HomeMy WebLinkAbout02-5726IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS,
KYLE C. DELANCY, GINA M. PERRY, MAC G.
DELANCY AND MARIE DELANCY
Defendants
COMPLAINT IN REPLEVIN
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02750500
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY, MAC G.
DELANCY AND MARIE DELANCY
Defendants
Civil Action No. ~;~ 2- -,
COMPLAINT IN REPLEVIN AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by an attorney and filing in writing with the court your
defenses or objections to the claims set forth against you. You are warned that if you fail to do so the
case may proceed without you and a judgment may be entered against you by the court without further
notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. OF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
COUNT I - REPLEVIN
1. Plaintiff is a corporation having offices at 106 S. 16th Street, Philadelphia, PA 19102.
PA 17266.
Defendant, Kyle C. Delancy, is an adult individual residing at P.O. Box 34, Walnut Bottom,
3. Defendant, Gina M. Perry, is an adult individual residing at 1466 Wood Road, Lot 14,
Shippensburg, PA 17257.
4. Defendants, Mac G. Delancy and Marie Delancy, are adult individuals residing at 407
Deborah Court, Chambersubrg, PA 17201.
5. Plaintiff is the holder of a Retail Installment Contract (hereinafter the "Contract") and
Security Agreement secured by a mobile home duly executed and delivered by Defendants in favor of
Mt. Rock Homes, Inc. on or about July 25, 1995. A true and correct copy of the Contract and Security
Agreement is attached hereto, marked as Exhibit "1" and made a part hereof.
6. Pursuant to said Contract and Security Agreement, Defendants took possession of the
mobile home more particularly identified in the Contract as a 1996 Astro Riverbridge Mobile Home, Serial
Number AP960181.
7. Mt. Rock Homes, Inc. subsequently assigned its right, title and interest in said Installment
Sale Contract and Security Agreement to Plaintiff.
8. Under the terms of the Contract, Defendants were to make 180 (one hundred eighty)
consecutive monthly payments of $204.00 beginning October 25, 1995.
9. The total principal amount due to Plaintiff pursuant to the Contract was $19,257.00.
10. Plaintiff maintains a first lien on the aforesaid mobile home by virtue of the Certificate of
Title issued by the Commonwealth of Pennsylvania Department of Transportation, a true and correct
copy of the Certificate of Title is attached hereto, marked as Exhibit "2" and made a part hereof.
11. Defendants are in default of the terms and conditions of the Contract because Defendants
have failed to make the required monthly payments since September 4, 2002.
12. Plaintiff is entitled to immediate possession of said mobile home which Plaintiff holds a
security interest in and any proceeds of the mobile home, including insurance proceeds by virtue of
Defendants' default.
13. Defendants have made partial payment under the Contract leaving an unpaid balance in
the amount of $14,183.71 as of September 30, 2002.
14. Plaintiff avers that the Contract provides for finance charges at the rate of $3.79 per diem.
15. Plaintiff has performed all conditions precedent as holder of all right, title and interest in
the collateral, but Defendant wrongfully remain in possession of the mobile home at the above-stated
address.
16. By virtue of Defendants' default, Plaintiff has an immediate right to possession of the
mobile home covered by the Security Agreement the value of which is $14,183.71, plus continuing
finance charges at the aforesaid rate of $3.79 per diem.
17. Under the terms of the Contract, Defendants have undertaken to pay to Plaintiff its
reasonable attorneys' fees and costs of retaking possession of the collateral.
WHEREFORE, Plaintiff prays for Judgment against Defendants, Kyle C. Delancy, Gina M. Perry,
Mac G. Delancy and Marie Delancy, jointly and severally, in Count I of this Complaint In Replevin, as
follows:
A. For possession of the mobile home, more padicularly identified as a 1996 Astro
Riverbridge Mobile Home, Serial Number AP960181
COUNT II
ACTION IN CONTRACT FOR IN PERSONAM DAMAGES
18. Plaintiff incorporates herein by reference thereto each of the preceding paragraphs of this
Complaint in their entirety as if the same were more fully set forth herein.
19. In the alternative to Count I, Plaintiff pleads an action in contract as a result of Defendants'
default for the accelerated balance due under the Contract in the amount of $14,183.82, plus appropriate
additional finance charges at the rate of $3.79 per diem on the balance due from September 30, 2002
and costs.
20. Under the terms of the Contract, Plaintiff is entitled to recover reasonable attorneys' fees
and costs of retaking possession of the collateral.
21. Contemporaneously hereunder, Defendants have been advised of his/her right to dispute
the validity of this debt, or any part thereof, pursuant to the Fair Debt Collection Practices Act 30 Day
Notice, attached hereto, marked Exhibit "3" and made a part hereof.
WHEREFORE, Plaintiff prays for the entry of Judgment on Count II against Defendants,
jointly and severally, in the amount of $14,183.71 plus continuing finance charges at the aforesaid rate of
$3.79 per diem from September 30, 2002, reasonable attorneys fees and expenses for retaking
possession and costs.
WELTMAN, WEINBERG AND RETS, CO. L.P.A.
..--. o cz s,u i e
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., LP.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#:02750500
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE
USED FOR THAT PURPOSE.
I t I I
EXHIBIT
~U~A~NST 11.lE SELLE~ 0~: GOODS OR SE~YICE~
T ~ ~ B~
~ YO~ A.~ ~N~ ~ U~ V~C~ ~E
~E IS PART ~ ~ ~
o~T~ o~ ~ w~ FO~
NOTICE TO BUYER: DO NOT SIGN THIS CONTRACT IN BLANK, YOU ARE ENTITLED TO AN
EsweX~..CT COpy OF THE CONTRACT YOU SIGN. KEEp IT TO PROTECT YOUR LEGAL RIGHTS.
SUYER ACKNOWLE~E~ RECEIPT OF A COpy CF '~IIS RETAIL INSTALLMENT
!
~-J(PIIDi I
.
:I~W, :this' law firm'.is reqfiired to'advi§e y00 t,hat unless'within'30 d~iY§~ aft~/' r6fi~i t of
this' notice you' di~pt/te'th~ vali~lit~t Bf'thi§ debt Or any portion ther66f the ~lebt:~ili;be assumed
'- '".'t lid ;bs] If.'~ i et O On' ;sent to us.ln'.w,ritlng, we are required to 'provide.you With
.' :]~/edfic&;~ion 6f.'th~ d~bt:, in the &v~t" within'.a 30'-'dhy p~rlo~l' y~)u' r~q6~st.in 'w~itin~l'..th~'. name of '..-
...the original 'creditor,'it will be ~r6vid'ed tO'you'if different, from the Current'creditor: In'the.event] .. ':
- th'at you 8isp~te t,h.e, debt ai~d'/.~r request 'tl~e"n~r~ ~f th'~ 9.rigin~l creditor: i'n ~riting Within' th~ '
.,'.] ".30~da .'perle ; fid. furth..er acti6n wi'il' be taken to. obtaili.'.a-Juogmen~:in'.th~ pending lawsuit untii- .-'
· :the 9erifi ati 'and nanle of the-od in I reditor'has.been.provided'to ye :'- "' "" ' ".: . . .
..-.. 'Thi~ law hrm"is' att"rapPing t~) colle~t.tfii~ ~l~bt for]ou) clier~t ~ndlah~, inforrflatioh'6btaihed '.: '
'.w~ll be'used fo~ that puro : '
: ":" ' T'he.ab'ov~'N~tic~ is B~in~'¢ven' pursuant to th~ Fai'r D~bt.Coli~ction Pra'~ti~:~§'Act'and'is'
' Separ~ite and distinct from"th'a.foreg0ing"Co/nplaf~t"whi~h:'must I~ 'responded to ih ~:onfoi'mi¢ . - -
... with the instructions therein. Because of the 'difference. ip time parameters, we.will not move :for.
· .D. efau 't Judgment for at lea~ thirty,. (30~ day~ fron~' the' date"of service 'of this Complaint 'upon
you, and if you request verification, we will not move for .Default 3.udgmen( Un~il .~/.reasonable
' ' · time after vefificati0r~' ha~' been pr~vide'd and after.the'expiration of.thi~,thirt~ (3(~) CaY period
VERIFICATION
Tho undersigned does hereby verify subject to the penalties of 18 PA.C,S. ~4904 relating
1o ur~swom falsifications to authorities, that he/she is Charles S Richards
(Name)
._,.A.,.,s.,.s_._i._s_t~,~.t:.. Tr~a,~r¢~r .... Of Beneficial Savings Bank _, plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing
Compl,.imt are true and correct to the best of his/her knowledge, information and belief.
WCr¢l o'_ 2'"/.50500
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05726 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL SAVINGS BANK
VS
DELANCY KYLE C ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DELANCY KYLE C
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of FRANKLIN County, Pennsylvania, to
serve the within COMPLAINT - REPLEVIN
On January 15th , 2003 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Franklin Co
18.00
9.00
10.00
97.60
.00
134.60
01/15/2003
WELTMAN WEINBERG REIS
Sworn and subscribed to before me
this R~z~t day o~
A.D.
Prothonotary
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05726 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL SAVINGS BANK
VS
DELANCY KYLE C ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
PERRY GINA M
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of FRANKLIN County, Pennsylvania, to
serve the within COMPLAINT - REPLEVIN
On January 15th , 2003 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
0 / 5/2003
Sheriff of Cumberland County
WELTMAN WEINBERG REIS
Sworn and subscribed to before me
this ~a~ day
~ A.D.
/ ! -Prothonot~r~
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05726 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL SAVINGS BANK
VS
DELANCY KYLE C ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn accerding te law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DELANCY MAC G
but was unable to locate Him in his bailiwick. He therefere
deputized the sheriff of FRANKLIN County, Pennsylvania, to
serve the within COHPLAINT - REPLEVIN
On January 15th , 2003 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
01/15/2003
Sheriff of Cumberland County
WELTMAN WEINBERG REIS
Sworn and subscribed to before me
this ~ day of~~
/
~-3 A.D.
rothonotary
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05726 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL SAVINGS BANK
VS
DELANCY KYLE C ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DELANCY MARIE
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of FRANKLIN County, Pennsylvania, to
serve the within COMPLAINT - REPLEVIN
On January 15th , 2003 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
oi/i5/2oo3
Sheriff of Cumberland County
WELTMAN WEINBERG REIS
Sworn and subscribed to before me
this ~k_ day of
A.D.
Prothonotgr~ '
In The Court of Common Pleas of Cumberland County, Pennsylvania
Beneficial Savings Bank
VS.
Kyle C. Delancy et al
SERVE: Kyle C. Delancy No' 02 5726 civil
~ow, December 6, 2002
hereby dep{ttize the Sheriff of Franklin
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland Count~, PA
Now,
within
Affidavit of Service
,20a ,
o'clock/~
M. served the
at
by handing to
and made known to
copy of the ori~nal ~z~~-~
the contents thereof.
So answers,
County, PA
COSTS
Sworn,5.an~ subscribed/.,before SERVICE
me ~ day offl(~ f ~. ,20 d 2- MILEAGE
~:~J//77),--~ L /7~ --- AFFI~A~T
~ I a[ncm A. Strine, Nota~ Public
/ L Y , ission Expires Nov. 4, 2004 ~
In The Court of Common Pleas of Cumberland County, Pennsylvania
Beneficial Savings Bank
VS.
Kyle C. Delancy et al
SERVE: Gina M. Pe~£y No. 02 5726 civil
NOW, December 6, 2002 ., I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby dephtize the Sheriffof Franklin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
within
upon __,~.1~~1~~
by handing to
,20D. a. , at _~.-,~,,%. o'clock /~ M. served the
and made known to ___~
of the
copy ori~nal ~
the contents thereof.
So answers,
Sworn a)'tll, subscribc,d/o_efore
me, thi~ day ol;A}L~- ~ ·
County, PA
COSTS
SERVICE
,2O '~-- MILEAGE
AFFIDAVIT
f~-~ $
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Defendants
No. 02-5726 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan
PA I.D. #-47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02750500
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Defendants
Civil Action No. 02-5726 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
COUNT I
Kindly enter Judgment against the Defendants, Kyle C. Delancy, Gina M. Perry, Mac G. Delancy
and Marie Delancy, above named, in the default of an Answer as follows:
For possession of the vehicle, more particularly identified as a 1996 Astro Riverbridge Mobile
Home, Serial Number AP960181.
COUNT II
Kindly enter Judgment against the Defendants, Kyle C. Delancy, Gina M. Perry, Mac G. Delancy
and Marie Delancy, above named, in the default of an Answer, in the amount of $14,574.08 as follows:
Amount claimed in Complaint
Interest from 9/30/02 to 2/11/03
at the contract interest rate of $3.79 per diem
TOTAL
$14,183.71
$390.37
$14,574.08
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance
with PA R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02750500
Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh,
PA 15219
And that the last known address of the Defendants is: 1466 Woods Road, Shippensburg, PA 17257; 1466 Woods
Road, Lot 14, Shippensburg, Pa 17257; 39 North Second Street, Box 362, Chambersburg, PA 17201; 39 North
Second Street, Box 362, Chambersburg, PA 17201
IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · . CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff :
VS. .~
Civil Action No. 02-5726 Civil Term
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY and MARIE DELANCY
Defendants
IMPORTANT NOTICE
TO: Gina M. Perry"
1466 Woods Road, Lot 14
Shippensburg,'-PA 17257
Date of Notice:
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO TH.E: CLAIMS SET F~RTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO
A LAWYER AT ONCE. 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 Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
WELTMAN,'WEINBERG & REIS CO., L.P.A.
William '1'. Molczan
PA I.D. ff47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955 ':
WWR ~02750500
IN THE;COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS' BANK
Plaintiff
VS.
Civil Action No. 02-5726 Civil Term
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY and MARIE DELANCY
Defendants
TO:
Kyle Delancy ?
1466 Woods Road
Shippensburg, 'PA 17257
IMPORTANT NOTICE
Date of Notice: -, I /~¢~-"~ /~2 ~
YOU ARE IN DEFAULT BECAUSE
YOU HAVE FAILED TO ENTER
A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE1 CLAIMS SET F~RTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO
A LAWYER AT ONC'~:. 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 Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
William T. Molczan
PA I.D. ~/47437
WELTMAN, WEINBERG & REIS CO., LP.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #02750500
· .?;
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GI"NA M. PERRY,
MAC G. DELANCY an.d MARIE DELANCY
Defendants '
Civil Action No. 02-5726 Civil Term
IMPORTANT NOTICE
TO:
Julie G. Doresett
cio Marie DelancY
39 North Secon. d Street, Box 362
Chambersburg, PA 17201
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI'FI'EN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM
i-
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,
;'.,
TELEPHONE THE FOkLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
GO TO OR
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
PA I.D. ¢~,7437
WELTMAN, WEINBERG'& REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
~2750500
IN THE~COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
Civil Action No. 02-5726 Civil Term
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY and MARIE DELANCY
Defendants
TO:
Julie G. Doresett
cio Mac G. De!ancy
39 North Secorid Street, Box 362
Chambersburg,.PA 17201
IMPORTANT NOTICE
Date of Notice:
YOU ARE Iiq DEFAULT BECAUSE YOU HAVE
FAILED TO ENTER
A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY ..AND FILE IN WRITING
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
WITH THE COURT YOUR DEFENSES OR
UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO
A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOELOWlNG OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PA I.D. fl47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue ,
Pittsburgh, PA 15219
(412) 434-7955
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according
to the Praecipe attached are not members of the Armed Forces of the United States or any other military
or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned
further states that the information is true and correct to the best of the undersigned's knowledge and
belief and upon information received from others.
WELTMAN, WEINBERG & REIS CO., L.P.A,.
Willia]~ ~L/. rv¥°lczan
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#02750500
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Civil Action No. 02-5726 CIVIL TERM
Defendants
N,OTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judament was entered against
you on ~
(xx) Assumpsit Judgment as to Count I for possession of the vehicle
more particularly identified as a 1996 Astro Riverbridge Mobile Home,
Serial Number AP960181 and Assumpsit Judgment in the amount of
$14,574.08on Count II plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx)
Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Julie G. Doresett
c/o Mac G. Delancy
39 North Second Street, Box 362
Chambersburg, PA 17201
Prothonotary
PROTHONOTARY (OR DEPUTY)
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Civil Action No. 02-5726 CIVIL TERM
Defendants
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Ju~lgm~nt was entered against
you on ~
(xx) Assumpsit Judgment as to Count I for possession of the vehicle
more particularly identified as a 1996 Astro Riverbridge Mobile Home,
Serial Number AP960181 and Assumpsit Judgment in the amount of
$14,574.08on Count II plus costs.
( )
Trespass Judgment in the amount
of $~ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx)
Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Julie G. Doresett
c/o Marie Delancy
39 North Second Street, Box 362
Chambersburg, PA 17201
Prothonotary
PROTHONOTARY (OR DEPUTY)
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Defendants
Kyle Delancy
1466 Woods Road
Shippensburg, PA 17257
Civil Action No. 02-5726 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Jud~men~t was entered against
youon
(xx) Assumpsit Judgment as to Count I for possession of the vehicle
more particularly identified as a 1996 Astro Riverbridge Mobile Home,
Serial Number AP960181 and Assumpsit Judgment in the amount of
$14,574.08on Count II plus costs.
( )
Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx)
Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
PROTHONOTARY (OR DEPL~T~~-
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BENEFICIAL SAVINGS BANK
Plaintiff
VS.
KYLE C. DELANCY, GINA M. PERRY,
MAC G. DELANCY AND MARIE DELANCY
Civil Action No. 02-5726 CIVIL TERM
Defendants
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or JudCmen~ was entered against
you on
(xx) Assumpsit Judgment as to Count I for possession of the vehicle
more particularly identified as a 1996 Astro Riverbridge Mobile Home,
Serial Number AP960181 and Assumpsit Judgment in the amount of
$14,574.08on Count II plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx)
Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Gina M. Perry
1455 Woods Road, Lot 14
Shippensburg, PA 17257
Prothonotary
P ROTHO~-O~AR~ (OR ~ E P U~l-y~