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HomeMy WebLinkAbout07-1537ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7152 Attorney for Plaintiff LAKELAND BANK assignee of IN THE COURT OF COMMON PLEAS Armstrong Mobile Home Sales ' CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. v RICHARD D. SHUMAN and LINDA L. CIVIL ACTION - LAW SHUMAN, now known as Linda L. Short Defendants NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 LAKELAND BANK assignee of Armstrong Mobile Home Sales Plaintiff v RICHARD D. SHUMAN and LINDA L. SHUMAN, now known as Linda L. Short Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT The Plaintiff, LAKELAND BANK, by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of EIGHTY TWO THOUSAND ONE HUNDRED SEVENTY-EIGHT DOLLARS AND SEVENTY-ONE CENTS ($82,178.71), along with interest thereon at the rate of 15.0% from July 26, 2006, upon a cause of action of which the following is a statement: 1. The Plaintiff, LAKELAND BANK, is a corporation organized and existing under the laws of the State of New Jersey, having its principal office and place of business at 250 Oak Ridge Road, Oak Ridge, New Jersey 07438-8906. 2. The Defendant, RICHARD D. SHUMAN, is an adult individual residing at 57 South 391h Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Defendant, LINDA L. SHUMAN, now known as LINDA L. SHORT, is an adult individual residing at 5703 E. Main Street, PO Box 185, Verona, New York, 13478. 4. On or about July 10, 1998, Defendants entered into a Pennsylvania Manufactured F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\LAKELAND - TAMMAC\LAKELAND 33129.wpd: 2 Home Agreement Sale Contract for the purchase of a 1999 Redman 28x72 mobile home, which contract was immediately assigned to Lakeland Bank as set forth in said Security Agreement. A true and correct copy of said Pennsylvania Manufactured Home Agreement Sale Contract is hereto attached, marked Exhibit "A" and made a part hereof. 5. The Defendants defaulted on the obligation to make payments, by failing and/or refusing to honor the remaining contract payments. 6. Defendants' Mobile Home was repossessed and sold at sale for the sum of Twenty Seven Thousand Two Hundred Fifty-Three Dollars and Twenty-Four Cents ($27,253.24) as set forth on Plaintiff's statement of account attached hereto, marked Exhibit "B" and made a part hereof. 7. There is an outstanding deficiency balance due and owing in the sum of Twenty Five Thousand Seven Hundred Forty-Five Dollars and Sixty-Eight Cents ($25,745.68) as set forth on Exhibit "B" hereto. 8. Plaintiff incurred expenses, including, but not limited to expenses in preparing the mobile home for sale, past due expenses, including lot rent and the like, in the total amount of Thirty Two Thousand Eight Hundred Nine Dollars and Sixty-One Cents ($32,809.61) as set forth on Exhibit "B" hereto. 9. Due to the default of Defendants and pursuant to the terms and conditions of the Security Agreement signed by Defendants, interest in the amount of Nine Thousand Nine Hundred Twenty-Six Dollars and Ninety-Eight Cents ($9,926.98) through July 3 25, 2006, has been added to said account as set forth on Exhibit "B". 10. The balance due and owing by Defendants to Plaintiff is the sum of Sixty Eight Thousand Four Hundred Eighty-Two Dollars and Twenty-Seven Cents ($68,482.27) as set forth on Exhibit "B". 11. Due to the default of Defendants, and pursuant to the terms and conditions of the Security Agreement signed by Defendants, attorney's fees in the total amount of Thirteen Thousand Six Hundred Ninety-Six Dollars and Forty-Four Cents ($13,696.44) have been added to said account. 12. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of EIGHTY TWO THOUSAND ONE HUNDRED SEVENTY-EIGHT DOLLARS AND SEVENTY-ONE CENTS ($82,178.71), along with interest thereon at the rate of 15.0% as set forth herein. Respectfully submitted, KODAK & I , P :r Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7152 Attorney ID No. 18041 Attorney for Plaintiff 4 18111WLVANIA MANUFACTURED HOME ?,..MENT SALE CONTRACT Dated: JULY 11 ANNUAL FINANCE PERCENTAGE RATE CHARGE Thacost of your credit The dollar amount the as a yearly rate. credit will cost you. 15.0000 % $ 158,258.00 oar t S ha wit e: Number of Pa ments Amount of Pa manta Wham F Amount Financed Total of Payments Total We 'Tice The amount of credit provided The amount you will have paid The total cost of your purchase on to you or on your behalf. after you have made all credit, including your downpaymen payments as scheduled. of5 9,500.00 $ 55,675.00 $ 213,933.00 $ 223,433.00 Security: You are giving a security interest in the manufactured hem 30 $ 713.11 Month , be innh AUGUST 10 1 *repayment: If you pay foal, you will not have to pay a patalty. Filing Fees: $ u Late Charge: It 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, that it remains apaid Assumption: Someone buying your manufactured home cannot assume the remainder of this Contract on the original terms. See below and any other Contract documents for any additional Information about nonpayment, default, any required repayment In full before the scheduled date and prepayment refunds and penalties. a means estimate In this Contract, RD fog, BOX 2528A IF YOU 00 NOT MEET YOUR CONTRACT wean OBLIGATIONS, YOU MAY LOSE THE thoSELLER. ARMSTRONG MOBILE HOME SALES FLEETWOOD PA 19522 MANUFACTURED HHOME THISNDPROET YTHAT - YOU BOUGHT ANDIOR cane r, a - MONEY ON DEPOSIT WITH THE ASSIGNEE. You are RICHARD D SHUMAN LINDA L SHUMAN This Contract is between Stier and Buyer. AN the 83 DANIEL ROAD W KUTZTOWN PA 19530 intn have been made by Seer. Serer intends to to assign this Contract is the Aniline. BUYERIS). ratas ... of f A t Fi ti I i amo PROMISES JOINT AND SEVERABLE: If then it more than one Buyer, each of you promises, separately and together, to pay at sums due set and to moun at za on o tem Cas h Price perform all a rsamnts in this Contract. 00 500 $ 62 TRADE-IN: You have . , 1981 HALLMARK s 9 ,000.00 $ N/A -B 9 02? .00 traded following Cash Downpayment home: ome: manufactured reran Make LIW an Model rats wance Still sumo of n $ 500.00 Ifs balence Is dill awing on the manufaetund home you have traded in, the Saint will pay off this amount on your behalf. You wamnt and represent to except as shown above as the amount'Stia Owing.' dose encumbrance or security Interest f u i f h d i Net Trade-In , rom rn s ree us t at any tra e- n PROPERTY INSURANCE You may choose the person through whom Insurance Is obtained aaamst lost of or damage to the manufadund home and $ 9,000.00 against Nobility arising out of use or ownership of the manufactured home. H you obtain property insurance through set, the premium cosh for the the hem staid To Property Insurance Company of the ITEMIZATION OF AMOUNT FINANCED l d d i I d b l Total DownyaYmeet nc u e ow are n e insurance terms indicate section of this Contract. In the section called YOUR PROMISES ABOUT INSURANCE on the reverse tide of this Contract, you are promising to insure $ 9,500.00 the manufactured home and keep it insured. Unpaid Cash Price Balance X Msnufactumdllomol ,470.00 Term 60 __M as. Other 8 H/A Tenn Mot. $ 53 000.00 Physical Damage Ins. -Vescnbel To Credit Insurance Company I X CompnhentNoon $ INCL. Tenn 60 Mos. Other a N/A Term Mos. X $ N/A Manufactured Home reescribel To Property Insurance Company a ii X Fire and Theft $ INCL, Toa 60 Mot. TOTAL CHARGES 6 2,470.00 $ 2,470.00 CREDIT INSURANCE IS NOT REQUIRED: Cndk Life Insurance is not required to obtain credit, and will not be provided unless you sign below and ague it t g t l ifi a To oublic officials for. Toga and Registration License sy w a ca e or pa to pay the additional cod. Please read the NOTICE OF PROPOSED CRE01T INSURANCE on the reverse side. Your insurance cert , you the MAXIMUM amount of Insurance available. 20.00 By signing, you select Single Credit Life Insurance, What it your age? By signing, you both select Joint Credit Let Insurance, what an d Lien Fee 00 5 which costs E H /A Years which costa t N/A your ages? . $ To Sales Tax 1 $ N/A 2 Signature of uyerto be Insured for mp rem Life Insurance . To Flood Fee a $ 35.00 ,pnatuno of Buyers to be Insured for Joint nn e # To Closing Costs Insurance _ I $ 145 , 00 nsurer, MANUFACTURED HOME You sane to purchase, under the terms of this Contract, the following manufactured home and its appliances, furniture, Amount Financed oqu?moit and fixtures, which It caged the 'Manufactured Homi Is this Contrast. $ 55 675.00 NN Year and Manv(actmr UNU A Width Color & Medal Sarisl Number Ramon Charge N 1999 REDMAN 28X72 SANDPIPERSHADOWRIDGE1223-3680 $ 158 258.00 Total of Payments (Time Balance) Equipped $ 213 933.00 with Payment Schedule • You agree to pay ASSIGNEE We may assign this Contract ad Seeariy Agr....eI to a'Assipa' 11 M ray tee the Owner of this Contract assigns this Contract to to us the Amount Financed Out another easignes, the term than saran to such ether atsig.... Agar the Anipmm4 d rights and haarrte of the Seller in this Contract and in W Interest in 299 Uninterrupted monthly Secerhy Agnemant that balesg to ad M afwes" by tie Assignee. The Acclaims we eerily yen whose sed k Sao makes an assiannaot. payments of $ 713. 11 each CO-SIGNER: Asy gems difaloN tha CaShods Agreement promises, separably ad together with d CaSgamb?sd Boyerfs), to pig as rams due ad ado find payment of $ 713.118. to perform as agrammals In We Contract CoSianer will not be as Owner of the Maofodwd Name. CO-OWNER: Any person signng the Ca4uroer's Security Agraemaat giros is a gawky bownst a the Ma tfut od Hems and gums, apantely said ' The Taat payment will be due on hamir together with d C*4wmW and Beyerlel to perform tit agreements in the Security Narcosis and d othr pate of thin Contract aapl W and then to Pay" "stied payments will be due an that same day TERMS: The teat shows in the Miss above an part of this Contract. of each month followin SECURITY AGREEMENT: To secure the payment of ail sums due and the performance of ell required ADDRESS WHERE MANUFACTURED HOME Will BE KEPT: obligations under this Contract, you give us a ncurfty Interest in the Manufactured Home, in dl opphancet, furniture, equipment and natures (Called 'accasdons*) attached to the Manufactured Home at any liter time. and in any proceeds of the Manufactured Home, including insurance prewdL The Assignee may set-of any =*cuts due and mpaY wider thin Contract Most mY at ADDITIONAL TERMS AND CONDITIONS: THIS CONTRACT CONTBAIES ON THE REVERSE SIDE your money on deposit whit Assign. This includes my mass which is new or easy a the Man in YOU ARE OBLIGATED TO ALL THE TERMS OF THIS CONTRACT WHICH APPEAR ON THE FRONT AND deposited with Assign by you. Auigro may de this without my pier erf m to yea. REVERSE SIDES. woogratatdlhell I -rodNom asVo own ana,morftce ouL NOTICE TO BUYER: 00 NOT SIGN THIS CONTRACT IN BLANK. YOU ARE knig;rgMew , ENTITLED TO AN EXACT COPY OF T HE CONTRACT YOU SIGN. KEEP IT TO PROTE UR LEG -.A] III- TBM FILE iiiiaimiE San auymd ' ` I v R HARD D S M Q ? gJJK,w,-• 7- •t? BuYER (BEAU ?4a" e L I N A L HU N - r_ ?DMIlID6E RECEIPT OF A COMPLETED COPY OF THIS CONTRACT AT THE TIME OF . ffrt"1747 1ADDITIONAL TERM 1. PROMISE TO PAY: You agree to pa us the Total Sale Price for the Manufactured Home by making the Total Downpaymnl and ppaytnp as the Amount Financed plus intend. You promise to make payments in accordance with Ilan Payment Schedule. You promise to mob ppayments on or before the same do. of each month as the fist sy?in^rut due date. You agree to pay a1 ether amounts S AND CONDIT ?. company on your behalf and give you a copy of any insurance policy we obtain x year lies are unable to do so, we will notify you that you must obtain replacement insurance train as broker of your choice. If replacement covmgenselts in additional coat: to yon for On y period of gar insurance policy, we will mmbune you fdr the coats. which may 6eceme due under the terms of this Lantroct. You oaree to pay t Short or Asinones costs of .it Yams also agree to pry reasonable attorneys fees if &Nr or Assignee hires an sttomeyy to coNct amounts due under this Contract or to protect or ode possession of the Manufacture Home. You agree to make payments at the place or to send payments to the address which the Assignee most recently specifies in the written notice to you. 2. NOW THE TOTAL OF PAYMENTS IS COMPUTED: The Total of Payments is the sum of the Amount Financed and the Finance Charge. The Finance Charge consists solely of interest computed dally on the outstanding balance of the Amount Financed. TRa finance Charge shown on the front side has been computed on the assumption that we will receive aI payments on their scheduled due data. 3. COMPUTING INTEREST: We will charge interest on a daily basis an the outstanding balance subject to interest on each day of the loan lean. The daily interest rite is equal to the Annual Percentage Rate divided by the number of days in that calendar tear. Buyer agrees that because Interest is calculated on a daily basic, late payments will naulf in additional intend (and, if appkcable, a late charge). Early payments will result in less interest being charged. Early andlor late payments will cause the amount of the find payment to change. 4. LATE CHARGE: Buyer agrees to pal a lpite eharg for any payment not made within 10 do v after cha TWO late date. its due be a fuAamon mount The late chi leew'N be do nt. cons der any part of a month in excess a 10 d y: ton the when earned. No late bharpe wit he due if the reason that the oyment it Iola is because, after default, the entire outstanding balance on this Contract is due. No Rala charge will be due H the only reason that the payment b late is because of a bb charge assessed on an nrker payment. S. APPLICATION OF PAYMENTS-.We will apply payments in the following order of priority: merest late charges, het and then principal 6. PREPAYMENT: You may propalY. in full or in part, the amount owed on this Contract at any time without onalty. It you 1011 prepay this Contract m part, you agree to continue to make ngulerh schedule msnts you wig mike. f ou P poil ay in tut, weuwillrnI is Contract ' tund to you nytunwill earnedncrethe dit prmnncs paremium you paid. y 7. WAIVERS: a. WAIVER BY SELLER AND ASSIGNEE: We and Assignee waive the right to trial any property as security for the repsyment of this Contract, except far the Manufactured Home and the other security c acdicanv mentioned n this Contnct. b. WAIVERS BY BUYER CDSIONER AND CO.OWNER You agree to make an payments on at before they an due without our having to ask. You give up any right you may hove to require that we enforce our rights against some other person or property before we enforce our rights against you. You syran that we may give up our rights against some other person but not against you. You waive due diigmncs in collection and all defenset bated on suretyship and enpoianent of collateral or security. B. INTEREST AFTER MATURITY AND JUDGMENT: Interest at the rate provided In this Contract shat continue to scame on the unpaid balance until paid In full, oven after maturity andlor after we get a judgment a end you for the amounts due. This will ailyfy oven R the maturity occurs because of acceleration. It at any time interest as provided for in this perapnph Is not permitted by law, Merest shag accrue at the highest rate allowed by applicable law beginning at that time. 0. YOUR PROMISES ABOUT OUR SECURITY INTEREST: You will not permit anyone other thin u to obtain a security Intend or other rights in the Minufactund Heme. You will ps IN fig fee necessary for us to obtain and maintain our security interest in the Manufactured Hams. You w assist us In having our security Interest noted on the Certificate of Title to the Manufactured Home You will not sol or Vivo sway the Manufactured Home. If someone puts a Ilen an the Manufactured Home, you will pay the obligation and clear the fen. 13. OUR RIGHTS IF YOU BREAK YOUR PROMISES ABOUT THE SECURITY ? a MANUFACTURED HOME OR INSURANCE: If you fag to keep your promises to pay fig few Illegal, Was or the costs necessary to keep the Manufactured Home in good condition and np*t=" . ' advance any money you promised to pay. If you fag to keep your promises about npka/ess we may advance money to obtain insurance to cover loss of or damage to the Mao We have the choice of whether or not to advance any moneyy for those purpons. Such f emeaer MEN% behalfoto they balance an whyou Iwo on It is ich we imposenFinance Charges at the Aind advance on youramount Psrcmtaps Rate of this Contract. You hone to repay the money advanced is we dare may ill Immediately on demand, or f) dung with your monthly payments. If we choose to alew M repay he mono9 d how adva eenced abnp with your ay. M an monthly y payments, wa can ehoese the amoal ls anp you heve to rep oft our rights stetd n title en L all `. p parmdtryman k d by law, we d 0 have rho other r<phte menlened. Our payments myour betaaK loin eel eeae your hIlun to perform your promises in this Contnct. Tha premeas yw made n rho sestiene abeee calvd OUR PROMISES ABOUT THE MANUFACTURED HOME and YOUR PROMISES ABOUT hay bgsp INSURANCE and our rights under this action shall real martin with any judgment intend is hdion and Sban apply maid ell amounts owed en paid in full. Y 14. DEFAULT: In thle pangnph 'You' meant the Buyer. Co-Signer and Co-owner, or any ea of z them. You will be in "Default a this Contract 'd any one armors of the folowno things happrc a. You do not make any payment on or before it is due; or b. You do not keep any promise you made in this Contrast; or c. You do not keep any promise you made in another contract, note, ban or agreement with Setif or Assignee; or d. You made any maims statement In the credit ailppFcatbn for this Contract: or e. You committed any forgery in connection with this Contnct; or f. You dim, are convicted of a cane involving fraud or dishonesty, or are found by a eeurt, with jurisdiction to do so, to be incapachated; or g. You file bankruptcy or insolvency proceedings, or anyone films bankruptcy or ineleeecy proceedings against you; or h. You use the Manufactured Home or allow someone also louse it In a way that causes k oat to be covered by your insurance; or ,. L You do something that causes the Manufactured Home to be oub)ect to confiscation bV government authorities; or t. "a Manufactured Home is last, stolen, destroyed or damaged beyond economical npak, and not fixed or found within a reasonable Ins; or k. Another creditor tries to take the Manufactured Home or your money on deposit wkb Assignee by legal process. 15. OUR RIGHTS IF YOU ARE IN DEFAULT OF THIS CONTRACT: If you am in Dsfn* of this Contract, we may enforce our it hts according to law, after we hove given you ary,appieobb!oto andlor right to can as nquirelby law. We may also do the things epecifrllp mentioned as this Contract. We may do ore of these things and at the same time or later do another. Same of IM !hilt we may do are the following: a. ACCELERATION: We con demand that you pay to us the entire unpaid boNece swig me lit Contract and at unpaid finance Charge. and other money due. You a res that Two will pay this mansep.to us n ens sin Is paymerit anmedntely upon receiving our demand. b REPOSSESSIbN: We can repossess the Manufactured Home, unless preHBe1 by low. We can do this ourselves, have a qualified person do it for us, or have a governeeat effial by?i do It for us. You alms that we can peaceably come on to your pproperty to do this. We on my other thinpa founin the Manuhelured Hama, Ent win return ihau lhmg? to yw i }w ttL f yw t want iheev thinpt back, a. you apse to ask us In a bitter it-"I' by at mAritbi llftonet ¦ s ou do rear it us this Miler, yyea ooHe up may claim la tnpt. You agm lest w erg lane Beer it license plates is nppoasenny the Minufactund He- and teknp d to a place tar steratiR c. VOLUN7AHY DELIVERY: We Co. ask you to Vise us the f ManufIt Nemee st a essosarbiti convenient place . You a M. to yyin w the Manufactured Home i we as d. OELAY IN ENARCEMENT: W. can delay enforcing our rights under Qb a.t w terse It losing any rights. 10. YOUR PROMISES ABOUT THE MANUFACTURED HOME You will keny the Manufactured Home in good condition and npak. You will pay ON taxes and charges on the Minufactund Home. You will pay all costs of maintaining the Manufactured Home. You will not abuse the Manufactured Home or permit a^ythina to be done to the Manufactured Home which will reduce its value, other than for normal wear and nay. You will not use the Manufactured Hone for Illegal purposes or for him or lease. You will not move she Manufactured Home from your address shown on the front of this Contract to a new permaeenl place without notifying us in advance. You win permit us to rasped the Manufactured Home at any reasonable fine. You agree that the Manufactured Home will, at all times until this Contract Is paid In full, remain personal property. You agm to place the Manufactured Home in such a way that it can be removed without substantial damage or impairment of its value. If you plan to place the Manufactured Memo on a promises you are basing, You must obtain a Landlord's Waiver satisfactory to us. The Landlord's Waiver must permit us to enter the promises and to Manufactured hags. is glost hdamagedmust ptform lour promises underl this Conracto even if The default your or destroye d. 11. YOUR PROMISES ABOUT INSURANCE: You will keep the Manufactured Home insured against fin, theft and other hazards against which owners customarily Insure such Manufactured Homes unto all sums due us an paid in full. The Insurance coverage must be satisfactory to us and protect your interests and our nteretta at the time of any insured loss. The insurance must name us as 'Ma-peyee• on the poky. The insurance must be written by an insurance company duly Reveled to all Insurance in the state when the Manufactured Home is permanently kept. The insurance policy must provide us with at Mast 10 dayys prior written notice of my cencetetbn or nduden m t you teal nft ahpokey or other evidence of insurance covers ps to us. In tM Call 9. Oa reque'Jam anent of any has: age to rho Manufactured Hums, you wit armedialely y n wmnp and file a proof of less with the nwnr. We may fie a proof of loss on your 6shalfnol'rf'rf youusfed ar refuse to do sa. We may endorse your acme to an y c a ,draft or other Instrument we receive in payment of xis nsvnd bas or moan manna Pnmnens. Wa may apply any Insurance Huads we receive is npak or nvvlace rho Mmefastund Hum K, n our opnwn, a is aonomicsly feasible and you are not tbea in M(aeh ending this Contnct. Otherwise, we wall app M the insurance proceeds to reduce the unpaid balance due us. 12 OUR PROMISES ABOUT INSURANCE: Thu paregn h applies only K we hove contrasted to pudaw physical damage, comprehensive, fire andlor tfieIt insurance at your expense and the premium has been included in the Amount Financed. If you preppy the turns duo on this Contract, unless you specificsW request cancellation, the nsurance will remain n effect to Rs scheduled expiration date. If the lnnnnce we obtained for you is cancelled by the nserance company prior to its scheduled expiation dots, we will attempt to place comparable insurance with another insurance 18. SOME THINGS YOU SHOULD KNOW IF WE REPOSSESS THE MANUFACTUR® NMEName repossas+without usnga government official (by replevink a. NOTICE: We will send you a Notice of Repossession to your lad address we (tame oba L This Notice will tell you how to buy back Imilevm) the Manufactured Home. This No4cs win us lie other information mquned by law. b. CURE: You have the *ht to cure your Default at any time before we al do fW mimcl d Home. It you cure your Default. this Contract will remit in effect as though the Dow tidal occurred. c. REDEMPTION: You have the right to buy back Indaem) the Manufactured Now vat 15 days of mailing the Notice of Repossession and at any later time before we sell The ldaedstlsael Home. it. SALE: If you do not cure your Default or redeem, you give up ail claim to and w wit miss Manuf actured Home. The money received at sale will be used to pay costs and spear sal lba be pay the amount you owe on this Contract. e. SURPLUS OR DEFICIENCY: If there is money left, we will par it to the Beyer. B there he are enough money from the sale to pay what you owe, Buyer and Co-Signer agree to pay who it so owed to us. npeseeaig L EXPENSES: We have the right to charge you, and you agree to pay the costa at storing, repairing, prearng for sale and soling the Manufactured Home as may be allowed by va These costs will only Ba due d: 1. Default exceeds fifteen 115) days at the time of repossession; 2. The costs art actual necessary and reasonable; and 3. We can prays the costs were paid. 17. HEIRS AND PERSONAL REPRESENTATIVES BOUND: After your death, this Contract sbai be enforceable against your hears and personal representatives of your estate. 18. GOVERNING LAW: This Contract is to be Interpreted according to the law of Pennsylvania. 18. SEVERABILITY OF PROVISIONS: If for any reason any part of this Contract shall become ieph void or unenforceable, that pad shall not be a part of this Contract. 20. ASSIGNMENT BY BUYER: Buyer shall not assign this Contract. 21. THERE ARE NO WARRANTIES BY SELLER EXPRESSED OR IMPLIED, INCLUOINB TE WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. UNM WE HAVE GIVEN YOU A SEPARATE WRITTEN WARRANTY. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ARM. AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER SIT TO DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE OF PROPOSED CREDIT INSURANCE The signer(s) of this Contract hereby take(s) notice that Group Credit Life Insurance coverage will be applicable to this Contract If so marked on to front of this Contract, and the coverage will be written by the insurance company named. This insurance, subject to acceptance by the bssuao. covers only the person or persons signing the request for such Insurance. The amount of charge is Indicated for the Credit Insurance U be purchased. The term of insurance will commence as of the date the indebtedness is incurred and will expire on the original scheduled msuff" oll?r of the indebtedness, unless a shorter term Is so marked on the front of this Contract. Subject to acceptance by the insurer and within 30 days„ 1 will be delivered to the insured debtor(s) a certificate of insurance more fully describing the insurance. In the event of prepaynsnest d. Indebtedness, a refund of insurance charges will be made when due. qW(. ,Ian 'STRA"' ?J LakeRIDGE ROAD? OAK RIDGE, NEW JERSEY 07438-8906 ADMItq 50 OAK WwW.Iaketandb8nk.10m ank%, 2 973.697-2000 July 25, 2006 Heritage Financial Attn: Elizabeth Mallory Suite 304 600 East Crescent k 07458 Upper Saddle River, NJ • human Richard & Linda # 098-1648 Re. S in regards to the }dear Ms. Mallory, pursuing judgment application and for you to proceed in cater printout, note, authorization Of the comp a copy Please note that the total deficiency 0 totaling This letter serves as have enclosed ul. Ple above-mentidebtor. ought might be helpf80961 and all interest due at 15 any other documents $32, 482.27. rincipal, expenses totaling balance is $68, tal judgment $25,745.68 ino of today. The to $9,926.98 as rice of this unit is $27,253.24. The net sales p uestions to contact me if You should have any q Please feel free ?- Sincerely, ?? Y j ? , ; : ? ! z#s Leo L. Macali n, VP Collection Department Sr 973-697-7905 LLIvVjk Enc. -B- + • 03/06/2007 TUE 14:41 FAX 2018185166 LAKELAND - LEO MACALI 14AR=06=2007 14::03 KNUPP KODAK & IMBLUM ?I VERIFICATION 007/007 71-7 238 715$''. P.07 eiz I, LEO L. MACALI, Vice) President of LAKELAND BANK, verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. LAKELAND BANK eo L. Macali, Vice President Dated: 3/13/07 33129 TOTAL P.07 t'F ? Q O ? C? N fl M73 '(?.. r y C7 ? i-r1 too LAKELAND BANK assignee of Armstrong IN THE COURT OF COMMON PLEAS Mobile Home Sales CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA v RICHARD D. SHUMAN and LINDA L. SHUMAN, now known as Linda L. Short Defendants NO. 07-1537 CIVIL CIVIL ACTION - LAW TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) RICHARD D. SHUMAN and LINDA L. SHUMAN, now known as Linda L. Short, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiffs Complaint $82,178.71 Interest from July 26, 2006 at the rate of 15% per annum $9,501.87 Total $91,680.58 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. U , KODAK & By Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. 4?67 1.0d J 4 1. Pr onotary LAKELAND BANK assignee of Armstrong IN THE COURT OF COMMON PLEAS Mobile Home Sales CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V NO. 07-1537 CIVIL RICHARD D. SHUMAN and LINDA L. SHUMAN, now known as Linda L. Short CIVIL ACTION - LAW Defendants TO: RICHARD D. SHUMAN, Defendant(s) You are hereby notified that on n-.„ m .20a the following (Judgment) has been entered against you in the above-captioned case. Tudgment entered in the amount of $91,680.58. DATE: 7k,r?, l a d ao I Pro onotary I hereby certify that the name and address of the proper person(s) to receive this notice is: RICHARD D. SHUMAN 57 SOUTH 39m STREET CAMP HILL PA 17011 Dated: May 8, 2007 Robert D. Kodak, Attorney for Plaintiff Robert D. Kodak Gary J. Imblum LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 kkidaw®verizomnet April 16, 2007 RICHARD D SHUMAN 57 SOUTH 39"' STREET CAMP HILL PA 17011 FILEM.Y Facsimile 717.238.7158 RE: Lakeland Bank, assignee of Armstrong Mobile Home Sales VS: Richard D. Shuman and Linda L. Shuman n/k/a Linda L. Short No. 2007-1537-Civil, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 33129 Dear Mr. Shuman: In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint.. Very truly yours, KODAK & IMBLUM, P.C. Robert D. Kodak THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: PATRICIA CHESTER HERITAGE FINANCIAL RECOV 600 E CRESCENT AVENUE SU I UPPER SADDLE RIVER NJ 0745 - - A7 #194981 FI LAKELAND BANK assignee of Armstrong Mobile Home Sales Plaintiff v RICHARD D. SHUMAN and LINDA L. SHUMAN, now known as Linda L. Short Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1537 CIVIL CIVIL ACTION - LAW IMPORTANT NOTICE TO: RICHARD D. SHUMAN , Defendant(s) DATE OF NOTICE: APRIL 16, 2007 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 Robert D. Kodak Gary J. imblum LINDA L SHUMAN NKA LINDA L SHORT 5703 E MAIN STREET P O BOX 185 VERONA NY 13478 LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 kkilaw®verizomnet April 16, 2007 7,. 5 1LET F Facsimile 717.238.7158 RE: Lakeland Bank, assignee of Armstrong Mobile Home Sales VS: Richard D. Shuman and Linda L. Shuman n/k/a Linda L. Short No. 2007-1537-Civil, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 33129 Dear Ms. Short In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint Very truly yours, KODAK & IMBLUM, P.C. Robert D. Kodak THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/ kqb enclosure cc: PATRICIA CHESTER HERITAGE FINANCIAL RECrW% 600 E CRESCENT AVENUE SU UPPER SADDLE RIVER NJ 074 #194981 FILE LAKELAND BANK assignee of Armstrong IN THE COURT OF COMMON PLEAS Mobile Home Sales CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 07-1537 CIVIL v RICHARD D. SHUMAN and LINDA L. CIVIL ACTION - LAW SHUMAN, now known as Linda L. Short Defendants IMPORTANT NOTICE TO: LINDA L. SHUMAN, NOW KNOWN AS LINDA L. SHORT, Defendant(s) DATE OF NOTICE: APRIL 16, 2007 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 cn `1J k b 04 i? r 4L- f SHERIFF'S RETURN - REGULAR ? CASE NO: 2007-01537 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAKELAND BANK VS SHUMAN RICHARD D ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHUMAN RICHARD D the DEFENDANT , at 1945:00 HOURS, on the 23rd day of March at 57 SOUTH 39TH STREET CAMP HILL, PA 17011 by handing to SUSAN BATES, SISTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Postage .63 Surcharge 10.00 L)lb` 161 00 43.03 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/29/2007 KODAK & IMBLUM By. Aipj Deputy Sheriff A.D. 2007 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2007-01537 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAKELAND BANK VS. SHUMAN RICHARD D ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT SHUMAN LINDA L N/K/A LINDA L SHORT by United States Certified Mail postage prepaid, on the 22nd day of March ,2007 at 1000:00 HOURS, at 5703 E MAIN STREET PO BOX 185 VERONA, NY 13478 and attested copy of the attached COMPLAINT & NOTICE +-1-, Together . The returned receipt card was signed by GLENN MUTTERSBAUGH on 03/27/2007 . Additional Comments: Sheriff's Costs: So ans r- Docketing 6.00 Service 4.88 R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 20.88 ?yJ?fa-t- Paid by KODAK & IMBLUM on 03/29/2007 Sworn and Subscribed to before me this day of A.D. , a true H newery fa y ¦ Print your metre and addrome on the romm A so that we can return the cod to you. ®. Rerarired by ¦ Attach this card to the t>ach of the i11 , or on the front if space pw *8 1. ArMs Addressed to: Linda L. Shuman nka Linda L. 5703 E. Main Street PO Box 185 Verona, NY 13478 Agent of Davery D. N deuMery ibsae ditwa Ap ilm 1? ? Yee M YE% ~ d*. y address blow: ONO SWAN YOP XYJWAMW Mau 0 a p m Mau 0 Repmmsd O Ream Recey?t for Merchandise 0 Insured Me# C.O.D. 4. Restricted Dativery? (Extra Fee) 0 Yes 7005 1820 0002 4619 0579 07-1537 civil PS Form 3811, February 2004 Domestic Ream ReodpC 102595-0240-1540 *q "4h PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P. R. C.P. 3101 to 3149 LAKELAND BANK, ASSIGNEE OF IN THE COURT OF COMMON PLEAS ARMSTRONG MOBILE HOME SALES CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Writ No. vs RICHARD D. SHUMAN and LINDA L. SHUMAN n/k/a LINDA L. SHORT 57 S.39TH STREET CAMP HILL, PA 17011 Defendant(s) Term 20- No. 07-1537 CIVIL Term 2007 Amount due $91,680.58 Interest FROM DATE OF JUDG - 05/10/07 Atty's Comm. $ 4,584.03 Costs to -be determined $ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, I (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania (2) against RICHARD D. SHUMAN Defendant(s); (3) and against Garnishee(s); (4) and index this writ (a) against RICHARD D. SHUMAN 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 and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC. (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA. 17108 (717) 238-7159 Dated 6/13/07 Attorney For Plaintiff(s) •(o)boT•E aTng aag •paaTsap sz suapuad sTT a s'P bUZxapuT pue pagoe;;e ST aagsiuzeb aqq ;o aweu aqi uT d;zadozd Teaz ;T Aluo paaaTdwoo aq pTnogs (q) (t) gdazbazag .(q)b0T£ aTng aaS -Aaeiouoq-4oad aqa dq A-4unoo Oeuj uT asznoo ;o ee paaTnbaz sT buixapui Ajunoo zaggoue oa sansei ;Tam aqa uau4 •(a)iOTE aTng Aq pazTSOgane se paaTsap ST 'aOuaznssi ;o AOunOO aql uT suoTInoaxa aqa ;O burxaput ;T ATuo paaaTdwoo aq pTnogs (e)(6) gdezbezed (IT-im aq; uT papnTOUT aq 03 sT aagsTuzub paweu a uT dTuo pa'39Tdwoo aq pTnogs anoge) (E) gdezbezad •panset goTi4m uT Alunoo aq; ;o ;;?zags aqa oO ATuo paIOazip aq Aew ;uawbpnE pazza;suezq a uo panes? }TSM a (o)EOTE aTng zapun •paieotpui aq pings .t;unoo aqa '(q)EOTE aTng dq pazTaogjne we A;unoo zag:10ue ;o ;;TZags ag; o; p9-4Oazip sT -4SSM aqO uagM (Z) gdezbezed zapun SION I oI r N O) N H r o E LO cn a a b a H a ?4 a ? I z o ?4 o 3 z cf+ C ? _ <1 l z4 Y _ 0- V LJ 5 © N 7 M4 4. 0 ;3 M Q N? z 0 H U W k W a 0 W w a H U W a 1 06 4 ? m w 44 x 41 m 0r-i x a ?4 0 v o oW P4 4 e4 Q M ? J >16 C;)- J` N WRIT OF EXECUTION and/or ATTACHMENT s . . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1537 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LAKELAND BANK, ASSIGNEE OF ARMSTRONG MOBILE HOME SALES, Plaintiff (s) From RICHARD D. SHUMAN AND LINDA L. SHUMAN N/K/A LINDA L. SHORT, 57 S. 39TH STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC.. (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 $91,680.58 Interest FROM DATE OF JUDG - 5/10/07 Atty's Comm % $4,584.03 Atty Paid $182.91 Plaintiff Paid Date: JUNE 15, 2007 L.L. $.50 Due Prothy $2.00 Other Costs Curti M. Lo o otary (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 ?t_rtr: tom. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ Advance Costs: 150.00 Sheriff s Costs: 66.20 18.00 $ 83.80 1.30 t ?- .50 2.00 Refunded to Atty on 11/06/07 14.40 30.00 66.20 ? lzl o c. i d 7 So Answers; R. Thomas Kln, eriff W cI??CV v Q--Au iaA-t baker LGOl R0'O WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1537 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LAKELAND BANK, ASSIGNEE OF ARMSTRONG MOBILE HOME SALES, Plaintiff (s) From RICHARD D. SHUMAN AND LINDA L. SHUMAN N/K/A LINDA L. SHORT, 57 S. 39TH STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC.. (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 $91,680.58 L.L. $.50 Interest FROM DATE OF JUDG - 5/10/07 Atty's Comm % $4,584.03 Due Prothy $2.00 Atty Paid $182.91 Other Costs Plaintiff Paid Date: JUNE 15, 2007 91J Curti R. Long n dtary (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 cyk,