HomeMy WebLinkAbout03-6407MICHELLE C. KAHAN, ESQUIRE
Attorney I.D. No. 47118
2536 Eastern Boulevard
Number 152
York, PA 17402
(717) 846-2954
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
PROVIDENT BANK OF MARYLAND
Plaintiff,
VS.
NO. dPJ ~ ~' 5'o~2 ~t ~
CIVIL ACTION- AT LAW
KEITH A. BURKHOLDER,
Defendant
COMPULSORY ARBITRATION
NOTICE
You have been sued in court, tfyou wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with
the court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so the case may proceed without you and a judgment may be entered against
you by the court without further notice for any money claimed in the complaint or for any
other claim or relief requested by the plaintiff You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO 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 IlxtFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
1 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(8OO) 990-9108
ADVISO
Le ban demandado a usted en la corte. Si usted quiere defenderse de estes demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha
de la demanda y la notificacion. I-lace falta asentar una comparencia escrita o con un abogado
y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra
de su persona. Sea avisado que si usted no se defiende, la corte tomato medidas y puede
continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la torte puede
decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta
demanda~ Usted puede perder dinero o sus propiedades u otros derechos importantes para
usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR DEL SERVISO.
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTTRA ESCRITA ABAJO PARA AVERIGUAR IX)NDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
1 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
PROVIDENT BANK OF MARYLAND
Plaintiff,
VS.
KE1TH A. BURKHOLDER,
Defendant
NO. 03
CIVIL ACTION - AT LAW
COMPULSORY ARBITRATION
COMPLAINT FOR RECOVERY OF DEFICIENCY AFTER RESALE OF VEHICLE
AND NOW, TO WIT, this 10r~day of December, 2003, comes the Plaintiff, Provident Bank
of Maryland, by and through their Attorney, Michelle C. Kahan, Esquire, and files the
following Complaint:
1. The Plaintiff, PROVIDENT BANK OF MARYLAND (hereinafter referred to
as "Plaintiff'), is a financial institution qualified to conduct business within the
Commonwealth of Pennsylvania, with its principal place of business at 114 East Lexington
Street, Baltimore, Maryland 21202.
2. The Defendant, KEITH A. BURKHOLDER (hereinafter referred to as
"Defendant"), is an adult individual residing at 7 N. Corporation Street, Newville,
Cumberland County, Pennsylvania 17241, also possible residing at 600 N. Middle Road,
Newville, Cumberland County, Pennsylvania 17241.
3. That on the 8th day of May, 2000 at Cumberland County, Pennsylvania, the
Plaintiff by an Installment Sales Agreement in writing, a copy of which is hereto annexed,
marked Exhibit "A", and made a part hereof, financed the Defendant' s purchase of a used
1996 Dodge 1500 PU Truck from Cumberland Valley Motors, located at 6714/20 Carlisle
Pike, Mechanicsburg, Cumberland County, Pennsylvania 17055, in the amount of Fifteen
Thousand Six Hundred Ninety-Five and 95/100 Dollars ($15,695.95). The Defendant agreed
to pay the Plaintiffsixty (60) monthly payments of Three Hundred Forty-Nine and 06/100
Dollars ($349.06) each, commencing June 7, 2000 for the vehicle.
4. The Plaintiff delivered the vehicle to the Defendant on the said 8th day of
May, 2000 and demanded monthly payments thereof, yet the Defendant became in default
when Defendant failed to pay the installment sums of $349.06 due on September 7, 2000 and
$349.06 due on October 7, 2000.
5, Thereafter, and on the 16th day of October, 2000, at Baltimore, Maryland, the
Plaint/ffby a letter, a copy of which is hereto annexed, marked Exhibit "B", and made a part
hereof, notified the Defendant that due to the missed payments, Plaintiff accelerated the
balance due under the loan.
6. Thereafter, the Plaintiffproceeded to repossess the vehicle.
7. Thereafter, and on the 21 st day of December 2000, at Car and Truck Auction
of Maryland, Inc., 803 Belair Road, Bel Air, Maryland 21014, the Plaintiffsold for and on
account of the Defendant, the said 1996 Dodge 1500 PU Truck vehicle at public auction to the
highest bidder.
8. The said 1996 Dodge 1500 PU Truck vehicle brought the sum of Eight
Thousand Seven Hundred and 00/100 Dollars ($8,700.00) at the said sale.
9. The expenses attending upon such sale, including repossession, storage and
transporting, copies of which are hereto annexed, marked Exhibit "C", and made a part
hereof, amounted to the sum of Six Hundred Ninety-Seven and 50/100 Dollars ($697.50).
Defendant received credit for insurance claims/cancellation in the amount of One Thousand
Seven Hundred Ninety-Five and 07/100 Dollars ($1,795.07), leaving a balance of Nine
Thousand Seven Hundred Ninety-Seven and 57/100 Dollars ($9,797,50) to be credited upon
the said purchase price.
I0. Therefore, by reason of the facts aforesaid, the Plaintiffhas been damaged in
the sum of Five Thousand Seven Hundred Ninety-One and 87/100 dollars ($5,791.87) plus
interest from March 21, 2001 at a daily interest rate of 95/100 dollars ($0.95). These
damages being the difference between the purchase price of the vehicle financed by the
Plaintiff, less the amount realized on the resale of the vehicle, less the amount received for an
insurance credit/cancellation, and adding expenses of sale, payments made by Defendant and
interest.
11. The Defendant agreed, as per the terms of the Installment Sales Agreement,
that in the event the Agreement was placed for collection with an attorney, the Defendant will
pay attorney' s fees of 15 percent of the amount owed by the Defendant plus court costs and
disbursements. A copy of the terms of the Installment Sales Agreement is hereto annexed,
marked Exhibit "A", and made a part hereof.
12. The Plaintiff has incurred attorney' s fees on amounts collected to date, will
continue to incur attorney's fees, and has incurred costs in pursuit of this action.
13. This Complaint is an attempt to collect a debt.
WBEREFORE, there is due and owing by the Defendant, KEITH A.
BISRKHOLDER, to the Plaintiff, PROVIDENT BANK OF MARYLAND, the sum of Five
Thousand Seven Hundred Ninety-One and 87/100 dollars ($5,791.87), plus costs of this suit,
interest from March 21, 2001 at a daily interest rate of 95/100 dollars ($0.95) and reasonable
attorneys' fees in the amount of fifteen percent (15%).
Respectfully submitted,
~I~' linC ~
~Ka~t ~ii squire
Attorney for the Plaintiff
2536 Eastern Boulevard, No. 152
York, Pennsylvania 17402
Telephone: (717) 846-2954
I.D. # 47118
VERIFICATION
I, Donald Plott, do hereby certify and say that I am an employee for Provident Bank
of Maryland, and that I am authorized to make this Verification on its behalf, and that I do
verify that the statements made in the foregoing Complaint are true and correct to the best of
my knowledge, information and belief, upon information supplied.
I understand that false statements made herein are subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
Date:
Donald Plott
State of Maryland to wit:
County/City of Baltimore
I hereby certify on this 26th day of March, 2001, before me, the subscriber, a notary public in
and for the county/city and state aforesaid, personally appeared Raymond Goldberg, Vice
President of Provident Bank of Maryland the Plaintiff herein, who solemnly declares and affirms
under penalties of perjury and in due form of laws as follows:
That the affiant is duly authorized by the Plaintiff to make this affidavit; that the affiant is
competent to testify to the matters stated herein; that the affiant has personal knowledge of
the facts stated herein and that they are tree and correct.
That there is justly due and owing by the Defendant to the Plaintiff, over and above any
discount and without deduction or set-off, the sum of money set out in the foregoing
declaration and/or in the document/written obligation/itemized statement of account attached
hereto amounting to $5,777.62 with interest from 03/09/01 to 03/23/01 of $14.25, plus
attorney fees of 15% of the amount owed.
3. That the said indebtedness represents merchandise sold/moneys advanced/services performed
by the Plaintiff to or for the Defendant.
That the Plaintiff has not directly or indirectly, received any part of the money or goods
charged herein as due or received any security or satisfaction for which credit has not already
been given.
That the Plaintiff Keeps regular books of account and that the keeping of said books of
account is in the charge of or under the supervision of the affiant. The entries in said books
of account are made in ordinary course of business. Said entries show that the Defendant is
indebted to the Plaintiff in the manner and amount herein set forth.
That the Defendant is not in the Military Service as defined in the Soldiers's and Sailors'
Civil Relief Act of 1940 with amendments, nor has been in sjach service within 30 days
hereof.
Raympfid Goldberg
Vice President
As witness my hand and seal this date above wr~
(SEAL)
~ ~,{~.~ 7210 Ambassador Road P.O. Box 1661 Baltimore, Maryland 21203-1661
^~,~,~B,n~a~ INSTALLMENT SALE AGREEMENT Dealer Number Contract Number
Buyer (and Co-Buyer) Full Name and Address Seller (Dealer's Full Name and Address)
(Include County& Z{p Code)
(EITH A. BURKHOLDER CUHBERLAND VALLEY HOTORS
600 N HIDDLE RI) 6714/20 CARLISLE PIKE
(EWVILLE PA 17241 HECHANICSBURG, PA 17055
in this Agreement, the words 'l', 'me", and 'mine" refer to the Buyer and Co-Buyer. The words 'you' and "your" refer to the Seller and, after assignment of
this Agreement, to Provident Bank of Maryland. "Property' refers to the item to be purchased under this Agreement.
I may buy the Properly described below for cash or on credit. The cash price is shown below in the "Itemization of Amount Financed' as "Cash pdce." The
credit price is shown below as 'Total Sale pdce." By signing below, I elect to buy the Property on credit under the terms of this Agreement.
I have paid you the Total Downpayment shown below. I will also pay you the Unpaid Balance of Cash Pdca plus my Other Charges. I will also pay a Finance
Charge at the Annual Percentage Rate shown beh3w. The finance charge will accrue daily, beginning on the date of this Agreement on the Unpaid Balance of
Cash Price and Other Charges that remain unpaid. I will pay you these amounts in monthly payments as set forth below.
Property Description. I agree to buy and you agree to sell the following property:
New or Used Year Make and Model Style identification No. Primary Use for Which Purchased
~] personal/fam,y/household [] business
DODGE
USED 1996 1500 PU TK B7HC 16Y4TJ128771 I-) .O~icultural
ANNUAL PERCENTAGE RATE
The cost of my credit as a yearly
reta.
FEDERAL TRUTH-IN-LENDING DISCLOSURES
FINANCE CHARGE Amount Financed
The dollar amount The amount of credit
the credit will cost provided to me or on my
me. behalf.
11.99 % $ 5247.65 $ 15695.95
Total of Payments Total Bale PHce
The amount I will have paid The total cost of my purchase on
after I have made aU payments credit, including my down payment
as scheduled, of
$ 3635. O0
$ 20943.60 $ 24578.60
My Payment Schedule wlmm Be:
Number of Payments
bU
Amount of Payments
349.06
06/07/00
Late Charge. If a payment is more than 10 days late, I wilt pay a late
charge of 2% of the amount of the payment in arream.
PmbeymenL If I pay off aady, I will not have to pay a pana{ty.
Security Intamst. I am giving a secudty interest in the property being
purchased.
* Due Dates. Payments cannot be due on the 29th, 30th, 31st or 1st of
the month.
Additional Information. I may see the other side of this Agreement for
more information including information about nonpayment, default, any
required repayment in full before the scheduled date, prepayment refunds
and secudty interest.
ITEMIZATION OF AMOUNT FINANCED
1. Cash Price-Consisting of (A) Cash Pdce of Goods Sold
(B) Separate Charges, if any, for Defivery, Installation, Repair or other Services
2. Total Downpaymeet --- Net Trade-in $ 1795.00 plus Cash Downpayment $
My Trade-in is a
I~R~ Fn~n F150 PICKUP
Year Make Model
3. Unpaid Balance of Cash Pdce (1 minus 2)
S 15695.00
$ N/A S I ~695.00 (1)
1840. O0
$ 3635.00 (2)
Identification No.
$ 12060 00 (3)
4. Other Charges Including Amounts Paid to Others on My Behalf: (you or your affiliates may receive finandal benefits from my purchase of insurance and other products.)
(a) Cost of Required Insurance Paid to the Insurance Company Named Below
(b) Cost of Optional Mechanical Repair Protection or
Extended Warranty Paid to the Company Named Below
{c) Cost of Optional Credit Insuranca for the Term of the Agreement Paid to the Insurance Company
or Companies Named Below. Life $ 399.19
Disability, Accident and Health $ 720.46
(d) Official Fees Paid to Government Agencies
(e) Taxes Not Included in Cash Pdce
(f) Government License and/or Registration Fees (Itemize)
$ N/A
S N/A
1119.65
23.80
924.00
46.00
N/A
27 50
N/A
(S) Government Certificato of Title Feas E~(H'I ~'~F ~'t~1
(h) Other Chargas (Seller must identity who will receive payment and describe purposs)
to for
Total Other Charges and Amounts Paid to Othem on My Behalf $
5. PdncipahAmount Financed (3 plus 4)
6. Finance Charqe
Items 6, ? and 8 are
calculated assuming I 7. Total of Payments (5 plus 6)
make all payments on 8. Payment Schedule: One installment of $
the dates and in the
amounts scheduled.
349.06
and 59 installments of $ 349.06 each, monthly, beginning
¢]7 .lIJ~19 2~(~due on the date shown
in the payment schedule above.
$ 3635.95 (4)
$ 15695.95 (5)
$ 5247.65 (5)
$ 20943.60
Ineurance. If any insurance or extended warranty or mechanical repair protection is checked below, policies or certificates will be issued to me describing
the ten'ns and policy limitations and exclusions.
Required Insurance. You require proper'b/insurance. I may obtain it from anyone I want who is acceptable
to you. Item 4(a) above shows the cost of this insurance, if purchased through you
Insurance Company Term: __ months
Deschption of Coverage:
Optional Mechanical Repair Pmtsctie. or Extended Warranty.
Item 4(b) of the Itemization above shows the cost of this insurance.
Company
[] $25 Deductible [] $50 Deductible
[] $ Deductible
Optional Credit Insurance. YOU DO NOT REQUIRE THAT I BUY CREDIT LIFE INSURANCE AND CREDIT DISABILITY INSURANCE IN ORDER TO
OBTAIN CREDIT. YOU WILL NOT PROVIDE THESE COVERAGES UNLESS I SIGN FOR THEM AND AGREE TO PAY THE ADDITIONAL COST. If I
want this insurance, I wilt check the insurance desired and sign bota~,'. If I have chosen this insurance, the cost is shown in 4(c) of the Itemization above.
Check the insurance der'-ed: ~] Life (Buye~ Co-Buyer [] Both [] )
~] Disability, Accident end Health (Buyer [] xCo-Buyer [] Both [] )
UNIVERSAL UNDERWRITERS LIFE INS CO 6363 £OIIFGF RVn OVFR~ AMD PARK, KS 6621[
(Name of Insurer)
Under policy of designated insurer, maximum amount of insurance under this Agreement is $
under this an.d any ojl~,er in,~ta[~3eot ii~greement of the Buyer under Seller's group policy, is limited to $
Buyer's Signature Date Co-Buyer's Signature Date
(Home Office Address)
~.0943 o 60 . The total amount of insurance
30,000
NO LIABILITY INSURANCE INCLUDED. THIS COVERAGE IS NOT AVAILABLE THROUGH YOU.
IF YOU DO NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE THE PROPERTY YOU BOUGHT ~NITH THIS AGREEMENT.
This is a simpts interest contract. The amount of Finance Charge shown above may differ from the amount I actually pay. You credit each payment flit to credit
insurance premiums, if any, then to late charges, if any, then to earned Finance Charge, and then to the unpaid balance of the Amount Financed. You compute my
Finance Charge on the unpaid batance of the Amount Financed eacfl day using the simple interest rate that applies te this Agreement. Notwithstanding the payment
due dates set forth above, if the payment schedule provides that a payment is due on the 29th, 30th, 31st or 1st of the month, you will change the due date to the 2nd
of the month. The eadier I make payments before their due dates (and the larger the payments) the less Finance Charge I will pay. You will send me a refund check if I
have paid you more than I owe after I make my last payment. On the other hand, the later I make payments after they are due (or the smaller the payments) the
greater the Finance Charge. If the amount i owe on the date my final payment is due is 125% or less of the scheduled amount of my final payment, I will pay my entire
balance due. If the amount I owe on the date my final payment is due is more than 125% of the scheduled amount of my finaJ payment, I agree to make one or more
additional monthly payments in the same amount as my scheduled payments until the amount I owe on a payment date is 125% or less of a scheduled payment. At
that time I will pay the entire amount I owe. You will tell me before my last payment is due of any additional amount I owe you if it is $1.00 or more,
I agree to the previsions set forth on both sides of this Agreement. I acknowledge that this Agreement is contingent upon Provident Bank of Marylaed's acceptance of
its terms, which terms are satisfactory to you and me.
NOTICE TO BUYER:
.~j~.~ONTRACT YOU SIGN. KEEP IT TO PROTECT YOUR LEGAL RIGHTS.
05/08/00
Buyer Signs Date Co-Buyer Signs
I ACKNO~WLEDGE, THAT A COPY OF THIS CONTRACT WAS DELIVERED TO
o ,o ,oo
Buyer Signs Date Co-Buyer Signs
DO NOT SIGN THIS CONTRACT IF BLANK. YOU ARE ENTITLED TO AN EXACT COPY
05/08/00
Date
05/08/00
Date
Co-Buyers and Other Owners - e co-buyer is a person responsible for paying the entire debt. An "other owner' ta a person whose name is on he title to
the Property, but who does not have to pay the debt. By signing below, the other owner grants you a security inte.~st in the Properly. This permits you to
repossess the Property if the Buyer (or Co-Buyer, if any) defaults as descdbod on the back of this Agreement. An other owner' can lose his or her interest
in the Property if the Property is repossessed.
Other Owner's Signature Address
NOTICE: SEE OTHER SIDE
Accepted, and this Contract is hereby assigned to Provident Bank of Maryland, in accordan~sions ~jhe Dealer's Assignment on the
reverse side hereof. .
05/08/00
Dealer's Signature Date
PA 9003lA (3/98) WHITE: Original Bank Copy YELLOW: Deatefs Copy PINK: Buyer's Copy GOLDENROD: Sank File Copy
NOTICE
ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO
ALL CLAIMS AND ~EFENSES WHICH THE DEBTOR COULD ASSERT
AGAINST 'THE SELLER OF THE GOODS OR SERVICES OBTAINED
PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY
THE DEBTOR HEREUNDER.
I My Responsibility as to the PrOPle~ I wil~, keep the ~P~,opert
taxes, liens and encumbrances I v~ifl' fdl~ay tb ~,o~:Wl~en y~a~k ~0~' ff~ar~y
money you pay to release or di~ct~arge a~y';s~c~\ ta)tss'~pS or
encumPrances. Until I rel~ay you, such sbms shall bepar~ of.the pb)igation
secured under this ,~m~rte~t. I will not 'u~e thblPr~r~3et'tyl'(~l~a~l~lbr
improperly. I will not, without your wdtten permission, use the Property for
hire. I will not without your wdtten permission, remove the Property from this
state or the location designated above as my address, or transfer or sell any
interest in the Property. I will not do any act or omit to do any act that would
permit the Property to be seized in any civil or cdminal fon'eiture proceeding or
by any f~deral, stats or Iccal gevemment body for any reason I will not lose
possession of or hide the Property. J will not lease or sell the Property or any
interest I may have in the property or attempt to do so, without your pndr
express written permission
2. Insurance. I will keep the Property insured at my expense against the risk
of damage or destruction and such other dsks as you may mcluire I will keep
such insurance for as long as I owe any amount under this Agreement.
Losses under such insurance shall be payable to you and me as our interests
may appear. The policy insudng the property must name me as the
policyholde[ Such insurance must provide that it may not be cancelled
without 15 days' notice to you, The maximum deductible I may maintain
concerning such insurance is $500. I will deliver all such insurance policies to
~ou. I will obtain at your request from any insurance company insudng the
ropeerty, any certificates, written assuranc~ r proof of insurance yoN re$~uire.
You may apply the proceeds from insurance, in your sole di~lreapd~ Icj r~lace
the Property or to pay sums I owe under this Agreement I hereby assign to
you any monies, not in excess of all amounts I owe you, that may become
payable under such insurance proceeds or refund of unearned premiums
Upon cancellation or termination of any insurance, you will credit any premium
refund you receive to my outstanding Principal Balance, or pay it to me if my
outstanding Principal Balance has been paid.
3. Late Charges and Collection Costs. I ogme to pay a late charge (also
called a pefauit charge) of 2% on the amount of the payment or payments in
arrears for more than 10 days You may collect a late charge only once on
each payment in arrears You may collect such late charges as you earn
name and address of the person to whom I must make payment or send
notices Your notice will also set forth the time and place of the proposed sale
of the property I am liable for your actual, necessary and reasonable costs in
retaking, stodng and repairing the property when ~ have been in default more
than 15 days at the time of repossession. You must have evidence of such
costs as required by law The Pennsylvania Department of Banking may
disallow these costs under certain circumstances
After repossession you may reinstate the Agreelpprl~ ~ad r~t~m the
o me provided I pay all past due ~nstallments d~e udder the Agreer~nt 0'-f
permitted by law) If my default at repossession ex~deCl II~'~/s, ~'~ rn~ust
also pay expenses of re ak rig, reps nng and stor ~hgk~ perrrli~ed by qw~ ~
You will store the Property for 15 days in t,,~ c~nty li~t which ~ was
repossessed. However, if repossession occurred out of state, you will store it
for 15 days near the place of repossession or in the county in Pennsylvania in
which it was sold Dunng this 15~lay period I may recieem the Property and
terminate the Agreement To do so, I must pay you the amount of the unpaid
time balancer the amount of any accrued default charges permitted by law,
and any other amounts due under the Agreement, less any rebate of
unearned finance charges I am not required to pay costs of retaking,
repairing and storing the Property unless my default exceeded 15 days at the
time of repossession I am entitled to have the reasonable value of the
Property determined in any action you bhng to recover a deficiency. You will
credit me with the reasonable value so determined or the sale pdce you
receive when the Property is sold after repossession, whichever is more,
$. My Additional Obligations. I will sign financing statements or other
documents you require to perfect your secudty interest. I will obtain end
deliver to you a certificate of title under applicable state iow. The certificate of
title will show a lien or encumbrance in your favor. I will pay any fees or taxes
resulting from obtaining such certificate or any supplemental certificate or
termination document. If I make payments.by.~ai~, I may require you to issue
~ receipt for such gayments only if I pl~lyou witty,fa
~dt~mpeq envelope. ~f I make any payp~ept ~(ip,oheck tY{~t is return~ ~o you
unpaid after the second presentment for any reason, you may impose a
returned check fee of $10, if such fee is permitted by law,
6. Miscellaneous. You and I agree that commercial reasonableness requires
no more than 15 days' notice of public or pdvate disposition of the Prope~y
after repossession. Your dghts and remedies are cumulative Your recourse
to a right or remedy does not mean you waive others. No waiver of any
default shall constitute a waiver of any other or later defaufi. Acceptance of
any overdue payment and/or any delinquency charge shall not constitute a
waiver of, nor shall it cure my default in, not making such payment when due
You may proceed with all of your nghts and remedies despite such
them. or yqg may accumulate and collect them with the final payment under acceptance Your acceptance of a check or draft purporting by its terms, or by
this .~lfeeW/eht~ If you place this Agreement for collection with an attorney the terTns of any endomement it contains, to be in full payment of the amount I
who is not ¥ou¢ saladed employee, I will pay yo~ attorney's fees of 15 percent, , , owq will not prevent ,¥9u ,frpm collecting or qs~ertle, g the right to collect,
ofth~lamo~r~tq'~/e you, pluscourt costs ah~,diltbb~s~h~nts. ' ~ a~idltional amounts 'owe, bn~s such check or draft s accompaned by a
4. Default. ~me is of the essence of this Agreement. I will be in default if I
fail to make any payment when due. I will be in default if I fail to pay any other
amount I am obligated to pay you under this Agreement. I will be in default ~ I
fail to perform any of my obligations under this Agreement. I will be in default
if I breach any promise, or condition contained or referred to in this Agreement.
I will be in default if I Hikes ~r~ '~atse statements in applying for the Cr~flt~
exteeqed under this Agreement.
If I default, you shall have the dght, at your election, to declare the then
outstanding Phncipal Balance, together with accrued finance charge and any
other amount I owe you under this Agreement, to be immediately due and
payable. Finance charge shall continue to accrue until the entire Principal
Balance has been paid in full or until a judgment is entsred. Any judgment
shelt bear interest at the highest rate allowed by law. Further, you may take
immediate possession of the property with or without court proceedings. You
may, lawfully and without breach of peace, enter upon any premises with fr~e
dght of enhy where the Property may be, and take possession of and rerrove
the property. Repossession of the Property shall not affect your right to retain
all pdor payments. You may then sell the propeAy at public or phvate sale,
You may apply the proceeds,~ any ,ms,a, ie of the property first, to the actual
and reasonapfe cost of the r~osm~iand sale, including costs of stodng
and ~onditJonil~g the Prop,e, rty~ next to attorney's ~sI and finally to the
oufe~ndinl~ P~ci~al Balance '~'~ accrued finance charge and other charges
I owe. You are entitled to costs tepi'e~h~l actual, necessary and
~pqabl~ ~pecees you incur in retaking, storing and repairing the Property
n yo'u repossess the Property without legal process. You will not be
entitled to such costs, however, unfess you ha..v~lme~the,,at~tft law
requirements entitling you to such costs. You will, pa~/'~ne ar{~ b~iance
remaining or pay it as othenvise provided by law. I am liable for any
da ,fic.~, ~,o~. ~nay take poseession of any other property of mine, or of any
oth~' para,ri, Iocatsd in or on the Property at the time of repeseesston If
permitted by law, you may retain or dispose of any other property belonging to
me or to any other person that is s~, ~lutred. If goods that are personal
property not covered by the security inter,st granted in this Agreement are so
acquimcl, ~ will advise you of the presqnc~,of such other goods within five days
of the date of repossession of the P~l~eYt,,' VVhen you receive such notice,
you will search the Property. If you lecats such other goods, you will hold
them for five business days. During such time I may take possession of such
other goods, tf I fail to notify you withle the required period and take
ixmsession of the other good~ att~r~ polity you, you may dispose of such
offer goods in a commerclafly~reasbriable manner If you elect to salt such
goods at auction, you will c~eqit my account with the sale proceeds, minus
your costs of sale. If such other goods appear to you to be of nominal value,
In addition to the foregoing y~ may exercise any and all dghts of a secured
pedy under applicable laws. Your' representative may take any action you are
authorized by this Agreement to ~ke.
If you repo&..~ss the prope~'ty,, I have certain legal rights. This paragraph
contains a summary of my principal legal rights; I acknowledge that I may
have other and broader rights ~'n these. Upon repossession through legal
process, I shal~ have such dghta, ~ece~ve such notices, and be liable fo= c~t6
of suit (including reasonable attorney's fees) as the cour~ may dete~i~e ' If
separate written agreement to that effect, and you sign such separate
agreement and accept such check or draft If you remedy my default in order
to protect your interest, such remedy shall not cure the default You may
proceed to enforce all your dghts available upon default. No transfer, renewal,
extension, or assignment of this Agreement, or any interest in it, and no loss,
damage or destruction of the Property shall rdl~dse me from my obligation
under this Agreement
?. Rules of Intsrpretatfon. This Agreement is made in the State of
Pennsylvania. Pennsylvania iow and federal law shall govern this Agreement
This Agreement constitutes our entire agreement. You and we can change
this Agreement only in a writing we sign. If applicable law prohibits any part of
this Agreement, such part shall be ineffective to the extent of such prohibition
without invalidating any other pert of this Agreement. All words in this
Agreement shall be construed to he of such number or gender as the
circumstances require Headings of the numbered paragraphs of this
Agreement are for convenience only. They shall not be deemed part of this
Agreement,
NO REPRESENTATION, PROMISE OR WARRANTY, EXPRESS OR
IMPLIED, HAS BEEN MADE wrrH RESPECT TO THE
MERCHANTABILITY, BUlTABILrFY OR FITNESS FOR A PARTICULAR
PURPOSE OF THE 60008 OR OTHERWISE UNLEBB THE SAME IS
ENDORSED H~RI~qN IN WRITING OR IS CONTAINED ON A SEPARATE
WRii i =~ ~NSI'RUMENT SIGNED BY THE DEALER.
The following two sentences apply only if the agreement is for the sale of a
used vehicle. THE INFORMATION YOU BEE ON THE WINDOW FORM FOR
THIS VBI#IG~.E IS PAR~OF THIS CONTRACT. INFORMATION ON THE
WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE
CONTRACT OF BALE.
GUARANTY
In consideration of the making and acceptance of this Installment Sale
Agreement (the "Agreement'*} by the Buyer and Dealer, respectively,
Guarantor (jointly and severally, if more than one) unconditionally guarantees
to the holder of the Agreement ("Holdet'') the payment of all sums due or to
become due under the Agreement, and the full perfon'aanc~ by Buyer of all
promises and covenants in the Agreement. Guarantor agrees (despite
anything in the Agreement to the contrmy) upon any default by Buyer, to pay
upon request to Holder the entire unpaid Phncipal Balance, together with all
lawful charge~ T'~'diecharge or re~ase of Buyer by operation of law or
otherwise wi~l,~ot,~e~t the liability of the Guarantor. This Guaranty shall be
fully binding de~plte any lack of capacity or liability on Buyers part. The
the Guaranto[ Any transfer or assignment of Holder's interest in this
Agreement will not affect the liability of the Guarantor.
Guarantor consents to all extensions of time for the making of any or all
payments by Buyer, and further guarantees the payment of ali sums due by
reason of such extensions. Guarantor expressly waives notice of acceptance
of this Guaranty, notice of assignment, notice of nonpayment, notice of
amount of ledebteqnese outstanding at any time, protest, demand and
prosecution of collecbon, foreclosure and possessory rerneqles
UViLT~IESS the signature(s) of Guatan~t~r(s) orl ~ !!
redeem the property. The statement will itemize the amount required to
reiterate ~ ,-edeem. The statement will also give me notice of your intent to Guarantor
resell, the property at the end of 15 days from the date you mell the notice,
tellr~l me'wflere the Property is stored~ The statement will also tell me the
DEALER'S ASSIGNMENT
Seller sells and assigns to the Assignee named below all of its right, titie'a~l~
interest in this installment Sale Agreement ("Agreement").
Seller represents, warrants and covenants to Assignee that: (a) (i) no
statements made or furnished to Assignee by Buyer or any Co-Buyer
(collectively "Buyer"), Seller or any ether person are untrue or incomplete; (ii)
Buyer has not financed the down payment of the Property; (ii) Bwer is a bona
fide applicant having legal capacity to enter into the Agreement; (iv) Buyer's
signature on all documents is genuine; and (v) the amount stated in the
Agreement to he due will in fact be due and payable at the time or times
provided therein free of any claims, defenses, setoffs or counterclaims; (b)
Seller has verified Buyer's identffication; (c) the down payment for the Property
is paid in full with negotiabid funds; (d) Seller has sold the Property daschhed
Jn the Agreement and the process of the Agreement are to be used to pay fur
such Property and related items; (e) Seller had indefeasible title to the
Property immediately pdor to the purchase ~,, Suyer, and the dght and
authority to sell the Property to Buyer, frae and clear of all liens and
encumbrances; (f) Seller has the authority to assign the Agreement to
Assignee free and crear of all liens and encumbrances; (g) Seller will secure
and perfect for Assignee a security interest in the Property free and clear of all
liens or encumbrances, and deliver to Assignee evidence satistecto~y to
As.qignee of sc,ch security iqt~rest .wJthir~ six months ,ol' the, date of the
Ag~e~llelt~ (h)the d~e~ti6h ~Sf t~ II~o~e~'y'i~ trite ~lnd P~omp~et~' ih' the
Agreement and the PropeAy will he or has been duly delivered to and
accepted without revocation by BuyerL, (il :insUrance or other coverage
provided or arranged by Seller does qpt viqlate any applicable law or
regulation and insurance documentatiori ~ re~tes of unearned premiums, if
any, will be delivered to Buyer by Seller within the time required by law; (j) the
Property is insured by a company acceptable to Assignee against fire, theft
and collision, Assignee is loss payee and written evidence of such insurance
has been or will promptly be provided to Assignee; (k) all optional credit
insurance sold by Seller to Buyer is for the full term of the Agreement and is
limited to coverage of Buyer; (I) Seller has provided Buyer with a completed
Agreement and any other document required by apelicable law, and the
information filled in thereon by Seller is accurate and complete; (m) Seller is
licensed to the extent required by law; (n) Seller has complied with all
applicable transaction reporting requirements including, without limitation, the
requirement under Section 60501 of the Internal Revenue Code and its
implementing regulation (as they may be amended from time to time) to report
cseh receipts of more than $10,000; (o) Seller has complied with As$ignee's
procedures regarding the Fair Credit Reporting Act (FCRA) including, but not
limited to, the following: (i) Seller has only submitted to Assignee credit
information on Buyer after Buyer's signatures were obtained on a credit
apptisation acceptable to Assignee ("Application"); (ii) Seller has not submitted
any ~'edit information on any individual whose signature does not appear on
the Application (except to the extent permitted by law, information on a non-
apelisant spouse pursuant to applicable community property or similar laws);
(iii) Seller has advised Buyer that his/her Apptioafion has been submitted to
A~ignee at Assignee's current address; and (iv) Seller has advised Buyer that
c~edit was approved by Assignee; (p) Seller has compiled with
requiramente of the FRCA and ECOA and all other federal, state and local
~vs, rules and regulations that apply to the extension of credit and consumer
profeddon or that otherwise apply to the sale of the Property; (q) Seller will
promptly kxward to the proper authorities all federal, state and local fees and
taxes due in connection with the sale of the property; (r) Seller does not
~ ,rgR~qxer,fo.r, filing fees or other costs paid by Seller to public officials to
pon'eot Assignees security idtereat in the PropeAy, except where allowed by
law, nor does Seller make any type of charge, including documentary or
prosasaiog charges, which Seller does not make in a cash transaction; and (s)
all charges thee Seller is required by law to disclose in the Agreement are
· ccuretely disclosed.
E~~ ;~ ~ warranties, representations and covenants is matedal to
Aselgoee's acceptance of this Agreement If any of them is breached or is
erroneous, Seller unconditionally promises to accept reaseignment of this
Agreement, without recoume against Assignee, and to pay Assignee, upon
demand (1) the unpaid balance of the Agreement as determined by Assignee,
(2) ~[ losses and expenses incutTed by Assignee as a result of such breach or
ur~lhJth, a~l~ (3) out-of-pocket expenses paid or incuned by Assignee in
connection with the collection of any amount due under the Agreement,
including attorney's fees and costs of litigation, whether by or against
Assignee, and expenses with respect to reposeessleg, storing, repainng and
selling the Property. In addition, Seller shall indemnity Assignee in the
manner and to the extent sPe~fidd in the preceding sentence it Assignee
suffers a ross or expense in any judicial or administrative proceeding because
of any claim or defense asserted against Assignee as a result of any act or
omission on Seller*s bert. If this Agreement is rescinded by court order, Seller
shall pay Assignee the amount specified in this paragraph
Seller shall be liable even if a waiver, compromise, settlement or variation of
the terms of the Agreement releases Buyer,
This assignment shall bind Seller's heirs, representatives, successors and
assigns and shall inure to the benefit of the successors and assigns of
Assignee. Seller waives notice of acceptance of this guarantee and
assignment, notices of non-payment and nomperfon'nanse and air other
notice~ that may he waived in connection with a transaction of this kind
This assignment is without recourse against Seller except as provided in this
Agreement or in another agreement, if any, between Seller and Assignee
relating to th~ fina@~:ing,or purcha.~e=f retai JpfitalJ~en contracts . ~
named assignee.
DEALER'S GUARANTY
Check [] Intfidl! [I I ',, !; Deaidr u~conditionally guarantees the payment of
all monies due Or to become due under the Agreement. Deetsr agrees, upon
default by Buyer, to pay Bank upon demand the unpaid portion of the Principal
Balance and all amounts owing under this Agreement.
DEALER'S REPURCHASE AGREEMENT
Checkr''l Initial__ In the event Bank shall elect to repossess the
Property, Dea~er wilr, upon request, repurchase the Agreement from Bank for
an amount equal to: (i) the unpaid Pdncipel Balance, plus (ii) all amounts
owing under the Agreement on the date of the repurchase plus (iii) an amount
equal to all losses and expenses incurred by Bank in connection with such
repossession that are not incJuded within items (i) and (ii), Dealer shall bear
sole responsibility for resale of the Propel"y, sending all notices to Buyer and
to others required by law, and disbursement of any surplus received from such
sale to Buyer as required by law.
DEALER'B UMITED REPURCHASE AGREEMENT
CheckE] Initial The above Dealeds Repurchsee Agreement is
hereby assumed and inco~orated heroin by reference, as it fully set forth
herein, provided that Deaidr's obligation shall terminate upon payment to Bank
by Buyer of the first reguidr monthly installments if
mede within 30 days of their respective due dates.
PARTIAL RECOURSE
Check• Initial Dealer unconditionally guarantees that if Buyer is
in default ~in~ the payment of any amount remaining to be paid under the
Agreement, Dealer will pay, upon demand by Bank, any amount up to the sum
of$ _
Ch~lt[~. initi.I ~f Wn'HOUT RECOURSE
The Assignment of the Agreement shall be without
recourse against Dealer, except as provided in •eater's Assignment and as
provided in the Dealer Agreement. However, Dealer unconditionally
guarantees the payment of any itmgular or "pickup" payment, except the final
scheduled payment, due or to become due under the Agreement.
PA 90031A
P O Box 1661
Baltimore MD 21203 1661
0 Pmvidonl
BANK
F~eceipt for CerZifiect Mail
KEITB A BURKHOLDER
600 N MIDDLE RD
NEWVILLE PA 17~41-8638
October ~6, 2000
RE:
Installmer* Agreement dated 05/08/00
Collateral goods: USKD 96
(the "Vehicle")
Loan Account nmlber: 97057302
covering the following
DODG 1B7HCl&¥4TJ128771
2.89
Dear Customer:
The Installment Sale Agreement referred to above is in default because you
have failed to make the following payment(s):
$.00 due on
$349.06 due on 10/07/00
$349.06 due on 09/07/00
Total Amount Past Due: $705.10 includes late charges.
and/or have failed to comply with the following provisions of the Agreement.
This letter is to notify you that the Vehicle described above will be
repossessed unless the Total Amount Past Due set forth above (together with
any other installment which may become payable in the meanwhile) is paid
within ten (10) days of the date of this Notice.
It is imperative that ~he default be cured without delay so that you can,
among other things, avoid becoming liable for the expenses of retaking and
storing the Vehicle. If the Vehicle is repossessed, the Bank will deliver to
you or send to you by certified mail a notice describing the conditions under
which the Bank may permit you to redeem the Vehicle, details as to the resale
of the Vehicle, your liability for any deficiency, the location of the
Vehicle, and the address as to where payments should be aade.
Any payment or notice you deliver Bust be identified by your name and account
number and be delfvered to the Installment Credit/Collection Division,
Provident B~ of Maryland, 7210 Ambassador Road, Baltimore, Maryland 21244.
=-all~4
· Pmvidan!
BANK
March 7, 2001
Receipt for Certified Mail
Oo not use tot International Mail (See reverse)
SIMPLE INTEREST PROCEEDS
Keith A. Burkholder
7 N. Corporation Street
Newville, PA 17241
Re: 97057302
Dear Mr. Burkbolder:
This is to advise you that your 1996 Dodge. serial number 1B7HC16Y4TJI28771, was
sold on 12-21-00 for a gross amount of $8.700.00. These proceeds were applied as
follows:
APPLICATION OF PROCEEDS
TO COSTS OF SALE:
Amount of sale
Less:
Cost of Preparation and Sale
Cost of Repossession
Cost of Storage
Cost of Transporting
$8,7OO.O0
187.50
275.00
90.00
145.00
TOTAL
$8,002.50
Credit for Insurance claims/cancellations
Net Proceeds
1,795.07
$9,797.57
TO BALANCES AS OF DATE OF REPOSSESSION
BALANCE
NET PROCEEDS
Late Charges $27.92 S27.92
Interest 436.48 436.48
Principal 15,110.79 9,333.17
REMAINING
BALANCE
$0.00
0.00
5,777.62
TOTALS $15,575.19 $9,797.57 $5,777.62
S:~LOANOPS\LOA\SHELLS~F I 15S.DOC
· Pmvidonl
BANK
Page Two
CURRENT TOTALS
Remaining Balap,'~ (as of 3-9-01)
Per Diem (daily interest) from date of letter
$5,777.62
$ 0.95
As you can see from the above, your total due today is S5,778.57. Your current
percentage rate of interest will be 6% as of the date of this letter in the amount of S0.95
per day. Under the terms of your contract, you remain responsible for payment of this
current total plus interest that is assessed from the date of this letter.
Should you wish to pay the remaining balance due within two (2) weeks, we will waive
any interest that may accrue and accept the remaining balance of $5,777.62 as full
settlement of the debt. On the other hand. if the full amount cannot be paid in one ( 1 )
installment within the two (2) week time period, your outstanding balance will accrue
interest at the rate of 6% per annum. Failure to respond to this letter in the allotted two
(2) week time span may result in the referral of your account to our attorney for
appropriate legal action.
Shculd you wish to discuss this matter further, do not hesitate to contact the writer at the
number listed below.
Sincerely,
Donald A. Plott
Sr. Loan Counselor
(410)277-7957
DAP/nla
S:~LOANOPS\LOA\SHELLS~FI I5S.DOC
· Pmvidan!
BANK
March 7, 2001
Receipt for Certified Mail
SIMPLE INTEREST PROCEEDS
Keith A. Burkholder
600 N. Middle Road
Newville, PA 17241
Re: 97057302
Dear Mr. Burkholder:
This is to advise you that your 1996 Dodge, serial number I B7HCI6Y4TJI28771, was
sold on 12-21-00 for a gross amount of $8.700.00. These proceeds were applied as
follows:
APPLICATION OF PROCEEDS
TO COSTS OF SALE:
Amount of sale
Less:
Cost of Preparation and Sale
Cost of Repossession
Cost of Storage
Cost of Transporting
S8,700.00
187.50
275.00
90.00
145.00
TOTAL
$8,002.50
Credit forInsurance claims/cancellations
Net Proceeds
1,795.07
$9,797.57
TO BALANCES AS OF DATE OF REPOSSESSION
BALANCE
NET PROCEEDS
Late Charges $27.92 $27.92
Interest 436.48 436.48
Principal 15,110.79 9,333.17
REMAINING
BALANCE
$0.00
0.00
5,777.62
TOTALS $15,575.19 $9,797.57 $5,777.62
S:~LOA NOPS~LOA\S HELLSkF 115S.DOC
Pfovidl n!
BANK
Page Two
CURRENT TOTALS
Remaining Balance (as of 3-9-01 )
Per Diem (daily interest) from date of letter
$5,777.62
$ 0.95
As you can see/'rom the above, your total due today is $5,778.57. Your current
percentage rate of interest will be 6% as of the date of this letter in the amount of $0.95
per day. Under the terms of your contract, you remain responsible for payment of this
current total plus interest that is assessed from the date of this letter.
Should you wish to pay the remaining balance due within two (2) weeks, we will waive
any interest that may accrue and accept the remaining balance of $5,777.62 as full
settlement of the debt. On the other hand, if the full amount cannot be paid in one ( 1 )
installment within the two (2) week time period, your outstanding balance will accrue
interest at the rate of 6% per annum. Failure to respond to this letter in the allotted two
(2) week time span may result in the referral of your account to our attorney for
appropriate legal action.
Should you '-ish to discuss this matter further, do not hesitate to contact the writer at the
number listed beloxv.
Sincerely,
Donald A. Plott
Sr. Loan Counselor
(410)277-7957
DAP/nla
S:Xl OANOPS\LOA\SHELLS\F115S.DOC
BELAIR AUTO AUC21ON
803 BELAIR ROAD
gEL AiR MD
{410) 879-7950
UNIVERSAL KEY
DATE SOLD
LEASE
un_~ RECEi ,'EE
PROVIDENT BANK OF MARYLAND
72]0 AMBASSADOR ROAD
BALTIMORE, MD 2]244
1996 DODGE TK RAM] 800
2228678
9:47:08
PUT BLACK 8G 62902
]BTHC]6Y4TJ]2877~
LNE WO#
32 7228678
SALE PRICE
SELLING FEE
RECON CHARGES
TOTAL CHA~~2S
NET AMOUNT OF CHECK WRITTEN
SUBLET NAME EXPLANATION
KEY CHARGES
85.00
55.00
8,700.00
140.00)
8,560.00
AMOUNT
55.00
TOTAL RECON CHARGES 55.00
Richard & Associates, :Inc.
3999 Spring Road
ShermansDale, PA 17090
'World W/de I,~vest,gat/on
and Repossession Serwce
&nce 1977
Phone: (717) 241-5884
Fax (717!241-6255
Ernafl: marepoCpa net
Provident Bank Of Maryland
7210 Ambassador Road
Baltimore MD 21244
Attention: Mr. Fred Baber
Invoice No.
Invoice Date
Client Name:
PROV-00-112
121512000
Burkholder
Name: Burkholder
Account #: 97057302
Keith
Unit Price Amount
Collateral: Dodge 1500
PIU 1996
YIN: 1B7HC16Y4TJ128771
Description: Storage Invoice
$90.00 $90.00
Invoice
Comments
Charges Began ....... 1111312000
Date R~.eased .......... 1113012000
Days Stored ............ 18
Released To: Car & Truck
We Thank You for Your Business.
Please make check payable to:
Richard & Associates Inc,
3999 Spring Road
Shermans Dale, PA 17090
Amount Due $90.00
/
ichard soc iato, nc.
3999 Spring Road
ShermansDale, PA 17090
-and Repossess,,o'? Service
Since 1977
Phone (717)241-5884
Fax (717/ 241-6255
Ernail rnarepo~pa net
Provident Bank Of Maryland
7210 Ambassador Road
Baltimore MD
Attention: Mr. Fred Baber
2'1244
Invoice No,
Invoice Date
Client Name:
PROV-00-107
1211/2000
Burkhc'~er
Name: Burkholder
Account #: 97057302
Keith
Unit Price Amount
Collateral: Dodge 1500
P/U 1996
VIN: 1 B7 HC16Y4TJ 128771
$145.00 $145.00
Description: Transport
Fee
Invoice
Comments
Transported vehicle to Bel Air Auto Aucton, slot
#175
We Thank You for Your Business.
Please make check payable to:
Richard & Associates Inc.
3999 Spring Road
Shermans Dale, PA 17090
Amount Due /$145.00 'i
Ptic rd & Assoc iate ; '!nc.
3999 Spring Road
Shermans Dale, PA 17090
World W, de
and tRepossesslon
Since 1977
Phone; (717i 241-5884
Fax: (717124!-6255
Emad rnarepo~;oa net
Provident Bank Of Maryland
7210 Ambassador Road
Baltimore MD
Attention: Mr. Fred Baber
21244
Invoice No.
Invoice Date
Client Name:
PROV-00-97
11/13~2000
Burkholder
Name: Burkholder
Account #: 97057302
Keith
unit Price Amount
Collateral: Dodge 1500
PIU 1996
UN: 1B7HC16Y4TJ128771
$275.00 $275.00
Description: Involuntary
Repossession
Invoice Notified Cumberland Co. Community Center,
comments Operator #22,
We Thank You for Your Business.
Please make check payable to:
Richard & Associates Inc.
3999 Spring Road
Shermans Dale, PA 17090
SHERIFF'S RETURN -
CASE NO: 2003-06407 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROVIDENT BANK OF MARYLAND
VS
BURKHOLDER KEITH A
REGULAR
RON KERR
Cumberland County,Pennsylvania,
says, the within COMPLAINT & NOTICE
BURKHOLDER KEITH A
DEFENDANT at 1258:00 HOURS,
at 600 N MIDDLE ROAD
NEWVILLE, PA 17241
K JOANNE BURKHOLDER, MOTHER
a
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 17th day of December
by handing to
together with
true and attested copy of COMPLAINT & NOTICE
2003
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this ~ ~ day of
q--/~,~, .-2 ~ A.D.
~r~thonotary
So Answers:
R. Thomas Kline
12/18/2003
MICHELLE C KAHAN
By: f~t~_ /~-x~---
Deputy Sheriff