HomeMy WebLinkAbout07-1896COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff No. d ~ " ~0 61o C~• lc~ ~ ~ ~z1'-'\
vs. 1.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
CIVIL ACTION
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS
SET FORTH IN THE FOLLOWING PAGES, YOU MU5T TAKE ACTION WITHIN TWENTY (20)
DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE
WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A
JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE
FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF
REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS
IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMATO AND ASSOCI , P.C.
By:
onald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff No. ~~' , ~ ~9~
vs.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
CIVIL ACTION
Defendant(s)
COMPLAINT
The above Plaintiff brings this action against the above Defendant to recover the sum
of $15,904.54, with interest thereon as hereinafter stated, upon the following cause of action:
1. The Plaintiff, SOVEREIGN BANK is located at 1130 Berkshire Blvd.
Wyomissing PA 19610..
2. The Defendant, DODI L. ALEXANDER-BARBER also known as Dodi
Alexander is located at 121 Meals Drive, Carlisle PA 17013.
COUNT I
3. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
4. On or about March 16, 2004, Defendant executed and delivered to Waypoint
Bank, for value received, a promissory note for the sum of $9,060.60 which was payable in
monthly installments, as fully described in the attached note. A true and correct copy of said
promissory note is attached hereto, made a part hereof and marked Exhibit "A".
5. Sovereign Bank is the successor by merger to the interest of Waypoint Bank.
6. The above promissory note, attached hereto as Exhibit "A", provides that in the
event of Defendant's failure to pay any of the installments when due, then all remaining
installments shall at the option of the Plaintiff become immediately due and payable.
7. Defendant defaulted in the payment terms of the above note on or about
November 1, 2004.
8. Defendant made her last payment on or about June 8, 2006.
9. By reason of Defendant's failure to pay the installments when due, Defendant
has defaulted on said promissory note, and pursuant to such, has caused the entire balance of
$6,551.30 to be immediately due Plaintiff.
10. Plaintiff has performed and complied with all terms and conditions required
under said above note.
11. Pursuant to the written terms of the aforesaid note Plaintiff is entitled to receive
interest on the above amount determined by applying the agreed interest rate of 13.24 % per
annum to the past due balance. As of March 21, 2007 the total amount of interest due to
plaintiff is $5,144.58.
12. Plaintiff is entitled to have the 13.24 % interest charge continue to accrue as set
forth above, from March 21, 2007 on down to the date of judgment in this matter.
13. In accordance with the aforesaid agreement, Defendant further agreed to pay
Plaintiff's reasonable attorneys' fees incurred in the collection of any balance due Plaintiff, which
total $1,441.29.
14. The Plaintiff has made demand against the Defendant for the aforesaid sum, but
Defendant failed or refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against the Defendant for $13,137.17
together with the continually accruing interest charge at the agreed rate of 13.24 % per annum
from March 21, 2007, and cost of suit.
COUNT II
15. Plaintiff incorporates the allegations of every paragraph enumerated above of this
Complaint as if said paragraphs were fully set forth here at length.
16. On or about September 7, 2000, Defendant opened a personal line of credit with
Harris Savings Bank as fully described in the attached contract. A true and correct copy of which
is attached hereto, made a part hereof and marked Exhibit "B".
17. Sovereign Bank is the successor by merger to the interest of Harris Savings Bank.
18. The above contract, attached hereto as Exhibit "B", provides that in the event of
Defendant's failure to pay any of the installments when due, then all remaining installments shall
at the option of the Plaintiff become immediately due and payable.
19. Defendant defaulted in the payment terms of the above contract on or about
November 1, 2004.
20. Defendant made her last payment on or about June 8, 2006.
21. By reason of Defendant's failure to pay the installments when due, Defendant has
defaulted on said contract, and pursuant to such, has caused the entire balance of $1,913.23 to be
immediately due Plaintiff.
22. Plaintiff has performed and complied with all terms and conditions required under
said above contract.
23 . Pursuant to the written terms of the aforesaid contract Plaintiff is entitled to receive
interest on the above amount determined by applying the agreed interest rate of 9.50 % per annum
to the past due balance. As of March 21, 2007 the total amount of interest due to plaintiff is
$433.23.
24. Plaintiff is entitled to have the 9.50 % interest charge continue to accrue as set forth
above, from March 21, 2007 on down to the date of judgment in this matter.
25. In accordance with the aforesaid agreement, Defendant further agreed to pay
Plaintiff's reasonable attorneys' fees incurred in the collection of any balance due Plaintiff, which
total $420.91.
26. The Plaintiff has made demand against the Defendant for the aforesaid sum, but
Defendant failed or refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against the Defendant for $2,767.37 together
with the continually accruing interest charge at the agreed rate of 9.50 % per annum from March
21, 2007, and cost of suit.
COUNT III
Alternative to Counts I and II -Unjust Enrichment
27. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
28. The goods, wares, merchandise, and/or services, described in the exhibits
attached hereto were purchased by Defendant, and Defendant received and accepted the benefit
of such goods, wares, merchandise, and/or services provided by Plaintiff.
29. At all times material hereto, Defendant was aware that Plaintiff was providing
the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff
expected to be paid for such.
30. At all times material hereto, Defendant, with the aforesaid knowledge,
permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services,
and to incur damages.
31. At all times material hereto, Defendant was unjustly enriched by retaining the
benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff
fair and reasonable compensation.
32. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's
expense, an implied contract exists between Plaintiff and Defendant, and Defendant is
obligated to pay Plaintiff the uantum meruit value of the value of the goods, wares,
merchandise, and/or services described in the exhibits attached hereto, in the amount of
$8,464.53.
WHEREFORE, Plaintiff demands judgment against Defendant for $8,464.53 together
with the continually accruing interest charge at the statutory rate of 6.00 % per annum from
March 21, 2007, costs of suit and all other relief to which Plaintiff may be justly entitled.
AMATO AND SSOCI ES, P.C.
By:
onald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
___.`.~- Note, Disc%sure, and Securi A reement
Lender Borrower
~. WAYPOINT BANK DODI AT.F.XATTi)Ejj_$~B~
449 EISENHOWER BLVD
HARRISBURG, PA 17111. 253 ADAMS ST
STEELTON, PA 17113
^ Refer to the attached addendum for additional
Borrowers and their signatures.
Loan Number 0151009209
Loan Dak ' 03/16/2004
MahriiryDak 03/lb/2009
,Loan Amount 6, 636.00
Renewal of
Annual Percentage Rate Fnance Charge amount Firrencad
The cost of my credit as a esr Total of Payments
rate, Y IY The dogar amotmt the credit wt71 The ameurc of credit provided to me The amount I will have paid when I
12.990 cost °K' 2 , 424.60 or on my behalf. have made ail scheduled Paymetss.
% S S
IY Psymern SchedWe Wig Be: S
ayments Amount of Paymerns When Payments Are Due 'e' mans as estitrtak.
60 S 151.01 Monthly beginning 04/16/2004
a
s
Demand. ^This Dose has a demand feature. ^This trek is payable on dement and all disclosures ate based on an assumed maNrity of one year.
ProWYment. If I pay off this nok euly, I ^ may ~ wilt not have to pay a minimum finance charge.
7h^s If I py off this nok early. I will not be entitled to s refund of part of the additional finance e-wrge.
L-Tlets Charge. Tf a payment is late (more than 15 days after due) I at71 be charged a late charge equal to lOX of
the unpaid amount or $20.00, whichever is greater.
Sassily. I am giving a security interest in:
^the geode or ProPutY wing putt:hased.
^collatenl severing other bans with you may also secure this loan.
^ (brief description of other property)
Hgng Fees. S-.~_
Non-Blitty ktsuranca. $ --
^Raquired Deposit. The atuaral percercage tak does trot take into account my requited
^Assumption. Someoro 6u . ~ deposit.
Contract Documents. I txa see co~~ ~~ this obligation rmnot asutote the rentaittder of the obligation on the original terms.
~• ~ PreWymeN refunds atd~peml ~t documents for arty additional information atwut notgwyment, default, any tequitW n:PaY~t before tlk scheduled
.~ ~
Promise.to Pey. For value received, I promise m guytn ~ar~ Your order. at
your address above,~ip~~n oF~S~ . d 3
Rlts.t~r~st from ' ~~ rak of
% PaYe~~
Merest accrues on a basis. I agree
pay lak charges in auwMance with rite provisbas shown in the
Tmtlr-in-Lending Disclosures. The purpose of this ban is
Payment. I will pay this nok as follows:
~Insereudue monthly
Principal due monthly
This nok has 60 pay~ie, The fast Payment
wr71 be in the amount of S .151.01
will be due APRIL 16 , 2004 and
f 151.01 will be due oo thPae~i 6th
day of each month
thereaPoer. The fatal payment of the white unpaid balance of principal
and interest wAl be due _MAR('H ~ ~nno
Poet-Maturity Interest. Inkrest will accrue afar maturity on the unpaid
balance of this note on the same basis as inknest accrues before maturity,
uNess a specific post-nryatriry inknes[ rak is agnxd m in the rozt senknce.
^Inkrest will aurae at the rate of % per year on the balance
of this nok not paid at maturity, including maturity by axektation.
^Atdditlonal Finance Charge. I also agree to pay a nonrefundable fee
of S ,-{ and k veil! be ^ paid in cash. ^ paid Pro tats over
~ Iwn terns. Ll withlteid from the proceeds. (If this fce is withheld from
the proceeds, the amourc is included m the principal sumJ
^ Ngnimum Fhtance Charge. I agree ro pay a minimum finance
charge of S if I pay this trek off before you have
}tamed that much in finance charges,
fO Rah mad Payment Fee. I agtx to pay a service charge of S 25.00
payment (check or aummadc payment) remrtted unpaid.
^ Dttrsr Taints.
~ ~ ~ ~
Amount given to me direWy S
Amount paid on my (loan) account
AmouN paid so otlwrs on my belwlf (You
may room or receive a portion oP these
amounts.)
To insutartce comPsNes
To public officials
(less) Prepaid Finance Charge(s) S
Amormt Financed ~ 6, 636.00
Security. To severe the obiigatlorts of tbis Loan
Agreement, I give
you a security inkrest in the Property described below:
^A0 Debffi. The Property wig also serve as rnDatera! for
all present and tutee debts.
^Other Security. This Loan Agreement is secured by
PANDSS
Ea~i ' Simpts Interest Note, Disclosure, and Security Agreement
2002 Bankers Systems, Inc., St. Cloud, MN Form NDaS-SI-PA 6/1/2002 Consumer Dan -Not for Open-End Credit
• Page 1 of 3
X 1 1 I I • I I
Defittitlons. As used is this Loan Agreement, ®indicaies terms that apply m
this Loan Agreement Zam Agreement refers m this Promissory Nok, Security
Agrament, and Trnth in Leading Disclosures, and any extensions. renewals,
modifications, and substitutions of this Loan Agreement. Loan rckrs m this
tratsactien generaiiY. imludinB obligations and duties arising from the terms of
all documens prepared or submitted for this transactioq such as applicadoas,
security agreaocns, disclosures, or notes, and this Loan Agreement Seauiry
Agreement refers m the severity agreement contained within this Loan
Agreement Scarred Debts refers m all sums advanced m you under the terms of
the Loan Agreement, and all present and future debts (if the All Debts subsection
of the Security Agreement has been checked). The pronouns I, me and my
rckr m each Borrows signing this Loan Agieement, indivlduany ant mgether
with their hits, successors aM,assigns, and each other person or legal entity
(including guaranies. endorsers, ant surctis) who agrees m pay this Lan
Agreement Yorr and your rckr m the Lender and its successors and assigns,
Advance Roeadtuo And Means. Yon will advance the loan proceeds by
way of cheek, alit, war transfer, credit x an aoAUm or any combination
as you std I agree. The advance(s) will oceur upon cotstimmation of the
Iona and as you and [agree, except that m advance(s) will occur until
after three business days from the dal of cotsutnmadon if the loan is
rescitdable pursuant m Regulation Z (12 C.F.R § 226).
Payments. UNess otherwise provided in the Other Terms section, each
PaY~ 1 make on this Loan Agreement will be appled first m soy charges
I owe other than principal and inters[, they m inxrest that is due. and
finally m Principal that is due. No lase charge wUi tie assessed on any
payment when the only delinquency is due m late fees assessed on earlier
payments std die payment is otherwise a full payment. The acme! amount
of my final payment will depend on my peytnent record.
httarut Inxrest will accrue on the unpaid primipal balance until paid in
kU. For itiirest ralailatinq die accroal method will determine the number of
days in a year. The inters[ rate and otlter charges on this Losn Agreement
will never exceed the highest tax or rJiarge allowed by law kr this loan. If
tli amount collected is foutd m exoxd di highest tax or charge aDowed,
you wr'U refund an amount tttx:essary m twmply with the law.
Post-Masudty 4ttarert. httercs[ will acetue on the principal balatxe remaining
unpaid after fitul ioasirity ar tli tax spectfpd in this Loan Agreement. For
purpose of this sxtion, final maturity occws on any of the following dais.
• If this Loci Agreement is payable on demand. on the dax
you make dettraid for Payment
• ff thin Loan Agramem is payable on dematd with alptnap paymena
dai(s). oa the dax you make denisid for payment a oa the fiat
aitetrtate payment dax, whichever is earler.
• On the dal of tli last scltedNed payment of principal.
• On the dax you acalerap the due date of this Last Agreement
(demaM irttotediate PaY~)•
• Upon the entry of judgment on this mp and ceppties m amoutis owed
under this nee or under arty aiih judgment umt7 paid in full.
i'rePevment. I [nay Prepay this Loan Agreement in whole or in
part at any thne. MY P~ prepayment wUl cot exvese any lair
scheduled poyments'utitil Ipay in full.
Comrnisslons. I understand sad agree that you (or your atfdiap) wU! earn
commissions or fee on arty insursrce products, and may cam such fee
oa other services dot I buy tluough you or your affiliate.
Warrsrsdes and Represeittatlons. Ihave the power std authority m rnir itroo
this Loan Agnxment The execution and delivery of this Ivan Agreeroem will
not violase any agremem governing tti a my property, or m which [ am a party.
[ own all of tli Property, uNem otherwise agreed and disclosed x you io
writing. Your claim m the Property is ahead nt die chins of any other crcdimr,
except as disclosed in writing m you prior m any advaroe on the Secured Debts.
The Property has not been and wUl cot be used far any purpose that would
violate any laws or subject the Property m forfeiture or seizure. f
Dsfault. Subject m any limitatinns tit the Rol Estate or Resldetrce Secwity
section, I wUl tie in default if any of the following oceur.
• I fall m stake a Payment when due. '
• I fail m d
perform any cotdifion or keep any promise of this or
airy agreement I have made with you.
Remedies. Subject m any limitations in the Real Estax or Resldemx
Security section, after I default, and after yQp give any legapy requited
mdce and oppornirrity m vet the default. you may a[ Your option to
do any one or more of the following.
' of tt saLoan NY part of the atmuau owing by the tetras e[
Agreement due.
• Use uiy and all remedes you have under star a federal law, or in
any instrument seauing this Loan Agrerttent. W
• Make a claim for any ant all insitratia betiefis or refunds diet w
may tie available on my default.
• Setoff any amount due and payable uMer the terms of [Iris Loan Agreement
against my tight m teaive tmney from you, uNess prohibited by law. ro
• Make amours advattad on my behalf due and add those amours m dp the
balance owing under the tams of this Lawn Agreement P
• Require me m gather the Property and [Hake it available to you in a reasonable ~
fashion (uNess prohibited by law); keep or dispose of the Property as provided
by law; apply dta.Proceeds x your expeaus of collection and erdorcernent i~
end then x the Secured Debts; and, uNess prolubiid by law. and knowing
any requited entice of deficiency, hold me liable kr any defiieney if what D
you receive from die sale does cot satisfy the Securd Dubs,
BY wing any one or more of these remedus you do not give up A
your right m use any otlir remedy. You do cot waive a default if you
choose tux m use a remedy Hy electing not x use any remedy. you ~
do not waive your right m later consider di event a default and m use
mY remedies if the default continues or occurs again, lee
Real Estate or Raddenq Security. If this Loan Agruemem is secured
by teal essx or a residence drat is personal Property. the exispnce of a
default ant your remedies for such a default will tie determined by applicable
law, by die ptms of any separsx iristiumem crating di security inters[
std. ro the extern not prohibited by law and cot cotinary m the terms of
the uparai security instrument, by this Loan Agreement
PANDS2
Waivara. To the extent mt prohibited by law, I waive protest, presenirnent
for payment, demand, notice of acceleration, entice of inint m accelerate,
and entice of dishomr. You may renew or extend paymeNS on this Loan
Agreement, regardless of the member of such renewals or extensions. You
may release any Borrower, endorser, giiarenmr, surety, accommodation
maker. or any other cosigner You may release. substimp, or impair
mY AnPerty severing this Loan Agreement
CoUactlon Eirpensas and Attorneys' Foes. On or after Default m the
extent permitted by law, I agree m pay all reasonable expenses of conectioq
enforcement, a protection of your rights and remedies order this Loan
Agreement Expenses include, but arc not limited m, attorneys' fees, court costs
and other legal expenses. These expemes are due and payable immediately. If
cot paid immediaely, these expenses will bear inserest from du date of payment
~i'1~ ~ full at the rate provided in the t,;rma of this Loan Agreement.
xpenses wnl be secured by the Property I have grsmed you, if
say. To the extent permitted by the United States Badmtpmy Code. I agree m
Pay lee reasonable attorneys' fees you incur m coUea this debt as awarded
by mY court exercising jurisdiction under the Batdntiptuy Code.
General Provisions. This Loan Agreemem is governed by the laws of
Pennsylvaoi, the United Stares of America, and x the extern requited, by die
laws of die jurisdiction where the Property is Incased. U two or more Borrowers
sign this Loan Agteetnent, we are liable m repay jointly std severally. This
Loan Agreement is the complete and final expression of our agreetneatc No
modification of this Loan Agreement is effective udess made in writing and
signed by me and you. The duffs ant benefits of this Loan Agreatirit will
hint and benefit the successors and agsiga of me std you. IP any provision
of this Loan Agteenpm is unenkrcsbk, then the uaenforceabk provision
will be severed std the remaining provisions will be enforceable.
UNcss otherwise required by law, any notice will be given by delivering it
or mailing it by first class mail ro my last kmwn oddness. Notice x one
party will be deemed m tie mils x ail parties. VVhem a mtice is required. I
agree that 10 days prior written notice will be teasotiable notice m me under
the UNform Commercial Code or other applicable star law,
I wUl provide you mY financial statement or information you request.
All financial sutetaeas and information I give you will be corretx and
complex. My name a~ address arc my exact legal name and my
principal rcsiderie. I will provide you with at least 30 days mtice
prior to changing my name a principal rcsldetta.
~'U!v Provisions that ant you as an agent are mt subject m the
provisions of 20 Pa: A. Senior 5601 U seq. (Chapxr 56• Decedents,
Estates and Fiduciaries Cade). BY exercising airy of your rights under
tltis [lose. you do so for your sole beafit
I agree m sigq deliver, cad file any additional dovernens or certifiatiots that
you may consider necessary m perfect, continue, and preserve my obligations
under this Lan sad m cotd[rni your lien status oa nay Property.
rI1 I I ~
in whirl~i I have a~~ mw or~dx fud~~wherever tli Pro
will be located, and all proceeds and products from the Property. Property
hiluds all parts, acassoiies, repairs. rcplacemetis, improvemeius, and
accessions i the Property• NY original evidence of title or ownership; and all
obligations riot support the payment a performaiie of the Property.
Tf the All Dabs subsection is cricked. the Property also secures all prsem
ant future debts, even if this Losn Agreement is cot rckrertced in the debt
isstrument, the fume debts are also scarred by otlier co-axral, a If the future
debt is tttuehtsed m or of a ditkteot type that[ this debt. Nothing in Ibis Lan
Agnametit is a twmmitment x mall kmrc loans or advances. This Loan
Agrettint will not severe any debt kr which you fall m give any requited
mtice of rite right of rcscissan (i.e., right m canal), or any debt kr which a
non-possessory, mn•puicliase moray security inprost ie created in householdd
onds in wmicdoo with a conswrrr lotm, as those pmts ate defused by
ederal law governing unfair and deceptive credo practices.
Ptirchass Money Security Interest. If this is a Purchase money loan (the Man
procecds arc used m purchase die coUateral),1 authorize you. at your option, m
isburse the loan proceeds directly m the seller of the Property. The portion of
the Property purrdtesed with loan proceeds will remain subject m your purchase
money security interest until the Secured Debts are paid in full. Payments oa
any con-purchase money loan also secured by this Security Agreement will
not lx applied m the purchase mnoey ban. Payments on the pinrLase moay
as wUl be applied first m the non-purchase money portion of the ban, if any.
ant then m the Purchase money porton io the order io which the purchase
mmteY ~oPem' was acquired. If the purchase morcY Property was acquired
the same tinte, then paymens will be applied is the order you select. No
severity interest will tie termitupd by application of this formula.
aiwre. I waive all claims for less or damage nosed by your acs or omissions
lira Yen aased reasonably and in good faith. I waive all rights 1 have mw or in
the kturc m a honiatead a personal Property exemp[ma in the Property.
AnumpGotis, Someoa buying the Property cannot aasuine the
igadoa You may declare the entire bslatice of the Loan Agramem
be ttnmedtasety due and payable upon the creation of, or connect for
creation of, a ttanskr or sale of the Property.
arfectlon of Security Interest. I autlioriu you m file a finaming
le[nent covering the Property. I agree m comply with, fiiilimoe,
otherwise assist you in comiection with perfetxing your security
serest under the UNktm Commercial Code.
ufies Towavd Property, i will protect the property and your interest
against any competing claim. Except as otherwise provided in this Loan
gramwt, I will keep the Property in my possession at the address
itidicaid in this Loan Agreement I will keep the Property in good
pair and use it only for Personal, fam7y, or household purposes, I will
mtmediately inform you of any loss or damage m di Property, you have
right of.reasonable access m inspect the property,
I will keep hooka, records, and accounts about the Property and my asses
in general, m which I will allow you reasooabk sass. I will pay all taxes
and essessmens levied or assessed agaiact me w the Property. I wUl not sop,
lease, Haase, a otherwise transfer or encumber the Property without your
prior written consent You do not authorize any sale a other disposition of die
Property: Any sale or disposition you do ne suthorire will violax your rights.
Tf I pledge the Property m You (deliver the Property ism your. or your
dsignated third party's possession or contraQ, I wUl, upon receipt, deliver
any proceeds and produGS of the Property aryou. I wUi provide you with
arty nodes. documents. financial shteanents, reports, aid odic inkmtadon
rclatittg m the property I receive as the owner of the Property.
" Simple Interest Nots, Disclosure, and Security Agreemem Consumer can -Not for Opon-End Credit
°2002 Bankers Systems, Inc., St. Cloud MN Form NDaS-SI-PA 8/1/2002
t3 Page 2 of 3
Insurance, I atiree to keep the property insured against the risks reasonably
associa.ed with i:. Property anal the Property is released from this Security
Agreement I may provide the required insurance through an existing poll
of insurance that I own or control, or through a policy that I buy. I have
+ free choice in the selixtion' of an insurance company, mbjeil to applicable
law. I will maintain this insurance in the amotttas you require and !rave rite
hsurance company name you as loss payee on any insurance policy. I will
give you and tthhee insuraauce c;muparry immediate rotice of any loss. You may
apply tiro insurarce proceeds roward what is owed on the Secured Debts. If
the insurance ptncxeds do not cover the amounts I owe you, I wgl pay the
difference, You may require additiorad security as a condition of permitting
any tnsuratta proceeds to be used to repair or replace the Property. If you
scquire the Property in damaged condition, my rights ro any insurance policies
and proceeds mil pass to you ro the exsent of the Secured Debts. I will
itnmedmrcJy notify you of pri"'collation or termination of insurance.
I am rapdred to mahdain fnstuattce on the Property to protect your
tntetrst. It I tall to maintain the required btsmance, or tag to provide you
with eddence of Lumamoe, I uoderatand and agree to the following.
• Yon may (hot are rot twttdred to) place htisurance ~ the Property to
Protest yottr Lrtereat, which will mot cover my equity is the Property.
The inamaaaY you provide may be written by a oompeny other
than one I would chooses and may 6e writtm at a higher rate thou
I could obtain V I pmcchased the insuratce.
• I wm pay tort the .crash of any Property hasurattce you provide.
Authority to Perform. I authoritt you ro do anything you deem reasonably
If I ro protect ~ ~~ and your security interest in the Property.
perform any of my duties under this Loan Agreement, you arc
arrthorimd, after providing me with any required notice and opportunity ro
perform. m perform the duties oct:ause them to be Pwfonned and add the costs
of performance ro the Seemed Debts. Thex atuhonzstions include, but arc Trot
limised m, ptxmission m pay for the repair, mainrcnance, and preservation of the
Property and taking any natal ro obtam or preserve the benefus and rights of
the Property. Your authority m perform forme will rtes crease an obligation ro
opt and your failure ro perform wilt not prerJude Yoa from exercising any
rights under the law or Chia Severity Agrcanent. If you come into aerates!
or consuuaive possession of the Property, You will prcxrve and protect the
~ ray ro rho extern required by law. Your duty of care with rcspea to the
pert' wrB be satisfied if you exercise reasonable care in the safekeepurg of
the PraPerS' or in the xlection of a third parry in pasxssion of the Property.
Third Party Agreement
For tiro purposes of the provisions within this enclosure, I, rare or my means the
person signing below ardyoumeans the Lender identified in this Loam AgreaneN.
I agree to give you a security iaserest in the Property that is desai'bed in the
Security Agreement section. I agree to the terms of this Loan Agreement, but I
am in ao way personally liable for payment of the debt. Thb means that if the
Borrower defaults. my inserest in the severed Property may be used to satisfy tlk
Borrower's debt. I agree that Yon may. without releasing me or the Property
from This ThiN party Agreemem and without notkx or demand upon me. extend
new credit m any Borrower, renew or change Kris Loan Agreement one or more
times sad for arty term, or fail m perfect yon. security inserest in, impart, or
release any.security (uicluding guaranties) for the obligations of any Borrower.
f have received a completed copy of this Loan Agreement.
Attach FTC 'Preservation of Corwrmer Claims and DefenseF'
Notice if Applicable.
Credit tnstrrsrtp. Credu life. credit accidem std slelmtess (disablliry), and any
other inmramce coverage quoted below, are mt required ro abhin credit and you
will not provide them uNess I sign and agree ro paythe additiotW premium. If
I warn such instnartce, you wiU obtain it for me (if I qualify for coverage).
You arc quoting below ONLY the coverages I have chosen m purchax.
Credit Lite
Premium $
^Single ^Joinl~None Torm
Credit Disability
Premium $
^Single ^Joint~None Term
Premium $
^Single ^Joint ^None Term
Slgnatm~e. My sigrtamrc below means I want (only) the insurance coverages)
X~!/ ei Noneeis the cad, I have doclimtd the coverage you offered.
'~ /3 DOB Imo/
^ Single Interest Inaumnce. I may obtain single interest insurance
from anyone I wan that is acceptable m you. If I get the insurance
from or through you I will pay $ '
for of coverage.
^ Property Insurances. I may obtain property insurance from
anyone I want that is acceptable to you. Tf I get the insurance from
or through you I will pay $
for
of coverage.
r~ ~ I ~
Product rcfus b arty ituurartce product or annuity I purchase from you. With
regard to any Product I purchase from You, the following apply.
• The Product is not a deposit aammt or other obligation of any depository
insimtion or any affiliate of any depository irtstiWtion.
• The Product is trot guaranteed or htsmrod by any deposiory institution
or sny affiliate of airy deposiory instmtion.
• The Product is not insured by the Federal Deposit htsunnce
Corporation (FDIC).
• The Product, except in the case of Federal Flood Insurance or Federal Crop
Insurance, is trot iasored by any federal government agency.
• ~ if this box is rltecked, there is Investnamt risk associated with
the Product, including the possible loss of vahre.
By sigNng, I aciurowledge that I have rxeived a copy of this disclosure
on today's dare. Unless Ibex disclosures arc provided electronically
or I have purchased the Product by mail, I also ackrrowkdge that you
have provided rhea dixlosures to me orally.
NOT APPLICABLE
X N(1T APPT 7f•ART F Desk
X NOT APPLICABLE Dau
•.
Yau (the coWper) are 6dog asked to guaranty thb debt, Thinly
try l0 rha~ve to. Be~wre you can aKotypady u you~have to you
that yon want to aoeept this tespo
You may have to pay up to the tYtg amormt of the debt if the
borrower does trot pot'. You also may have to pay late fees or
eellectron ooah, which increase thkr amotmt,
The creditor can collect this debt from you wif6oat tftst ttyhtg to collect
tram the borrower. The a+edttor can use the wine oolkctlon methods agatoat
you that can 6e ffied agatast the bortawer, such as antng yoq etc. If thk
debt h ever io default, that tact may became pert oryerrr credit rYCOrd.
This notice h nog the contrail that make you liable rot the debt.
B7 ~, I agree to We terms eontatned ha fbls Loan AgrxmeW, I also
acknowledge receipt of a copy of this Loan AgrwtKnt on roday't date.
Cosigners. See Notice to Cmtgner above before sigribtg.
x~~HODI AL ~ '--'~
Sigrado~~l~fi[/r4'( Q ~l/~iL(~~ ~~'~T/(/'"
Title BRANCH REPRESENTATIVE J r
PANDS3
Ex~.r "Simple IMarest Note, Diacloaure, end Security Agreement Consumer Loan -Not for Opan-End Credit
°2(102 Bankers Systems, Inc., St. Cloud, MN Form NDaS•SI-PA 8/1/2002
Pegs 3 of 3
MODIFICATION AGREEMENT
Automatic Payment
This Modification Agreement is entered into this 16th day of MARCH 2004 , by and
between DODI ALEXANDER-BARBER ~ of
253 ADAMS` ST, STEELTON, PA 17113 ("Borrower") and
WAYPOINT BANK f/k/a Harris Savings Bank and York Federal Savings and Loan Association,
a federal savings bank, with its principal office at 235 North Second ~ Street, P. O. Box 1711,
Harrisburg, Pennsylvania, 17105-1711 ("Lender").
Note Date 03/16/2004
Account Number 0151009209
Loan Amount SIX THOUSAND SIX HUNDRED THIRTY-SIX AND NO/100
Dollars ($ 6 , 636.00 )
WITNESSETH the parties hereto intending to be legally bound hereby declare, promise and
agree as follows:
AMENDMENT TO AGREEMENT
The Annual Percentage Rate of 12.990 % as provided in the Note will be increased to .13.240
upon the Borrower(s) causing or allowing the automatic Loan Payment terms associated with their
active Waypoint checking account to terminate for any reason including Waypoint's action pursuant
to the account agreement. The Annual Percentage Rate Increase shall become effective the day after
Borrowers' account is closed or the Automatic Loan Payment stops or is stopped.
Except as modified herein, all of the terms and conditions of the Note shall remain in full force and effect,
shall not merge into this Agreement. This Modification Agreement shall be binding upon the parties hereto,
their heirs, executors, administrators, successors and assigns.
IN WITNESS WI-IEREOF, the parties have hereunto set their hands and seals the day and year first
above written.
Waypoint Bank:
~~~ '
Waypoint Bank Representative BoRROwER
Waypoint Bank Representative
Waypoint Bank Representative
Waypoint Bank Representative
BORROWER
BORROWER
BORROWER
WP68r20020419
• r 09-07-00 14:32 HARRIS SAVING BANK ID~T17 243 5907
P02/06
H~1RRt....,?aAViM~S BANK
PERSONAL LINE OP CREDIT -
-u1Y Mtudmum Credit Llmis dw Thb Agraerne Q~
As used in this Agreement the words "1, me and my mean each and e0 of the one of Credit ACCOUrIt Nu er 70
persorrc who sign below as Borrower, Tha
HARRIS SAViNti BANK a and Yowe• mean:
I (Wei Promice m repay airy extensions of erodh and proper charges to rho Account, she Cann of rho Account ~~
xath Interest wbWesed in eoeordanos whh this Agnomens. 1 (Wal Promin m pay MY change fi rite Arnual Percemaga Rata wR be appgcabk m the then
each month at least the min(mum Payment due whhfi TS days of Ute bllHng date. H outstanding beknq an the Account and sny subsequent bens or axrcrcittlonc
you ills soh' or uks other Iogal action to coileat the amount due on the Account, I _
hn11 pay.H cote Iriwrred and a roasonabw aRdrney'a fee of at not kua than 1691 o f of ersdh, unW the Annual Pucatrcage Rata changes again. •
the amount duo. I promise m rape fioraasa io tM Minimum Mod iW.r~mage Rap may resuh fi a corrasponding
Account so the extent tlu Y upon demand any extension of cndh an the nth Y Yment
t the out+serrdfig prficipal bafanoa on the Aoeant PAYIIaENT: 1 undaratand that I can pay my autamndirp balance fi fuE K any time
exceeds cha aurhortzed orodh Iimh: payment under [his esntend wig be due N 3~9GO mr tha~ dYip nswa b~Wncs [pr gory ept~tha Mlrumum Paymenn wlu~
addition m she mfn4num Payment due on the Acaaunt. It roe LmDOraiRy Prohibit ~ volurtury cndk nsurance promlumc, H at
further oxtenabn of credit. I promise m continuo m melee die mbimton paymertta g P+d•p. plus Flrnnee Chan s,
duo on the aooou acted, late chaitgoc and snY other tus.
irt. vnathcted by uts mmporary /arohibhian. LATE CHARGE: Bottbwor agrees m pay a late chage of
MAXWtiM t3KDIT LRiIIiT: 1 understand that you wlE advice ms from dme m time of DeY~ amount but not kss than ~_.llcf the
the +nasimum amount of tfia ktan advances than made on hs dw data shown on the month aq 00 ff any Daymarit it not
Agnament. I apse that tM total cursor Y~ wW ~°~ m me under tNs ly Lamont. No late cha a
ndttd bahnea under Uda Agreemem wHl not the reason the payment 4 kp & a contin ' d ro wig bs due N
exceed my Maximum Cndh Umh. Ii you approve any loan advances far ma above because, aftaf defauh. the CtIW'o outstand ~ oV on a prior PWmeM or
my maslmum Credit Umh Iwhieh you do not haw m do-, I w1p s ~ -ance became due,
chow my Maxlmtrrii Crodh LkNt on demand. P V You tlu amount ALITONATK; PAYMEIAiT D®pCT10AL•~ fl chocked, i suthtulm
Lanz Adwneos:l can obtain ben advanooa in the fodowing vrayss doduat my mondiry PsYmem from my You m autoaladcally
AumorlkOvardraRAdvan it ~$Q?7 1 that i rtuinsa(n~` AooowK Wa.
checked, t can tvrip a Wnronal check fa nton: than paymetn k dw. t egns m ~~ y°u• on the daso each momlyy
the balance on my pasonY check aceowit /~Z00025027 am rnafitetn a balaru:s b the Account auffiokrtt m cover ~
medially aansfer to my oheotanq atxoiart an You wig auto• momfrhr Wymarrc whoa k ie duo. You may. as yew sole dlacredo to
Tha mnkraart Ian adwnn tMe Borrower can obumtn a +pfaNmft m wvr Ure owrdn/t Aueomado n. ierkats the
airy dme U $50.00 If PaNnent Deducdon.
Spackl Checks: if checked ou wr7 au -""~- the Aummatlo Payment Daduetlon k sambamd for any reason, the kimnst rem
may uae ro otrtafi®n acv y PPIy ma whit special checks whk:h 1 oa mY loan wt4 hcreace by, CIA
ances. I may siaSioUau rheas ohedts m a th4d .Tha new rats wN bo akecdw on
would a rcgukr cheek. Thb rttininum advenp elver 1 can obtafi Pat<Y as 1 the first payment dw dap fopowfig she cancdhnlon of sM Automade Paymom
st any sfiu y Oeduorbn.
HARRIS SAVING aANK CHECK AND ATM CARD; ANNUAL PIE: Btarower agrees m WY an amwl tae of ~ ~ ,,,,
m me a Check and ATM ^ % ~~' Y°'+ wp provide inoludod fi your charges after the amtiver -~i ra--whfdt wIl bs
Cad which ! tvq use m obtain ban advance b eery month of yo„r ~,
mY (Dori Pwsanal kieitdRoadan Numbw and Y using APPLtCAT10N OF PAYIyIEt1f1-S: You wU ePWY Payment fi the fo0owing order of
the Check and ATM Card at rho Money PdoritY: fFst m airy fans, than m fiterest then to optional orodh Ilia insurance
Access prd (MAGI ar VISA •AummstadTotler Machtno•(ATM), w 1 qn obtain baria Mamkrrris, H arty, then m PrfioipaL
m PurtAteea goods or aarvkes by ualnq iM Check and ATM Card at any Dartkfpstkig GOVERNpQa< LAW, AMEIIDMEtsTS 4lyp NOTh:al:
MAC or VISA merehanL that •o++Pp tM Chock and ATM card. ~ tlra kws of the Commonwwkh M PennsYhrattia, State off Masm shall bs gowmed
AA loan advances togogKy wAl bs conskktred a slrrole, concogdatad ban. I a Crodh Granmr Open • and Endh Piovision of Thin mod' fi' Subdda g,
tfia[ such ehedc or the com tY•• of the Mnoumd Code of Me 12 of the Canmerdal Law ankh:
Puny record of each vansactbrt gariwapd bV ms wig nodae• from you m ma alall F~ifoond ~ Federal law, as apppgbls, Ap ~~
consdtute my written autltaritatlon required by hw, address ss h a by ordinary me9 addnssad m ma n such
PERIO~~ apidTEwMn r ou wEl card ms a momhly cewrnem showing tM status of Manged or mo~~ Y « records. Note of rho mmla of the Agreomem may bs
p ymanm mua a mods. a wrhun a ~ ~ COUrw of dasMq between you and ms, but
adva~ito~is~The .FlNAnNCE CNARGEwO ~ charged a Ffianea Charge on all ban Youu wN adMSS~ti~~ bbY maAng such smandmams and mediFo ~ry t~
posed to mY Adeoum at the OaBy Periodic Rsu itd(0 026027 aX,,~ k modlikntlon. ~ mail 30 days Prior w the effeodrs dap of any amandmarn a
DaYy Psrktdb Rata, when muhrpifed by 365, b That JDWT Lbt91LRY: U ttUs Agreamoris Is seeeptsd by mars than om Borrower, sash
RATE of 9.50 equal to an ANNUAL PERCENTAt3R shat ba lointry and satrarally ikbk and
%. You figure the -irtditca Charge on ag my Account pursuant m the mans of the atPssa m pay you for ep k>an advances
the following way:frst, you Rqun she balarwa of my ACCOUfn nch da in agreemarc.
oYCle by addkp new Ioan advance Y the biting D~AULT: I w1a be fi dafauk It: lal I fa8 m make any required WYment on tkras to
babnes as of the[ day. You titan aubvac~ m my Aceamt m the opening ban ibl Any smmmam in my app4cadon is falsas a Id 1 fag m WV any other debt I owe
TI'ia Y aY bakrlcs, Than ~ ~Ymerlp «~ Posted that Wy. I ~ ~ fW I baoortie Inwlwd fi bankruptcy ar aknilu fieolwney Orocaedingr, or lal
gives you m W You muhipiy my balance subket m a Flrurres k••P Y of Promius under>his Agreamaiit
Charge each day fi Lhe bglkp cYd+ by the Daby Porfodb Rata, and add salt day's R~EDIES OM DEFAULT; On defauh, n
Chaiga for the actual number of days fi the ' egroemwtt m entered crack clu0 be Provided fi the porsgrcph above, yew
~~ biDirig cYde. Thtc ghraa you this tertrdrtated, and a1 of
Ftunce Charge for due bN6ng eyok. ~ this' Agreement chap 6s fiamdlataly due and psyabla. Hay °~atdw You b
VARIABLE RATE,® tt checked, the Annusl Percensege Rau at any tirtu, wiT ~~ m airy attontaY Tar won, t may be charged rcasortabls attorryya' fog,
determ(nad by adding she "m.roin." whkh w81 net change dur6p the term of rho ODIC REVU1lV: You Mrs Ufa right to review
Account, m the "fidex" v s, ~ You and ether credhon: and u on ~ °~ Derformsrrce whh
ale ich vvrll ahangs from time m skr». Verifbatbn of mY kicome ac arty t( ~~ from you I rnusL provkla you Whh
Attnusl Perwnp n Rau can rent' eon thad~fint d~a t pf each bM mast. Tha H you reaconabiy bs6sya 1 wG noc bo able m meet the npayman requkamanLs
Cha a Dau"1. g ~ V ng °Yek ("Rate e~ma~) the cbsitlg out of daposh aeeorntts whh mtkiatjon of
~ ~ Paymettt provkbn [tf ebdudl: b.1 the WkntiW6on of subs by oUKr
Tha margin for the Aoooum k _ 5 9h pdn;errceg• Pab!ts. cndhgra indigting flnenoW dlsvass on
The htdax 4 she h-ghase Prktte Rdp publiehsd br Tf„ WeE Street Journal and fi nrv ~~ or c.1 ttta ktcttrdng of
ctpniftcerq addklonal aeoursd w tntaeeurod debt which in your reasonable beEef
affect a: of the 16th day of each month prior u tlK Rate Change pap. wotdd rdtallaitge my ebPrty m romakt cotta
The ANNUAL PERCENTAGE RA' wig never slmaad ~.8 _ 00 !6 du deenenel WYmartt fi tiro wilt a 30 day notbs from yo kNn; you haw the dght m
r~ TiEAIYiNATfON: Tlds Agnstrieitt may be tarmfiated by You at any rktr by written
notice cam to me; hotwaver, the serminatbn aheA not afhctmy rosponsWigrytq
CREDIT7NSU WY my outsta obligations under [hk amens,
RANGE IS NOT REQUIRED, Creech Life Innusttee is tort hquind m obpfi crsdk, and wgl rat 4e provided unku Borrower(s) signs irobw and agrees
to pay the eddhktnal coselsl. Coverage hi awCabN m eomower(s1 undw B9 yssre of ape.
BY slgnfig, Borrows requacu Sirlpk Crcdt Life Insurance, whk:h costa
BY si0nfig, Borrower rcgUesp Joint Cradh Life insurance, which coats
f _ 0705sar moral, par sl,ooo-;00 of the actual da0y beianba, b .123~ar tgon~
.~~~' Q' per S 7 A00.00 of the actual daihr baianco.
urc o rrowe u1sUr Me
natures mowers m nsure
as
RECEIPT P COPY: f agroa to the teams of this AgrsamenL and acknowledge naa~t of a complste(y Ailed ~n
2065 RIZ1~R ~ Agreemem,
w.r ('ARL•TCTS.w, PA 27013
Adtlrew
e[l~
"a.t:
2000
ddnsa
NOTICEt SEE REytiRSB 610E FDR IMPORTANT INFORMATKIR ANp YOUR (THE BORRDWER'SI
,`
VERIFICATION
~eY1 ,hereby states that he/she is the ~c°AQl SOLCIQI<5 ~' of
Savprc«n ,gl,~yl~' ,Plaintiff in this action, and verifies that
the statements made in the attached Complaint are true and correct to the best of his/her
knowledge, information and belief. The undersigned understands that the statements herein
are made subject to the penalties of 18 PA C.S. §4904 relating to unsworn falsification to
authorities.
"J~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff No. 07-1896 Civil
vs. _
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
CIVIL ACTION
Defendant
PRAECIPE FOR JUDGMENT
II
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Kindly enter judgment by default for want of an answer in favor of Plaint~ff and against
the above-named defendant(s) only and assess damages as follows: j
Debt $15,904.54
Interest (from 3/21 /2007 to 5/18/2007
at 13.24% per annum) X06.14
Payments CD.00
Total ~ 16,210.68
LL
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOIE SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
Pursuant to RCP 237.1, I certify that a copy of the annexed written notice(s) ollf intention to
file this praecipe was mailed or delivered to all parties against whom judgrrjent is to be
entered and to their attorney of record, if any, after the default occurred, anc~ at least ten
days prior to the date of filing of this praecipe. Please note that said notice wasl mailed to all
parties on May 8, 2007. '~
Dated: 2007 ~~
AMATO AND ASSOCIATES, P.C. ~,
By: '
Rona d m ,Esq., Atty ID #32323
Michael J. Kennedy, Esq., Attu ID #72412
Attorneys for Plaintiff
107 North Commerce Way ~,I
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FI~M
2063610
' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff No. 07-1896 Civil
vs.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
CIVIL ACTION
Defendant
CERTIFICATION OF ADDRESSES
I do certify that the precise fast known address of the within named plaintiff is:
1 130 Berkshire Blvd.
Wyomissing PA 19610
I do certify that the precise last known address of the within named defendant is:
121 Meals Drive
Carlisle PA 17013
AMATO AND ASSOCIA~"ES, P.C.
By: / ,~
Ronald Amato,~sq., Atty lD #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(6101 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff No. 07-1896 Civil
vs.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
CIVIL ACTION
Defendantls)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF NORTHAMPTON
The undersigned, being duly sworn, according to law, deposes and says that the
above Defendantls) is/are not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act of 2003;
That Dodi Alexander-Barbera is over 18 years of age, resides at 121 Meals Drive,
Carlisle PA 17013 and is employed;
-~1~~
Sworn to and subscribed
before me this day
of Mck~ 2007 A.D.
NOTAR UB
NOTARIAL SEAL
GEOFFREY G SCHOENECK
Notary Pubilc
HANOVER TOWNSHIP, NORTHAMPTON CNTY
My Commission Expires Mar 29, 2008
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff
vs.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
Defendant(s)
TO: Dodi L. Alexander-Barber
a/k/a Dodi Alexander
121 Meals Drive
Carlisle PA 17013
Date of Notice: May 8, 2007
No. 07-1896 Civil
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMATO AND ASSOCIAT , P.C.
By:
Ronal Amato, q., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
SOVEREIGN BANK
Plaintiff
vs.
DODI L. ALEXANDER-BARBER
a/k/a Dodi Alexander
Defendant
No. 07-1896 Civil
CIVIL ACTION
NOTICE OF JUDGMENT
(XX) NOTICE IS HEREBY G{VEN THAT A JUDGMENT IN THE ABOVE CAPTIONED
MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s)
IN THE AMOUNT OF 516,210.68 ON /~ ~~ , 2007.
( 1 A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF
CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN
JUDGMENT IS/ARE ENCLOSED.
PROTH NOTARY -~ MB AND COUNTY
,~5~
If you have any questions concerning the above, please ontact the undersigned.
AMATO AND ASSOCI ES, P.C.
BY~ ~ ~i
Ronald Amato,,E~(., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-01896 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SOVEREIGN BANK
VS
ALEXANDER-BARBER DOI~I L
JESSICA HERMANSEN
Sheriff or Deputy Sheriff of
Cumberland County,P~nnsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ALEXANDER-BARBER DOL~I L AKA DODI ALEXANDER the
DEFENDANT at 11511:00 HOURS, on the 17th day of April 2007
at 121 MEALS DRIVE ',
CARLISLE, PA 17013 ',
by handing to
DODI L ALEXANDER BARBER
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: So Answers:
Docketing 18.00 ~'
Service
4.80 '~
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
3~ 04/18/2007
-D`~ AMATO & ASSOCIATES
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Sworn and Subscibed to
before me this day
of ! ,
By.
Dep t Sheri f
A.D.