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HomeMy WebLinkAbout04-0031IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, vs. Plaintiff, CALVIN L. CONRAD and TRUDY A. OLIVO, Defendants. CIVIL DIVISION NO. Oq -- 31 ISSUE NUMBER: TYPE OF PLEADING: COMPLAINT CODE 011 ASSUMPSIT FILED ON BEHALF OF: Plaintiff, FORD MOTOR CREDIT COMPANY COUNSEL OF RECORD FOR THIS PARTY: Donald S. Mazzotta, ESQUIRE Pa. I.D. #11461 LAW OFFICES OF DONALD S. MAZZOTTA, P.C. Firm #742 938 Penn Avenue Pittsburgh, PA 15222 (412) 471-0300 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CALVIN L. TRUDY A. FORD MOTOR CREDIT COMPANY, Plaintiff, CONPAD and OLIVO, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Court Administrator 4th Floor, Cumberland County Courthouse S. Hanover Street Carlisle, Pennsylvania 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, vs. CALVIN L. TRUDY A. AND NOW, its attorneys, CONRAD and OLIVO, Defendants. COMPLAINT - CIVIL COMES the Plaintiff, Ford Law Offices of Donald S. ACTION Motor Credit Company, Mazzotta, P.C., and by at to as "Plaintiff." 2. CALVIN L. CONRAD is an individual residing at York Road, Lot #11, Pennsylvania 17070, at the same address, 1. Ford Motor Credit Company is a corporation doing business PO Box 6508, Mesa, Arizona 85216, and is hereinafter referred 113 Old New Cumberland, CUMBERLAND County, and TRUDY A. OLIVO is an individual residing and both are hereinafter referred to collectively as "Defendants." 3. On or about June 5, 1999, Defendants entered into a written agreement (hereinafter "Agreement") for the purchase and financing of a motor vehicle. A true and correct copy of Agreement is marked Exhibit "A", attached hereto and made a part hereof. payment 5. Plaintiff is the holder of Agreement and is entitled to under the terms thereof. Defendants defaulted for failing to make payments when is a statement: respectfully presents its complaint in civil action against the defendant above-named upon a cause of action whereof the following and as due, and Plaintiff incurred a loss in the principle amount of $7,123.67. 6. Plaintiff is entitled to interest from February 19, 2003 to January 1, 2003 at the contract rate of 20.00% per annum, totaling $1,238.01. 7. Demand for payment has been made upon Defendants, but Defendants have failed or refused to pay. 8. Under the terms of Agreement, Plaintiff is entitled to reasonable attorney's fees of 20.000% in the sum of $1,424,73. WHEREFORE, Plaintiff seeks judgment against CALVIN L. CONRAD and TRUDY A. OLIVO the amount of $9,786.41, plus interest from June 18, 2003 to date of judgment and costs of suit. BY: LAW ~FFICES OF DONALD Do Attorneys S. MAZZOTTA, ta, Esquire ~r Plaintiff IN THE COURT OF COMMON PLEAS FORD MOTOR CREDIT COMPANY, Plaintiff, vs. CALVIN L. CONRAD and TRUDY A. OLIVO, Defendants. OF CUMBERLAND COUNTY, No. PENNSYLVANIA VERIFICATION I, Donald S. Mazzotta, Esquire, state that I am not a party to the action but that at the request of the Plaintiff, and based upon knowledge, information, records, and documents supplied to me by the Plaintiff, the averments set forth in the Complaint are true. A Verification executed by the Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: December 30, 2003 By: D°n~ ~ 06/05/99 TO Public 0~1c1~1, (i~?~r license ($..~. t~e ($ ~. ~0~_j. & [] Cfm:lit LEe $ N/~. _ Premium Insu~cl(s) Signature(s) Credit Signature Do not ~lgn this contract in blank, You are entitled to an exact copy of the contract you sign. Keep it t~r le~l flg?~. . PLEASE CALl. US AT t~00-727.7000 Buyer sc knowledg~:~';at. I~T a.,tA~M~lln/d~/lt t pletely filled In copy ct this contract at the tlme_c~ sl~ning, t! PLAIN EXHIBIT ADDfrIONAL AGREEMENTS PLA IN T i FF'$ EXHIBIT SHERIFF'S RETURN CASE NO: 2004-00031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CONR3kD CALVIN L ET AL - OUT OF COUNTY R. Thomas Kline , duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT CONRAD CALVIN L but was unable to locate Him deputized the sheriff of YORK Sheriff or Deputy Sheriff who being a diligent search and , to wit: in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 18th , 2004 attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 38.00 .00 75.00 02/18/2004 DONALD MAZZOTTA Sworn and subscribed to before me this ~- day of j~ ~/u Pr°th°n°tary~ this office was in receipt of the So answe~~'~--~?: ~ ~i R. Thomas Kline Sheriff of Cumberland County SHERIFF'S RETURN - CASE NO: 2004-00031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CONPJtD CALVIN L ET AL OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT OLIVO TRUDY A but was unable to locate Her deputized the sheriff of YORK , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On February l@th , 2004 attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 02/18/2004 DONALD MAZZOTTA Sworn and subscribed to before me this o2~ %~ day of~ ~3V' A.D. this office was in receipt of the So answers~-~C~f~ ~ ~ itu R. Thomas Kline Sheriff of Cumberland County COUNTY Of YORK OFFICE OF THE SHERIFI5°f2 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN 1. PLAiNTIFF/S/ Ford Motor Credit Company 3 DEFENDANT/S/ Calvin L. Conrad et al SERVICE CALL (717) 771-9601 2. COURT NUMBER 04-31 civ~ 4. TYPE OF ~:~lT OR COMPLAINT PLEASE Notice and Complaint SERVE /' 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, A~ACHED, OR SOLD Calvin L. Conrad 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO., CITY, BORO, TWP., STATE AND Z~P CODE) AT 113 Old York Road Lot 11 New Ct~berland, PA 17070 7 INDICATE SERVICE: O PERSONAL ~ PERSON IN CHARGE ~DEPUTIZE ~] CERT. MAIL [] 1 ST CLASS MAIL 0 POSTED [] OTHER NOW January 9 ,20 04 I, SHERIFFC(~'It~ilI'~]OUNTY, PA, do hereby deputize the sheriff of York COUNTY to execut~_~,~--rf~ake return t~.~. ccording to law. This deputization being made at the request and risk of the plaintiff. SHERIFF 0 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COUNTY -CUNBERLAND ADV FEE PD BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sbeF. ff levying upon or attaching any property unbar within writ may leave same without a watchman, in custody of whomever is founri in possession, after notitying person of ~eW or attachment, without liability on the pa~ of such deputy or the sheriff to any plaintiff herein for any loss. destruction, or removal of any property before shedffs sa~ thereof 9. TYPE NAME and ADDRESS OfA'FTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMEER 11. DATE FILED DONALD S. MAZZOTTA PC 938 PENN AVENUE PITTSBURGH PA 15222 412-471-0300 01-05-2004 12, SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be m)mpleted if notice is to be mailed) {~I)~RF[~! ANn CTY 13. I acknOwmdge receipt of the writ 15. Explration/Heari,g Date o~complaintasindicatedabove. RONDA N. AHRENS /RAT 02-04-2004 16 HOWSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) EHERJFF'SOFFICE( ) OTHER( ) SEE REMARKS BELOW 17./~ hereby cerkfy and return a NOT FOUND because I am unable to ~3cate the inriiviriual, company, etc. named above. (See remarks below.) 18.'q%qME AND TITLE OF INDIVIDUAL SERVE[3 / LIST ADDRESS H ERE IF NOT SHOWN ABOVE (Relationship to Defondan{) 19. Date of Service 20. Time of Service 21.A'FTEMPTS ~D~e~//'/7/ //~7~33me Milesj7/~ ~lnt' IDate Time Miles Int. IDate Time Miles fot. IDate 33rna Miles Int. IDafo Time Miles Int, IDate Time Mi,~s Int. 22. REMARKS: .~~l.~.~ ~,,-.~11 23. Advance Cost$ 24. erviceCosts 25. N/F 26. Mieage 27. g . . ound 30. Notary 31.Surchg. 32. T..C~I33. C~stSDU~a(~e~i~Ch/eCkNo 41. AFFIRMED and subscribed to before rne I~liS 30th _ so ANSWE;S p~67_,~,,//,.[~,.,.44. Sig~44. Signature of 45. DATE Jameav, v~;,~. ~Pu~tic SHERIFF WILLIAM M. H~3E ~ 01/30/04 I _~lty O~ YOl'b, YO~ C~;~4y, PA , 48. Signature of Foreign 49. DATE My U, olltffflealon F?,~ree Mar. 21, 2005 County Shedff 50. I ACKNO¥'VLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE I 51 DATE RECEIVED OF AUTHOR ZED SSU NG AUTHOR TY AND TITLE 1. WHITE - Issuing Authority 2. PINK * Attonney 3 CANARY - Shedfl's Office 4~ SLUE - Sheriffs Off'me 3. DEFENDANT/S/ SERVE COUNTY OF YORK OFFICE OF THE SHEI I fl (7t7) 77~-960! 28 FAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN 2 COURT NUMBER Ford Motor Credit Company 04-~1 4 TYPE OF WRIT OR COMPLAINT Calvin L. Conrad et al Notice az~l Complint 5. NAME OF INDIVIDUAL. COMPANY, CORPORATION, FTC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED. OR SOLD Trudy A. Olivo 6. ADDRESS (STREET OR RFC WiTH BOX NUMBER. APT. NO., CITY, BORO, TWP, STATE AND ZIP CODE) AT 113 Old York Road Lot ll New C~nberland, PA 17070 7. INDICATE SERVICE: Q PERSONAL Q PERSON IN CHARGE J~DEPUTIZE O CERT. MAIL Q 1ST CLASS NLAJL Q POS11~D ~ OTHER NOW J~ary 9 ,20 04 I, SHERIFF OF 4~rr(c]c~. P~C~. do hereby d~ep~pti~.p the sheriff of York COUNTY to execu~ m~ak.~.etur~j)~f~of according to law. This deputization being made at the request and risk of the plaintiff. '~"~ SHERIFF OF~m~I, COUNTY B. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WiLL ASSIST IN EXPEDITING SERVICE: C~nberland OUT OF COUNTY -CUMBERLAND ADV FEE PD BY ATTORNEY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff revying upon or attaching any property under within writ may reave same witflout a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liabiliIy on the per~ of such deputy o~ lhe sheriff to any plaintiff herein for any loss. destruction, or removal of any property before shedffis sale thereof. g. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE I 10. TELEPHONE NUMBER 11 DATE FILED DONALD S. MAZZOTTA, ESQ. 938 PENN AVENUE PITTSBURGH PA 15222I 412-471-0300 01-05-2004 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW; (This area must be completed if notice is to be mailed) CUMBERLAND COUNTY SHERIFF'S DEPT. 13. I acknowledge ~ceipt of the writ DATE RECEIVED 15. Expirabon/Hearing Date or complaint as iodicated above, RONDA M. AHRENS /RAT 01-12-2004 02-04-2004 16, HOWSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17.,,~ereby cerUfy and return a NOT FOUND because I am unable to locate the individual, company, etc, named above. (See remarks below.) 18. N~tME AND TITLE OF INDIVIDUAL SERVED / LiST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Se~ice 20 Time of Service 41, AFFIRMED and subscribed fo before me ~.his 30th so IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA/~IA FORD MOTOR CREDIT COMPANY, vs. CALVIN L. TRLTDy A. Plaintiff, CONR3kD and OLIVIO, Defendants. CIVIL DIVISION NO. 04-31 CIVIL TERM ISSUE NUMBER: TYPE OF PLEADING: PRJkECIPE TO REINSTATE COMPLAINT CODE 011 ASSUMPSIT FILED ON BEHALF OF: Plaintiff FORD MOTOR CREDIT COMPANY COUNSEL OF RECORD FOR THIS PARTY: Donald S. Mazzotta, ESQUIRE Pa. I.D. #11461 LAW OFFICES OF DONALD S. MAZZOTTA, P.C. Firm #742 938 Penn Avenue, Suite 700 Pittsburgi~, PA 15222 (412) 471-0300 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, FAIRLANE CREDIT, LLC, Plaintiff, VS. CALVIN L. CONRAD and, TRUDY A. OLIVIO No. 04-31 TO: Defendants. PRAECIPE TO REINSTATE COMPLAIN~ Prothonotary of Cumberland County Please reinstate the COMPLAINT against Defendants, and TRUDY A. OLIVIO regarding the above-captioned matter. PENNSYLVANIA CIVIL TERM CALVIN L. CONRAD 7 By, "-/~O~VS for Plaintiff SHERIFF' S RETURN - CASE NO: 2004-00031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CONP~AD CALVIN L ET AL OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT CONP-AD CALVIN L but was unable to locate Him deputized the sheriff of SNYDER , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On August 23rd , 2004 attached return from SNYDER Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Snyder County 33.60 .00 70.60 08/23/2004 DONALD MAZZOTTA Sworn and subscribed to before me A.D. ~rothonotary __ , this office was in receipt of the Sheriff of Cumberland County SHERIFF'S CASE NO: 2004-00031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS CONRAD CALVIN L ET AL RETURN - OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT OLIVO TRUDY A but was unable to locate Her deputized the sheriff of SNYDER , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On August 23rd , 2004 attached return from SNYDER Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 08/23/2004 DONALD MAZZOTTA Sworn and subscribed to before me this 3/~ day of ~3- 223,w3 ~ A.D. ~ ~ Prothonotary ' this office was in receipt of the So an swe?_~s~ ~ //~ R/ Thomas Kline ~ _ Sheriff of Cumberland County SAVED # 04-31 MISC. DKT. BK. # 33 PAGE # 190 IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY VS CALVIN L. CONRAD and TRUDY A. OLIVO DKT. NO: 04-31 CIVIL NOTICE AND REINSTATED COMPLAINT AFFIDAVIT OF SERVICE AND NOW, August 19, 2004, I, Dennis Troutman, Deputy for Joseph S. Reigle, Jr., Sheriffof Snyder County, Pennsylvania, being duly sworn according to law deposes and says that the above described Notice and Reinstated Complaint was served on Calvin L. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., at his residence at 2B, East Sassafras Street, Selinsgrove, Snytler County, Pennsylvania, by personally handing to Trudy A. Conrad, wife of Calvin L. Conrad and adult person in charge of the residence at the time, a true and correct copy of the above described Notice and Reinstated Complaint, and that I made known to Trady A. Conrad the contents of the same. 1 further certify and return that the above described Notice and Reinstated Complaint was served on Trudy A. Olivo, now by inarriage Trudy A. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., at her residence at 2B Sassafras Street, Selinsgrove, Snyder County, Pennsylvania, by personally handing to Trudy A. Olivo, now by marriage Trudy A. Conrad, a true and correct copy of the above described Notice and Reinstated Complaint, and that I made known to Trudy A. Conrad the contents of the same. SO ANSWERS JOSEPH REIGLE, JR., SHERIFF SNYDER COUNTY, PENNSYLVANIA RECEIVED FROM: Cumberland County Sheriff SNYDER COUNTY SHERIFF'S FEES: Docketing, Service, Etc. $ 24.00 Mileage 6.60 Notaly 3.00 DEPOSIT $75.00 Receipt # 2909 REFUND $41.40 Check# 2535 TOTAL: $ 33.60 DEPUTY DENNIS TROUTMAN COMMONWEALTH OF PENNSYLVANIA COUNTY OF SNYDER SS: swo TO, SUBSC BED BEEO THIS z~/,l~_ DAY OF ~ff/t~d' - ~04 PAID TO COUNTY CHECK # REIMBURSED TO PETTY CASH CHECK # Ih The Court of Common Pleas of Cumberland County, Pennsylvania Ford Motor Credit Company VS. Calvin L. Conrad et al SERVE: Trudy A. Olivo No. 04-31 civil ]NiOW, August 6, 2004 hereby deputize the Sheriff of , I, SHERIFF OF CUMBERLAND COUNTY, PA, do SnyderCouIlty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriffof Cmmberland County, PA Now~ within upon ___ at by handing to a and made known to Affidavit of Service ,20 ,at o'clock copy of the original So answers, M. served the the contents thereof. Sworn and subscribed before me this __ day of ,20 Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA ~{n The Court of Common Pleas of Cumberland County, Pennsylvania Ford Motor Credit Company VS. Calvin L. Conrad et al SERVE: Calvin L. Conrad 04-31 civil No. Now, August 6, 2004 hereby deputize the Sheriff of Snyder deputation being made at the request and risk of the Plaintiff. Sh~riffofCumberland County, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Now, within upon at by handing to a and made known to Affidavit of Service ,20 ,at o'clock copy of the original SO answers, M. served the the contents thereof. Sworn and subscribed before me this __ day of ,2O Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, vs. CALVIN L CO~, and TRUDY A OLIVO/CONRAI) Defendants. CIVIL DIVISION NO. 04-31 TYPE OF PLEADING: Praecipe for Default Judgment CODE FILED ON BEHALF OF: Plaintiff, FORD MOTOR CREDIT COMPANY COUNSEL OF RECORD FOR THIS PARTY: Donald S. Mazzotta, ESQUIRE Pa. I.D. #11461 LAW OFFICES OF DONALD S. MAZZOTTA, P.C. Firm~742 938 Penn Avenue Pittsburgh, PA 15222 (412) 471-0300 IN THE COURT OF COMMON PLEAS OF CUMBERLA/qD COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, NO. 04-31 vs. CALVIN L CONR3~D, and, TRUDY A OLIVO/CONRAD, Defendants. PLAINTIFF'S PRAECIPE FOR DEFAULT JZJDG~4ENT PURSUANT TO PA.R.C.P.1037(b) TO: PROTHONOTARY OF CUMBERLAND COUNTY Please enter a judgment against the CONRAD and TRUDY A OLIV0/CONRAD for failure Plaintiff's complaint. defendants, CALVIN L to file an Answer to Amount claimed in Complaint $9,786.41 Interest through September 21, 2004 $2,466.50 Attorney's Fees Costs (to be added by Prothonotary) $ TOTAL $12,252.91, * With interest accruing on TOTAL at the rate of 6% per annum from the date of Judgment together with costs of suit. I certify that a written notice of intention to file this praecipe was mailed to defendant and to defendant's counsel (if known) after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of this notice is attached. LAW OFFI~p OF DONALD S. MAZZOTTA, By: Don~ald ~.~ t~~ta, Esq.~~ Attorney fo '~laintiff Pa. I.D. # .1461 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, VS. Calvin L Conrad and TRUDY A OLIVO No. 04-31 Defendants. TO: Calvin L Conrad 2B East Sassafras Street Selinsgrove, Pennsylvania 17870 DATE OF NOTICE: September 13, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WlTHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator 4th Floor, Cumberland County Courthouse S. Hanover Street Carlisle, Pennsylvania 17013 (717) 240-6200 I HEREBY CERTIFY THAT THIS NOTICE WAS SENT ON THE DATE SET FORTH ABOVE. LAW OFFICES OF DONALD S. MAZZOTrA, P.C. At%rncys, f'ol~PlhintLff · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, No. 04-31 VS. Calm L Com'ad and TRUDY A OLIVO Defendants. TO: TRUDY A OLIVO 2B East Sassafras Street Selinsgrove, Pennsylvania 17870 DATE OF NOTICE: September 13, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN 'I/~N DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WI'fHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator 4th Floor, Cumberland County Courthouse S. Hanover Street Carlisle, Pennsylvania 17013 (717) 240-6200 HEREBY CERTIFY THAT THIS NOTICE WAS SENT ON THE DATE SET FORTH ABOVE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, Plaintiff, NO. 04-31 VS. CALVIN L CONRAD, and, TRUDY A OLIVO/CONRAD, Defendants. VERIFICATION OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037(b) (2) (iii) I, Donald S. Mazzotta, duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsifications to authorities that the defendants are not in the active military service of the United States of America that The Notice of Intent to Take Default Judgment was mailed by ordinary mail US Mail, in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy/copies, and such facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. Do Esq. Attorney fo~ Plaintiff Pa. I.D. # 461 Dated: SAVED # 04-31 MISC. DKT. BK. # 33 PAGE# 190 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY VS CALVIN L. CONRAD and TRUDY A. OLIVO DKT. NO: 04-31 CIVIL NOTICE AND REINSTATED COMPLAINT AFFIDAVIT OF SERVICE AND NOW, August 19, 2004, I, Dennis Trou~nnn, Deputy for Joseph S. Reigle, Jr., She~iffof Snyder County, Pennsylvania, being duly sworn according to law deposes and says that the above described Notice and Reinstated Complaint was served on Calvin L. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., a~ his residence at2B, East Sassafras Street, Selinsgrove, Snider County, P~nnsylvania, by personally handing to Tmdy A. Conrad, wife of Calvin L. Conrad and adult person in charge of the residence at thc time, a true and correct copy of the above described Notice and Reinstatad Complaint, and that I made known to Tmdy A. Conrad the contents of the same. I further certify and return that the above described Notice and Reinstated Complaint was served on Tmdy A. Olivo, now by marriage Tmdy A. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., at her residence at 2B Sassafras Street, Selinsgrove, Snyder County, Pennsylvania, by personally handing to Trudy A. Olivo, now by marriage Trudy A. Coarad, a true and correct copy of the abovo described Notice and Reinstated Complahtt, and that I made known' to Trudy A. Conrad the contents of the same. · SO ANSWERS JOSEPH REIGLE, JR., SHERIFF SNYDER COUNTY, PENNSYLVANIA RECEIVED FROM: Cumberland County Shrift SNYDER COUNTY SHER/FF'S FEES: Docketing, Sm-vice, E~. $ 24,D0 MHeag¢ 6.60 Notary 3.00 DEPOSIT $75.00 Receipt # 2909 REFUND $41.40 Cheok'~d 2535 TOTAL: $ 33.60 DEPUTY DENNIS TROLrrMAN COMMONWEALTH OF PENNSYLVANIA COUNTY OF SNrYDER SS: SWORN.TO/AND SUBSCBt[BED BEFORE ME PAID TO COUNTY CHECK # REIMBURSED TO Pfi'~ 1 Y CASH CHECK # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff, VS. CALVIN L CONRAD, and, TRUDY A OLIVO/CONRAD, Defendants. N0.04-31 NOTICE OF ORDER, DECREE OR JUDGMENT TO: TRUDY A OLIVO/CONRAD 2B East Sassafras Street Selinsgrove, Pennsylvania 17870 X Plaintiff Defendant Additional Defendant x ) costs A copy of the Order or Decree is enclosed, or The judg~nent is as follows: $~2,252.91 plus Deputy SAVED # 04-31 MISC. DKT. BK. # 33 J PAGE # 190 IN T}:IE COURT OF COMMON PLEAS CUMBE~AND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY VS CALVIN L. CONRAD and TRUDY A. OLIVO DKT. NO: 04-31 CIVIL NOTICE AND REINSTATED COMPLAINT AFFIDAVIT OF SERVICE AND NOW, August 19, 2004, I, Dennis Troutman, Deputy for Joseph S. Reigle, Jr., Sheriff of Snyder County, Pennsylvania, being duly sworn according to law deposes and says that the above described Notice and Reinstated Complaint was served on Calvin L. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., at his residence at 2B, East Sassafras Street, Selinsgrove, Sn3/der County, Pennsylvania, by personally handing to Trudy A. Conrad, wife of Calvin L. Conrad and aduR person in charge of the residence at the time, a true and correct copy of the above described Notice and Reinstat~l Complaint, and that I made known to Trudy A. Conrad the contents of the same. ] further certify and return that the above described Notice and Reinstated Complaint was served on Trudy A. Olivo, now by marriage Tmdy A. Conrad, named defendant, on August 17, 2004, at 5:00 P.M., at her residence at 2B Sassafras Street, Seliasgrove, Suyder County, Pennsylvania, by personally handing to Trudy A. Olivo, now by marriage Trudy A. Coarad, a true and correct copy of'the above described Notice and Reinstated Complaint, and that I made known to Trudy A. Conrad the contents of the same. . SO ANSWERS JOSEPH REIGLE, JR., SHERIFF SNYDER COUNTY, PENNSYLVANIA RECEIVED FROM: Cumberland County Sheriff SNYDER COUNTY SHI~PdFF'S FEES: Docketing, Sea'vice, Em. $ 24.00 Mileage 6.60 Notre3, 3.00 DEPOSIT $75.00 Receipt # 2909 REFUND $41.40 Chee~ 2535 TOTAL: $ 33.60 BY: P~..~.~,~. DEPUTY DENNIS TROLrrMAN COMMONWEALTH OF PENNSYLVANIA COUNTY OF SNYDER SS: SWORN_TO/AND SUBSCI//BED BEFORE ME PA.ID TO COUNTY CHECK # REIMBURSED TO PETTY CASH CHECK # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, FORD MOTOR CREDIT COMPANY Plaintiff, vs. CALVIN L CONRAD, and, TRUDY A OLIVO/CONPJUD, Defendants. NOTICE OF ORDER, TO: CALVIN L CONRAD 2B East Sassafras Street Selinsgrove, Pennsylvania ) x) ) ) x) costs NO. 04-31 DECREE OR JUDGMENT 17870 Plaintiff Defendant Additional Defendant PENNSYLVANIA A copy of the Order or Decree is enclosed, or The judgment is as follows: $12,252.91 plus