HomeMy WebLinkAbout08-1859I y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
BENEFICIAL
JOSEPH W LOPP III and KANDI L LOPP
Defendant(s)
Plaintiff
NO
0'8 - v R59 bvi i -rem
COMPLAINT IN CIVIL
ACTION
Filed on behalf of.
BENEFICIAL
Counsel of Record for This Parry:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PF_PA_1 I Cmplt Cvr Sht
P&F File No. 07-28311
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL
Plaintiff
V.
JOSEPH W LOPP III and KANDI L LOPP
Defendant(s)
NO.
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 an 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 TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER
Usted ha sido demandado en corte. Si usted desea defenderse
de las demandas que se presentan mas adelante en las
siguientes paginas, debe tomar accion dentro de los proximos
veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado
una comparecencia escrita y radicando en la Corte por escrito
sus defensas de, y objecciones a, las demandas presentadas
aqui en contra suya. Se le advierte de que si usted fall de
tomar accion como se describe anteriormente, el caso pude
proceder sin usted y un fallo por cualquier suma de dinero
reclamada en la demanda o cualquier reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted puede perder
dinero o propiedad au otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU
ABOGADO INMEDIATAMENTE. SI USTED NO TIENE
UN ABOGADO, LLAME 0 VAYA A LA SIGUENTE
OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS
OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE
UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE
PUEDA PROVEER INFORMACION SOBRE AGENCIAS
QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0
BAJO COSO A PERSONAS QUE CALIFICAN.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PA_21Notice to Defend P&F File No. 07-28311
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL
Plaintiff ) NO.
V. )
JOSEPH W LOPP III and KANDI L LOPP )
Defendant(s) )
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, BENEFICIAL, by and through its attorney, GREGG
MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C. and files the
following Complaint in Civil Action, and in support thereof aver as follows:
Count
Account Stated
1. Plaintiff, BENEFICIAL , is a corporation with offices with an address for the
purposes of this litigation C/O the law offices of Patenaude and Felix, APC, 213 E. Main Street,
Carnegie, PA.
2. Defendant(s) is JOSEPH W LOPP III, an adult individual, believed to currently
reside at 103 CENTER ST ENOLA, PENNSYLVANIA 17025.
3. Defendant(s) is KANDI L LOPP, an adult individual, believed to currently reside
at 103 CENTER ST ENOLA, PA 17025.
4. Heretofore, the Defendant(s) opened an account with Plaintiff being Account No.
71171413510689. A copy of the Account Agreement is attached hereto as Plaintiff s Exhibit "A"
and is incorporated herein by reference..
PA-05A Civil Cmplt Crdt Line P&F File No. 07-28311
The Defendant(s) made payments, but has refused to pay, and now refuses to pay
the balance due and owing on the aforesaid account and now the full amount of the account is
due and payable in the sum of $14,797.38 as of , plus interest at 22.98 % and cost.
6. Plaintiff maintains accurate books of account recording all credits and debits for
this account.
7. Defendant(s) have/has received monthly billing statements from Plaintiff setting
forth the nature and amount of all debits and credits and the transactions between Plaintiff and
Defendant(s) give rise to an account stated, upon which Plaintiff has relied.
By failing to object or dispute the statements, Defendant(s) have/has assented to
and agreed to the correctness of the balance due on the credit card account so as to constitute and
account stated.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amountof $14,797.38 plus interest as attached hereto, with continuing interest thereon at the
legal rate from the date of Judgment plus costs.
Counts II
Breach of Contract
9. The averments of paragraphs 1 through 7 are incorporated herein by reference as
if the same were set forth herein at length.
10. Defendant(s) completed an Application for Credit and the Agreement is attached
hereto as Plaintiffs Exhibit "A" and is incorporated herein by reference.
11. Defendant(s) is in default for failing to make payments as due.
12. The terms of the Contract provided that Defendant(s) will pay Plaintiffs
reasonable attorney's fees.
13. Plaintiff avers that counsel for Plaintiff is not a salaries employee of Plaintiff and
PA-05A Civil Cmplt Crdt Line P&F File No. 07-28311
that such attorney's fees will amount to $3,000.00,
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amountof $14,797.38 plus interest as attached hereto, with continuing interest thereon at the
legal rate from the date of Judgment, reasonable attorney's fees in the amount of $3,000.00 plus
costs.
submitted:
A.P.C.
Date:
e g L. M is, Esquire
E. Ma' Street
aP 15106
(412) 429- 675
PA-05A Civil Cmplt Crdt Line P&F File No. 07-28311
r
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page I of 4)
LENDER (called "We", "Us", "Our")
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE 104-HAMPDEN CENTER
MECHANICSBURG PA 17050
BORROWERS (called "You", "Your")
LOPP III, JOSEPH W
LnPP. KANDI L
103 CENTER ST
ENOLA PA 17025
01 AND OVER 1.915 % . 22.980 %
LOAN NO: 711714-13-510589
In this Agreement, "you", "your" and "Borrower" mean the customer(s) who signs this Agreement. "We", "us", and
"our" refer to Lender. This Agreement covers the terms and conditions of your Personal Credit Line Account. We want
you to understand how your Personal Credit Line Account works. Read this carefully, ask us any questions, and if you
agree to be bound by this Agreement, sign below, if more than one person signs, each will be responsible for repaying all
sums advanced under this Agreement.
Your Credit Line Account is a revolving line of credit extended to you and secured as described below. You can obtain
funds from your Personal Credit Line Account (up to your credit limit) directly from us or by using the special checks we
supply to you. You may pay your total unpaid balance at any time or in installments.
REQUIRED INSURANCE. You must obtain insurance for term of ban covering security for this loan agreement as indicated by
- the word "YES" below;-namiaE-us as Loss Paper
Physical damage insurance on vehicle fisted under "Security' above, if "Y" appears under 'Insured."
You may obtain any required insurance-from anyone you choose. -
VOTICE. SEE THE FOLLOWING PAGES FOR ADDMONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO
BILLING ERRORS.
F3-D7-00 _-
IN1110,r1.1'r111r1.1101111111011 PA0663BI
"LO19C641FL16RLAIDOOPAOS63610""LOPP - " ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4)
Available Credit: You may obtain funds directly from us or through your special checks up to your available credit. Each
check mu a wntten for at least $100.00. Your available credit is your credit limit (shown on page one) less the total
unpaid balance, including Finance Charges, of your Account. If you make loan payments by check, we will adjust your
available credit seven days after we receive your check to allow for check clearing. If you request funds in an amount that
would cause you to exceed your available credit, we are not obligated to honor your request. If we do lend you an amount
over your available credit, you agree to pay us that excess amount, plus Finance Charges, immediately.
Promise to Pay: You promise to pay Lender. (a) amounts borrowed under this Agreement; (b) Finance Charges,
A mimstratrve rges (the late charge and bad check charge) and other charges provided in this Agreement; (c) credit
insurance charges, if any; (d) collection costs permitted by applicable law, including reasonable attorneys' fees; and (e)
amounts in excess of your credit limit that we may lend you, plus Finance Charges.
Payments: You-may repay your entire outstanding balance at any time without penalty. You may not use your special
checks to pay any amounts due under this Agreement. Because the Finance Charge is computed each day, you will contact
us regarding the exact payoff amount for the day you intend to make full payment. If you do not pay the entire unpaid
balance on your Account at once, you agree to pay at least the minimum payment shown on your monthly statement.
Payments will be applied as follows: First, to any accrued but unpaid Finance Charges; Second, to any unpaid
Administrative Charges (the late charge and bad check charge); Third, to any unpaid credit insurance charges; and Fourth,
to the outstanding balance of your Account. Any part of your monthly payment to be applied to amounts borrowed on
your Account will be applied to the amounts borrowed under your Personal Credit Line Account in the order in which the
amounts were borrowed. Any part of your monthly payment to be applied to Finance Charges will be applied in the same
manner.
Minimum Monthly Payment: The Minimum Monthly Payment for any billing cycle will be the greater of (1) the
pima of SM or the ymen mount (as described below) plus any Administrative Charges and credit insurance charges,
rounded to the nearest $1; or (2) the Finance Charges due for the billing cycle plus any Administrative Charges and credit
insurance charges; or (3) the amount of the Annual Fee assessed to your Account. In each instance the Minimum Monthly
Payment will be adjusted to include any unpaid amounts due from previous billing cycles.
The Payment Amount depends on the monthly periodic rate applicable to your Account, and is calculated as follows:
Monthly Periodic Rate
through
over 1.33% through 1.45%
over 1.45% through 1.57%
over 1.57% through 1.70%
over 1.70% through 1.83%
over 1.83% through 1.95%
over 1.95%
Payment Amount
o ccount ance
1354E of Account Balance
1.67% of Account Balance
1.80% of Account Balance
1.93% of Account Balance
2.00% of Account Balance
115% of Account Balance
Finance Charges: This is the interest charged on the balance of your Account during each billing cycle. The Finance
C arge Is cx cu ated from the date that each advance, check or charge is posted to your Account. The Finance Charge is
- computed by multiplying the average daily balance-in-your Account in each billing c?rele times the monthly periodic rate
stated on page one. The average daily balance is determined by totaling all daily unpaid balances in each billing cycle and
dividing the total by the number of days in that cycle (but not less than thirty). A daily unpaid balance is the amount owed
each day, excluding any unpaid Finance Charge, Administrative Charges, and credit insurance charges for prior billing
cycles. -
Annual Fee: You agree to pay an Annual Fee as stated on page one for participation in this revolving credit plan. The
rattle nnua Foe is stated on page one and is due and payable on the date that your Account is established, and the
subsequent Annual Fee-stated on page one is due and payable on the seme?day of each sulieequentyear. You-ague that-this---
fee may be charged to your Account balances
Bad Check Charge: If you pay by a check which is returned for any reason, you agree to pay a bad check charge of $20.
Late Charge. If you do not pay any required Minimum Monthly Payment within 15 days after it is due. you
agree to-pay - -
s ate charge-of 10% of the Minimum Monthly Payment due or $20, whichever is greater (excluding any unpaid late
charges and amounts due from prior billing cycles).
NOTICE SEE THE FOLLOMN-O PAGES FOR ADDITIONAL PRUM1099 AND IMPORTANT INFORMATION REGARDING-YOUR RIGHTS TO-DISPUTE BILLING- - -
ERRORS.
f3&1 00 -- ICI I??¦®MM?1111?? NI?.??I?N?I PA066362
"LOISCa41FLSWAASO00PAOS63620""LOPP ¦ ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4)
Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the
Personal C re 1 Line Account for foes paid to public officials in connection with perfecting, recording, releasing or
satisfying a security interest in the security. You agree that these fees may be charged to your Account balance.
Exchange of Information: You understand that from time to time we may receive credit information concerning you
from o, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a
regular basis, we obtain related to your Account, including but not limited to credit reports and insurance information,
with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an
inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information
regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the
sharing of such information (except for the sharing of information about transactions or experiences between
us and you) by sending a written request which contains your full name, Social Security Number and Address
to us at P.O. Box 1547, Chesapeake, VA 23320.
If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be
submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent
of such department) may release your residence address to us. should it become necessary to locate you. You agree that
our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the
quality of our service to you.
Terminstion and Changes in the Agreement: We can terminate your right to obtain additional advances or
change The terms o is Agreement, me u tng increasing the rate of Finance Charge at any time. Prior written
notice will be given to you when required by applicable law unless you consent to the change before that time.
Changes may apply to both new and outstanding balances unless prohibited by applicable law.
Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other
acmVW u unpaid c get Immediately a or to cancel your credit privileges under this Agreement because of:
(a) failure to make any payments in full when due under this Agreement;
(b) frequent overdrawing of your dine of credit;
(c) failure to supply us with any information requested;
(d) supplying us with misleading, false, incomplete or incorrect information;
(e) breaking any of the promises, terms or conditions that are contained in this Agreement;
(f) the filing of a bankruptcy petition by or against you;
(g) the death of any borrower who signs this Agreement; or
(h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a
subordinate lien).
After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other
collection costs related to the default, if not prohibited by applicable law.
Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the
contract rate until paid in full.
- YOUR-BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important imformation about your rights and Lender's responsibilities under the Fair Credit Billing
Act.
Notify Lender In Case of Errors or Questions About Your Bill
If you think your bill is wrong, or if you need mnm_information about a transaction on your bill. write Lender on a
separate sheet at the address listed on your bill after the words: "Send your billing error notice to: (Lender's, name and
address)." Write to Lender as soon as possible. Lender must hear from you no later than 60 days after Lender sent you the
first bill on which the error or problem appeared. You can telephone Lender, but doing so will not preserve your rights.
NOTICE: SEETHE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISKM BIWNG
ERRORS.
f3NRE-00 lull PA056363
N1019C641FL96RLA6NWAD563630mmLOPP -- " - ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4)
In your letter, give Lender the following informatioh:
• Your name and account number.
• The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the
item you are not sure about.
Your Rights and Lender's Responsibilities After Lender Receives Your Written Notice
Lender must acknowledge your letter within 30 days, unless Lender has corrected the error by then. Within 90 days, Lender
must either correct the error or explain why Lender believes the bill was correct.
After Lender receives your letter, Lender cannot try to collect any amount you question, or report you as delinquent.
Lender can continue to bill you for the amount you question, including finance charges, and Lender can apply any unpaid
amount against your credit limit. You do not have to pay any questioned amount while Lender is investigating. but you are
still obligated to pay the parts of your bill that are not in question.
If Lender finds that Lender made a mistake on your bill, you will not have to pay any finance charges related to any
questioned amount. If Lender did not make a mistake, you may have to pay finance charges, and you will have to make up
any missed payments on the questioned amount. In either case, Lender will send you a statement of the amount you owe
and the date that it is due.
If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinquent. However, if Lender's
explanation does not satisfy you and you write to Lender within ten days telling Lender that you still refuse to pay, Lender
must tell anyone Lender reports you to that you have a question about your bill. And, Lender must tell you the name of
anyone Lender reported you to. Lender must tell anyone Lender reports you to that the matter has been settled between us
when it finally is.
If Lender doesn't follow these rules, Lender can't collect the first $50 of the questioned amount, even if your bill was
correct
Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Riders
signed as part o this loan transaction are Incorpore Into this Agreement by rcfavoce.
Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania
Consumer scount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated,
particularly Section 6217.1.
Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending
disclosures contained in it.
You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement.
This Agreement is entered under the applicable provisions of Federal law and the Pennsylvania Consumer
Discount Company Act.
(SEAL) I (SEAL)
mer 1 Ter gnat '
Date:
Witness: (SEAL)
I
03-1tij --
irrrrr??rrrrrr?
- "L619c611fLsMAa000PA0553640mut-WF- --
Date: Q- I- y q
(SEAL)
PA666364
ORI01WIt
,.
LOAN CLOSING STATEMENT (Par I of 1
REVOLVING LOAN VOUCHER
CREDITOR
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE 104-HAMPOEN CENTER
MECHANICSBURG PA 17050
BORROWERS LOAN NO: 711714-13-510889
LOPP 111, JOSEPH W
LOPP, KANDI L
103 CENTER ST
ENOLA PA 17025
Borrowers agree to and direct the disbursements and Advance indicated below. If any estimated amount shown below
varies from the actual amount paid, Borrowers agree to the disbursement of the actual amount and a corresponding
change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan
Agreement (account number shown above.)
Initial Annual Fee ............................................................9 50.00
CASH OR CHECK TO BORROWER .....................................................f 14050.00
TOTAL ADVANCE(S) .............................................. ................ f 15000.00
Bo W s:
3w INH?111?Ir?111i?11?1???11
"L019Ca41FL99RLV9000PA1379210"iq.OPP - ¦ ORIaIWIl PA1329T1_ _
ARBITRATION RIDER
United States
and this Arbitration Rider, this Arbitration Rider shall govern. No class actions or joinder or consolidation
of any Claim with the Claim of any other person are permitted in arbitration without the written consent
of you and us.
No provision of, nor the exercise of any rights under this Arbitration Rider shall limit the right of any
party during the pendency of any Claim, to seek and use ancillary or preliminary remedies, judicial or
otherwise, for the purpose of realizing upon, preserving, protectlop, or foreclosing upon any property
involved in any Claim or subject to the loan documents. The use of the courts shall not constitute a
waiver of the right of any party, Including the plalntK to submit any Claim to arbitration nor render
Inapplicable the compulsory arbitration provisions contained in this Arbitration Rider.
THE PARTIES ACKNOWLEDGE THAT THEY HAD A RIGHT TO LITIGATE CLAIMS THROUGH A
COURT BEFORE A JUDGE OR JURY, BUT WILL NOT HAVE THAT RIGHT IF EITHER PARTY
ELECTS ARBITRATION. THE PARTIES HEREBY KNOWINGLY AND VOLUNTARILY WAIVE THEIR
RIGHTS TO LITIGATE SUCH CLAIMS IN A COURT BEFORE A JUDGE OR JURY UPON ELECTION
OF ARBITRATION BY EITHER PARTY.
You may contact, obtain the arbitration rules of, or file a Claim with NAF or JAMS as follows:
National Arbitration Forum (NAF)
P.O. Box 50191
Minneapolis, MN 55405
(800) 4742371
Code of Procedure
rmn r4dium
Date:
Date: a "C? I-
BENEFIC SUM DISCOUNT L_OMPANY Q - Date.
09421/2004 12:48 -Page 2 of 2 - 0111LE05- - - -
1-millmilli 1III0111,1111111111011
L019MIR - 98- xAR - 8 - 000 - 01111.E -Z-2- 0' LOPP" ORtGOM
JAMS/Endispute
55513th Street NW
Suite 400 West
Washington, DC 20004
(800) 352-5267
Financial Services
Arbitration Rules and Procedures
Borrow .
OSEPH W. L P 11I.
VERIFICATION
The undersigned, Gregg L. Morris, hereby states that he is the attorney for Plaintiff in
this action and verifies that the statements made in the foregoing pleading are true and correct to
the best of his knowledge, information and belief. Counsel has signed the verification at the
request of Plaintiff as a matter of time and convenience. Plaintiff has represented to counsel that
there is a debt due and owing from Defendant to Plaintiff in the amount as set forth within the
foregoing pleading. Plaintiff has provided counsel with all relevant information in order to allow
counsel to sign this verification. Plaintiff agrees to provide a verification signed by Plaintiff
upon request by Defendant. The statements are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities. 1 ?
Date:
P en de & Felix, A.P.C.
2 Main Street
Carnegie, PA 15106
(412) 429-7675
PA_01 Atty Verification P&F File No. 07-28311
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11 SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01859 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL
VS
LOPP JOSEPH W ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
LOPP JOSEPH W III the
DEFENDANT at 1706:00 HOURS, on the 31st day of March 2008
at 103 CENTER STREET
ENOLA, PA 17025
by handing to
JOSEPH W LOPP III
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 18.00
Service 13.44
Postage .58
Surcharge 10.00
.00
WJDF??F ??-. ? 42.02
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
04/01/2008
PATENAUDE & FELIX
By. 4
Deputy Sher' f
A. D.
S
CASE NO: 2008-01859 P
LOPP JOSEPH W ET AL
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL
VS
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
T nT)T) V7TTTMT T. the
DEFENDANT , at 1706:00 HOURS, on the 31st day of March
at 103 CENTER STREET
. 2008
ENOLA, PA 17025
JOSEPH W LOPP III
by handing to
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
41bt Ibt `/- 16.00
Sworn and Subscibed to
before me this
of
SHERIFF'S RETURN - REGULAR
day
So Answers:
Thomas Kline p
04/01/2008
PATENAUDE & FELIX
By:
Deputy Sheriff
A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL
Plaintiff
NO. 08-1859
V.
JOSEPH W LOPP III and KANDI L LOPP
Defendant(s)
PRAECIPE TO
DISCONTINUE WITHOUT
PREJUDICE
Filed on behalf of:
BENEFICIAL
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_ 170 Prcp Disc w/o Pr do P&F File No. 07-28311
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL
Plaintiff
NO. 08-1859
V.
JOSEPH W LOPP III and KANDI L LOPP
Defendant(s)
PItAEC'IPF TO DISCONTINUE WITHOUT PREJUDICE
TO: Prothonotary
Please discontinue the matter captioned above without prejudice. Thank you.
submitted:
& Felix, A.P.C.
Date: June 12, 2008
Mw N;ay nd subsc ' ed before me this
o ,2 0?
Notary Public
L.
? 13 E. Mai eet
C A 15106
(412) 429-7675
NOTARIAL SEAL
HEATHER L GOGAL
Notary Public
CARNEGIE BOROUGH, ALLEGHENY COUNTY
My COMMIalon Explfe$ Oct 19, 2011
PA_170 Prcp Disc w/o Ndc P&F File No. 07-28311
„'. ; 7 ?. ? rr' T ? Yk
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I, GREGG MORRIS, attorney for Plaintiff, BENEFICIAL, hereby certify that a true and
correct copy of foregoing document was served this date by ordinary mail upon the following:
Dorothy L Mott, ESQ.
125 State St
Harrisburg PA 17101
Date: June 12, 2008
PA- 170 Prcp Disc w/o Pr do P&F File No. 07-28311
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
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