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HomeMy WebLinkAbout08-3572I ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attorney for Plaintiff LEBANON FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA v NO. 3 S7 ctv?tr,?? DARREN J. REDDY and CHRISTA N. REDDY CIVIL ACTION - LAW Defendants 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 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. 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 Avlso USTED HA SIDO DEMANDADO/A 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 comparencencia 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 falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra 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 u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 LEBANON FEDERAL CREDIT UNION Plaintiff v DARREN J. REDDY and CHRISTA N. REDDY Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA NO. ©?--3S_77 a C1 v,1 +CC^ CIVIL ACTION - LAW COMPLAINT The Plaintiff, LEBANON FEDERAL CREDIT UNION, by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of TEN THOUSAND ELEVEN DOLLARS AND TWENTY-FOUR CENTS ($10,011.24) along with interest thereon at the rate of 9.49% from August 19, 2006, upon a cause of action of which the following is a statement: 1. The Plaintiff, LEBANON FEDERAL CREDIT UNION, is a banking institution organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 300 Schneider Drive, Lebanon, Pennsylvania 17046. 2. The Defendant, DARREN J. REDDY, is an adult individual residing at 1400 Bent Creek Blvd, #216, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Defendant, CHRISTA N. REDDY, is an adult individual residing at 1400 Bent F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\LEBANON FCU 34453.wpd 2 Creek Blvd, #216, Mechanicsburg, Cumberland County, Pennsylvania 17050. 4. On or about July 20, 2006, the Defendants did enter into a Pennsylvania Motor Vehicle Installment Sale Contract with Ladd Hanford Chrysler Dodge for the purchase of a new 2006 Dodge Charger, which contract was immediately assigned to Member Financed Autos as set forth therein. A true and correct copy of said July 20, 2006 Contract is hereto attached, marked Exhibit "A" and made a part hereof. 5. Said contract was assigned to Lebanon Federal Credit Union as set forth on the August 3, 2005 Assignment of Motor Vehicle Installment Sales Contract attached hereto, marked Exhibit "B", and made a part hereof. 6. The Defendants defaulted on the obligation to make payments, and refused to honor the remaining contract payments. 7. The Defendants' vehicle was repossessed with an outstanding balance due and owing of Twenty Three Thousand Seven Hundred Fifty Two Dollars and Seventy Cents ($23,752.70) as shown on Plaintiffs January 13, 2006 Repossession Notice, a true and correct copy of which is attached hereto, marked Exhibit "C" and made a part hereof. 8. Defendants'vehicle was sold at auction for Fourteen Thousand Nine Hundred Thirty Dollars ($14,930.00) as set forth on Exhibit "D" attached hereto and made a part F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\LEBANON FCU 34453.wpd 3 hereof. 9. The balance due and owing by Defendants to Plaintiff is the sum of Eight Thousand Three Hundred Forty-Two Dollars and Seventy Cents ($8,342.70) as set forth on Plaintiffs July 19, 2006 Deficiency Notice to Defendants, a true and correct copy of which is attached hereto, marked Exhibit "E" and made a part hereof. 10. The balance due and owing by Defendants to Plaintiff is the sum of Eight Thousand Three Hundred Forty-Two Dollars and Seventy Cents ($8,342.70) as set forth on Exhibit "E" hereto. 11. Due to the default of Defendant, and pursuant to the terms and conditions of the Pennsylvania MotorVehicle Installment Sale Contract, executed by Defendants and attached hereto as Exhibit "A", attorney's fees in the total amount of One Thousand Six Hundred Sixty-Eight Dollars and Fifty-Four Cents ($1,668.54) have been added to said account. 12. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of TEN F:\USER\ROBIN\CCP&D] CMPS\CCP COMPLAINTS\LEBANON FCU 34453.wpd 4 THOUSAND ELEVEN DOLLARS AND TWENTY-FOUR CENTS ($10,011.24), together with interest as set forth herein. Respectfully submitted, KODAK & IMBLUM, P.C. Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff PENNSYLVANIA 07/20/W.'.-: MOTOR VEHICLE INSTALLMENT SALE CONTRACT, Dated ce (y . ANNUAL FINANCE Amount Financed Total of Payments Total Sale Price PERCENTAGE RATE CHARGE The amount of credit provided The amount you will have paid after you The total cost of your purchase on The cost of your credit as The dollar amount the to you or on your behalf. have made all scheduled payments. credit, including pour downpayment W a yearly, Hate. credit will cost you. . 89 of $ 9.49 % Z 7253.60 s ' 22671.76 $ 29925.36 s 30572.25 Your Payment Schedule will be. S i No. of Paymen t of A"u, Payments hen Payrnerits Are Due ecur ty: You are giving .a security interest in the motor vehicle being purchased. t Monthly, beginning e a - Pr p yment: If you pay off eariy, you will not have to pay a penalty. LADD'HANFORD CHRYSLER DODGE MAZDA In this Contract 2247 CUM$SRI_AND STREET. we are the LEBANON PA 170412 SELLER. _ Name Address Zip Code DARREN J..REDDY County DAUPHIN 949 INNSBRUCK DR. the HUMMELSTOWN PA ` ' 17036 BUYER(S). the BU _ Name(s) Address(es) Zip Code(s) CHRISTA N. REDDY IF YOU DO* NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE THE MOTOR VEHICLE-AND PROPERTY-THAT YOU BOUGHT WITH THIS CONTRACT, AND/OR MONEY ON DEPOSIT WITH THE ASSIGN,EF_ , . This-Cotibact is between Seger and Buyer. All disclosures have been made by Seller. Seller intends to assign this Contract jq the Assignee. - ---- -• f.v?n?aoianuiv? wm?mnn:a n? use amountof S ??05.00„ *, If there is more than one Buyer, each promises, separately and together, to pay all Sums due.us and to pefform all agreements in this Contract pyid to t inn uealrnpn Buoy TRADE-IN: &salestaxof;" 2?9R 7Q): You have traded in 2004 VOLVO 840 YYIMS382942008685 the hallowing vehicle: Cash Price Year and Make, . Description $ 23204.70 Cash Downpayment If a balance is still ow g on the vehicle you have traded in, the'Se(ler will pay off this amount on your behalf. You warrant and represent to us that $ 500,*00 any trade-in is free frd n lien, claim, encumbrance or security interest, except as shown in the .1temizition'of Amount Financed' as-the 'Lien Payoff.` PROPERTY INSURANCE: You may choose.,the,pprson through.whom insurance is obtained against loss or damage to the Vehicle and against Trade In liability arising out of uie or ownership of -the yelricle.- In this Contract, you are promising to.insure the VetiihJ}a'and keep it insured, Value of TradeJn DEBT CANCELLATION (GUARANTEED AUTO PROTECTION) AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A CONDITION OF THE $ 19000.00 CREDIT. This agreement will not be provided unless you sign below, agree to pay the additional charge, and sign the separate disclosure and Lien Payoff to: agreement page, which• is part of this Contract This agreement will apply during the entire term of the Contract This agreement may not cover _ vour entire indebtedness- see the MAXIM[IM PR(1TFUMN simnunt datad in tho camra+a diwincnra 2nd 9amaman+ 1 A953, 11 Type of Debt Cancellation Agfeement Charge Signature Guaranteed auto protection (GAP) ; NA By signing, you select guaranteed auto protection. Signature of Buyer Unpaid Cash Price Balance Optional Debt Cancellation (GAP) . $ ma Document Preparation Fee SERVICE CONTRACT OR WARRANTY AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A. CONDITION OF, THE CREDIT. The service contract $ . 55, Big - or warranty agreement will not be provided unless you sign Ahe separate agreement with the third party provider, who is not the Seller named Paid to Others on Your•Be above, and agree to pay the additional charge. This section does not apply to any warranty that you may receive for which there is not separate charge To Public Officials for. . License, Tags and Registration CREDIT INSURANCE IS NOT REQUIRED: Credit Life Insurance and Credit Accident & Health (Disabilityr) Insurance are not required to obtain ; 4A- C119, c redit, and will not be provided unless you sign below and agree to pay the additional cost(s). Please 'read the NDTiCE-OF`: PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or policy wig tell you the MAXIMUM amount of insurance available. All insurance Lien Fee purchased will be for the term of the crediL We may receive a financial benefit from your-purchase of credit insurance. $ 5.00 By signing, you select Single Credit-Life Insurance, What is your I BY Signing, you select Single Credit Accident & What Is your Taxes Not.lncluded in Cash Price which costs; NA age? Years Health Insurance, Which costsT - NA' age?% Years S A Signature of Buyer to be insured for Single Credit Ufe Insurance I Signature of Buyer to be insured for Single Credit Accident & Health Insurance By signing, you both select Joint NA What are By signing, you both select Joint Credit NA Credit Life Insurance, which costs t your ages? Accident & Health Insurance, "filch casts = 1. 1 2. Filing Fees: $ Late Charge: If a payment is late; you will be charged 2% of the portion of the payment which is late for each month, or part of a month greater-than 10 days, that it remains unpaid. See below and any other Contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date and prepayrnwit . refunds and penalties a means estimate ?. Whoiare Percentage your ages? to be insured To $ NA For Messenger Service To . ' Z . NA -% for To Credit Insurance Company -% $ NA signatures of both Buyers tone Insured for Joint Credit-- , • A 'Signature! Of both Buyers.to be Insured for Joint - i Life Insurance Credit-Accident 3 Health Insurance For To I Ann I-IANEngn r Hgy-gl Insurer. $ " 5.00 - VEHICLE: You have agreed to purchase, under the terms of this Contract, the following motor vehicle and its extra equipment, which is called For p, ATI RE TAX .the'Vehicle" in this Contract' To M .Y ffMdMak > BYU al Ns._xL I(1AImCapacity srilllNumber S NA « N OW. CHARGER SDN b 20KA4313561-117840 DOD9 For Equipped _ A.T::._,.- P.S.. _ AM-t:M Stereo 5 Spd:, Other To With _ A.G..:T AM-FM Tape.: Vinyl Top j NA « ASSIGNEE: We may assign this Contract and Security Agreement to a sales finance company.which is the;1ssignee.' If the Assignee assign; For the Contract to a subsequent assignee, the term also refers to such subsequent assignee. After the assignment, all rights and benefits of the To Seller in this Contract and in the Seciirity.Agreement shall belong to and be enforceable by the-Assignee: The Assignee will notify you when and if.Seller makes an assignment S' NA "MEMBER FINANCED AUTOS For To' CO-SIGNER: Any person signing the t;aSignel's Agreement below. promises: separately add together with all. Co-Signet(s) and.: Buyer(s), :to pay all sums due and to. perform all agreements in;this Contract Go-Signermill not be an-Owner of theNehicle.. ; For CO-OWNER: Any person signing the Cc-Owner's Security Agreement below gives us:a, security interest in the•Vehicle and agrees sep$rately and Amount Financed together with all Co-Owner(s) and Buyer(s),-to perform all agreements.in the Security Agreement and all other par4gf this Contract except the s.. ..22671.76 "Promise to Pay' section. TERMS: The terms shown'in the boxes above are part of this Contract We may retain a portion of amounts marked' PROMISE TO PAY: You agree to pay.pi'the Total Sale Price.for the Vehicle by making the,Cash Downpiyment and aligning the Trade-In, if shown atiovon of before the date of this Contract; ant paying us the Amount, Pbab ed plus interest You promke le make payments in accordance With the Payment Schedule. You promise,to make. ppyments on of before,the same iday.of each illorith i the first payment due date:•Y.ou.agree to pay all other amounts which may become due under the terms of this Contract You agree to pay the Seller or Assignee costs of:sait You.also:agn;e to pa! reasonable attorneys' fees I Seller or Assignee hires an attorney to collect amounts due under this Contract or to protect or get possession of the Vebicle 'You agree to make payments at,the place or b send payments to the address which the Assignee most recently specifies, in the written notice k you. The Annual Percentage Rate ' be. negotiable With the Seller. ADDITIONAL DISCLOSURES, TERMS-AND CONDITIONS The Seller may assign thus do htlata and ' tyetain its right to Disclortirese Before sfgning'thb Contract, be sure'that you Feceive and read the: Disclosure tc recelve a part of4he Finance Charge. - Buyer. j : Terms and Conditions.: Before: signing this Contract, be sure you 'receive and read tht following, N marked f(, which are additional pages to and part of this Contract IM This Contract continues on the reverse side. O Debt Cancellation (guaranteed auto protection) separate disclosure and agreement By signing below, we agree to sell the Vehicle to you under the terms of this Contract SELLER LADD. HANFORD CHRYSLER. ISODGE MAZDA BY: NOTICE TO BUY . DO NOT SIGN THIS -CONTRACT IN BLANK. YOU ARE ENTITLED TO EXACT COPY OF THE CONT CT YOU SIGN. KEEP 41T TO PROTECT Y R'HTS. BUYER 07/20724 (SFAL)' ..Date VIEW 07/20/24 BUYER ? Date Date ... . CO-SIGNER: YOU SHOUIrb READ THE NOTICE TO CO-SIGNER, WHICH HAS BEEN GIVEN TO YOU ON A ARpTE DOCUMENT, BEFORE SIGNING THE CO-SIGNER'S AGREEMEN.T... . CO-SIGNERS AGR>f Wl4T: You,.tW.person.(or.persons) signing below as "Co-signer," promise to pay to us all. sums due on this ContraCt:and to perjorrn a17:. agrepments in this Contract. You intend to be legally bound.by all the•terms of thi3.Contract,; separately, and together, with the Buyer. You• are making this promise to tnducx us to make this* Contraet'with'the gayer,.even thoUgh•We' will use the proceeds only for the Buyer's benefit. You agree tb pay even thoiiih.wermay not have made any prior demand for payment on the Buyer or exercised our security idtereiit. You also acknowledge recdlving a completed-copy of this Contract. (SEAL) Co-Signer's Signature ' Address Date (SEAL) Co-Signerl Signature Address . Date CO-OWNERS SECURITY AGREEMENT: You, Rhe penrdn signing- below as "Co-Owner;" together.with the Buyer or otherwise being all of the Qwners.of the Vehicle, give us a security-interest in -the Value identirsed above. You agree to be bound-by-the terms' of the Security Agreementxnd:all-other pacts of.this Contracdt:except the "Promise To Pay" section: You are aching urthe security interest to induce Us to'make thia•Conti:tct with the•Buyer,.and to secure the payment by the Buyer. of all sums due on this Contract. You will not be responsible for any deficiency which might be due after repossession and sale of the Vehicle. - (SEAL) Co-Owner's Signature Address Date::. BUYER' C IGN R AHD .CQ.-OWN.ER, .IVAPPLICABEE,ACKN'OkED.GE RECEIPt:.OF A :COMPLET:ED-:Cq::PF•.:THIS CONT AT THE TIME OF SIGNINGf INCLUDING THE ADDITIONAL DISCLOSURES-AND.-PAGES LASTED 1NiTHE' SECTION CA ' ADDITIONAL DISCLOSUWEN D 0 ?JDITIONS. . BANCO10JW FORM PA 12W-%C WN) _ e? B YER CO-SIGNER CO-SIGNER OR CO-OWNER NOTICE: SEER RSE AE FOR IMPORTANT INFORMATION. ORIGINAL.- White • DEALER CDPY - Canary - BaiROwER'S/COSIGNER'S COPY . Pink - COPY - GoWentad • 2004 BANCONSUMER SERVICE, INC. J?? ADDItIONAL TERMS AND CONDITIONS ) ?-1 1. SECURITY AGREEMENT! To secure the payment of all sums due and the performance of all required obligations under this Contract, you give a security interest in the Vehicle, in all parts (called 'accession") attached to the Vehicle at any later time, and in any proceeds of the Vehicle, including insurance proceeds. The Assignee may set-off any amounts due and unpaid under this Contract against any of your money on deposit with Assignee. This includes any money.which is now or may in the future be deposited with Assignee by you. Assignee may do this without any prior notice to you. 2. HOW THE MAL OF PAYMENTS IS COMPUTED. The Total of Payments is the sum of the Amount Financed and the Finance Charge. The Finance Charge copsists solely of interest computed daffy on the outstanding balance of the Amount Financed. The Finance Charge shown on the front side has been computed on the assumption that we will receive all payments on their scheduled due dates. . 3. COMPUTING INTEREST: We will charge interest on a daily basis on the outstanding. balance subject to interest on each day of the ban term, including any period for which a late charge is also Imposed. The daily Weft rate is equal to the Annual Percentage Rate divided by the number of days in 'that calendar year. Buyer agrees.that because interest is calculated on a daily basis, late payments will result in additional interest (and, I applicable, a late charge). Ferry payments will result in less interest being charged. Early and/or late payments will cause the amount of the foal payment to change. 4. LATE CHARGE: Buyer agrees to pay a Ida-charge, for any payment not made within 10 days aft-its due date. The late chM will. be 2% pr month on the unpaid amount of the payment We will' consider any past of a month in excess of 10 days to be a- full month. The late charge will be due when earned. No late charge will 'be due if the reason that the .payment is late is because, after default, Pie.entire outstanding balance on this Contract is due. No late charge will be due N the only reason that the payment is late it because of a late charge assessed on an earlier payment. 5. APPLICATION OF PAYMENTS: We w.IN apply payments in the following order of priority: first.to interest; and then to late charges, fees, pdncipal and any other amounts you owe in the order that we choose. 6. PREPAYMENT: You. may. prepay, in full or in part,, the amount owed on this Contract at any time-without penalty. If you:prepay.the Contract in part,-you agree to continue to make regularly scheduled' payments urd you pay all amounts due under this Contract This will reduce the number of payments you will make. 7. WAIVERS. a. WAIVER BY SELLER AND ASSIGNEE: We and Assignee waive the. right to treat any property as security br the 'repayment of this Contract; except for the Vehicle and the other security specifically mentioned In this Contract b. WAIVEft BY BUYER, CO-SIGNER AND CO-OWNER: You sgfee td make all payments on or before they arc due without our having to ask H you dons, we may enforce our rights without notifying you.in advance. You give up any right you may have to require that we enforce our rights against some other. person or property before we enforce our rights against you. You agree that we may On up our rights against some other person_but not against you. You waive due diligence in collection and all defensesbbased on suretyship and impairment of collateral or security. 8. INTEREST AFTER MATURITY AND JUDGMENT: Interest at the rate provided in'this Contract shall continue to accrue on the unpaid balance, until paid in full, even after maturity and/or after we get a jhldgment egainst you for the amounts due. This will-apply even if the maturity occurs because of acceleration. Watany-time interest as provided for in this paragraph is not permitted?y law, interest shall accrue at the highest rate allowed by applicathle law beginning at that time. 9. YOUR PROMISES ABOUT OUR SECURITY INTEREST: You will not permit anyone other than us to obtain a security interest or other rights in the Vehicle. You will pay all filing fees necessary for us to obtain and maintain our security interest in the Vehicle. You will assist. us • in having our securiy, interest noted on the Certificate of Title to the Vehicle. You will not sell or give away the Vehicle. U someone puts a lien on the Vehicle, you will pay the obligation and clear the lien. 10. YOUR PROMISES ABOUT THE VEHICLE: You will keep the Vehicle in good condition and repair. You will pay all taxes and charges on the Vehicle. You will pay all costs of maintaining the Vehicle. You will not abuse the Vehicle or permit anything to be done to the Vehicle which will reduce its vahie, other than for-normal wear and use. You will not use the Vehicle for illegal purposes or for hire or lease. You will not move the Vehicle from your address shown on: the front of this. Cont(act to a new permanent place of garaging without notifying us in advance. 11. YOUR PROMISES ABOUT INSURANCE: You will. keep the Vehicle insured against fire, theft and collision until all sums due us are paid in full. The insurance coverage must be satisfactory to us and protect your interests and our interests at the time of any.insured loss. The insurance must name us as "loss-payee" on the policy. The insurance must be written by an insurance company qualified to do business in Pennsylvania and licensed to sell insurance in the.state where the Vehicle is permanently garaged. The insurance.pDlicy must provide us with at least ten (10).days prior written notice of any cancellation or reduction in coverage. On request, you shall deliver the policy or other evidence of insurance coverage to us. In the- event of the loss or damage to the Vehicle; you will immediately notify: us in writing and file a proof of loss with the insurer. a..OUR RIGHT TO FILE PROOF OF LOSS: In the event of any loss or damage to the Vehicle, If you fail or refuse to file a claim or proof. of loss with the insurance company, you agree that the Seller, Assignee, any subsequent assignee, or any authorized employee of any ... -... ,"..._n -- V-1- - -A ..s L.......d L 46. 0......"..e...n.nnsnv in un„r nsma sniff srtine 12.-OUR RIGHTS IF YOU -BREAK YOUR PROMISES'ABOUT THE SECURITY INTERE VEHICLrOR INSURANCE: If you fail to keep your ptomises.lo pay filing fees,.taxes, lien; the costs necessary to keep -the Vehicle in good condition and repair, we may advance i money you promised to pay. If you fad to keep your promises about required insurance, may advance money to obtain insurance to cover loss or damage to the Vehicle: We have choice of whether or not to advance any money for these purposes. Such insurance will limited to an amount not greater than you owe on this Contract. THE INSURANCE' PURCHASE MAY BE SIGNIFICANTLY MORE EXPENSIVE AND'PROVIDE YOU LESS COVERa THAN INSURANCE YOU COULD PURCHASE YOURSELF. We will add any money we advance. on your behalf. to the balance on which we imps Finance Charges at the Annual Percentage Rate of this Contract You agree to repay money advanced as we alone may specify: G) Immediately on demand, or (u') along with p monthly payments. If we choose to allow you to repay the money advanced along with r monthly payments, we can choose the amount of these payments-and how long you baw repay. If. any of our rights stated in this paragraph are not permitted by law, we still have other rights mentioned. Our payments on your behat wilhnot•cum your failure to perfc your promises in this Contract. 13. DEFAULT: In this paragraph "You" means the Buyer; Co-Signer and Co-Owner, or any r of them. You will be in "Default" of the.Contract if any one or more of the following thii happen: a. You do not make any paymenton or before it is due; or b. You do not keep any premise. you made in this Contractor c. You do not keep. any promise you made in another: Contract,.Note, Loan or Agreem with Seder or Assignee; or d. You made any untrue statement in the credd'applicotion for this Contract or e. You committed any forgery in connection with, this . Contras or . t You die, are convicted of a crime involving fraud or dishonesty, or are found by ace with jurisdiction to do so to be incapacitated; or. g. You file bankruptcy or insolvency 'proceedings, or anyone files bankruptcy insolvency proceedings against you; or • h:. You take the Vehicle outside the 'United States. or Canada .without our written consent; L You use the Vehichi or allow someone else to'use it in a way that causes it not to covered by your insurance; or j. You do something that causes the Vehicle to be subjgct to confiscation by governm authorities; or k The Vehicle a lost, stolen, destroyed or damaged beyond economical repair, and fixed or found within a reasonable time; or: 1. Another creditor tries to take the Vehicle or your money on depositwith Assignee legal process. 14. OUR RIGHTS IF YOU.ARE IN DEFAULT OF THIS CONTRACT: If you, ark in Defa it of.l Contract, we may enforce our rights according to law: We may also do the things specific mentioned in this Contract We may.do one of these things and at the-same time or later another. Some of the things wemay do.are the following:. . a. ACCELERATION:. We can demand that you pay to. us. the enti*unpaid balance ow on the Contract and all unpaid Finance-Charglis and other moey due! You agree that you pay this money to us in one single payment-immediately upon receiving our demand: . b. REPOSSESSION:_We can repossess the Vehicle, unless prohibited by law. We can this ourselves, have 'a quali ied•person dQ itfQfus, or. have a goverrnnent official (by replei do it.for us You agree that we can. peaeeably.r*ome on to, your property-to do.this. We -m take any otherthings found in the Vehicle, but will return these things to yowif you ask.-If, want these things back; you may reclairn.them within thirty (30) dayS of our mailing yo Notice of Repossession. If you do not reclaim the things found in the.Vehicle within-that tii we may dispose of those.things in the same manner as the motor vehicle. You agree that may use your license plates in repossessing the Vehicle and taking itto a place for storage. c. VOLUNTARY DELIVERY: We can ask you to give us the Vehicle at a reasona convenient place. You agree to give us the Vehicle N we ask d. DELAY IN ENFORCEMENT: We can delay enforcing our rights under this Conti without losing any rights. 15. SOME THINGS YOU SHOULD KNOW IF WE. REPOSSESS THE VEHICLE: If we reposs without using a governmentofficial•(by replevin): a. NOTICE: We will send you a Notice of Repossession toyourlast address we know ab This. Notice will tell you how to buy back (redeem) the. Vehicle. You will NOT have the righ reinstate the Contract. This means you will have to pay the total balance on the Contract; other amounts due. You may. not get the Vehick back by paying delinquent mstillments. I Notice will tell you other information required by law. b. REDEMPTION: You have the-right to buy back (redeem) the Vehicle withiri:15 day the mailing of the Notice anif at any later time before we sell the Vehicle. If you redeem Vehicle, we will deliver the Vehicle to you at a place as -provided by.law, as soon a reasonably possible, but in not more than ten (10) business days of our receipt of the fu required. If you do not redeem, you give up all claim to the Vehicle. c. SALE: If. you don't redeem, we will sell the Vehicle. The money received at sale wil' used to pay costs and expenses you owg, and then to pay the amount you owe.on Contract d. SURPLUS OR DEFICIENCY: If there is money left, we will pay it to the Buyer: If they not enough money from the sale to pay what you owe, Buyer and Co-Signer agree to pay M is still owed to u& e. EXPENSES: You agree to pay the costs of repossessing, storing, repairing, preparing sale and selling the Vehicle as may be allowed by law. These costs will only be due if. 1 nofann avroodt fieoan ih rih nave at tha timer n ronnceoSeinn- and will not, revoke the power you have given us to file a proof of loss. You agree that we may exercise this power for our benefit and not for your benefit, except as provided in this Contract and by law. b. OUR RIGHT TO. ENDORSE INSURANCE CHECKS: You agree that the Seller, Assignee, any subsequent assignee, oran authorized employee of any of them rwe'd may endorse your . name, acting as your agent, to any check, draft or other instrument we receive in payment of an insured loss or return of insuraam premiums. You agree that you do not hate the right to, and will not, revoke the power you have given us to make your endorsement You agree that we may exercise this power for our benefit -and -not for your benefit, except as provided in this Contract and by law. c. USE OF PROCEEDS: We may apply any insurance proceeds we receive to repair or replace the Vehicle if, in our opinion, it is economically -feasible and you are not then in default of this Contract Otherwise, we will apply the insurance proceeds to reduce the unpaid balance due us. After the balance due us is paid, any excess will belong to you. 3. We can prove the costs were paid. 16. HEIRS AND PERSONAL REPRESENTATIVES BOUND: After your death, this Contract be enforceable against your heirs and personal representatives of your estate. 17, GOVERNING LAW.-This Contract is to be interpreted according to the law of Pennsylva I& SEVERABILITY OF PROVISIONS: If for any reason any part of this Contract shall bec illegal, void or unenforceable, that part shall not be a part of this Contract. .19. ASSIGNMENT BY BUYER:' Buyer shag not assign this Contract 20. THERE ARE NO WARRANTIES BY SELLER,' EXPRESSED OR IMPLIED, INCLUDING ' WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPO UNLESS •WE JiIAVE GIVEN. YOU A SEPARATE WRITTEN WARRANTY OR UNLESS .SELI ENTERS INTQ A SERVICE CONTRACT WITH BUYER WITHIN 90 DAYS FROM THE DATE THIS CONTRACT. Buyer's Guide Window Sticker: If the Car which is described on the face of this Contract has a.Buyer's -Guide Window Sticker required by the Fede Trade Commission Used Car Trade 'Regulation Rule, the following notice applies: The information- you see on the window form for this Vehicle is part: of this Contract. Information on the window form overrides a contrary provisions in the contract of sale. NOTICE-ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR. COD, ASSERT AGAINST THE SELLER OF GOODS: OR. SERVICES OBTAINED'PURSUANT HERETO Olt WITH THE PROCEEDS .HEREOF. RECOVEI HEREUNDER BY THE DEBTOR SHALL NOT EXCEED-AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE OF PROPOSED CREDIT INSURANCE The signer(s) of this' Contract hereby take(s) notice that Group Credit Life Insurance coverage or Group Credit Accident and Disability Insurance coverage will be-applicable toAk Contract N so marked on the front of. this Contract, and each such type of coverage will.be written by-the insurance company-named. This insurance, subject to acceptance .by tl insurer, covers only the person or.pefsons signing the request for such insurance. The amount of charge is indicated for each type :of Credit Insurance to be purchased. The tens insurance wig commence as of the dale. the. Indebtedness is incurred and wig expire on the original scheduled maturity date of the indebtedness.. Subject to acceptance by the insun and within 30 days, there will be delivered to the insured debtor(s) a certificate of insurance more fully describing the insurance, In the eventof prepayment of the indebtedness, refund of insurance charges *91 be made when due. NOTICE: SEE OTHER SIDE FOR IMPORTANT INFORMATION. THE PROVISION BELOW IS NOT PART OF THE PENNSYLVANIA MOTOR VEHICLE INSTALLMENT SALE CONTRAdTjETW6EN THL BUYEQ ANOSELLER. ASSIGNMENT o To induce you, the "Assignee" identified on the face of this Contract or as follows. to purchase the within Contract, the Seller hereby Warrants and re iese (Nary, appl federal, state and kical laws and regulations, iricluding,.but not.limitedb Article 2 of tf Pennsylvania Uniform Commercial ode (i13 Pa been made a 21 01 sconformity with all Contra and the Vehkde covered thereby, is absolute, free of all gins, encumbrances and security mtere ye rthith our tide to the C Contra genuine, the signatures thereon are not sts,'and is subject only to the rights of the Buyer as set fort+therein; the Contract forgeries, arose from the sale of the Vehicle therein described, and all parties thereto are of full age and had. capacity to contract; the description the Vehicleand extra equipment-is complete-and correct; the cash downpayment and/or trade-in allowance were actually received and no part thereof consisted. of notes, post-date checks,. other. credit advanced by us to Buyer or rebates or similar payments from us to the Buyer (however manufacturer,rebates may constitute all or•a part of the down warranties and statements therein art but* there is owing thereon the-Amount Financed plus interest at the- Annual Percentage Rate. of,the•Contract set forth therein; we are'duly licens( under the Pennsylvania Motor Vehicie'Sales Finance Act and have duly complied withalltrequirements thereof with respect to the transaction and with the federal truth-in-Lending A and with any other federal or state law, rule or regulation: applicable to this Conlm4t a motor vehicle title certificate showing a lien or encumbrance in favor of Assignee has been or will t applied for promptly; the registration of the Vehicle has not been suspended and the Seller knows of no facts which may resull..in the Pennsylvania Motor Vehicle Financial Responsibilily Act; the Buyer(s) named in the within Contract is jare),.personagy kiv n ?to` the Seller ?t?•same iden cal person under(s) who, signaturels):is (are) effused to. this Contract; and;Seger has no knowledge of facts impairing. the validity or value of the h t reacheU'afany time, Seller shag repurchase said Contract from.Assignee, on demand, and wgi ContracL.tfany. auch warrantiet or representations should t pay therefor, in cash, the `amount owing: thereon, computed asset forth below -and sal remedy shall be cumulative and not exclusive, and shall not affect any other right or remedy that Assignee might have at law-or in refuses tommake any. payment due hereunder on the assertion, either oral or.writien, that the Vehicle is defective, not as represented to tho Buyer by.Seller, o tth that Seller-refusess to honc any warranty or service- agreement of Seger-or manufacturer, Seller agrees-that, on teeing advised by Assiggnneeee of such claim of Buyer,:Seller.wgl repurchase the Contract from Assign and pay Assignee for same immedately in accordance •with• the repurchase terms set forth -below and Seller-Wrther agrees to' hold includin attorne ' f Assignee harmless . from any other claims of Buye g Ys ees, casts and expenses incurred in defending against claims asserted by Buyer and including ctain! s for refund. payments made bjrR'uyerto Assigr? If the $elie cantracts to purch tse'property insurance off behalf. ofthe Boyer, and that Insurance is cancelled by the insurance company. 0=116, itsschedvIed expiration date, Seller will attempt t place comparable coverage with . another insurance company;on behalf of the-Buyer. tf Sellei is unable. to do so. Sager will r and. pay to B er-any additional co*- incurred b the Buyer In obtaining replacement insurance for the unexpired g *1 °y Assignee and accepting period of the original insurance-poesy, By signing and datiag.;the:CoMnsd,"as Seger, delivering the. Contract to'.th payment for it, Seger authorizes the Assignee to act as the Seller's agent for the eorrecti purpose of completing-or rig the identificatloih of the Assignee. in thi Assignment to reflect the tare Assignee who purchased the Contract and/or for the purpose of signing Seller's name to this Asligrhment, without recourse, 9 the Assignment isrdelivere Without the Seller's signature. Assignee may exercise the power even-in'this paragraph for the benefit of the Assignee- and not for the-beihefit of the Seder. Seller does not have the Aghtt and at;roes not to revoke the power given in this paragraph. In the event that Seller Is. required by this Assignment to repurchase the Contrast and/or Vehicle ; Seder shaft pay to Assignee, in cash, the full unpaid balance of the Contract as of thi date of repurchase, plus any then earned Finance Charge and any and all costs and expenses paid or incurred by Assignee in respect thereto, including reasonable attorneys'- fees, is connection with claims by or against any Buyer,,Owner or persons in possession of the Vehicle and/or by or against Seger. For value. received, Seller hereby serfs, assigns and transfers unto the Assignee, ibi successors and assigns, the within Contract, all moneys due and to become .due thereunder, and at right,-title and interest in and to the Vehicle therein. described, with.full power in the Assignee in. its or our name to take such legal or other action -which we might have taken save for tlih Assignmesif. Unless, Seller marks either of the endorsements below, titled "WITH FULL RECOURSE" or "WITH REPURCHASE," Seller'a.asslenment shall, except for the provisions of thr Paragraph filled "Assignment," be without recourse. O. WITH FULL RECDURSE-Seller ligtees thK in addition to the paragraph above tided."Assignment," in the event of default by Buyer in the full payment om the due date thereof of ant Installment payable under the Contract or in the pronhpt performance of. any other :obligation to be performed under the Contract by Buyer, Seller will, on de and by Assignee, forthwitt repurchase the Contract from Assignee for a repurchase price, in cash, computed as set forth above. . O WITH REPURCHASE-Seller agrees.that, In addidon,to the provisions of the paragraph above tided "Assignment," in the eventof any defauft•.by Buyer: which shall entitle Assignee tc repossess the Vehicle, Seger will, if the •Vehfcie.is repossessed by Assignee and delivered to Seller, and without regard to the then condition of the Vehicle; forthwith repurchase-the -Contract and:lhe Vehicle from Assityiee fora repurchase price, in:cash, computed as set lorthabove By signing below, we agree to the terms of the Assignment Seller BY BANCONSWER FM PA 123OC-SIC (2/e4) . Date I 1-1 Assignment of the Motor Vehicle Installment Sales Contract Borrower( s) DARREN REDDY Co-Borrower: CHRISTINE ECK Address of Borrower(s) Date of Contract Dealer Principal balance of Loan Application ID 949 INNSBRUCK DR APT B 20 Jul 2005 Ladd Motors, Inc $22,671.76 143498 HUMMELSTOWN, PA 17036 L Vehicle Securing the Loan Make: 2006 DODGE VIN 2B3KA43G56H178403 Model CHARGER Assignee/Lender Credit Union Name Lebanon Federal Credit Union Credit Union Address 300 Schneider Drive Lebanon, PA 17046 For value received, Member Financed Autos, assigns all its rights, title and interest in the above referenced motor vehicle installment sales contract to Lender: Member Financed Autos Date 03 Aug 2005 By: ' ., 4 SCORPIO ASSET MANAGEMENT, INC. P.O. BOX 61025 • KING OF PRUSSIA, PA 19406 • TELEPHONE 610-337-0947 • FAX 610-337-1839 • TOLL FREE 14888-698.6687 January 13, 2006 Account Number: 35628 Daren J. & Christa Reddy Vehicle: 2006 Dodge Charger 949 Innsbruck Drive, Apt B VIN#: 2B3KA43G5614178406 Hummelstown, PA 17036 Storaee Location: Lien holder Location: Asset Recovery Solutions Lebanon FCU 319 S. Yd Street 300 Schneider Drive Lemoyne, PA 17043 Lebanon, PA 17046 CERTIFIED MAIL: 70041160 00013497 0579 NOTICE OF REPOSSESSION RIGHT TO REDEEM AND NOTICE OF OUR PLAN TO SELL PROPERTY This letter is to notify you, pursuant to law and pursuant to the provisions of your. installment loan note, that your motor vehicle has been repossessed as of the date stated above, because of default under your installment loan contract. We have your 2006 Dodge Charger, VIN# 2133KA43G561-1178406 because you broke promises in your agreement. Under the law, you can get this property back at any time before we sell it by paying us the Total Amount Due noted below (not just the past due payments): COPY Unpaid Balance: Keys: Repossession: Storage (estimated): Auction: Misc. Costs: Total Amount Due: $22,602.70 75.00 350.00 250.00 225.00 250.00 $ 23,752.70 Payment should be to Scorpio Asset Management, Inc. at the address shown above. Payment must be received within 15 days from the date of this notice. If you want us to explain to you in writing how we have figured the amount that you owe us, or if you have any other questions regarding the sale, you may call us at 1-888-698-6687 or write us at the above address and request a written explanation. The cost of storage is $25.00 per day. You have fifteen (15) days to redeem your personal possessions. If they are not picked up after fifteen (15) days, they will be discarded. In the event you do not redeem the repossessed. vehicle by payment of the Total Amount Due within 15 days, we, as agent for Lebanon FCU, intend to sell the vehicle at public or private sale. A sale could include a lease or license. The sale will be held at the Klick Lewis, 800 E. Main Street, Palmyra, PA no sooner then January 28 h, 2005. You may attend the sale and bring bidders if you want, subject to the terms and conditions of the sale as set forth by the seller. The money we get from the sale (after paying our costs) will reduce the amount you owe. If we get less than what you owe, you still owe the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. We are sending this notice to the following other people who have an interest in the 2006 Dodge Charger, VIN# 2BEKA43G56H178406 or who owe money under your agreement. Sincerely, John Gray Supervisor This communication is from a debt collector. Others Receiving Notification: 6LS0 46hE '0000 09'['C fippt-? 1 M N e--I M M N J ¢ O M m zcn(L 00 OWZ N zmo Q Cr Z o wpm w J a M LrJV'7J V ?r v? r r, •W" uo sMQQ •swnwei AWrOOS CE) O o O O ? rn H V)- Co N r-I 0) Ma a Q o to O O O O N r-I I--, --l O) o r-I O C O H H H W z H z x0 H w W H 0 w a N 0 r Ei Q a U W w a w 0 cz 0 o? a ma 1=- O 1-000 0 ? o E rn R S2 N .¢ r--I r-? I r-f 4J O c`- o ui o ,-? N i a o ru C7 N O O O cc CL- ru O m a rn O Q' ti .a Ir M a O V z U (n 0 V) O co 0 r-I W Q•• J ? H J Y M N e-I o M o M 0 M 0) 144 r-i O H rn N r-I O1 M O O N O1 r-I 0 O H H H A w a U w A w w 0 W a O O LO rU_ FT4 July 19`h 2006 Darren J Reddy Christa N Reddy 949 Innsbruck Dr Apt B Hummelstown, PA 17036 SALE OF COLLATERAL STATEMENT Dear Mr. & Mrs. Reddy; Please accept this letter as formal notification that Lebanon Federal Credit Union has sold the collateral held on your installment loan note, the 2006 Dodge Charger, VIN# 2B3KA43G56H178403 for $14,930.00. Fees related to the sale were $0. Thus $14,930.00 has been applied to your loan balance leaving a remaining balance due of $7,667.70. Below is an accounting of the repossession and sale. Payoff Balance Prior to Sale $22,597.70 Repossession Fees 675.00 Keys 0.00 Transport 0.00 Detail/Auction Fees .00 Sub-Total $ 23,272.70 Less Sale Amount 14.93000 Adjusted Sub-Total $ 8,342.70 Collection Costs 0.00 Grand Total Now Due: $ 8,342.70 Please review the above breakdown and contact me if you have any questions. Arraignments for paying the remaining balance must be made within 5 days. By doing this you can avoid further costs for collection. After 5 days the balance will be forwarded for collection and or legal action. Collections costs will begin at that time. Sincerely, UI . Tony Filingeri Collections Manager MAY-30-2008 1:3:07 KNUPP KODAK & I MBLUM 717 2'38 7158 P.08 VERIFICATION 1, __" )_&OAV? ajU?? I vx- V P e) ititle) of Lebanon Federal Credit Union, verify that the statements made in the aforegoing document are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. Leb nor. Feder Credit Union By: Vp" Title: 4(, P Dated: (o 0 S 344511 Reddy TOTAL P.08 N ?AJ W ?r SHERIFF'S RETURN - REGULAR CASE NO: 2008-03572 P COMMONWEALTH OF PENNSYLTANIA: COUNTY OF CUMBERLAND LEBANON FEDERAL CREDIT ?NION VS REDDY T-)ARRFrT T 'PT AT. DENNIS FRY Sheriff or Deputy Sheriff of Cumberland County,Penns*lvania, who being duly sworn according to law, says, the within REDDY CHRISTA N NT & NOTICE was served upon the DEFENDANT , at 1414:00 HOURS, on the 24th day of June 2008 at 332 LIBERTY COURT MECHANICSBURG, PA 17050 CHRISTA REDDY by handing to a true and attested cop of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge n ' / b'1/b . Sworn and Subscibed to before me this of So Answers: 0.00 1D.00 ., .00 gI ?' 1D.00 R. Thomas Kline .00 26.00 06/25/2008 KODAK & IMBLUM By: Y puty She A.D. `"`? --- S i HERIFF' S RETURN - REGULAR CASE NO: 2008-03572 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEBANON FEDERAL CREDIT ION VS REDDY DARREN J ET AL SHAWN HARRISON Sheriff or De ut Sheriff f p y o Cumberland County,Penns lvania, who being duly sworn according to law, says, the within COMPLA NT & NOTICE was served upon REDDY DARREN J the DEFENDANT , at 1420 :00 HOURS, on the 24th day of June 2008 at 1400 BENT CREEK BLVD #207 MECHANICSBURG, PA 17050 by handin to g KELLY BRANSON, GIRLFRIEN D, ADULT IN CHARGE a true and attested cop of COMPLAINT & NOTICE together with and at the same time dir ecting Her attention to the contents thereof. Sheriff's Costs: Docketing 1 Service 1 8.00 0.00 So Answers: r Affidavit S h 00 urc arge 10 .00 R. Thomas Kline ?) le916F 3 .00 .00 06/25/2008 KODAK & IMBL Sworn and Subscibed to .. By: before me this da y eputy Sheriff of A. D . LEBANON FEDERAL CREDIT UNION Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-03572 CIVIL DARREN J. REDDY and CMUSTA. N. REDDY CIVIL ACTION -LAW Defendants TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT MGMENT Please enter judgment in favor of Plaintiff and against Defendant(s) DARREN J. REDDY and CHRISTA. N. REDDY, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $10,011.24 Interest at the rate of 9.49% per annum from August 19, 2006 $1,860.51 Total = $11,871.75 I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice is attached. KODK&DO By A , .C. ?._._.. Robert D. Kodak, Attorney for Plaintiff DATED. 81 t1/o8 Judgment entered and damages assessed as above. Pro onotary 1- 7 LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION Robert D. Kodak 407 NORTH FRONT STREET Gary J. Imblum POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 www.kodak-imblum.com July 18, 2008 Telephone 717.238.7152 Facsimile 717.238.7158 DARREN J REDDY FILE P 1400 BENT CREEK BLVD #207 MECHANICSBURG PA 17050 RE: Lebanon Federal Credit Union VS: Darren J. Reddy and Christa N. Reddy Our File No. 34453 No. 2008-03572 Civil, Court of Common Pleas Cumberland County, Pennsylvania Dear Mr. Reddy: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter judgment against you in the amount as set forth in said Complaint. Very truly yours, RDK/bjh enclosure KODAK & IMBLUM, P.C. Robert D. Kodak robert.kodak@kodak-imblum.com THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. cc CARL SUCCA PRES COMMERCIAL ACCEPTANCE CO PO BOX 3268 SHIREMANSTOWN PA 17011 339413 LEBANON FEDERAL CREDIT UNION Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-03572 CIVIL DARREN J. REDDY and CHRISTA. N. REDDY CIVIL ACTION -LAW Defendants FILE 60"OPY IWORTANT NOTICE TO: DARREN J. REDDY, Defendant(s) DATE OF NOTICE: July 18, 2008 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 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 A: DARREN J. REDDY, Defendido FECHA DEL AVISO: July 18, 2008 AVISO E%IPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION Robert D. Kodak 407 NORTH FRONT STREET Gary J. Imblum POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 www.kodak-imblum.com July 18, 2008 CHRISTA N REDDY 332 LIBERTY COURT MECHANICSBURG PA 17050 RE: Lebanon Federal Credit Union Telephone 717.238.7152 Facsimile 717.238.7158 FILE COY VS: Darren J. Reddy and Christa N. Reddy Our File No. 34453 No. 2008-03572 Civil, Court of Common Pleas Cumberland County, Pennsylvania Dear Ms. Reddy: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, RDK/ bjh enclosure KODAK & IMBLUM, P.C. Robert D. Kodak robert.kodak@kodak-imblum.com THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. cc CARL SUCCA PRES COMMERCIAL ACCEPTANCE CO PO BOX 3268 SHIREMANSTOWN PA 17011 339413 LEBANON FEDERAL CREDIT UNION Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-03572 CIVIL DARREN J. REDDY and CHRISTA N. REDDY CIVIL ACTION -LAW Defendants E%IPORTANT NOTICE FILE Or TO: CHRISTA N. REDDY, Defendant(s) DATE OF NOTICE: July 18, 2008 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 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. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 A: CHRISTA N. REDDY Defendido FECHA DEL AVISO: July 18, 2008 AVISO RA PORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 rnrra ? n rte' c? LEBANON FEDERAL CREDIT UNION: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. DARREN J. REDDY and CHRISTA N. REDDY Defendants : NO. 2008-03572 CIVIL : CIVIL ACTION -LAW TO: DARREN L REDDY, Defendant(s) You are hereby notified that on I ( , 204 the following (judgment) has been entered against you in the Bove-captioned case. Jndgment nird in the amount of $"11,871.75. DATE: Pr onotary I hereby certify that the name and address of the proper person(s) to receive this notice is: DARKEN J REDDY 1400 BENT CREEK BLVD #207 MECHANICSBURG PA 17050 LEBANON FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. D.ARREN J. REDDY and CBRISTA N. REDDY Defendants : NO. 2008-03572 CIVIL : CIVIL ACTION -LAW TO: CI-IRiSr. N. REDDY? Defendant(s) You are hereby notified that on Au4 . I i , 20.4 the following (judgment) has been entered against you in the above-captioned case. b dgm-ni at"ed in the amount of $11,$71.75. DATE: thonota I hereby certify that the name and address of the proper person(s) to receive this notice is: CHRISTA N. REDDY 332 LIBERTY COURT MECHANIC sBURG PA 17050 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 LEBANON FEDERAL CREDIT UNION Plaintiff Vs DARREN J. REDDY 1400 Bent Creek Blvd #207 Mechanicsburg, PA 17050 AND CHRISTA N. REDDY 332 Liberty Court Mechanicsburg PA 17050 DEFENDANT(S) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Writ No. Term 20 No. 08-3572 Term 20 08 Amount Due 8/11/08 jdmt $ 11,871.75 Interest from 8/11/08-9/9/08 (3.13 per diem) $ 90.77 Atty's Commission $ 593.59 Costs (to be determined) $ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania (2) against DARREN J. REDDY and CHRISTA N. REDDY (3) and against e en ants ; arnis ee s , (4) and index this writ (a) against DARREN J. REDDY and CHRISTA N. REDDY Defendant(s) and (b) against arnis ee s , as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY INCLUDING BUT NOT LIMITED TO, FURNITURE, OFFICE EQUIPMENT, JEWELRY, SUPPLIES, ELECTRONICS, LAWN AND GARDEN EQUIPMENT, ETC. (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 9/9/08 Attorney For Plaintiff(s) (a)bOl£ a1nd aaS pansap si suapuad sg a se 9uixapui put pagaepe sI aagsiun9 agl,lo aweu aql ui ,C odoid leaiii ?Iuo polaldwoa aq plnogs (q)(b) gdT3Awvd (q)b0l £ a1n21 aaS 'titlouoglad aql ? q ?.lunoo legl ui asmoo 3o st pannbaj si 9uixapu! Clunoa ragiout of sanssi jwm aql uagM '(t)bOI £ a1nd ? q paziioglnt su palisap s! `aoueinssi }o ,Clunoa aqi ui suognaoxa agl3o 9u)xapui j! Xluo palaldmoa aq plnogs (u)(},) gdei9Eltd (lum aql ui papnlom aq of s1 aagsimfl pawtu t ul ?juo palaldwoa oq plnogs anogt) (£) gdej9taed panssl goigm ui flunoo oql;o jjuags aql of hluo paloamp aq , Pw luaw9pnl pataa3sutu t uo panssi lum t (a)£o 1 £ alnN iapufl palvoipu! aq plnogs f)unoa aql `(q)£Ol £ aln d 4q pazpoglnu su rjunoa tagloue;o 33PNs agl of palaanp sl uim aql uagm (1) gdeAmd iapurl MON 0 N f-? oD O O N v E-• 0 Z R, 01 W U rs.; z z W W (? Q Q Q W ?z Z ? U Q 44- Su cn o 00 rD r? W W 0 w W d w WI 8 b 0 v 0 ra -ZI ca go -?L 00 POD - CA 0Ul00ID ... O00p0ID .r rn cn --c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3572 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LEBANON FEDERAL CREDIT UNION, Plaintiff (s) From DARREN J. REDDY,1400 Bent Creek Blvd #207, Mechanicsburg, PA 17050 and CHRISTA N. REDDY, 332 Liberty Court, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of the defendants at the above address in Cumberland County including but not limited to, furniture, office equipment, jewelry, supplies, electronics, lawn and garden equipment, etc.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,871.75 L.L. $.50 Interest from 8/11/08 - 9/09/08 ($3.13 per diem) -- $90.77 Atty's Comm $593.59 % Due Prothy $2.00 Atty Paid $183.00 Plaintiff Paid Date: 9/11/08 (Seal) REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: KODAK & IMBLUM PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 Other Coststo be determined Curtit R. Lon ono By: Deputy R. Thomas iKline, Sheriff, who being duly sworn according to law, states this O Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Advance Costs. 150.00 Sheriff's Costs. 71.79 Docketing 18.00 78.21 Poundage 1.41 Law Library Prothonotary Mileage Surcharge Levy Postage Garnishee .50 2.00 9.00 40.00 88 71.79 ? 4 ?a z?o 4 '- Refunded on 05/27/09 So Answers, R. T omas Kline, Sherif By Sharon R. Lantz U? 0 w :7z -(70 c3:: r. .J ? `s ?YYT `r ? '0 N 1 2 4©3,z- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3572 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LEBANON FEDERAL CREDIT UNION, Plaintiff (s) From DARREN J. REDDY,1400 Bent Creek Blvd #207, Mechanicsburg, PA 17050 and CHRISTA N. REDDY, 332 Liberty Court, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of the defendants at the above address in Cumberland County including but not limited to, furniture, office equipment, jewelry, supplies, electronics, lawn and garden equipment, etc.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,871.75 L.L. $.50 Interest from 8/11/08 - 9/09/08 ($3.13 per diem) -- $90.77 Atty's Comm $593.59 % Due Prothy $2.00 Atty Paid $183.00 Plaintiff Paid Date: 9/11/08 (Seal) REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: KODAK & IMBLUM PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 Other Coststo be determined CurA R. Long, P By: Deputy PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 LEBANON FEDERAL CREDIT UNION Plaintiff Vs DARREN J. REDDY and CHRISTA N. REDDY 152 WEST HILLS DRIVE WILLIAMSPORT PA 17701 DEFENDANT(S) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Writ No. Term 20 No. 2008-3572 Term 20 08 Amount Due 8/11/08 jdmt ............. $ 11,871.75 Interest from jdmt -4/14/10 $1.95 per diem .............. $ 1,191.45 Attv's Commission 5%?statutorv rate .......... $ 593.59 Costs (to be determined) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of LYCOMING County, Pennsylvania (2) against CHRISTA N. REDDY, De end ants ; (3) and against arnis ee s (4) and index this writ (a) against CHRISTA N. REDDY Defendant(s) and (b) against arnis ee s as a hs pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN LYOMING COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC., (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 4/14/10 Attorney For Plaintiff(s) ??-- $ 00 00 0 0 o c? ? 03 o La ? ? D d i d 171 m r r7l m m 2 m d r d Y d n n Z y Z NOI I -Tt C:, .., ? - Imo. _ ? n N 1 m T ? Z m d ? a J r-? m fJ Z ? O t? Z ° x Under paragraph ( I 1 when the writ is directed to the sheriffof another counh as authorized by RUIe? 10;(11). the counts should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment i mn he directed onh to the sheriff ofthe counts in which issued - Paragraph (1) (ahoce should be completed onh in a named garnishee is to he included in the svrh)- Paragraph (4)(a) should be completed onk if indesing ofthe eeecutions in the COM h' of isairmcc. IS desired as authorised by Rule ,104(a). When the writ issues to another count indexing is required as of course in that count by the pnithonotan Sec Rule ? 10 (h) Paragraph (4)(h) should be completed onh if real propem in the name of the garnishee is attached and indc\ing as a his pendens is desired. Sec Rule ',104(c) _ C