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07-1803
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant No. L ` COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR405452281 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff VS. Civil Action No. STEPHANIE P SFERLAZZA Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation having offices in 5700 CROOKS RD STE 301 TROY, MI 48098-0000 . 2. Defendant is an adult individual residing at 329 S WASHINGTON ST MECHANIC SBURG,PA 17055 . 3. On or about APRIL 7, 2001, Defendant duly executed a RETAIL INSTALLMENT CONTRACT (hereinafter the "Contract") a true and correct copy of said Contract is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly identified in the Contract as a 2001 SATURN SEDAN. 5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned to Plaintiff. 6. Plaintiff avers that Defendant is in default of the Contract by having not made payment to Plaintiff as promised, thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that a balance of $ 6,248.27 is due from Defendant as of FEBRUARY 9, 2007 8. Plaintiff avers that the Contract between the parties provides that Plaintiff is entitled to interest at the rate of 6.0% per annum. 9. Plaintiff avers that the Contract between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees. 10. Plaintiff avers that such attorneys' fees amount to $1,000.00. 11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, attorneys' fees, interest, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, STEPHANIE P SFERLAZZA , individually, in the amount of $ 6,248.27 with continuing interest thereon at the Contract rate of 6.0% per annum from FEBRUARY 9, 2007, plus attorneys' fees of $1,000.00 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molc , Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:05452281 r}ts co,.,??c-T ? S Ace-oM?A ? ta.D ?? G M4? sM +!¢T8? f. ? ?. Q . / GMAC RETAIL INSTALMENT SALE CONT" 1 J y J I Dealer Number Contract Number . G 6 9 Buyer (and Co-Buyer)-Name and Address (Include County and Zip Code) Seller (Creditor) Name and Address "I•p; AN] 1` 1' :;Ef?a:L!IZkP. :'A.TURN, if. r"p!.1 :'!.1•: I')I: b: 514 E :S1P1PSOA! CA!iLL_1.4: PIFfrQ1 N1G;NW,C, PA 1/o','! f?ICCRP.N[L:CIISIJH!: !'F ! iO`?`.: C I1MB!iR L A I,l D You, the Buyer (and Co-Buyer, if any). may buy the vehide described below for cash or on credit. The cash price is shown below in the "Itemization of Amount Financed" as "Cash Price" The credit price is shown below in the Federal Truth-In-Lending Disclosures as 'Total Sale Price' By signing this contract. you choose to buy the vehicle on credit under the agreements on the front and back of this contract. 'You" and your'refer to you, the Buyer, and any Co-Buyer, "We "Us" and "Our- refer to the Seller named above and to anyone to wham the Seller assigns this contract Seller intends to assign this contract to General Motors Acceptance Corporation (GMAC). Description of Vehicle. You agree to buy and we agree to sell the following vehicle: New or Used Year Make and Model Body Type --Vehicle Identification No Use for Which Purchased c[?;' I - - -- __--? C, personal .lags icul;ural I [!business If truck--Describe body and major items of equipment sold. , ANNUAL PERCENTAGE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price RATE The dollar amount The amount of credit The amount you will have paid The total cost of your purchase The cost of your credit as a the credit will cost provided to you or on after you have made all pay- on credit, including your down- yearly rate. you. your behalf ments as scheduled. payment of $ I enr ? 1W erl.. t _... f9.Gr.,.t.t t, :771 ?l $ $ $ $ PavmeM Schedule Will Be: Number of Payments Amount of Payments When Payments Are Due Or as Follows. Monthly beginning ' ^- -- Late Charge. If a payment is not paid in full within 10 days after it is due, you will pay a late charge- If the vehicle purchased is a heavy commercial motor vehicle, the charge will be 4% of the amount of the payment that is late. If the vehicle purchased is of highway business or farm equipment, the charge will be 5% of the amount of the payment that is late. Otherwise, the charge will be 2°'a per month on the amount of the payment that is late, Computed on the basis of a full calendar month for any fractional month period in excess of 10 days., Prepayment. It you pay off all your debt early you may be entitled to a refund of parjpf Pe fpance charge. Security Interest. You are giving a security interest in the vehicle being purchased. I Additional Information: See the other side of this contract for more information including-information-about nonpayment, default. any required repay- ment in full before the scheduled date, prepayment refunds and security interest. I I. ITEMIZATION OF AMOUNT FINANCED 1 Cash Price (including any accessories, services, and taxes) $ 0:1 (1) 2 Total Downpayment = Net Trade-in $ • / A. + Cash Downpayment $ 1 6100. 1014 + Other (Describe) $ Your Trade-in is a $ 1 , 60(4 . r30 (2) Year Make Model . -. ? ,..", _ -. ... Bajarrs oLCastt Prim (t rrtsulg 2) $ 15,910-00 .. (3) . n"wA4x-a'-S"„ s Amodtts-Paid to, Others on Your Betlallf , na1f be keBpig pert of these artgtetls.J: (Seuter ,. ., n - r., . . . lpsrpapoe Paidlo the Insurance Comparry Named in the b&Vehimk£et r i r ., err_.c-s ?.?ar? Narrhed ch ttla,tF:w i? s •?'" - e lur UZ Tumr of the C-Irac.l Paid S $ omtUebw s11 $` NIA :. --Pdbfnweam'etd Jlgernes: "? -., :$-------------? - - F `7axes Nat MlcGidad$Casti PJ»a U. -'S? -.?: zv :r-: -&:, Q? , . ? '(R . , , , ' ? ., „pd;ovearnent}icegse alid.6f RegLSVadon Fees(ttarr ¢e);^° ... - ' ..$ ? r1, ?.F : -, _arOo'varmreni CerhTicatebf Tale Fees $?227 W_ i Other Gy ges (Seller must identify who will mceNe payment and dtscrbe plrpose) . . - e r? to bantRA E%f?tRR. oS. 73,W00 Mme $ 1,335.00 to $- - - - - - 33-$- Total OdwCharges and Amounts Paid to Others on Your Behalf $ 2,649.20 (4) 3Amount oarrced=Orr?ar3Balarrce(3+4j $ , 6 Rrtence Charge Additional Disclosures 7 Tlma Balance-Total Of Payments (5 + e) --T°--Flagrrlroa by Stele Law . - y ? F "I a Paygr 4t Schedule:?2- instalmeinta?f S each, monthly beginning - tom-) tDey) t?'r.) or N echedubd WYrrhenta ere Irragerm a whevan, ""''?-..• ,. as hhdlceted m the. Federal Tr-In-Leading Diedosuras, above. below 0te pikies or certifi Ms issued by the Carhpama5 named wi4 describe the terms and conditions. l sf _.,,a -------------- -- (Name of ktstnar-LAe) - (Hone Office Address) . (Name of Insurer-A a H) (Home Office Address) This Policy wr 'ti pay amounts due on this contract upto$ N/A APPROVAL: I DESIRE TO OBTAIN THE CREDIT LIFE ANIXOR ACCIDENT AND HEALTH INSURANCE CHECKED ABOVE FOR THE PERSON/ PERSONS PROPOSED FOR INSURANCE. Buyer Signature Date Co-0uySig rk nature Date ANY INSURANCE THIS CONTRACT DESCRIBES DOES NOT INCLUDE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is `fo uo' HeA- (NAME) mnmq,i ?o cA (-?dyrti nifiS fA b(of G KA plaintiff herein, th9tt (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. WWR#05452281 C.Tt .13 1 1 0`3 r ?. i?1Sw2r -?o Comp 1c? ? n+ In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Division GMAC, LLC plaintiff Vs. Stephanie Sferlazza Defendant 4/20/2007 To Whom It May Concern: No. 07-1803 Complaint in Civil Action I, Stephanie Sferlazza, attempted to fulfill my contract with GMAC. I entered into an agreement to pay. In February of 2005 I was incarcerated. I explained that the agreed amount was not available. They were not flexible. When I was released, I lost my job. The agreed amount was not paid but I did make an effort to pay something. Soon after I started to make payments in the amount of $40.00 a month, an employee from Weltman, Weinberg and Reis CO., L.P.A., contacted me. They told me I wasn't paying enough and that they were going to sue. I explained that I would make more payments as soon as I could. They called everyday. Most days it was a very nasty lady who finally told me "they weren't receiving the payments so they didn't count." She also told me "they didn't want my $40.00 a month". I also had a man call me and said he wanted to refinance my house so they could have their money. I stopped payments. Attached are the amounts I paid and the dates. Thank You, D rn-merce Ch*1.*'rle 09 Pasyinan' ,HiVo,,Y Page 1 of 2 P,u it i ` lli vr a Name Confirmation # Amount From Account 11/1 i';"2C'(1fi Washington Mutual 49073608 $146.00 TOTALLY FREE CKING 537051021 Nkoni o: 11/1 i i2Jt)Ec "'(' Penny 48368577 $15.00 TOTALLY FREE CKING 537051021 UA4+mo: 1111"r'/2J(1Et PF L Eletnc Ubhbes 47440931 $48.00 TOTALLY FREE CKING 537051021 114+mo: 11/1=006 h0:Jse 48908598 $723.00 TOTALLY FREE CKING 537051021 Akmo: 1110612006 E*N TON, THE 48368575 $20.00 TOTALLY FREE CKING 537051021 Memo: 11/04/20x6 E)q)ress Fashion 48456992 $55.00 TOTALLY FREE CKING 537051021 dtemo: 11/02/2D)6 SEARS 48368413 $48.00 TOTALLY FREE CKING 537051021 Menlo: 1013112006 Imuse Wlemo: Apply to October payment 48268654 $200.00 TOTALLY FREE CKING 537051021 10127f2006 MA 47575975 $10.00 TOTALLY FREE CKING 537148918 10/1312006 G-MAC 47124215 $10.00 TOTALLY FREE CKING 537148918 1d/13l2006 PPI_ Eletric Utilities Memo: 46020080 $48.00 TOTALLY FREE CKING 537051021 1010712006 SEARS 47144090 $10.00 TOTALLY FREE CKING 537051021 Memo: 10/07/2006 J C Penny 47144089 $15.00 TOTALLY FREE CKING 537051021 Memo: 10/07/2006 house Memo: 47144088 $550.00 TOTALLY FREE CKING 537051021 1010712006 Express Fashion 47144087 $15.00 TOTALLY FREE CKING 537051021 Menlo: 10/07/2006 8014 TON, THE 47144086 $10.00 TOTALLY FREE CKING 537051021 Merno: 10/06/2006 GMAC Mom: 46738757 $10.00 TOTALLY FREE CKING 537148918 09/29/2006 GM AC: Memo 46261723 $10.00 TOTALLY FREE CKING 537148918 09/19/2006 Washington Mutual 46216408 $75.00 TOTALLY FREE CKING 537051021 Memo: 09/1 5r2" MAC 45767275 $10.00 TOTALLY FREE CKING 537148918 09/14/2006 house Menlo: 45985125 $723.00 TOTALLY FREE CKING 537051021 09/13/2006 PPL Elebic Utilities 45631301 $46.00 TOTALLY FREE CKING 537051021 Memo: 09108/2006 GMAC Menlo: 45162135 $10.00 TOTALLY FREE CKING 537148918 08/30/2006 SEARS 45294784 $20.00 TOTALLY FREE CKING 537051021 08/30/2006 Washington Mutual Mertes: 45294782 $20.00 TOTALLY FREE CKING 537051021 08/30/2006 J C Penny Memo: 45294781 $20.00 TOTALLY FREE CKING 537051021 08/30/2006 Express Fashion Memo: 45294780 $20.00 TOTALLY FREE CKING 537051021 08/3012006 BON TON, THE 45294779 $20.00 TOTALLY FREE CKING 537051021 Memo: 08/19/2006 Washington Mutual 44796137 $62.00 TOTALLY FREE CKING 537051021 MI&2006 MAC 44494709 $10.00 TOTALLY FREE CKING 537148918 https://banking.commereepc.com/billpay/bp_pmt_history_print.asp 4/20/2007 P vnm?ar?P n»?in? 4oK (XV11112003 GalkC Memo: D8/04/20015 GIAAC Memo: D8103/2006 York County Clerk of Courts Memo: final payment D8/01(2006 York County Clerk of Courts Memo: D7/2812006 GMAC Memo: D7121/2006 GMAC Memo: 07/20/2006 SEARS Memo: D7120/2006 Washington Mutual Memo: D7/20/2006 J C Penny memo: ,07/20/2006 Express Fashion Memo: 07202006 BON TON, THE Memo: 07/17/2006 CAPITAL ONE Merno: dose this account 07/142006 GMAC Memo: 07/132006 York County Clerk of Courts Memo: 07/11/2006 York County Clerk of Courts Memo: 07/072006 house Memo: July 07/072006 GMAC Memo: 071042006 York County Clerk of Courts Memo: ?age 2 o' 2 44185760 $10.00 TOTALLY FREE CKING 537141918 43834082 $10.00 TOTALLY FREE CKING 537143918 44032710 $650.00 TOTALLY FREE CKING 537051021 43133866 $10.00 TOTALLY FREE CKING 537051021 43510335 $10.00 TOTALLY FREE CKING 5371411918 43182954 $10.00 TOTALLY FREE CKING 5371411918 43407326 $20.00 TOTALLY FREE CKING 53705'1021 43407325 $100.00 TOTALLY FREE CKING 53705'1021 43407324 $30.00 TOTALLY FREE CKING 53705'1021 43407323 $20.00 TOTALLY FREE CKING 53705'1021 43407322 $20.00 TOTALLY FREE CKING 53705',021 43257319 $12.55 TOTALLY FREE CKING 537051021 42878947 $10.00 TOTALLY FREE CKING 537146918 43092106 $700.00 TOTALLY FREE CKING 537146918 42724273 $10.00 TOTALLY FREE CKING 537051021 42856299 $723.00 TOTALLY FREE CKING 537051021 42687774 $10.00 TOTALLY FREE CKING 53714EI918 42688059 $10.00 TOTALLY FREE CKING 537051021 888 937-0004 Copyrroru O 2003.=? Pwmw*an1a Commarw eaoeap, bw. rlttps://banking.commercepc.com/billpay/bp_pmt_history_print.asp 4/20/2007 C -v as ; zr a F ' ® q ? t. ' om IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC, Plaintiff, Vs. Case No.: 07-1803 MOTION FOR JUDGMENT ON THE PLEADINGS STEPHANIE P SFERLAZZA, Defendant. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 05452281 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC, Plaintiff, VS. STEPHANIE P SFERLAZZA, Defendant. Case No.: 07-1803 MOTION FOR JUDGMENT ON THE PLEADINGS AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Judgment on the Pleadings and respectfully moves this Court pursuant to Pennsylvania Rule of Civil Procedure 1034 for judgment on the pleadings. In support thereof, Plaintiff avers as follows: 1. This action arises out of the accumulation of credit card debt by Defendant. 2. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of $6,248.27 with continuing finance charges thereon at the rate of 6.0% per annum from February 09, 2007, plus attorneys' fees of $1,000.00 and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 3. Attached to the Complaint was Verification from an authorized representative of Plaintiff verifying the accuracy of the amount sought. See Exhibit "A". 4. Defendant Pro Se filed an answer in response to the Complaint, admitting all of the material facts. pled in the Complaint and stating only that she has no means to pay. A true and correct copy of Defendant's answer is attached hereto as Exhibit "B" and made a part hereof. 5. Financial inability to repay a debt is not a defense in an action to collect that debt. WWR No. 05452281 6. Under Pennsylvania Rule of Civil Procedure 1029(b), the averments of the pleading to which a response is required are deemed admitted when not denied specifically. 7. Defendant's answer contained no New Matter. 8. Under Pennsylvania Rule of Civil Procedure 1032(a), "a party waives all defenses and objections which are not presented either by preliminary objection, answer or reply..." 9. The pleadings are closed and time exists to dispose of this Motion before trial. 10. No genuine issue of material fact exists as to Plaintiff's claim. 11. Plaintiff is entitled to judgment in its favor as a matter of law on the amount sought in the Complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order directing judgment on the pleadings in favor of Plaintiff and against Defendant, Stephanie P. Sferlazza, in the amount of $6,248.27 with additional interest at the legal interest rate of 6.0% per annum from February 09, 2007, plus attorneys' fees of $1,000.00 and costs. Respectfully Submitted: James C.iWarmbrodt, Esquire /'kj.D.#42524 W TMAN, WEINBERG & REIS CO., L.P.A. f1 27 Koppers Building 43 Seventh Avenue P ttsburgh, PA 15219 412) 434-7955 W WR No. 05452281 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant No. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05452281 EXHIBIT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. Civil Action No. STEPHANIE P SFERLAZZA Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation having offices in 5700 CROOKS RD STE 301 TROY, MI 48098-0000 . 2. Defendant is an adult individual residing at 329 S WASHINGTON ST MECHANICSBURG,PA 17055 . 3. On or about APRIL 7, 2001, Defendant duly executed a RETAIL INSTALLMENT CONTRACT (hereinafter the "Contract") a true and correct copy of said Contract is attached hereto, marked as Exhibit "1" and made a part hereof. 4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly identified in the Contract as a 2001 SATURN SEDAN. 5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned to Plaintiff. 6. Plaintiff avers that Defendant is in default of the Contract by having not made payment to Plaintiff as promised, thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that a balance of $ 6,248.27 is due from Defendant as of FEBRUARY 9, 2007. 8. Plaintiff avers that the Contract between the parties provides that Plaintiff is entitled to interest at the rate of 6.0% per annum. 9. Plaintiff avers that the Contract between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees. 10. Plaintiff avers that such attorneys' fees amount to $1,000.00. ll. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, attorneys' fees, interest, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, STEPHANIE P SFERLAZZA , individually, in the amount of $ 6,248.27 with continuing interest thereon at the Contract rate of 6.0% per annum from FEBRUARY 9, 2007, plus attorneys' fees of $1,000.00 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Mole , Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:05452281 39p ! j:. S ^I-RR GS c 5 a cc oN.PA 1 ZD e y q AP ff c siv. hQZ 8v D E-- _ ?/?1y?• RETAIL INSTALMENT SALE CONT- FINaNL1ALSERV 6 --4, Fol Dealer Number YC. Contract Number _ G 9 ' Buyer (and Co-3uyer)-Name and Address (include County and Zq Code) Seller (Credaor) Name and Address ;'•f!, Ir?l;?rt7 ?• 1' ':rL•'kf 37.Rt--. ; ;?' r ! :: .r rf.e :'!. : r ; •: 51 ? li :;S'rlkt?U:F - 1' , .... ..OP L [?:l.!•: . !':I•: MI-V!AW if`.1t1!!!!=. PA !/1.9Y: '1 :!•?..: hi i:':• lair-: Vf- i;G: c.., C l.ik^.t!LN. L "hl l! You, the Buyer (and Co-Buyer. it any), may buy the vehicle described below for cash man credit. The cash price is shown below in the "Itemization of Amount Financed" as 'Cash Price" The credit price is shown below in the Federal Truth-In-Lending Disclosures as "Total Sale Price- By signing this contract. you choose to buy the vehicle on credit under the agreements on the front and back of this contract. '1'ou- and'your'refer to you, the Buyer, and any Co-Buyer,'We. "Us-and'Our- refer to the Seller named above and to anyone to whom the Seller assigns this contract. Seller intends to assign this contract to General Motors Acceptance Corporation (GMAC). Description of Vehicle. You agree to buy and we agree to sell The following vehicle: New or UseA Yeor k13ke and Model Body Type Vehicle Identification No. Use for V Ihidh Pwchased ?, i •. • i ... -,rr,;: i [i.;111.ii .. .. l .:.. - ! .. ., ... =}Personal l lagnculinrat j 0 business If (luck-Describe body and major items of equipment sold .ANNUAL PERCENTAGE FINANCE CHARGE Amount F'imnced Total of Payments Total Sale Price RATE The ddlar amount The arrant of credit The amount you will have paid The teat cost of your purchase The cost of your credit as a the credit will cost provided to you or on after you have made all pay- on credit, including your down. yearly rate. You. your behalf- ments as scheduled. Payment of $ f • ' ?!??is .., 5 S S S Number of Paymtents Amount of Payments Whan Payments A. Due Or as Follows: .•` ?'. - _. Monthly beginning ,.... ,. Late Charge. If a payment is not paid in full within 10 days after it is due, you will pay a late charge. It the vehicle purchased is a heavy commercial motor vehicle, the charge will be 4% of the amount of the payment that is late R the vehicle purchased is off-highway business or farm equipmenl, the charge will be 5% of the amount of the payment that is late. Otherwise, the charge will be L:: Del month on the amount of the payment that is late, compiled on the basis of a full calendar month for any fractional month period in excess oft 0 days:' ..., Prepayment. If you pay ell at, your debt early you may be entitled to a refund of pagpf t 1 ante charge. Security Interest. You are giving a security interest in the vehicle being purchased. Additional Information: See the other side of this contract lot more inlormalion including. information-about nonpayment, default, any required repay. ment in fun before the scheduled date, prepayment refunds and security interest. ?.. 3 Unpaid Balance of Cash Price (1 minas 2) 4 Other barges "ding Amounts Paid to.Odmas on Yell 8~ (SBAW may be keeping pmt of thima anaassj 'A Cost of Requ. if Physical 0anuge Insurance Paid to the haraaa.Company Named in Rue . tislaanceSedion Below=Covering Damage to the Vehicle - ^•e Cost of Optional Mechanical Repair Insu artce Paid to the Insrarce Company Named in the ..hisurance Section,Below-CovenirgCetainMechanhicatRepairs - . .. .. $ N/A "•C. Cost at Opwna) Cted"rt Life "I" Accident and Heats I su,vee or the Term of this Contract Paid dm• e Insuragce Compaq or Companies Named in Rie pisrnraroe Section, Below. S e KyA Oilmbily. Accidtat and Heaths ..X/A D Olfirial Fees Paid to Goverment Agencies' - - -' -m 5 - _5 - Yt9 E Tares Not Included;. Cash Price F:-Government License and/or Registration Fees (item e) - - S- 5 ? y G Government Certificate of Trile Fees - $ Z1. b0 H Other Charges (Seller must identify who will receive payment and describe purpose) to a 1 .. _.t1 for b s 335.00 to We Yt:c $ 5S - s Tonal Onher Charges and Amounts Paid o Others on Your Sehall $ ITEMIZATION OF AMOUNT FINANCED 1 Cash Price (incYuderg arty accessories. services, and taxes) $ 1 b , 14'".• . 0i? (t) 2 Total Downpayment . Net Trade-in $ - / p . Cash Dowrpaymerd $ +Other (DesaLe) $ Your Trade-in a a $ rP0 (2) Year Make Model ; 15,9113-W (3) 2,649.20 A?„I star. s T Tame Balance Total d Pay,.Kihra (5 a) s? ey ?' b4 . , 're ey sntare Law :. 6 PaY 41 ScMdule: - insialmenls? W 4 ' /' Meaol,, monthly baamn.p F P,,??i x' • _ - ruva.l toayl cr..l a a .?n.e„ vn»..rv .,....a,..« o. i,..e.a.., s indl-et m u.e Fwd«al Trum-rnLeridig QSClowrls, above. ?:r _ Insurance ft any insurarice s Checked below. the policies a otmlgcstes isarrod by Regh:d . y' Compartirs curried will d.,be me temps and rxrdtions. Phylikalk! Damage knurarrx We require that you Nava pty5foi damage. *r -optiond You may obiaal a trae'anYprie You want who is a¢epfa6! o is, We' have.. eclunl-,p Pi? 4snnatrce_ We Have shown sfdwim the cost of Iles nsurarire m 4A of the hernaaLom of Amouni Fhwnced.• pre ctW d ilya a 5laarnpe in 46 at dfa herrroahotr of Amount 't1A' . - . f. Teral-_months-- Irtzaeahce ('.ortyarhy, 12/P CoSrcpn ant ether,. hrmsis¢ irxiu6iy Foe, Then and Combned 'µ t] St1 Detlua,b!e Addrsonat Crxprage Tam. C' 36 months or 3s o00 ides, whichever m? IS fill Conprehensrve ndudeg Re..ThA(aad o Combirird Tem.'J M!A Addtiprul Ca.erage - ?S250ediciible rj SSO Deductible- G• S :. u F,.e. Theft and Combined Addr,ionaf Coverage Deducible .. Cptmnal. d denied-,_ Tcvnng aid Labor msti.0 Rental Reimhurseamm O C8 y - .. _. Radio Eflitapartimi, ';'OplfonWCreditLkteardror Atskdenfapd HealRrins i..nCe_1N4 Qd milt . ..: ante to obtain credit. We coo rot provide them umess yrnr sipr fordmerrr prd ! You to have credit -wee and colt ar d*M and heahh in.- . ?Wet agree opay ttieaddtimal COSTR ... _. desireA andsfgn beSOw•. t you have Uwsen phis irinirairce, fhe cost s Siralatl in 4C Of fhb Itern¢ationof Arrxxut f•->rar>r?_ abo,.e; • CMS the insuraimca Check the insuraneedm*ed=t YLufe(Buyern.Co.Byer - t?DisaaTdY. Accident and: Health Qkjer Only) (Marie at Insurd-Life) _ (fionie Office Address) , (Name of Insurer-A d H) !L/A (Home Olfire Address) This pokey will pay amounts due on this contract up to S APPROVAL: 1 DESIRE TO OBTAIN THE CREDIT LIFE ANDADR ACCIDENT AND HEALTH INSURANCE CHECKED ABOVE FOR THE PERSON/ PERSONS PROPOSED FOR INSURANCE. Buyer Signature Dae Co-Buyer S'ignawre Date ANY INSURANCE THIS CONTRACT DESCRIBES DOES NOT INCLUDE COVERAGE FOR BODILY INJURY AND PROPERTY DAMAGE CAUSED TO OTHERS. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is 'iou-o' (NAME) N'C 7MQ A ?o c t-? ii,r A &ria-h (of C RX L , plaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. WWR#05452281 an5wtr -b CO mplart{w- In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Division GMAC, LLC plaintiff Vs. Stephanie Sferlazza Defendant 4/20/2007 To Whom It May Concern: No. 07-1803 Complaint in Civil Action a o Z f: " tV :r? I, Stephanie Sferlazza, attempted to fulfill my contract with GMAC.'I entered into an agreement to pay. In February of 20051 was incarcerated. I explained that the agreed amount was not available. They were not flexible. When I was released, I lost my job. The agreed amount was not paid but I did make an effort to pay something. Soon after I started to make payments in the amount of $40.00 a month, an employee from Weltman, Weinberg and Reis CO., L.P.A., contacted me. They told me I wasn't paying enough and that they were going to sue. I explained that I would make more payments as soon as I could. They called everyday. Most days it was a very nasty lady who finally told me "they weren't receiving the payments so they didn't count." She also told me "they didn't want my $40.00 a month". I also had a man call me and said he wanted to refinance my house so they could have their money. I stopped payments. Attached are the amounts I paid and the dates. 181 1 ,( 6 to Thank You, Commerce Online Payment History Paymient Date Payee? Name 11117/2006 Washington Mutual Memo: 11/1712006 J C Penny Memo: 11/17/2006 PPL Eletric Utilities Memo: 11/13/2006 house Menlo: 11/06/2006 BON TON, THE Menlo: 11/04/2006 Express Fashion Memo: 11/0212006 SEARS Memo: 10/31t2006 house Memo: Apply to October payment 10127/2006 GMAC Memo: 1011312006 GMAC Memo: 10/13/2006 PPL Eletric Utilities Memo: 10/07/2006 SEARS Memo: 10/07/2006 J C Penny Memo: 10/07/2006 house Memo: 10107/2006 Express Fashion Memo: 10/07/2006 SON TON, THE Memo: 10/06/2006 GMAC Memo: 09/2912006 GMAC Menlo: 09/19/2006 Washington Mutual Memo: 09/15/2006 GMAC Menlo: 09/14/2006 house Memo: 09/13/2006 PPL Eletnc Utilities Memo: 09/08/2006 GMAC Memo: 08/30/2006 SEARS Memo: 08/30/2006 Washington Mutual Memo: 0813012006 J C Penny Memo: 08130/2006 Express Fashion Memo: 08/30/2006 BON TON, THE Memo: 08/19/2006 Washington Mutual Memo: 08/18/2006 GMAC Memo: Confirmation 4 Amount From Account 49073608 $146.00 TOTALLY FREE CKING 5370; 48368577 $15.00 TOTALLY FREE CKING 5370; 47440931 $48.00 TOTALLY FREE CKING 5370' 48908598 $723.00 TOTALLY FREE CKING 5370: 48368575 $20.00 TOTALLY FREE CKING 5370,' 48456992 $55.00 TOTALLY FREE CKING 5370; 48368413 $48.00 TOTALLY FREE CKING 5370.f- 48268654 $200.00 TOTALLY FREE CKING 5370: 47575975 $10.00 TOTALLY FREE CKING 53714 47124215 $10.00 TOTALLY FREE CKING 53714 46020080 $48.00 TOTALLY FREE CKING 53705 47144090 $10.00 TOTALLY FREE CKING 53705 47144089 $15.00 TOTALLY FREE CKING 5370° 47144088 $550.00 TOTALLY FREE CKING 5370: 47144087 $15.00 TOTALLY FREE CKING 5370 47144086 $10.00 TOTALLY FREE CKING 5370: 46738757 $10.00 TOTALLY FREE CKING 5371, 46261723 $10.00 TOTALLY FREE CKING 5371, 46216408 $75.00 TOTALLY FREE CKING 5370 45767275 $10.00 TOTALLY FREE CKING 5371 45985125 $723.00 TOTALLY FREE CKING 5370 45631301 $48.00 TOTALLY FREE CKING 5370 45162135 $10.00 TOTALLY FREE CKING 5371 45294784 $20.00 TOTALLY FREE CKING 5370 45294782 $20.00 TOTALLY FREE CKING 5370 45294781 $20.00 TOTALLY FREE CKING 5370 45294780 $20.00 TOTALLY FREE CKING 5370 45294779 $20.00 TOTALLY FREE CKING 5370: 44796137 $62.00 TOTALLY FREE CKING 5370: 44494709 $10.00 TOTALLY FREE CKING 5371, https://banking.commercepc.com/billpay/bp_pmt_history_print.asp Commerce Online 08M 112006 GMAC memo: 0810412006 GMAC Memo: York County Clerk of Courts 081032006 Memo: final payment York County Cleric of Courts 08101/2006 Memo: 07/2812006 GMAC Memo: 07121/2006 GMAC Memo: 07120/2006 SEARS memo: 07/202006 Washington Mutual Memo: 07/202006 J C Penny Memo: 07/202006 Express Fashion Memo: 071202006 BON TON, THE Memo: CAPITAL ONE 07117/2006 Memo: dose this account 07/142006 GMAC Memo: York County Clerk of Courts 07/132006 Memo: York County Clerk of Courts 071112006 Memo: 07/072006 house Memo: July 07/072006 GMAC Memo: 07/042006 York County Clerk of Courts Memo: 44185760 $10.00 43834082 $10.00 44032710 $650.00 43133866 $10.00 43510335 $10.00 43182954 $10.00 43407326 $20.00 43407325 $100.00 43407324 $30.00 43407323 $20.00 43407322 $20.00 43257319 $12.55 42878947 $10.00 43092106 $700.00 42724273 $10.00 42856299 $723.00 42687774 $10.00 42688059 $10.00 TOTALLY FREE CKING 5371 TOTALLY FREE CKING 21111114 TOTALLY FREE CKING d= TOTALLY FREE CKING TOTALLY FREE CKING AN TOTALLY FREE CKINGOM TOTALLY FREE CKINGrmst TOTALLY FREE CKING 6W TOTALLY FREE CKIN4VION TOTALLY FREE CKING4M TOTALLY FREE CKINtmN0 TOTALLY FREE CKING 440 TOTALLY FREE CKING i TOTALLY FREE CKING ? TOTALLY FREE CKING 00 TOTALLY FREE CKING ? TOTALLY FREE CKINGaillIN111111 TOTALLY FREE CKING W 888 937-0004 Copyright O M3.2M Po wyhranW Commetee Bancorp, hrc. https: //banking. commereepe. com/billpay/bp_pmt_history_print-asp i VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this Motion, and that the facts set forth in the foregoing Motion are true and correct to the best of his knowledge, information and belief. WWR No. 05452281 CERTIFICATE OF SERVICE A true and correct copy of Plaintiff's Motion for Judgment on the Pleadings has been served by 86 U.S. Mail, Postage Pre-Paid, on day of , 2007, upon the following: Stephanie P Sferlazza 329 S Washington St Mechanicsburg,Pa 17055 BY: James . Warmbrodt, Esquire P I. a #42524 EL AN, WEINBERG & REIS CO., L.P.A. 718 K ppers Building 436 Se enth Avenue Pittsb gh, PA 15219 (41 434-7955 WWR No. 05452281 ra ?Vl SHERIFF'S RETURN - REGULAR CASE NO: 2007-01803 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC LLC VS SFERLAZZA STEPHANIE P RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SFERLAZZA STEPHANIE P the DEFENDANT , at 2057:00 HOURS, on the 2nd day of April , 2007 at 329 S WASHINGTON STREET MECHANICSBURG, PA 17055 STEPHAINE SFERLAZZA by handing to 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 19.20 Affidavit .00 Surcharge 10.00 .00 =?J13lb7 (?., ?? 47.20 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 04/03/2007 WELTMAN WEINBERAEIS By: c / -19 Deputy Sheri day A. D. PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: OS"gS-22g- 1 Please list the within matter for the next Argument Court. ---------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) 6MAC--) LI.C., ( Plaintiff ) VS. sfePAm J+ee iG Zz4, (Defendant) No. W3 civil 2o07 1. State matter to be argued (i.e., plaintiff 's motion for new /trial, defendant's demurrer to complaint, etc.) : ??A.;?+? ?t ? l1'.f 6,, Xr o, A,- 2. Identify counsel who will argue case: Waltman, Weinberg & Reis Co. W,11,?M > In, ICU- 6( 1400 Koppers Bldg. (a) for plaintiff : y7y 3 7 436 7th Ave. Address: Pittsburgh, PA 15219 (412) 434-7955 (b) for defendant:?? Se > Address: Pec AA16S 170s-S' 3. I will notify all parties in writing within two days that this case has been listed for argument. TeS . 4. Argument Court Date: ser1 11 4V- 0 3/ z O o v ?/JY 11? VZZ7 Attorney f ??^ ?; r , i CERTIFICATE OF SERVICE A true and correct copy of the Praecipe For Listing Case For Argument has been served by First Class Mail, postage pre-paid, on -I- day of C.U 2008 upon the following: Stephanie P Sferlazza 329 S Washington St Mechanicsburg,Pa 17055 `?-? BY: C) { ,,5 _Kf , GMAC MORTGAGE, LLC, Plaintiff VS. STEPHANIE P. SFERLAZZA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1803 CIVIL IN RE: PLAINTIFF'S MOTION FOR JUDGMENT ON THE PLEADINGS BEFORE HESS, OLER AND EBERT, J.J. ORDER AND NOW, this 10 ' day of September, 2008, upon Plaintiff's Motion for Judgment on the Pleadings, it is ordered, adjudged and decreed that said Motion is GRANTED and judgment is entered in favor of Plaintiff in the amount of $6,248.27, with additional interest at the legal interest rate of 6.0% per annum from February 9, 2007, plus attorneys' fees of $1,000.00 and costs. BY THE COURT, 4 /dam /James C. Warmbrodt, Esquire Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 For the Plaintiff `' Stephanie P. Sferlazza, Pro Se 329 S. Washington Street Mechanicsburg, PA 17055 Defendant :rlm Co 1! e s m?? t?Clu Kevin ,?(f Hess, J. YINVAIASNN3d )Olf) ell Am h S #QI WV 1 ! d3S 0001 AUVIU;'vOHi id 3?U d0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC MORTGAGE, LLC., Plaintiff TYPE OF PLEADING VS. STEPHANIE P SFERLAZZA Defendant. COUNSEL OF RECORD OF THIS PARTY: THIS IS AN ATTEMPT TO COLLECT A DEBT USED FOR THAT PURPOSE. Case No.: 07-1803-CIVIL PRAECIPE FOR JUDGMENT PER ORDER OF COURT FILED ON BEHALF OF: Plaintiff Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 05452281 $7,875.54 AND ANY INFORMATION OBTAINED SHALL BE ?-^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC MORTGAGE, LLC., Plaintiff Case No.: 07-1803-CIVIL VS. STEPHANIE P SFERLAZZA Defendant. PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Pursuant to Pa.R.C.P. 237, I certify that a copy of this Praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. In light of the Court Order granting Judgment on the Pleadings in favor of Plaintiff on September 10, 2008, kindly enter Judgment against the Defendant, STEPHANIE P SFERLAZZA, in the amount of $7,875.54 computed as follows: Amount Awarded per Order: $6„248.27 ? Interest from February 09, 2007 to October 10, 2008 at the legal rate of 6.0% per annum: $627.27 Attorneys' Fees: $1,000.00 TOTAL: $7,875.54 Attached is a copy of the Court Order in favor of Plaintiff for Judgment. WELTMAN, WEINBERG & REIS, CO., L.P.A. By: a ul? u1'btNIVA c Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Plaintiff's address is: c/o Weltman, Weinberg &. Reis, Co., L.P.A., 1400 Koppers Building, 436 7* Avenue, Pittsburgh, PA 15219 And Defendant's address is: 329 S WASHINGTON ST., MECHANICSBURG,PA 17055 GMAC MORTGAGE, LLC, Plaintiff VS. STEPHANIE P. SFERLAZZA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1803 CIVIL IN RE: PLAINTIFF'S MOTION FOR JUDGMENT ON THE PLEADINGS BEFORE HESS, OLER AND EBERT, J.J. ORDER AND NOW, this ip day of September, 2008, upon Plaintiff's Motion for Judgment on the Pleadings, it is ordered, adjudged and decreed that said Motion is GRANTED and judgment is entered in favor of Plaintiff in the amount of $6,248.27, with additional interest at the legal interest rate of 6.0% per annum from February 9, 2007, plus attorneys' fees of $1,000.00 and costs. BY THE COURT, James C. Warmbrodt, Esquire Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 For the Plaintiff Stephanie P. Sferlazza, Pro Se 329 S. Washington Street Mechanicsburg, PA 17055 Defendant rlm `4. Copy ?Lrtom y? f s . r,k r ..4. r.. ' I twe tr ": 7. 4 `? k`r F s•'? n? -A VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Wo CUA, Wo Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05452281 _ Cz? Vol 1"8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC MORTGAGE, LLC., Plaintiff VS. STEPHANIE P SFERLAZZA Defendant. Case No.: 07-1803-CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendants ( ) Garnishee You are hereby notified that a fol owing Order or Judgment was entered against you on D 62 O o (xx) Assumpsit Judgment in the amount of $7,875.54, plus interest at 6.0% per annumb plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of (xx) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ( ) By Consent STEPHANIE P SFERLAZZA 329 S WASHINGTON ST MECHANICSBURG,PA 17055 THIS IS AN ATTEMPT TO COLLECT A DEBT USED FOR THAT PURPOSE. Prothonotary By: PRO ONOTAR EP AND ANY INFO TION O AINIED SHALL BE ' ~~ RECEIVED JUN 14 YU1U IN `THIr ~QU~t°t' ~iF ~QMA~~N ALl~A~ ~9I' ~UI~iH)~RLANI~ CQU~i~'4~, PFN~+I~YL.VANIA CIVIL, I~IVI~IQl~ Plai~~iPf vs. ST'1PHANIE F SFIARLAZ~A A~i~enc~ant end C[T'1~11a+i~ ~A'A1I~ M~MB1aI~S I ~T FE:I~ERAL CRlai~i~ UI~IIQAi ~t~V ~I~IGrA1 IIAI~ii~, ~~PftiB~'IQ~~ Il"d`F~I~iR(?GATQRIE~ IN A'T'1'AC'H11~~1~iT CITI~~iWS B,A~N~ ~O~EREIGI~T B.~lNI~. RZEM~~RS 1sT 1FE~~1tAL CREAK UNION cn ~ -- -; -,~t r,r ; FIIr~A ~N HEHAL,F QP; ~ ~ ,~,, "? IAlaintlfF ~ '~ - ~~2U~1$~L QF RIC0I~I3 Ql+ ~ ~_r~ ~~ ~. ,= ` r; .A `I~II~ P:AR1"~: ~ c~ J ~ -•< ~I~tthsw I~. Urbmt~, E$~quira RA I,A. ~90~~3 WEL,T'MA~N, W1IAJBERC'r & Ii~I~ C()., L.P.A. ` 14Q0 I~~ppers Buii~ing ~~b Sevonfih Av~nu~ I'itt~burgh, RA 1321 ~ (412~A~~rT~33 WWR~34~~281 1 II+i ~'HB ~f3I7A~° ~F Gt~MME'~Ai AI:.~A~ ~UMBI~RI.AAIi~ ~BUN~'~', PE?+l°NS'~LVA1~ilA GIVI~ I~IV1~1:4~T ~A~, lai~~ Plaintiff vs. ~~'i~Fb1A1'~Il/ p ~~'~~A~~A ~pfpndapt ~n ~I~I~~?alg aAl~i M~MHBRg 1 ~T F8T.3~RAI. GR:1~1~I`l' U'1~lIQN SUV'EI~IGN SANK ~arnishess Gi~rii Action l+lo,: p~=183 TQ: Gitizens bank guggQStes~ Rsranee IJp.; ~X~f.~fX~0901 663 North fast ;~troet, Carlisle, PA 17013 Membors 18~ Foderal Credit Union 321 3~'ork load Carlisle, PA 1741 Sovereign Bank 17 West High Street, Carlisle, PA 17013 RB; S`I'>,PI~NIE P Sl{E1I,,A~A 32~. ~ W~-.~I~ATGT~I~T ~TI~>E~T lY1IECI~A1'+TI~S)~ITI±1G, PA 1<7Q~S IhiPi~~~~,AiT P~TA~'I1~1~~ ~'~ ~A~I~H~I~t A, ~fou arQ required to f31e answers to the fo#lovvirjg intet~g~tocibs kvithin tweflty (20j days after service upon,you. F'ailure.tq .do so tray result in Judgment against you, B. Iidrein, the word "defendant" means any one or more of the dependants against whom the writ of >~ xecutia~ is issued. +~. , .While service op Writ upon tha Garrtist~e@ attaches ail property of the Dependant subject to attaehmont which is then in the hands of the garnishee, it also attaches all property of the defendant which comas into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured >ay the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. lll>~~~i~Q~A~~~)i~l~ ~ AT~~+~l~lid~AlT I , At the time you were served or at any subsequent time did you owe the defendant any money or ware you liable to him on any nogotiabl~e or other written instrument, or did he claim that you owed him any rnaney or were liable to him for any reason (including funds an deposit for checking or savings accounts and certificates of deposit)? NO l a. If'tha aaswaa tta Intar~agatory 1 is in the aI?~crraatjtrs, state tl~e following: the mount of rnonay you owe or owed to defendant, and, if such rnot~®y is jn the for7ti of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount Qr amounts that defendant clairr~$ qr claimed that you owe or gwed to him; and the nature and amount of each of each liabilitiea, N~~ ~. At the urns you wars served or at arty $ubsaquent time was there In your poassssion, custody or control of yourself and one or more other persons any pra~party of any nature owned solely or in, part by the d~fendgnt. IUD 3. ~t the tune yc~u wer® served Qr at any subsequent thus did you Maid legal titiQ to ar~y pgQps~r oY any nature owned solely or part by the defendant or in which defendant bald or claimed any intsFest? NO ~, At the tira~a you wars served ar at any sub~aquont tune dl~i ysru hold as flduaiary any pr~Party in which the defendant hid an int4~ast? ~~ ~. At any tuna before Qr after you wars sawed, did th~o defendant tragafieF Qr daliuer• -any pFOperty to you or t,~ any person or place pursuant to your dirsctiQns or consent and if sn what was the consideration thsfeof~ ND 6. At any time after y€~u ware served did you pay, transfer, pr deliver arty tne~ney Qr property to the defendant car to any person err place pursuant to his direction or otherwise discharge arty clairri of the defendant against you? ~~ ?, If yqu are a bank ar other financial institution, at the time yQU were served ex at any su>~ssqusnt time did the defendant baud funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as bring funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state. the reason for the exemption, the amQUnt being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a hank or oth®e €it~ancial institution, at the ti~te ypu wane served ~r at ~y subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise ®xempt funds, did not exceed the amount of the general monetary axarnption under 42 Pa.C.S. § 8123? If so, identify each account. X X X X00 ~v~~n~A '~ 0 •©~ C~c~c~ ~ ©~ ao 9. If the answer to Intsr~p$atAry 1 is in the al~Pllrrriative, stets the date th¢ sheriff served these interra$atories un this institution, NIA 10. If the answer- to Intan*pgatory i is in the af~i~tative, state the data the wFittsn instr~ur-neat, checking or savings account, csr-tii'ycate of deposit, or other funds were frozen, restricted, or otherwise put on hoid by this institution. N~~ 1 I. Il°th® ~slaonse tQ Inter~$ator~r 7 is in t}iv afi~irrnative, are der funds aotuingled in the account which are not deppsited electronically oa a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? N ~'R 1~. I€the Kespvnse to Interrcjgatory 11 is in the af€irmative, stets the am©unt ol"rfiQn4e~esrnpt funds on deposit in the account. N' ~} Aye , A~Iat~€la~w I~. Urb~~,-Esquire - I~A I,13. #~Q963 Wlal:,~'MAN, WfaII~iH1I~fi & A~I~a ~C?„ L,P.,A. 14f~f? I~©ppers l~ullding 436 Seventh Avenue Pittsburgh, PA 1321 ~ (42434-795 W1~lfS4~~281 4 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Jody L. Burkholder (Name) Deposit Operations AnalystofMembers 1st Federal Credit Union _ (Title) ~~ompany~ garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ~~~~ (SIGNATURE) ~, IN THE Gt3C1R~' qF C(~MME~N PLBAS ~UMBBRLANI3 ~E~UNst'1~`, PENNS`~LVANIA trIVII., pIVISIQ~i ~a14~1A~, Ll~ Plaintiff 'VS, ST'BPI-IANIE P SF1~;R1..A~~A 1~@fendant Vin' C11'I~~NS BANS M)MBERS I ST F!~D1rRAL CRCQI`1" UAiIC)1~1 SQVIREIGN BAND Garnishees `I'E): Citizens Bank 66S North last Street, Carlisle, PA 17Q13 Members 1st Federal Credit I~nion 321 York Road Carlisle, PA 1713 Sovereign Bank 17 West High Street, Carlisle, AA 17Q13 Civil Action No, ~7~1&~ c' = Fi ,~ `~ .--a -r. ~ ca ' -~ ea ~_r, N q _ :. ,.~ tt,~, t" • ' ~ > . = £ .='r_.. ~~y ~. .~ - ~~ • • yam -G ~' ~C -.,t Suggested Rsf+~rer~~e No,. ~CX~b~f~CnQ901 RG; STEPHANIIr P SF)~,R.LA~ZA 329 S WA~HINGT©N STR>ivFT MECHAIYICSHUR(~, YA 17QS3 ~11~Af3RTANT ATQ`TI~ES ~'~ GA~tNI~1HE1~! A, You era required to file answers tv the following interrogatories within twerrty (~©) days after service upon you. Failure t~ do so may result in Judgment against you, B, Herein, the word "def~ondant" means any one or more of the defendants against whom the writ of Execution is issued. ~. While service of Writ upon the Garnishee attaches all property of the IDefQndant subject tQ attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which corms into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather- by the amounts deposited and withdrawn during the intervening period. Ahs~e~ II~IT11~>i~RQt~A~TLII~~~i IAi ATT~+~I-1<~I~A(T 1. At the time you ware served or at any subsequent time did you awe the defendant any money or were you liable to hurt on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking ar savings accounts and certificates of depositl? No-See Attached 1 a. If the answaa tQ int®rxagatory 1 is in they af~rnaatiue, state the following: the amount Qf money you ow® or owed to def©ndant, and, if such money is in the form of a fund, the present location th@r®of; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant clair~ns or claimed that you owe or owed to him; and the nature and amount of Qaeh of such liabilities. Answer to No. 1 is no. 2, ~1t the time you were seivad or at arty subsequent time wa$ there in your posesssion, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. No-See Attached 3. At the lima you were served or at any subsequent tim© did you hold Isgal title to any property of any nature owned solely or part by the defendant pr in which defendant held or claimed any interest? No ~, A,t the tune you ware served or at any subsequent tune did you hold as fiduciary any property in which the defendant had an interest? No ~. At any tirn® before or after you wars served, did the defendant transfer or deliver any property to y©u or to any parson or place pursuant to your directions or consent and if so what was the consideration thereof? No 6. At any time after you ware served did you pay, trttnsferr, or dalivar• any money Qr prapsrty to the defendant or to any parson or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 7. IC ynu are a hank ar other- financial institution, at the time you avers served or• at any subsequent tune did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No 8, if you are a bank or other financial institution, at the time you were s®rved or at arty subsequent time did the defendant have funds on deposit in an accotant in which the funds on dspnsit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8 i23? if so, identify each account. No R. Cf the answer to Interrogatory 1 Is in the affirmative, slats the date the sheriff servsd these interrogatories an this institution, Answer to No 1 is no. 1(1. if the answer to interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. Answer to No 1 is no. i 1. If the response to Interrogatory 7 is in the aff rmatiuc, are oth®r funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? Answer to No 7 is no. 12, if the response to Interrogatory 1 l is in the affirmative, state the amount of nan~exempt funds on deposit in the account. Answer to No 11 is no. Wfila`I'I~9A~1, W&;~R~a ~ l~~IS G~., l.~,P.~, ~y. ~ ..- A~4atthdur Q. Urban, Esquire PA LTA. #~Q9~i3 WEI,TMAAJ, Wll?~l1~Ei~~ ~9i R1/IS CQ„ L,P.A. 140U Koppers Building 436 Seventh AvQntae Pilt~burgh, PA 1321 ~ (4i2) 43A~~7935 WWR#3432281 r 'Tl~e undersigned dies hereby verify subject to the penalties of 1$ PA. ~.~. 490 relating to unsworn falsifications to authorities, that he/she is Timothy .T Cooney C.O.P. Team Mana er of Soverei n Bank ,garnishee ]~~~~~~! (Tit1~) . (Cornpany~ that he/she is duly auth©rixed to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ,: - , ~ I~AiA URE) ~ . ~--~-~ Spa-Q--P t a- = t ~ ~r-~---, ANSWERS TO INTERROGATORIES Account # 511082843 Balance: $0.00 ^ftF;r fallowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00 :"~~rvo~,nt Holder: Stephanie P Sferlazza PO Box 55 Carlisle, PA 17013-0055 VERIFICATION I, Timothy J. Cooney, C.O.P. Team Manager of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank gy: Timothy J. Cooney C.O.P. Team Manager IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: GMAC, LLC vs. Stephanie P Sferlazza CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Matthew D. Urban, Esquire Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Service by certified mail addressed as follows: Stephanie P Sferlazza PO Box 55 Carlisle, PA 17013-0055 Timot y .Cooney C.O.P. Team Manager Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 June 24, 2010 ~~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION GMAC, LLC Plaintiff(s), vs. STEPHANIE P. SFERLAZZA Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. C7 ~ .~ c = NO.: 07-1803 ~ ~-` ~-~~ ~. :: Answers to Interrogatories. T - ,- _~~ L. r_, ~, J _,:: %° •- - Code: 200 Execution ~` ~' -"< Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA LD. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484)323-1351 (610) 640-1965 fax ndeenis@stradley. com www.stradley.com t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION GMAC, LLC Plaintiff(s), vs. STEPHANIE P. SFERLAZZA Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. NO.: 07-1803 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1-12} At the time of service of above-captioned Writ of Ixecution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The garnishee, Citizens Bank of PA, states that it maintains a checking and :>avings accounts in the name of the Defendant, STEPHANIE P. SFERLAZZA, with a combined balance of $259.34, which is less than the $300.00 Statutory Exemption and the $125.00 Garnishee's processing fee. Therefore, no funds are available subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Christina Graham who being duly sworn according to the law deposes and says that she is an Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. l,; Christina Graham Sworn and subscribed before me this n day of y~ ~ , 2010. Notary Public coatr4oNW~-~T~ Q... F ~'Y~~~~ NoKa~~ ~ ppblk Dara WNkersotl, NotsrY CITY d` h' ~ pprli 264 Nry Comml9sla- 6cgres atbn ~ Notaries ~,ynber, ppnnsylvanla Assod y Certificate of Service I, Christina Graham, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 2°d day of July, 2010. WELTMAN, WEINBERG & REIS 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 STEPHANIE SFERLAZZA 329 S. WASHINGTON STREET MECHANICSBURG, PA 17055 c hristina Graham r-, t, r' ~~~( ~.J ..td - .sl , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant CITIZENS BANK, SOVEREIGN BANK and MEMBERS 1sT FEDERAL CREDIT UNION Garnishee No. 07-1803 PRAECIPE TO SETTLE, DISCONTINUE ANfl END WITHOUT PREJUDICE TO REFILE AS TO THE GARNISHEE SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, Esquire PA. I.D.#90963 WELTMAN, WEINBERG ~ REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05452281 ~~~ ~~ ~~ ~~ ~rb~rJ C~~~` ~~is ~~ ~y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Civil Action No. 07-1803 Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE AS TO THE GARNISHEE SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION ONLY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter as to SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION only, upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. /~ By: Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05452281 SWORN TO AND SUBSCRIBED ;t~ai,4tiiu1~JN+,~£:ALI"Yi of PENNSYL191~NIA ._. Natarial Seal Wendy L. Gault, Notary Public "ity of Pittsburgh, Allegheny County rammasion Expires 3uly 15, 2010 _ _. =i:nc ., s;~,an~ ^ ~rirf^~!^r :aP i+Jrta„^I?S a a! before me this ~ day tir ~ 1r 1 `' i ? A'..Y°~ T ~ ~..~ ~ , :,~ ~iiVl l G~,d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant CITIZENS BANK SOVEREIGN BANK and MEMBERS I sT FEDERAL CREDIT UNION Garnishee t No. 07-1803 PRAECIPE .FOR JUDGMENT AGAINST GARNISHEE CITIZENS BANK ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, ESQUIRE PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05452281 PA ~~u (l~ !~1 urkth C,~ 4~ G~UaNB ,~~ta~/~ 9a~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant CITIZENS BANK SOVEREIGN BANK and. MEMBERS 1ST FEDERAL CREDIT UNION Garnishee Civil Action No. 07-1803 PRAECIPE FOR JUDGMENT AGAINST GARNISHEE CITIZENS BANK ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, CITIZENS BANK, in the amount of $63.34, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEJ~B~~G & REIS CO., L.P.A. Bye / MATTHEW D. URBAN, F,SQUIRE PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 1521.9 (412)434-7955 WWR#05452281 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t'` Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: Attn: Operation Services 525 William Penn Place, Room 1.53- 2618Pittsburgh Pa 15219. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant CITIZENS BANK SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee Civil Action No. 07-1803 NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff ( )Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 7~ g,~/GI (xx) Assumpsit Judgment in the amount of $63.34 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( } Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award Citizens Bank Attn: Operation Services 525 William Penn Place, Room 153-261$ Pittsburgh Pa 15219 Prothonot By: P AR (OR DEPUTY) r~ June 23, 2010 WELTMAN, WEINBERG 8~ REIS CO., LPA A'fTN: PARALEGAL DEPT. 1400 KQPPERS BUILDING PITTSBURGH, PA 15219 Re: Writ of F_xecution No. 07-1803 GMAC, LLC VS. STEPHANIE p. SFI=RLAZZA And Citizens Bank of Pennsylvania Garnishee Dear Sir or Madam: 525 William Penn Place Suite 153-2618 Pittsburgh, PA 15219 Citizens Bank of Pennsylvania has been served with the above-captioned Writ of F~cecution. Dur records indicate that the Defendant does maintain 2 checking and 1 savings account at the Bank, which currently has an available balance of $363.34 after the deduction of the garnishee's processing fee of $125.00. Thank you for your prompt attention to this matter. if you have any questions concerning this, please call me at 1-888-999-6884. Very tru{y yours, Laura Noe Operatio Services 1-888-9 ~ 884 ziz .d gal; ~oN wd«-z~ o~oz ~~Z ~N~r ~ Sa ~~s~ "1 -~t~ SAP -2 PM 1= 20 CUM~~~a- v ~ouMY pENPvSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant No. 07-1803 PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE CITIZENS BANK ONLY FILED ON BEHALF OF Plaintiff CITIZENS BANK SOVEREIGN BANK and MEMBERST I sT FEDERAL CREDIT UNION Garnishee COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, Esquire PA. LD.#90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05452281 ~8.Op }~A ATI'+/ CY 475571a ~ a47(o(v7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION GMAC, LLC Plaintiff vs. STEPHANIE P SFERLAZZA Defendant Civil Action No. 07-1.803 CITIZENS BANK SOVEREIGN BANK and MEMBERST I ST FEDERAL CREDIT UN10N Garnishee PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE .CITIZENS BANK. ONLY TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above captioned matter upon the records of the Court and mark the cost paid as to Garnishee, CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A B~ ~ MATTHEW D. URBAN, Esquire PA. I.D.#90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05452281 Sworn to and subscribed Before the ~~ Day of , 2010 OTARY UBLIC COMMONW~ F ~NNSYLVANIA Noanai Seai Sheila G. 6evan, Noary wubik i~oa'1'wp., Atlphany Caurny My_CommlaaWri Iraa Nov. if 2010 Mbin M h A 6Ndn of Notaries WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1803 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC, LLC Plaintiff (s) From STEPHANIE P. SFERLAZZA, 329 S. Washington St, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013 MEMBERS 1sT FEDERAL CREDIT UNION, 321 York Rd, Carlisle, PA 17013 SOVEREIGN BANK, 17 W. High Street, Carlisle, PA 17013 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 $4,898.27 Interest $710.60 Atty's Comm % Atty Paid $166.70 Plaintiff Paid Date: 5/27/10 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs D Avid D. Buell, Prothonotary B?;_ 0- ?W'1- r-- Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED -OFFIt31` I! JAN -6 AM 9: 27 PEP, tNIS YLk1,t 1 A GMAC LLC i vs. Stephanie P Sferlazza Case Number 2007-1803 SHERIFF'S RETURN OF SERVICE 06/14/2010 12:20 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1218 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Stephanie P. Sferlazza, in the hands, possession, or contro of the within named garnishee, Sovereign Bank at 17 W. High Street, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Julie Myers, Customer Service Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 16, 2010 to Stephanie P. Sferlazza at 329 S. Washington Street, Mechanicsburg, PA 17055. 06/14/2010 12:51 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1249 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Stephanie P. Sferlazza, in the hands, possession, or contro of the within named garnishee, Citizens Bank at 665 N. East Street, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Beth Purvis, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 16, 2010 to Stephanie P. Sferlazza at 329 S. Washington Street, Mechanicsburg, PA 17055. 06/14/2010 12:41 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1238 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Stephanie P. Sferlazza, in the hands, possession, or contro of the within named garnishee, Members 1st Federal Credit Union at 321 York Road, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Jen Robertson, Member Service Representative II, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 16, 2010 to Stephanie P. Sferlazza at 329 S. Washington Street, Mechanicsburg, PA 17055. 01/05/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $198.02 January 05, 2011' CK=4- W gas R-4--a53z4/ SO ANSWERS, RO4NR7 N DERSON, SHERIFF_ B haron R. Lantz ,ci CaunsySwte She,;ff. ita eos?ft In:;