800-990-9108 PA 17013 CVRNOT/PARET W&A FILE NO. 125503263 WITH T A s partir que tra ido IENE o A EDE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 NO. ()~ - ~619 C'u~L~ l Plaintiff VS. CIVIL ACTION - LAW DAVID STRONG 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 Defendant (s) COMPLAINT Now comes the Plaintiff, PALISADES COLLECTION LLC , by and thro gh its attorneys, and the law firm of Wolpoff & Abramson, L.L.P., and files this C mplaint and in support avers as follows: 1. Plaintiff, PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 is a business entity doing business within the Commonwealth of Pennsylvania nd the other states of the United States. 2. Defendant, DAVID STRONG a last known address of , is an adult individua with 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 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 he eto, incorporated herein and marked as Exhibit "Alt. 4. At all relevant times material hereto, Defendant(s) has/have used s id charge card for the purchase of products, goods and/or for obtaining services CCPWRI/PARET W&A FILE NO. 125503263 ~....L.O.J~ 5. Plaintiff provided Defendant(s) with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned cred't card account to which there was no bona fide objection by Defendant(s). A true and correct copy of the Statement of Account is attached hereto, incorporated ere in, and marked as Exhibit liB". 6. As of the date of this Complaint, the remaining balance due, owi g and unpaid on Defendant's credit card account as a result of the charges made y said Defendant(s) and/or any authorized users is the sum of $ 7984.03. 7. Pursuant to the Credit Agreement and/or applicable Pennsylvania unpaid or delinquent balances on said account shall continue to bear inter rate of 18.00%. See Exhibit "A" as previously identified herein. aw, any st at the 8. As of the date of the filing of this Complaint, the amount of in erest which has accrued is the sum of $ 3122.30. 9. As of the filing of this Complaint, Plaintiff has incurred reaso ble attorney's fees from the law office of Wolpoff & Abramson, L.L.P. in the c llection of the amounts due from Defendant(s) incident to the within action based u 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 96.80. 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 $ 7984 03, plus attorneys fees in the amount of $ 1596.80, plus interest in the amou t of $ 3122.30, plus costs of this action and any other relief as this Court de ms just and reasonable. Respectfully submitted, Amy F. Doyl 1187062 Daniel F. Wo son #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 Co lection 267 East Market St., York, PA 17403 (717) 846-1252 Counsel for Plaintiff CPWRI2/PARET W&A FILE NO. 125503263 LLLOJ~ 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 alf of said Plaintiff in this action and verify that the statements made in the f regoing Complaint are true and correct to the best of my knowledge, information, a d belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made sub ect to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsificatio to authorities. Date: Amy . 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. 125503263 222827 EXHIBIT "A" "':;"'1 .'I~,;;'(.j t!;;:"'- 'it "~ ::,:~,-~::! ."..-.',' "':1 , ....,-..,. '''''','1 ~~ ~~ ""'1 ~}]f:; '10. ,y~ PRr.' fIn' ^ "-' <~V' ' ~\ .~Ir.,' Financ!al ::i)t.915Z-l] 3053 PROVIOIAN NATIONAL BANK VISA' AND MASTERCARD' ACCDUNT AGREEMENT Please review this dOcumellt and keeo it with your otl1er imllonant papers. ihis Account Aqreemem carnalns me terms that govern 'lour Providian Natfona Account !the "Account"). The Account aik:tws you to maKe purcnases Dy uSing your VISA or MasterCarD crecit card (the "Cann wherever It is ilooorea and ta or any orner participating financial institution and from Automated Teller MacllJnes. COnveniet1ce cneckS may also ile provided to '{OU as an aoditionai way Agreement "you" and ''your'' mean eacl1 oerson lor whom we have opened a credit card Account "We," "QUe wours.~ ana "'Js~ mean ~ra'J1oi<in National 6an on your till\(11) statement. The Account may be used onlY for personai, family. househOld. and charitable purposes. ana not lor any ousiness at commerc Account shall constitute acceptance oj the terms 01 this Agreement. You and we agree as follows: Pa~ment=. You w\\l receive a monthly statement showing your outstanding balance. Payment on this Account is reqUired in U.S. doUars (checks must be pa Ie at a U.S. at/ice of the bank the cneck is drawn on) ror at least the payment due as shown on your statement tJy the payment due date in accordance with payment instructions on y r monthly statement TIle bacl< at your monthly statement incluoes the rules we follow when we post pa~mentS ,0 '({lur Account. Convenience cnecKs and mer checks we may issue to y may not lle used to maXe payments on your Account or to mal<e oayments an any other account you have 'Nlth us or our affiliates. The payment clue will be: 3% ot the new balance silown n your statement pius tile amount of any past due payment. ana may include Ihe amount by wiliCl't the new OaJance exceelis your credit line. However. the payment due will not be less. s'15/.unitss 'jour new balance is Jess than S15, in which case tt'le payment clue Vliil be the amount 01 tl'1e new balance). If your Account is past due or above ttle creait line, we may require a hiqher minimum payment. but we will notify you before doing so. If your oayment is more than the payment due, it will tie treated as a single payment and none 01 it wilt be aDpli [0 tuture payments due. We may accept late or partial payments, or payments marKed upaid in tulr or marked with other restrictions.. ...,ith\3ut ltlsir.g our Ml;jllt to cnIlect a~ amounts owin under tl1is Agreement Finance Charges. Finance charges begin to accrue on a debit wilen it is included in one at your daily balances and continue 10 accrue until tl'lat balance is redu d by a payment or credit Your Account has two daily balances: the Pnrr:f'l.ase Balance which consists 01 purciiaSes you malee 'Nitti your Card. and fees. other than cas.t\ aavance transa '01\ iees, cnargelJ to your Account. inclUliing fees tor Optionai services: and the Casn Advance Bal.mce wtTiell consists of ail cash ativances and cash aL1vance transaction tees. Any paym t amou(l[ 'Nt receive that exceeds the finance charges and fees then due will orc!inarily be appiied first to tile Balance with the lower ANNUAL PERCENTAGE RATE (APR) untillhat BaIa is zero, and ttlen to tne remaining Balance. We reserve me right to apply payments differently without fuctt\er nOtice. The Purer.ase ana CdSh AdvanCe Balances are reduced by piiym as 01 the date receiveo, and by creditS as of the date posted. Purchases are included in your Purt:llase Balance as of ttle date made. Fees are included in your Purchase Balance as at he transaction lJate. Cash advances are included in your Cash Advance 8ajance as follows: cash advances from other financial instirutioos and through Automated Teller Machines of the date made: tunds ~Jectronically transmitted, as of the oate transmitted.: cash ad-nI\C8 chec\ls made payaole to you that are identified as cashier's checks, wtlich we may mail to au at your request as at seven days after the date we prim on -me check; all Olher checks, inClUdIng any convenience ctlecks, as ot the date presented to us. Casn advance tI'1nsaction f are included in the Cash Advance Salance as of the transaction data. Other debits are included in your Purchase or Casil Advance 8alance as at the date posted. PIttance charges are to 'fOur Purthase aoo Cash AdVance aalances each. day ami are ttlen posted on the last day of tlle billing c,/cle. There is no perioo witl1in Which credit extended may be repaicl without in urring a finance Charge. To figure tt1e daily finance charge for purchases and the daily finance ctiarqe for cash advances, we start with your previous day's Purchase 8aJat\Ce and Cas Advanca Balance.. aad aU debits.--am1-'SUOtr.Icr'a11 mnits 'fur the mlrrent day to the appilCOcle Bilal\Ce (as ~piained in me paraqraoh al:love), and mUltiPly the net amount by the iUlp.lica. Ie daily periOdic rate (S28 follOWing paragraons), The finaoce charge for pun:hases is then adcled 10 and included in mat day's PurcnaS8 Balance, ancl the finance cnarqe tar casn aav es is Uten added to and included in that day's Cash Advance Balance. We treat a credit balance for any d~ as zero. We dettrmine me total finance charges on your Balances for the alliin CVde ~ aOding together the finance ct\arge lor purenases <<if each day within lhe billing cycle and the finance cllarge for cash aavances tor each day within the !lim~.eYCle. In calcu ting finance charges, a.n adjustment will be maoe for any transaction or payment that would have affected the finance charge calculation in a prior billing cycle had it been posted in that CIe. The appiicable claily periodic rate for such a transaction will be the rate in effect for thll current biHinq C'fcle rattw than the. rate in etfec:t on the date of the trilnsactian. The term "Prime R<ite~ as used in this Agreement means the prime rate pUblished in T71! Wall Street Journal on the first business day 01 the previoUs ca{end month. Any increase or decrease in the APR will tall:e effect on the first day ot yout billing cycle and may result in a slight increase or decrease In the amount 01 your minimum payment. The ANNUAL PEHCENTAGE RATE for purchases will vary and may be adjusted eaci1 billing cycle up to 10.99% above Prime Rate. Using this formula. the PR for purchases in the Aprii 2000 billing cycle is 19.99'Yo, corresponding to a daily periodic rate at 0.0548"!., and your APR lor purchases will not go oelow 19.99'Y... The ANNUAl.. ~RCENTAGE RAn for cash advances will vary and may be adjusted eacn billing cycle up to 12.990/.. above Prime Rate. Using this formula. ttle AP for casll advances in me April 2000 billing cycle is 21,990/.., corresponding to a dallY perioclic rate of 0.0502%, and your APR for cash advances will n01 go belOW 21.99%. To determine. the averilJe daily balance shOwn on your statement tor purdlases. add aacn day's Purchase 8aIance (including daily finance cnargel in the b~r c/cle and divide by tl1e number 01 days in the billing cycle, To determine the aVllrage daily balance shown on your statement for cash advances, add each day's Cash Advance a (includinq daily finance Charge) in the biUing cycle and divide by the number of days in the billing cycle. You can muttigty each at tt\ese aWnQl! dail'j balances by the number of days in fI billing cycle and by the applicable daily periOOic rate to oatlin subtotals, and then add the two subtotats togerner to d!l:ermine the total amount 01 finance Cl1arqes an your balances tor e billing cycle. 11 a casll advance transaction fee, credit fine increase lee, or Express Card processing fee is ciwgecl (see MIa section), tIlose amounts ani alSO FINANCE CHARGES, Fees. A memt1emip le, of S7.95 wUI be charged to your Account each month. 11 you request ancl we issue an additional Card on ytIur Account tor an aut/'lorized additional earn will be charged to your Account This fee will be charged to yout Account when the additiOnal Card is issued ancl every 12 montl1s therutrer tor CGrd is outstanding. If you request and use our Express Card Service. a one-time fee of $19.95. whict\ is a AMANCE CHARGE. 'Mil be charged to your Accou Pl'OC!SSing mcy not be avaUable. We may charge your Account $29 for. aach Card you ask us to ~pSce: each ~tumed payment each CI1ltdc you write on yo unpaid: aach stoD payment order or l'1flewal 01 such an order, each billing cyde withIn which your Account is definQuent (late chan;le); and each bilUng cycle exceeds your credit line even it your Account is closed. It you request copies o( timing sta1ement& ttlat were first sent to you more thaf1 two months earlier, we ma S2 for each such copy. A cash advance fee at 3% (minimum $5), which is a FINANCE CHARGE. may be charged for each casll adVance transaction made on your line I.ncreases, you may be chargad a tee, which is a fiNANCE CHARGE, the amount at which will be disclosed to 'Iou betore you accept the line increase otter. If a one-time autOmatic payment from 'JOur persooal ctletking account, WI! may charge your Account a tee of $4.95 for each "'Quest ThiS fee is a FINANCE C wilemer.m 4Ct.twadl::l~ ~,~;I~\J'B.fR1'fII:H'1Mf'9OMf-cnectrinO-accmmt tomaxetne payment. Detallit. You wi~ be in default i1 any information you provided us prINtS to be inctlmp\ete or untrue; if you do not comply with any part ot tl'lis Agreement; upon insolvency; jf you dO not pay ather debts when clue: it a bankruptcy petition is tfuld by or against you; or it we believe in Qood faith that you lTl3!' nat pay or peno tnis Agreement If you ani in default, we may, without further demand or notica, cancel your creait prtvifeqes. declare your Account balance immediatelV due remeay we may have. In tile avant at your c1etiult, the ou1StandinQ balance on your Account will continue to accrue interest at the APA(s) dlsdosed in tile Finan Aqreement, aven if we have tiled suitto collect the amoum you owe. Credit line. Your cred.it line and cash advance line are disclosed. wRen'fOO open your Accoum ana on your statement each montn. Your casn advance line is Ii - crecllt line. We may increase or decrease your credit line and/or your cash adVance line based on intormation we obtained tram you or your credit recorcs. our available credit for ~ is nonnally the difference between your cretiit line and your Account balance (inctuding: tr.msactlons made or authorized but not yet posted). Yo available!: credit fOf a cash <Id1r.1nce is normally the difference betWun your cash advance line ana your cash Advance Balance or me dirference between your cl'!dit line and, your Ace balance. whichever Is less.. If you send US a large payment WI may timityour available credit. while we confirm thatthe checK will dear. For Clrtain transactions, available credit may be I . You will not use your Account for, and we may refUse to honor, any transaction that would cause you to ~ your avallabte credit or 'J<l.ur ~ai\abll creQit far caSl'\ atNances.. 'four line may be reduced it yeu Q~t to 00 over your cash advance credit line. Promise to Pay, YOU promise to pay us wilen due all amounts borrowed when you or someone else uses your Account (even if the amount charged !Xcteds ytJ r Iltrmission\, aU otMi' transactions. and ct\al'ges to 'JCUf Account, and all coIlectlon COSts we incur inCluding. but not limited to, reasonable attomey's tees and. court costS. (If you win suit. we will pay your reasonable attorney's tees and court costs.) Cbangu. Atter we provide you any notice required by law. we may chanqe afT>! pan of this Agreement and add or remove any terms. conditions, or reouirements II a change is made fO the Finance Charges section 01 tI'lis Agreement. tile new jinance Charge calculation will apply to your entire Account balance from the effective date of the chang Changes will apply to balances that incllldl! iterm oosted to your Accnunt before tfle date of thp. cnanoP.. and will apply wi1ett1er or nor you continue to use the Account Foreign Exchange/Currency COJJVertian. If you use your Cara tor transactions in a currencv otner than U.S. dollars. the transactions will be canvertsd to U.S. dolla ,generaily using either a (I) govemment-mand.ated rate or (il) wholesale market rate in effect the day before the transaction is processed. increased by 3%. If a credit is subS8QuemIY given or a transaction, it will oe decreasecl by tt1e same percentaqe. The culTeoo/ conversion f'i,te USeQ 011 the conversion dare may ditter tram me rate in effeCt on the date you used your Card. au aqree to accept the convened amount in U.S. C1olfar.;. The Cant; Cancellatlon, You may cancel your credit privileges at any time Ily nOIitying: us in writing and clestroyinq ttle Cardls). Upon the card expirational tl1e end t the month shown .on it, we reserve tne rrql1t not to renew tile Card. We may caneeJ the Card and your c~dlt privileges at any rime artsr 30 days nonce to you, or Without nO,lice if permi by law. il your Care is cancelled or rlor renewed, finance charges ana other fees will continue to be assessed, paymanes will continue to be dUll. Jnd all orher 31lPticable prOVtSions at this A reement WIll remaIn in effect. It you tenninate your credit prtviieges, ac if we cancel or 00 net renew Itle CarO,' you may no JonlJer write checks on your Account and you should destroy ny unused cnecKS we may have ISSUed to you. Bank VISA o.r MasterC;;.ro et casnadvances :rom us use the Account in this or its asSignees, as listecl pureose. Any use of this r,atee otS20 for each lonq as each adaitiOlla/ In some cases, express Account that we return inwhiCI1V1Juroalance Charge a handling fee at count. For some credit u request that wt make RGE. and it will apply ur death. bankruptcy, or your olllig.ttkms under gayable, aM use any Chargn sectiOn oftnis 5100 iCvnimueo on r~er.;e.1 06019 "~.,. ": . , , >;f .. 1J ,I 'I .;l .....i I ~~j II i~~~~ :'-.." : -- '~l "". :~jj ~ ~ ~-,.; ~~~.;~ Pet$Ol\3.l Into.rmatlQJl; Oaeumems. Yoowm provide us at leaSt 10 dayS notice dyou change your name. home or mailing address. telephone numbers, emUloyment, or vou will provide us additiOnal financial imormattOlt We reseNt the riqtlt to obtain imonnation trom otfiers, Induding creait reporting agencies. an<I 10 provide your add YourAccounttoothers.W h... r in' 'N- t ... .. do not fulfill your oohgatiOns under tt1is Agreement, a negative credit report ttJat may reftect on your cred.it may he submitted to credit ~ agencieS. Customer Service; Unauthorized Use, lan, or Theft of Checks or lhe Card.. Each Card must be signed on receipt. You are responsible lor safeguardin Identification Number (P'tN), which prOVides acC8S$ to Automated Teller Machines, ane any checKs issuet! tQ you from theft. al\C lor keepino your PIN sepa discover or suspect that the Caro, PIN. or any unused checks are lost or stolen, or that there may be an unauthorized transaction on your Actount. you will \1 1-800-211.5815. So we can immediately act to limit (asses ami liability, you will phone lIS even though you may alSO notify us in writing. Your liability lor u betore you notify us is limited to SSO. If you report or we SUSllect unauthorized use of your Account, we may suspend your credit privileoes until we resolve the p or issue you a new Card. If your card is lost or stolen. you will promptly destroy all checks that may he in YO\ll' possession. To improve customer service and se calls may oe monitoreD Of recorded. MerctlantRelaOons. We will not be liable jf any person or Automated Teller Machine refuses to honor the Card or accept your checks, or fails to return the reS90nsltlillty for goodS ana seMces purchased wrttI the Card or checks eJl:cept as required hy law, (See Special Rule below.) Cert:a.in l1enefits that are avai provided by thir(Hlarty vendors, We ate. oot responsible far tne quality, availability, or resultS of any of the services you choose to use. Slo~ PaymetU. Olders. If you ~ish 10 stop payment on a check, you may send us a stop payment Qrder by writing to us at our address for Customer SeMce list can make a stop paymem order orally by calling the numbef Ilsred on your statement When you make a stop payment order, you must provide your information about tile check: the exact amount the date on the chect the name of the ?a1'\Y to whom it was payable, the name of the person who signed i 'fou will be asked 10 canfion an oral stop paymem order in writing.' . IN ... .. . ~ or it we have not received an adequate description of the item so that paymem can be stopped. The order will not be effective it the ctteck was ~ by us opportunity to act on Ute order. We may, wtt!\Gut liabilhy, disregarn a written stoP payment order six montl1S atter receipt unless it is renewed in writing. . Standard at Care. Because this Account invotves a credit card and may lnvolw check transactions "th3t are processed throlJQh separate national systemS b consolidated by us, and because not every check. and. Card stip will be sent ttl us. transactions in your Account will be processed mecharlically without our nece Our processing system will call our attention to certain items, which we will examine. We will ~mioe all transactions when you report that your card or any stolen. We do not intend ordlnanly to examine all items, and we will not be negligent it we do not dQ so.. ThIs rule establisnes the standard of ordinary care exercise in administering your Account Because of our limited review, and because neither your cancelled checks oor card transaction slips will be returned statement you should be careful to enter all chetks in YQur thacX register or otherwise keeg a record of tl1em. You should also save your credit card cash advanc anrlle In check '.lour monthly statements aaainst vour /'P.Cord ann to notifv us immMiatp.N 01 :mv umuthori2ml transactions or error.: Waiver of Certain Rights. We may delay or waive enforcement of ~ provision ot this Agreement without losing our right to enforce it or any other provision late . You waive: the right to presentment, demand, protest. or notice of dishonor; any appijcable stature of limitations; and any fight you may have to require us to proceed against anyone fore we file suit a93,inst jllU. Appll.cahle.t.aw:; S'lJ"lnilllly, .uilllm8ll1. No rnatteI" wttm you live, this Agreement and your Account are governed by tederallaw and by New Hampshire law. is Agreement is a final expression at tile agreement between you and us and may not be contradicted by evic:lenc8 of any alleged oral agreement If any pl'O\lisiorl of tt1i:S AlJreement is held to be invatid or unenforceable, you and we will consider that prolttsion modified W contonn to applicable law. and the rest of the provisions in the Agreement will still be entorcea Ie. At any time after we determine in good faith that any proposed or enacted legislation. requlatolY action, or iuuicial aecision has renDered or may render any material provisions at Agreement invalid or unenforceable, or impose any increased tax, reporting requirement or other burden in connection with any such. pravtsi.on or its. er.tan:ement..~, after at , 30 days notice to you, or wtthout notice it Pf,rmitteO by law, cancel tt\e Card_4nd your craclit privileges. We may transfer or assign our right to aU or some of your payments. It state laW Utres tt'iat you rfICam notice of such an event to Protect the purchaser or assignee, W1 may give you such notX:e hy tiling a financing statement with the state's Secretary of State. Notices. Other notices to you sttaU lJe effectM: when deposited i1I the mail addressed to you at the address shown in our records. unless a longer notiCe pe .od is specified in this Agreement or by law, which period shall start upon mailing. Notice to us snail be mailed to our aDdress tor Customer Service on your statement (or other addre we may specify) and sl'lan be effectiVe when we receive it YOUR BlUING RIGHTS _ KEEP THIS NonCE FOR FUTURE USE. This notice contains im'l1Qrtam intmmation about your rights and our responsibilities under the 'r Credit Billing Act. Notify JJ$ in Cas. DI Errors at QU,sUl1llS AbDut Your B/II. If you think your but is wrono. or It you need more intormatlon about any transaction on your bill. write on a separate sheet. at our address listeclln the BiUing RightS Summary on your bill. Write to us as soon as possible. We must hear trom you 1\0 lattr than 60 days after we sent you th first btIl 00 which the efror Of problem appeared. You can telephone us, but doing so will not preserve your rights. In your litter, give us the followinq: Your name and Account AUmber 1'he doMir amount at the suspected error _ A descrtption of tt\e errcr and an explanatiOn, if possible. of why you believe there is an error. If you need more information. describe the iiem u are not SUn! about. Yaur RJrha and Our ResporlSitJltlflts Aft., WI ae-tam Your Wrinsn NotJu. We must acknowledge your"letter witl'lln 30 days, 'unless we have corrected error by then. WIthin 90 days, we must either colT8Ct the error or explain whY we believe the bill was correct. After we receive your letter, we cannot try to collect any anKIunt you Q ticn, Of report you as delinquent We can continue to bill you for the amount you Question, including finance charges, and 'Nt can apply any unP3kl amount against your credit line. You 0 not nave to pay any questionea amount while WI are ilTVestigating, but you are still obligated to pay the parts of your bill tnat are not in questiOn, It we find "!hat we made a mistake on your blll. you, wiD not haw to pay aiIy finance chal'Qe related to any questioned amount. It we didn't make a mistake, you ctwges. and you w"' have w make up the missed paymentS on the Questioned amount. In eittler case, we will send you a statement of the amount you owe and you tail to pay the amount we think you owe. we may report you as delinquent However, it our explanation does not satisfy you and you write to us within 10 days refuse to pay, we must tell anyone we report you to that you question your bill. And. we must tell you the name ct anyone we ",ported you to. W. must tell anyone matter has been settled betWeen us when it finally is. If we dOn't 1c*w these rules. we can't collect the first $50 of the questioned &mOOn\, even i1 your bill was co S,.,:ial RBl. for Ct,dlt Card Purthl$U If you have a problem with the quality of the propelT/ or se.Nices that you pufthased with our credit card and you correct the problem with 'me merchant. you may not have to pay the remaining anKJunt due on the property Of services. There are twO Jimitations an this riQht (i) Y purdtHe1n year.... 'StItI!:.11t1t1Qt~ -ymsr'Mme stm, within'oo mUes of your current maiOng address; and (b) the purd1ase price must nave been limitations do not apply it we own or opel'3te the merchant or if'Wl mailed you the advertiSement tor the property or services. REWAII1lS PROGRAM - lb. fellow"" T..... and Conditions. alcnIg wtIII\lIe ReOemplIonllules dlsdosed 1011I. Rewards _I"B_', apply to \lie Rewanls ("Program"). BilJlbiJIly. ParticipatiOn In the Program Is mtr\Cted to individuals '#lIho maintain a Providian VISA or MasterCard credit card account rAccounr) in good standing We reserve lt1e right to approve. deny, or revoke membership or not allow redemption of Rewards:. as defined. balOw. to any imiMaual10f any reason wtmsoever. Eamlng of PtJin1s. During tne first 12 months your Account is o"en. yCIu wiU earn 2 pOOUs ,-Points) tnr each $1 of Net Purchases.Thereafter, at the end of each onthly billlno cycle. you w"l earn 1 Point tor eacI1 $1 of Net PurchaSes. "Net Purcnasas" means purchases 0' goods or services made by 'IOu or awj authoriled user at tile Account, inus any retUrns or refunds. and excluding balance transfers. ash adv;l.ncas. traveler's checkS, and access checks. Points do not accrue tor imerest charges or fees of any kind. such late payment tees, annual tees. overllmit tees, and unauthorized charges. Changes made to the abow list irt at our sole discretion. Point accrual will begin upon your Enrollment 0 in the Program. No retroactiVe Points will be awarded. The Enrollment Oate means the date we approve you as a proqram member. Points may only be earned if your ACCount is open d is not past due or above the: credIt tine. When 'jour Account. is currem and is within its credit line. you will begin to earn Points again. TIIere is no limit on the nurntlel' of Points tl'Iat be earned. PoInts do not have a cash value, cannot be Pllrcttased O! excnanged for cash, and cannot under any circumstance be redeemed tor cash or used as a payment tor y ur Account or other obflgations to us. Stalement of Points. Program Points are updated monthly at the tfme 01 your Account. billlnO statement. Pmnts earned during the month will be posted at your billin are net imilable ftIr redemptiOn until at least two business days after your billing statement date. Expintion of Points. Points will expire ftve years after being awarded. Points redeemed and expired will be based on a lirst-ea.me<I. first-went. baSis. Redemption at PolntJ. PoInts may be redeemed for prodUCIS or services fRewards'"). which are set forth in a Brochure mailed to you kern time to time. Points m your Account is ogen and is not past due ~r above the credit Ime. AU Rewares are subject to availability. We reserVe I'he right to modify or cancel any Reward at a are redeemed tor a Reward, the number at Points required for the Reward will be subtr3tte11 from your Point balance. You wtll contact the parties listed in the Bra on how to redeem your PointS, la~ UablUty and feu. You wiD be responSible tor any federal. state, or local taxes due arising out ot tha accrual at Points or redemption of the Rewards. You will al be responsible tor any fess or otheC Charges due in connection wittl the redemption of any Reward. Changa to the ~""m. me Program ana the benefits are otf8red at Qur sole discretion. We reserve the right to aUar or c/lange any Program feature or ben it. PfOSpettille!Y ot retroactively, including, wi1holJt limitation. Point accrual Of redemption criteria. and to cancel or temporarily :suspend the Program at any time witnout notice. In Ih event you commit any fraud or abuse your privileges relating to the accrual 01 Points or redemption af Re.wams., we feseNt the rigltt to cam~el any accrued Points as weU as ca your Account ~d particq:Jation in tbe Program. li.."e cancel the program. WI will normally .crovide alleast 30 days written notice 10 you at tile address. provided to us, Hawevef, if you olatt any proviSion Qf these Terms and Conditions. you are In de.fault under your Account, or ytlur ACcount is dosed. we may cancel the Program without providing yOu 30 days written notice and 'IOU will forfeit any unused Points. You may cancel your participation at any time. The pragram is void wnere prot\ibited by leoeral, state, or local law. Rewards. Maritz Inc. and SRI provide administrative services for rlldemption of the Rewaros. Mantz Int. and BRI are independent conuacrors ana are not affiliated itn us. Neimer we, Mantz Inc.. no! SRI shan be liable for bodily harm and/or propeny damage tllat may result from participatinq in the Program, nor foe tile redemJ)tion 01 Rewards and S8 of RewardS. In the even! any_ Reward. that is reueemeti is moIiified. detective, Of otherwise unsatisfactory co you. you will look solely to the mercl1am or milflufacrurer of the Rewa and not to us tor any repair, relund, or satisfaction 01 your claim. We are not responSdJIe. tar any lost, stolen, destrOyeQ. aT ~Plred Rewards, the Caret. your Personal from your Card. If you ~""\ifyllSbjcalliog UthOlized. use occurfiflg blem to our satisfaction nty, you agree that your or\ your stl.tement You nt number and. specific and tt1e check number. w Crt we had a reasonable re the transacoons are "Iy reviewing rNeryitem. ecks have lJt!en lost or t We in good faith will 'f<lU _ Il1e momh~ and purchase slips. Yml onty be redeemed If time.. When Points ure forinstructlons 222830 EXHIBIT "B" '" " <t a. > "'0 "'''' "'a. '" N"- "'0 o 0," "''" -Z "''' '<t_ "'V> .... Vl '<t<t '<t () -' c-' W .oZ EO ~- Zf- () ~'" C-' ~-' 00 UU U <tv> '" o <t v> - -' <t NO. "' -'" N," -0 0_ '<t> 00 N'" '<to. o c W .0 E ~ Z ro u w :>: '" '" N '" o In "' N c W "'.0 '" E - ~ o>Z .- W "- '" '" '" '" N '" o o '" <Xl o "'-- O.....(Y)ClCl .C\IC\iZ...... o::tO.....O> a> ON a:: <t O'lC'\lOI-O <- Ov> " N o '" N '" o N o o N <t '" " "9- ~") .-.' (0 (:':::) 0 ;:.J ~'" 1" .0 en -'1 fI:. :~"" .-:::! Ii ~'l::r :r:..,..., ;;D rnr-::! ,',-, -"r11 8 O? ~ ill ~ ;-:~ r-;:J ..... ..~~i ~~?, ~ ~ ::2 V J;". -" . ..~ i~~'~ D ~ ;-:-;rn -G p:: ~-l ~ U1 c..) ~D .1:;'- .< ~ J:- SHERIFF'S RETURN - REGULAR CASE NO: 2005-02019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS STRONG DAVID SGT. JODY SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STRONG DAVID the DEFENDANT 2005 , at 1345:00 HOURS, on the 29th day of April at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to DAVID STRONG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 .00 .37 10.00 .00 28.37 ~~e."~~~ R. Thomas Kline 04/29/2005 WOLPOFF & ABRAMSON Sworn and Subscribed to before By: C /! ~I'I 'q r . Debt :-t;t.., De-puty Sheriff me this 3-<-4. day of _M.. ;{ A.D. l). 0 YnAPP(. ~ P othonotary 754 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 NO. 052019CIVILTERM Plaintiff vs. DAVID STRONG Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), DAVID STRONG and for want of ANSWER TO COMPLAINT. ( X ) 7984.03 3122.30 1596.80 Amount due $ Interest $ Attorney's Commission $ Filing costs $ TOTAL $ 12703.13 , 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. and costs is for specified a sum certain from DATE: --4'1/0r- Signature: ~ c: 1L Amy F. Doyle 1187062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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 Plaintij Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 1701: (717) 303-6700 JUDGMENT IS EN}ERED ~S , , /;7 Prothonotary/Cl ~,..Ci vi I i vis i on /' NOW, ~. 20~, By: Deputy PRAECJ/PANOJ W&A FILE NO. 125503263 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 NO. 052019CIVILTERM Plaintiff vs. DAVID STRONG Defendant(s) TO: DAVID STRONG 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 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 Cumberland County Bar Assn. 32 S. Bedford St. Carlisle 800-990-9108 PA 17013 By: Amy ~& \f.- #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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 IMPNOT/PANOTC W&A FILE NO. 125503263 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 No. 052019CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DAVID STRONG Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 and certify that the last known address of the within Defendant(s) is: DAVID STRONG 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 Amy F. ~l~ C ~ #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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 Attorneys in the Practice of Debt Collec 4660 Trindle Road, 3rd Floor, Camp Hill. (717) 303-6700 PCRES/PANOJ W&A FILE NO. 125503263 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 No. 052019CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DAVID STRONG Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ C-".-^~~e{"'~ 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, DAVID STRONG , above-named, is over 21 years of age; is last known to reside at 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 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 Tara A. Bandjough, Notary Public Hampden Twp., Cumberland County My Commission Expires July 23, 2007 Member, Pennsylvania Association of Notaries C11u C? 0_ _ Amy F. Doyle ~x_ #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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 Plainti Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 1701 (Zl~ 303-670~~ l-. -Li day of ~~Yf\.. , 20 D~~ SWORN and SUBSCRIBED to before me this ~~Y\ ~\~-~l/'\ Notary Public ~ PNMAFF/PANOJ W&A FILE NO. 125503263 TWO IRVINGTON CENTRE 702 KING FARM BLVD., ROCKVILLE, MD 20850 REGIONAL OFFICES , 10605 JUr'JICIAL DR.. BLDG. A.5, FAIRFAX. VA 22030 1108 E. MAIN ST" STE. 1003, RICHMOND, VA 23216 5122 GREENWICH RD" VIRGINIA BEACH, VA 23462 919 N. MARKET ST" STE.1300, WILMINGTON, DE 19899 1 VALLEY BANK BLDG. BOX 1226, CLARKSBURG, WV 26302 2625 TOWNSGA TE RD #330. WESTLAKE VILLAGE, CA 91361 4660 TRINDLE ROAD, 3RD FLOOR. CAMP HILL, PA 17011 39500 HIGH POINTE BLVD" STE 250, NOVI, MI 48375 300 CANAL VIEW BLVD" ROCHESTER, NY 14623 758 NORTH CARROLL AVE" SOUTH LAKE. 1)( 76092 180 GLASTONBURY BLVD.. GLASTONBURY, CT 06033 NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS [NOT REGIONAL OFFICES OF WOLPOFF & ABRAMSON, L.LP. " I MIN HA ,ALA MA PHOENIX, ARIZONA ANCHORAGE, ALASKA CABOT, ARKANSAS 125503263 DAVID STRONG - ... -. . .--- W 0 l P 0 F F at A BRA M SON, l. l. P. Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, PA 17011 717-848-6203 OUTSIDE YORK METROPOLITAN AREA (TOLL FREE) 1,800-758-0675 FACSIMILE (717) 737-9051 PLEASE DIRECT ALL INQUIRIES TO YORK OFRCE JUNE 2005 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 AFFILIATED FIRM LOCATIONS (NOT REGIONAL OFFICES OF WOLPOFF & ABRAMSON, L.L.P.] " ENGLEWOOD, COLORADO FARGO, NORTH DAKOTA FT. LAUDERDALE, FLORIDA CLEVELAND, OHIO NORCROSS, GEORGIA OKLAHOMA CITY, OKLAH HONOLULU, HAWAII EUGENE. OREGON BOISE, IDAHO PROVIDENCE, RHOOE ISI MERRILLVILLE. INDIANA COLUMBIA, SOUTH CARe CHICAGO, ILLINOIS KNOXVILLE, TENNESSEE KANSAS CITY. KANSAS SANDY, UTAH LEXINGTON, KENTUCKY MILWAUKEE, WISCONSI~ METAIRIE, LOUISIANA RAWLINS. WYOMING MINNEAPOLIS, MINNESOTA ST. LOUIS, MISSOURI GREAT FALLS, MONTANA OMAHA. NEBRASKA LAS VEGAS, NEVADA MANCHESTER, NEW HAMPSHIRE CEDAR KNOLLS, NEW JERSEY RALEIGH, NORTH CAROLINA . The National Collection Attorney Network I. an affiliation of ..parata law' W&A Hours of Operation: 8 a.m. - 11 p.m. E.S.T. M.F I W&A File No, 125503263 Re: PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN vs. DAVID STRONG Docket No. 052019CIVIL TERM Dear DAVID STRONG Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. ~~~ ~ Enclosure CC: DAVID STRONG Sincerely, ~Q.Q Amy F. Doyle #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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. I Counsel for Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 1 (717) 303-6700 This is an attempt by a debt collector to collect a debt and any information obtained wi II be used for that purpose. NOT 1 OD/P ANOTC L TRHD. (05123105) t AJ D ~ t- It ~ ~ D ,,~ = 0 = - 0 <:..r1 11 g " "'<) (/) :::! ()'-- r-. R;:D -"0 -0 ~ V r--- N in ~ p:: -..J l? @ ~ C) ~ -n _ ,-_ :T~~ ....0 ~ ~~ < )---.: ~.~= C) W W :.')fT', t .. :];1 :u ~ N -< 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NO. 052019CIVILTERM Plaintiff vs. CIVIL ACTION - LAW DAVID STRONG Defendant(s) NOTICE OF JUDGMENT ( x) Notice is hereby in the above-captioned matter has $ 12703.13 , 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. Proth ISlon By: If you have any questions regarding this Notice, please contact the filing party. ili~ Amy F. Doyle --- #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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: DAVID STRONG 405 WALNUT BOTTOM RD CARLISLE PA 17013-3743 STNTC/PANOJ W&A FILE NO. 125503263