HomeMy WebLinkAbout08-2944Robert D. Kodak, Esquire
Supreme Court I.D. 18041
KODAK & IMBLUM, P.C.
Post Office Box 11848
407 North Front Street
Harrisburg, PA 17108-1848
717-238-7152 Fax: 717-238-7158
email: robert.kodak@verizon.net
Attorney for Plaintiff
BB&T CREDIT SERVICES, INC.
Plaintiff
Vs.
JAMES R. WRIGHT
Defendant
IN THE COURT OF COMI?ION PLEAS
CUMBERLAND COUNTY,, PENNSYLVANIA
CIVIL DIVISION -LAW
NO. as- dggq C:4v?l. lie
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 e warned that if you
fail to do so the case may proceed without you and a judgment may be enterd 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 SE FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION A OUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE AY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA " Y OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
BB&T CREDIT SERVICES, INC.
Plaintiff
vs.
JAMES R. WRIGHT
Defendant
IN THE COURT OF COM:
CUMBERLAND COUNTY
CIVIL DIVISION -LAW
NO.
COMPLAINT
The Plaintiff, BB&T Credit Services, Inc., by its attorneys, Kodak &
[ON PLEAS
PENNSYLVANIA
Imblum, P.C., brings
this action of Assumpsit against the Defendant to recover the sum of $14,074.87, along with interest
thereon at the rate of 9.59% per annum from February 28, 2008, upon a cause of action of which the
following is a statement:
1. The Plaintiff, BB&T Credit Services, Inc., is a corporation of
under the laws of the State of North Carolina, having its principal office an
1410 Coulter Drive, Roanoke, Virginia 24012.
I
2. The Defendant, James R. Wright, is an adult individual residin?
Mechanicsburg, Cumberland County, Pennsylvania 17050-3086.
I
and existing
l place of business at
at 4744 Brian Road,
bixomp:34291 bb&t.wpd:29N0v06
3. On or about March 31, 2007, the Defendant entered into an 14tallment Sale Contract
and Security Agreement for the purchase of a 2003 GMC Yukon. A true and correct copy of said
Installment Sale Contract and Security Agreement is attached hereto, marked Exhibit "A" and made
a part hereof.
II
4. The Defendant defaulted on his obligation to make payment, and refused to honor
the remaining contract payments.
?I
5. Defendant's vehicle was repossessed with an outstanding bal ce due and owing of
$27,934.26.
6. On or about September 14, 2007, Defendant's vehicle was s?ld at sale for the sum
II
of $16,900.00.
il7. Defendant was notified of the sale of said vehicle and the defi0ency balance due and
owing in the amount of $11,729.06 as per Plaintiff's Exhibit "B" attached hereto and made a part
hereof.
8. The current balance due and owing by Defendant to Plaintiff is
as set forth on Plaintiff's Affidavit attached hereto, marked Exhibit "C" and
sum of $11,729.06
a part hereof.
hixomp:34291 bb&t.wpd:29Nov06 2
9. Due to the default of Defendant, and pursuant to the term
Installment Sale Contract and Security Agreement at Exhibit "A", attorney's
of $2,345.81 have been added to said account.
and conditions of the
,es in the total amount
10. Plaintiff frequently demanded payment from Defendant of said amount due and owing
as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount
of any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant
along with interest as set forth herein.
Respectfully submi
KODAK &Imk
1e sum of $14,074.87,
Robert D. Kodak, EsquI
re
407 North Front Street
Post Office Box # 1184
Harrisburg, PA 17108 1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
bi:comp:34291 bb&t.wpd:29N0v06 3
'(Page .2 of 13)
w
4 Bl?&T INSTALLMENT SALE CONTRACT A nU
FWY AGREEMENT (PENNSYLVaauet
WRIGHT l U
Lap tdarrw arose
PrrNse a Pay: You Wonsae to pay us the Amount Fln shown be Thar 944-0849439
. shown h .
AIWUAL FtNANCm '=F ed
PERCEMTAGE RATE The dolt Tirnt d crarlt The amount u cell ? ?rrce
.aid yo _ The total cost of
yo1V
see o ydeary rate pay as Provided «on he- whorl You as Purchase on credit, irmchafrmp
You
scheduled d 0,40-
Psymermts: You era repay, this contract g&__=Xscutive monthly payments of $
rmmmencinGO3 MAX '•'
Security Interest: You give us a security interest in the property being purchased.
Pragymant: If you pay off early, you will not have to pay a prepayment penalty.
isle Charge If payment is rot paid in full whW 10 days after it is due, you will pay a lap ohhage. The dharge will be 2% per month d the
part of the payn ant that Is top, igued based an a ktl calendar month for any part d atlas tiho is more Iran 10 days.
Other Terms: You must rotor to the reverse akte of thle form for addlNorwl inWrionlon about nahpaymeM defauh , and any
required repayment at this obligation In full before it* sdreduled date.
I you do net meet yarn oontract obligations. You any bee the oroaartr-
1. Cash Price of Vshmide _ - - - ^nnm.cv
a. Vehicle Cash Price S_ c: Accident a Health Insurance S
IT b. Saks Tax 11-MIG 001a _ d. Optional Service Contract $ - !!A
c. Total Cash price $ 2644 .08- To:,,l. - - N7ry¢-
2. Down Payment r A
a. Castro S_? NJ N/A?
Term
n b. Trade-in Allowance $ S. 0--mMI Certificate of Titluctible
e Fees $
Less: Amount Owing S I. ' f. Govemmern ucense
Net Trade-in: ancyor Repktratkn Fees
Trade-in: LldentiNl $ At nn
Cv ce - lodai- Yaarg. Other Chargea ta" wAw *" who Is wid rm arc I pAvewn;
_ „?
3. llrgTotal Down sld Balance of Cash Price ---@ 0@ - To For $
4. Other Items Financed S ?- TfAttlit - ?- $ -- W-
(Seller may retain a poison of these charges I. Tote) Other Items Fkernoed $ MIA
to the extent permitted by law) 6. Principal Amount Financed (3 + 4(f)) $ _171117w_
a. To: °f negative N S A 6. France Charge $ 26565'50'-
D. Credit Lie insurance $ 7. Time Balance (5+ 6)
S
_ ate,
SUMMARY NOTICE REGARDING PREPAYMENT AND REINSTATEMENT:
You may prom all or pan at the mourn you owe under Oft Contract at any tirtn without penalty. Soft rovr, charges or
rebates unseated thane chwgw it you dorrl and SNIT MP-@Sm the property, Seller may (but need not) doer
You to pay the amounts you owe Mier to go IM properly back and nNnetap this Contact
Credit Insurance: You are not required to purchase credit as or accident and hasp, insurance. Upon the death of the Insured, credit Nis
insurrrc• pays the scheduled unpaid Pon oldie Amount Financed. During she diaadlity of the Buyer and subject to the benefit waiting
RLAW, accident 8 health Insurance the scheduled mo
nthly
ante.
Type Poemium Tens agnN?+olq
S Single
Credit (Sxgle S N/A By dPAq. You selea wdt Me insurance.
You may oWairfV011irly'Im mince from anyone accept" to Seller.
ern we nit. a sew pnopeny err coon danaged and popery insurance In not tulficisnt to cove are
Sae an GAP adandurn for 0!!4 deWle of your GAP coverage. The lee for Dept CncooNsillon 0
Radio p -- 0 woW Tan. p P.& ;;*91
11 gram to the Seller a ssrxrrly interest In the form of a
r no A111111111111 rercergage Nap may
• part of the Finance Charge.
46120
rot men on the see to the property, or in accordance with the lAyform
The Seller may assign this contract and rosin its right to recNw
Notice to Buyer.
Do not sign this contract in blank. You are entitled to an a act co the contract you sign.
Keep it to protect your legal rights.
4601 CARLISLE P)KF CHANICSBURG PA 17050
Ad*- aw« n apiece.
luca
BY SIGNING BELOW YOU ACKNOWLEDGE THAT YOU HAVE READ AND RECEIVED AN EXACT
COPY OF THIS C&NAC AND YOU AGREE TO BE' JOINTLY AND SEVERALLY BOUND BY ITS
TERMS. l,Y TH E THAT APPEAR ON THE REVERSE SIDE.
Co Owner You agree to be fully bound by the security Interest provisions of this contract, waive presentment
demand red notce old or, and a- - t- curry extension or extensions of time that may be granted in connection with thle cgmtract
sw? -am Car- a
Guw-W:Byaigrsrgbokw,youW-woop"nwma-4parkrmsrrcedaldtlrdo ti0"ssalraNh ,,, ?nw
notion ddishonor, and#intonellkdanySUMexemption lowr to the proPerlY ba^g purchao•d, and agree dto eery to aw rd,wdw extension d meter or asmpameor., o
crierm
ods
cations not may be granted in aorvnectbn with this agreement.
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• ADDI IONALTERNIS (PENNSYLVANIA)
Charges: This is a $11111310 Wwtoa dwgee contract. Finance chsi w wB scxue 9n the unpaid balance on a dally basis.-Pay,
ffwft will be applied Ilat b accrued Mwm charges, Dust to principal, then to lets charges, it any. hAonOdy payments meals before or alter
the due date will afoot ft amount of i I - paid. The anal payment may be more or fees than the originally scheduled amount, depend.
Ig an the timing of ea0er payments reletiw to DnI scheduled due dates. NOD Wm of the ikal payment amount will be malted. The
Seller may retain a portion of the flunoo charges. The APR may be negob" with ft Seller.
DetNMtlora: -ft. 'your and 'yours' veer to the Buyer(s). 9; 1ws. 'me• &W *us* refer to the Seller or the Sellers and anyone to whom
Ito SOSer assigns this oontraet.
Security; on the hold of and Care of ??tY: You oleo OW us a security interest in any parts or things you add to to property described
undl you _ aWmn@ M. as was as in any uneaned Insurance premiums and/or service contracts. We WII keep We to the
obtain a how repaid Ilerm. Yee coiac. During Dais time. you agree not lo sell,: tease or give der properly to anyone sta. n6r allow anyone to
seaaMy Ihtaast against b. You agree to'use b carefully and keep it In good repair. You agree not to more the
property from any of tla addresses Aided on the font of ft agreement, except for temporary.parlode or upon written notice to us and with
our written approval. You agree not to we or permit anyone to use the property as alaxi bab or delivery vehicle or in violation of any taw.
kuurance; Taxes: Ybu shes remain hood by this agreement even If ft property to lost or damaged. Ntu agree to mabtakh collision and
comprehensive Isuralce and ottan"tw Yssxe the property against d$ke as we may require. The insurance policies must name us as tle
cep The policies must also say that we will be noosed within ton days it the Insurance in canceled. You shall dNhar the policies to our request. N the property Is lit or damaged, we may use the Insurance proceeds to repair or replace R. or to repay any amounts
you owe us. Ule may act an ym behalf n making and a$" insures ce dales and we may sign your name(s) on any drafts drawn by the
Mswes. You shall pry all totes and fees all On property when dus. lf you fall to do so, we shall have Ute right (but no obligation) to Insure
ft property or pay any tax or be and you Mall raimburw us wfth Iterest et the annual percentage rate you are paying on the contract.
Prepaymerst: You have ft right to repay to unpaid balance in full of in part at any time.
Default and Repoessedon: Ntu will he in debulf:
1. N you fall b make any payment w1MMe 10 dogs of Its due date.
2. If you beak any opus promise you have. made to us in this agreement or in connection with any other agresmeM with us.
3. If you dsa beans bsalvftoray otyw property is tw amhjad d a proooo ft in bw rupicy niheaft orrowga WWw.
4. say popery swwkg Mi$ agrienwa is IoM atom, K6sWrd* damaged, dwloyed, sold, or cordacaled by gwernme a aahoridec.
5. If you make any bar or misleading dabernwnt(s) in connection with ft agreement.
If you are In default, we may om peer all relnainlg payments b be dos and payable, without giving you notice. You agree that our rights
of possession will be greater Man yours. Nee will defier to property to us at our request. or wa nay use lawful means to take s oLK$aae
wisroui notice or other I"M wkn. We try is De prepery after giving proper ratite to you at YOLK most roost address on our records.
We may apply lee p?oosede of tlW sale toward what you onus us. Nee agree to pay the difference between tls $We proceeds aed What you
we us. We may claim benefits under any Ins canoe policies andor service contracts and terminate them to obtain refunds for unearned
charges. '
To De Indent permitted by law. we may add to whatyou oWe us any tees pakfbras oats of repossession anti safe or for enforcing your
obligations. In lea event it becomes neces Lary for counxN employed or retained by us to institute legal proceedings to celled your
obligation or protect any security, you apes to pay our attomeW fees and the cam costs we incur in enforcing our rights under this
agreement tofill coolant pw itted by low.
TradalniYbu'cantsy, that you own free and dear, except as disclosed to ua, any trade-in property described on the front of Dda agreement.
Law That Applies: ether Terms: Pennsylvania low and ederal law govem'this ag esmant lf we excuse one debut by you that will not ?I
excuse later delauss. Neer heirs and reprowdesves will also be bound by ft agreement. You walve tle benNft of any state aampson
few as to the property being purchased, 0 any part of this contract becomes Illegal or unenforceable, gat Illegality or LKrenbrceabaly
shelf not affect to ramMrder of the contract.
There are no warranties by SMIa , ameaaesd w Implied. Including warranllu of magwNsMlBy, and lsness for a particular
p rpow It, however, we make a - what warranty covering the vehicle or, within 90 days from the doe of this, contract, we
oxtail a service contract covering Use vehicle, the ewiuslon of warand" shall not affect any Implied warranties during
the term of Ile applicable written wor aely w service oontrwL
NOTICE
ANY HOLDER OF THIS CONSUMER CREW CONTRACT IS SURIECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD
ASSERT AGAINSTTHE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOV-
ERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
ASSIGNMENT
Seca asst and esslpns this Istasnant safes contract and sacrky agreement and es Seller's right, boo and interest in the motor vehicle
herein described to BUT Crack Services, Inc.. ('Landon. Seger represents and werfants that ft agreement arose from the We ot its
motor vehicle, and Is gam+Ia. accurate, erdwasable, and the only agreement executed by Buyer for ft motor vehicle: that Buyer is of the
age of majority and otherwise had legal capacity to contact; Dmat Under shell have a valid lkat Ian on ft motor vehicle sold under this
agreement; executed by Buyer for the motor while agreamird; that all statements contained In ft apeenwit and in the Buyer's credit
app/ealion are sue and cenrec to rice beat of SWW's knowledge and bNIM; Mat sit motor vehicle has been dasvered to and scooped by
Buyer. Mat SaW knows at no dele se, astoff or cmrderdaim available to Buyer: Dot no corsidepMon other than she motor vehicle
described has been or will be advanced a Buyer in ocermlion with this Vansaglon; and at the time of safe. Seller was vested with
absolute file or absolute wt o tty to sell ft vehicle to Boyer free of as fens or security interests of any parson. Sofa epees to Indemnity
and hold Lender harmless from all ins, aspense and liability Incurred from any breach at Sellers warranties above or Incurred because of
any claim of violation of any ederal, ales or boil shuttle. hie or regulation, regardless of SOSer's luowfedge or lack of knowledge thereof
and regardless of Lenders knowledge or lack at knowledge thereof. ihdudkp, but not limbed to. those related to truth-in-landing diaclo- -
tyres, dmlel or deceptive acts or practices and a" credit opportunity, and fo accordance with and subect to the terms and condgbns
checked below:
? WITHOUT RECOURSE
err
a WITH RECOURSE: Undersigned guaanWas prompt and full pelfamance of all the undertakings and obligations thereunder of
Dire Buyer Derain rwr d:
El FULL REPURCHASE: Wit w recoures except that unckudge d agrees to repurchase the motor vehicle, to urpeld portion of
Do purchase price of which is represented by tie agreement, subject to tie terms d Lender's agreement with tit uderalgned.
? PARTIAL REPURCHASE: Mw emuea, a mW Dee lf se motor vehicle Is repossessed, with 4111 urpaid portion at purdles0
price as represented by tle will in agreement, undersigned will pay such unpaid balance of the purchase prim and receive do
vehicle. or in Iles thereof. will pay an demands and rWIr4uWl as rights to to vehicle wil oui water
d:ltgawn. If moor vehicle is not repossessed and Buys IS In default, his whereabouts either known or unknown, undersigned
will pay to Larder on demand any amount due on the purchase pia up to ft dollar sum mentioned in shy pwa~, and will
resngulsh all rights to th vehicle wriDelx further obligation. Undersigned M?9bY waives protection under any underlying deafer
agreement.
El LASTED REPURCHASE: Without rwourse except that V Mre Buyer rammed Dwain falls to pay installments,
MWO undersigned will PLKdme to motor vehicle. ft unpaid portion of ft purchase pupa of whidn le represented by the within
agreement, shlbjod to the terms of Lenders dealer agreement with the undersigned.
Signed BL Dealer (SEAL)
rl /ahrilrn6 eshh! ueehar
(Page 12 • of 12)
Branch Banking do Trust Co.
INGOVery D"Mt" d
i
December 07, 2007 .o. Bic 1489
NC 26359-1489
James Wright
4744 Brian Rd
Mechanicsburg PA 17050-3086
Re: 94408494391001
2003 GMC Denali
1 GKFK66U83J 146120
Recently, BB&T repossessed the above referenced collateral and notified ou that it
would be sold at private sale unless you redeemed it or secured a person o was both
willing and able to purchase the collateral.
This notice is to provide you with an accounting of the disposition of the proceeds of the
sales and to advise you of the remaining balance owing on the account. Th accounting is
as follows:
I
Loan Balance at Time of Repossession $27,934.26
Plus Expenses Involved With Repossession $694.80
AMOUNT OWED BEFORE SALE $28,629.06
Proceeds From Salc of Collateral $16,900.00
Other Credits $0,00
I
Less Total Amount Credited To Account $16,90D.00
r
Balance Owing $11,729.06
The Balance Owing is due and must be paid. In the event that you can not y the
account in full, please call the Representative listed below and discuss the possibility of
establishing a plan of repayment that is satisfactory to both you and BB&T
In the event that you do not pay the Balance Owing in full or contact BB& to establish a
satisfactory plan for repayment within ten days from the date of this letter, our account
will be reviewed for further action.
Our office hours are Monday-Thursday, 8:30 a.m.-9:00 p.m. and Friday, 8:I 0 am.-5:30
p.m. EST.
Thank you for your prompt attention to this matter.
9
Maria Bridwell
1-800-459-2689
Y
AFFIDAVIT 9- INDIRECT SOLD AFFIDAVIT
VIRGINIA:
BB&T Credit Services Inc
A Corporation, )
Plaintiff, )
V.
James Wright
Defendant (s). )
STATE OF VIRGINIA )
CITY/COUNTY OF ROANOKE )
I,Teresa A. Slate, being an individual over the age of 18 and competent to testify,
follows:
and depose as
1. That I am an employee of Branch Banking and Trust Company
2. That Branch Banking and Trust Company is the authorized agent of the Plaintiff r purposes of
collecting this debt;
3. That the following facts are true:
a. that on or about 3/31/2007 defendants signed an Installment Sale
And Security Agreement bearing interest at 9.591/o, a copy of which is
hereto;
b. That on or about 8/9/2007_ Defendants(s) defaulted on said
Contract;
c that Plaintiff repossessed and sold the collateral securing said contract;
d. that on 12/7/2007 , Plaintiff sent notice to Defendant(s) showing
the application of the sale proceeds and demanding payment of the
deficiency balance in the amount of $11729.06
e. that $0.00 has been received and applied to the deficiency balance,
Adjusting the balance now due and owing under the contract to $1172!
and;
f. that under the terms of the contract, Defendants(s) is (are) liable for atto ey
fees and court costs incurred by Plaintiff in any action to collect the bal ice due under the
Contract as permitted by law;
4. That the debt herein described is now due and owing from Defendant(s) to Plaintiff,
And
5 _x The defendant is not now on active military service as defined by the Service Members Civil
Relief Act
or
Based upon my review of the credit application, credit report, and/or other demographical data,
the defendant is, upon information and belief, in the military service.
I DO SOLEMNLY SWEAR AND AFFIRM under penalties of perjury that the contents of the for going affidavit are
true to the best of my knowledge, information and belief /? ?
(? = 154
Banking Officer of Branch Banking and Trust Co.
Subscribed and sworn to before me
This 28 February 2008
No ary Public
My Commission Expires: ;P;/ Day o'AV--Z V1q
MAY-02-2008 09:09 FROM:
T0: 717 238 7158 P.6/7
VERIFICATION
1, Teresa A. Slate
(muse)
of BB&T CREDIT SERVICES, INC., verify that the statements made in the
(ui1.)
document are true and
correct. I understand that false statements herein are made subject to the penalties of 1 ? Pa. C. S. §4904, relating
to unsworn falsification to authorities.
BB&T CREDIT SERVICES,
By:
Title:
Dated: 5-2-06
34291
".?
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0
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02944 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BB&T CREDIT SERVICES INC
VS
WRIGHT JAMES R
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
WRIGHT JAMES R but was
unable to locate Him in his bailiwick.
COMPLAINT & NOTICE ,
He therefore returns the
the within named DEFENDANT , WRIGHT JAMES R
4744 BRIAN ROAD
NOT FOUND , as to
MECHANICSBURG, PA 17050-3086
DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing 18.00
Service 10.00
Not Found 5.00
Surcharge 10.00
.00
h?la?t?b8? 43.00
So answe ,-'
R. Thomas Kline
Sheriff of Cumberland County
KODAK & IMBLUM
05/27/2008
Sworn and Subscribed to before
me this day of
A. D.
M t
ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM, P.C.
PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7152
ATTORNEY FOR PLAINTTFF
BB&T CREDIT SERVICES, INC.
Plaintiff
v
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY,
PENNSYLVANIA
NO. 08-2944 Civil Term
JAMES R. WRIGHT
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-referenced matter for service upon
Defendant(s) as follows:
James R. Wright
c/o: New Penn Motor Express
475 Terminal Road
Camp Hill, PA 17011
TO: Cumberland County
Prothonotary
Robert D. Kodak Attorney fo intiff
Attorney I.D. No. 18041
Email: robert.kodak@kodak-imblum.com
Dated: Tune 28, 2008
1 a .` l acs
• SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02944 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BB&T CREDIT SERVICES INC
VS
WRIGHT JAMES R
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
WRIGHT JAMES R
unable to locate Him in his bailiwick
COMPLAINT & NOTICE ,
but was
He therefore returns the
NOT FOUND , as to
the within named DEFENDANT
, WRIGHT JAMES R
POE: NEW PE MOTOR EXPRESS 475 TERMINAL ROAD
CAMP HILL, PA 17011
HAS NOT WORKED HERE SINCE FEBRUARY 2008; NO HOME ADDRESS
KNOWN.
Sheriff's Costs:
Docketing 18.00
Service 14.00
Postage .42
Surcharge 10.00
Not Found nn 5.00
711slo F `M 4 7. 4 2
So answe
R. Thomas Kline
Sheriff of Cumberland County
KODAK & IMBLUM
07/14/2008
Sworn and Subscribed to before
me this day of
A. D.
TIDE PRO
CUMBERLAND trt. o,, ; .
PENNS?'LVAH t%
ROBERT D. KODAK, ESQUIRE
KODAK LAW OFFICES, P.C.
PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-71.59 ATTORNEY FOR PLAINTIFF
BB&T CREIDT SERVICES, INC. IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
v
NO. 08-2944
JAMES R. WRIGHT,
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-referenced matter for deputized service
upon Defendant(s) as follows:
JAMES R. WRIGHT
637 OBSERVATORY DRIVE
LEWISBERRY, PA 17339
YORK COUNTY
TO: Cumberland County
Prothonotary ? 3 ?bll?
M4 D. Kodak Attorney for Plaintiff
Attorney I.D. No. 18041
Email: rkodak@kodaklaw.com D
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Dated: February 29, 2012 11. -7,5 ,ad NIX
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson -
Sheriff
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Jody S Smith
Chief Deputy ;P; 26 i"All l; 7
Richard W Stewart
Solicitor F,Fr CUMBERLAfil ?? ^ t
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BB & T Credit Services, Inc. Case Number
vs. 2008-2944
James R. Wright
SHERIFF'S RETURN OF SERVICE
03/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: James R. Wright, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint
and Notice according to law.
03/12/2012 09:56 AM - York County Return: And now March 12, 2012 at 0956 hours I, Richard P. Keuerleber, Sheriff
of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within
Complaint and Notice, upon the within named defendant, to wit: James R. Wright by making known unto
himself personally, at 637 Observatory Drive, Lewisberry, Pennsylvania 17339 its contents and at the
same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
March 21, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
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!N "bu a f,,n sh 1 7 4^oSJft hr
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber
Sheriff
Reuben B Zeager
Chief Deputy, Operations
PETER J. MANGAN, ESQ.
Solicitor
Richard E Rice, II
Chief Deputy, Administration
BB&T CREDIT SERVICES, INC.
vs.
JAMES R. WRIGHT
Case Number
08-2944 CIVIL
SHERIFF'S RETURN OF SERVICE
03/12/2012 09:56 AM -DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED
THE REQUESTED COMPLAINT IN CIVIL ACTION (CICA) BY "PERSONALLY" HANDING A TRUE
COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: JAMES R.
WRIGHTAT 637 OBSERVATORY DRIVE, LEWISBERRY, PA 17339.
SHERIFF COST: $45.20
March 15, 2012
NOTARY
MICHAEL IYONOVAN, DEPUTY
SO A S,
L
RIC RD P K ERLEBER, SHERIFF
Affirmed and subscribed to before me this Co o A TH PE.vNSYLUA ,A
Q
15TH day of MARCH 2012 jil
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CITY OF YORK, YORK C LINTY
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