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Home My WebLink About00-05628 -, ,.;~.." . < J'~"-'_ ,,-,,,-_ '"" .'~_",., ,.-~,' <<__, ,-~ -;' G.",,~:;~_: '"C't ;:;':.-i {,'. ,,'" "',,. _ '",~" .; .~', ,~~,,";!~, -' ~. :; ..,._, '.c.' <~ " c-~ ,"_ . ._ HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17105 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 00 - .S'I...:J..P (L,"(~ CHARLES L. BARNER 54 Meadowbrook Court New Cumberland, PA 17070 Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within 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 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. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4th Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 Date: August 2, 2000 D ALLEN & RAHAL, LLP Eugene' . Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff . - -"''"d' --- >.- ,- . .' '''''"" " '"--.~.,,,,,'-,*,"--'~- ".. . ,- ,. ~"'. "'. ._'H ",1> .. '~"-' ;'~";,_':,,:;'~.,;,L,' .,' :,; .i',:,,~. ,~:".'Z~~'~:":;':;';~-0':'~'.,'- ;;,,- ;,:" ~) ",,:, , -;,~:~:.:., , ,'~ HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17105 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 0tI- .j(,.2JY CWd .-.- 1.L..vv<- CHARLES L. BARNER 54 Meadowbrook Court New Cumberland. PA 17070 Defendant COMPLAINT 1. Plaintiff is Harris Savings Bank, a Pennsylvania state-chartered savings bank, with its principal office at 235 N. Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105. 2. Defendant Charles L. Barner, is an adult individual living and residing at 54 Meadowbrook Court, New Cumberland, Pennsylvania 17070. 3. Defendant, as buyer, entered into a Pennsylvania Motor Vehicle Installment Sale Contract with Brenner Cadillac Oldsmobile, Inc., as seller, respecting a 1993 Jeep Cherokee. VIN #1J4FJ78S6PL549548. A true and correct copy of the said Pennsylvania Motor Vehicle Installment Sale Contract is attached hereto. made a part hereof and marked Exhibit A. 4. The Contract was subsequently assigned to Plaintiff. 5. Defendant defaulted in her obligations under the Contract, and the Vehicle was repossessed. 6. On April 25. 2000, Plaintiff sold the Vehicle. leaving a deficiency balance owing in the amount of $5,615.49. . -'~, ~,> ", ,- ,~":~nt>;-;'i.:":'-~,J:i,~ ,...~'"J0 "":'.;-;6:,. ,;",;p:",::,~>- ';.'~,,;;'~ ''"' \>.'.-".-,' ^-;; ','0-, '",~ ,~'::.'-~,,-.. 'd';'-.';,,"< ."., ,'-~-,--::" 7. Despite Plaintiff's repeated demands, Defendant has failed and refused and continues to fail and refuse to pay the current balance owed to Plaintiff under the Contract. WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $5,615.49, together with interest, attorneys' fees and costs of suit. KEEFER WOOD ALLEN & RAHAL. LLP. Date: August J 2000 By: Eug ne E. epinsky, Jr. Attorn. .. No. 23,702 210 Walnut Street P.O. Box 11963 Harrisburg. PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff -2- ,." ~', ,~> '" '.~ .- .' _'0'" --,._, VFRIFI~ATION 1. (S)He is LlS:.o.... A. {l./Jo...r..s. h , hereby verifies and states that: A V (J of Harrill Savings Bank. Plaintiff herein; The undersigned 2. (5)He Is authorized to m..ke this Verlfleatlol'l on ita behalf; 3. The facts set forth In the foregoing Complaint are tNe and correct to the best of (hsr)hls knowledge, Information and belief; and 4. (S)He Is aware thaI false statemsnla herein are made subject to the penalties of 18 Pa. C.S, 54904, relating to unsworn falsification to authorities. j~ 1f1{vW-- Dated: tluj!Lll.:l I . 2000 ~~""'"" J'. . ~- " "-"~~'t'" <Iiff:,;: MOTO~Y~W~ TAllMENI SALE CONTRACT, Dated th lYY9 t>551 OU'-l'1!\.) ANNUAL' '. fiNANCE Amount Financed Totalo(Payments Total Sale Price P~NTA(h TE. CHARGE The amoun! ot credit provided The amount you will have paid afleryou Thelotal cosl of your purchase on TilecostotyourCt, ;as rhedo!!aramountthe to you oron your behalf. have made aU scheduled payments, credit, including your downpayment a yearly rate, c;reditwill cost you. 01$ 3400.00 14.15 % $ 3738.58 I 11573.90 T 1531l!.411 I 18712.48 .. Your Payment Schedule will be: Security: You are giving a security interest in the motor vehicle being No. of Pay men Is Amount of Pay men Is When Payments Are Due purchased. 48 I 319.01 Monthly,beginning 09/13/1999 I N/R Prepayment: If you pay off early, you will nol have to paya penaJly. filing fees: $ 5.00 late Charge: If a payment is late, you will be charged 2% of the portion of the payment which is late for each month, or part of a month greater than 10 days, Ihat it remains unpaid, See below and an~ olher Contract documents for any additional Information about nonpayment, default, any required repayment in full before the scheduled date and prepayment refundsalldpenaltles, e means estimate JULY J~ lnthisCuntrac.t weare the SEllER. Zip Code IF YOU 00 N{}T MEn YOUR CotnR~CT OBLIGATIONS, YOU MAY LOSE THE MOTOR VEHICLE AND PROPERTY THAT YOU BOUGHT WITH THIS CONTRACT, AND/OR MONEY ON DEPOSIT WITH THE ASSIGNEE. ,This Contrad Is between Seller and Buyer. All disclosures have been made by Seller. Seller intends to assign this Contract to the Assignee. BRENNER CRDILLRC OLDSMOBILE. INC Name Address 22l!l! PRXTON ST HRRRISBURG PR 17111 '(ouare the BUYER(S). CHRRLES L BRRNER 1840 NORTH STREET HRRRISBURG PR 17103 Name{s) Address{es) ZipCode(s) L L % Itemization of Amount Financed Cash Price T 14140.00 CashOownpayment T 1900.00 Trade-In Value of Trade-In T 1500.00 LienPayotfto: I N/R Unpaid Gash Price Balance I 10740.00 ~ To Credit Insurance Company T N/R c TOPllbllcOfficialsfor: '2 License, Tags and Regisllation " ~ I l!8.50 11 i Lien Fee ~ $ 5.00 ~ To " T N/R 0 ~ To .F c 0 I 4l!.00 ~ To is s $ N/R ~ ".f To "HL~" 1M. I 758.40 Amount financed T 11 573. 90 finance Charge T 3738.58 Total of Payments {Time Balance) . I 1531l!.48 Payment Schedule .You agree to pay to us IheAmount Finance<l plusinlerestin 47 paymenlsof$ 319.01 each,anda. final payment of I 319.01 .Thefirst paymenlwiJIbedueon SEP 13th 1999 ,andthenpayments wlll be due on lhat same dayol each monlh following. E If tllere is more than one Buyer, eac~ promises, separately and together, to pay allsllms due us and to perform all agreements in this Contract TRADE-IN; You have traded in the foUowlng vehicle: 1984 JEEP WRGONEER Year~nd Ma~e Description If a balance is still owing on the vehicle you have traded in;theSeller,will pay off this amount on your behalf. You warrant and represent to us Illat any trade-in is free from lien, claim, encumbrance or security interest, except as shown in the Itemization of Amount Financed as the "Lien Payoff,' PROPERTY INSURANCE: You may cMose the person through whom Insurance is obtained against loss or damage to the Vehicle and against liability arising out 01 use or ownership 01 the Vehicle. In this Co ntract, you are promising to insure the Vehicle and keep il insured, CREOn INSURANCE IS NOT REQUIRED: Credit Life Insurance and Credit Disability Insurance are not required to obtain credit, and will not be provided unless YOll sign below and agree to pay the additional cost(s), Please read the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or pOlicy will tell you the MAXIMUM amount of insurance available. All insurance purChased will be for the term of the credit. By signing, you selecl Single Credit We Insurance, ,Whatisyour By signing, you seleclSingJeCredit Accidenl& which cosls $ N/A age? ~ Years Health Insurance, which cosls $ N/A Whal is your age1_Years By signing, you both select Joinl Credit We Insurance, which cools $ N/A What are your ages? SignatureoIBuyerlobeinSllredlorSing!eCredilAccidenl&HeaRhlnsurance By~igning.youbolhselectJoinl~redit N/lf'hatare Percentage Accldent&HeaRhlnsurance,whlchcosls$_ your ages? to be insured Signalure of Buyer 10 be insured lor Single Credit We Insurance 2. SignaturesofbolhBuyerstobeinsuredlorJointCreditWelnsurance 2. Signatures of bolh Buyers 10 be insured for Joinl CledilAccident & Health Insurance % Insurer. VEHICLE: You have agreed to PUttMSe, under the terms of this Contract, the following motor 'lellicle and its e'l".tra equipment, ~hit.h is t.alled the "Vehicle" in this Cantract t:!L!J. Ye!!: ill Make USED ~ SON !W!Y.s!W: /10.0!, l.rY..l;!Ton~ Serial Number 1J4FJ78S6PL549S4B 1993 JEEP CHEROKEE Equipped _A,T._P,S, _AM-FMStereo --':'SSpd, Other with _A.C._P.W: '_AM.FMTape _Vinyl Top ASSIGNEE: We may assign this',Contfact and Security Agreement ta a sales.finance company which is the "Assignee." If the Assignee assigns the Contract 10 a suhsequent assignE:le, the term alsa refers to such subsequent assignee, Afler the assignment, all rights and benefits of the Seller in this Contract and in the Se(.urity AgreementshalJ belong to and be enforceable by the Assignee. The Assignee will nolify you when and if SeJler makes an-assignment. HARRIS SAVINGS BANK. 23.5 North Second Street, Harrisburg. Pennsylvania 17105 CO-SIGNER: Any person Signing the Co-SIgner's Agreement below promises separately and together with all Co.Signer{s} and Buyer(s}, to pay all sums,due a~d to perform ,~!l agreements.!n thi!>,~?,~tracl. CO:f~igne( wi!1 not b~ an Ow~er of the .Vehicle. ' , CD.OWNER: Any person signing the (jo-Owner's Security'Agreement below gives us a security interest In the Vehicle and agrees separately and together w\~h all CQ-Ownerls\,a".d Buyer{s}, tp. perf9rm ,all agreemen\~ in the Security Agreement and all olher ParIs of t~is Contract except Ihe, "Promise to Pay" section. ' , , ,. TERMS: The terms shown in the boxes above are part of Ihis Contracl. PROMISE TO PAY: You agree to pay US the Tolal Sale Price for the Vehicle by making the Cash DownpaymentandassigningtheTrade-ll1,ifshawnabove,onorbeforethedate.ofthisContlact.and paying us the Amount Financed plus interest You promise to make payments in accordance with Ihe Payment Schedule. You promise to make payments 011 or belme Ihe same day of each month as the iilst paym\mt due date. You agme to pa'1 Ml {I\her amounts which may becllme due umler lhe l.erms oflhis Contract. You agree 10 pay ths Seller or Assignee costs 01 Sll it. You also agree to pay reasonabJeatlorneys' lees if Seller or Assignee hires an allorney fo coli ectamounlsdueunderlhis Conlractor to protectar get possession of the Vehicle. You agree to make paymenlsatthe place or 10 send payments to the address which IheAssIgnee most recenlJyspeci lies in the written noUce 10 you, Bysigningbelow,weagreetoselltheVehicletoyouund~rthetermsofthisContract. SECU~ITY AGREEMENT: To secure the payment af all sums due and the performance.of all required obliBations under this Contract, you give a security interest in the Vehicle, III all paris (called accessions~l attached to the Vehicle at any later time, and in any proceeds 01 IheVehicle, including insurance proceeds. The Assignee may set-oft any amounts due and unpaid under this Contract agalllst any .of your money on dep.oslt with Assignee. This includes any money which is now or may in the future be deposited with Assignee by you, Assignee maydo thiS without any prior naticelo yau. ADDITIONAL TERMS AND CONDITIONS: THIS CONTRACT CONTINUES ON THE REVERSE SlOE. YOU ARE OBLIGATED TO ALL THE TERMS OF THE CONTRACT WHICH APPEAR ON THE FRONTAND REVERSE SlOES, INC 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, YO~AL RIGHTS. . BUYE..;::':,'a ~ &"~~. (SEAL) 07/30/1999 Dale 07/30/199 Date BUYER (SEAL) Dale C '.SIGNER: YOU SHOULD READ THE NOTICE TO,CO.SIGNER, WHICH HAS BEEN GIVEN TO YOU ON A SEPARATE DOCUMENT, BEFORE SIGNING THE CO-SIGNER'S AGREEMENT. ' CO-SIGNER'S AGREEMENT: You, the person (or persons) signing be].ow as "Co-Signer," pramise to pay to us all sums due on this Contract and to perform all agreements in this Contract. Y 011 intend to be1egally b.ound by all the terms of this Contracl, separalely and l.ogether, with the Buyer. You are making this promise 10 induce us t.o fllake this Contract with the Buyer, even though we wi11 use the proceeds only for the Buyer's benefit. You agree 1.0 pay even Ihough wc may not have made any prior demand for payment on the Buyer or exercised our security inlerest. You also acknowledge receiving a completed copy of this Conlract. (SEAL) Co-Signer'sSignatur,e Address Date (SEAL) Co-Signer's Signature, Address Date CO-OWNER SECURITY AGF.EEMENT: You, the person signing below as "Co-Owner," together with the Buyer or otherwise being all ofthc Owncrs of the Vehicle, give'us.a Security Inleresl in the Vehicle identified abovc:'You agree to be bound by the terms of the Security Agreement and all other parts of Ihis Contract except the "Promise To Pay" seclion. You are giving us the security inlerest to inducc us to make this Contract with the Buyer, and to secure the payment by the Buyerofall sums due on this Contract. You will not be responsible f.or any deficiency which might he due after repossession and sa]c of the Vchiclc, (SEAL) Co-Owner's Signature Address Date BUYER, CO-SIGNER AND CO-OWNER. AS APPLICABLE, ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT ATr;;ExME~ SI~N.G. A. ,""" ~ __w~ . . , '""'"'~ ,~""'~;. ~ - "-"'~ ~ ~" .,~, \-"~I~~U. ldllY ilIIO'/lll 'altc"jJdymelll~ \'lilt cause Hie alHourn or lne jJliil1'l!d'Yl~nt to Clldllll€. '->,- .,-- '. ,-. . ! " ,._, .'l:.I"-"....'Vt~" ..- ~"c, u, \; i .1" 1 b, Youdo nol Ileep any promise you made mthisContlact;or 3. LATE C.HARGE: Buyer agrees to pay a Jate charge for any payment not made within 10 c. You dO not Ileep any promise you made in another Contract, Note, Loan or Agreement days aflellts due date. The late charge will be 2% per month on the unpaid amount of the with Seller or AS$.ignae;or .., . paymen!. We ~ln consider any part of a month in excess of 10 days to be a full month. The d. You made any unlrueslatementin Ihecreditapplicationlorlhis,Contracl; or . late charge Will be due when earned, No late Charge will be due if the reason that the y '~d f . . payment is Jate is bec.ause, alle.r default, the.entire outstanding balance on this Contract is r,..g." l".eq.cp~lpJ any orgery 111 connecllo~,l!jillHl),i~ontract;or ' R.;" d NIt h lib d f h t"~-~I~d'-dle,5r, onvicledolaCrimeinvolvfnlrfraud6tdlshonesly,oraffHO~ndbYilcourt ue. 0 a ec argewl e uel I eonly reasonthallhepaymentislateisbecauseota late wlthjunsdictiontodosotobeincapacitaled;df1\l-1 ..charge assessed on an earlier payment. g. Youtilebankruptcyorinsolvency.procew~alir'ariyonefHesbanllruptcyor :'4. AP~UCATfON Of PAYMENTS: We wi)J apply ~aYrnents in the lollowing order of priority: insolvency proceedings against you; or first to rntl!rest and then to late charges, fees, prinCIpal and any other amounts you owe In h. You take the Vehicle outside the United States or Canada'without our wrilleniconsent. the order that we choose. or ' ~;? PRE.PAYMENT~ You may,pr~pa)f, in luU 0{ in pari, the amol.mt owed Illl t\w~ CIlI1\rac\ lit Ol,ny i. You use t~e Vehic.le or 'ailow:siJrnellne else to use i( in a way tlllit,b.uses it,not,to be time ,wltllout penalty: If you prepay the. Contract in part, you agree, to continue to malle . ,covered by Y04r JIlsurance; or",,~,,~ . ,,,,c,' .,>..,.", .'. ~ ',.. ,,_,_, __ _ '-', ... regularly scheduled payments untii ,you pay all amounts due under this Contract. This will ,j. You do something that causes the Vehicle to be subject to confiscation by government reduce the number at payments you will malle, T2 140TXAQ S~~rltres;or, .'- 6.WAIVfRS. ..' 111\1 AQ aRUa2IH~fi\it Th''''WJ'ISIqS~~W''''''''I'!W."djA<fljl'l:lil!'fY\lW~~"'"p";I,"nd''' a. WAIVER BV,SElLER AND ASSIGNEE: We and Assignee waive Ihe right to treal any ~ orlounm.rhhl~MnM/l~I:f;h\e;'bt . . '. ' . property as secu the repaymentof.thisContlact, except for the Vehicle and the other I. Another credllor tries to talle the Vehicle or your money on deposrt With Assrgnee by securityspeclficai tionedmthisContract.. legal process, b, WAIVERS BY , !!" CO-SIGNER AND CO-OWNER: You agliS~'i1lk,~IM1!lbllriURmll~URfalBllm lI<l~IIfII,jN ~OOdlT!il!ll1llll1BlNlllAi)ilJ/~Wl<i;n Default oftlt;s (lr. be(\lIe tl?e~ an:,~, ~~out our ha\!I~g to as~. 11,You don't, we may en1orce. our rights Contr.act, w~ ma.y.en1orce our (Ignis according 10 law. We may also do the things specitlcally Without nohfrrng yo, :~:,€~ance. You give up any right you may have to reQ~rre that.we mentIOned In thiS Cont~act. We may do one 01 these thrngs and at the same time or later do enforce our nghts ago. too -e~,,~e other pe~on or pl,operty before we enforce our nghts agamst another, Some of the thmgs we ma~ do are the fOllowing: you, 'fo,u agree t~~t Wl!I'F give ~p our rights agamst some other person,but not ag~inst you. a. ACCELERATION: We can-demand that'you pay to us th'ii entire unpaid balance owing You waIVe due dlhgence ""collection and all defenses based on suretyship and Impillrment of 011 lhe Contract and all unpaid finance Charges and other money due. You agree that you will collaleral or sec6lfiy~&t\ 1 {1! pay this money to us in one single payment immediatelY upon receiving our demand,. ' 7. INTEREST AfTER MATURITY AND JUDGMENT: Interest at the fate provided in this b. REPOSSESSION: We canRD~el'iji3~nLnl~jbited by law, W,e,can do Contract shall cllOOntWttWc:i:qcrue on .the unpaid balance until paid 111 ~ull, ,even after ma!unty thiS ourselves, have a"Qualified, per~~n do:it fot us, or have a.g~vernment'offjcial (bY' replevin) and/o~ after we"ga't':ljUlfllntent agatnst.you for the amounts due. ThiS Will apply even rf the do II for us. You agree that we can peaceably: come on'lo your property to do this. We may matUrity O~CUIS becau~e III acce~f~tlllll, \\ at all)' time interest llS -provlrlerllor in this tOl,~e llny tAher things,l!lunrl in the V'~hicle, blltrw~1 re\urnthese things to you i1 you as~, 1\ you para.graph IS not pe~mlUed by ,law, Interest shall accrue at the highest rate allowed by want these things bacll, you agree"lo,ask us in'a ,letter sent to us by certified'rriail within 24 applicable law bmlHlj(lil~ fJ1at time, , hours. II you do not send unhis lett.er,. you give up any claim to these things, You agree that 8. YOUR PRor:.'iS"ES'1l'tibliT OUR SECURITY INTEREST: You will not permit anyone other we l11ay use your license plates in r~possessing;the Vehicle and taking it to a,place for storage, Ihan us to obtain a secu.rily intere.st or other righl.s i~ the Verncle.,Yclll will \lay all filing lees c, ~OlUNTARY ~ELIVERY:. w.~ can ask .iYOU. to give 'us ;Ihe Vehicle at,a. reasona,bly necessary for uA:li.wtam and mamtall1 our security mterest in the Vehicle. You will assist us convenlenl place. You agree to'lllVe ~s the, Vehr,cle If we ask. in having our security interest noted on.lhe Certificate of Tille to the Vehicle. You will not sell d. DELAY IN ENFORCEMENT: We'can delay enforCing our rights' under this Contract or give aw.ay the Vehicle. If someone puts'a!tien on the Vehicle, you will pay the obligation and withoullosing any rights. clear the hen, &6) .Gtl\'19! ., _: 14. SOME THINGS YOU SHOULD KNOW If WE REPOSSESS THE VEHICLE: If we repossess 9. Y.OUR PR~MISES ABOUT THE VEHICLE: You will. keep the Vehicle in good condition and without using a government official (qy (eplevin): repair. You Will @ilt'~1 taxes and charges on the Vehicle. You Will pay aQM1ls of maintainll1g a. NOTICE: We will send you a Notice of Repossession to~Mast address we Ilnow about t~e Vehicle. ,YOl[wnrhot abuse the Vehicle or permit anything to be done to the Vehicle which This Notice will tell you how to buy 'back (redeem) the Vehicle. You will NOT have the right to ~III reduce ItS value, o!her than for norf!la! wear and use. ~ou will not use the Vehicle for reinstate the Contract. This means you will have 10 pay the total balanCE! on the Contract and l!legaJ purpo~es.or for hIre or lease. You WIll not mo~e the Ve~lcle ~p;lm-yaUf addr~ss shown all - ather amounts dUe. YQU may not get tI\lr,Vehic~ back by paying dclillQuenl installments. ThIS the front 01 thl&~ng~t to a new pe.rmanent place of garagll1g without notifying us 111 Notice wrlltell you other information,reQuired by law. advance,' , , . ,,' "0\1-1 b; ~~DEMPnON: Y,ou have,the righbt~bJlY bacll(redeem) the Vehicle within 15 days of 10, YOUR PROMISES ABOUT INSURANCE: You wllllleep the Vehicle II1sured against fire, the mallll1g of the Notlce,and at any l:1\erlime before we sell the'Vehlcle..ILyou do not theft and collisi@Qunnl all sums due us are paid in fuJt:- The insula nee coverage must be redeem, you give up all claim to the Vehicle, satisfactory to us 'and protect your interests and our intere,sts at the time of any insured loss. c. SALE: If you don't redeem, we will sell the Vehicle. The money received at sale will be :The insurance'must name us as "Ioss.pa~e,e" on the pollcl'.,The insura'nce must be written by used to pay costs and expenses you owe, and then to pay the amount you owe on the 'an insurance coAparty qualified to do business in Pennsylvania and licensed to sell insurance Contract. 33~ tIttS1l~T0Ir1lJrf~~e~ perma~ently garaged. ~he'!nsuranc~ policy must provide us d. SURPLUS OR DEfiCIENCY: If there,is money lell, we will pay ilto the Buyer. If there is wllh at leastlq.r?AYs'''pnor !;Imtte." .fIat\Ce'.af an~ canoaltat.\on <lr retluctklll ill C(lveragl:, On 1I0t enough money 1r1)m the sale to pay, what you owe, Buyer,aml Co,Slgnel agree to pay what request, you shS'l1ltleIM~Lthe poliCY or, other evidence of IIlsurance coverage to us. In the is stiU owed to us event of any t~ss or d~mage. to the,Veh~cfe:~you will immed,iately notify u.s in writ.ing and file a e. EXPENSES': You agree to pay the costs 01 repossessing, storing, repairing, preparing for proof of loss WII~!nSUrer. We may file a. proof.of loss on your be.half If you fall or. refuse!o sale and selling the Vehicle as may be allowe.d by law, These costs will only be due if: do so. We ma~ !;S,€.,YQW-dlame to .any check, dlaf.t or other IIlslrument we recerve 111 1. Default exceeds fifteen (15l days at the time of repossession; paymenl 01 aIT . urbHIri!'?t return IIlsurance ~rem!uf1.ls.'We m~y, a~~ly. any II1su~ance 2. Theamount of costs are actual, necessary and reaso'nable; and pro~eeds we r~~ kr:ttpalr ,or repla~e ,the Veh!cle ,If, 111 our OPIl119f1, It IS e.conomlcally 3. We can prove the costs were paid, .feaSible and yoifarenOfthen 111 default under thiS Contract. OtherWise, we will apply the insurance proceeds to reduce the unpaid balance due us, ,~\ ' 15, HEIRS AND PERSONAL REPRESENTATIVES BOUND: After your death, this Contract shall 11, GUR RIGHOO~&-ti"il UEAK YOuR--h\ii~-A'iJ~\.~!&IlmY INTEREST, be enforceable againsl your heirs and personal f~ntatives of your estate. Q32U VEHICLE OR INSURANCE:, If you fail to,keep your promises to pay filing lees, taxes, liens or 16. GOVERNING LAWJ1~~isto be interpreted acanl.Bl'tto!Jeet of Pennsylvania. the costs neces~~tlhbfen..theVehicre in good Condition and repair, we may advance any . . money you prorfiHiid'~"P~f.-If you fail to keep your promises about required insurance, we .17. SEVERABILITY Of PROVISIONS, If for any reason any pa~ of thiS Contract shall become may advance money to obtain insurance to cover loss or damage to th e Vehicle, We have the 11Iegal,vOld or unenforceabJe, that part shall not be a part of this C ontract choice of whelh.l!{,.pr ao~ le;'i4vance any money for these purposes. Such insurance will be 18. ASSIGNMENT BY BUYER: Buyer shall not assign this Contract. limited to an atr\ou~r'rto'n!rhter than you owe on this Contract. THE INSURANCE WE 19 THERE ARE NO WARRANTIES BY SElLER EXPRESSED OR IMPlIED 'INCLUOING THE PURCHASE MAY BE SIGNIFICANTLY MORE' EXPENSIVE AND PROVIDE YOU LESS COVERAGE WARRANTIES Of MERCHANTABIliTY AND' fiTNESS FOR A PARTlC'ULAR PURPOSE THAN INSURANCE YOU COULD PURCHASE,YOURSELF. . UNLESS WE HAVE GIVEN YDU A SEPARATE WRITTEN WARRANTY OR UNLESS SEllER We will add any money w~aPvance on your behalf to the balance on which we impose ENTERS INTO A SERVICE CONTRACT WITH BUYER WITHIN'90 DAYS FROM THE DATE OF Finance Charges at the An~tfal Percentage Rate 01 this Contract. You agree to repay the THISCONTRACr. !iSl.eIE'" , . "," 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 Commis~ilSnl;l~lftl Car Trade Regulation Rule, the following notice applies: rut t q"fite information you see on the window form for this Vehicle is part of this Contract. Information on the window form overrides any contrary provistqftS~n the ,contract of sale: ' " " .,;' , NOTICE-ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS ANO DEfENSES WHICH. THt DEBTOR COULD ASSERT AGAINST THE SEllER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF, RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER, NOTICE OF rRoPOSEO CREDIT INS.URANCE The signer(s) otthis Contract hereby talle(s) notice that Group,Credit Life Insurance coverage or Group Credit Accident and Disabifily Insllrance coverage will be applicable to this Contract if so marlled on the front of this Contract, and each such lype of coverage will be written by the insurance company named. This insurance, subiect to acceptance by the insurer, covers only the person or persons signing Ihe request for such insurance. The amount 01 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 incufred and will expire on the original scheduled maturity date of the. indebtedness, Subiect to' acceptance by the insurer and within 30'oays, Ihere will be,oel'ivered to the insured deblorls) a certmcate 01 insurance more.lully describing,lhe 'lI1surance~ In the event 01 prepayment 01 the indebledness, a refund ot insurance charges wit! be made when due. ' NOTICE: SEE OTHER SIDE FOR IMPORTANT INfORMATION, THE PROVISION PROW IS NOT PART OF THE PENNSYLVANIA MOTOR VEHICLE INSTAllMENT SALE CONTRACT BETWEEN THE BUYER AND SELLER. , ASSIGNMENT To induce you, the "Assignee" identified on the face of thls Contract or as follows, (Name) txPp.f~(l1J!17ithin Contract, the Seller hereby warrants and represents, and conlinues to warrant and repreapfJhatltlJ:lI~~aM!!jl(lAmfom!MM!lml!tapplicable fed"eral,:SfaTe anD Jocallaws and regulations, including, but not limited to, Article 2 of the Pennsylvania Uniform Commercial Code (13 Pa. C.S.A ~~2101 et seQ); our1ille to the Contract and the Vehicle covered thereby is absolute, free of aU liens, encumbrances and securilY,interests, and issu~ectonl~totherighlsoftheBuyerassetforththerein;theContractisgenuine, the signatl!res thereon are not forgeries, arose from the sale of the Vehicle therem deSCribed, andeff~lti\.r.l~\etiJlllre of ful! age and had capacity to contract;,the ,description of:the Vehicle and extra eqUipment is complete and correc!; the cash downpayment and/or trade-in allowance were actually received and no part thereof consisted of noles, posl.dated che.c1<s, other credit advanced by us to Buyer or rebates or similar payments from us to the Buyer (however manufacturer rebates may constitute all or a part of the downpayment); all warranties and s\atllmllll\S\hllrllil'i are \rue; tneTIl is owir.g\hefllllll\he l\m.our.t Financed pIllS interest at the Plnnual Percel'J\Ol,ge Raleol the Cllntrac\ set forth therein; 'He are dul~ licensed undet thlO Pennsylvania Motor Vehicle Sales finance Act and have dUly complied with all requirements thereof with respect to the transaction'and'wilh 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 certificale showing a !ien or encumbrance in favor of I\ssignee has. been or will be applied for promptly; the regislration of the Vehicle has not been suspended and the Seller knows of no facts which may result in the suspension of said registration under the Pennsylvania Motor Vehicle financial Responsibility Act; the Buyer(s) named in the within Contract is (are) personally known to the Setler to be the same identical person(s} whose signature(sl is (are) affjxed to this Contract; and Seller has no knowledge of facts impairing the validity or value of lhe Contract. If any such warranties or 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 forth below, and said remedy shall be cumulative and not ,exclusive, and shall not affect any other right or remedy that Assignee might have at law or in equity against Seller. In the event that Buyer fails or refuses to ma~e any. payment due hereunder on the asserlion, either oral or wriUen;that the Vehid eisdefective, not as represented to the Buyer by Seller, or Ihat Seller refuses to honor anywarlanty or serVice agreemenl 01 Seller or manulaclurer, Seller agrees that, on being adV'lsed by Assignee 01 such claim 01 Buyer, Seller will repurchase the Conlract 110m Assignee and pay Assignee 101 same immediately in accordance with the repurchase terms set forth below, and Seller lurtlier agrees to hold ASSignee harmless trom any other claims ot Buyer, inCluding attorneys' fees, costs and expenses incurred in defending against claims asserted by Buyer and including claims for refund of payments made by Buyer to Assignee, Jf the Seller contracts to purchase property insurance on behalf of the BUYer, and that insurance is cancelled by the insurance company prior to its scheduled expiration dale, Seller will attempt to place comparable coverage, With ..nother insurance company on behalt of the 8uyer. It Setter is unable to do SCl, Seller will notify Buyer and pay to Buyer any additional costs inc.urred by the Buyer in obtall1mg replacement insurance for the unexpired period Ilfthe Ilriginal insurance policy. By de1iveringthis Contract to the Assignee and accepting paymen ttor it,Sellerauthofizes,theAssignee to complete or correct the identification of the Assignee in this Assignment to reflect the true Assignee who purchased this Contract,.and/or to sign Seller's name to this Assignment, without reCDurse, it the Assignment has been delivered without SeJler's signature, In the event that Seller is required by this Assignment to repurchase the Contract andlorVehicle, Se lIershall pay to Assignee, in cash,the full unpaid balance of the Contract as oflhe date of repurchase, plus any then earned Finance Charge and anya nd all costs and expenses paid or incurred by Assignee in respectther eto, including reasonable attorneys' tees, 'm connection wi.th claims by or against any Buyer, Owner or persons in possession ofthe Vehicle and/or by or against Seller., " "", :,c' . . .'", For value received, Seller hereby sells, assigns and transfers unto the Assignee, its successors and assigns, the wifhin Contract, all moneys .due a~d to bec~me due thereund~r.-and a.lI right, title and interest in and to the Vehicle Iherein described, with tull power in the Assignee in ils or our name to talle such legal or other ~ctlOn whlch.we might have taken .s~ve for thIS Assignment. Unless Seller marks either 01 thll endorsements below, titled "WHH fUll RECOURSE" or "W\1H REPURCHl\SE," Seller's asslgl'llm:nt shal\.-elltept 1m the PfOV1SlOOS Ilf the paragraph tilled "Assignment," be without recourse. '"',-, '..; ~", . ,'" .' :.': .-," .0. o WITH 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 dat~ thereof of a.ny installment 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, forthWith retlurchase theContraclfrom Assignee lora repurChase price, in cash ,computed as setlorth above. . ".: , . o WITH REPURCHASE-Seller agrees that, in addition to the provisions of the paragraph above titled "Assignment" in the event of any default by Buyer which shall entrt1e ASSignee to repossess the Vehicle, Seller will, if the Vehicle is repossessed by Assignee and delivered to Setler, and without regard to the then condition of lhe Vehicle, forthwith repurchase the Contract and the Vehicle from Assigneelora repurchase price, in cash,computed asset forth above. By signing belo\'l,we agree to the terms of the I\ssignmenl. Seller By I),t~ -'.~\".~. ;.' ~:. ';,-''-" I,,,i;.,~ .m~H -~ ~-'. -MLil~ '.'fu"",", .".~",="~..,o~.,.. , ~,-~, , "l =~ ~ ~~"-lIIi11ir~~ < '''''~-',' -' =..*"'-'~~~ o.,~"~- f.'" N. -',~ -pO -t t ~'ih~. i' B 8 ~ ~~ ',e:; ~~~~ t ~ .=.. ~ ".". () ~ S,~ -om mrrl Z:JJ &55:": -(~'j !<' ,-. ;:"'C) ~c] >c: ~ ". r,- a o "'"' r:= G") o -n :j..\ , r"-~ ;~~ ~.~ ~~ l~~ "J .--I "- ~ (J'l :t"" :c,: co ::::> C) "' ;. if.' ~' i I; I 8 ~ J ~ -~. liii ~.. 0-,,", SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-05628 P C~MMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARRIS SAVINGS BANK VS BARNER CHARLES L 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: BARNER CHARLES L but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On September 21st , 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep. York Co 18.00 9.00 10.00 57.05 .00 94.05 09/21/2000 KEEFER, WOOD, ~ . '> Thomas K ~ne . Sheriff of Cumberland County ALLEN & RAHAL Sworn and subscribed to before me this dJ.. '2::: day of ~ .;}-bIQ A.D. ~. ,.' Q ?k<tt...., ~. Prothonotary ... - <~ , COUNTY OF YORK . OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST.. YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN ..........)ltlsrttUCTlONS.... ....:<:..... ..................................).............p.~.QtItytjtl~..........trQ..~.~....... ...tI~......gl;....4CI-fA.tI.".CO):lII;$......... 2, COURT NUMBER 20-5628 Civil 4. TYPE OF WR[T OR COMPLAINT Notice & Complaint 1. PLAlNTIFF/S/ Harris Savings Bank 3. DEFENDANT/SI Charles L. Barner SERVE . { 5. NAME OF [ND[VIDUAL COMPANY, CORPORATION, ETG, TO-SERVE OR DESCRIPTION OF PROPERTY TO BE LEV[ED, ATTACHED: OR SOLD. ~ Charles L. Barner ..,... 6. ADDRESS (STREET OR RFO W[TH BOX NUMBER, APT. NO., C[TY, BORD, lWP., STATE AND ZIP CODE AT 54 Meadowbrook Court, New Cumberland, PA 17070 7. IND[CATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE G\oEPUT[ZE CUna.:rm:m:rMllld 0 18T ClASS MA[L 0 POSTED NOW 8/17/00 , 20 _ I, SHERIFF OF)ffl)}IlIGCOUNTY, P , do hereby de York COUNTY to exec . nd ma re to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL [NSTRUCT[ONS OR OTHER [NFORMATlON THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COONTY CUMBERLAND ADVANCE FEE PAID BY CUMBERLAND COONTY SHERIFF NOTE ONLY APPLlCABLE ON WRIT OF EXECUTION: N.S. WAJVER OF WATCHMAN - Any deputy sheriff levying upon oPa'ttaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liabll1ty on 1he part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof, 9. 1YPE NAME AND ADDRESS gf ATIQ8NEUORIGlNAIOR and SIGNATURE EUGENE E. PEP~NoKY, JK., 1>0\.2. 210 WALNUT ST., PO BOX 11963, HARRISBURG, PA 17108-1963 12, SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (Thrs area must be completed If notice IS to !:Ie mal[ed), CUMBERLAND COUNTY SHERIFF 10, TELEPHONE NUMBER 11. DATE FILED 8/15/00 (717) 255-8051 SPACEBELOw.FoaO$E;(J"'TfI~$fI!;!n"'F.."DONO:r. WR.:rE:BELOW..THISUNE........ . 13,1 acknowledge receipt of the writ 14. DATE_RECEIVED 15, Expiration/Hearing Date or complaint as indicated above. J. LUDWIG 8/21/00 9/14/00 POSTED I POEI) SHERIFF'S OFF ( ) OTHER ( SEE REMARKS [nt ~ \j23. Advance Costs ,';Q 100.00 41. AFFIRM6J"'\'n~~ ~"!dljur',"C'r1 t.... h'",fg b NOTARIAL SEAL 42, day of ~SH~cfaro ~ry'Publ ~, C.hY:.~lo york, ~CO~1 ,o./N 1 ,.' 'v. _ mlsslor}.Expl "" K:Q, ..... ,..-. 46. Signature oJ Foreign Goun Sheriff SIGNATURE 49, DATE 50. I ACKNQW EDGE RECEIPT OF E SHERIFJ='S IZED ISSU[NG AUTHORITY AND 1, WHITE - Issuing Authority 2. P[NK. Attorney 3, CANARY - Sheriffs Office 4. BLUE - Sheriffs Office 44. Signature of Dep,Sheliff 45. Signature .of York County Sheriff WILLIAM Ill. 47, DAT~ '13 CO 48. DATE 9/19/00 51. DATE REC8VED ". _ ",!,'~-i ",01" '11e1-)1;; ~',~,'.~""'h' ;-.,::'/.11,:' ","\"!i:"~;;,,".1*'''~!-:!~''4f'~'"'' "'i,~"f,,,:,:,t,~!Ii!'''lfJi.l{,~L~li.tL"''ii~.. Fl." "'~':- J-,-&~'.JW.~1i;~_ il111iliJ 'ml!JI)r'''jU]_~j~!!~\j}Jli"J~,t''.o>l'''''.jr~~'k ~ ,".~ '.' -"""''''''-'- ._~.~. ' OT I Wd lZ 911\1 00, Vd 'J\HQ).. .:iJltJ3HS :10 30L:Uf'l . "n3!d'303b\" ~- '. /~; - -- ----- ;C!:~~:~6bu~<<6F';~RK O'FFrC"E OF THE SHERIFF . :'.';-:!;ff'~,' zIl EAST MARKET ST, YQRK, PA 17401 .o'-",3i!~:~l:'..~;,' '. SERVICE CALL (717) 771-9601 -"""'~ -, 1'j\:;'~'.w,"~'r. ":'~ . -?;:: SHERIFF s~iWfc'~. ~~ . ~"" ...",-~~""'f!{~....j .'. .. PROCESS RECEIPT, and AFFIDAVIT OF RETURN ,:-~: " '.,. ;.:~'J:-:~~f: .: ~ . . . INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DETACH ANY COPIES 1. PlAINTIFIl"/ - IIU-r~s Senrings p,~nk 3, DEFENDAN;IS/ Cn~~les L. Barner '"""",, SERVE"'.{ 5. NAME OF INDIVIDUAL COMP~NY, CORPORATfON. ETC, TO SERVE OR DESCRIPTION OF PROPER1Y TO 6E LEVIED, ATTACHED. OR SOLD, _.......... ~ '.:har.les L.. Barner ~ __ 6, ADDRESS .(STREET-OB RFOWlTH SOX NUMBER, APT. NO".CITY, BORD, TWP.. STATE AND_ZlP CODE AT ,~_ -~,'adcworOOK Cou~t, New _Cuml.,ex.L<!nd, PI' 17070 7. JNDlcAt~~RVICE; -OPERSO~AL- O-F.l;BS.O~{NC_~~E'- "::i'P.E:f'UiiZE CJ..!:~ta..9EaThofAll~J O.1STCLAS,SMAlL o POSTED OOTHEA NOW . :..:,.. C J t,? i!jQ .' . '. . 0\ ,go:, 1,~Ii@JEf, OF"!'OB.~QQ,l!NI'f_f'.A,d_O he~13l:>yd"putize the she~iff of ,::.;l . York .. . '-'., ... ..... '., ! . .. . QO}JNTY_to el<!lcl.!wJbls Wnt a[]d milke. return,lhereof accorql!1g to law. ThIS deputation being made at the reqLiesf a-ria riSK anile plaiilfif{-- . . ~... ... .. .... .". . - . '1&.~ .; . . _ ...~,';.~. ~..~, ::r' ,'....J.' '" '.." .... SJ-lERlffOFYORKCOUNTY B. SPECIAL ~~TRUCTiONS OR 01H~~R INF.OAMATJON.~AT~l:L__ASJLSI!N :EX.P~OI~NG..SER.~~~E: .'- . C urn be C j, w C! r-' of..!: / . .. . .OUT Cf' COUNl'Y .':: CUMBERLAND 2, COURT NUMBER ..- . , , . 4, TYPE OF WAlT OR COMPLAINT ~ "'" '0" ". ~ . ~ . .' ~.".. ~-~-~'" '.e ~E FEE. PAlO BY CUl1EERU\Npm\Jm:L~t1-.:eEIFl'> =. ,--,' NOTE ONLY~~PLlCABLE ON WRIT OF EXECUTION: N.S. WA~R .OF WATCHMAN - Any deputy sheriff levying upon or attaChing any ptoperty under within writ may leave same without a wawman. In custody of whomever is fo_und in posses'slon, after notlfying person of feyy' or attachment, :without liitbiJity on the parf'of such deputy or the sheriff to any plaintiff herein for ani.f9ss. destruction, or removal of any property before' sheriffs sa.le ther~f, . 9. TYPE: NA .AND ADDRES$ of ATTQBNE'U ORIGJ~QA ana SIGNArURl: , _~_ 10, TELEPHONE NUMBER_ 11, DATE FILED EUv~ E. PEPlt\SKY, JR.,t;~- ' .,; '....,-;<.. 717" 1.l0~mT ST., PO BOX 1i963,l-l!'.IUUSBORG, PJl,>1~/1Ull-~J9_ ._,"" 255-8051 12. SEND "._'E 01= SERVICE COPY NAME AN.D ADDRESS. ~E1-o.W: (Th,is a~ea m~st be:~lT1P~eted if ~otice is to De.m~~f ~ COUNTY SHERIFF ... u.." . ..... . . . ... . . :li!':. ,_", .~.,_ "',,., '" '<' _*-.', ' '. .' ,: ' . .. _ . . '. .0> . -., ~' i:"l.":'i~A'CE,J1I;:j,QWJ'O'~ USE QFTHE SHERIFi""PQNOT WRITE BELClW THIS LINE 13,1 ackiiowre~age receipt of the writ 14. DATE RECEIVED 15, ExpirationfHearing Date ~. .~ oicomp'~asindicatedabove, j. ~J9 .::',..". '..ro_ 8/21/00 POSTED ( PO. ( - SHERIFP5. 6FF ( . ) OTHER ( SEE REMARKS Int. "! ~- 22, AEMARKS~ -~~.' ~.., ii. ~'t~ . it )l. ,'(. ~ ~ (t "1 , - ~', - \\l. ::j:. .~ ,}3. ~van. ce aSI$ '.Q 100.00 ~34. f=orelgn ~nty Coats ......., -it.4", ... ///://.: 40. Cost Due or Refund w .-C,;b / 47. DATE: 48. DATE ..... ?/yz4?~ 49. DATE 51. DATE RECEIVED 2. PINK. Attorney. 3. CANARY - sheriff:; Offi~ 4, BI,.UE . Sheriff's Office ~. - ~- '_ :.~;.i~:: . "',,,C,,,""'- ';~'<,',;;..;- ""'.... HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17105 Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. CHARLES L. BARNER Defendant No. 00-5628 Civil Term PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff and against Defendant by default in the sum of $5.615.49, with interest and costs of suit, for Defendant's failure to answer or otherwise plead to Plaintiff's Complaint. I hereby certify that written notice was given Defendant in accordance with Pa. R.C.P. 237.1 (copy attached). KEEFER, WOOD, ALLEN & RAHAL. LLP By: ~b lpinSkY, Jr. Attorney I.D. #23702 210 Walnut Street P. O. Box 11963 Harrisburg, PA 17108-1963 717-255-8051 Dated: November 1,:( ,2000. Attorneys for Plaintiff -~".'.- . '--' ,...~ '''' '.",-,,,.,,. 0 \; .,'--.o'.2-"'.','J:c';'f._.. /).' 2c,=-~c '.' ..;r" _ ',__,..;:'~".';.:',-:.":",;~ ,: '"-;.,..::":.,;.-;;,~:~ _. ',-'," ',.,;, , ,- :::,;" _' ;" ." ,-.,--.--,',-",."." .:.~.;:,,~,:c-~<, ..~ :~': ~;;:i.,. <:~J!.; ';;';-~ . ';".>~\~1 .-~ HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17105 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 00-05628 CHARLES L. BARNER 54 Meadowbrook Court New Cumberland, PA 17070 Defendant IMPORTANT NOTICE TO: CHARLES L. BARNER DATE OF NOTICE: OCTOBER 16, 2000 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 KEEFER WOOD ALLEN & RAHAL. LLP. By: Eugene E. pinsky, Jr. Attorney I.D. No. 23,702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff fJi3{"c "__< ,'_-;;)~)~,<,,-", - ';.' '.0_' !..n, >.,:..~ - .,;",~ . -"-". - '''-c','' ".J ,','. o .bIitwi.,.~,! . . , . ,~ '=" ~ -<q.. t p -..0 /:i::. 0 c; --;J :';--': 0 G' QJ A u .-:"- ~"0 ~ ....... P- (i-) P'--.'; ~ -.t ""' 3 -...J ,- ~~ ~"> ,- " :~~ (<J' "7" , ~:.;::c~; 1',) 'Pc::. S~! r---... f-- '<<"'" ~ ~ -, c,-:J -.:.... " UJ --< -,. <___~h~ _ _0.. ., ,~, .._ -~," ~-. . '0 ',..0 '-'''','.-' ". - ..~" ,..-"-""~ '- -,' <-c<;,,;'CC',,' .,' ')";~,,: "~:""~;.'>:'" '~ .;;,,; ,"-'!-"';"." ~- .' "_.' 'O-"~'_ ,'~-"-,.;" ,';,::;~,;,;,~;'~ ~',' :).:.;~",;;;;'::,:,:~-,'<\,: _,~".,.;"~,,,;, -,C~_'~'_ \ ",-..',';:~~~~~~!;<.: -''i;".';:'"'' 0""'" _ , -';_:\::'(~ ,",':,,","' ...' '. HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17105 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION-LAW V. CHARLES L. BARNER Defendant No. 00-5628 Civil Term NOTICE To: CHARLES L. BARNER You are hereby notified that on November .2.~ 2000, the following Judgment has been entered against you in the above-captioned case. By default in the sum of $5.615.49, with interest and costs of suit. DATE: November~, 2000 (L:t.;)k ~ Prothonotary aO~{J~p. ~/Wyf Deputy ~ I hereby certify that the name and address of the person(s) to receive this notice is: Charles L. Barner 54 Meadowbrook Court New Cumberland, PA 17070 ~\J Attorne for ~aintiff