HomeMy WebLinkAbout07-1066Robert M. Reibstein, Esquire
Attorney I.D. No. 20456
705 East Montgomery Avenue
Narberth, PA 19072
(610) 6641999
CACV of COLORADO, LLC IN THE COURT OF COMMON PLEAS
1999 BROADWAY CUMBERLAND COUNTY, PENNA.
DENVER, COLORADO, 80202
V. No. C:- Fe
ALYSSA A. CARTER
1654 NEWVILLE ROAD
CARLISLE PA, 17013
CIVIL ACTION
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 attorney and filing in writing with the courtyourdefenses orobjections
to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without
further notice for any money claimed in the complaint or for any other claim or relief requested by the
Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER,
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE.
Court Administrator
One Courthouse Square, 4'i Floor
Carlisle, PA 17013
(717)-240-6200
'This communication is frorr; a
debt c0ect:^ -. i m is art
attemr pt to cu's??,?
any intorrnxiora J ; <,,. rliil
be used fur that pui P06e.
Robert M. Reibstein, Esquire
Attorney I.D. No. 20456
705 East Montgomery Avenue
Narberth, PA 19072
(610) 664-1999
CACV of COLORADO, LLC IN THE COURT OF COMMON PLEAS
1999 BROADWAY CUMBERLAND COUNTY, PENNA
DENVER, COLORADO, 80202
V. No. ell
u
ALYSSA A. CARTER
1654 NEWVILLE ROAD
CARLISLE PA, 17013
CIVIL ACTION
COMPLAINT
1. Plaintiff, CACV of Colorado, is a corporation with a principal office located at 1999
Broadway, Denver, Colorado.
2. Defendant, Alyssa A. carter, is an adult individual residing at 1654 Newville Road,
Carlisle, Pennsylvania.
3. On or about January 22, 2004, Defendant entered into a written Pennsylvania Motor
Vehicle Installment Sale Contract with Superior Owned of Mechanicsburg, Pennsylvania relative to the
purchase of a 2000 Ford Explorer automobile calling for Defendant to make 60 monthly installments of
$393.32 which was contemporaneously assigned to Household Automotive Finance Corporation. A true
and correct copy ofthe Retail Installment Contract and Security Agreement and Assignment are attached
hereto made part hereof and marked as Exhibit "A".
4. Defendant breached the terms of said written agreement by failing to make payments when
due entitling Household Auto Finance Corporation to repossess said vehicle.
5. Said vehicle was repossessed on or about December 22, 2004 whereby Defendant was
given Notice of Repossession, Right to Redeem, and Notice to Sell Property by certified mail dated
February 3, 2005. True and correct copies of certified mail receipt and the repossession invoice are
attached hereto made part hereof and marked as Exhibits "B" and "C" in their entirety respectively.
6. After Defendant failed to execute the right to redeem the subject vehicle, it was sold at
public auction on or about October 22, 2003 for a net sale price of $4,650.00 whereby there remained a
deficiency balance due Household Auto Finance Corporation the sum of $5,769.18. True and correct
copies ofthe auction sale documents and notice of deficiency balance are attached hereto made part hereof
and marked as exhibit "D" in it entirety.
7. On or about May 4, 2005 for value received, Household Auto Finance Corporation sold
and assigned all of it's right, title and interest in said Pennsylvania Motor Vehicle Installment Sales
Contract to Plaintiff. A true and correct copy of the notarized Certificate of Purchase is attached hereto
made hereof and marked as Exhibit. "E".
8. Per Exhibit "A", Plaintiff is entitled to continuing finance charges at an annual rate of
15.95% on the unpaid principal balance claimed from September 14, 2006 through current date in the sum
of $2,629.46 and continuing at the rate of $3.78 per day.
9. After repeated demand, Defendant has failed and refused to pay all or any part of the sums
owed Plaintiff on said account.
.....,.-- ?,.y ?.--Im. T..
F0RM PA 23DC-SLC (3/03) SIMPLE INTEREST FOR DEBT CANCELLATION MUST ACCOMPANY THIS CONTRACT.
PENNSYLVANIA-
MOTOR VEHICLE INSTALLMENT SALE CONTRACT, Dated JANUARY 22, - 2004 '
A F Amount Financed Total of Payments - Total Sale Price
ANNU
L
PERCENTAGE RATE INANCE.
CHARGE The amount of credit provided The ami tint you will have paid after you The total cost of your purchase on
The cost of your credit as ' The dollar amount the to you or on your behalf. have made all scheduled payments. credit, including your downpayment:,, _
a yearly rate. credit will cost you.
.
of S 111111111111111-M
15.59 % S 7279.20 S 16320.00 S 23599.20. S 24399, LIS
No. of Payments Mount of Payments. When Payments AreDue
tie I s 391.32 .Alonthly, i ift 02/21/2084
I s N/A
Security: You are'giving a security interest in the motor,vehicle"beini.
purchased.
Prepayment:. If you payoff early, you will not have to pay a penalty. ,
Filling Fees: > O. w
Late purge: If a:paymenl is late, you will be charged 2%of the portion of the paymentwhich is late for each month, or parlof a month greater than 10 days,thal h remains dnpaid. '
See below and any other Contract documents for any additional information about nonpayment, default, any required repayment in lun before the scheduled date and prepayment
refunds add penalties. " e means estimate
any trade-in,is free from Fier, dawn; encumtirapce or security interest, except as.shorn In the Itemtrabal of Amount Financed as the Oren Payoff.
PROPERTY INSURANCE: You may 0iose the person through whom insurance is obtained against loss or damage to the Vehicle and against Trade-in
liability irising opt of use or ownership of the Vehicle. In this Contract, you are promising to insure the vehicle and keep it insured. Value of Trade-In
DEBT CANCELLATION (GUARANTEED AUTO PROTECTION) AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS-A CONDITION OF THE S.
CREDIT. This agreement will not be:provided. unless you sign below, agree to pay Ureadditional *charge, and sign the separate disclosure and Lien Payoff to: _
agreement page, which is. part of this Contract This agreement will apply during the entire term of the Contract- This agreement may not cover $
your entire indebtedness; seethe MAXIMUM PROTECTION amount stated in the separate disclosure and agreement • • Unpaid.Cash Price
IF YOU DO NOT MEET YOUR CONTRACT
In this Contract i OBLIGATIONS, YOU MAY LASE THE MOTOR .
we are " .' SLPERIOR PREOWNED VEHICLE AND PROPERTY THAT YOU
the SELLER. ' 6110 CARLISE PIKE MECHANICSBURG PA 17050 - BOUGHT WITH THIS CONTRACT,. AND/OR
Name Address Zip Code MONEY ON DEPOSIT WITH THE ASSIGNEE:
•
County CUMBERLAND and Beyer. AM
This Contract is between Seiler
ALYSSA A CARTER dielosures have been made by Seger. Selby
You arc t• , inter" assign this Confined totheAssignee.•
the BUYER(S). 114 COMMERCE ST QtA(NBERSBURG PA _ 172ei
01'AmountFinanced
Itefnitation
Name(s) Add resales) Zipcode($) . .
cub Price (including optional service
County contract and/or warrentims the
•
If there is more than one Buyer, eich promises, separately.aed together, to pay all sums due us and to perform all agreements in this Contract
u /
,
amount of -S
paid to
TRADE-IN: &salestaxoftuin
You here traded in Cash Price
the following vehicli:
Year and Make' Description
i Call,
Cash Downpayment.
It a balance is still owing on thi vehicleyou he" traded in, the Seller will pay off this.amount on your behalf. You warrant and represent to us that . S
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nce Y!
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alth Inisuranee
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& A
id For
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VEHICLE: You have.agres to purchase, under the terms of this Contract, the following motor vehicle and its extra equipment, which is called
For N/A
the 'Vehicle' in this Contract. To
HL11 YM 1111111111111 SeEk . R& ityl& Mg. DL buck IM Capacity Sldat Number S ! ''
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R
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K
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3
6
For . N/A
D
TRUC
EXPLORER
XLT
1FMZU8
P0YZC
USED 2000 FO
SN
7385
Other
AM
FM
5 S
d
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Sb
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.
.
. _
.
. _
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Equ
with - A C. - P.W. _":FM 7iDe _ Vinyl Top . $ '.N/A
•'
ASSIGNEE: We may assign this Contract ind Security Agreement to f sales fine= company which is:the'Asiignee.' If the Assignee assigns. for
the Contract to a subsequent assignee, the term also- refers to such subsequent assignee. Alter the isstgnment, all rights and benefits'of the To
SelleCih this Contract and in the Security'Agreament shall belong to and be enforceable by the Assignee. The Assignee will notify you when
and it Seger makes an assignment. ?ptfalL.o {p- F 1 N AATC e
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For
N/A
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CO-SIGNER: Any person signing my For
all sums due and to perform all a--
and
CO-OWNER: Any person signing I Amount Financed
C rs
N/A
Ooeument Preparation Fee
SERVICE CONTRACTOR WARRANTY AGREEMENT IS.VOLUNTARVAND-NOT REQUIRED AS A'CONDITION OF THE CREDIT. The service contract S
or warranty agreement will not be provided unless you sign the separate agreement with the third party provider, who is not the Seller named Paid to Others on Your Behalf
above,.and.agree to.pay the additional charge. This section does not apply to,any warranty that you-may receive for which there is not separate' To Public Officials loc.
charge..
License, Tags and Registration
CREDIT INSURANCE IS NOT REQUIRED: Credit.Lte Insurence.and Cradt Accident& Health (Disability) Insurance are not required to obtain. _
72
M
credit, and wig not be provided unless you sign below and agree to'•pay the additional cosas):Tlsase read the NOTICE OF PROPOSED CREDIT. -
insurance
INSURANCE on the reverse-side, Your insurance. certificate or,poficy will tell yowthe MAXIMUM amount-of insurance.available. AN Lien Fee
.
purchased willbe for the term of the credit We may-receive a financial benefit from your purchase of credit insurance. $
.By signing, you select Single Credit Life Insurances .What is your By signing, you select Single Credit Accident & •• What is your . Taxes Not Indudid in s ,rice
which costs $ N/A age? Years 'Health insurance, which costs i N/A. age?-Years S ;
.. To
Signature of Buyer to be insured lwSingle Credit Life Insurance . -NS+?ureofBuyer tobeinsured forTngle Credit kcidem&Health Insurance $ ':N/A
ek
tJdnt C
i
b
th
dit
B
si For Messenger Service
By signing, you both select Joint What are . s
c
re
o
n& you
Y
p
What are • Percentage ' To
CreditUfainsurance,which costs SN- yourages?; • Acdderd&HuRblraurarimwhich =is$ N; yoursges? to be
- insured S N/A
For
•t To Credit Insurance Company
Si--h omes of both On to be insured (or Joint Credit ers to be insured for Joint
Si tones of both Bu - N/A y
Type of Debt Ciniellatiori Allreement , Charge Signature
Guaranteed auto protection (GAP( S N/A ' By signin& ydu select guaranteed auto protection
' Signature ol Buyer '
Type of Debt Gncellation Agreement Charg Signature
Guaranteed auto protection (GAP) S N/fi By signing, you select guaranteed auto protection
I
Signature of Buyer
.S
Optional Debt rice lotion
Document Preparation Fee
SERVICE CONTRACTOR WARRANTY AGREEMENT ISNOLUNTANT ANU•NUI a DUIReU AS A WRUlltun UP Inc 611eMl I. I Be SCrsa:e wnua
of warranty agreement will not.be provided unless you sign the separate agreement with the third parry provider, who is not the Seger named Paid to Others on Your Betulf
above, and.19. to.pay the additional charge. This section does not apply fit-any warranty that you may receive for which there is not separate' To - Public Officials for:
charge .'
License, Tells and Registration
CREDIT INSURANCE IS NOT REQUIRED: Credit Life' Insurance-and Credit Accident & Health (Disability) Insurance are not requireddo obtain s 1 -
credit and wig not be provided unless you sign belowand sgree.to:psy the additional msft Please read the.NOTICE OF PROPOSED CREDIT .
INSURANCE on the reverse'side. Your-insruance•cer ificate or,policy will tell you the MAXIMUM amount of insurance available. All.imurence Lien Fee
purchased will be for the term of the credit'We.may receive a finanaatbenefit from your purchase of credit insurance. S
By algniiig you select Single Credit Life lmurance i -What is your -By signing you select Single Credit Accident & What is your Taxes Not Included in s rice
which costs $ „u/A agel_ Years Health Insurance, which costs $ N/A &gN. - Years S
To
Signature of Buyer to be insured for Single Credit Life Insurance Signalfee of Buller to be Insured for SkIBe Credit Accident & Hub Insurance
S N/A
Signing, you both select Joint What OR By silift you both select Jaw Credit Wtw are --.P For Messengei ' Service •
BY
•
Credit Life Insurance, which costs S N!o; your ago? kcideet It Haab Insurance, which cods $ A you ago+, lobe ' To
'r.•. - insured' $ ' N/A
1 1: % For
! ?> To Credit Insurance Company
•
$
Signatures of both Buyers to beihsured for Joint Credit Signatures of both Buyers to be insured for Joint For'
. '
Ule Insurance. . .-Credg Accident & Health Insurance
To
.r r -. - - Insurer I N/A
VEHICLE: You hrve.agree to purchase, under the terms of this Contrsct the following motor vehicleand its extra equipment which is celled For
the 'Vehicle' in this Contract. To .
mu YMlladMau Skills . 1111111 iXIII NKs L ?WAIMCanciltt RNNum4e[ $ N/A
USED 2000 FORD' TRUCK` EXPLORER 'XLT 'SW IFMZU83POYZC67385 For '
Equipped .. A.T. - P.S. - AM-FM.Sterso . _ 5 Spd. Other To
with A.C ' P W I[4-FM Tape Anil Top " S N/A , e
ASSIGNEE: We may assign this Coritrect end Security Agreementto f sales finance company which'is the'Assiinee.`If the Assignee assigns For
the Contract to a subsequent assignee, the term also refers to'such subsequent Assignee. After the assignment, all rights and benefits'of the To
Sellrff in this Contract and in the Security -Agreement shag triton to and be info able by the Assignee. The Assignee will moldy you when $ N/A a
and it Seger makes an assignment ?o llfle.0 n ?j P 1441 ttATW
', ZO ( fticl h YO?tF &trCs L)r. y For
$ ' ".N/A
CO-SIGNER: Any person signing the Ca-S'igner's Agreement below promises separately'and together with all CaSigner(s) and Buyer(s), to pay For
all sums due and to perform all agreements in this Contract. Co-Signer will not be an Owner of the Vehicle. Amount Finamced
CO-OWNER: Any person signing the Co-Owner's Security Agreement below gives us a security interest in the Vehicle and agrees separstely and =
together with all Cc-Ownef(s) and Buyer(s), to perform all agreements'in the Security Agreement and all other parts of this Contract exceo-the -
'Promise to Pay' section. We may retain a portion of amounts marked'
T61IS:•The terms shown in the boxes above are part of this Contract
PROMIM-TO PAY: You agree to pay us the Total Sale'Price for the Vehicle by making the Cash Vehicle, including insurance proceeds. The Assignee may set-off arty amounts due and.unpaid
Downpayment and assigning the Trade-In, if shown aboyq on or before the date of this Contract under this Contract against any of your.money on deposit with Assignee. This includes any
and paying us the Amount Financed plus interest You promise to make paymentsm accordance money which is now or may in the future be deposited with Assignee by you. Assignee may do
.with the Payment Schedule. You promise to make payments on•or before-the same day of each thismithout any prior notice to you., -
month as the first payment due date. You agree to pay all other, amounts'which may become due ADDITIONAL DISCLOSURES; TERMS AND CONDITIONS:
under the tams of this Contract You agree to pay the Seger or Assignee-cests'ofsug. You also Disclosures: Before signing this Contract be sure that you receive and read the Disclosure to
agree to pay remonable-etterneys, fees if Seller or Assignee hires an, aftorney to collect amounts Buyer,
due under this Contract or to protect of get possession of the Vehicle..You agree to make
psymenh at the place or•lo-send,paymeals to the address which the Assignee most recently Terms and Conditions: Before signing this Contract be sure you receive and read the
specifies in the written notice to you following, if marked X, which are additional pages to and•pift of this Contract
'SECURITY AGREEMENT: To secure the payment of all sums due and the performance of. all ® This Contract continues on thexerverse side..,
required obligations under this Contract you give.a security1rderest in the Vehicle, in all parts
(celled 'accessions) attached to the Vehicle it any later Ume,-and- in any proceeds of the •O Debt Cancellation (guaranteed auto protection) separate disclosure and agreement
T • By signing'bebw; we agree .Ao sell the vehicle to you under the terms of this ContrseL NOTICE 'TO BUYER=DO NOT-SIGN THIS CONTRACT IN BLANK. YOU ARE"'
ENTITLED TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO '
PROTECT_ YOUR LEGAL RIGHTS.-
SELLER BUYER' 2 (SEAL) -01 BY iPUYER s' (SEAL).
. i Date Date
CO-SIGNER: OU HOULD READ THE NOTICE TO COSIGNER, WHICH HAS BEEN GIVEN TO YOU ON A SEPARATE DOCUMENT, BEFORE
SIGNING THE CtF-SIGNERS AGREEMENT.
CO-SIGNERS AGREEMENT: You, the person (or persons) signing below as "Co-Signer;" promise to pay to•ui all sums due on this Contract and to perform all
agreements in this Contract. You intend to be legally bound by all the terms of this Contract, separately and together, with the Buyer. You are making this piomiie to
induce us to make this Contract with the'Buyer, even though we will use the proceeds only for the Buyer's benefit. You agree, to pay even though we may-not have
made any'lihor demand for paymelit'"n the BuXar or oxercised our security interest. You also acknowledge recei6ing icompleted-copy'of this Contract.'
(SEAL)
Co-.Signers Signature Address Date
(SEAL) '
.. Co-Si;hers Signature Addrea's Dale
CO-OWNER'S SECURITY AGREEMENT: You, lase person signing below as "Co4)wner," together with the Buye%'orkoiherJyiae being'all the Owners of the yehide,
give us a Security Interest in the Vehicle identified above. You agree to be bound by the terms of the Security Agreemenuand all olher'parts of this Contract except she
"Promise To Pay" section. You are giving usthe skirity interest to induce its to make this Contract with the Buyer, and 4o satire chi payment by the Buyer oC all sums due
on this Contract. You will not be?responsiblc for.any ;ficieney whcWmiglil be duel after'repossession and sale of.llie Vehicle. .
(SEAL); •' --1-fi?2001
Co-Owner's Signature Address Da e
BUYER, CO-SIGNER AND CO-OWNER, IF APPLICABLE, ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS
CONTRACT AT THE TIME OF SIGNING, INCLUDING THE ADDITIONAL DISCLOSURES AND PAGES LISTED IN THE SECTION
CALLED ADDITIONAL DISCLOSURES, TERM AND CONDITIONS.
!BUYER BUYER CO-SIGNER CO-SIGNER OR CO-OWNER
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION.
BANCONSUMER FORM PA 23DC-SIC 131031 ORIGINAL - venue - DEALER COPY - Geary • BORROWERS/COSIGNERS COPY • Pink - COPY - Gotsrmed 0 2003 BANCONSUMER SERVICE, INC.
ADDt_T;IONA TERMIS:ANB&ONDITIDNS
1. IfWiTHE TOTAL•OF-PAYMENTS•IS:COMPUTED: The Total4of Payments is the:sum of the • choice of whether or not to advance any-money for.these purposes. Such insurance will be,
Amount Financed' and the Finance Charge.'The Finance Charge consists "solely of interest limited to an amount,nal greater than you -owe'ori this Contract. THE, INSURANCE WE'
Computed daily on the outstanding balince of the Amount Financed. The Finance Charge PURCHASE MAY BE•SIGNIFICANTLY MORE EXPENSIVE-AND PROVIDE YOU LESS'COVERAGE
shown on the front side has been computed on the-assumption that we will receive all ..THAN INSURANCE YOU COULD PURCHASE YOURSELF. ' I . 1 'r '
-payments on their scheduled due dates. We will add any money we advance on your behalf to the balance-on which we impose
2, COMPUTINGIIJI•TEgES,T: We will charge•interest on a daily basis on the outstanding Finance Charges at the Annual Percentage Rate of this. Contract You agree to repay the
balance subject to interest on each day of the loan term, including any period for which.a late money advanced as we alone'may specify: (I) immediately on demand, or (ii) along with your
charge is also imposed. The daily interest rate is equal to the Annual Percentage Rate divided monthly payments. If we choose to allow you to repay the.money advanced along with your
by the number of days in that calendar year. Buyer agrees that because interest is calculated monthly payments, we can.choose the amount of these payments and how long you have to.
pn• a daily basis tote payments will resultiin additional interest (artd, it applicable, a late
charge).- dy.pay `ents•di 4result in less interest-being charged! Early an te`s'tate payments repay.iyf an?r?of qVa rights stated irrSthjs paragraph are not permittedlg,lawl we still have the
. other ngfifs m€nCxined. Our paynitn s on yawl behalf will not cure your$allure-lo•perform,
will cause the amount of the final payment to change. your. promises in this Contract
3.,LATE CHARGE: Buyer agrees to pay a late charge for any payment not'made within 10
days after its due date. The•late.charge will be 2% per month on the'unpaid'amount of the- 12. DEFAULT: In this paragraph "You" means the Buyer, Co-Signer and Co-owner; or.any one
of them. You will be in "Defaulr''of the.Contrecl if any one or more of the following.things•
payment We will consider any part of a month in excess of 10 days to be a full month. The
late charge will be due when earned. No late charge.will be due if the reason that the c+CA rat 8d
dun
or.be?:
do not
any payment o
.Yo
' 'a
payment is late is because, after default the entire outstanding balance on this Contract is keep
.
u
Allhii Contractor ctor
not keep any promise you made'ii+l6ii Contr , ,.
you
b. You da
due. Me fate charge will be due if the only reason that the payment is late is because of•a late ' .
- -
Note, Loan or Agieement.
You do not keep any promise you made in another Contract
c
charge assessed on an earlier payment
4. APPLICATION OF PAYMENTS: We will apply.paynients;in the following order of priority,. ,
.
.
with Seller or Assignee; or
d. You made any untrue statement in the credit application-for this Contract; of.
first to interests and then to late charges, tees, principal and any other amounts you owe in
,
e.. You committed any forgery in connection with this Contract or
'
the order that o
to full or in WN the amount owed on this Contract at any
PREPAYMENT: T: You u may prepay round by a court'
I. You die, are convicted of a trine involving fraud or dishonesty, or are
-
,
lf you'prejiay the Contract imparL-you agree lo'Continue* to make
time without peoslty. with-jurisdiction to do so to be incapacitated; or
-' '
.
regularly scheduled payments until you pay all amounts due under this Contract. This will g.You. file bankruptcy or insolvency proceedings, or anyone files bankruptcy or
reduce the'number,ot payments you.wil make.
WAIVERS
6 insolvency proceedings against you; or
h. You take the Veh'Ide outside theHniledSUtevor•Canada without•pur wrilteo i:orisent or
.
.
a: WAIVER- BY. SELLER AND ASSIGNEE: We and Assignee waive the right to treat ffny.IDT T i.pYnu?uso the fticlegF all?lsomeone;etserlovse t into lay that cruses lmotito be
=
property as security for the-repayment of this Contract, except for the Vehicle and the other
3Ku4ty specifically mentioned in this Contract -
covered by your IrNurance: or•
j. You do'som'ething that causes the Vehicle to be subject to confiscation by government
b. WAIVERS BY BUYER, CO-SIGNER AND CO-OWNER: You sgred`161dRe fll'&yments on.- authorlries; or
or before they are due without our having to ask. If you don't, we may enforce our rights k The Vehicle is lost, stolen, destroyedlor•damaged;beyg3tp onomical repair, and not
without notifying you in advance, You give up any fight you may have-to require that we
f
f
i
ht
i
t
- fixedorfounAwitbo.a?oatile,lime-or,? z?. rrn,r
to`tikb'the'Yehiele or-y?urMmoneY' ot?deposit with Assignee by
'N ' Aloitier cNaKir•tres
t &
ore we en
orce
our r
g
s aga
ns
enforce our-rights against some other person or.properly be
you. You igree that-we may give up our rights against same other person but not against you: :
-
. legal process. I I .. ,
You waive due diligence in collection end-al defenses based on suretyship and impairment of • 13. OUR RIGHTS IF YOU ARE IN DEFAULT OF THIS-CONTRACT: It you are in Default of this
collateral orsecurtty.' '' - ' - • Contract, we may enforce our rights according to law. We may also do the things specifically
7: INTEREST AFTER MATURITY AND JUDGMENT: Interest at the rate provided in this mentioned in this Contract We may do one of these things and at the same time or later do
Contract shall continue tD*prue on the unpaid balance unit paid in full, even after maturity 'anothir. Some of the things we may do are the following: - ,
and/or after we get a judgment against you for the amounts due. This will apply even N the a..ACCELERATION: We can demand that you poj.to us the entire unpaid balance owing
maturiiydccuts because of acceleration. If at any time interest as provided for in this on the Contract and all unpaid Finance Charges and other money due. You agree that you wig
paragraph is not permitled'by'Iaiv, interest shall accrue at the highest rate allowed by pay this money to us in one single payment immediately upon receiving our demand: • '
applicably law beginning at that time. "' - b. REPOSSESSION: We can repossess the Vehicle, unless prohibiteil'by law. We can do
8. YOUR PRQMISES!AgOUT OUR SECURITY INTEREST: You will not permit anyone other this ourselves, have a qualified person do it for us, or have a government official (by replevin)
than us to obtain a security interest or other rights In the Vehicle. You wig pay all tiling fees do it for us. You agree that we can peaceably come on to your property to do this. We may
necessary for us to obtain and maintain our security interest in the Vehicle. You will'asslst us ' like any other things found'in the Vehicle, brat will return these things to you it yod ask' If you
in having our securillyrinteilest rated on the Certilicale of Title to the Vehicle: You will not sell want these things back, you may reclaim them`wlhin thirty (30) days of'our mailing you a
or give away the Vehicle. If someone puts a lien on the Vehicle, you will-pay the obligation and , Notice of Repossession. If you do not reclaim the things found in the•VIII6 wlhin`thot time,
clear the lien, we may dispose of those things in the same manner as. the:motor vehicle:'Y6 agree that we
8. YOUR PROMISES ABOUT THE VEHICLE: You will keep the Vehicle in'good.condition and in repossessinj tie Vehicle and taking it to rplacefor•storage.
may use your license plates
:repair. You w0payiall taxes and chargeson the Vehicle. You will pay all costs of maintaining . ,
,
"c. VOLUNTARY DELIVERY: We can'ask you to give ui the Vehidi-if eT'rea"sonably
the Vehicle. You will not abuse the Vehicle or permit anything to-be done to the Vehicle. which convenient place. You agree to give us the Vehicle H we ask. "
will reduce its value, other than for normal wear and use. You will not use the Vehicle for
You will not move the Vehicle from your address shown on
illegal purposes?orfor hire or lease . If. DELAY'IN ENFORCEMENT: We can delay enforcing our-rights under this Contract
.
the front of this Contract to anew permanent place of garaging without notilying-us in , without losing any rights.
' 14. SOME THINGS YOU SHOULD KNOW-IF'WE'REPOSSESS'THE VEHICLE: If we'repossess
advance -
10. YOUR PR&WSESWUT INSURANCE: You will keep the Vehicle'insured against tire,
10.
theft and collision unit all sums due us are paid in'full
The insurance coverage must be
oHiciaL(by replevinl:.'
NOTICE: go will send you a Notice of Repossession to your last address we know about.
a
. NOTICE:
.
satistaclery toes and protect your interests and our,inlerests at the time of any insured less.
' tell you how to buy tack (redeem) the Vehicle. You will NOT have the right t.
This
reinstate the Contract This means you will have to pay the total balance on the Contract and
on the policy. The insurance must be wriltemby
The insurance muss name us as loss-payee older amounts due. You may not gel the Vehicle back by paying delinquent installments. This
an insurance company qualified to do business in Pennsylvania and licensed to sell.insurime • Notice will tell you other informotion.tequired'b-y law.
In the state where ttWtVehI* is permanently garaged. The insurance policy must provide us'•+ : 6•REDEMPTION: You have the
righl'lo buy trick (redeem) the Vehicle within'15 days of
,
with at least ten (10) daysydor written notice of any cancellation or reduction in coverage. On
request•you shall deliver the policy or other evidence of insurance coverage to us.. InAtle: , the mailing of the Notice and'al any liter tiine.before we,sell the Vehice. If'you rideem the
event of the loss or damage to the Vehicle, you will immediately notify us in writing and file a Vehicle, we will deliver the Vehicle to you it a place as provided by law, as soon es is
proof of loss with the insurer. reasonably possible,. but in.notmore than ten (10).business days of our.receipt of-the-funds
a, OUR RIGHT Jq-FILE PROOF OF LOSS: In the event of any loss or damage to-the - ' required: lf.you do not redeem, you,give•up all claim to lhe.Vehicle. ., n•, r'0:, '
Vehicle, it you•fil orreluse•to file a claim or proof of loss`wlh'the insurance company, you . •c. SALE: If•youdon't redeem,:we will sell the Vehicle. The money received at sale will.be
agree that the Seller, Assignee; any subsequent assignee, or any authorized employee of•any used to pay costs and expenses you.owe, and then to pay the amount you.owe en the
of them ('we') may file a proof of loss.wlh the insurance company, in your name and acting- Contract r
as your agent„ vigh Respect-lo-the insured claim. You agree that you do not have the right to d. SURPLUS OR DEFICIENCY: If there is money left we will pay it to the Buyer. If There is
and will not revoke the power you have given us to fide a proof of loss You agree that we may . not enough money from the sale to pay what you owe, Buyer and Co•Signer agree to pay what
exercise this power for our benefit and not for your benefit, nc apt as provided in this
' is still owed to us.. 0N N
Contract and" law. e. EXPENSES: You agree to pay the costs of repossessing, storing, repairing, preparing for
b. OUR RIGHT TO ENDORSE INSURANCE CHECKS: You agree thatthe Seger, Assignee, sale and selling the Vehicle as may be slowed by law. These costs will only be due if:..
any subsequent•a&tignee, or an authorized employee ot.any of them ('we') may endorse your
to any check; draft or other instrument we receive in -payment of
acting iV
;Fr agent
name 1. Default exceeds fifteen (15) days at the time of repossession; T + '
'
'
,
.
,
,
an insured loss or return of insurance premiums You agree that. you do not have the right to costs are actual, nedessary and reasonable; and
,
2. The amount of
+ 3. We.caO prove the costs were paid.
and will not revoke the power you have given us to make your. endorsement You agree that y-15
4111S AND'PERSONAL REPRESENTATIVES;BOUND: After your death; this Contact shall
we may exerciaeIthis power for our benefit and not for your benefit except is provided in this
Contract and Dy hew, .
be enforceable against your.hdrs and personal representatives of your estate.
- c. USE OF PROCEEDS: We may apply any imunnce proceeds we receive to, repair or
replace the Vehicle if, in our opinion, it is economically feasible and you are not then in 16. GOVERNING LAW:,Thes Contract is to be interpreted according to the law of Pennsylvania.
•17. SEVERABILITY OF PROVISIONS: If-for anyreason any part of this Contract shifl.become
default of this Contract. Otherwise,-we will apply the insurance proceeds to reduce•the unpaid illegal, void orvnenforceable, that par shall not be a part of this Contract
rtNn:Lt UK InsurUlNt;t: IT you nu re Keep Your promises to pay nlmg Zees, Taxes, (lens or
the costs necessary to keep the Vehicle•in good conditan and repair, we may advance any UNLESS WE HAVE GIVEN YOU A SEPARATE WRITTEN WARRANTY OR UNLESS SELLER
money you promised to pay. If you fail to keep your promises about required insurance, we ENTERS INTO ASERVICE CONTRACT-WITH BUYER WITHIN-,90,OAYS FROM THE. DATE OF
may advance money to obtain-insurance to cover loss or damage to the Vehicle. We have the : THIS CONTRACT. . . . , , • :-
Buyer's Guide Window Sticker. If the Car which is described on the face of this Contract has a Buyer's Guide Window Sticker required by the Federal
Trade Commission Used Car Trade Regulation Rule, the following notice applies: - ' I I
Tfielriformation you see on the window form,for this?Vehicle is,4art,of this.Contrict. Inferflt?lion on•te window farm overrides any
:IJ:J „ '. ? " VV VS U_ru
LC:. t L'J i+Y `rrF7L.rl VIC I J 713ri J .2 N
conirary provisions in the contract of sale. I
NOTICE-ANY, HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND. DEFENSES WHICH THE DEBTOR COULD
ASSERT AUAINST THE SELLER OF GOODS OR SERVICES OBTAINED' PURSUANT HERETO OR WITH THE-POCEEDS HEREOF.'-RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT, EXCEED AMOUNT'S PAID BY THE DEBTOR HEREUNDER. . ;
p • I NOTICE OF PROPOSED CREDIT INSURANCE'.
The signer(s? of lha Contract here6ytpke(s).notice that Group Credit Life Insurance'coverage or Group'Credii Accident anti Disability Insurance coverage will be applicable to this
Contract if so marked•on the front of this Contract, and each such type of coverage will be written by the'insunnce company named. This insurance, subject to acceptance by the
insurer, corers only the person or persons signing the request for such insurance. The amount of charge is indicated for each type of Credit Insurance to be purchased. The term of
insurance will commence as of the date the indebtedness is incurred and wig expire on the original scheduled matirify dale of the indebtedness. Subject to acceptance by the insurer
and within 36alis, there will be delivered to the insured debler(s) a certificate of insurancp more fully describing the.insurance. In the event of prepayment of the indebtedness, a
refund of insurance charges will be made when due.
NOTICE::SEE OTHER SIDE FOR IMPORTANT INFORMATION! ,
-. -- ... _ --- __..._._,...o -- ... r9. Wait jnjnua Tuu anuutu anew It Wt KtrV55t?3 rnt vtnrctt; It We repossess
advance. r' without-using a government official(by replevin):. '
theft and YOUR cPllisio ,until all BOUT sums s due due us-are paid s-are paid will keep the Vehuiclerance insured coverage magainst tire, a NOTICE: We will send you a Notice of Repossession to your last address we know about.
the tat sn until' interLests The at ins the time of ust be This NoticirWil tell you how to buy back (redeem) the Vehicle. You ivil NOT have the right'to
The isatisfactorye s and protect your interests and our inter any a written r reinstate the Contract This means you will have to pay the total balance on the Contract and
an inssuranc urance compa ecompsny name us qualified is t to do *loss-p' business s in the Penpolicy. nsylvania The andinsurance.licensed to must sell l insurarato b:ey oilier amounts due. You may not get the Vehicle back by paying delinquent installments. This
in the state while tR'LVehicle i permanently garaged. The insurance policy must provide us':: Notice willtiiu jou other information required bj law.
.with at least ten (10 days prior written notice of any cancellation or reduction in coverage. On • • : U. REDEMPTION: You have lhe-r ht to buy back (redeem) the Vehicle within'15 days of
'request you shall deliver the policy orother evidence of insurance coverage to us. InAh the mailing of the Notice and'al any later time before we sell the Vehicle. If'you redeem the
event. of the-loss or-damage to the Vehicle,.you will immediately notify us in writing and file a Vehicle, we will deliver the Vehicle to you at'a place as provided by law, as soon as is
;proof of lass wilh.the insurer. _ ..reasonably possible, but in not.more than ten (10).business days of Durseceipt of the funds
a. OUR RIGHT T, .FILE PROOF OF LOSS: in the-event of any loss or,damage todhe - required: ll.you do not redeem, you.give up all claim to the Vehicle. , ti I 'f
'Vehicle, if you•fi1 ,.FILE file a claim or proof of loss-with the insurance company, you . c..SALE:.It-you don't redeem,,we will sell the Vehicle. The money received at sale will be
agree that the Seller, Assignee, any subsequent assignee, or any authorized employee of any used to pay costs and expenses you owe, and then to pay the amount you.owe on the
..of them ('tine") may file a proof of loss mith the insurance company, in your name and•+cting. Contract . - • . •
as your agent,%Kiespec?to:the insured clam. You agree that you do not have the right to d. SURPLUS OR DEFICIENCY: It there is money left, we win pay it to the Buyer. If there is
and will not revoke the power you have given us to file a. proof of lass You agree that we may not enough money from the sale to pay what you owe, Buyer and Co-Signer agree to pay what
,exercise this power for our benefit and not for your benefit, except as provided in this . is still owed to us.
:Contract and try IaYr. - - H \v e. EXPENSES: You agree to pay the costs of repossesssiinQ storing, repairing, preparing for
b. OUR RIGHT TO ENDORSE INSURANCE CHECKS: You agree that.the Seller, Assignee, sale and-selling the Vehicle as may be allowed by law. These casts will only be due if.
any subsequent rgnee; or an authorized employee orany of them r'we9 may endorse-your 1. Default exceeds fifteen (15) days at the time of repossession;
name, acting fit Or agent to any check, draft or other instrument we receive in payment of 2. The amount of casts are actual, necessary and reasonable, and
an-insured loss or returo-ofinsurence premiums You agree that you do not have the right to 3. We.ean prove the costs were paid.
and will not revoke the power you have*given us to make your,endorsernent. You agree that a 15.HEIRS AN D'PERSONAL REPRESENTATIVES BOUND: After
we may exercfse.this power for our benefit and not for your benefit, except is provided in this your death, this Contract shall
Contract and by Lae. be enforceable against your.heirs and personal representatives of your estate.
- c. -USE OF •PROCEEDS:.We may apply any insurance proceeds we receive to repair or 16. GOVERNING LAW: This Contract is to be interpreted according to the law of Pennsylvania.
replace the Vehicle if, in our opinion; it is economically feasible and you are not then In •11. SEVERABILITY OF. PROVISIONS: 11-for any-reason any part of this Contract shall become
default of this Contract Otherwise, we will apply the insurance proceeds to reduce-the unpaid illegal, void or unenforceable, that part shall not be a part of this Contract
,balance due us After the balance due us is paid, any eXcessyfjn belon110C.10 lou„ ?,, .'. ' 18. ASSIGNMENT BY BUYER:'Buyer shall not assign this.Contract -
11: OUR.RIGHTS IF YOU BREAK YOUR PROMISES ABOUT THE RITY INTEREST, 9?THERE ARE 110 WARRANTIES BY SELLER, EXPRESSED OR-IMPLIED, INCLUDING TNE'
VEHICLE OR INSURANCE: 11-you fail to keep your promises to pay filing fees, taxes,.tiins or WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR: PURPOSE,
the. costs necessary to keep the Vehkk'in good condition and repair, we may advance any UNLESS WE HAVE GIVEN YOU A SEPARATE WRITTEN WARRANTY OR UNLESS SELLER
money you pAniised to pay. If you fill to keep your promises about required insurance, we ENTERS INTO A-SERVICE CONTRACT WITH BUYER WITHIN-,V;DAYS FROM THE DATE OF
may advance money to obtain insurance to cover loss'or damage to the Vehicle. We have the .THIS CONTRACT..
Buyer's-Guide Window Sticker. If the Car which is described on the face of this Contract has a Buyer's-Guide Window Sticker required by the Federal
Trade Commission Used Car Trade Regulation Rule, the following -notice applies:
Tfie'information you see on the window form foGtais MVehi4lebs,part,of this{ onI J. rectn?nforf=n?oJt_be window foym.overrides any
contrary pMvisions in the contract of sale.
NOTICE-ANY,,, HOLDER. OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS All DEFENSES WHICH THE' DEBTOR COULD
-ASSERT AGAINST THE SELLER OF GOODS. OR SERVICES OBTAINED PURSUANT HERETO OR WITH' THE-06CEEDS HEREOF.-RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT-.EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. ` .
fi' S! NOTICE OF PROPOSED CREDIT INSURANCE
The signerls) of this Contract hereby-takefs) notice that Group Credit Life Insurance'coverage or Group"Credit Accident'anA Disability Insurance coverage will be applicable to this
Contract if'so marked'on the front of this Contract, and each such type of coverage will be- written by the-insurance company named. This insurance, subject to acceptance by the
insurer, covers only the person or persons signing the request for such insurance. The imdunt of charge,is indicated for each type of Credit Insurance to be purchased. The term of
insurance will,commence as of the date the indebtedness is incurred and will expire on the original scheduled maturily'date of the indebtedness. Subject to acceptance by the insurer
and within 30 days, there will be delivered to the insured debtor(s) a certificate of insurance more fully describing the.insurance. In the event of prepayment-of the indebtedness, a
refund of insurance charges will be.made when due.
NOTICE: SEE OTHER SIDE FOR IMPORTANT INFORMATION. •: --
g191HE-P11OVISION BELOW 13 NOT PART OF THE-PENNSYLVANIA MOTOR VEHICLE INSTALLMENT SALE CONTRACT BETWEEN THE BUYER AND SELLER.
j ASSIGNMENT
TO induce you, the "Assignee" identified on the face of this Contract or as follows, (Name)
-to purchase the within Contract-the Seller hereby-warrants and represents, and continues to warrant and represent that:•the sale-hai•been made-in strict conformity-with all applicable
federal; state and local laws and regulations,'including,:but not limited to, Article 2 of the Pennsylvania Uniform Commercial Code-(1314 C.S.A. 112101 at seq); our title to the Contract
and the Vehicle covered thereby is absolute, free of all liens, encumbrances and security interests, and is4subject only to the rights of the Buyer as set forth therein; the Contract is
genuine;'the signatures thereon are not forgeries; arose from the sale of the-Vehicle therein described, and all parties thereto are of full age and had capacity to contract the description of
the Vehicle and extra equipment is complete and correct; the-cash downpayment and/or trade-in allowance were actually received and no part'thereof consisted-of notes, post-dated
checks, other credit advanced by us to Buyer or rebates; or similar•payrnents trointus to,Ihe Buyer (however manufacturer rebates may constitute all-or a part of the downpaymerlp; all
warranties'and statements therein are true; there is owing thereon the Amount Financed plus interest at the:Annual Percentage•Rate of theZontracl set forth therein, we are duty licensed
under the Pennsylvania Motor Vehicle Saks Finance Act and have duly complied with all requirements thereof with respell to the transaction and with the federal-Truth-In•Lending Act
and with any other federal or state law, rule or regulation applicable to this Contract; a motor vehicle title certificate showing a lien or encumbrance in'favor of Assignee has been or wig be
applied for promptly; the registration of the Vehicle has not been suspended and the Sellir knows of no facts *which may'risuft Ira the suspension oftfaid registration under the
Pennsylvania Motor Vehicle Financial Responsibility Act; the Buyer(s) named,in the. within Contract is (are) personally known to the Seller to be the same identical persons) whose
signature(s) is (are).iffixed to lhi Contract and Seller has no krarrkdge of facts ifnpairing.the validity or value of the Contract: It inj such warranties of representations should be
breached at any time, Seller shall-repurchase said Contract from Assignee, on demand; and will pay therefor, in cash, the amount owing thereon, computed as set•forlb below, and said
remedy shall be cumulative and not exclusive, and ahall,not affect any other right'or rimedy that Assignee might have•at law orlin equity against Seller. In the event that Buyer fails or
'refuses lo'make-any.paymeot due hereunder on the'assertion; either oral or Written, that the Vehicle is-defective, not as represented to-the Buyer by Seger, or that Sener refuses to-honor
any warranty or servicesailreemint of Seller or manufacturer; Selleragrees that on being advised by Assignee'of such•clainvof Buyer, Seller Will repurchase the Contract from Assignee
and pay Assignee for same immediately in accordance with the repurchase terms set,lotth below, and Seller further agrees to told Assignee harmless from any other claims of Buyer,
including attorneys' fees, costs and expenses incurred in defending against claims asserted by.8uyer and Including.claims for refund of payments made by Buyer to Assignee. If the Sager
contracts to purchase property insurance on behalf of the Buyer; and that insurance is cancelled by the insurance company prior to its scheduled.expirstion.date, Seller will attempt to
place Copt _ rabic coverage with.anothei insurance company' on behalf,of•the Buyer.Af Seller is unable to do so, Seller wig notify Buyer andtpay:to.Buyer any add costs incurred by
'35the Buyerrin obtaining replacement insurance for the un;xpired'period otthe original insurance polley.'By signing and dating-the Ctiniraet'as'Seller, detivirtn rContract to the
Assignee and.accepting.payment for it Seger authorizes the Assignee to act as the Settees agent for the purpose of completing orcorredirig,the identification 9f -the Assignee in this
Assignment to reflect-the true Assignee who purchased the Contract and/or for the-purpose of-signingtSeller's name to this Assignment, without recourse; U-the'Aisigrlmeld is delivered
without the Seller's signature. Assignee may exercise the power given in this paragraph for tlie'tWQit of the Assignee ind•not for the•benelit of the Sellir.`SeNer doe's dot have'the right to
andogrees not to-revoke the power given.in this paragraph. -+ -
In the event that Seller'is required by this Assignment to repurchase the Contract and'/or Vehicle, Seller shah pay to Assignee; In cash, the full unpaid'balance'ofthe Contract as of the
date of repurchase, plus anyAhen earned Finance Charge and any and all costs and expenses paid or incurred by Assignee in respect thereto, including reasonable;atlorneys"fees, in
connection wilh.claims by oragainst any Buyer, Owner or persons irrpossess!on of the Vehicle and/oi by or against Seller. ° '
.'For value received, Seger hereby sells, assigns and transfers into the Assignee, its successors and assigns, the within Contract a(1'moneys due and to become•due thereunder, and all
right tide and interest in and to thi Vehicle therein,desiribed, with full.power tithe Assignee in its or our name to take such legal or,otheF action which we might have taken save for this
Assignment Unless Seller marks either of the endorsements below, titled "WITH FULL RECOURSE" or "WITH REPURCHASE;" Seller's assignment shall, except for the provisions of the
paragraph filled "Assignment," be without recourse.
ETWITH FULL RECOURSE-Seller agrees that in addition to the paragraph above titled "Assignment," in the event-of default by Buyer in the full payment on the due date.thereof of any
instalment payable under the Contract or in the prompt performance of any other obligation to be performed-under the Contract by Buyer, Seller will, on demand by Assignee,.fotthwdh
repurchase Ute•Contract from Assignee for a repurchase price, in cash, computed is set forth above.
0 WITH REPURCHASE-Seger agrees that in•additfon:to the provisions of the paragraph above titled"'Assignment" in the event of any default by Buyer which shag entitle Assignee to
repossess the Vehicle, Seller win, it the Vehicle. is. ased_by Assignee and delivered to Seel ,and without regard to the " n of the Vehicle, forthwith repurchase the
Contredand the•vecash; computed as set forth a
By signmg below, w",.p., .
Selki iiibwwLC:rnLfm,PA,17M By
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HOUSEHOLD .. - .. , Y
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by and Mau Vehicle Retail'
This Assignment is attached to and expressly rtl . a of that certain
tween:
installment Contract Mw Contract") detail . 0 .':
Seller(Deaiership
8110 • "'=*'
ICBBURGt? PEA 170f0 ' Y"?"
it is expressly Wderstood and agraed that Household Auto Finance is SbOut0d each and every
time where the name
appears wathinthe Contract:
For TAM received, Seller hereby expressly sells, assigns and transfers all of Seller's right, the and
interest in the Contract, In all monies due and to become due 1lwreunder, and in and to the vehicle and --
Wo prol" and seas* mwesth described therein, to Hawehoid Auto Finance ardor Its surxes-
gnhisantfes; :mot
M assigns, subsidlaries and affiliates. All repmsent itiora; waffm* , utd kemnihcataons,
and told harmless provisions made by Seller in the Conbaci; and all other terms of the assignment
contained therein, are hereby made in favor of Household Aube Finance:. r
.
This Assignment specifically Inchrdes, but is not limited to, all right, title and Interest D Seller In any,
{rrseearce policies and other producis (and the proceeds thereoq pub , endorsed or obtained by--';?' '
said Buyer(s) under the terms of the Contract. This Assignment specifically h? s all right, tide
collateral or security irtlerest described or tom-,
interest of Seller in and to the vehicle, any property, .?,?.
vided toe In the Contract.
Notwithet ending anything th the contrary contained In the Contract, this Assignment, upon execution ..:, _ .
by Seller, shall assign Seller's rights in the Contract to Household Auto Finance and not to any
;?,,•
assignee(s) named In the Contract. This Assignment shall not be deemed to relieve Self firm any -7
liability for The breach of any warranties, tepreserdaflows or agreemeri s contained herein or in the
nce and Dealer. -,?1,?•
Contract or in the Master Dealer Agreement between ous?o
X 6110 CARL]SLE PEE ...
Seller-Dealership (please prong. ,r*v
Seller's Agent (please prnq. X :. r•.
Agent's Signature. X
Tate of Agent • X "
Date of Assignment X r s?'4
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The following is an NOIT Certified Mail receipt
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V.J. WOOD RECOVERY SERVICE
2291 Old 22
Hamburg, PA 19526
Phone 3 Fax: 610462-3406
Cell: 610487-1335
E-mail: vjwoodmpo@yahoo-com
Nsl1I: - 2649
Licensed and Bonded Towing & Hauling
Collector - Repossessor Fiat Bed Service
Commercial Liquidatbn Service
Invoice # 2851
To: Aoct M. 500001524934
HS6C ALYSSA CAR IER
P.Q. Ow 17915 1654 NEWILI.E RD
San Wego U 92177 CARLISLE PA 17013
DATE'AERVICED: IM2005 Invoice Dates 2/3/2005
vehicle 2000 FORD EXPLORER
VIN: IFMZ 183PCVZO67385 ?p Fees $0.00
voltpsl y Fees $0.00
Top: PA FLV 4696
color. MUE Invaatipatlon Fee: $0.00
Close Fee: $0.00
Located At;
1654 NEMILLF RD Towing Service: $0.00
CARLISLE PA ICeya Fee: $100.00
Storage Fee: $0.00
Delivered Tot
Woolly's Storage Condition Report: $0.00
2291 Old 22 PkAuroa: $0.00
Hamburg, PA 19526
Olirar E7tpa11Ma:
$0.00
No
YMed
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R
:
ey
app
Renwri:ss TOTAL INMOICE DUE: $100.00
¦
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HSBC • 269
V.J. WOOD RECOVERY SERVICE
2291 Old 22
Hamburg, PA 19526
Phone & Fax: 610-562-408
Cell: 616-5874336
E?nail: vjwoodrepo@?ahoo.com
Licensed and Bonded Towing & Hauling
Collector -Repossessor Flat Bed Service
Commercial Liquidation Service 1
Invoke ?r
To: Acd M 500001524934
HSBC ALYSSA CARTIER
P.O. Box 17915 1654 NEMILLE RD
San Diego CA 92177 CARLISLE PA 17013
DATE SERVICED: 1/28 MS
Vehicle 2000 FORD EXPLORER
VIN: 1FMZU83POYZC57385
Tog: PA FLV 4695
Cokor: BLUE
Loebsd At
1554 NEVWILLE RD
CARLISLE PA
Delivered To:
WOWS Storage
2291 Old 22
Hw* , PA 19526
Key Reamered: No
Remark es
Invoke DGW. ?1/31/2005?
RepeewNon Fee: $300.00
Vok int" Pee: $0.00
Investlgatil" Pee: $0.00
Close Pea: $0.00
Towing Servioa: $0.00
Kegs Pee: $0.00
SEorage Pear $0.00
CorAfflorr Report! $0.00
Pkturea: $0.00
OUM E:Pames: $0.00
TOTAL INVOICE DklE: is
/ D[?6L?OnC?
FEB 0 T 2005 L
V
G
I `
i
CARRIAGE TRADW AUTO AUCTION
1200 RIDGE PIKE
CONSHOHOCKEN, PA 19428
(215) 825-70854
WED, MAR 30, 21005, 1:13 PM
HSBC AUTO FINANCE 00069150
500001524934 ALYSSA CARTER
STOCK NUMBER: 00583651
2000 Ford # Explorer
1FMZU83P0YZC67385
I
AUCTIONED: 03/28/2005
NUMBER OF AUCTIONS: 1
SOLD TO: 00017399 JOSHUA MOTOR CAR COMPANY INC
13 MARKET ST
PALMYRA NJ 08065
ffl
PICK-UP CHARGES .00
DETAIL LABOR SALES 75.00
SUBLET MECH 128.94
AUCTION FEE 95.00
f
i
NADA : 6-825.00
SALE PRICE:
TOTAL EXPENSES:
NET REMITTANCE:
E
r
I
1
m ¦
8000.00
298.94
7701.06
Ln
W
M
r*
0
P
1200 RIDGE PIKE
` ' . - • - CONSHOHOCKEN, PA 19428
(610) 825-7085 OR
• • C-A-R-S-A-L-E
- f
00069150
HSBC AUTO FINANCE
6602 CONVOY CbURT
SAN DIEGO I CA 92111
4 OR 1NE, BY USE OF OUR PLATE OR AUTHORIZED SIGNATURE HEREBY AGREE TO
SELL THE DEUNUM VEHICLE UNDER THE TERMS AND RULES OF CARRIAGE
SALE DATE:
STOCK
VIN:
LANE
2000 Ford
Expl?
BLUE
03/28/2005
00583651 BA
IFMZU83POYZC67385
G00026
Dorer
4D Uti
VBCYL?IT-AI?-F?T-PS-f Ei-Eii-fSfi-QC?T-SR-AG
TRADE AUTOAUCTTOf1. FEDERAL LAW REQUIRES THAT YOU STATE THE MILEAGE UPON
TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A
SELLING CONDITIONS: .
FALSE STATEMENT MAY RESULT IN FINES ANOMR IMPRISONMENT.
IF THE SELLING PRICE IS $1,90.00 OR LESS, THE "24 HOUR GUARANTEE" IS NULL
AND VOID. THE VEHICLE WILL BE SOLD'"AS IS -WITH ALL FAULTS' AND CANNOT ? (1) I hereby certify to the beat of my knowledge. the odometer reading
BE RETURNED FOR ANY REASON UNLESS REGULATED BY FEDERAL OR PENNA reflects the amount of mileage in excess of its mechanical limits.
LAW.
? The 24 HOUR GUARANTEE Is to allot the buyer time to have a mecha
i
h ? (2) 1 hereby certify that the odometer is NOT the actual mileage.
n
c, N t
e
X buyers eaoense, verrfy r* conditions In which the vefhide was sold. Only components
bated below are covered unless excluded by specific mention under 'Announced
D
b
" HW AUTO FINAPII
s
cb
. The 24 hour guarantee expires at the dose of business on the following
working day from the date of sale. i Print7hrrdsrors Nantes state the odometer now reads
A. MOTOR: Limited to interred engine parts, such as: pistons, rings, valves, lifters, 67417 miles (no tenths) and to the beat of my knowledge that it reflects the
carnshref4 crank shaft, oil pump, bearings, timing gears and chains, cylinder block,
head and Intake manifold. (Valve and lilfar noise are not covered on vehicles older then actual mils ge of the vehicle described above, unless one of the above state-
three years.) (Current year included.) i
B. TRANSMISSION: Limited to tranernission case, gears, bearing, and torque converter Monts Is che4.
.
C. REAR: Limited to drive shell univetaalllobds, front and rear erdes and differential.
D
AIR CONDITIONER: Limited t Trenalareh
Slgnsturt?(allllet
'el
-
w-",
.
o comPressor and condenser (A.C. not covered on -
I Je
vehices older than titres Ireare ( Curenyear Included.)
E. STEERING: The steering gear housing and all internal Parts power steerin
um IT IS UNDERSTOOD THAT:
A There are no warranties expressed Or knpead of alMdhfMtlfety or Knees for a pertlas r
of velfcles
g P
p.
vehre body, piston, and rack. ,
B
Sh
uld
?
m
F. FRAME DAMAGE: Fame damage must be reported within 72 hours. Scrapes and .
o
a CCYered mOChdcal tuft ocCV, the seio can bewrna Mill end vo
b
onNery
adiu0nenst we be made for Wwored ardr.tws hems, &vW at She eallery dNaeuon.
Jack damage ere not considered trams` damage. Excessive frame rusting Is conskl- C vehicles we sad w1b all vlmbA defects at tkre of solo lrrhfa rig any and all M
Pans and
eyed frame damage. awhnn«n.
0. AIR BAGS that have been deployed "rat properly replaced must be announced.
? "
" D. ==Is r..pormwe for any dumps lrwh sd wrpe vehicle is in the passes on in rMs
weed
AS iS WITH ALL FAULTS
THIS MOTOR VEHICLE TS SOLD AS IS WITHOUT ANY
WARRANTY EITHER EXPRESSED OR IMPLIED AND CANNOT BE RETURNED FOR a The brayer is fully ream able for any ofd d evens" of varilyhg vehicle's mschar" condition,
ANY REASON, INCLUDING FRAME OR UNIBODY DAMAGE, UNLESS REGULATED BY F Printed Mellor Is Prepared by Curls Tirade for to ovner"wo due toyer It does no relieve the
FEDERAL OR PENNA. LAW. THE PURCHASER MUST BEAR THE ENTIRE EXPENSE
resporobibly of el ! ipe 77kade itOO ?MOPOnkeleM jot @*nm" aI J rhYftn'p tiro P dew
e
rh
p1" die
OF REPAIRING OR CORRECTING ANY DEFECTS THAT MAY PRESENTLY EXIST OR N//
d
.
awipmarx ,
I -
TH AT MAY OCCUR IN THE FUTURE INCLUDING FRAME DAMAGE.
? (
G. AM vehicles mast be void for end nsMhored nom the "Ego"
' dtls
of the sele. AN Vehicles Propenyawrtpn 24 tahus from
rmrekeg on prenfeee will be char
ed a i2 Qa
vk
t
? Announced defecLS: s
g
np
p
ee and s S10.eD
day etcre
gs be.
-
H. The ouctlon reserves the dgtn to cancel a Sole If the vehicle is not paid for in full WW* 24 howl Rom
die date of the sale.
- I. ALL DEPOSITS PAID BY THE BUYER ARE NON-REFUNDABLE unless she elk is voided under
tl 5 b '`j 0 - ?' ?- SALE PRIIC
E/ BUYER FEE TOT,AL
I JOSHUA MOTOR CAR 11COMPAIT INC
13 KARK
$ ,
QV`?
$
$ y
'
e
ET ST ?J
P A L 8 Y R A NJ O 8 O b 5 ! TAX TITLE a TAGS TOTAL WfT 6 T
02117/05 00017344 $ $
The Purchasing Dealer ceNfies tlhat the above vehicle is purchstsd for resets In the form of
C.C.
$
LESS 15%
DEPOSIT
t8ft9M Peraor10l Property in 1110 regular course o/ bush el; and is the son usually
Purohased b
tin
b
f CHECK $ DEPOSIT $ -
y
s
uyer
or resale. in the everd that ft property In used for any purpose CASH
other then roads buyer will pay direct to die proper ta6g ou•horhiee Such sale or use tax $ NON-REFUNDABLE
as mq then soon and become payable. The buyer further asrdaes that he holds a retell
.
sale tax'"We"on WOO" 'I-- or other permit Inwed by the sales tax aA horiry.
CHECK $ BALANCE DUE BALANCE
0 PURCHASER EEI -RECEIPT OF ODOMETER STATEIENT ACKNOWI EDGED $ IN 1 WORKING $
? CASH $ DAY
Buyers 81 Dace NET BALANCE
1. or we, by use of our pleb or arrthmiyad algneture, hereby agree to pay the Indicated sal
Price for the
hi
l
d $
ve
e
c
escribed under • e forms and rubs of the Carriage Trade Auto Auction. NA
DA
.
.
DATE /
WhPo•: AUCTION COPY; Canary: FILE COPY; Pink: SELLER'S COPY; Goldenrod: BUYERS COPY; Great: GATE RELEASE COPY
CERTIFICATE OF PURCHASE
I, KENNETH D. URBAN , hereby depose and state that:
1. I am an Authorized Agent of CACH, LLC, a Colorado Limited
Liability Company.
2. As such, I am authorized to give this Certificate, and possess sufficient
personal knowledge to do so regarding:
Customer Name: Alyssa A. Carter
Original Creditor: Household Automotive Finance
Account Number: 500001524934
3. On or about May 4, 2005 this account was issued by the
original creditor. CACH, LLC is the current owner of the account and
purchased the account for good and valuable consideration.
Date: L; ti 2 4?
Sworn and subscribed to before me this ? day o
2006.
Nota Public FPRUDEINCE TINBERG
ry RY PUBLIC
F COLORADO
My Commission Expires: My Commission Expires 05/03/2010
¦
t_yp f -6 I-r-
¦
qkl?' -
VERIFICATION
I 'KENNETH D. URBAN
hereby depose and state that:
The language of the foregoing document is that of counsel and not
necessarily my own; however, I have read the foregoing document and
the factual information contained therein is true and correct to the best of
my personal knowledge.
I am the Authorized Representative and a duly authorized representative
of the plaintiff;
The factual allegations set forth in the foregoing pleading are true and
correct to the best of my knowledge, information and belief, and they are
that Alyssa A. Carter owes the balance of $8,841.37 to CACH, LLC on
previously submitted invoices, which balance is due and unpaid as if the
date of the execution of this Verification.
I am aware that if any of the foregoing is willfully false, I am subject to
punishment.
I understand that false statements made herein are subject to the penalties
relating to unsworn falsification to authorities.
B
Dated: JUN 2 6 2005
Authorized Representative
CZ1
? N 0
V
-- ri i -T"l
-cl
T?
0?0
ryw
ROBERT M. REIBSTEIN, ESQUIRE
705 MONTGOMERY AVENUE
NARBERTH, PA 19072
(610) 664-1999
ATTORNEY I.D. NO. 20456
CACV OF COLORADO, LLC
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
61
NO. 0-1066 CIVIL TERM
ATTORNEY I.D. NO. 20456
ALYSSA A. CARTER
CIVIL ACTION
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Please kindly enter Judgment in the above captioned case by default for want of the
answer being filed within the time prescribed by the Pennsylvania Rules of Civil Procedure
against the Defendant and assess the damages as per statement below.
ROBERT M. REIBSTEIN
ATTORNEY FOR PLAINTIFF
ASSESSMENT OF DAMAGES
Amount of Judgment ............................................ $10,823.96
Costs .....................................................................
ROBERT M. REIBSTEIN
Attorney for Plaintiff
ROBERT M. REIBSTEIN, ESQUIRE
705 MONTGOMERY AVENUE
NARBERTH, PA 19072
(610) 664-1999
ATTORNEY I.D. NO. 20456
CACV OF COLORADO, LLC
VS.
ALYSSA A. CARTER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
0'l
NO. 0-1066 CIVIL TERM
: ATTORNEY I.D. NO. 20456
CIVIL ACTION
CERTIFICATION PURSUANT TO RULE 237.1
TO THE PROTHONOTARY:
This is to certify that on April 4, 2007, Plaintiff s attorney sent notification pursuant to
Rule 237.1 to the Defendant by certified mail, return receipt requested, and by First Class regular
mail.
ROBERT M. REIBSTEIN
Attorney for Plaintiff
ROBERT M. REIBSTEIN, ESQUIRE
705 MONTGOMERY AVENUE
NARBERTH, PA 19072
(610) 664-1999
ATTORNEY I.D. NO. 20456
CACV OF COLORADO, LLC : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
V. : NO. 07-1066 CIVIL TERM
:DATED: APRIL 4, 2007
ALYSSA A. CARTER
TO: ALYSSA A. CARTER
1654 NEWVILLE ROAD
CARLISLE, PA 17013
: FIRST CLASS MAIL - PROOF OF MAILING
NOTIFICATION PURSUANT TO RULE 237.1(a)(2)
IMPORTANT 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 THE CLAIMS SET FORTH AGAINST YOU. 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS
AT A REDUCED FEE OR NO FEE.
LAWER REFERENCE SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
ROBERT M. REIBSTEIN
Attorney for Plaintiff
ROBERT M. REIBSTEIN, ESQUIRE
705 MONTGOMERY AVENUE
NARBERTH, PA 19072
(610) 664-1999
ATTORNEY I.D. NO. 20456
CACV OF COLORADO, LLC : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
b?
VS. : NO. 05-1066 CIVIL TERM
ATTORNEY I.D. NO. 20456
ALYSSA A. CARTER : CIVIL ACTION
CERTIFICATION OF ADDRESSES
TO THE PROTHONOTARY:
This is to certify that the address of the Defendant is 1654 Newville Road, Carlisle,
Pennsylvania 17013; and the Plaintiff's address is 1999 Broadway, Denver, Colorado 80202
ROBERT M. REIBSTEIN
Attorney for Plaintiff
ROBERT M. REIBSTEIN, ESQUIRE
705 Montgomery Avenue
Narberth, PA 19072
(610) 664-1999
Attorney I.D. No. 20456
CACV OF COLORADO, LLC
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
O?
NO. A3-1066 CIVIL TERM
ATTORNEY I.D. NO. 20456
ALYSSA A. CARTER
CIVIL ACTION
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF MONTGOMERY
SS.
ROBERT M. REIB STEIN, ESQUIRE, being duly sworn according to law, deposes and
says that he represents the Plaintiff in the above entitled case; that he is authorized to make this
affidavit on behalf of the Plaintiff, and that the above named Defendant is 42 years of age; the
address of the Defendant is 1654 Newville Road, Carlisle, PA 17013; the occupation of the
Defendant is a businesswoman; and the Defendant is not in the Military Services of the United
States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil
Relief Act of 1940 and the amendments thereof.
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 1-) DAY OF
n < < , 2007
NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sandra L. Trucigeon, Notary Public
Lower Merion Twp,, Montgomery County
My Commission ExOres June 9, 2009
Member, Pennsylvania Association of !Votaries
ROBERT M. REIBSTEIN
ATTORNEY FOR PLAINTIFF
?J.
fi
Azi.
(Rule of Civil Procedure No. 236)
CACV OF COLORADO, LLC
VS.
I ALYSSA A. CARTER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
0'1
NO. k5-1066 CIVIL TERM
ATTORNEY I.D. NO. 20456
CIVIL ACTION
Notice is given that a judgment in the above captioned matter has been entered against
Defendant on A - L as 2007, in accordance with provision of Pa. R.C.P. 236.
/? Lll??e4
PPROMONOTAO?TF f
If you have any questions concerning the above captioned case, please contact:
ROBERT M. REIBSTEIN, ESQUIRE
705 Montgomery Avenue
Narberth, PA 19072
(610) 664-1999
Attorney I.D. No. 20456
of PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS
P.R.C.P. 3101 to 3149 Etc.
IN THE COURT OF COMMON PLEAS OF
-CACV. OF -COLORADO,--LLB----------1 CUMBERLAND COUNTY, PENNSYLVANIA
1999 Broadway
Denver, CO 80202
-------------------------------------------
Vs.
ALYSSA A. CARTER
1-6 54 -9-e-, -e R -----oad -----------------
- vill
Carlisle, PA 17013
-------------------------------------------
Writ No.---------------------------- Term, 19------
No. --07-1066-CIVIL-TERM -------------
----- Term, 19------
Amount due ------------ $ -- 10---,-----823-.----96 -----
Interest from __4«5L07___-____ -_
Att'y's Com. -----------------------------------
Costs ---------------- $ ------------------------
To the Prothonotary of said Court: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
CUMBERLAND
(1) Directed to the Sheriff of ------------------------County, Penna.;
(2) against _ALYSSA A __ CARTER _- -Please- le_v_y__on_ all_-pe-l sQ114_rop?ry_ blonging
to Defendant at 1654 Newville Road, Carlisle,--PA--_17013.- Defendant (s) ;
-------------------------- - - - - - -
(3) and against
_______________ Garnishee (s) ;
(4) and index this writ
(a) against -------------
------------------- Defendant (s) and
(b) against -----
---------------------------------------------------------------------- Garnishee (s),
as a lis pendens against the real property of the defendant (s) in the name of the Garnishee (s) as follows : (Specifically
describe property)
(5) Exemption has (not) been waived.
Dated ------- 5 2 5/ 0 7------
Attorney for Plaintiff (s)
ROBERT M. REIBSTEIN, ESQUIRE #20456
NOTE
Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b),
the county should be indicated.
Under Rule 3103(c) a writ issued on a transferred judgement may be directed only to the sheriff of the county
in which issued.
Paragraph (3) above should be completed only if a named garnishee is to be included in the writ.
Paragraph (4) (a) should be completed only if index fng of the execution in the county of issuance, is desired as
authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that
Bounty by the prothonotary. See Rule 3104(b).
Paragraph (4) (b) should be completed only if real property in the name of a garnishee is attached and index-
ing as a lis pendens is desired. See Rule 3104(c).
tn i A y O Cn ?'`
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WRIT OF EXECUTION and/or ATTACHMENT
1 -,.
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, Plaintiff (s)
From ALYSSA A. CARTER, 1654 NEWVILLE ROAD, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY BELONGING TO DEFENDANT AT 1654 NEWVILLE ROAD,
NO 07-1066 Civil
CIVIL ACTION - LAW
CARLISLE, PA 17013.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10,823.96
L.L. $.50
Interest FROM 4/25/07
Atty's Comm %
Atty Paid $128.80
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: MAY 29, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT M. REIBSTEIN, ESQUIRE
Address: 705 MONTGOMERY AVENUE
NARBETH, PA 19072
Attorney for: PLAINTIFF
Telephone: 610-664-1999
Supreme Court ID No. 20456
Ir / ??
6rtig R. Long, Prothonotary
Ey .22.
Deputy
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-01066 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CACV OF COLORADO LLC
VS
CARTER ALYSSA A
DAWN KELL Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CARTER ALYSSA A the
DEFENDANT at 2047:00 HOURS, on the 14th day of March 2007
at 1654 NEWVILLE ROAD
CARLISLE, PA 17013
by handing to
MICHAEL SHAW, HUSBAND
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
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
18.00
4.80
.00
10.00 R. Thomas Kline
.00
32.80 03/15/2007
ROBERT M REIBSTEIN
By
day Deputy Sheriff
, A.D.
'S
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
Advance Costs: 150.00
Sheriffs Costs 66.61
18.00 83.39
1.31
.50
2.00 Refunded to Atty on 03/25/08
4.80
20.00
20.00
66.61 ? 4/4" ?-
So Answers,
R. Thomas Kline, Sheriff
By CL,I I of. ^?6dd&YP
C
cam. G 3 5??
R. )0?(q?
of
r
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1066 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, Plaintiff (s)
From ALYSSA A. CARTER, 1654 NEWVILLE ROAD, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY BELONGING TO DEFENDANT AT 1654 NEWVILLE ROAD,
CARLISLE, PA 17013.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10,823.96
L.L. $.50
Interest FROM 4/25/07
Atty's Comm %
Atty Paid $128.80
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: MAY 29, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT M. REIBSTEIN, ESQUIRE
Address: 705 MONTGOMERY AVENUE
NARBETH, PA 19072
Attorney for: PLAINTIFF
Telephone: 610-664-1999
Supreme Court ID No. 20456
urti R. Long, Prothonotary
%L-??Deputy
DOROTHY KRAFT, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
JOHN R. DAIL_EY, M.D., AND a=" =r
DAILEY EYE ASSOCIATES, ?'-
DEFENDANTS NO. 07-1766 CIVIL
IN RE: PRE-TRIAL CONFERENCE
REQUEST FOR CONTINUANCE " -`
ORDER OF COURT
AND NOW, this 13th day of January, 2010, after Pre-trial Conference in the
above captioned matter, and Attorney Richard Seidel, Counsel for Plaintiff having
related to the Court that he is currently undergo chemo therapy and that his current
medical condition will not permit him to try this case during the February 2010 Term of
Civil Court and Counsel having requested a Continuance,
IT IS HEREBY ORDERED AND DIRECTED that the Continuance requested by
Plaintiff's Counsel is GRANTED.
IT IS FURTHER ORDERED AND DIRECTED, by agreement of Counsel, given
the fact that the case is a medical malpractice case requiring at least 5 days for trial and
a lengthy list of witnesses to be scheduled, that the case sl-all be tried beginning
September 20, 2010. Both Counsel are hereby attached for trial that date.
IT IS FURTHER ORDERED AND DIRECTED that attorney Seidel shall advise
the Court on or before July 9, 2010, of his medical status. Should Attorney Seidel have
continued medical problems as of that date, arrangements will be immediately made to
have other counsel try this matter on September 20, 2010.
By the Court,
'?%? A
M. L. Ebert, Jr., J.
-"Richard S. Seidel, Esquire
Attorney for Plaintiff
Michael M. Badowski, Esquire
Attorney for Defendants
Court Administrator - AAS 1/40
bas
Cc? P
111q116
2