HomeMy WebLinkAbout99-06410ALLFIRST BANK, successor by merger
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.,
Defendant
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. 99-6410 Civil
: Assigned to:
PRAECIPE
Please enter a Default Judgment in the above-captioned matter in favor of Allfirst Bank and
against the Defendant, Jeffrey E. Arnold, Sr., because of the Defendant's failure to file a timely answer to
Plaintiffs Complaint.
COUNTI
Address of Plaintiff Principal $20,244.11
Allfirst Bank Interest thru 10/6/99 1,274.90
499 Mitchell Road Attorneys' fees 23 27.85
Millsboro, DE 19966
TOTAL ................................$ 24,746.86
Plus continuing interest from 10/7/99, at the rate of 9.74% as stated in the Note and Security Agreement,
attorney's fees and costs of suit, and any other costs pursuant to the Complaint.
COUNT If
Address of Plaintiff Principal $9,338.79
Allfirst Bank Interest thru 10/6/99 508.30
499 Mitchell Road Attorneys' fees 1.477.06
Millsboro, DE 19966
TOTAL .....................................$ 11,324.15
Plus continuing interest from 10/7/99, at the rate of 12.74% as stated in the Note and Security Agreement,
attorney's fees and costs of suit, and any other costs pursuant to the Complaint.
In addition, a Notice of Praecipe to Enter Judgment by Default was duly mailed to the Defendant Jeffrey
E. Arnold, Sr., on October 23, 2002, pursuant to Pennsylvania Rule of Civil Procedure 237.1. A copy of said
Notice is attached to this Praecipe.
Dated: Respectfully submitted,
BARLEY, SNYDER, SENFT & COHEN, LLC
By:4IL
William I Colby, Jr , sq ire
-
Attorney for Plaintiff-
P.O. Box 942, 501 Washington Street
Reading, PA 19603-0942
(610) 376.6651; I.D. No. 46880
ALLFIRST BANK, successor by merger : IN THE COURT OF COMMON PLEAS
to DAUPHIN DEPOSIT BANK AND : OF CUMBERLAND COUNTY, PA
TRUST COMPANY CIVIL ACTION - LAW
P.O. Box 17292, Department 501-340
Baltimore, MD 21203,
Plaintiff No. 99-6410 Civil
VS.
JEFFREY E. ARNOLD, SR.
7 Columbia Avenue
Camp Hill, PA 17011,
Defendant Assigned to:
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
DATE OF NOTICE: OCTOBER 23, 2002
TO: JEFFREY E. ARNOLD, SR. 7160 3901 9844 7790 2061
18 WAYNE ROAD
CAMP HILL, PA 17011 SENDERS RECORD
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF
YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE NO. (717) 249-3166
Respectfully submitted,
BARLEY, SNYDER, SENFT & COHEN, LLC
By:
Willis F. I y,1r., Esq iqwf
Attorney fo PI in tiff
P.O. Box 942, 501 Washing on Street
Reading, PA 19603-0942
(610) 376-6651
I.D. No. 46880
BE
BARLEY SNYDER
S01 RS.htnfeq, SUeo
CO. %1' 942
ReeJmf. PenmitvanI4 19603.0912
JEFFREY E. ARNOLD, SR.
18 WAYNE ROAD
CAMP HILL, PA 17011
PS Form 3817, Mar. 1989
716e0 3901 9844 7790 2061
TO: JEF?REY E. ARNOLD, SR.
18 WAYNE ROAD
CAMP HILL, PA 17011
SENDER: (Is
REFERENCE: alllirst/amold
RETURN
RECEIPT
SERVICE
Total Postage a
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ALLFIRST BANK, successor by merger
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. 99-6410 Civil
: Assigned to:
CERTIFICATE OF SERVICE
WILLIAM F. COLBY, JR., ESQUIRE, verifies that a true and correct copy of
Notice of Pmecipc to Enter Judgment by Default has been mailed to Defendant Jeffrey E.
Arnold, Sr. on October 23, 2002, to 18 Wayne Road, Camp Hill, PA 17011, by first class mail,
postage prepaid and first-class, certified mail. He understands that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to
authorities.
Date:
BARLEY, SNYDER, SENFT 8t COHEN, LLC
Attorney fod Plate
501 Washington St., P.O. Box 942
Reading, PA 19603-0942
610-376-6651
I.D. No. 46880
1122230-1
ALLFIRST BANK, successor by merger
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
P.O. Box 17292, Department 501-340
Baltimore, MD 21203,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.
7 Columbia Avenue
Camp Hill, PA 17011,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. 99-6410 Civil
: Assigned to:
NOTICE OF RRARCIP TO ENTER JUDGMENT BY DEFAULT
DATE OF NOTICE: OCTOBER 23, 2002
TO: JEFFREY E. ARNOLD, SR. 7160 3401 9844 7790 2067
18 WAYNE ROAD
CAMP HILL, PA 17011 wommmmam
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF
YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT I IAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE NO. (717) 249-3166
Respectfully submitted,
BARLEY, SNYDER, SENFT & COHEN, LLC
WillWn F. C;61gy, Jr:, Esq?irE/
Attomey foe Plaintiff \?
P.O. Box 942, 501 Washing on Street
Reading, PA 19603.0942
(610)376.6651
I.D. No. 46880
BARLEY SNYDER
501 Wa,hingnm s, e ,
110. Min 942
Readmit, Penn,ylvanta 19601-91=
JEFFREY E. ARNOLD, SR.
18 WAYNE ROAD
CAMP HILL, PA 17011
PS Form 3917, Mu. 1999
7360 3901 9644 7790 2061
TO: 10FREY E. ARNOLD, SR.
I8 WAYNE ROAD
CAMP HILL, PA 17011
SENDER: 113
REFERENCE: allfirst/arnold
RETURN Poste
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ALLFIRST BANK, successor by merger : IN THE COURT OF COMMON PLEAS
to DAUPHIN DEPOSIT BANK AND : OF CUMBERLAND COUNTY, PA
TRUST COMPANY, CIVIL ACTION - LAW
Plaintiff No. 99.6410 Civil
VS.
JEFFREY E. ARNOLD, SR.,
Defendant Assigned to:
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BERKS
ss
Before me, the undersigned authority, personally appeared WILLIAM F. COLBY, JR.,
ESQUIRE, who being duly swom according to law, doth depose and say that Jeffrey E. Arnold,
Sr., the Defendant, is not in the Military or Naval Service based on the following facts:
Age of Defendant:
Unknown
Last known place of employm.:nt:
Last known place of residence:
as of the date of this Affidavit.
SWORN TO and sub cribed before me
this day of 4ZQA---*. , 2002.
J
Notary Pub
NOTAAIAL SEAL
MARY C. KURtZ, Notary Public
Reao ^g, Bel KS County, PA
My Cr,-rir-ss'a. ix0tes 7.14.2003
Unknown
18 Wayne Road, Camp Hill, PA
1122250.1
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COURT OF COMMON PLEAS OF BERKS COUNTY
Reading, Pennsylvania
Curt Long, Prothonotary
TO: Jeffrey E. Arnold, Sr.
18 Wayne Road
Camp Hill, PA 17011
Date:
Rc: Allfirst Bank,
VS.
Jeffrey E. Arnold, Sr.,
No. 1999.6410
Plaintiff
Defendant
You are hereby notified in accordance with Pennsylvania Supreme Court Rule #236 that
Judgment has been entered on a
O Decree Nisi
() Verdict *
() Viewers Report
( x) Default
() Assessment of Damagcs
O Arbitration Award
() Order
and entered to No. 1999 against Jeffrey E. Arnold, Sr., Defendant.
**And that a Certificate has been filed indicating that each of the parties have been
notified of the intention to file said judgment by the Attorney for the Plaintiff.
Curt Long, Prothonotary
eputy rot ionotary
1122250.1
LAw OFFICES
BARLEY, SNYDER, SENFT SL COHEN, LLC
sot Wa ama= 8rt<tat; Sm F=R- P.o. Box "I-ReADM PiNN3YLVAMA M01-013
ALLFIRST BANK, successor to
DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
P.O. Box 17292, Department 501-340
Baltimore, MD 21203,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.
7 Columbia Avenue
Camp Hill, PA 17011,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. CO- Lu1d
Assigned to:
NOTICE
n '
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 arc 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE. NO. (717) 249-3166
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ALLFIRST BANK, successor by merger
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
P.O. Box 17292, Department 501-340
Baltimore, MD 21203,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.
7 Columbia Avenue
Camp Hill, PA 17011,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. 7Zo. 9 9. L ym Cep /, 4w_
Assigned to:
COMPLAINT
Allfirst Bank, successor by merger to Dauphin Deposit Bank and Trust Company,
is a Maryland State chartered commercial bank, with a mailing address of P.O. 17292,
Department 501-340, Baltimore, MD 21203 ("Plaintiff7.
2. Jeffrey E. Arnold, Sr., is an adult individual who resides at 7 Columbia Avenue,
Camp Hill, PA 17011 ("Defendant").
3. Plaintiff made available to Defendant and Alyce A. Arnold, also known as Alice
A. Arnold ("Alyce") various credit facilities (collectively the "Loans").
4. The Loans are as follows:
(a) Loan Number 113973898002 dated April 17, 1996 in the original amount
of Twenty-Two Thousand Five Hundred Fifty-Six Dollars and Eleven Cents ($22,556.11)
("Loan 1"); and
(b) Loan Number 100250628001 dated June 24, 1997 in the original amount
of Ten Thousand Seven Hundred Ten Dollars ($10,710.00) (Loan "2").
i o. i e.99nvrCr843005 .1
5. Despite specific repayment terms set forth in the Loan Documentation evidencing
Loan 1 and Loan 2, Defendant has failed to pay to Plaintiff the amounts required to be paid to
Plaintiff pursuant to the terms and provisions contained in the Loan Documentation evidencing
Loan 1 and Loan 2.
6. As a result of Defendant's failure to pay required amounts due on Loan 1 and
Loan 2, Plaintiff has filed this Complaint to assure the repayment of Loan 1 and Loan 2.
COUNT I-LOAN I
On April 17, 1996, Plaintiff made available to Defendant and Alyce the amount of
Twenty-Two Thousand Five Hundred Fitly-Six Dollars and Eleven Cents ($22,556.11) ("Loan
1").
8. Loan 1 is evidenced by a Note and Security Agreement dated April 17, 1996 in
the principal amount of Twenty-Two Thousand Five Hundred Fifty-Six Dollars and Eleven
Cents ($22,556.11) ("Loan I Note"). A copy of the Loan 1 Note is attached as Exhibit "A".
9. The terms and provisions of the Loan 1 Note provide that Defendant pay to
Plaintiff the amount of Two Hundred Ninety-Six Dollars and Three Cents ($296.03) per month
beginning June 5, 1996 for a period of one hundred twenty (120) months.
10. Defendant failed to pay to Bank the required monthly payments pursuant to the
Loan 1 Note from March 5, 1998 until the date of this Complaint.
11. The Loan 1 Note provides that if Defendant fails to make any payment due
Plaintiff on or before the date it comes due, such failure constitutes a default under the terms and
provisions of the Loan 1 Note..
12. As a result of Defendant's failure to pay to Plaintiff required monthly payments
on the Loan 1 Note, Defendant is in default on Loan 1.
•2-
10.18.99/' I'C/847003.1
13. The following amounts are due and owing by Defendant to Plaintiff on Loan 1:
Principal $20,244.11
Interest through October 6, 1999 1,2764.90
Attorneys' fees equivalent to 15% of
the amount due 3.227.85
Total $24.746.86
14. Despite repeated demands, Defendant has failed to pay Plaintiff the amount of
Twenty-Four Thousand Seven Hundred Forty-Six Dollars and Eighty-Six Cents ($24,746.86)
due on Loan 1.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
Twenty-Four Thousand Seven Hundred Forty-Six Dollars and Eighty-Six Cents ($24,746.86) on
Count I of this Complaint, plus interest fees and other charges imposed by this Court.
COUNT II - LOAN 2
15. On June 24, 1997, Plaintiff made available to Defendant and Alyce the amount of
Ten Thousand Seven Hundred Ten Dollars ($10,710.00) ("Loan 2').
16. Loan 2 is evidenced by a Note and Security Agreement dated June 24, 1997 in the
principal amount of Ten Thousand Seven Hundred Ten Dollars ($10,710.00) ("Loan 2 Note").
A copy of the Loan 2 Note is attached as Exhibit "B".
17. The terms and provisions of the Loan 2 Note provide that Defendant pay to
Plaintiff the amount of Two Hundred Forty-Five Dollars and Thrifty Cents ($245.30) per month
beginning June 5, 1996 for a period of sixty (60) months.
18. Defendant failed to pay to Bank the required monthly payments pursuant to the
Loan 2 Note from March 10, 1998 until the date of this Complaint.
•3-
10. i e.wnvrC/sa 3oos.1
19. The Loan 2 Note provides that if Defendant fails to make any payment due
Plaintiff on or before the date it comes due, such failure constitutes a default under the terms and
provisions of the Loan 2 Note..
20. As a result of Defendant's failure to pay to Plaintiff required monthly payments
on the Loan 2 Note, Defendant is in default on Loan 1.
21. The following amounts are due and owing by Defendant to Plaintiff on Loan 2:
Principal $9,338.79
Interest through October 18, 1999 508.30
Attorneys' fees equivalent to 15% of
the amount due 1.477.06
Total 11 24.
22. Despite repeated demands, Defendant has failed to pay Plaintiff the amount of
Eleven Thousand Three Hundred Twenty-Four and Fifteen Cents ($11,324.15) due on Loan 2.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of Eleven
Thousand Three Hundred Twenty-Four and Fifteen Cents ($11,324.15) on Count lI of this
Complaint, plus interest fees and other charges imposed by this Court.
Respectfully submitted,
BARLEY, SNYDER, WNFT & COHEN, LLC
Attocy for Plaintiff
P.O.-Box 942, 501 Washi
Reading, PA 19603-0942
(610)376.6651
I.D. No. 46880
A-
10.19.99/wrc/8J 3003.1
VERIFICATION
TAMMY A. REITER verifies that she is Vice President of ALLFIRST BANK,
successor by merger to BANK OF PENNSYLVANIA, DIVISION OF DAUPHIN DEPOSIT
BANK AND TRUST COMPANY, Plaintiff in the within matter, that she is authorized to
execute this Verification on its behalf, and that the facts set forth in the within Complaint are true
and correct to the best of her knowledge, information and belief. She understands that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: 1999
Tammy Ocher! Vice President
•5-
10.1 E.99/WFC1647005.1
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EXHIBIT B
Name or Borrower(s) ORIGINAL VAN
IAN 00
UEffR[Tf ARNOlO Y[CIUNICSBURG FA
AlR[AARNOLO ty tale -rp Code
NOTE AND SECURITY AGREEMENT, Dated AINf 24 19 97 Branch Cerro Hill Office
ANCE
RGE Amount Financed
Th
nl
f
dif
id
d Total of Payments
T
eama
o
en
prov
e
to hewwwtyouwighavepailalteryou
E oNr~Ithe
it will call you.
M you or onyaubehalf. have rude all scheduledpsymente.
9,822.90 S 10,795.10 S 14,719.00
Yea Payment Schedule will be:
Security: You art giving asecurity lnues
Cl IM goods or property being purchased.
M (brief deccriplion of other property) _
Fees S MORTGAGE RECORDING FE
assurne
on
Late Charge: If a payment is late, you wil be charged 5% of the payment not to esceed 115 00.
Prepayment: II you pay off early, you wig not have to pay a penalty.
See your entire Note and Security Agreement la ant additional intormafion about nonpayment, default, any required rep+yment in fug
before the achaduMd dale and preprymenl refunds and penalties. a means estimate
you
Amount paid tooth on your behalf
to public 0flidah
11Io Insurance tqroan y emey ppyy
retailing A Fen of IHs sansei)
S 7e[ In
113 10 MEMBERS IST ate' a'
to NoRWIs(
$ 258.84
to AAFfS
a Ann nn
$
The Amoral Percentage Rate, Amount Financed and Payment Schedule shown above are pall of this Note and
Security Agreement (which is called file 'Note'), You are the penon (or Persons) who signs below as 'Borrower'
or 'Co-Signer.' If mute than one person signs below, each will be liable, separately and together, for all promises
in this Note.
You FROMISIi DAUPHIN DEPOSIT BANK AND TRUST COMPANY
TO PAY TO US: 9607 Oerry Street flatrisbusg, PA 17111
or to our order, at any of our offices, the Amount Financed, plus interest as provided below, in the number of equal
monthly payments shown in the Payment Schedule. Payments are due beginning on the date indicated in the
Payment Schedule slid on the same day of each following month until we are paid in full. You may pay in advance
All or part of the balance due at any time without penalty or premium.
IQ NORWEST
S t tot nn
to
S
to
3
IQ
S
SECURITY AGREEAENT,• As security for the prompt payment of the IIOIV INTEREST 1S CIURGED: The Finance Charge consists only of
suns you owe and she proper performance of your promises in this Note,
'
' interest imposed daily on the ousstandinT balance of the Amount Financed
you slid all the
Co-Owners
signing below grant us: at the Annual Percentage Rase. The Finance Charge shown above was
(i) a security interest in tire following personal property, and its figured by assuming that all payments were received on their due dates. If
equipment and accessories: any payment is lase, you muss pay mnre Finance Charge than Is shown
I, because of she additional interest imposed. If you pay early, the Finance
Charge will be less. The amount or the increase or decrease In Finance
Cha,gc will be due Willi she lass payuleuf, which will be modified to reflect
2, she actual amount then due.
SET-OFF: The law gives us a right of set-off in any of your property in our
9. possession at any time. includingg deposit accounts. This neans that, if you
default, we may exercise our rigln of set-off and apply any of your property
Our security interest includes parts, called 'accessions,' added to the in our possession, including deposit accounts, to the sums )0u owe on this
personal property at any later tittle. Nose. ...
(ii) a Mortgage on 4823BRIAN00 FLOOD INMIRANCE: If this Noe is secured by improved real estate or a
mobile home, which is Imated in a flood tune, flood insurance is required
MECNANICSBURG FA 11055 For de full term of this Note.
All dic property which secures this Nine is called she 'Collateral.' Our
rights and your respottsibilisies regarding an? personal properly Cldlalcral PRUI'HRIT INSIIRANCh: If Ibis Note is sccuied by Collateral which i\
i
are provided in this Security Agreement, vs lick continues nil file reverse not
n Our piosessioll, instoince against physical daiuage III dlc Collateral is
rC uired lilt the full term of iltis Now
q
r
side. Our rights in any real property Collateral are contained in the
reo
perat
hlurt6'age. As your expense,
you
ce
will
e slid nd join with us in si i .
c
INSURANCE AND PROPERTY INSURANCE MAY RF
OBTAINED TIIROUGII ANY AGHNT
BROKER OR O'fIIER PERSON
ton
m
d in talo
any
,which we
et
Jecm
6•
and liking documents sn
n
,
01; YOUR CIIOICE
S
I
i
S
i
2
4
r
fcclion of, and satisfy our security
necessary to ppeerfect, maintain per .
nsurance
on
ee
n
ect
.
o
the security
interest in the Collateral. Agreement on she reverse side.
AUTOAIATIC PAVURNTS: ® If checked, you request that all monthly fla)mcuts due, including laic payment and returned item charges, otl this Nntc
be charged so and paid from your Account NO. 5700151111 . You auihuiile us to alnnmatically pay each monthly payment when due front that
Account beginning R 10 97 and continue until all sum% owed ,it Ibis Note have been paid in full.
CREDIT INSURANCE IS NOT REOUIRED: Subject to acceptance by t he insurer trained below, credit insurance is available through us for the tern!
Of this Now at rise costs shown below. Single Credit Life and Single Credit Accident & Iicaltl hourance are available to any title Borrower or Co-signer
signing below for insurance. Joint Credit Life and Joint Credit Accident and Wilds Insurance are available Ili any Iw'o (if you signing for such Insurance
below. NO credit insurance will be provided unless the appropriate siafeme mfv) is signed by hire Iligerfs) rat he insured and the cosis shown below are
included in the Amount Financed. (See file NOTICB 01: PROPOSED CRL•DI f INSURANCE on she re\crse side).
By signing, you want Single Credit Life Insurance, which
costs f
What is
Signature of Buyer to be insured for Single your age?
Credit Life Insurance. -Years
& Ileallh
What is
your age'.'
-Years
Wbal are ay signing, you Win wails !!lint LNdll ACC1,1011 W'haf are Itrcensape to
)our agci! & I1eallli limirdllce w Ilith cuNs $ your ages! be insured
z. %
Signature I of Buyers to c insured or Signature of boils flu)cis m be insured for Joint
luml Cred1 JtJfe Insurance. Credit Accident & Ilcahh Iowr.uue.
Instucr: US LIFE CRI:DI'f LIPG Insurance Company, Schamnlmig. 111. 60177
IIY SIGNING BELOW. YOU INTEND 'To III: LLG /LY BOUND ItV At.[. 01:1 MCI ENNIS 01. 1111% Not li
Il AI ti0 A('KN LEDGE RECEIV NO A CO,1 'f II:D COVY Ol:'I111S NUTI:.
(SPAI.)
tlne\s tit •niluf LIAlMa (SUAL)
Ililess IIIII S , g J rC
(SIiA1.)
ninllc\w s 11111uw Cris .IgllJhilC _-_-_--
IS1:A1•)
Ifllcs\ IJ i l it w c r's. l g nal 11 re
4\\111\\I\IIY IbM\I 1'4%01\11111 Pl 1ll.ly NOIICF:SEE trYI'.I?SF SI DF FOR I SIPOI1 I AN I' I N1 I I(SI4I ION. Vlvq e\\limst o1a\Ia\r11. IM
ADDITIONAL. TERMS
ULT,- The following are each 'Defaults': periodic statements issued, therefore. no receipt will be Issued nor mailed
m fail to nuke any payment w us on or before the day it comes at the time these transfers/payments occur. Transfers scheduled fur dates
or
any outer note or agreement yyou not
(v You cannot pay any of your debts as
l The COllaenl is any shilen, da
rrt The Collateral is sold, transferrIAT
wome or to pan, to a person who is not a patty to the Security
Agreement or Mortgage;
;still proceedings are begun under the Bankruptcy Code by or against you;
(Ix Any judgment Is entered of record against you• or
U Any of your property is attached or its to WAS foifeited.
DEFAULT AND REQUIRED PAYMENT IN FULL: If any Default
occurs. we muse. if we choose. 'accelerate' the maturity of Itch Nole.
we
our Intention to take action if you do not b
provided In our notice. If we file an action to
that are non-business days for us will be processed on the business day
signatures if any lime; following the requested date. This authorization will be effective until we
rte any of your promises Or receive written notice of rerminatbn or change in the terms of the transfer
eennem, the Morgage, or in from you. We may terminate this agreement with thirty days written notice.
ater have with us; The service will be discontinued after a second overdraft violation occurs.
come due; MULTIPLE PARTIES: If there is more than one Borrower on this Note,
dem ..yed; or one car more Co•Siphers, all of your obligations also he prhnary. reach
led, gfveto or delivered, in will be liable, separately and together, for all promises In this Note.
to
you a ree we may continue, to impose interest daily on all sums owed In
us at Ilse rate provided in this Note until we receive payment in full, even
if we have obtained judgment against you.
LATE CHARGE: If any payment Is not made within 10 Jays of its due
date, we will char ge and you agree lea pay a late ppayment charge of S% of
the amount of the late payment not to exceed SIM.
RETURNED ITEM CHARGE: if any payment for any amounts owed
under this Note is returned, you will be charged, and you agree to pay,
SI0.00 for each returned item. This charge is in addition to any late
PPJ ment ebarpe you mayy Incur.
N
PUENT OF FEES TO PUBLIC OFFICIALS: You agree in pay any
and all fees for the perfecllsn, continuation and satisfaction of our
security interest in either personal or real property.
AUTHORIZATION FOR AUTOAIATIC TRANSFER. You agree to abide
by our rules concerning automatic transfers. This service is subject to all
future stale and federal regulatory changes in addition to changes in our
Rules. Regulations and Fees. The transaction will be itemized on the
WAIVERS: If we declare the unpaid balance of the Note and earned
Interest to be immediately due and payable, you waive your rights to
require us to do certain things. Those things are;
(i) to demand payment of amounts due (known as 'presentment');
(n) to give notice that amounts due have not been paid (known as 'notice
of dishonor'); and
(Ili) to obtain an official certification of nonpayment (known as 'protest*).
NO NOTICE OR LOSS OF RIGHTS: We can do any or the following
without telling you or losing any rights against you or the Collateral:
(i)accept a check or other order marked ' sld In full' or with similar
langus a as a partial payment under this Note;
(ii) give a5ditlonal time fur payment of any amount owing under this
dote;
(iii)exercise, give up or delay exercising any right against any person or
pro fly:
((v) add or release any person or property obligated under this Note;
(v) car fail to protector enforce our interest in any of the Collateral;
RISK OF LOSS: You will remain bound by ibis Note even if the Collateral
Is lost, stolen, damaged or destroyed.
BENEFIT AND BURDEN: All of the benefits of this Note shall favor us.
our successors and assigns. The obligations shall bind you, and your
heirs, personal representatives and assigns.
NOTICES. Unless otherwise required by law, cacti demand or notice
under this Note shall be delivered or sent by regular mail, addressed to the
party at Its address provided in this Note. Either party may change its
address by giving such a notice to the other party. Reasonable notice, when
notice is required, shall be deemed to be 10 days.
LAIV. This Note will be governed by the laws of the Commonwealth of
Pennsylvania, and any applicable federal laws.
SECURITY AGREI*hIENT
SECTION I. LOAN AND COLLATERAL. When you sign Ilhis Note and Interest it prov
deliver It to us, and complete the other required details, we will make a maintain insurai
loan to you. This Security Areement Wiles only to the chdlaieral as necessary us keh
descrilsesl on the front side of t tis Note. As used in the following section we alone chum
of this Seeuri% AfiredneOt, 'you' also includes say Co-Owner of the replacement insh
collateral. cover loss or di
SECTION 2. FOUR OTIIER AGREEMENTS. 2.1 OB'N, SELL, ETC. greater ilia" wit:
You own the Collateral free and clear of all liens and security interests. behalf will he at
You will not sell, Iransfer, lease, give, deliver car otherwise dispose OI the at the Animal I
Collateral. In whole or in pan, to any person win is not a party to this immediately on
ht this Note. If you
fit effect, or to pa
e Collateral in grid f
dvance any sums yt
tin I
)owe
to the
to honor your promises to
g fees, loxes or the costs
soon and repair, we nary, if
umised fan pay and obtain
rent insurance we obtain to
Illateral may he limited to an amount not
is Note. Any Amount we advance an your
nce on which we impose Finance Charges
of this Now, still army he repayable: (f)
rag with your monthly payments; or (iii)) of
may specify. Our payments on your behalf
perform your promises in this Security
Security Agreement. You will not permit any lien or security interest to be the end of the Note, as we along
obtained on the Collateral other than ours. will not cure your failure to
----------
M your cost,
repair. You will
will
e it
on
..a e/nr-vise ^x. vvnen, IT me uemateral consists or a deposit account
or certificate of deposit, we may refuse to allow you to close the account
or withdraw any sums from it. If the account or certificate of deposit
matures while the Note remains unpaid, we will automatically renew the
of isit for the same time period, as provided in the deposit agreement,
unless oat ant we agree that the deposit should be renewed on Other
terms. rite renewed certificate or account shall be Collateral subiect to
4.4 INSURANCE. While ally sums are owed on this Note, you will carry
insurance on any Collateral whicli is not fn our possession against fire,
theft and other casualty. The policy must contain a deductible clause and
he in An amount and with an insurer that ate satisfamory to us. The policy
must name us as the 9oss•payee.' The policy must provide that any loss
is to be payable to you and to us as our interests Appear. It must also
provide that we be given not less than 10 Jays prior wruen notice of any
cancellation or reduction in coverage for any reason. On request, you
shall deliver Ibe policies, certilicntes or other evidence tof insurance to tm
In the event of any Inns or damage lea the Collateral, you will immediately
notifyy its in writing and File a pouf Is loss with the insurer. We may file A
PT12 of loss can your Ischall d' you fail ur « fuse its do stn. We may Ids[)
sign your nano to any check, draft or other older for the payment of
insurance ppmcetds in the event of loss or damage to tIc Collateral. If it is
monunrically feasible. Ili our judgment, we will apply the insurance
rsNG OUR 51XURITY INTEREST. If a certificate tof title is
v the Collateral you will assist us in having tout security interest
the certificate of title.
rR AUTIIORin' TO US. If you fail fan do what is required of you
ions 2.2, 2.4 and 23, we may, if we choose, perform your
its and pay such costs and expenses. We will add the amounts we
m the sums the Borrower owes on this Note, on which we impose
You will permit us to inspect the Collateral at any
LOSS OF RIGHTS. The Note and this Security
e negotiated, assigned, extended or renewed by us
ty of you or the Collateral. We may add or release any
obligated under the Note and this Security Agreement
MM1.5 in the Collateral.
LT. A default under the Note will be a Defaull under
meat. In addition to all the rights and remedies of A
default which are provided under the Uniform
we declare the Note to be immediately due and payable
conditions:
1 OF DEPOSITS. We may apply any deposits included
lainst the sums the Borrower owes on this Note. If the
or
to
m us, we
Ire contract of ucppsnn or applcame law may require
atrial enahies fur Iloe early withdrawal.
F COLLATERAL. We may require you to surrender
I a icasunablcnnvcnicnl prate we designate.
'OSSE.SS10k. If you du nil surrender the Collateral
p(Nsnsession or it, with or without legal process, In
You anchorite us w peaceably enter on say menu es
may be located for lite purpose of taking possession
4.4 EXPENSES OF REPOSSF.S.SION AND STORAGE. We may charge
you our Rasonable expenses in repossessing, transporting repairing,
storing and selling the Collateral so long as they ore allowed by law.
4.5 YAL OF COLLATERAL. We may sell, assign or deliver lite
Collateral at one or more public or private sales. We will give )ou
reasonable notice of file time and place of sale. We may purchase the
Collateral at that sale, free of any equitable or legal right or claim you may
have in the Collateral. We will apply the proceeds of sale first to our
expenses and then to the sums you owe on this Note. We will pay any
surplus to you. If a sum is still owed to us, you and Co-Signer must pay it
to us.
The Signer(s) of this Note hereby take(s) notice that Group Credit Life Insurance coverage and/or Group Credit Accident and Health Insurance
coverage, will be applicable to lids Note if sat marked on the hunt of this Note, and cacti such type of coverage will be written by the insurance
company named. This insurance, subject to acceptance by to insurer, covers only the person(s) signing the request for such Insurance. The amount o
charge is indicated for each type of credit insurance lea be purchased. The term of the insurance will commence as of the date the indebtedness is
incurred or on the date from which the interest or Finance Charges accrue, if later, and will expire can lire original scheduled maturity dare of the
indebtedness. Subject to acceptance by the insurer and within 30 days, there will be delivered to the insured debtor(s) a certificate of insurance more
fully describing the insurance. In the event of prepayment of the indebtedness, a refund of insurance charges will be made when due.
NOTICE--ANY HOLDER OF TIIIS CONSUMER CREDIT CONTRACT IS SUIUF.CT TO ALL CLAIMS AND DEFENSES
WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT
HERETO Olt SVITII TIIE PROCEEDS HEREOF, RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
AMOUNTS PAID BY THE DEBTOR IIERCUNDER.•
•Does not apply If purchused for commerclal or agricultural use. If Ihls Ivan Is applied In whole or substantial purl to a purchase of goods or
service front a seller Alto Is Affiliated %%flh Bank by coalition control or limitless arrangement, than I Base the rights set forth under "notice"
shown above.
11ANCONSUMtR FORM FASH HC )11. Is%) NOTICE: SEE. FRONT SIDE. FOR IMPORTANT INFORAIAI ION
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06410 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST BANK
VS
ARNOLD JEFFREY E SR
f.
VALERIE WEARY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ARNOLD JEFFREY E SR the
DEFENDANT , at 2020:00 HOURS, on the 2nd day of October , 2002
at 18 WAYNE ROAD
CAMP HILL, PA 17011 by handing to
JEFFREY E ARNOLD SR
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: So Answers:
Docketing 18.00
Service 9.66 i?yrr+?f
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
37.66 10/04/2002
BARLEY SNYDER
Sworn and Subscribed to before By:
me this P a day of Deputy Sheriff
mrG? Juu.L A.D.
"Prothonotar
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06410 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALLFIRST BANK
VS.
ARNOLD JEFFREY E SR
HAROLD WEARY
Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT was served
upon ARNOLD JEFFREY E SR the
defendant, at 14:39 HOURS, on the 29th day of October ,
1999 at 7 COLUMBIA DRIVE
CAMP HILL PA 17011 ,CUMBERLAND ,
County, Pennsylvania, by handing to NANCY BIENHOWER (MOTHER)
a true and attested copy of the COMPLAINT ,
together with NOTICE ,
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 9.30--+/qF7?'-?
Affidavit .00
Surcharge 8.00 Kline, R. Inomas
SherIff
$35-30-B1?01/ SNYDER, SENFT & COHEN
by
U0puuy S
Sworn and subscribed to before me
this q 4-' day of
19_? A.D.
- 011."PPSCTfd7 dLyf
ALLFIRST BANK, successor
DAUPHIN DEPOSIT BANK AND
TRUST COMPANY,
Plaintiff
V.
JEFFREY E. ARNOLD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 99-6410 CIVIL TERM
AND NOW, this 22nd day of October, 2002, it
appearing that docket activity has occurred recently in the
above-captioned case, the case is stricken from the purge
list, and shall remain active.
/ William F. Colby, Jr., Esquire
For the Plaintiff
Jeffrey E. Arnold, Sr.
18 Wayne Road
Camp Hill, PA 17011
Defendant
Court Administrator
wcy
' l R?S
_ I ./$-aa
J
By the Court,
ALLFIRST BANK,
Successor to DAUPHIN
DEPOSIT BANK AND
TRUST COMPANY,
Plaintiff
V.
JEFFREY E. ARNOLD,
SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.99-6410 CIVIL TERM
ORDER OF COURT
AND NOW, this 22"' day of January, 2003, upon relation of the Cumberland
County Prothonotary that the above-captioned case was erroneously placed on the 2002
purge list, when in fact the complaint had been reinstated, the case is stricken from the
2002 purge list.
BY THE COURT,
William F. Colby, Jr., Esq.
P.O. Box 942
501 Washington Street
Reading, PA 19603-0942
Attorney for Plaintiff
Jeffrey E. Arnold, Sr.
18 Wayne Road
CampHill, PA 17011
Defendant, Pro Se
-23.03
C?_-
Me
Or '; , ?, ;:?T1RY
03 ,J!?123 A f ll: n?
cutlf?bibl%j cowry
PENN,s1tvA A
WRIT OF EXECU'T'ION and/or A7-1'ACHNIENT
COMMONWEALTII OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 99-6410 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ALLFIRST BANK, SUCCESSOR BY MERGER TO
DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Plaintiff (s)
From JEFFREY E. ARNOLD, SR., 18 WAYNE ROAD, CAMP HILL, PA
(1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PERSONAL PROPERTY INCLUDING BUT NOT LIMITED TO THE HOUSEHOLD
CONTENTS OF 18 WAYNE ROAD, CAMP HILL, PA AND ANY VEHICLES LOCATED ON
THE PREMISES.
(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 gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 $36,071.01 L.L. S.50
Interest 51,783.20 + 12.74%/ MO. FROIft 10/7/99
Ally's Comm % Due Prothy SI.00
Atty Paid S151.46 Other Costs
Plaintiff Paid
Date: JANUARY 8, 2003
CURTIS R. LONG
Prothonotaly;
(Seal) -I;L?2 ma?
Deputy
REQUESTING PARTY:
Name WILLIAM F. COLBY, JR., ESQUIRE
Address: P.O.BOX 942
501 WASHINGTON STREET
READING. PA 19603-0942
Attorney for: PLAINTIFF
Telephone: 610-376-6651
Supreme Court ID No. 46880
R. Thomas Kline, Sheriff, who being duly swom according to law, states
this writ is returned STAYED AS PER ATTY.
Sheriff's Costs: Advance Costs: 150.00
Sheriffs Costs: 71.25
Docketing 18.00 S 78.75
Poundage 1.40
Advertising
Law Library .50
Prothonotary 1.00 Refunded to Atty on 06/06/03
Mileage 10.35
Misc
Surcharge 20.00
Levy 20.00
Post Pone Sale
Garnishee
TOTAL S 71.25
Swam and Subscribed to before me So Answers-
ThisZdayof
? mas Kline, heS ritt?
2003 A.D. ?
rohonotary By laudA. B"rcw ak6 er Lj/j
"ter
ri C
c
s
b
ALLFIRST BANK, successor by merger
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
P.O. Box 17292, Department 501-340
Baltimore. MD 21203,
Plaintiff
VS.
JEFFREY E. ARNOLD, SR.
7 Columbia Avenue
Camp Hill, PA 17011,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
No. 99-6410 Civil
: Assigned to:
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint filed in the above-captioned matter.
Dated: 44X
BARLEY, SNYDER, SENFT & COHEN, LLC
By:?
William . Colby, r. s uire
Attorney for Plaintiff
P.O. Box 942, 501 Washington Street
Reading, PA 19603.0942
(610)376.6651
I.D. No. 46880
1111933.1
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C%j
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tt.
a
LAj
u
?O O U
A
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW AND EQUITY
ALLFIRST BANK, successor by merger ( ) Confessed Judgment
to DAUPHIN DEPOSIT BANK AND
TRUST COMPANY : (X) Other - Default
Plaintiff
No. 99-6410 Civil
Vs. Amount Due: $36,071.01
Interest: $1,783.20+
JEFFREY E. ARNOLD, SR. : Atty Fees: 54,704.91
Defendant : Costs: S
12.74°/dmo. from IOnr99
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
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:
PRA CIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of 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 in the possession, custody or control of the said gamishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
Defendant(s) described in the attached exhibit.
BARLEY, SNYDER, SEND & COHEN, LLC
Date: --dt. 0.3
% iHfam` IF y, sq
Attorney for anti
P.O. Box 94 , 501 Was t
Reading, PA 19603-0942
(610) 376-6651
I.D. No. 46880
Street
h
CJ
W
C
r
Notes: If real property, supply six copies of description including improvements and an
original and copy of affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 99.6410 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ALLFIRST BANK, SUCCESSOR BY MERGER TO
DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Plaintiff (s)
From JEFFREY E. ARNOLD, SR., 18 WAYNE ROAD, CAMP HILL, PA
(1) You arc directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PERSONAL PROPERTY INCLUDING BUT NOT LIMITED TO THE HOUSEHOLD
CONTENTS OF 18 WAYNE ROAD. CAMP HILL, PA AND ANY VEHICLES LOCATED ON
THE PREMISES.
(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 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) ana 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 hintlhcr that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $36,071.01 L.L. 5.50
Interest $1,783.20 + 12.74%/ MO. FROM 10/7/99
Arty's Comm % Due Prothy $1.00
Atty Paid $151.46 Other Costs
Plaintiff Paid
Date: JANUARY 8, 2003
CURTIS R. LONG
Prothonotary
C.??
(Scat) ?By:t? / //?i2iti
Deputy
REQUESTING PARTY:
Name WILLIA.N1 F. COLBY, JR., ESQUIRE
Address: P.O.BOX 942
501 WASHINGTON STREET
READING, PA 19603-0942
Attorney for: PLAINTIFF
Telephone: 610-376-6651
Supreme Court ID No. 46880