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HomeMy WebLinkAbout03-3109 BELCO COMMUNITY CREDIT UNION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. CIVIL ACTION-LAW NO: Od - J/CJ'1 CZ;U~C ~€fL~ JEFFREY S. VANBOSKIRK Defendant NOT ICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Legal Services, Inc. S Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 NOT I C I A Le han demand ado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demand a . Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Legal Services, Inc. a Irvine Row Carlisle, pennsylvania 17013 (717) 243-9400 BELCO COMMUNITY CREDIT UNION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. 03 -.)/D9 e'o~L~~ JEFFREY S. VANBOSKIRK DefendantCsl CIVIL ACTION - LAW COMPLAINT 1. Plaintiff is Belco Federal Credit Union, hereinafter referred to as "BELCO", a Pennsylvania Corporation with an office at 403 N. 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17108. 2. Jeffrey S. VanBoskirk, a Defendant, is an adult individual with an address at 105 S. Market Street, 2nd floor, Mechanicsburg, Cumberland County, pennsylvania 17055. 3. Defendant applied for a revolving credit loan from Plaintiff pursuant to the Application dated June 3, 1986, which is attached hereto, marked Exhibit A and made part hereof. 4. Defendant's delinquent balance on the account is $7154.38. 5. Because of Defendant's failure to make monthly payments and in accordance with the standard Agreement, a copy which is attached hereto, marked Exhibit "A" and made part hereof, Defendant owes an attorney commission of $1073.16 for a total of $8,227.54. 6. Defendant has failed and refused to bring this account current. 7. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff requests entry of judgment against Defendant in the amount of $8,227.54 together with costs of suit thereon. Respectfully, Submitted, Date: 0HD' BY:,>>VLt , QW Arthur M. Feld, Esquire Attorney I.D. No. 07172 1309 Bridge Street New Cumberland, PA 17070-1116 (717) 770-0292 Attorney I.D. # 07172 VERIFICATION MIen1=. ~ClAAj~L)f) states subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is the L-oss Pre.venTion ~Q, for the Plaintiff in this matter, that he/she is authorized to make this affidavit on its behalf and that the facts set forth in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. to) 'd.lo J ~ ot)3 f3IL 6 1---- BELCO FEDERAL CREDIT UNION 403 North Second Street Post Office Box 82 Harrisburg, Pennsylvania 17108 Account Number o8'S~:lo Note Numbp.r, 9.2 C. I Soc. Sec. NJnber If., 7- s :J.- 7'J":5 7 REVOLVING CREDIT APPLICATION, NOTE, PLAN, AGREEMENT AND TRUTH-IN-lENDING DISCLOSURE the undersigned member(s} jointly and severally apply for a revolving credit loan plan to be used for provident and productive purposes, anc agree with the above named credit union to the terms below. This document includes a Truth.ln.Lending Disclosure. 1. Upon approval, the credit union may from time to time make one or more advances to the undersigned member(s) who may pay the balance in full or in part at any time without penalty except that minimum.,P~riodic payments are required on each loan acccount hereunder regardless of any prepayments, as long as any balance exists hereunder. 2. The credit union may change the periodic rate(s) or otherwise amend this agreement, or refuse any request for an advance at any time for any reason not prohibited by law. The credit union may terminate this agreement upon adverse re-evaluation of a maker's credit worthiness, upon failure of a maker or of the credit union with good cause. Action taken under this paragraph shall not affect the obligations of the undersigned or any other obligor. 3. For value received and to be received, the undersigned maker(s) jointly and severally (each shall be agent for the other and be responsible for the advances to the other, whether with know- ledge of same or not) promise to pay to the credit union all sums advanced from time to time on loan accounts under this revolving credit plan plus a FINANCE CHARGE (interest) rate to be disclosed prior to each advance in accordance with law. The credit union shall have the right to change the rate of the FINANCE CHARGE (interest) at its discretion upon giving notice required by law; provided that such change shall not apply to the balance due for the past credit extended if no additional extensions of credit are made hereunder after such change; the maximum rate of the FINANCE CHARGE (interest) shall not exceed an ANNUAL PERCENTAGE RATE of 21%. If additional credit is extended hereunder after the date of such change. the change shall apply to the balance due for past charges. The FINANCE CHARGE is computed on any unpaid principal balance(s) outstanding and is calculated at the time a payment is made; balance{s) change each time new amounts are borrowed or payments are made or credits given. 4. Minimum payments on each loan account shall be $ 10,00 per month for each $ 500,00 or fraction thereof outstanding principal balance calculated after each advance but not less than $ 20.00 per month. Minirnllrn rnnnthlu n::ilurnAnt~ ~h!:lll nnt h.. r.......'........ ......n ...hn'.....h ...hl> .__~__~-' _...c'''"' .... ....,,,,__', ,;I.,. ..-._~_.'-""""-____ 8. (A) If an amount has been entered on a "Revolving Credi Request Voucher" as "Pledged Shares and/or Deposits," the persol signing such voucher hereby pledges such amount of shares and/o deposits, whether held individually, jointly or in trust, as security fo any and all moneys advanced under this plan and interest accruel thereon and authorize the credit union, in the case of default, tl apply same to payment of said obligation. (B) The undersigned hereby pledge all shares and/or deposit and payments and earnings thereon which they now or hereafte may have, whether held individually, jointly, or in trust, as securit~ for any and all moneys advanced under this plan and interes accrued thereon and authorize the credit union, in the case 0 default, to apply same to payment of said obligation. However, thi pledge does not include amounts held under an "individual retire ment account," "Keogh plan." 9. The undersigned hereby give the credit union a securit~ interest in what the undersigned buy(s) with the money borrowed Collateral securing other loans with the credit union may also secun advances made under this plan. 10. Property insurance, if written in connection with any advanc! under this plan, may be obtained from any person of maker's choice 11. In the event any payment on any loan hereunder is not mad! when due, or if an event of default occurs under any security agree ment which may be executed in connection herewith, then thl entire unpaid balance of all loan accounts under this agreement plu accrued interest shall become immediately due and payable, at thl option of the credit union upon compliance with applicable lav relating to notice. The undersigned further agrees to pay all usua and customary costs of collection permitted by law. In connectior herewith, the undersigned jointly and severally waive presentmen for payment, demand, protest and notice of protest and dishonor 12. The failure of the credit union to exercise any of Its right ............. ...1.0:.. ..._.......~__'" _L_II __.. L.._ ..,j__.__ _ ,., . ~ . YOUR BilliNG h 'GHTS - KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about you. rights and our responsibilities under the Fair Credit Billing Act. NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR l, IAN ACCOUNT STATEMENT. If you think your statement is wrong, or if you need more Information about a transaction on your sta' ement, write us on a separate sheet at the address listed on your statement. Write to us as soon as possible. We must hear from you r..:) later than 60 days after we sent you the first statement on which the error or problem appeared. You can telephone us, but doing so w;1I not preserve your rights. In your letter, give us the following Information: .Your name and account number. .The dollar amount of the suspe<. ted error. *Descrlbe the error and explain, IJ you can, why you believe there is an error. If you need more information, .describe the item you are not sure about. If yow.have authorized us to pay your loan account automatically from your savings or share dralt account, you can stop the payment on any amount you think in wrong. To stop the payment your letter must reach us three business days before the automatic payment is scheduled to occur. YOUR RIGHTS AND OUR RESPONSIBILITIES AFTER WE RECEIVE YOUR WRITTEN NOTICE. We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the statement was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to send statements to you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your statement that are not in question. If we find that we we made a mistake on your statement, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement, And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is, If we don't follow these rules, we can't collect the first $50,00 of the questioned amount, even if your statement was correct. SPECIAL RULE FOR CREDIT CARD PURCHASES. If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. There are two limitations on this right: (a) You must have mede the purchase in your home State or, if not within your home State, within 100 miles of your current mailing address; and (bl The purchase price must have been more than $50.00. These limitations do not apply if the credit card issuer owns or operates the merchant, or mailed you the advertisement for the property or services. 7!Ift(!!L~C (SEAL) Applicant maker (member) signature (SEAL) Sx hib>t A "NOTICE: See other side for important Infomatlon." (.:l ~ f[ 1i .~ ~ ~ - ~ C?1 ~ ~ CE" CI)~(' ~ fi -.... 0 t~~ r) ,;: , , <.". ft, - '- ~ - ,,:~ C~l , ('~) ;::: 1~ -r) ,. -'.'. , ,.. ...:: " , l:"') ~. , - iT} ~, C. '-' ,;..~ " :< :n 55 (7) -< € BELCO COMMUNITY CREDIT UNION, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. JEFFREY S. V ANBOSKIRK, Defendant: : NO. 03-3109 : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE To: THE PROTHONOTARY OF CUMBERLAND COUNTY PLEASE NOTE that, pursuant to P A. R.C.P. No. 1012, The Law Offices of Markian R. Slobodian appear for Jeffrey S. Vanboskirk, Defendant in the above-referenced case. Papers should be served on the undersigned at the address set forth below. Respectfully submitted, THE LAW OFFIC~RKIAN R~WBODIAN ~ ..-/ RKIAN . DIAN, ESQ. I.D. NO. 41075 "- ANDREW R. EISEMANN, ESQ. I.D. NO. 87441 801 North Second Street Harrisburg, PA 17102 717/232-5180 Dated: 0/'/03 Attorneys for Defendant CERTIFICATE OF SERVICE: I, hereby certify that I have, this date, served a true and correct copy of the foregoing Praecipe by U.s. Mail, first class, postage prepaid, addressed to the following individual: Arthur M. Feld, Eq. 1309 Bridge Street New Cumberland, PA 17070-1116 Dated: ~,Io J o C <". ;:g:~?'; Z.== 71 (is d -< ." r:: l__' ~~~~ 2. ::< {-,1 (....:~ ~ ';"J I t):) C -n 1 . ",~-) \'? :.,..) --: (:; - -T. :- -T) ~2 (') (),T1 I iJ -< SHERIFF'S RETURN - REGULAR CASE NO: 2003-03109 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BELCO COMMUNITY CREDIT UNION VS VANBOSKIRK JEFFREY S JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VANBOSKIRK JEFFREY S the DEFENDANT , at 1633:00 HOURS, on the 17th day of July , 2003 at 105 S MARKET STREET 2ND FL MECHANICSBURG, PA 17055 JEFFREY VANBOSKIRK by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.90 .00 10.00 .00 34.90 ,r~~~ R. Thomas Kline 07/18/2003 ARTHUR FELD Sworn and Subscribed to before By: V uty Sheriff (.. 1Eo me this day of ~ 0Lv03 A.D. O~ ~honotary ,~ BELCO COMMUNITY CREDIT UNION Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA vs. NO. 03-3109 JEFFREY S. VANBOSKIRK CIVIL ACTION - LAW Defendants Would you please enter judgment in favor of Plaintiff and against Defendant, Jeffrey S. Vanboskirk, 105 S. Market Street, 2nd Floor, Mechanicsburg, PA 17055 for failure to plead to the Complaint within twenty days of service thereof. I hereby certify that the Default Notice required by Rules of Court was sent to the Defendants as shown on the copy attached hereto. Assess damages as follows: $7690.96, together with interest thereon from date of judgment together with costs of suit thereon. jd. VVl~ Arthur M. Feld, Esq. September 23, 2003 BELCO COMMUNITY CREDIT UNION COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 03-3109 JEFFREY S. VANBOSKIRK Defendant/s CIVIL ACTION - LAW IMPORTANT NOTICE To: ANDREW R. EISEMANN, ESQUIRE FOR THE DEFENDANT DEFENDANT/S DATE OF NOTICE: August 25, 2003 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. Legal Services, Inc. S Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 ArQ;; ~; ~e for plaintiff 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 I.D. No. #07172 Attorney ~ IP ~ ~ (") c::. '[ :-C 0 ~ ~ W ."'-1 D C" ,--' ;p,U: ,..... - .-." r 0 n f', .-0 ':,:,. ....... ~ z-', Z\U' "" _.,,~ >:.; --t- ~ pt! Cl)~r:" .+-H 1.. '~., ~~. .::l~), 3 lO <::,:,'1:.: .''l'" 6'- -4 ~, x ',:'~~ , i-' :~: ,"f'\ f:l'. ~ -..:.c ~ 5c: N , , r - l='" '".., ~ :;2 :;iJ <:0 -<. -J:- -' . ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION BELCO COMMUNITY CREDIT UNION ( ) Confessed Judgment (X) Other DISTRICT JUSTICE vs. JEFFREY S. VANBOSKIRK 105 S. MARKET STREET, 2ND FLOOR MECHANICSBURG, PA 17055 Defendant File No.L.f)D3-L?3/0'1 Amount Due $7057.30 Interest FROM 02/23/05 Atty's Comrn Costs Total TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue Writ of Execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant (s) LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant (s) in the possession, custody or control of the said garnishee (s) . (Indicate) Index ~lc0 ~ this writ against ~ /)-yI1~~ Signature~ Arthur M. Fe1d, Esquire 1309 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff (717) 770-0292 ID No. #07172 DATE: -- [ [:, +- ~ i (:) ....... 1r ~ ~ -.... ~ '-. b'- .t, ~t:f Lv 2 () [} ..c::. .0-) --".1 "- i.0 G ..0 () "1 .,() <> f:=J r- tI{ 0 () D 0 C>- o --- I I I I , r; R; w ~~ 0~ -....- --0 - - -". l \) , ~ - ~ - ~f: c} (',-) - , , ":, "'. ~ - - [ - ~ t! '> l , . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-3109 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s) From JEFFREY S, V ANBOSKIRK, 105 S. MARKET STREET, 2NO FLOOR, MECHANICSBURG, PA 17055 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY (2) You are also dire<ted to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 (5) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to atta<lunent is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $7057.30 Interest FROM 2/23/05 LL $.50 Atty's Comm % Atty Paid $116.90 Plaintiffpaid Due Prothy $1.00 Other Costs Date: FEBRUARY 24, 2005 CURTIS R. LONG (Seal) Prothonotary ~d;'o",-g _p 7Eo?J7.J~ r Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 71 7-770-0292 Supreme Court ID No, 071 72 R Thomas K]ine, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Advance Costs: ]50.00 Sheriff s Costs 50.09 Docketing ]8.00 99.9] Poundage .99 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 01/20106 Mi]eage 9.60 Misc. Surcharge 20.00 Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 50.09 Q Sworn and Subscribed to before me ~ So Answers; .~~4.1> ~ <::; "-' f1 ~ this 30- day of R Thomas K]ine, Sheriff l BY~; L~wb,4~J i:~~1:.. tF- \',,~--':' ZS :(; cl (;- 8V~ Saul '.. ,. , ,", 10 ',Jd . J' '\0,,:: -,. ". ''','' 0 ~iIB3~is "HljJ J:JL:U > -)'0 \. tVL 5.2 70.)..) R.u /73L{U WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-3109 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff(s) From JEFFREY S. V ANBOSKlRK, 105 S. MARKET STREET, 2NO FLOOR, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $7057.30 Interest FROM 2/23/05 LL $.50 Atty's Comrn % Atty Paid $116.90 Plaintiff Paid Date: FEBRUARY 24, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary ~y iZ< Ch- ~ - p , 7fJ'l/VL ./ Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No, 07172 r ,.J.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION BELCO COMMUNITY CREDIT UNION ( ) Confessed Judgment (X) Other DISTRICT JUSTICE vs. JEFFREY S. VANBOSKIRK 15 N. 5TH STREET LEMOYNE, PA 17043 Defendant File No. 03-3109 Amount Due $7057.30 Interest FROM 02/23/05 Atty's Comm Costs Total TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pur.suant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue Writ of Execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant (s) LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant (s) in the possession, custody or control of the said garnishee(s) . (Indicate) +do<- Index this writ against Signature: *- /tt. - ~ Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff (717) 770-0292 ID No. #07172 DATE: e t-.l ~ffi ; z, t::" en e, N -<<':~ co ~C~ ~ C. -" >CJ :x ~ N ~ ... ..-< U'I N ~ e. + ~ ~ .(q. ....... ~ '7\:) t4' ~-;O~~~~ t-~ ;" ~ . B 1:: () 0 '1' . .V) ~~ ~ CC()~~~ ~ , "I' ,9- ~~ ~ ~~ ... ~ ~ \ ~ ... .. t ~ ... ... ... .. "" ~ " ~~ ..... ,.... h{' ~ ,.--., "- ~ ~:n ~ g~ \ -f<< -< WRIT OF EXECUTION and/or ATTACHMENT ./ ... .'--.. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-3109 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s) From JEFFREY S. V ANBOSKIRK, 15 N 5TH STREET, LEMOYNE, P A 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 $7057.30 Interest FROM 2/23/05 L.L. Atty's Comm % Atty Paid $179.49 Plaintiff Paid Date: NOVEMBER 28, 2006 Due Prothy $1.00 Other Costs (Seal) eums1t~~ By: Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, P A 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No. 07172 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL S 18.00 1.47 1.00 14.96 20.00 20.00 75.43./ 1;~//)1 ~ S I :[ d L - J:10: qnnz .... -J UiJ Advance Costs: Sheriff s Costs: $ 150.00 75.43 74.57 Refunded to Atty on 01/16/07 So Answers; R. Thomas Kline, Sheriff ) cJ <4Wl~ b&v.u)bJ By Claudia A. Brewbaker C) l}J , w -. 10 --Q j, u-O (:J<.. S1/~O ~. If rO(,<( WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s) From JEFFREY S. VANBOSKIRK, 15 N 5TH STREET, LEMOYNE, PA 17043 NO 03-3109 Civil CIVIL ACTION - LAW (l) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 $7057.30 Interest FROM 2/23/05 L.L. Atty's Comm % Atty Paid $179.49 Plaintiff Paid Date: NOVEMBER 28, 2006 Due Prothy $1.00 Other Costs Curtis R. (Seal) By: Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, P A 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No. 07172