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Home My WebLink About07-2866IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07- a8(o(o Civil Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served by entering a written appearance personally or by 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 any further notice for any money or relief requested by the Defendant. 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 OUR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania Phone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania Phone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. Plaintiff, V. CIVIL ACTION-LAW JEANNIE MOHMAND . Defendant. COMPLAINT N6 AND NOW, TO WIT, this day of May, 2007 comes the Plaintiff, Acco York Federal Credit Union, by its attorneys, Kagen, MacDonald & France, P.C., and more specifically Edward A. Paskey, Esquire and files the within Complaint as follows: 1. The Plaintiff, Acco York Federal Credit Union, is a Pennsylvania lending corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having an office at 1529 Rodney Road, York, York County, Pennsylvania 17404. 2. Defendant is Jeannie Mohmand, an adult individual, who resides at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055. 3. At all relevant times, the Defendant has been the real owner of a tract or parcel of land, with buildings and other improvements thereon, located at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055 (the "Premises"). The Premises are more specifically described hereinafter. A copy of the deed is attached hereto as Exhibit "A" and incorporated herein by reference. 4. On or about July 13, 2005, in consideration of a loan of $25,000.00, made by Plaintiff to Defendant, which funds were received by Defendant, the Defendant, as Promisors, executed and delivered to the Plaintiff, as Promisee, a mortgage note dated July 12, 2005, (the "Note"), in the principal amount of $25,000.00 (the "Principal"), and requiring the payment of interest on the Principal at the rate of 9 percent per year (the "Interest"). A true and correct copy of the Note is attached hereto as Exhibit "B" and incorporated herein. 5. The Note obligates the Defendant to pay to Plaintiff the Principal and Interest in equal, consecutive installment payments of $401.69 each (the "Installment Payments"), on the 30th day of each month beginning July 30, 2005, until the Principal and Interest are paid in full. 8. The failure of the Defendant, inter alia, to pay when due and payable the Installment Payments and Renegotiated Installment Payments constitutes "default" as defined under the terms of the Note. 9. The Defendant has failed or refused to pay the Installment Payments due and payable on the 30th day of June, 2006, through April, 2007 constituting defaults under the terms of the Mortgage. The sum of these amounts is $4,418.59. 11. The terms of the Note provide that upon the occurrence of a default by the Defendant that the Plaintiff may accelerate and demand immediate payment of all sums secured by the Note. 12. The sums presently due and payable to Plaintiff by Defendant and secured by the Note are computed as follows: A. Unpaid principal $ 22,661.60 B. Unpaid interest through April 30, 2007 $ 1,481.67 C. Attorney's fees $ 1,500.00 TOTAL $ 25,643.27 WHEREFORE, Plaintiff demands judgment in the sum of $25,643.27 together with costs and interest from the date hereof as a result of the Defendant's default on the note. Respectfully Submitted: KAGEN, MACDONALD & FRANCE, P.C fe?wa"I A ?L" Edward A. Paskey, Esquire Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: By: L4n? !LtAL (-- 00 Penny Gentzlei, CEO Acco York Federal Credit Union NOU-16-2006 09:25 FROM:CUMBERL( I q 5-a-7 T" 1.8667327243 ReeLRT P. AZiECLER 113 ?s ZFCORDEit OF DEEDS x'11 ^^ THISDEEDZW5 FEB 8 Aid 10 35 TAX PAIRCEL LIL11,027"40 Made the day of in the year two thousand five, (2005). BETAKEN NAE H. PARK and WON J. PARIS husband and wife, of Cumberland County Pennsylvania, hereinafter referred to as the GRANTOR AND JEANNIE B. MOHMAND an individual person, of Cumberland County Pennsylvania, hereinafter referred to as the GRANTEE WITNE£SETH, That in consideration of THREE HUNDRED NINETY NINE THOVSAND NINE RUNDRE,D DOLLARS 0399,90000), in hand paid, the receipt whereof is hereby acknowledged the said grantors do hereby grant and convey to the said grantee, her heirs and assigns, ALL THAT CERTAIN piece or parcel of land situate in the Township of Lower Allergy Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with survey made July 7, 1966 by D.P. Raf}ensberger, Registered Surveyor, as follows, to Wt.- BEGINNING at a point in the center line of the Public Road leading from Lisburn to Slate Hill. L.R. 21014, at the Northeast corner of lands now or formerly of ,Harry Deckman; thence along said lands now or formerly of Harry Deckman and Lands now or late of Mary Herr North Eighty four (84) degrees fifteen (15) minutes West Five Hundred Sixty (560) feet to an iron pin; thence along other lands now or formerly of George N. and Martha M Lenksr, of which the tract of land herein described was apart, North Thirty-eight (38) degrees Thirty (30) minutes Fart Five Hundred Thirty-eight (538) feet to a point in the center line of the aforesaid public road; thence along the center line of the aforesaid public road South Forty-seven (47) degrees Nineteen (19) minutes East Two Hundred Twenty-eight ('228) feet to a point; thence further by same South 7Wexly (20) degrees Worry-seven minutes Fast 7Wo 1fvndre4 Airreen and nfne-tenths (213.9) jest to a point; thence still ??eK 267 PAM23.1 ,NOV-16-2006 09;,26 FROM:CUMBERLr T 16667327243 h by the center line of the aforesaid public road South Seven (7) degrees Thirty (30) minutes `Pest One Hundred Fifteen and Six-tenths (11 S. 6) feet to the point and place of BEGINNING. CONTAIN.tNG three and one-half (3 %) acres of land, more or less HAYING thereon erected a two story brick ranch type dwelling known and numbered 4020 Lisburn Road Mechanicsburg, Pennsylvania. BEING THE PREMISES which Eugene E. Costello and Joan L. Costello husband and wife, by Deed dated June 30, 1976 granted and conveyed unto Nae H. Park and Wort J. Park husband and wife, and recorded in Deed Book R 26, Page 91, in the Office of the Recorder of Deeds in and for Cumberland County, Grantors herein. TOGETHER with all and singular, the tenements, hereditaments and appurtenances to the same belonging or in anywise appertaining, and the reversion and reversions, remainder and remainders, rents, issues, and profits thereof; AND also all the estate, right, tfile, interest, properly, claim and demand whatsoever, both in law and equity, of the said patties of the first part, of, jr; to or out of the said premises, and every part and parcel thereof. TO HAVE AND TO HOLD the said premises,'with all and singular the appurtenances, unto the said partiac of the second part their heirs and assigns, to and for the only proper use and behalf of the parties of the second part, their heirs and assigns forever, AND THE said Grantor hereby comnant and agree that they wlll WAJUUNT SPECIALLYlke property hereby conveyed IN WITNESS WfLEREO ,, the said party of the first part have hereunto set their band and .seal, the day and year first written above. N_ia"-KV?t Park /s?,tt} H P Wftness: (plc - c?' ismw Won J. Park 2 BOOK 267 FACET 320 ... .. .. . .. . NOV-16-2006 09:26 FROM:CUMBERL/ T 18667327243 . , Commonwealth afPennVIPania: // ; ss County of ?c ,,.6.a t?? On this, the day of 2005, before me a Notary Public, the undersigned Off"", personally appeared Nag 19 PARK, husband and wife, known to me for satisfactorily proven) to be the person whose name is Subscribed to the within instrument, and acknowledged tha they executed the same for the purpose therein contained V WITNESS WI?REOF, I hereunto set my hand and orycial seal. COMMONWM OR PENNSYLVaNrA NabM SW Rft" M tik02M4 Notary PAft Lay*y a am C1s1Ybuaw ON* W Carne Ow Eiiro Nov 17, 2007 tNGMW, ftnrogoveniaAssodatbnQf NgRaMM NOTARYPUBLIC (SEAL Commonwealth of Pennsylvania: SS COM& of On this, the day of 2005, before me a Notary Publ14 the undersigned oftcr, personally appeared WON J. PAM, husband and w ft, kWwn to me (or satisfactorily proven) to be the person whose name is subscribed to the within ins& men4 and acknowledged that they executed the ,same for the purpose therein contained IN WITNESS W.FIE EOF, I hereunto set my hand and official seal. NOTARY PUB {seal} OMMONW LTH OF PENNSYLVARA Notadal3eal ftwnad MD= K Notary F'ubtio Lemoyne SMO Cm.dMIM C *U* My Om..,* kx E`4 +i P 4 Nbr 17, 2007 Mombor. ft9rw Avw0v Associauon Of Norarks 3 BOox 267 PAGE2321. NOV-16-2006 09:26 FROM:CUMBERL' G'ERTwicATE OF REUDENCE ' 18667327243 4 hereby certify that the precise residence of the grantee herein is as follows: .rv yo LUssuz1v p,4 (sr?,c} 400 A Y qr /!get for Grants Commonweaith of pennsylvania SS County of RECO"E,D in the Office for Recording of Deeds, etc., in and for said County, in Deed Book volume J Page WHNESSS my Hand and Dfflcial Seal this day of ,1005. AML) qfDw& AML) Cc,rh r, ('j; In Cum. 1: ?x 0404? "M F, CP t= W V- m ga ?r s? VMS i •r Sao, P4012322 ii N c'7?s 94 4 ?bp [II « O°ryy C31 K7 Ca Lei 1 e? P, 'xC s w:L .7 r ? w ca -a :7? NOTE Note Number 789495 JULY 12, 2005 MECHANICSBURG PENNSYLVANIA 10556 [Date] [City] [State] 4020 LISBURN ROAD (Property Address) BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to Pay U.S. $25,000.00-- --------------------------------00100 DOLLARS--------------------- (this amount is called "principal"), plus interest, to the order of the Lender. The Lender is: ACCO YORK FEDERAL CREDIT UNION 1529 RODNEY ROAD YORK PA 17404 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 9.00 % The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6 (B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the 30TH day of each month beginning on JULY 30„ 2005. I will make these payments every month until I have paid all the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, On JUNE 30, 2012 amounts under this Note, are still owing, I will pay those amounts in full on that date, which is called the "Maturity Date". I will make my monthly payments at 1529 RODNEY ROAD, YORK, PENNSYLVANIA 17404 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments $401.69 BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a "prepayment". When I have a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any sums already collected from me which exceeded permitted will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 00calender days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 00% of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. MULTISTATE FIXED RATE NOTE - Single Family - Fannie Mae/Freddie Mae Uniform Instrument Fnrmllfln Page 1 of 2 (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that If I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or mailed to me. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICE Unless applicable law required a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given my mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in the Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person), without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. SSN:, eal) ,sw_dos-so'13?4 "-Borrower (Seal) SSN: -Borrower (Seal) SSN: (Seal) ? '° oho ?I op V$t b ('V jrl1 K IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: Jeannie Mohmand DATE OF NOTICE: June 5, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 KAGEN, MACDONALD & FRANCE, P.C. 11ow c,-,z A " Edward A. Paskey, Esquire Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. AVISO IMPORTANTE A. Jeannie Mohmand FECHA DEL AVISO: June 5, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDED Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATEMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. . CERTIFICATE OF SERVICE AND NOW, to wit, this b day of June, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, served a copy of the Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. Edward A. Paskey, Esquire Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 o ? , t j3 SHERIFF'S RETURN - REGULAR CASE NO: 2007-02866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ACCO YORK FEDERAL CREDIT UNION VS MOHMAND JEANNIE SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MOHMAND JEANNIE the DEFENDANT at 1836:00 HOURS, on the 16th day of May , 2007 at 4020 LISBURN ROAD MECHANICSBURG, PA 17055 JEANNIE MOHMAND by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13 .44 k<? Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41.44 05/17/2007 KAGEN MACDONA FRANCE Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, V. JEANNIE MOHMAND Defendant. TO THE PROTHONOTARY: NO. 07-2866 CIVIL TERM CIVIL ACTION/LAW MORTGAGE FORECLOSURE ENTER JUDGMENT in the above case for failure to file an Answer to the Plaintiffs Complaint against Jeannie Mohmand, in favor of Acco York Federal Credit Union in the sum of $22,661.60 with interest plus costs of suit ($1,481.67 for interests and $1,500.00 counsel fees), and demands. Total: $25,643.27 I hereby certify that the attached Notice is a true and correct copy of the original Notice of Intention to Enter Default Judgment that was mailed to the Defendant on the 7th day of June, 2007, pursuant to Pa.R.C.P. 237.1. '? q k &:?? Attorney for Plaintiff Edward A. Paskey, Esquire JU-0 I=. z& , 20-67-Judgment entered by the Prothonotary this day according to the tenor of the above statement. 92 P thonotary C171 --J?l OFFICE OF THE PROTHONOTARY Of Cumberland County Curtis Long Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Telephone (717) 240-6195 Date: June 2007 No : 07-2866 To: Jeannie Mohmand RE: Acco York Federal Credit Union, Plaintiff VS: Jeannie Mohmand, Defendant Notic,I is given that judgment in the above captioned matter has been entered against you on Curtis Long PROTHONOTARY OF CUMBERLAND COUNTY BY krj'A I / lrp? -2?' If you have any questions concerning the above case, please contact: Edward A. Paskey. Esquire Attorney or Filing Party 2675 Eastern Boulevard Address York, PA 17402 Telephone # 717-757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL NO. 2007-02866 CREDIT UNION, Plaintiff V. JEANNIE MOHMAND Defendant CIVIL ACTION-LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK : ss: Plaintiff, being duly sworn according to law, deposes and says that Acco York Federal Credit Union is the Plaintiff in the above-captioned matter; that it personally knows the Defendant, Jeannie Mohmand, is over the age of 18 years; and that he resides at 4020 Lisburn Road, Mechanicsburg, PA 17055. Plaintiff further avers that Defendant is not in the Military Service or in any branch of the Armed Forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. ,jk C. A Penny Gen ler, CEO Acco York Federal Credit Union Sworn to and subscribed before me this /;L day of v n C , 2007. NOTARY PUBLIC --- My Commission Expires: p{OTARIAL SEAL TAIA S. ELI NOTARY PUBLIC SPRINGS SBURY 1YVP., `FORK COUNTY MY COMMISSION rvPIRES FEB. 25 2010 w OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Curtis R. Long Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6195 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA Plaintiff: Acco York Federal Credit Union Defendant: Jeannie Mohmand Judgment No. 07-2866 CERTIFICATE OF RESIDENCE PA R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: 1529 Rodney Road, York, PA 17404 AND CERTIFY THAT THE LAST KNOWN ADDRESS OF THE WITHIN DEFENDANT IS: 4020 Lisburn Road, Mechanicsburg, PA 17055 AZVA?' d Penny Gen ler, CE Acco York Federal Credit Union IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. r'a a NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT 23 TO: Jeannie Mohmand _,+ P DATE OF NOTICE: June 5, 2007 = y c> IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOTAFFORD ONE, GO TO ORTELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 KAGEN, MACDONALD & FRANCE, P.C. ?u-)C?-'z A " Edward A. Paskey, Esquire Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. AVISO IMPORTANTE A. Jeannie Mohmand FECHA DEL AVISO: June 5, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDED Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATEMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. CERTIFICATE OF SERVICE AND NOW, to wit, this b day of June, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, served a copy of the Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. &.? A . T,,'L - Edward A. Paskey, Esquire Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 N L C qs pry -?C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 PlaiMiff, V. CIVIL ACTION/LAW JEANNIE MOHM?kND DefOndant. CERTIFICATE OF SERVICE AND NOW, to wit, this )'-- day of April, 2008, I, Edward A. Paskey, Esquire, do hereby certify that I have this date served a copy of the Notice of Deposition of Jeannie Mohmand by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the'party of record as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Respectfully Submitted: KAGEN, MACDONALD & FRANCE, P.C. ?? 0i 6z ? LA Edward A. Paskey, Esqui Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION NO. 07-2866 Plaintiff, V. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. CERTIFICATE OF SERVICE AND NOW, to wit, this ? day of May, 2008, I, Edward A. Paskey, Esquire, do hereby certify that I have this date served a copy of the Notice of Deposition of Jeannie Mohmand for June 9, 2008 by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the party of record as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Respectfully Submitted: KAGEN, MACDONALD & FRANCE, P.C. Edward A. Paskey, Esquire Attorney ID No. 80304 ' 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565