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Home My WebLink About99-05477'id'$ SEARS, ROEBUCK AND CO., PLAINTIFF VS. KENNETH W. JONES, DEFENDANT IN THE C6URT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims 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. or 4dpR. Cumberland County G&m*heeye Carlisle. Pennsylvania 17013 Telephone: 717 -2466"o ?24-?i-3(l?? &C A%vc z L b e il'i'l ?e, SEARS, ROEBUCK AND CO., IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. KENNETH W. JONES, DEFENDANT COMPLAINT IN REPLEVIN 1. Plaintiff is Sears, Roebuck and Co. ("Sears"), a corporation organized under the laws of New York with a place of business located at 45 Congress Street, Salem, Massachusetts, 01970. 2. Defendant is Kenneth W. Jones, an adult individual residing at 46 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, 17070 ("Defendant"). 3. Defendant opened account no. 07084860-38395-8 (the "Account") and charged various purchases of merchandise to the account. 4. Sales invoices executed by the Defendant and Diana Jones, an authorized purchaser on the Account, at the times when purchases charged to this Account occurred, granted to "Sears" a security interest in the merchandise purchased until fully paid. Copies of the sales invoices signed by the Defendant and Diana Jones, an authorized purchaser on the Account, are attached hereto, marked as Exhibit "A" and are incorporated herein by reference. 5. Sears' security interest in the merchandise purchased pursuant to the Account is perfected without filing a UCC-1 Financing Statement pursuant to UCC 9-302(a)(4). Sears is a secured creditor of the Defendant and holds a perfected purchase money security interest in the consumer goods identified in Exhibit "B" which is attached hereto and incorporated herein by reference. 6. All payments made by the Defendant on the Account are applied first to any unpaid insurance or finance charges and then to pay for the earliest charges on the Account. 7. The total balance owed by the Defendant as of November 9, 1998 was Six Thousand Eight Hundred Eighty-five Dollars and Twenty Vents ($6,885.20). 8. On November 9, 1998 the Defendant filed a Petition under Chapter 7 of the Bankruptcy Code with the U.S. Bankruptcy Court, Middle District of Pennsylvania to no. 98- 05409RJ W. 9. On February 18, 1998 the Defendant received a discharge extinguishing his legal liability to pay certain debts including the debt owed to Sears. 10. Sears avers, however, that the discharge of the underlying indebtedness has no legal effect on the validity of its security interest in the merchandise identified in Exhibit "B". See Estate of Lellock vs. Prudential Insurance Co. of America, 811 F.2d 186 (3rd Cir. 1987). II. Pursuant to Sears' purchase money security interest in the merchandise identified in Exhibit "B", Sears is entitled to possession of such merchandise. 12. Upon information andbelief,Defendant isinpossessionofthemerchandise identifred in Exhibit "B". 13. The fair market value of the merchandise identified in Exhibit "B" totals Eight Hundred Fifty-two Dollars and Forty-five Cents ($852.45). 14. Although demanded, Defendant refused and continues to refuse to turn over possession of the merchandise to Sears. WHEREFORE, Sears respectfully requests this Court for a judgment for possession with respect to the merchandise identified in Exhibit "B". Dated: ?? ?krg Respectfully submitted, BASKIIN,, LEISAWITZ, HELLER & ABRAMOWITCH By: (2 0 ), LA ? c?arljles J. Phillips, Esquire 2201 Ridgewood Road Suite 400 Wyomissing, PA 19610 (610) 372-8427 Attorney for Sears, Roebuck and Co. I, Debra DeGrenier, state and aver that I am the Manager of Special Accounts of Sears, Roebuck and Co., state and aver that I am authorized by the Company to sign this Verification and that the facts set forth in the Complaint in Replevin are based on information furnished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the Complaint in Replevin is that of counsel and not of the undersigned. The undersigned verify that she has read the attached Complaint in Replevin and that it is true and correct to the best of his information and belief. To the extent that the language of the Complaint in Replevin is that of counsel, the undersigned has relied upon counsel in making this verification. This verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: S?Jgq SEARS, ROEBUCK AND CO. By: I?PJ A 01AlD?, Debra DeGrenier EXHIAIT "A" r-? ... TIME: D4:22PM SEARS CARLSBAD, CA 01678 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE PURCHASER: DIANA JONES ADDRESS: 199 LOS PADRES CITY/STATE: OCEANSIDE, CA ZIP CODE: 92054 PHONE: 619-385-4261 TRAN# PG/STORE REG# ASSOC# 6612 01678 203 158 EXCHANGE DATE SOLD 10/15/94 SOLD BY 000158 SALES CHECK 016781038614 3 32387 DX2-66 L-3 RET 1699.99T- DATE SOLD 10/01/94 SOLD BY 000158 SALES CHECK 016782033466 70 13393292 RET 179.99 EXPIRES: 12/30/1997 MULT CREDIT 50.OOT SUBTOTAL 1829.98- TAX 115.50- END OF RETURNED MERCHANDISE---- 3 32405 PEN 60 L-6 SAL 1999.99T 70 13379292 3YR SHOP M MDS 189.99 EXPIRES: 12/30/1997 3 32496 INK,S02003 MDS 34.99T 3 32495 INK,SO2003 MDS 17.99T MULT CREDIT 50.00 - SUBTOTAL 362.98 TAX 25.01 DEPOSIT 242.00 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/000/000 DELAYED DATE: 03/01 DELAY REASON: PROMOTIONAL 12/30/94 DELAYED TOTAL 145.99 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $145.99 N S' v. SALESCHECK # 016782036612 SATISFACTION GUARANTEED OR YOUR MONEY BACK "YOU CAN COUNT ON ME" TIME: .01:57PM RCCOCN 1224 SEARS HARRISBURG, PA 01224 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: DIANA L JONES ADDRESS: 164 J AVE CITY/STATE: NEW CUMBERLA, PA ZIP CODE: 17070 PHONE: 717-770-0467 TRANM PG/STORE REGN ASSOC# 8270 01224 122 4598 SALE 22 75058 A/C 5.1M, MDS 269.99T 70 22100292 CAP MA MDS .00 EXPIRES: 05/26/1997 SUBTOTAL 269.99 TAX 16.20 CARD TYPE: SEARSCHARGE ACCT S: 0784860383958/00 1/000 STATE: PA 05/26/96 SEARSCHARGE TOTAL 286.19 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $286.19 PURCHASED BY SALESCHECK / 012241228270 SATISFACTION GUARANTEED OR YOUR MONEY BACK ,TIME: .06:21PM RCCOCM 8414 SEARS CAMP HILL, PA 02624 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: DIANA L JONES ADDRESS: 164 J AVE. CITY/STATE: NEW CUMBERLA, PA ZIP CODE: 17070 PHONE: 717-770-0467 TRANS PG/STORE REGM ASSOCB SATISFACTION GUARANTEED 311 02624 24 802 OR YOUR MONEY BACK SALE 71 69255 HOSE,SPRNK MDS 9.997 71 69255 HOSE,SPRNK MDS 9.99T 9 79778 8LT PATH S SAL 31.49T 57 43043 TV PR1916C SAL 208.99T- MULT CREDIT 14.59T- SUBTOTAL 245.87 TAX 14.76 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/001/000 STATE: PA 06/08/96 SEARSCHARGE TOTAL 260.63 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $260.63 PURCHASED BY SALESCHECK # 026240240311 TIME: ,.11:49AM RCCOC# 8414 SEARS HARRISBURG, PA 01224 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: ADDRESS: CITY/STATE: ZIP CODE: PHONE: DIANA L JONES 164 J AVE OFF MIFFLIN AT DORE ARMY NEW CUMBERLA, PA 17070 717-770-0467 DELIV. DATE: 01/10/97 AFTERNOON TRAN# PG/STORE REG# ASSOC# 6793 01224 126 4 176 EXCHANGE DATE SOLD 07/08/95 SOLD BY 004176' SALES CHECK 026240264298 26 24802 WASHER,W.O RET 459.99T- SALE CREDIT 35.OOT DATE SOLD 05/11/96 SOLD BY 004176 SALES CHECK 012241261933 26 65852 DRYER, ELE RET 358.88T- SALE CREDIT 17.94T SUBTOTAL 765.93- TAX 45.96- END OF RETURNED MERCHANDISE---- 26 26892 A/WASHER W MDS 424.99T SETUP AND CONNECT 70 26308292 3YR HOME M MDS 99.99T EXPIRES: 0111012000 26 66812 DRYER ELEC MDS 340.94T SETUP AND CONNECT 70 26301292 3YR HOME M MDS 69.99T EXPIRES: 0111012000 DELIVERY FEE .00 SUBTOTAL 169.98 TAX 10.20 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/003/034 01/09/97 SEARSCHARGE TOTAL 180.18 KEN JONES 07-24260-32392-2 APRIL 21, 1999 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $180.18 J \ PURCHASED BY SALESCHECK # 012241266793 SATISFACTION GUARANTEED OR YOUR MONEY BACK - r. EXHIBIT "B" Item Purchase Date Purchase Price Fair Market Value Packard Bell Computer, Model No.5661,60CD 12/30/94 $1,955.99 $195.59 Fedders Air Conditioner, Model No. 4845GC53 05/26/96 $269.99 $145.79 Magnavox Color TV, Model No. 626PR I 916C 06/08/96 $197.29 $59.18 GE Electric Dryer, Model No. DVL223ETOWW 01/09/97 $340.94 $201.15 GE Washer, Model No. WBXR1060T5WW 01/09/97 $424.99 $250.74 M? ' F V J I ?. U C!." r: •r• CL. C! 1 a. V1 On J U D c\ W 9 1. SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05477 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SEARS ROEBUCK AND CO VS. JONES KENNETH W R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: JONES KENNETH W but was unable to locate Him - in his bailiwick. He therefore returns the COMPLAINT - REPLEVIN NOT FOUND as to the within named defendant JONES KENNETH W DEFT. IS NOW RESIDING AT: 428 JENNTRRR r)VTVO WTJr., Sheriff's Costs: So answer Docketing 18.00 Service 10.54 ?. Not Found Return 5.00 Surcharge 8.00 ias ine, eri $41`75-4 LE?SAWITZ HELLER, ABRAMOWITCH 09 17//199§ Sworn and subscribed to before me this day of 19 ((//?i?,\\II A.D. Win. Pp AQs,'. SEARS, ROEBUCK AND CO., PLAINTIFF vs. KENNETH W. JONES, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ?? _ j X77 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that ifyou fail to do so the case may proceed without you and ajudgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims 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. 46k-R, Cumberland Countv ' ?- (34tr le. Pennsylvania 17013 71 717- Telephone: 2 h, d?Ki TRUE _GWV Fppy We Uno 4r of at lslp N. 19 - SEARS, ROEBUCK AND CO., IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. KENNETH W. JONES, DEFENDANT COMPLAINT IN REPLEVIN Plaintiff is Sears, Roebuck and Co. ("Sears"), a corporation organized under the laws of New York with a place of business located at 45 Congress Street, Salem, Massachusetts, 01970. 2. Defendant is Kenneth W. Jones, an adult individual residing at 46 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, 17070 ("Defendant"), 3. Defendant opened account no. 07084860-38395-8 (the "Account") and charged various purchases of merchandise to the account. 4. Sales invoices executed by the Defendant and Diana Jones, an authorized purchaser on the Account, at the times when purchases charged to this Account occurred, granted to "Sears" a security interest in the merchandise purchased until fully paid. Copies of the sales invoices signed by the Defendant and Diana Jones, an authorized purchaser on the Account, are attached hereto, marked as Exhibit "A" and are incorporated herein by reference. 5. Sears' security interest in the merchandise purchased pursuant to the Account is perfected without filing a UCC-1 Financing Statement pursuant to UCC 9-302(a)(4). Sears is a secured creditor of the Defendant and holds a perfected purchase money security interest in the consumer goods identified in Exhibit "B" which is attached hereto and incorporated herein by reference. 6. All payments made by the Defendant on the Account are applied first to any unpaid insurance or finance charges and then to pay for the earliest charges on the Account. 7. The total balance owed by the Defendant as of November 9, 1998 was Six Thousand Eight Hundred Eighty-five Dollars and Twenty Cents ($6,885.20). 8. On November 9, 1998 the Defendant filed a Petition under Chapter 7 of the Bankruptcy Code with the U.S. Bankruptcy Court, Middle District of Pennsylvania to no. 98- 05409RJW. 9. On February 18, 1998 the Defendant received a discharge extinguishing his legal liability to pay certain debts including the debt owed to Sears. 10. Sears avers, however, that the discharge of the underlying indebtedness has no legal effect on the validity of its security interest in the merchandise identified in Exhibit "B". See Estate of Lellock vs. Prudential Insurance Co of America, 811 F.2d 186 (3rd Cir. 1987). 11. Pursuant to Sears' purchase money security interest in the merchandise identified in Exhibit "B", Sears is entitled to possession of such merchandise. 12. Upon information and belief, Defendant is in possession ofthemerchandise identified in Exhibit "B". 13. The fair market value of the merchandise identified in Exhibit "B" totals Eight Hundred Fifty-two Dollars and Forty-five Cents ($852.45). 14. Although demanded, Defendant refused and continues to refuse to turn over possession of the merchandise to Sears. WHEREFORE, Sears respectfully requests this Court for ajudgment for possession with respect to the merchandise identified in Exhibit "B". Dated: C)1')Y_T°l Respectfully submitted, BAS+KIN,, LEISAWITZ, HELLER & ABRAMOWITCH By: (BA ' / I k A l1 CE-arles Phillips, Esquire 2201 Ridgewood Road Suite 400 Wyomissing, PA 19610 (610) 372-8427 Attorney for Sears, Roebuck and Co. I, Debra DeGrenier, state and aver that I am the Manager of Special Accounts of Sears, Roebuck and Co., state and aver that I am authorized by the Company to sign this Verification and that the facts set forth in the Complaint in Replevin are based on information furnished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the Complaint in Replevin is that of counsel and not of the undersigned. The undersigned verify that she has read the attached Complaint in Replevin and that it is true and correct to the best of his information and belief. To the extent that the language of the Complaint in Replevin is that of counsel, the undersigned has relied upon counsel in making this verification. This verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: I Hqq SEARS, ROEBUCK AND CO. By. ?t A fV? O l l pn Debra DeGrenier EXHIBIT "A" r I M1 ! f'?Yfq 'wqF!' '• ili?i/?Y' / ppppyy ' Y a q??? ry???y.? 1?.??y. yam{ may! ? .•` erJ[ii?LY?VS?OM1yI ??[?Wp1Wl V?? ? Wn,• i•- ":. ArFi?i{1?ID1? LN2Ik•:kL-.D ?y! : PtT LT?I riD ttaC col. Ni ?Y 4tX 511 314 it :F'•• ;Twi pt?? yw7 ?qf. '.!1 p 1X:i or -Will S 'ItQ ;13,1 :t lit. MY 30 TIME: 04:22PM SEARS CARLSBAD, CA 01678 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE PURCHASER: DIANA JONES ADDRESS: 199 LOS PADRES CITY/STATE: OCEANSIDE, CA ZIP CODE: 92054 PHONE: 619-385-4261 TRAN# PG/STORE REG# ASSOC# 6612 01678 203 158 EXCHANGE DATE SOLD 10/15/94 SOLD BY 000158 SALES CHECK 016781038614 3 32387 OX2-66 L-3 RET 1699.99T- DATE SOLD 10/01/94 SOLD BY 000158 SALES CHECK 016782033466 70 13393292 RET 179.99 EXPIRES: 12/30/1997 MULT CREDIT 50.OOT SUBTOTAL 1829.98- TAX 115.50- END OF RETURNED MERCHANDISE---- 3 32405 PEN 60 L-6 SAL 1999.99T 70 13379292 3YR SHOP M MDS 189.99 EXPIRES: 12/30/1997 3 32496 INK,S02003 MDS 34.99T 3 32495 INK,S02003 MDS 17.99T MULT CREDIT 50.00 - SUBTOTAL 362.98 TAX 25.01 DEPOSIT 242.00 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/000/000 DELAYED DATE: 03/01 DELAY REASON: PROMOTIONAL 12/30/94 DELAYED TOTAL 145.99 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $145.99 :.a w SALESCHECK # 016782036612 SATISFACTION GUARANTEED OR YOUR MONEY BACK "YOU CAN COUNT ON ME" TIME: 01:57PM RCCOC# 1224 SEARS HARRISBURG, PA 01224 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: DIANA L JONES ADDRESS: 164 J AVE CITY/STATE: NEW CUMBERLA, PA ZIP CODE: 17070 PHONE: 717-770-0467 TRAN# PG/STORE REG# ASSOC# 8270 01224 122 4598 SALE 22 75058 A/C 5.1M, MDS 269.99T 70 22100292 CAP MA MDS .00 EXPIRES: 05/26/1997 SUBTOTAL 269.99 AX 16.20 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/001/000 STATE: PA 05/26/96 SEARSCHARGE TOTAL 286.19 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $286.19 PURCHASED BY SALESCHECK # 012241228270 SATISFACTION GUARANTEED OR YOUR MONEY BACK TIME: 06:21PM RCCOC# 8414 SEARS CAMP HILL, PA 02624 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: DIANA L JONES ADDRESS: 164 J AVE. CITY/STATE: NEW CUMBERLA, PA ZIP CODE: 17070 PHONE: 717-770-0467 TRAN# PG/STORE REG# ASSOC# SATISFACTION GUARANTEED 311 02624 24 802 OR YOUR MONEY BACK SALE 71 69255 HOSE, SPRNK MDS 9.99T 71 69255 HOSE,SPRNK MDS 9.99T 9 79778 8LT PATH S SAL 31.49T 57 43043 TV PR1916C SAL 208.997 MULT CREDIT 14.59T- SUBTOTAL 245.87 TAX 14.76 CARD TYPE: SEARSCHARGE ACCT #: 0784860383958/001/000 STATE: PA 06/08/96 SEARSCHARGE TOTAL 260.63 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $260.63 PURCHASED BY SALESCHECK # 026240240311 TIME: .11:49AM RCCOC# 8414 SEARS HARRISBURG, PA 01224 RETAIN FOR COMPARISON WITH MONTHLY STATEMENT OR FOR RETURN OR EXCHANGE DELIVER TO: CUSTOMER CUSTOMER: ADDRESS: CITY/STATE: ZIP CODE: PHONE: DIANA L JONES 164 J AVE OFF MIFFLIN AT DORE ARMY NEW CUMBERLA, PA 17070 717-770-0467 DELIV. DATE: 01/10/97 AFTERNOON TRAN# PG/STORE REG# ASSOC# 6793 01224 126 4176 EXCHANGE DATE SOLD 07/08/95 SOLD BY 004176 SALES CHECK 026240264298 26 24802 WASHER,W.O RET 459.99T- SALE 35. DATE SOLD 05/11/96D1SOLD BY 00410076 SALES CHECK 012241261933 26 65852 DRYER, ELE RET 358 SALE CREDIT 17 SUBTOTAL 765 TAX 45 END OF RETURNED MERCHANDISE---- 26 26892 A/WASHER W MDS 424 SETUP AND CONNECT 10 26308292 3YR HOME M MDS 99 EXPIRES: 0111012000 26 66812 DRYER ELEC MDS 340 SETUP AND CONNECT 70 26301292 3YR HOME M MDS 69. EXPIRES: 0111012000 DELIVERY FEE SUBTOTAL 169. TAX CARD TYPE: SEARSCHARGE 10. ACCT #: 0784860383958/003/0 34 01/09/97 SEARSCHARGE TOTAL 180. 88T- 94T 93- 96- .99T .99T 94T 99T 00 98 20 18 KEN JONES 07-84860-38393-8 APRIL 21, 1999 PURCHASED UNDER MY SEARSCHARGE AGREEMENT, INCORPORATED BY REFERENCE, I GRANT SEARS A SECURITY INTEREST IN THIS MERCHANDISE UNTIL PAID, UNLESS PROHIBITED BY LAW $180.18 PURCHASED BY SALESCHECK # 012241266793 SATISFACTION GUARANTEED OR YOUR MONEY BACK EXHIBIT "B" Item Purchase Date Purchase Price Fair Market Value Packard Bell Computer, Model No.566L60CD 12/30/94 $1,955.99 $195.59 Fedders Air Conditioner, Model No.4845GC53 05/26/96 $269.99 $145.79 Magnavox Color TV, Model No. 626PR I 916C 06/08/96 $197.29 $59.18 GE Electric Dryer, Model No. DVL223ETOWW 01/09/97 $340.94 $201.15 GE Washer, Model No. WBXRI060T5WW 01/09/97 $424.99 $250.74 i OFFICE OF THE SHERIFF Irk. CUN^; " !!!f ,,;!iyry SEP 9 2 o5 Pil 199 'W ?ARIJ:Lr PEN INS i'L'VANIA SEARS, ROEBUCK AND CO., PLAINTIFF VS. KENETH W. JONES, DEFENDANT IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5477-Civil PRAECIPE TO END. DISCONTINUE AND SETTLE TO THE CLERK: Please mark the docket in the above-captioned matter as ended, discontinued and settled. Dated: September 22, 1999 LEISAWITZ HELLER ABRAMOWITCH PHILLIPS P.C. l - By: Charles J. Phillips, squire 2201 Ridgewood Road, Sui a 400 Wyomissing, PA 19610 Attorney for Plaintiff UJS? r } ?: rw :.a2 T U