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Home My WebLink About08-0560ROBERT M. REIBSTEIN, ESQUIRE, 705 Montgomery Ave. Narberth, PA 19072 (610) 664-1999 ATTORNEY I.D. NO. 20456 CACV of COLORADO 37017th Street, Suite 5000 Denver, CO 80202 VS. Shirley Inman & Robert Inman Indv. & h/w 24 Mountain View Terrace Newville PA 17241 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA NO. 0$ - -r?-D Civ; ? -rrm : CIVIL ACTION 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 claim set forth against you. You are warned that if you fail to do so, the case may proceed 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 HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 debt coiiectu, Ffl',; is ar, tempt to C01100 a debt and ,9ny information obtained will 6e used for that pur;, --, ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456 CACV of COLORADO 37017th Street, Suite 5000 Denver, CO 80202 VS. Shirley Inman & Robert Inman 24 Mountain View Terrace Newville PA 17241 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNA NO: o f - 5G o C'u,?l ??~~ COMPLAINT 1. Plaintiff, CACV of COLORADO, Assignee of Household Automotive Finance is a limited liability company doing business at 370 17th Street, Suite 5000, Denver, Colorado. 2. Defendants, Shirley Inman & Robert Inman, individually and as h/ware an adult individuals residing at 24 Mountain View Terrace, Newville PA 17241. 3. On or about September 27, 2000, Defendants entered into a written Pennsylvania Motor Vehicle Installment Sale Contract with Diehl Toyota of York, PA, which was contemporaneously assigned to Household Automotive Finance Corporation for the purchase of a 1995 Ford Explorer calling for Defendants to make sixty (60) monthly installment payments of $449.73 each. A true and correct copy of said written Pennsylvania Motor Vehicle Installment Sale Contract is attached hereto made part hereof and marked as Exhibit "A" in it's entirety. 4. Defendants breached the terms of said written agreement by failing to make payments when due entitling Household Automotive Finance Corporation to repossess said vehicle. Said vehicle was repossessed on or about August 12, 2004 whereby Defendants were given notice of Repossession, Right to Redeem and Notice to Sell Property by certified mail on or about August 16, 2004. A true and correct copy of the Certified Mail Receipt is attached hereto made part hereof and marked as Exhibit "B". 6. After Defendants failed to exercise their right to redeem the subject vehicle, it was sold at public auction on or about October 11, 2004 for a net sale price of $2,700.00 whereby there remained a deficiency balance of $6,606.14. True and correct copy of the Public Auction Sale documents are attached hereto made part hereof and marked as Exhibit "C" in their entirety. 7. On or about December 2, 2004 for value received, Household Automotive Finance Corporation did sell and assign all it's right, title and interest in said Pennsylvania Motor Vehicle Installment Sale Contract to Plaintiff A true and correct copy ofthe Notarized Certificate for Purchase is attached hereto made part hereof and marked as Exhibit "D". 8. As per Exhibit "A", Plaintiffis entitled to continuing finance charges at the annual rate of 20.95% on the unpaid principal balance claimed in the amount of $4,432.55 and continuing at the rate of $3.79 per day. 9. After repeated demands, Defendants have failed and refused to pay all or any part of the principal balance due and owing Plaintiff. WHEREFORE, Plaintiffdemands judgment against the Defendants m the sum of $11,03 8.69 plus interest from the date of the filing of this complaint and record costs. Robert M. Reibstein, Esquire Attorney for Plaintiff RETAIL INSTALLMENT Seller Buyer SHIRLEY INMAN CONTRACT DIEHL TOYOTA INC ROBERT INMAN AND SECURITY Address Address AGREEMENT 1985 WHITEFORD RH 24 MOUNTAINVIEW TERRACE No. YORK PA 17402 NENVILLE PA 17241 Date SE P 27 Lh, 20 OSeller means the Seller above and anyone to whom the Salver transfers this Contract. Buyer means each Buyer above. SALE: Buyer awes to purchase the motor vehicle (Vehicle) and services described below from Seller. Buyer agrees to purchase the Vehicle from Seller on the terms of this contract and security agreement (Contract). Buyer understands that Seller to selling Buyer the Vehicle in its present condition. Description of Year 1995 VIN IFM01134X4SUA34822 Other. Motor Vehicle Make FORD Lic.NoJYear Purchased Model EXPLORER ? Now [J]Used Description of Trede-in 1995 CHEVROLET ASTRO IGBDM19WZ58270765 1986 CHEVROLET BLUER PROMISE TO PAY AND PAYMENT TERMS: Buyer promises to pay Serer the principal amount of $ 16497.17 .Buyer agrees to pay finance charges on the unpaid balance at 20.95 % per year from today's date until maturity. Finance charges accumulate on a 365 day basis. After maturity or after Buyer brooks any of the terms of this Contract or after a court Judgment Seller will earn interest on the unpaid balance at Cu . 95 % per year. Buyer agrees to make payments and to pay late charges as provided in the TRUTH IN LENDING DISCLOSURES. Buyer also agrees to pay any additional amounts according to this Contract's terms. ? MINIMUM FINANCE CHARGE: Buyer agrees to pay a minimum finance charge of $ N/Af Buyer pays this Contract in full before Seller has earned that much in finance charges. DOWN PAYMENT: Buyer agrees to pay or apply to the Cash Price, by the date of this Contract, any cash, rebate and net trade-in value described in the ITEMIZATION OF AMOUNT FINANCED. ? Buyer agrees to make payments over an extended period of time or at a future date as part of the. cash down payment as shown in the payment schedule in the TRUTH IN LENDING DISCLOSURES. TRUTH IN LENDING DISCLOSURES ANNUAL FINANCE AMOUNT TOTAL OF PAYMENTS TOTAL SALE PRICE PERCENTAGE RATE CHARGE FINANCED The amount Buyer win The total cost of Buyers The cast of Buyers credit The dour amount The amount of credit have paid when Buyer purchase on credit, including as a yearly rate, the credit provided to Buyer or has made all scheduled Buyers down payment of will cost Buyer. on Buyers behalf. payments. 2906.31 2095 % $ 1006 F.: 9 16497.0 S 26983.80 2989011 Paymerd Schedale: s payinent schedule is Number of Payments Amount of Pa nts When Payments Are Due 60 41i9.73 fIONFHLY, BEGINNING: NOVEMBER lath, 2000 Security: Buyer is giving Seller a security interest in the Motor Vehicle purchased. ?Nete Chwo: If a payment is more than 10 days late, Seller will charge Buyer "2% OF PAYMENT DUE PrOM1111eftt• If Buyer pays off this Contract early, Buyer ? may ? wli rat have to pay a Minimum Finance Charge. COntrid Pr0VW0 ne: Buyer can see the terms of this Contract for any additional Information about nonpayment, breaking the terms of thi ntr C i d f t t b th h l n d s o ac re , a y requ repaymen e ore e sc e u ed date, and prepayment refunds and penalties. BUYER RESifgCT1ONS: If Buyer does not most this Contract's obligations, Buyer may lose the property that Buyer bought in this sale. SECURITY: Buyer gives Seller a security interest in the Vehicle. Buyer also gives Seller a sewdty interest in all attachments, accessories, and equipment installed or placed in or on the Vehicle. Seiler refers to the Vehicle and any items installed or placed in or on the Vehicle as Properly. Buyer also gives Seller a security Interest In the proceeds of the Properly. Seller's interest will rot extend to consumer goods unless r acquires rights to the goods within 10 days after Sour enters Into this Contract or the goods are installed in or affixed to the eNde. Buyer assigns and gives a security interest in proceeds and premium refunds of any insurance and service contracts purchased with this Contract. CREDIT INSURANCE: Credit life insurance and credit disability insurance are not required to obtain credit Buyer will not receive ceedlt life insurance and credit disability insurance unless Buyer signs and agrees to pay the additional premium. N Buyer waft such insurance, Seller will obtain it for Buyer (if Buyer qualifies for coverage). Seller is quoting below ONLY the coverages Buyer has chosen to purchase. See Notice of Proposed insurance on page 2. Credit Lds: Insured ? Single ? Joint premium $ N/ATermNIA Credit Disability: Insured ? Single ? joint Premium $ N/ATerm N/A Name of Insurance Company: Buyer wants the credk insurance coverages Indicated above. Buyer dPoJb Buyer Blob ITEMIZATION OF AMOUNT FINANCED Motor Vehicle Price (ind. sales tax of $ 451.98 ) S Service Contract, Paid to: I NTERSTA $ Amount to Finance line e. (if e. is negative) $ N / Cash Price $ 19%H4 . 9'. Manufacturers Rebate $ NIA Cash Down Payment $ 400- UO Extended Down Payment $ NIA a. Total Cash/Rebate Down $ 400.0(1 Description of Trade-in •1995 CHEVROLET ASTRO b. Trade-in Allowance $ 11300.00 c. Less: Amount owing $ 8793.69 Paid to: CONSUMER PORTFOLIO 5FRVICFI: d. Net Trade-In (b. minus c.) $ 2 506 31 a. Net CasWrade-In (a. plus d.) $ 2906.31 Down Payment (e.; disclose $0 if negative) $ 2906 Unpaid Balance of Cash Price $ 113378 G. Paid to Public Officials $ `?f? ti( Insurance Premiums' $ N Filing Fee $ 01 EXHIBIT "A" RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMENT Ili- TOTAL SALE PRICE: Sonar gave Buyer the opportunity to purchase the Vehicle and described services for the Cash Price or the Total Sale Price. The Total Sob Price is the total price of the Vehicle and any services it you buy them over a period of time. Buyer is purchasing the items over a period of time. The Total Sale Prbo shown in the TRUTH IN LENDING DISCLOSURES assumes that Buyer will make all payments as scheduled. Buyer may actually pay more or less depending on when Buyer makes payments. Seller charges and collects finance charges. These charges are not more than state or federal law allows. If Buyer pays a finance charge or fee that is more than state or federal law allows, Seller will apply the charge or fee first to reduce the principal and refund any excess to Buyer. Buyer understands and agrees that some payments to third parties as a part of this Contract may involve money retained by Seller or paid back to Seller as cdmmissions or other remuneration. PREPAYMENT: Buyer may prepay this Contract in full or in part at any time. Any partial prepayment will rat excuse arty later scheduled payment until Buyer pays this Contract In full. Buyer may obtain from Seller or the insurance company mired in Buyer's policy or certificate of insurance a refund of any prepaid unearned insurance premiums. BUYER'S RESPONSIBILITIES TOWARDS PROPERTY: Buyer agrees to do the following: A. Buyer will defend Seller's security interest in the Property against anyone who claims to have an interest in the Property. Buyer will do whatever is necessary to keep Seller's claim to the Property ahead of the claim of anyone else. Setter's claim to the Property comes ahead of the claim of any of Buyer's other creditors. Buyer agrees to sign any additional documents and to provide Seller with any additional Information Seller may require to protect Senses security interest in the Property. B. Buyer will keep the Property In Buyers possession and in good condition. Buyer will only use the Property for Its Intended and lawful purposes. Unless otherwise agreed in writing, Buyer will keep the Property at Buyer's address listed on this Contract C. Buyer will not put the Property up for sale without written permission from Seller. Buyer will not transfer any rights in the Property without first getting Seller's written permission. D. Buyer will pay taxes, fees and expenses on the Property when due. Buyer will nobly Seller of an loss or damage to the Property Buyer will provide Seller reasonable access to the Property for the purpose of inspection. Seller may lawfuly, enter and inspect the Property. BREAKING THE TERMS OF THIS CONTRACT: Buyer agrees that the following are additional terms of this Contract. Buyer will have broken the terms of this Contract it one or more of the following occurs (except as prohibited by law): A. Buyer falls to make a payment due under this Contract B. Buyer dies. C. Buyer is involved in any insolvency or bankruptcy proceedings- D. Buyer fails to keep the Property insured, If required. E. The Property is substantially damaged, destroyed or stolen. F. Buyer uses the Property in violation of any rule, regulation or government order. G. The Property is taken by arty government authorldea. H. A money judgment or tax ken Is filed against Buyer. 1. Any of Buyer's property is subject to legal proceedings used to pay for a court ort r for a money judgment. J. Buyer makes any written statement or provides any financial information to Seller that is untrue or inaccurate. K. Buyer permits any Interest in the Property to become above or greater than senses interest in the Property. L. Any of Buyer's other creditors make the entire debt owed due immediately. M. A court order for a money judgment or a money judgment against Buyer becomes final. N. B or fails to keep any promise made in correction with this sale. If Buyer breaks arty of the terms of this Contract, Buyer agrees to pay court costs Seller spends to coked amounts Buyer owes. In addition, Buyer agrees to pay reasonable atiomeys' fees if Server refers this Contract to an attorney for collection. If there is more than one Buyer and any one of the Buyers breaks any agreement made in this Contract, Seller may exercise Setter's rights against each Buyer or all Buyers. SELLER'S RIGHTS: If Buyer breaks any of the terms of this Contract, Seller may exercise arty or all of Sonees rights under law and this Contract: SellSerellmay take any or all of the actions described above. ers decision not to take any of the actions does not mean that Seller has lost the, right to take any of the actions in the future.' In addition, Seller may require Buyer to pay Seller immediately, the remaining balance of the amount financed, finer= charges and all other agreed charges 0 Buyer does any of the following: A. Buyer falls to pay one or more Installment payments under this Contract. B. Buyer falls to pay taxes Wed against the Property. C. Buyer fails to furnish proof of payment of taxes levied against the Property. D. Buyer uses the Property for illegal purposes. Seller will mail to Buyer's last known address any required notice of an Intended sale or transfer of the properly. r agrees that notice Is reasonable If mailed to Buyer's leaf address, as reflected in Seller's records. Buyer agrees that notice mailed ten days before the intended sale or transfer (or such other period of time required by law) is reasonable. Buyer agrees that Seller may take personal property left in or on the Properly subject to Buyer's right to recover the personal property. INSURANCE: Buyer agrees to buy Insurance on the Property against the risks and for the amounts Seller reasonably requires. In addition: A. Buyer win name Seger as foss payee on any such policy. B. Seger may require added security on this Contract if Soler permits arty Insurance proceeds to be used to repair or replace the Property. C. If the Insurance proceeds do not cover the amounts Buyer still owes Seller, Buyer will pay the difference. D. Buyer win keep the Insurance until all debts secured by this Contract are paid. If Buyer does not buy, maintain, and arrange to have Seller named as loss payee, as agreed above, Buyer understands and agrees: A. Seiler may, but is not required to, purchase Insurance to protect Sellers interest in the Property. B. The insurance Seller buys may be from an agent or company Buyer might not choose. C. The insurance will not cover Buyer's equity in the Property. The premium Seller pays may be substantially higher than the premium Buyer might be required to pay for the Insurance Buyer has agreed to buy on this Contract. RESUMING CONTRACT: If Senor has taken back the Property, Seller may return this Contract to Its former status and return the Property to Buyer. Seller will return this Contract if Buyer pays all past due installments, interest Buyer currently owes, plus any other charges or amounts lawfully due to Seller under this Contract Buyer agrees to pay for the costs of a lawsuit if Seger takes the Property through legal action. At the time Seller takes the Properly Buyer must pay the expenses for taking, repairing, and storing the Property as allowed by law. Seller may only collect expenses from Buyer if more than 15 days passed from the day Buyer broke the terms of this Contract to the day Seller took the Property. EACH AND EVERY BUYER RESPONSIBLE: Each Buyer who a" this Contract agrees to pay this Contract according to its terms. This means the following: A. Buyer Is responsible for paying amounts owed under this Contract even if another Buyer,has signed this contract. 0. Seger may hold arty Buyer responsible for paying this Contract, even R Sailer chooses to give up Seller's right to hold any other Buyer responsible. C. Seiler may give up Seller's Interest in the Property and each Buyer is still responsible for paying this Contract. D. If Seller gives up any of Seller's rights, it will not affect Buyers responsibility to pay this Contract. , . r E. If Sailer extends new credit or renews this Contract, it will not affect Buyer's responsibility to pay this Contract. WARRANTY: Warranty information is provided to Buyer separately. NOTICE OF PROPOSED INSURANCE: If so indicated on the front of this Contract, credit life insurance coverage and/or reedit accident and health insurance coverage will apply to this Contract. The Insurance company named on the front of this Contract will write the insurance. The Insurance covers only the person(s) signing the request for Insurance. The charge for each type of credit Insurance to be purchased Is as indicated on the front of this Contract. The term of insurance will begin as of the date of this Contract and will and on tin original due date of this Contract. Subject to acceptance by the insurance company and within 30 days, a certificate of insurance will be given to the insured. It this Contract Is prepaid before It is due. a refund r r. e...a..ro nhamaa will ho mina when (tin 'A. Buyer fails to make a payment due under this Contract. B. Buyer dies. C. Buyer is involved in any insolvency or bankruptcy proceedings. D. Buyer fails to keep the Property Insured, K required. E. The Property is substantially damaged, destroyed or stolen. F. Buyer uses the Property in violation of any rule, regulation or government order. G. The Property is taken by any government authorities. H. A money judgment or tax lien is filed against Buyer. 1. Any of Buyer's property is subject to legal proceedings used to pay for a court otter for a money judgment. J. Buyer makes any written statement or provides any financial information to Seller that is untrue or Inaccurate. K. Buyer permits any interest in the Property to become above or greater than Seller's interest in the Property. L. Any of Buyer's other creditors make the entire debt owed due immediately. M. A court order for a money judgment or a money judgment against Buyer becomes final. N. Buyer fails to keep any promise made In connection with this sale. If Buyer breaks any of the terms of this Contract, Buyer agrees to pay court costs Seller spends to collect amounts Buyer owes. In addition, Buyer agrees to pay reasonable attorneys' fees If Seller refers this Contract to an attorney for collection. ff More is more than one Buyer and any one of the Buyers breaks any agreement made in this Contract, Seger may exercise Seller's rights against each Buyer or all Buyers. SELLER'S RIGHTS: If Buyer breaks any of the temps of this Contract, Sager may exercise any or all of Seller's rights under law and this Contract: A. Seller may pay taxes, fees, expenses, or charges on the Property or make repairs to the Property If Buyer has not done so. Seger is not required to do so. Seger will add any amount Seller pays to the amount Buyer owes Seller. This amount is due Immediately. This amount will earn interest from the date Seller paid t at the rate that applies after maturity. B. Seller may require Buyer to make the Property available to Seger at a place Seller designates that is reasonably convenient to Buyer and Seger. C. Seller may immediately take back the Property by lawful means. In taking the Property. Seller may not unlawfully enter onto Buyer's premises or cause a public disturbance. Seller may sal the Property. Seller may apply amounts Seller receives as provided by law to Seller's reasonable expenses and then to Buyer's obligations. D. Except when prohibited by law, Seger may sue Buyer for additional amounts If the proceeds of a sale do not pay all amounts Buyer owes Seller. takes the Property, Buyer must pay the expenses for taking, repairing, and storing the Properly as allowed by law. Seller may only coaled expenses from Buyer it more than 15 Contract pto the assed df from ter caoyk Bthe uyer broke the terms of this day Property. EACH AND EVERY BUYER RESPONSIBLE: Each Buyer who sighs this Contract agrees to pay this Contract according to its terms. This means the following: A. Buyer is responsible for paying amounts owed under this Contract even If another Buyer has signed this Contract. B. Seger may hold any Buyer responsible for paying this Contract, even If Seller chooses to give up Seller's right to hold any other Buyer responsible. C. Seger may give up Seller's interest in the Property and each Buyer is still responsible for paying this Contract. D. If Sheller gives up any of Setter's rights, it will not affect Buyer's responsibility to pay this Contract. E. If Seller extends new credit or renews this Contracl, it will not affect Buyer's responsibility to pay this Contract. WARRANTY: Warranty information is provided to Buyer separately. NOTICE OF PROPOSED INSURANCE: It so indicated on the from of this Contract, credit life insurance coverage and/or credit accident and health Insurance coverage will apply to this Contract. The. insurance company, named on the front of this Contract will write the Insurance. The Insurance covers only the person(s) signing the request for insurance. The charge for each type of credit insurance to be purchased is as Indicated on the front of this Contract. The term of insurance will begin as of the date of this Contract and will and on the original due dale of this Contract. Subject to acceptance by the Insurance company and within 30 days, a certificate of Insurance will be given to the insured. If this Contract is prepaid before it is due, a refund of insurance charges will be made when due. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF 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. IF BUYER IS BUYING A USED VEHICLE, THE INFORMATION BUYER SEES ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. TRANSFER BY SELLER This section of this Contract allows SNlsr fo transom this Contract to a third parry. This section does not apply to Buyer. Seller transfers to the party listed in the TRANSFER section on this Contract (Transferee) all of Seller's rights, title and Interest In this Contract Seller gives Transferee power, either in Transferee's own name or in Seller's name, to take all actions which Seller could have taken under this Contract. Seger assures Transferee of the following. A. This Contract represents a sale by Seger to Buyer. S. The statements contained in this Contract are true and correct. C. Buyer paid the down payment exactly as stated. D. The sale was completed in accordance with all applicable federal and state laws and reguiation8. E. This Contract is valid and enforosable. F. The names and signatures on this Contact are true and correct. G. This Contract is not subject to any claims or defenses on the part of Buyer. H. Seiler delivered a completely filled-in copy of this Contract to Buyer at the time Buyer signed this Contract. 1. Seller delivered the Vehicle to Buyer in good condition and Buyer accepted the Vehicle. If any of these assurances are broken or untrue, Seiler wig, upon Transferee's request, repurchase this Contract from Transferee. Seller will repurchase this Contract in cash in the amount of the unpaid balance, Including Interest, plus the expenses of Transferee, including atlomeys• fees. Seger will repay Transferee for any loss sustained by it because of a court ordered deduction of the amount Buyer owes Transferee. Seller will repay Transferee for any loss sustained by it as the result of a recovery made against Transferee. Seger gives up Its rights to notice of acceptance of this Transfer, non-payment, rron-performance, or any other notice from Transferee. Transferee may change the terms of this Contract with Buyer and any other person obligated under this Contract. Transferee may do so without notice to Seller and without affecting the legal responsibtgtiss of Seger under this Transfer. WITH LEGAL LIABILITY: If this Transfer is made 'with legal liability' as indicated in the TRANSFER section on this Contract, Transferee takes this Transfer with certain legal rights against Seger. Sager egress that If Buyer falls to pay or perform according to the terms of this Contract, Seger will, at Transferee's request, repurchase this Contract Seger will repurchase this Contract for the amount of the unpaid balance, including finance charges, due at that time. WITHOUT LEGAL LIABILITY: If this Transfer is made 'without legal Iabilty es indicated M the TRANSFER section on this bontr M Transferee takes this Transfer without liability to Seller except as provided above. ,.1 O 19K 1!1!16 eknkM 6y.1 l , I-. SL Cbu1 kW Fm R!14114W-PA WM , 0" 2 012) BUYER RESTRICTIONS: N Buyer does not meet this Contrad's obligations, Buyer may lose the property that Buyer bought M tltis eels. SECURITY: Buyer games Seller a security interest in the Vehicle. Byer also gives Setter a seariry Interest in all attachmeMS, accessories, and equipment installed or placed in or on the Vehicle. Seder refers to the Vehcle and arty items installed or placed in or on the Vehicle as Property. Buyer also gNes Seller a security interest in the proceeds of the Property. Sellers interest wiY not extend to consurler goods unbss Buyer aoqures rights to the pads wiarin 70 days after Seller enters into this Contract or the goods aro MTStalled in or affixed to the Vehicle. Buyer assigns arxi gives a security Interest in proceeds and premium refunds of any Insurance and service oonlrecis purdtased with this Contract. CREDIT INSURANCE: Credit life insurance and credit dsab8ity insurerae are rat required to obtain credit. Buyer will receive redit 1(fe Insurance and crock disability ineurarae not unless Buyer signs and agrees to pa the additional prem for EW er waSByer qubebe dSee of Proposed insurance an page 2. Credit Life: Insured ?Single?JointPremiumS N/ATenn N/A Credit Disability: Insured ? Single ? Joint Premium $ N/ATermN/A Name of Insurance Company: Buyer wants the credit Insurance coverages indicated above. Buyer dlo/b Buyer dblb PROPERTY INSURANCE: Buyer must insure the Property securing this Contract. Buyer may provide the Insurance through existing policies. Boyer may also provide the insurance by purchasing it through any [names company allowed by law to do business In Pennsylvania or In the state in which the Vehicle is registered and titled. The deductible amount for the insurance may not exceed $ NIA . If Buyer gets insurance from or through Seller, Buyer will pay $ N/A for N/A of coverage. The property Insurance premium is calculated as follows: ? Fire-Theft and Combined Additional Coverage $ N/A ?$N/A Deductible, Collision Coverage $ N/A ? $ N/A Deductible, Comprehensive cov. $ NIA The property insurance must protect against loss and physical damage. Buyer must name Seiler as beneficiary on the insurance pokey. Seller may require additional security before Seller allows Buyer to use insurance proceeds to repair or replace the Property. Buyer will pay all amounts that insurance does not cover. If Buyer fails to obtain or keep Insurance or to name Seller as beneficiary. Seller may obtain insurance to protect Seller's interest in the Property. Seiler will add the cost of insurance to the amount Buyer owes Seller. Any amount Seller pays for insurance is due immediately and will earn interest at the rate charged after maturity. ITEMIZATION OF AMOUNT FINANCED Motor Vehicle Price (trxi. safes tax of $ 451 - 'IH ) $ Ii , Service Contract, Paid to: I N T E R ST A$ 1 Amount to Finance line e. (N e. Is negative) $ N /, Cash Price $ 19284 `l1 Manufacturer's Rebate $ N!A Cash Down Payment $ 400.OU Extended Down Payment $ N/A a. Total Cash /Rebate Down $ 400.00 Description of Trade-In 1995 CHEVROLET ASTRO b. Trade-In Allowance $ 11300 00 c. Less: Amount owing $ fiPJ3 69 Paid to: CONSUMER PORTF0110 sFRVTrF1, d. Net Trade-In (b. minus c.) $ 2506 Al e. Net CasWrade-In (a. plus d.) $ Z906 I1 Down Payment (e.; disclose $0 it negative) $ 2906 3 J Unpaid Balance of Cash Price $ 1637A S; Paid to Public Officials S SiR 5f Insurance Premiums' $ N/ Filing Fee $ 5 0 To: $ N! To: DIEHL TOYOTA IN $ 5 n To: $ To: $ N / To: $ N / To: $ N! Total O&W Charges $ 118 5 Less: Prepaid Finance Charges $ N / Amount Financed $ 16497 1 'We may retain or receive a portion of this amount. NOTICE TO BUYER DO NOT SIGN THIS CONTRACT IN BLANK. BUYER IS ENTITLED TO AN EXACT COPY OF THE CONTRACT BUYER SIGNS. KEEP IT TO PROTECT BUYER'S LEGAL RIGHTS. Buyer /' 1i1pc - U9%27/2000 Signature 1 IN MAN Date 4 Sgnaturei UBI NMAN Date Seller. TRANSFER: Sailer transfers this Contract to By MOUSEAOLD 11111ON011111: FINANCE (Transferee) ? ` I al liability? "vithouc legal liability under the tern of TRANSIF BY R section. BY SIGNING BELOW BUYER AGREES Seller. TO THE TERMS ON PAGES 1 AND 2 By Date -_"k4W OF THIS CONTRACT AND ACKNOWLEDGES RECEIVING A COPY OF THIS CONTRACT. Byer: U9127/2000 Signature HIRLE INMAN Date 09/27/2000 nature ROBERT IN AN Data "r1 PENNSYLVANIA RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMENT 0 +885. IM ainWm Sy.Mma.I m.. &. Cbvc. MN Fpm RS-SI-MV-PA $048 OMOTOR VEHICLE - NOT FOR MANUFACTURED HOMES (page f o/2J r IUD '%=L s This Assig?avment is sttsabsd to and cWnssly =&& a pact of *A oertaia Maw VON& Retail InstalIMMt C,onu um (die ocentcac') fisted by and bet wo : It is eacpr+essly and Stood vc d agreed tbat Hocaehold Automotive F' Cbrporadon (" IWC') is substituted each and every time where fbo aaae appears witbin the Cronttact. For value t+eceived, SeUar hcreby e4py-sly sells, asdgas and trsaasfeas, pursuant to the indicated terms, of &a Contnet, s11 of SeUe es dom, title *ad isgwx0st v4ftn the Contact, and the pwperLy and sca mrity hemest described *mb k to IIWC =Nor ib suct, e•sats, assigns, svbsidisries and affiliates. All sept+esetststiaas, arsanmdes,~ des amd bold harmless provisions =tde by Seller in the Contract, sad sU other term of the assigamcat contained thacin, if any, are he:roby made in favor of HAFC. This Asa?nment spoeifioaUy tncludes, but is not limited to, all right, title and inteaoest o' Sauer. in any insurance policies or insurance proceeds pu rcbwo4 emdoned or obtalwA b. said Buyer(s) wader the terms of the Cond. This Assment specifically ta?elndes at rlght,'title and interest of Seller in and to any property or secu$ty interest de etMed' c provided for in the Contract. Notwithstanding anything to the contrary contained in the Contract, this Assignment, upc execution by Seller, shall assign Sellees rlj?xts in.the Contract to HAFC and not to 0.1 assignee(s) named in the Contract. This Assignnmt nt shall not ie doomed to relieve Sol from mnlr liability for the beach of any wan=dee, ?tqx entations or agreements eont dr • heroin or in the Contract. Seller-Dealership (please print) « Seller's Agent (please print) Seller's Si gun xm Titlc of. A•gcnt DkitC Of &SSxguinC-at usnt:? 05. The following is an NOIT Certified Mail receipt that was sent to the following account number (listed on the receipt): CERTIFIED MAIL RLCEIF (Domestic Mail Only No /OSUMf)ce C06'erai ¦u I OFFICIAL USE q r i m • AUG 16 2004 C3 CNWMft* ° u7 . n?oAr.y M1 ° TOM PaOW a Fees $ ?6 4 p / 6 P ° ° 1 _. ..._ .................. .. ' art?OaoRNa i EXHIBIT "B" I .f t' - v `o } i ?? loo 11 9 } ° P U r i a •fi 4 cr Q X ad ? m Q. ? g EL9r16 C) 0 =0 00 4.0 . a m °v'g? r`a m CM 13 ' wit CL-V oE w ° U a ? BIC' E ??D Er V?? m o 0 w 00? a d o io 4 ? • ?Y rIry r fib r:.~ ••f 't 'l .L d t 1 I. gO ? R 0 O' N V IrVD E v M .?? w O M hi r w .>o immammumm= w Ir 1 I I• I : woe l: 1 .? f. cn n ?. 01300 c °OO?ca ' ?.'r^r=?ca c'0pm_ ..:. 13..13¢ ` yrm?0 .r:. ;wm. Wa 4 m OivjlE " r °i 4m? C, M .?...'. m r O 1 p ?r I V !I I1 1 -. f I 'WW{ :.Cs IV F -co 'MZ w.W C 0 -ao -%J cn , Oi A r ??? ;?. of C . EL LZJ 13013 wl p 33 x, o I ? ° € 0 3 { q Q vu "SS UB D ElF S ?C Q ?p f C a; R (A m '7 M m g9 CL ON 0 EL m $ m (I 4w (A 0 CIL - 3om?8 ` N • 413L a a a • 9 3 1 n tit ?mo ?? m n CL m r l ti W Z p i ? ~ l W s O 6 I 1 ' t? p 1 ? I I ? CV ? `? w? IE to aj A ? f t 1 I ? I.J W rw ? w IF. ? ..? ° W q p ada3 WJS r. Ln 10. ^- { rn O.. -m N J ?w f m i ROO= -ssz? ???? ' P p G j Q V C/7 .?. y..? M ?:. Ln, 014 M1 i 1. 0 ?o V 9 3 W 0 a> g t `? YQ f 1 a ~ I 6 ? O E 'l /a5?o78? The following is an NOIT Certified Mail receipt that was sent to the following account number (listed on the receipt): r I Postal 1 u7 CERTIFIED RECEIPT MAIL- i ?o . m _q,, Proviclecy) ?? OFFICIAL !m USE Powo. i 3 COMW Fn C G 16 2004 C3 F" Powft* ° L oall„? ,a Tom?•n?.aPw $ z c 9 m m N> x 0 m c _ pD F, ?mf{1 -- C F O .r ft) V 00 P-4 can jLq :D In ~ me a7 '04 31 C P V1 1 r MA C {T ?r t r o ? m ? t7 -40 ? o . ??? 0 R a 1 C1 G -•"N +n X -rt - 3O m ce x p a 3 to # Z 4 ? a X s I P to x? "n a , -- r . un °° O o W C z X"o •X. " r ? ? mo$ N x ?. ?? yyin \ ?, g ? °O?o Q?p N W w y m = ?m1?m1 m jm?Q C R7 +• . O `J v zm ? rn > a s 70 z 8 ? r °? ?g ?g=o g ° Q W m $ K $ _ ?f 0 m ° 31 W' ? a z? b Z o g . i? = ? ? r p N, m Fn m r?i? s c 3 m km a ? co ? F. ru (D 1 M -I T 41 im M2 4 In c m O r- r pom r :`? D m v a s "' ' i _ ' ? N z m N r- C Z M Ap Off} m ° . tf1Q zir m oao R+ T ?n ZC 99 r Q -4 ? 0 no aR' ! <y O 3 S ?m 1 ?._ Map, L7 sT? 1 9wo D x x 0 ° x c r 3 m vc Y x = . 2 m1a x n m O ? m o? mm m x ?. r ON ? z m o RJ nr W r. ?? w? -i o tt? r *-4 ? ' H m o c €_ z o x n O M y EO 4+ N c, ? I q? ? e m Z ,r ? m m o " n x { O ` !l4 101 ?F N . w Q 0 ?p pb a cm i Q 9 ..r x 4•. N O? O ? x ti" . ? -?! m . m 7 s0i ' D Im ..?? ( ? D can . o 2 m 7 ? Mr- L a r v EXHIBIT "C" (? CA ?.a w to w to O f -4 rnc i e10 S 'O • d w to T Cs,d C t'1 c m m 3. 3 °i o r'm cm ncM0 GRc? ?; F- rF - ? _ n a w rm c 3.. r. 3? cwim ?m n?'m® t> ?s?>'.s.`. ti m mm C 'c a m^ v 3rf 'q N^ 50 g- w Col. j cl Co. no C v+ C y o...m p! nc, no y.°'iOF:? .o? o;... ?s ?. U n r?i mtr.t7 .?c_gj' T m o: n n d a d t u; m D-° m >iv M 'w, fA. d? - m no m .. Gc? ' S co. °, n.m.nm a o S. m' cY -?r 5y1c;.. a o 0_.w r n Moo, om, m C=, cill C=11_0 63 10 ?d>:g 9.. ' . G nt p can m °' ?s y = no. x m` 2 m !..• ' I-r o, .Y?1-aq??. C' aci ?.'?•,. Sdp'. v,' b '?B• ?a m Q drt.- ?!i m 1n o 4M%5., Im yo ev P3, >•m.., y is .. ?S M T fro-S m m w;_o. c `0 EF =r m m j, .. o El 7; SL ?..d? tm to Q iN!•C 7F,m .pp a N 1D G '?• G mo ?.?b N •. $ m.TCri3 N .M N iv to .?. Wit. to m 4a' ° mew 70 o nom rm?i 6r % Om <°? d :931.g. mm omo1°+?= N H vi C m a w of ACS ? a. y . .. ?r?'26 ?. _. rkYy'. ? _ m A•_o.. y ? m 3 m .ten ? a • ? ?o ' 5 w N 0 C3 a'. F, S 3 $ Sk Sm °. a m R ss'.? ? N:. c;.m g? ? • ?.d o. F 3. ?,r _ y? ?_?Cf w5s CL c?? ?a FSE.?.?.? n fn JM m c5 o CAN chi r r c W R/ 9 ? ya=i ice.; Rte ' Q p? =2'1, Coo, . J W ?y n 9 ICDI MIR. IT a mc ?r ? e? :I n CD CD F?4^ n _ <$ _ yam. ?9 Tw+n .? e?i o'g 'cl Irv G C ya eta m a d ? ?. N . ,. CL. m• m m 7 ' im m C m > y ? ?A-'-. ? n =4 3 w 7D =r ' } a ::5 n w ? 4 = a y .- ? Q w ? n ? ? ?`ped N < !? A o,rm CT R s cc" m n ,m t = p'1 o M NN '.? O ? t0 1 1: N V 16 Fr NM ? ? h R 1 S * '•a L: :nom' g r: n '... o: w y n a c` 4 ii to x .. 2004 046 01 0051 73.00 73.00 SOFT COPY WORK ORDER 12066192 10/12/2004 Ti Aoss ?R acs 488?oD Elmo low r GBAIRVI=, PA 17028 30 DEW, CA 92111 VIN 1FMpUMUSQA34822 ?,? 8/18/2004 1206692 TZAR MAKE MODEL BODY COLOR MILER =9 R 22N PS PS AC IN BS TOP CC EL IBT CLR 4X4 TL, SRS SI DF 1995 FORD TRUCK EXPLORER 4X4 XLT 4SIIV WHITE 125366 60 T A X X X X X X C BLD X X D X SOLD 10/11/2004 STOCU LEASE 500000656786 TITLE 48234708506 DETAIL TOTAL APPEARANCE RBCOND=ICKZNG TRANSPORTATION TOTAL TRANSPORTATION * NON-DBDUCT333LB CNAROBS AS IS OVER 1008 SOLD TO. 5129967 02 ATLANTIC CARRIER SYSTEMS INC 911 W MAIN ST VALLEY VIEW, PA 17983 lumiCE PRICE SALE PRICE SALE PEES 95.00 A/R ANT RECON TOT 123.00 DLR REOOM CzRTXFIZD SALES TAX PRD03 PER SMUAWT SAT FEE 2,700.00 TOTAL BIBS 218.00 ------------- NET SALE PRICE 2,482.00 ENTRY S 2004 046 01 0051 CHECK OR DFT # 0100673 .00 50.00 PARTS i XATlRTAL I.AECB: CR/17iSPBCT om/3718 SDELBT MOAIRS MISC MJJWM ODS BXPR Est .. ? ? 73.00 50.00 73.00 SELLING i UrfRATIVU PEES ADVANCE CHARGES TRANSP01tTATIOS 50.00 123.00 copy OWY 94®-r PAY 01" ?® 1%voice THIS H & S Towing Service, Inc. 148 Ole Lane Grantville, PA 17028 FAX (717) 469-8456 (717) 469-7093 BILL TO Keystone Auto Auction 488 Firehouse Road Grantville PA 17028-9215 I nvcke DATE INVOICE # 811812004 50807 _ c P.O. NO_ ITEM QUANTITY DESCRIPTION Towing 5 Went to Central Peni Mechanicsburg for 5 units dropped at Km=rji Auto Auction 2000 Ford Escort 1 1995 Ford Explorer vin.#A34922* 2 KiaSportWvin. , 1998 Ford Contour vin.#190681; 2000 Dodge Neon vin.0466 $50.00 each. RATE A TERMS Net 30 AMOUNT 50.00 250.00 6.00% Nre, 1210664A ao(,* -1 aq 0,11,1111, ?•6,o,4 Total 0.00 $250.00 All charges are due within 30 days of the billing date. A 1 112% Per month (18% Per Annum) late payment penalty will be imposed on amounts not paid when due. I acknowledge receipt of a copy of this agreement. central Fem Recovery Service PHONE (717) 697-6600 5203 East Trindle Road FAX (717) 697-3169 Mechanicsburg, PA 17050 INVOICEDATE 811812004 HOUSEHOLDAUTOMOTIVEFINANCING PO BOX 17915 SAN DIEGO, CA 92177 ATTN: JUAN MUNOZ DEBTOR INMAN, SHIRLEY ACCOUNT# 656786 S.S # 177-42-0074 YEAR 1995 MAKE FORD MODEL EXPLORER VIN # 1 FMDU34X4SUA34822 DATEREPOSSESSED 8/12/2004 DATECLOSED DATEGONE 8/18/2004 AUG 8 5 2004 REPOFEE: $325.00 TOTALAMOUNT: $325.00 CLOSEFEE: STORAGEFEE: SKIPFEE: IMPOUNDFEE: KEYS: DELIVERYFEE: PICTURESBC/R: DOORKNOCKFEE: INVOICE # 7536 U,5 (oj%to 1 THANK YOU, WE APPRECIATE YOUR BUSINESS PAYMENT DUE UPON RECEIPT CERTIFICATE OF PURCHASE Bethany Stephens I, hereby depose and state that: 1. I am an Authorized Agent of CACV of Colorado, LLC, a Colorado Limited Liability Company. 2. As such, I am authorized to give this Certificate, and possess sufficient personal knowledge to do so regarding: Customer Name: Shirley Inman Original Creditor: Household Automotive Finance Account Number: 500000656786 3. On or about December 2, 2004 this account was issued by the original creditor. CACV of Colorado, LLC is the current owner of the account and purchased the account for good and valuable consideration. Date: OCT t 31115 Sworn and subscribed to before me this 2005. Notary Public --? c/1 4??V& By: 13 FEB 2 6 200 My Commission Expires: day of a C'-'O?- I E D(?Rq rm TA q.2 ct? qC/ ?G ?O O 6 LO`o?QO EXI-IIBIT "D" s 14 VERIFICATION Bethany Stephens I, , hereby depose and state that: The language of the foregoing document is that of counsel and not necessarily my own; however, I have read the foregoing document and the factual information contained therein is true and correct to the best of my personal knowledge. I am the Authorized Representative and a duly authorized representative of the plaintiff; The factual allegations set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief, and they are that Shirley Inman owes the balance of $6,606.14 to CACV of Colorado, LLC on previously submitted invoices, which balance is due and unpaid as if the date of the execution of this Verification. I am aware that if any of the foregoing is willfully false, I am subject to punishment. I understand that false statements made herein are subject to the penalties relating to unworn falsification to authorities. By: ?U 1 3 2005 Dated: Authorized Representative W 00 rz? W 0 -, D L NJ t 0 ?& SHERIFF'S RETURN - REGULAR CASE NO: 2008-00560 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS INMAN SHIRLEY ET AL RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon INMAN SHIRLEY the DEFENDANT , at 0020:41 HOURS, on the 1st day of February-, 2008 at 24 MOUNTAIN VIEW TERRACE NEWVILLE, PA 17241 ROBERT INMAN HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge al rlOS 6?- 18.00 9.60 .00 10.00 .00 37.60 Sworn and Subscibed to before me this of day by handing to So Answers: R . Thomas K1 ine 02/05/2008 ROBERT REIBSTEIN By: Deputy Sheriff A. D. t1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00560 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS INMAN SHIRLEY ET AL RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon INMAN ROBERT the DEFENDANT at 0020:41 HOURS, on the 1st day of February-, 2008 at 24 MOUNTAIN VIEW TERRACE NEWVILLE, PA 17241 ROBERT INMAN by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 2/61/6P 00 V'16 . 0 0 Sworn and Subscibed to before me this day of So Answers: P--o j ? k ? , 0, R. omas Kline 02/05/2008 ROBERT REIBSTEIN By: Deputy eriff A. D. QROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 6641999 ATTORNEY I.D. NO. 20456 CACV OF COLORADO : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. VS. NO. 08-560 CIVIL TERM ATTORNEY I.D. NO. 20456 SHIRLEY INMAN & ROBERT INMAN, indv. and h/w : CIVIL ACTION PRAECWE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Please kindly enter Judgment in the above captioned case by default for want of the answer being filed within the time prescribed by the Pennsylvania Rules of Civil Procedure against the Defendants and assess the damages as per statement below. ROBERT M. REIB STEIN ATTORNEY FOR PLAINTIFF ASSESSMENT OF DAMAGES Amount of Judgment ............................................$11,038.69 Costs ..................................................................... l ROBERT M. REIBSTEIN Attorney for Plaintiff AND NOW, , 2008, Judgment entered in favor of the Plaintiff and against the Defendants by Default for want of an answer being filed within the time prescribed by the Pennsylvania Rules of Civil Procedure and damages assessed at the sum of $11,038.69 as per preceding statement. e? f I PRO ONOTA&- "" r 3/07/08 ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY I.D. NO. 20456 CACV OF COLORADO : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. VS. :NO. 08-560 CIVIL TERM : ATTORNEY I.D. NO. 20456 SHIRLEY INMAN & ROBERT INMAN, indv. and h/w : CIVIL ACTION CERTIFICATION PURSUANT TO RULE 237.1 TO THE PROTHONOTARY: This is to certify that on February 22, 2008, Plaintiffs attorney sent notification pursuant to Rule 237.1 to the Defendants by certified mail, return receipt requested, and by First Class regular mail. ROBERT M. REIBSTEIN Attorney for Plaintiff ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY I.D. NO. 20456 CACV OF COLORADO : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. V. : NO. 08-560 CIVIL TERM DATED: FEBRUARY 22, 2008 SH RLEY INMAN & ROBERT INMAN, indv. And h/w: FIRST CLASS MAIL - PROOF OF MAILING TO: SHIRLEY INMAN 24 MOUNTAIN VIEW TERRACE NEWVIILE, PA 17241 NOTIFICATION PURSUANT TO RULE 237.1(x)(2) 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 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. LAWER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ROBERT M. REIBSTEIN Attorney for Plaintiff ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY I.D. NO. 20456 CACV OF COLORADO : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. V. : NO. 08-560 CIVIL TERM DATED: FEBRUARY 22, 2008 SHIRLEY INMAN & ROBERT INMAN, indv. And h/w: : FIRST CLASS MAIL - PROOF OF MAILING TO: ROBERT INMAN 24 MOUNTAIN VIEW TERRACE NEWVILLE, PA 17241 NOTIFICATION PURSUANT TO RULE 237.1(a)(2) 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 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. LAWER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ROBERT M. REIBSTEIN Attorney for Plaintiff ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY I.D. NO. 20456 CACV OF COLORADO : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. VS. :NO. 08-560 CIVIL TERM : ATTORNEY I.D. NO. 20456 SHIRLEY INMAN & ROBERT INMAN, indv. and h/w : CIVIL ACTION CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: This is to certify that the address of the Defendants is 24 Mountain View Terrace, Newville, Pennsylvania 17241; and the Plaintffs address is 370 171" Street, Suite 5000, Denver, Colorado 80202. q?-? ROBERT M. REIBSTEIN Attorney for Plaintiff ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456 CACV OF COLORADO VS. SHIRLEY INMAN & ROBERT INMAN, indv. and h/w : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 08-560 CIVIL TERM ATTORNEY I.D. NO. 20456 : CIVIL ACTION AFFIDAVIT OF NON-MIIJTARY SERVICE COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF MONTGOMERY ROBERT M. REIBSTEIN, ESQUIRE, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above entitled case; that he is authorized to make this affidavit on behalf of the Plaintiff, and that after research with the Department of Defense, the above named Defendants are not in the Military Services of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereof. ROBERT M REIBSTEINATTORNEY FOR PLAINTIFF SWORN TO AND SUBSCRIBED BEFORE ME THIS Y DAY OF ?hc?r? h , 200_ g- NOTARY PUBLIC COMMONWEALTH Or='PENNSYLVANIA Notarial Sri Sandra L Tnrdgeori, Wary Public Lower Merion Tviip., MOA190rnery County My Commission Eq3 ss Jura 9, 2009 Member, Pennsylvaniv Assoedatlon of Notaries C? ? C?: ?y o -? = ca ` a = rv 0 C7 -r? (Rule of Civil Procedure No. 236) CACV OF COLORADO VS. SHIRLEY H-4MAN & ROBERT INMAN, indv. and h/w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 08-560 CIVIL TERM ATTORNEY I.D. NO. 20456 CIVIL ACTION Notice is given that a judgment in the above captioned matter has been entered against Defendants on March 7 20CS, in accordance with provision of Pa. R.C.P. 236. PRO ONOT If you have any questions concerning the above captioned case, please contact: ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456